DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of Claims
This non-final office action is responsive to Applicant’s submission filed 10/23/2025. Currently, claims 1-20 are pending. No claims have been added, amended and/or cancelled.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., abstract idea) without significantly more.
The claims recite method, system and computer program product for collecting and evaluating payroll data.
Exemplary claim 1 recites in part,
“receive institutional criteria for processing payroll transactions for employees in a first geographic location, wherein the institutional criteria is unique to the first geographic location from a plurality of geographic locations;
identify, from a plurality of data types, a subset of data types that correspond to the institutional criteria;
generate at least one rule that assesses whether the institutional criteria is satisfied;
generate a graphical user interface that receives data input from an employee;
display, from a plurality of data entry fields, solely fields associated with the subset of data types on the graphical user interface in response to determining that the employee is associated with the first geographic location;
in response to receiving at least one entry in the fields associated with the subset of data types, validate the at least one entry using the at least one rule; and
generate, on the graphical user interface, an error message in response to determining that the at least one entry does not satisfy the institutional criteria of the first geographic location.”
The above limitations describe the steps of, 1) collecting user input (institutional criteria and employee data), 2) generating one or more rules associated with the collected information, 3) validating user input (employee data) against the one or more rules, 4) generating a result (error).
The above steps describe the process of collecting and evaluating user input against one or more defined rules. The above limitations, under their broadest reasonable interpretation, encompass "Certain Methods of Organizing Human Activity" (managing personal behavior or relationship or interaction between people – following rules or instructions) enumerated in MPEP 2106.04(a)(2)(II)(C). If a claim limitation, under its broadest reasonable interpretation, covers managing interactions between people, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
The judicial exception is not integrated into a practical application. The cited claim recites additional elements in the form of a computing device (processor and memory) to perform the limitations encompassing the abstract ideas identified above. The computing device represents using a computer as a tool to perform the judicial exception as in MPEP 2106.05(f).
When considered both individually and as a whole, the additional elements do not integrate the abstract idea into a practical application.
The recitation of additional elements is acknowledged as identified above. The discussion with respect to practical application is equally applicable to consideration of whether the additional elements amount to significantly more. The computing device represents using a computer as a tool to perform the judicial exception as in MPEP 2106.05(f).
Therefore, there are no meaningful recitations, considered in combination, that transform the judicial exception into a patent eligible application such that the claim amounts to significantly more than the judicial exception itself.
Accordingly, claim 1 is directed to a judicial exception (i.e., abstract idea) without significantly more.
Claims 12 and 20 recite similar limitations as set forth in claim 1, and therefore are rejected based on similar rationale.
Dependent claims 2-11 and 13-19 recite limitations directed to the abstract idea, and do not integrate the abstract idea into a practical application nor amount to significantly more.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-9 and 12-20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Appl. Pub. No. 2023/0368214 (Suryanarayana et al. – hereinafter Suryanarayana), and further in view of U.S. Patent Appl. Pub. No. 2016/0328799 (Edwards et al. – hereinafter Edwards).
Referring to claim 1, Suryanarayana discloses a system for geography-based data collection and evaluation, comprising:
at least one memory; [See paragraphs 0069, 0078, Fig. 1]
at least one hardware processor coupled with the at least one memory and configured, individually or in combination, to: [See paragraphs 0069, 0078, Fig. 1]
receive institutional criteria for processing payroll transactions for employees in a first geographic location, wherein the institutional criteria is unique to the first geographic location from a plurality of geographic locations; [See paragraphs 0059, 0085, 0086, 0099, 0171]
identify, from a plurality of data types, a subset of data types that correspond to the institutional criteria; [See paragraphs 0169-0174]
generate at least one rule that assesses whether the institutional criteria is satisfied; [See paragraphs 0165, 0175, 0184-0186]
generate, on the graphical user interface, an error message in response to determining that the at least one entry does not satisfy the institutional criteria of the first geographic location; and [See paragraphs 0167, 0168, 0176-0178]
in response to receiving at least one entry in the fields associated with the subset of data types, validate the at least one entry using the at least one rule. [See paragraphs 0045, 0056-0058]
Suryanarayana does not explicitly disclose the limitations:
generate a graphical user interface that receives data input from an employee; and
display, from a plurality of data entry fields, solely fields associated with the subset of data types on the graphical user interface in response to determining that the employee is associated with the first geographic location.
Edwards teaches a system with the limitations:
generate a graphical user interface that receives data input from an employee; and [See paragraphs 0040, 0055, 0074, 0078, Figs. 16-18]
display, from a plurality of data entry fields, solely fields associated with the subset of data types on the graphical user interface in response to determining that the employee is associated with the first geographic location. [See paragraphs 0041, 0072, 0076-0078, Figs. 16-18 – The type of fields displayed are based on user specified geographic location.]
It would have been obvious to one of ordinary skill in the art at the time of the effective filing date of the claimed invention to have modified the system executing the method of Suryanarayana to have incorporated a multi-jurisdiction specific form feature as in Edwards with the motivation of assessing user compliance with one or more rules associated with multiple jurisdictions. [See Edwards paragraphs 0038-0043; Suryaranayana paragraphs 0041-0047]
Referring to claim 2, the combination of Suryanarayana and Edwards discloses the system of claim 1, wherein the at least one hardware processor is configured to determine that the employee is associated with the first geographic location based on the employee indicating, via the graphical user interface, that the employee works in an office located in the first geographic location or that the employee is a resident of the first geographic location. [See Edwards paragraphs 0011-0013, 0051, 0052 – The employee and/or jurisdiction data implies the geographic location of the employee office/residence.]
Referring to claim 3, the combination of Suryanarayana and Edwards discloses the system of claim 1, wherein the institutional criteria include one or more of: name, address, position, salary, a government-issued identifier, an amount of dependents, years of experience, a contract length. [See Suryanarayana paragraphs 0045, 0085, 0174]
Referring to claim 4, the combination of Suryanarayana and Edwards discloses the system of claim 1, wherein the at least one hardware processor is configured to display the fields associated with the subset of data types by: [See Edwards paragraph 0040]
displaying a first data entry field of the fields associated with the subset of data types; [See Edwards paragraphs 0011-0013, 0040, 0083]
receiving an entry in the first data entry field; and [See Edwards paragraphs 0011-0013, 0040, 0083]
displaying one of a second data entry field or a third data entry field based on contents of the entry received. [See Edwards paragraphs 0011-0013, 0040, 0083]
Referring to claim 5, the combination of Suryanarayana and Edwards discloses the system of claim 4, wherein the at least one hardware processor is configured to: display the second data entry field and hide the third data entry field in response to determining that the contents of the entry indicate that a response in the third data entry field is not required in accordance with the institutional criteria. [See Edwards paragraphs 0011-0013, 0040, 0083]
Referring to claim 6, the combination of Suryanarayana and Edwards discloses the system of claim 1, wherein the at least one hardware processor is configured to:
receive different institutional criteria for processing payroll transactions for employees in a second geographic location, wherein the different institutional criteria is unique to the second geographic location from the plurality of geographic locations; [See Suryanarayana paragraphs 0059, 0085, 0086, 0099, 0171]
identify, from the plurality of data types, a different subset of data types that correspond to the different institutional criteria; and [See Suryanarayana paragraphs 0169-0174]
generate at least one other rule that assesses whether the different institutional criteria is satisfied. [See Suryanarayana paragraphs 0165, 0175, 0184-0186]
Referring to claim 7, the combination of Suryanarayana and Edwards discloses the system of claim 6, wherein the at least one hardware processor is further configured to:
generate the graphical user interface that receives data input from an employee, by: [See Edwards paragraphs 0040, 0055, 0074, 0078, Figs. 16-18]
displaying, from the plurality of data entry fields, solely fields associated with the different subset of data types in response to determining that the employee is associated with the second geographic location instead of the first geographic location. [See Edwards paragraphs 0041, 0072, 0076-0078, Figs. 16-18 – The type of fields displayed are based on user specified geographic location.]
Referring to claim 8, the combination of Suryanarayana and Edwards discloses the system of claim 1, wherein the at least one hardware processor is further configured to store the at least one entry in a database of the at least one memory. [See Suryanarayana paragraphs 0162-0164]
Referring to claim 9, the combination of Suryanarayana and Edwards discloses the system of claim 1, wherein a given geographic location is one of a town, a city, a country, and a continent. [See Suryanarayana paragraphs 0059, 0086]
Referring to claims 12-16 and 17-19, they recite similar limitations as set forth in claims 1-5 and 6-8, and therefore are rejected based on similar rationale.
Referring to claim 20, it recites similar limitations as set forth in claim 1, and therefore is rejected based on similar rationale.
Claims 10 and 11 are rejected under 35 U.S.C. 103 as being unpatentable over Suryanarayana in view of Edwards as applied to claim 1 above, and further in view of U.S. Patent Appl. Pub. No. 2020/0118219 (Mauricio).
Referring to claim 10, the combination of Suryanarayana and Edwards discloses the system of claim 1 above. The combination does not explicitly disclose the limitation: wherein the at least one hardware processor is configured to execute a payroll transaction in response to determining that the at least one entry satisfies the institutional criteria of the first geographic location.
Mauricio teaches a system with the limitation: wherein the at least one hardware processor is configured to execute a payroll transaction in response to determining that the at least one entry satisfies the institutional criteria of the first geographic location. [See paragraphs 0031-0033]
It would have been obvious to one of ordinary skill in the art at the time of the effective filing date of the claimed invention to have modified the system executing the method of the combined teachings of Suryanarayana and Edwards to have incorporated a jurisdiction compliance feature as in Mauricio with the motivation of assessing user compliance with one or more rules. [See Mauricio paragraphs 0005, 0006; Suryaranayana paragraphs 0041-0047]
Referring to claim 11, the combination of Suryanarayana, Edwards and Mauricio discloses the system of claim 10, wherein a data type is processed differently in the payroll transaction for the first geographic location than when processed for a second geographic location. [See Mauricio paragraphs 0025, 0031-0033]
Response to Arguments
101 Rejection
Applicant's arguments filed 10/23/2025 with respect to the rejection of claims 1-20 under 35 U.S.C. 101 have been fully considered but they are not persuasive.
In response to Applicant’s arguments, Examiner respectfully disagrees.
As discussed above under section 101, the claimed invention is directed to a judicial exception (i.e., abstract idea) without significantly more.
The claimed invention collects information (institutional criteria) associated with a first geographical location and identifies one or more subset data types corresponding to the collected information. One or more rules are generated to validate whether institutional criteria are satisfied. User input is received via one or more fields displayed within a graphical user interface. The received user input is validated based on the generated one or more rules, and a result is presented to the user.
The claim simply provides a sequence of displayed fields, as well as user inputs, based on one or more rules and received institutional data. The one or more rules are applied to user input within the displayed field(s) in a graphical user interface. The “displaying solely” limits the type of displayed data/fields based on the institutional information. The “generate rule” and “validate using the rule with the GUI error message” simply compares the received information with the defined rule(s) and displays a result. The claim, under broadest reasonable interpretation, collects data (user input) and compares the collected data against one or more defined rules. The claim covers managing interactions between people, which falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. The claim simply uses computer technology (processor and memory) to implement the limitations encompassing the abstract idea. When considered both individually and as a whole, the additional elements do not integrate the abstract idea into a practical application. The claim does not improve the functioning of computer or any other technology or technical field.
Limiting the GUI to displaying subset data based on user input simply limits the type of data displayed which amounts to insignificant extra solution activity (MPEP 2106.05(g)). In addition, using computer technology to automate the limitations encompassing the abstract idea, amounts to using a computer as a tool to perform the judicial exception as in MPEP 2106.05(f). When considered in combination, the additional elements do not transform the judicial exception into a patent eligible application such that the claim amounts to significantly more than the judicial exception itself.
In Example 37, the claim as a whole integrates the mental process into a practical application. Specifically, the additional elements recite a specific manner of automatically displaying icons to the user based on usage which provides a specific improvement over prior systems, resulting in an improved user interface for electronic devices. However, the instant claim limits a GUI to displaying subset data based on received institutional criteria, receives user input and evaluates the received data against one or more defined rules. The claimed invention simply limits the data type displayed on a GUI and uses user defined rules to evaluate data input.
Accordingly, the claims recite an abstract idea, and the additional elements do not integrate the abstract idea into a practical application nor amount to significantly more.
103 Rejections
Applicant’s arguments, see pages 3 & 4, filed 10/23/2025, with respect to the rejection of claims 1-3, 6-14 and 17-20 under 35 U.S.C. § 103 as being unpatentable over Suryanarayana in view of Mauricio; and claims 4-5, 15 and 16 under 35 U.S.C. § 103 as being unpatentable over Suryanarayana in view of Mauricio and further in view of Edwards have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of Suryanarayana, Edwards and Mauricio.
Conclusion
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/OLUSEGUN GOYEA/ Primary Examiner, Art Unit 3627