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 final office action is responsive to Applicant’s submission filed 05/27/2026. Currently, claims 1-20 are pending. Claims 1, 12 and 20 have been amended. No claims have been newly added and/or cancelled.
Allowable Subject Matter
Claims 1-20 are allowed over prior art.
The following is a statement of reasons for the indication of allowable subject matter:
None of the cited and/or relevant prior art, single or in combination, teaches the combined limitations:
“generate at least one rule that assesses whether the institutional criteria is satisfied, wherein the at least one rule specifies one or more attributes of a data value associated with a data type of the subset of data types;
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, wherein one or more data entry fields of the plurality of data entry fields that are not in the subset of data types are suppressed from the graphical user interface; and
in response to receiving at least one entry in the fields associated with the subset of data types cause the thin client application to immediately upload the at least one entry to the user input database, wherein the perpetual validation module detects that the user input database has been updated and begins validation of the at least one entry in real-time in response to detecting the update, the perpetual validation module validating the at least one entry using the at least one rule”,
as recited in claim 1.
Claims 12 and 20 recite similar limitations as set forth in claim 1, and therefore are patentable over prior art.
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, wherein the at least one rules specifies one or more attributes of a data value associated with a data type of the subset of the data types;
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… immediately upload the at least one entry to the user input database, wherein the perpetual validation module detects that the user input database has been updated and begins validation of the at least one entry in real-time in response to detecting the update, the perpetual validation module validating 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 memory (perpetual validation module and data collection module) and hardware processor (remote server) to perform the limitations encompassing the abstract ideas identified above. The additional computer-related elements merely the additional elements a computer as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
In addition, the claim recites the additional feature of “wherein one or more data entry fields of the plurality of data entry fields that are not in the subset of data types are suppressed from the graphical user interface”. Limiting the data types of the data fields based on geographical location is simply an attempt to limit the use of the abstract idea to a particular environment. See MPEP 2106.05(h).
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 additional computer-related elements merely invoke these additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
In addition, the claim recites the additional feature of “wherein one or more data entry fields of the plurality of data entry fields that are not in the subset of data types are suppressed from the graphical user interface”. Limiting the data types of the data fields based on geographical location is simply an attempt to limit the use of the abstract idea to a particular environment. See MPEP 2106.05(h).
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.
Response to Arguments
101 Rejection
Applicant's arguments filed 05/27/2026 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 recited computing architecture comprising a memory for storing user input database and a hardware processor. The recited hardware processor executes a data collection module of the computing device of an employee for collecting user input data and transmitting the information to the user input database. In addition, the hardware processor executes a perpetual validation module accessing user input data and performing validation. The “validation” simply compares data field entry information with user input database information based on defined rules. See Applicant’s filed specification, paragraphs 0044, 0048-0051. The claimed invention simply uses computer technology to automate the limitations encompassing the abstract idea. Thus, the recited computer-related elements merely invoke the additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
In addition, the claim recites the additional feature of “wherein one or more data entry fields of the plurality of data entry fields that are not in the subset of data types are suppressed from the graphical user interface”. Limiting the data types of the data fields based on geographical location is simply an attempt to limit the use of the abstract idea to a particular environment. See MPEP 2106.05(h).
The claims fail to improve the functioning of a computer or other technology or technical field. The claims simply use computer technology to automate the limitations encompassing the abstract idea. The recited computing architecture comprising a memory for storing user input database and a hardware processor. The recited hardware processor executes a data collection module of the computing device of an employee for collecting user input data and transmitting the information to the user input database. In addition, the hardware processor executes a perpetual validation module accessing user input data and performing validation. The GUI simply displays a user interface with one or more data entry field. Limiting the data types of the data fields based on geographical location is simply an attempt to limit the use of the abstract idea to a particular environment. Thus, the recited computer-related elements merely invoke the additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
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. Limiting the data types of the data fields based on geographical location is simply an attempt to limit the use of the abstract idea to a particular environment.
In BASCOM, the court determined that the claimed combination of limitations did not simply recite an instruction to apply the abstract idea of filtering content on the Internet. BASCOM Global Internet Servs. v. AT&T Mobility, LLC, 827 F.3d 1341, 1350, 119 USPQ2d 1236, 1243 (Fed. Cir. 2016). Instead, the claim recited a "technology-based solution" of filtering content on the Internet that overcome the disadvantages of prior art filtering systems. 827 F.3d at 1350-51, 119 USPQ2d at 1243. In BASCOM, the design permitted the invention to have a filtering tool with the benefits of a filter on a local computer and the benefits of a filter on an ISP server. The benefits in BASCOM were possible because of customizable filtering features at specific locations remote from the user. It was held that the claims were a technical improvement over prior art technologies and served to improve the performance of the system itself. In the present case, the additional elements (or combination of elements) amount to no more than mere instructions to apply the judicial exception using a generic computer component. See MPEP 2106.05(f)(2).
In the instant case, the recited computing architecture comprising a memory for storing user input database and a hardware processor. The recited hardware processor executes a data collection module of the computing device of an employee for collecting user input data and transmitting the information to the user input database. In addition, the hardware processor executes a perpetual validation module accessing user input data and performing validation. The claimed invention simply uses computer technology to automate the limitations encompassing the abstract idea. Thus, the recited computer-related elements merely invoke the additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
When considered both individually and as a whole, the additional elements do not integrate the abstract idea into a practical application nor amount to significantly more.
Accordingly, the claimed invention is directed to a judicial exception (i.e., abstract idea) without significantly more.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to OLUSEGUN GOYEA whose telephone number is (571)270-5402. The examiner can normally be reached M-F: 9am-5pm EST.
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/OLUSEGUN GOYEA/Primary Examiner, Art Unit 3627
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