DETAILED ACTION
This is Non-Final Office Action in response to amendment filed on March 26, 2026. Claims 1-20 are pending.
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on March 26, 2026 has been entered.
Examiner remarks
The examiner previously withdrew the § 101 rejection in the Final Office Action mailed December 29, 2025. Upon further consideration and careful reexamination of the claims, the Examiner has determined that the claims are still directed to patent ineligible subject matter. Accordingly, the § 101 rejection is reinstated for the reasons set forth in detail below.
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 an abstract idea without significantly more. The claims recite receiving a client request to perform a read after write operation with respect to an object at an any local quorum consistency level, performing the read operation, generating, and submitting coordinator requests to the multiple centers, and replying a result to client. This judicial exception is not integrated into a practical application because the steps can be performed manually in human mind. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the claim here merely uses the processor as a tool to perform the otherwise mental processes. See October Update at Section I(C)(ii). Thus, the limitations recite concepts that fall into the “mental process” grouping of abstract ideas.
ANALYSIS under Revised Guidance of 2019 PEG:
Statutory Category:
The claims 1-20 are directed to one of the four statutory category (claims 1-8 a method or a process, claims 9-14 an apparatus and claims 15-20 a computer readable storage media).
Claim 1:
Step 2A – Prong 1: Does the claim recite a Judicial Exception? Yes.
The claim recites core steps focuses on identifying a request to perform a read after write operation with respect to an object, iteratively sending requests to different data centers, selecting the first successful response, and returning a result. These steps are essentially directed to request routing, retry logic and decision-making. Such activities fall under certain method of organizing human activity (e.g., managing requests across entities) and mental processes (evaluation, iteration, decision based on response). Although the claim is framed in distributed systems terminology (e.g., “local quorum,” “data centers”), the underlying logic can be characterized as “try sources one by one until one succeeds, the returning the result.”. Accordingly, the claim recite an abstract idea under Step 2A, Prong 1. Thus, the claim recite abstract idea under Step 2A, Prong 1.
Step 2A – Prong 2: Is the abstract idea integrated into a practical application? No.
The claim recites the uses generic components such as a “computing apparatus”, “processors”, and “data centers,” and describes behavior at a high functional level of generality. The claim does not specify how quorum is technically enforced, nor does it recite any new data structure and protocol, or any concrete improvements to latency, fault tolerance, or consistency mechanisms. The recitation of “any-local-quorum” appears technical in nature; however, it is defined functionally (i.e., responding when one data center satisfies a local quorum). There are no implementation details demonstrating a technological improvement. Accordingly, the claim merely applies the abstract idea using generic distributed computing components, rather than integrating it into a practical application.
Step 2B: Is there an inventive concept?. No.
The claim recites additional elements such as processors, distributed databases, multiple data centers, and quorum-based reads. However, these elements are well-understood, routine and conventional in distributed systems (e.g., Cassandra-style quorum reads). The further recitation of iterative retry across data centers, and stop when success occurs, reflects a conventional failover and retry strategy. There is no unconventional architecture, no specific algorithmic improvement, and no technical mechanism beyond functional description. Accordingly, the claim does not amount to significantly more than the judicial exception or abstract idea under Step 2B.
Dependent claim 2 recites “consistency configuration is configured on one or more of a per-request basis, a request type basis, a request context basis” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Dependent claim 3 recites “selecting a first data center of the multiple data centers to send a first coordinator request of the coordinator requests, wherein the first data center is selected based on a load balancing policy, a pseudo-random policy” abstract idea under step 2A(ii). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Dependent claim 4 recites “performing the read operation at the each-quorum consistency level includes generating and submitting a coordinator read request at the local-quorum consistency level to each of the multiple data centers” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Dependent claim 5 recites “…generating and submitting a coordinator request to one data center at a time” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Dependent claim 6 recites “generating and submitting the coordinator request to one data center at a time begins with a first one of the data centers, and only moves to a next one of the data centers upon receiving a reply from a previous one of the data centers” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Dependent claim 7 recites “submitting each of the coordinator requests to a coordinator node in each data center of the multiple data centers” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Dependent claim 8 recites “wherein the coordinator node in each of the multiple data centers only replies to the coordinator request once a quorum of nodes in the data center have responded” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application.
Claim 15:
Step 2A – Prong 1: Does the claim recite a Judicial Exception? Yes.
The claim recites core steps focuses on identifying a request to perform a read operation with respect to an object, iteratively sending requests to different data centers, selecting the first successful response, and returning a result. These steps are essentially directed to request routing, retry logic and decision-making. Such activities fall under certain method of organizing human activity (e.g., managing requests across entities) and mental processes (evaluation, iteration, decision based on response). Although the claim is framed in distributed systems terminology (e.g., “local quorum,” “data centers”), the underlying logic can be characterized as “try sources one by one until one succeeds, the returning the result.”. Accordingly, the claim recite an abstract idea under Step 2A, Prong 1.
Step 2A – Prong 2: Is the abstract ides integrated into a practical application? No.
Claim 15 recites the uses generic components such as a “computing apparatus”, “processors”, and “data centers,” and describes behavior at a high functional level of generality. The claim does not specify how quorum is technically enforced, nor does it recite any new data structure and protocol, or any concrete improvements to latency, fault tolerance, or consistency mechanisms. The recitation of “any-local-quorum” appears technical in nature; however, it is defined functionally (i.e., responding when one data center satisfies a local quorum). There are no implementation details demonstrating a technological improvement. Accordingly, the claim merely applies the abstract idea using generic distributed computing components, rather than integrating it into a practical application.
Step 2B: Is there an inventive concept? No.
The claim recites additional elements such as processors, distributed databases, multiple data centers, and quorum-based reads. However, these elements are well-understood, routine and conventional in distributed systems (e.g., Cassandra-style quorum reads). The further recitation of iterative retry across data centers, and stop when success occurs, reflects a conventional failover and retry strategy. There is no unconventional architecture, no specific algorithmic improvement, and no technical mechanism beyond functional description. Accordingly, the claim does not amount to significantly more than the judicial exception or abstract idea. In order to overcome 101 issues, the claim needs to recite a specific technical mechanism, such as a novel quorum evaluation algorithm, a specific data structure for replica coordination, or a latency-aware routing technique. The claim should further articulate a clear improvement, such as reduced cross data center traffic, improved consistency guarantees, or a fault tolerant coordination mechanism.
Claim 9 is rejected due to the similar analysis of claim 1. Claims 10-14 and 16-20 are similar analysis of claims 2-8 and do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element in claims 10-14 and 16-20 represent a further mental process step. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer component, then it falls within the “mental processes” group of abstract ideas. Each additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. An additional abstract idea (mental process step) is not sufficient to amount to significantly more than the judicial exception. Therefore, claims 1-20 are not patent eligible.
Allowable Subject Matter
Claims 1-20 are allowable over the prior art of record. However, claims 1-20 are rejected under 101 as being directed to a judicial exception. The claims would be allowable if rewritten in a form that overcomes the abstract idea issues.
The following is a statement of reasons for the indication of allowable subject matter:
Regarding claim 1 similar claim 9 and claim 15, the closest art, McHugh et al. (US 8396840 B1) discloses a method of operating a storage application that manages read and write requests (requests of write and read operation, Fig.1 and Fig. 9A, McHugh) associated with a database distributed across multiple replicas in multiple data centers (Fig.1 and col.1, lines 8-19, McHugh, i.e., distributed storage system replicas in multiple storage nodes “data centers”), the method comprising: by one or more computing devices that host the storage application (Fig.1, McHugh, i.e., computing device 102 that host the storage application “replicas”, step 304 of Fig.3 and Fig. 9A): receiving a client request to perform an operation with respect to an object at local consistency level (col.3, line 1 to col.4, line 52, McHugh, i.e., receiving a client request to perform operation with respect to object at consistency level in distributed storage). Watson et al. (US 20210397599 A1) discloses, in response to the client request (¶[0037], Watson), iteratively generating and submitting coordinator requests (¶[0038] to the multiple data centers at a local-quorum consistency level (¶[0013], [0037]-[0038] and [0053], Watson, i.e., continue responding to requests of the data items stored across the different datacenters at a local-quorum consistency level…until the replication operations completed and response to a request “result”), until one of the multiple data centers successfully replies to one of the coordinator requests with a result (¶[0037]-[0041], Watson, i.e., responding to requests of the data items stored across the different datacenters at a local-quorum consistency level until the replication operations completed and response to a request “result”) ; and replying to the client request based on the result provided by the one of the multiple data centers (¶[0013], [0037]-[0038] and [0041], Watson, i.e., the replication operations completed and response to a request “result”). Lebresne (US 20200153900 A1) discloses wherein the any-local-quorum consistency level allows the storage application to respond to the client request upon just one data center responding to the request based on a local quorum (¶[[0020], [0026] and [0031]-[0036], Lebresne, i.e., only process of the validation request of data consistency of the selected node of the most current) and wherein iteratively generating and submitting the coordinator requests to the multiple data centers (¶[[0020], [0026], [0031]-[0036] and [0057], Lebresne) includes, for each iteration, generating and submitting a coordinator request at the local-quorum consistency level to a current data center (¶[[0026], [0028], [0031]-[0036] and [0057], Lebresne), and only proceeding to a next data center if necessitated by a reply from the current data center (¶[[0026], [0028], [0031]-[0036] and [0057], Lebresne). It would have been obvious to a person having ordinary skill in the art before the effective filing date, having the modified Watson and Lebresne before them to local-quorum consistency level of Lebresne into the modified McHugh, as taught by Lebresne. One of ordinary skill in the art would be motivated to integrate managing Lebresne ‘s consistency level into the modified McHugh, with a reasonable expectation of success, in order to improve maintaining data consistency across replicas in a cluster of nodes (¶[0009], Lebresne). However, the prior fails to disclose or suggest “receiving a request to perform a read-after-write operation with respect to an object at an any-local-quorum consistency level, wherein the read-after-write comprises a read operation associated with a previously completed write operation, the client request comprises a request to perform the read operation at the any-local-quorum consistency level, and the previously completed write operation was performed at an each-quorum consistency level…”
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Chen et al. (US 20230062198 A1) disclose data consistency mechanism for hybrid data processing.
Bullowski et al. (US 11003550 B2) disclose methods and systems of operating database management system DBMS in a strong consistency mode.
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/HANH B THAI/Primary Examiner, Art Unit 2163
April 2, 2026