DETAILED ACTION
Status of Claims
This Office Action is in response to Restriction Election on 01/13/2026.
Claims 1-20 are pending of which claims 1-15 or Group I have been elected and claims 16-20 are withdrawn from consideration.
Claims 1-15 are examined hereon.
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 .
Claim Objections
Claim 15 is objected to because the claim recites “wherein the authenticated decrypted communication content is configured to be altered by the authenticated intended user.” However, the claim language contain the same element as claim 11 and is a repeating limitations. Appropriate correction is required.
Allowable Subject Matter
The present invention is directed to access to content. If the rejection rendered hereon are properly overcome, the claims may become patentable as the prior art made of record alone or in combination do not disclose an authentication identifier reader, the authentication identifier reader is configured to decrypt the client identifier from the authentication image when the authentication identifier reader identifies the authentication image, wherein responsive to decryption, a decrypted client identifier is configured to be validated, by the workflow engine, to authenticate the intended user, an authorization for access to the communication content of the communication platform is configured to be transmitted, by the electronic device, to the workflow engine .
Yet even if the missing claimed elements were found in a reasonable number of references, a person of ordinary skill in the art at the time the invention was made would not have been motivated to combine the above missing elements.
Election/Restrictions
Applicant’s election of claims 1-15 of Group I in the reply filed on 01/13/2026 is acknowledged.
Claims 16-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected Group II, there being no allowable generic or linking claim.
Applicant timely traversed the restriction (election) requirement in the reply filed on 01/13/2026.
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 1-8 and 10-15 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Analysis
In the instant case, claims 1-15 are directed to “An authorization system…” (Machine). Therefore, these claims fall within the four statutory categories of invention.
The claims recite an abstract idea of authorizing access to contents, which is an abstract idea. Specifically, but for the additional elements, the claim under its broadest reasonable interpretation recites limitations grouped within the “Certain Methods of Organizing Human Activity,” and “Mathematical Concepts,” grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test since the steps include managing relationships and mathematical calculations (See MPEP 2106.04 & 2106.04(a)). The use of a physical aid to help perform Organized Human Activity and Mathematical Concept steps does not negate the Organized Human Activity and Mathematical Concept nature of the limitations, but simply accounts for variations in memory capacity from one person to another. Further, claims can recite a Methods of Organized Human Activity and Mathematical Concepts even if they are claimed as being performed on a computer. See MPEP § 2106.04(a)(2), subsection III. The claim limitations reciting the abstract idea are grouped within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas as they relate to providing access authorization to contents for specific users based on authentication for the users identification. More specifically, the following non-underlined claim elements recite the abstract idea while the underlined, bolded claim elements recite additional elements according to MPEP 2106.04(a).
Claims 1, An authorization system for data verification and approval in communication platforms, comprising:
a workflow engine comprising: one or more processors; and at least one memory element, the at least one memory element configured to store instructions for controlling the one or more processors, the at least one memory element
retains one or more client identifiers associated with communication content;
a client device, the client device is in communication with the workflow engine over a network, the client device, comprising: one or more processors; at least one memory element, the at least one memory element configured to store instructions for controlling the one or more processors; a display; and a communication platform having a user interface, the communication platform of the client device is configured to
receive the communication content by a computer system,
the computer system having a client identifier of the one or more client identifiers to identify an intended user at which the communication content is created, the communication content is configured to be generated by the computer system and
encrypted by the workflow engine, and wherein responsive to encryption,
encrypted communication content is visually encoded as an authentication image,
the authentication image is displayed within the communication platform of the client device; and
an electronic device, the electronic device is in communication with the workflow engine over the network, the electronic device, comprising: a display having a graphical user interface; one or more processors; at least one memory element, the at least one memory element
stores the client identifier of the computer system; and
an authentication identifier reader, the authentication identifier reader is configured to
decrypt the client identifier from the authentication image when the authentication identifier reader identifies the authentication image,
wherein responsive to decryption, a decrypted client identifier is configured to be validated, by the workflow engine, to authenticate the intended user, and
wherein authenticated decrypted communication content is configured to be displayed on the display of the client device to the authenticated intended user, and
an authorization for access to the communication content of the communication platform is configured to be transmitted, by the electronic device, to the workflow engine.
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP 2106.04(d)), the additional elements are merely used as circuitry and tools to perform an abstract idea and generally link the use of a judicial exception to a particular technological environment. Specifically, these additional elements perform the steps or functions of the abstract idea. Viewed as a whole, the use of the additional elements as a tools to implement the abstract idea and generally linking the use of the abstract idea to a particular technological environment does not integrate the abstract idea into a practical application because it requires no more than a computer performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Additionally, the additional element of “the communication content is configured to be… encrypted by the workflow engine, and wherein responsive to encryption, encrypted communication content is visually encoded… decrypt the client identifier…” also does not improve a computer as it represents the mere performance of a mathematical calculation by a computer. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea.
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP 2106.05), using the additional elements to perform the steps amounts to no more than using a computer or processor to automate and implement the abstract idea. As discussed above, taking the claim elements separately, these additional elements perform the steps or functions of the abstract idea. These functions correspond to the actions required to perform the abstract idea. Viewed as a whole, the combination of elements recited in the claims merely recite the concept of authorizing access to contents. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and implement the abstract idea. Further, the additional element of encrypting, coding and decrypting also does not improve a computer as it represents the mere performance of a mathematical calculation by a computer. The use of a computer or processor to merely automate and implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05 (f) & (h)). Therefore, the claim is not patent eligible.
Dependent claims 2-8 and 10-15 further describe the abstract idea of authorizing access to contents. That is, although claims 2, 4, 5, 7 and 10 recite further functional steps using the additional elements of communication platform of the client device, the workflow engine and the electronic device, each are merely used as circuitry and tools to perform an abstract idea and generally link the use of a judicial exception to a particular technological environment. The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Therefore, the dependent claims are also not patent eligible.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-15 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention.
Claim 1 recites “the communication platform of the client device is configured to receive the communication content by a computer system…” The claim is unclear to one of ordinary skilled because it is unclear if the client device I receiving the content or a computer system. Therefore, the scope of the claim is unclear. (See In re Zletz, 893 F.2d 319, 13 USPQ2d 1320 (Fed. Cir. 1989)).
Claims 2-15 are also rejected as each depend on claim 1.
Claim 1 recites “the communication content of the communication platform.” There is insufficient antecedent basis for this limitation in the claim. Therefore, the scope of the claim is unclear. (See In re Zletz, 893 F.2d 319, 13 USPQ2d 1320 (Fed. Cir. 1989)).
Claims 2-15 are also rejected as each depend on claim 1.
Claim 1 recites “an authorization for access to the communication content of the communication platform is configured to be transmitted, by the electronic device, to the workflow engine.” The claim is unclear to one of ordinary skilled because it is unclear if it is the electronic device or the workflow engine that is getting authorization for access. That is, although the claims provides that an authorization for access to content is transmitted by the electronic device to the workflow engine, it’s unclear what entitie(s) is/are authorized for access to the content. Therefore, the scope of the claim is unclear. (See In re Zletz, 893 F.2d 319, 13 USPQ2d 1320 (Fed. Cir. 1989)).
Claims 2-15 are also rejected as each depend on claim 1.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure:
PGPub Hunt et al. (US 2020/0364319 A1) discloses: An authorization system for data verification and approval in communication platforms, (Figs. 1-2; Par. [0013]) comprising:
a workflow engine (“the content server 102 may embody computing device 202 of FIG. 2.”) comprising: one or more processors; and at least one memory element, the at least one memory element configured to store instructions for controlling the one or more processors, the at least one memory element
retains one or more client identifiers associated with communication content; (Fig. 3; Par. [0059] “At block 304, the user device 104 may provide and/or otherwise transmit the requested information (e.g., information requested in the information request such as user information, licensing information, and/or the like) to the content server 102. For example, user authentication credentials of a user of the user device 104 and/or platform identification information (e.g., MAC address of the network card of the device 104, a secure enclave identifier, geographical location information such as an IP address, etc.) may be transmitted, along with a credit card number, using the secure enclave of the user device 104, to the content server 102 for authentication, validation, processing, and/or the like… In some embodiments, the information requested in the media content request is transmitted to the content server 102 for authentication, validation, and/or the like by the content server 102.”)
a client device (“The user device 104”), the client device is in communication with the workflow engine over a network, the client device, comprising: one or more processors; at least one memory element, the at least one memory element configured to store instructions for controlling the one or more processors; a display; and a communication platform having a user interface, (Pars. [0017]-[0020]) the communication platform of the client device is configured to
receive the communication content by a computer system, (Fig. 3; Par. [0050] “At block 302, the method 300 includes receiving, at a secure enclave of a user device 104 and from a content server 102, encrypted media content.”)
the communication content is configured to be encrypted by the workflow engine, and wherein responsive to encryption, encrypted communication content is visually encoded (“the watermark may be… a visual watermark, a text-based watermark,”) as an authentication image, (Pars. [0060] “the content server 102… may utilize encryption… information to encrypt, decrypt, encode… media content,” [0077] “the content server may retrieve the watermark locally from the secure enclave and encode the watermark into the media content…”)
the authentication image is displayed within the communication platform of the client device; (Fig. 4; Par. [0075] “For example, the secure enclave of the user device 104 may transmit the watermarked media content to a media player application stored outside the secure enclave of the user device 104 for playing. Alternatively, the secure enclave may transmit the watermarked media content to the GPU of the graphics component for decryption and/or rendering as disclosed above. The GPU may then transmit, upon rendering, the media content to an unsecure media player application for facilitation of playing and/or viewing the media content via one or more output devices (e.g., displays).”) and
an electronic device (“secure enclave 219”), the electronic device is in communication with the workflow engine over the network, the electronic device, comprising: a display having a graphical user interface; one or more processors; at least one memory element, the at least one memory element (Fig. 2; Par. [0040])
stores the client identifier of the computer system; (Par. [0042] “Secure storage 223 may be used by the secure enclave to store… user information, account information,”) and
wherein responsive to decryption, a (Par. [0059], [0061] “Upon receipt of the information (e.g., payment information, user information, license information, and/or the like) requested by the information request, the content server 102 may authenticate, validate, and/or otherwise process the information. In some embodiments, processing the information includes verifying, authenticating, validating, confirming, and/or the like. For example, user authentication credentials may be processed by the content server 102 to ensure that the user device 104 (and/or the user associated with the user device 104) is authenticated for receiving the media content.”) and
wherein authenticated decrypted communication content is configured to be displayed on the display of the client device (Fig. 3; Pars. [0065] “At block 308, the user device 104 (e.g., the secure enclave of the user device 104) may use the decryption information (e.g., the first decryption key) to decrypt and/or decode the encrypted media content. Decryption of the encrypted media content may result in generation of decrypted media content.” [0066] “Once the encrypted media content is decrypted by the secure enclave of the user device 104, the decrypted media content is ready to be played, viewed, listened to, and/or otherwise interacted with or consumed by the user associated with the user device 104.”)
to the authenticated intended user, (Par. [0054] “In some embodiments, upon receipt of the encrypted media content, the user device 104 may determine that the encrypted media content is intended for the secure enclave of the user device 104.”) and
With respect to the limitation, “the computer system having a client identifier of the one or more client identifiers to identify an intended user at which the communication content is created, the communication content is configured to be generated by the computer system,” which is intended use/functional language of a computer system and does not have patentable weight as it describes the intended use computer system. However, as the claimed invention is directed to a function of An authorization system… comprising: a workflow engine… a client device… and an electronic device…, the recitation of the intended use/functional language of a computer system of the claimed invention does not serve to differentiate the claims from the prior art. MPEP § 2103 I C states that language that suggests or makes optional but does not require steps to be performed or does not limit a claim to a particular structure does not limit the scope of a claim or claim limitation. An example of such language includes statements of intended use or field of use (MPEP §2103 I C).
PGPub SPEAK et al. (US 2022/0150228 A1) discloses:
an authentication identifier reader, the authentication identifier reader is configured to (Par. [0099] “The scanned session identifier 38 associates the user 24 with the corresponding first device 14,”
when the authentication identifier reader identifies the authentication image, (Figs.; Pars. [0099] “the scanned session identifier 38 associates the user 24 with the corresponding first device 14, the corresponding second device 26 and the associated account provider system 12”)
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/WODAJO GETACHEW/Examiner, Art Unit 3697