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 .
This Office Action is in response to the Applicant’s Amendment filed December 21, 2025. Claims 1, 3-10, 12-18, 20-23 are pending in this case. Claims 1, 10, 18, and 20 are currently amended. Claims 2, 11, and 19 are currently canceled. Claims 21-23 are newly added.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 December 21, 2025, has been entered.
Response to Arguments
Applicant's arguments filed December 21, 2025, have been fully considered but they are not persuasive.
Applicant argues, regarding the claims, as currently amended, that the claims do not recite an abstract idea.
Examiner respectfully disagrees.
The claim, as a whole, recites a method of organizing human activity. The claimed invention involves validation of a correct execution of an authorization workflow, which is an abstract idea, without substantially more. The mere nominal recitation of technology does not take the claim out of the method of organizing human activity grouping. Thus, the claim recites an abstract idea.
While the claim now recites a trustless orchestrator, the said orchestrator merely amounts to no more than mere instructions to apply the exception using a generic computer component. The said orchestrator merely refines the abstract idea. Under the broadest reasonable interpretation, this is a further refinement of organizing human activities, mental process, mathematical concepts/formulas because these steps further describe the proof of the authorization in furtherance of the abstract idea.
Applicant further argues that the claims, as currently amended, recite “wherein the proof of the authorization workflow execution is provided to the plurality of approvers' entity nodes as a zero-knowledge proof (ZKP), wherein the ZKP hides information of the authorization workflow while providing assurance that the authorization workflow has been executed correctly according to the authorization workflow definition”, and that the ZKP hiding of information and confirming that the said information(workflow has been correctly executed, constitutes a technological improvement.
Examiner respectfully disagrees.
The ZKP provided to the nodes is merely making information confidential while providing proof that the said information is correct, in other words, mere manipulation of data, and as such is an example of a commercial or legal interaction and therefore an abstract idea. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. Though reciting steps performed by a computing device, such limitations are merely an attempt to limit the use of the abstract idea to a particular technological environment, which is insufficient to save a claim [see Ultramercial Inc. v. Hulu LLC (Fed. Cir. 2014)]. Further, the claims do not purport to identify new computer hardware; rather, they assume the availability of generic physical components for input, memory, calculation, comparison, and output [see SmartGene]. 101 covers neither mental processes nor processes that merely invoke a computer and its basic functionality for implementing the performance of mathematical calculations and human-performable processes without specifying even arguably new physical components or specifying processes defined other than by the steps themselves [see SmartGene; see also 2015 Update, section IV p. 7].
Applicant further argues that the authorizing of a transaction, if any, is not a commercial or legal interaction.
Examiner respectfully disagrees.
Note that the claims, in their current version, recite not the authorizing of a transaction, but rather the validation of the correct execution of a workflow.
Applicant further argues, that the claims imply an improvement to the functioning of the computer, even if the said improvement is not set forth in the claims.
Examiner respectfully disagrees.
While claims are interpreted in light of the Specification, during patent examination the pending claims must be interpreted as broadly as their terms reasonably allow. In re Zletz, 13 USPQ2d 1320 (Fed. Cir. 1989). We therefore find that 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. Further, since the applicant's invention can be implemented on a general purpose computer (PgPub, par 57), there has been no improvement to the technical field or to the functioning of a computer.. The claimed invention may have solved the business problem of validating a workflow, but it is not a claimed solution necessarily rooted in computer technology.
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, 3-10, 12-18, and 20-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
Regarding claims 1, 3-10, 12-18, and 20-23 –
Claims 1, 3-10, 12-18, and 20-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
In the instant case, claims 1, 3-9, and 21-23 are directed to a system, while claims 10, and 12-17 are directed to a method, and claims 18 and 20 are directed to a nontransitory computer-readable medium. Therefore, these claims fall within the four statutory categories of invention.
The claims, in their current version, recite validation of a correct execution of an authorization workflow. Specifically, the claims recite receiving a receiving a transaction request, verifying the request, receiving proof of authorization, provide the said proof to approvers, collect approvals, and generate proof of correct execution, which is described a commercial or legal interaction/ transaction and is therefore grouped within the within the “certain methods of organizing human activity” grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test (See MPEP 2106). Accordingly, the claims recite an abstract idea (See pages 7, 10, Alice Corporation Pty. Ltd. v. CLS Bank International, et al., US Supreme Court, No. 13-298, June 19, 2014; MPEP 2106).
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), the additional elements of the claims such as the processor and memory, merely use a computer as a tool to perform an abstract idea. Specifically, the processor and memory, perform the steps or functions of receiving a transaction request, verifying the request, receiving proof of authorization, provide the said proof to approvers, collect approvals, and generate proof of correct execution. The use of a processor/computer as a tool to implement the abstract idea 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)), the claims do not apply or use the abstract idea to effect a particular treatment or prophylaxis for a disease or medical condition (Vanda Memo), the claims do not apply the abstract idea with, or by use of, a particular machine (MPEP 2106.05(b)), the claims do not effect a transformation or reduction of a particular article to a different state or thing (MPEP 2106.05(c)), 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. 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), the additional elements of using processor and memory to perform the steps of validation of a correct execution of an authorization workflow amounts to no more than using a computer to automate and/or implement the abstract idea of validating of a correct execution of an authorization workflow. As discussed above, taking the claim elements separately, the processor and memory perform the steps or functions of receiving a transaction request, verifying the request, receiving proof of authorization, provide the said proof to approvers, collect approvals, and generate proof of correct execution. 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 receiving a transaction request, verifying the request, receiving proof of authorization, provide the said proof to approvers, collect approvals, and generate proof of correct execution. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or 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 3-9, 12-17, and 20-23 further describe the abstract idea of validation of a correct execution of an authorization workflow. 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.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Popov (US 2024/0231849) discloses Workflow authorization management.
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/Cristina Owen Sherr/Examiner, Art Unit 3697
/JOHN W HAYES/Supervisory Patent Examiner, Art Unit 3697