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
Claims 1, 10, 19, 22, 23, 24, 25, 26 have been amended.
Claims 5, 6, 8, 9, 14, 15, 17, 18 have been cancelled. (NOTE: If a claim is cancelled, it is not necessary to provide the “Cancelled” identifier and the claim with a strikethrough through its entirety.)
No claims have been added.
Priority
Applicant’s claim for the benefit of a prior-filed application under 35 U.S.C. 119(e) or under 35 U.S.C. 120, 121, 365(c), or 386(c) is acknowledged.
Information Disclosure Statement
The listing of references in the specification is not a proper information disclosure statement. 37 CFR 1.98(b) requires a list of all patents, publications, or other information submitted for consideration by the Office, and MPEP § 609.04(a) states, "the list may not be incorporated into the specification but must be submitted in a separate paper." Therefore, unless the references have been cited by the examiner on form PTO-892, they have not been considered.
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 – 4, 7, 10 – 13, 16, 19 – 26 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 land parcel record comprising geocoded information for at least a legal description and deed of a land parcel or a property of a landowner in a municipality;
generating a georeferenced map of the land parcel from the geocoded information, wherein the georeferenced map is formatted using a Geographical Information System;
validating the land parcel record against a geo-spatial description of the land parcel in one or more municipal records against the georeferenced map of the land parcel;
in addition to validating the land parcel record, synchronizing the georeferenced map of the land parcel to be in accordance with one or more municipality records and a municipality layout of land parcels owned by landowners of the municipality
adding the land parcel record and the georeferenced map with other land parcel records of the municipality, wherein the land parcel record includes the georeferenced map of the land parcel; and
transmitting a confirmation of ownership of the land parcel to the landowner
The invention is directed towards the abstract idea of real estate records management, which is further based on the collection and organization of information, as well as collecting and comparing information and, based on a rule(s), identify options, which corresponds to both “Mental Processes” and “Certain Methods of Organizing Human Activities” as it is directed towards steps that can be performed by a human(s), in the human mind, and/or with the aid of pen and paper, e.g., having a user receive a real estate transaction record, validating (comparing) the record against known/stored information, after validating (comparing), updating/synchronizing the information to ensure that copies of the records include the same content, and, based on the validation (comparison), add/store the record with other records and notifying a user confirming ownership of a land parcel.
The limitations of:
receiving a land parcel record comprising geocoded information for at least a legal description and deed of a land parcel or a property of a landowner in a municipality;
generating a georeferenced map of the land parcel from the geocoded information, wherein the georeferenced map is formatted using a Geographical Information System;
validating the land parcel record against a geo-spatial description of the land parcel in one or more municipal records against the georeferenced map of the land parcel;
in addition to validating the land parcel record, synchronizing the georeferenced map of the land parcel to be in accordance with one or more municipality records and a municipality layout of land parcels owned by landowners of the municipality
adding the land parcel record and the georeferenced map with other land parcel records of the municipality, wherein the land parcel record includes the georeferenced map of the land parcel; and
transmitting a confirmation of ownership of the land parcel to the landowner
are processes that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network (and defining how blockchain fundamentally works (see also the definition provided by Papantoniou, which states, “A blockchain is a growing list of records, called blocks, that are linked (chained) using cryptography. Each block contains a cryptographic hash of the previous block, a timestamp, and transaction data (generally represented as a Merkle tree).”)). That is, other than reciting a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network nothing in the claim element precludes the step from practically being performed in the mind. For example, but for the generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network in the context of this claim encompasses a user can receive and validate a land parcel transaction record, after validating (comparing), updating/synchronizing the information to ensure that copies of the records include the same content, store/add the record with other records, and notify another user of the land parcel’s ownership. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network, then it falls within the “Mental Processes” and “Certain Methods of Organizing Human Activities” groupings of abstract ideas. Accordingly, the claims recite an abstract idea.
This judicial exception is not integrated into a practical application. In particular, the claim only recites additional elements – a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network to communicate and store information, as well as performing operations that a human can perform in their mind and/or pen and paper, i.e. collecting, validating (comparing), and organizing information, as well as notifying a user regarding confirmation of land parcel ownership. The generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network in the steps are recited at a high-level of generality (i.e., as a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network can perform the insignificant extra solution steps of receiving and transmitting information (See MPEP 2106.05(g) while also reciting that the a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network are merely being applied to perform the steps that can be performed in the human mind and/or pen and paper; "[use] of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more.” Therefore, according to the MPEP, this is not solely limited to computers but includes other technology that, recited in an equivalent to “apply it,” is a mere instruction to perform the abstract idea on that technology (See MPEP 2106.05(f)) such that it amounts no more than mere instructions to apply the exception using a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network.
Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. 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. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a generic processor executing computer code stored on a computer medium and generic blockchain technology/distributed ledger network to perform the steps of:
receiving a land parcel record comprising geocoded information for at least a legal description and deed of a land parcel or a property of a landowner in a municipality;
generating a georeferenced map of the land parcel from the geocoded information, wherein the georeferenced map is formatted using a Geographical Information System;
validating the land parcel record against a geo-spatial description of the land parcel in one or more municipal records against the georeferenced map of the land parcel;
in addition to validating the land parcel record, synchronizing the georeferenced map of the land parcel to be in accordance with one or more municipality records and a municipality layout of land parcels owned by landowners of the municipality
adding the land parcel record and the georeferenced map with other land parcel records of the municipality, wherein the land parcel record includes the georeferenced map of the land parcel; and
transmitting a confirmation of ownership of the land parcel to the landowner
amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept.
Additionally:
Claim 2 is directed towards reciting generic technology at a high level of generality and applying it to the abstract idea, as well as describing a rule (who/what administers the technology).
Claim 3 is directed towards collecting and organizing information and the recitation of generic technology at a high level of generality and applying it to the abstract idea.
Claim 4 is directed towards reciting generic technology at a high level of generality and applying it to the abstract idea.
Claim 7 is directed toward descriptive subject matter.
Claim 22 – 26 is directed towards reciting generic technology at a high level of generality and applying it to the abstract idea, descriptive subject matter, and subject matter that has already been discussed above, in this case, describing what the contents of a record are intended to include, activities that can be performed by a human with the aid of pen and paper, and generic blockchain and hash technology.
The remaining claims recite similar subject matter that has already been discussed above.
In summary, the dependent claims are simply directed towards providing additional descriptive factors that are considered for managing real estate/land parcel transactions and records. Accordingly, the claims are not patent eligible.
Claim Rejections - 35 USC § 102
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claims 1 – 4, 7, 10 – 13, 16, 19 – 21 are rejected under 35 U.S.C. 102(a)(1)/(a)(2) as being anticipated by Papantoniou et al. (US PGPub 2022/0284432 A1).
In regards to claims 1, 10, 19, Papantoriou discloses (Claim 1) a method comprising; (Claim 10) a system comprising; (Claim 19) a non-transitory, tangible computer readable storage medium having instructions stored thereon that, in response to execution by a computer-based system, cause the computer-based system to perform operations comprising:
(Claim 10) at least one processor of one or more computing devices on a distributed ledger; and
(Claim 10) memory configured to communicate with the at least one processor, wherein the memory stores instructions that, in response to execution by the at least one processor, cause the at least one processor to perform operations comprising
(Fig. 1, 9, 10, 11, 12; ¶ 26, 27, 32 wherein the one or more computing devices comprise distributed nodes of the distributed ledger network):
In regards to:
receiving, by one or more computing devices on a distributed ledger network, a land parcel record comprising geocoded information for at least a legal description and deed of a land parcel or a property of a landowner in a municipality;
generating a georeferenced map of the land parcel from the geocoded information, wherein the georeferenced map is formatted using a Geographical Information System
(¶ 26, 28, 30, 32, 33, 34, 35, 40, 43, 45, 50, 52, 53, 54, 55, 56 wherein the system utilizes blockchain to receive and store land parcel records that comprise geocoded information for a legal description and land parcel or property in a municipality with a georeferenced map of the land parcel; ¶ 28, 30, 40, 46 wherein the georeferenced map is formatted using a Geographical Information System; ¶ 30, 40, 43, 53, 56, 57 wherein the system creates the georeferenced map based on the geocoded information
As a result, the system generates a georeferenced map from the geocoded information using information of the land parcel record and whenever changes are made to the record, the blockchain is updated with a new block that contains the new information, which includes, at least, a georeferenced map that the system can then retrieve so that it can be visualized/displayed to a user on a dashboard.
¶ 28 “The present invention provides a tool for the combination, and integration, of blockchain with GIS. This new GeoBlockchain (“GBC”) tool can be used to support the analysis of spatial temporal trends of blockchain transactions via a geospatially-enabled blockchain. For example, a blockchain application for real estate can provide a protocol that allows for a complete real estate transaction, which offers the same guarantees for both the signatories and for third parties as current procedures.”
¶ 30 “Geographic Information Systems (GIS), also known as spatial information systems, are digital systems for collecting, storing, analyzing, and visualizing spatial data.”
¶ 32 “Blockchain is a way to build trusted data in a distributed, unalterable ledger that records the history of immutable transactions. When a record is submitted to the blockchain it is stored in a distributed network system with multiple ledgers.”
¶ 33 “In example embodiments, the GBC tool of the present invention can be used for cadaster-land ownership and supply chain. A Cadaster is detailed recording of land information in a real estate system, which has comprehensive legal documentation, including the dimensions, and precise location of land parcels. Cadaster systems manage and control land ownership with diagrams, plans, maps, and charts to insure reliable facts about a specific land. This information forms the base attributes of GIS-based Cadaster Land Information Systems.”
¶ 34 “Land Information Systems use cadastral maps to show boundaries and ownership of land pieces and detailed information such as identifying numbers, district names, structure, boundaries, and the area size.”
¶ 40 “The mapping software (e.g., ArcGIS Enterprise) will leverage the spatial information from the blockchain provider, and it will transform, analyze, and visualize data from the blockchain and geospatial clouds in a GeoBlockchain dashboard 112. … Spatial data is the geographic representation of the land property parcel data that is exchanged from the blockchain procedure.”
¶ 52 “Land ownership can be described as parties, rights/restrictions and geometry (spatial extents or geometry).”
¶ 53 “The blockchain transfer document is linked to a layer in a map generated by a mapping program (e.g., Esri’s ArcGIS). A layer is a visualization or representation of data which can be files, databases, webservices, etc. Layers are represented on a map, or mapping application (See FIG. 1, 112 and FIG. 2, 214) through a geospatial process (see FIG. 3, 316). In one embodiment, the layer does not contain the blockchain itself, but rather a link (e.g., an API) to the stored blockchain in a mapping company blockchain server. Access to the map may be provided to the public through a URL available at the country recorder, insurance company, realtors, etc. Upon access of a parcel in a map, the blockchain data will be retrieved from the map server using the link tag in an ownership layer associated with the parcel layer.”
¶ 54 “The geoblockchain layer may be linked to a location in just one layer, or may also be linked to other layers. It may be desirable to exclude thematic layers which may change over time. Thus, many years in the future, when the other layers of the map have changed, the geoblockchain can still be shown to correspond to a basic, rarely changed layer of the map. In one embodiment, multiple blocks of data from different sources are included in the same layer. E.g., that data could be flood plain or flood hazard data from FEMA, a title report from a title company, hazardous waste data, buried fuel, tanks, etc.”
¶ 55 “The GeoBlockchain can combine data from multiple authoritative sources. For example, the flood plain or flood hazard data from FEMA, hazardous waste locations from the EPA, title report from a licensed title insurance company, the license of the title insurance company from a regulator, the zoning map from the city, recorded CCRs from a HOA, etc. could be combined into a GeoBlockchain compilation.”
¶ 56 “This prototype dashboard visualizes the property locations on a map and can answer "where" the transaction occurred and "why" the event happened based on historic transaction events. The "what" can also be provided, indicating the rights conveyed. For example, a zoning map would show restrictions such as RRRs in land (rights, restrictions, responsibilities).”);
validating, by the one or more computing devices using one or more Smart Contracts (SCs), the land parcel record against a geo-spatial description of the land parcel in one or more municipal records against the georeferenced map of the land parcel (¶ 28, 30, 33, 35, 40, 47, 53, 55, 88 wherein the system utilizes smart contracts to validate the land parcel record against geo-spatial description of the land parcel in municipal records, which include a georeferenced map of the land parcel, as discussed above);
after in addition to validating the land parcel record, synchronizing, by the one or more computing processors, the georeferenced map of the land parcel to be in accordance with one or more municipality records and a municipality layout of land parcels owned by landowners of the municipality (¶ 9, 26, 28, 35, 47, 50, 51, 52, 53, 61, 77, 88 wherein the system synchronizes with a municipality after information has been validated. Specifically, the system receives information from the blockchain and validated against municipality records to ensure that the information matches so that a new transaction can be stored with the proper blockchain record, thus, ensuring a proper chain of events for the parcel. Papantoniou discloses that information stored in the blockchain ensures that the information stored therein has been verified/validated, encrypted, and secure, i.e. immutable transactions, so that future transactions, such as a new transaction record stored in a municipality, title company, or etc., can be matched/validated with the blockchain data and updated, i.e. have a new block added to the chain, when a new transaction occurs, e.g., seller signs a transfer deed to the buyer and a copy is provided to the blockchain and links it to the chain of title, thereby ensuring that records are kept together and not mixed up with other records/transactions that do not correspond to the particular parcel/record of interest;
¶ 26, 36, 43, 50, 53, 55, 56 wherein the land parcel record further includes a survey, an abstract of a title of the land parcel, title search results, title insurance, an acquisition date of the land parcel by a current landowner, current owner information for the land parcel, previous owners’ information for the land parcel)
adding, by the one or more computing devices, the land parcel record and the georeferenced map as a block in a distributed ledger of the distributed ledger network with other land parcel records of the municipality, wherein the block is encrypted by hash and linked to a hash of a previous block in the distributed ledger to form a continuous chain of ledgers (¶ 26, 32, 33, 35, 43, 51, 52, 53, 56 wherein land parcel records can be added to the blockchain with other land parcel records of the municipality. As was discussed above, information is updated and synchronized with the blockchain in order to maintain a detailed record of a land parcel, wherein the record includes, inter alia, a georeferenced map of the land parcel. “A blockchain is a growing list of records, called blocks, that are linked (chained) using cryptography. Each block contains a cryptographic hash of the previous block, a timestamp, and transaction data (generally represented as a Merkle tree).” (see also: ¶ 38, 53)
¶ 26, 28, 30, 32, 33, 34, 35, 40, 43, 45, 50, 52, 53, 54, 55, 56 wherein the system utilizes blockchain to receive and store land parcel records that comprise geocoded information for a legal description and land parcel or property in a municipality with a georeferenced map of the land parcel; ¶ 28, 30, 40, 46 wherein the georeferenced map is formatted using a Geographical Information System; ¶ 30, 40, 43, 53, 56, 57 wherein the system creates the georeferenced map based on the geocoded information
As a result, the system generates a georeferenced map from the geocoded information using information of the land parcel record and whenever changes are made to the record, the blockchain is updated with a new block that contains the new information, which includes, at least, a georeferenced map that the system can then retrieve so that it can be visualized/displayed to a user on a dashboard.
As a result, the system generates a georeferenced map from the geocoded information using information of the land parcel record and whenever changes are made to the record, the blockchain is updated with a new block that contains the new information, which includes, at least, a georeferenced map that the system can then retrieve so that it can be visualized/displayed to a user on a dashboard.
¶ 28 “The present invention provides a tool for the combination, and integration, of blockchain with GIS. This new GeoBlockchain (“GBC”) tool can be used to support the analysis of spatial temporal trends of blockchain transactions via a geospatially-enabled blockchain. For example, a blockchain application for real estate can provide a protocol that allows for a complete real estate transaction, which offers the same guarantees for both the signatories and for third parties as current procedures.”
¶ 30 “Geographic Information Systems (GIS), also known as spatial information systems, are digital systems for collecting, storing, analyzing, and visualizing spatial data.”
¶ 32 “Blockchain is a way to build trusted data in a distributed, unalterable ledger that records the history of immutable transactions. When a record is submitted to the blockchain it is stored in a distributed network system with multiple ledgers.”
¶ 33 “In example embodiments, the GBC tool of the present invention can be used for cadaster-land ownership and supply chain. A Cadaster is detailed recording of land information in a real estate system, which has comprehensive legal documentation, including the dimensions, and precise location of land parcels. Cadaster systems manage and control land ownership with diagrams, plans, maps, and charts to insure reliable facts about a specific land. This information forms the base attributes of GIS-based Cadaster Land Information Systems.”
¶ 34 “Land Information Systems use cadastral maps to show boundaries and ownership of land pieces and detailed information such as identifying numbers, district names, structure, boundaries, and the area size.”
¶ 40 “The mapping software (e.g., ArcGIS Enterprise) will leverage the spatial information from the blockchain provider, and it will transform, analyze, and visualize data from the blockchain and geospatial clouds in a GeoBlockchain dashboard 112. … Spatial data is the geographic representation of the land property parcel data that is exchanged from the blockchain procedure.”
¶ 52 “Land ownership can be described as parties, rights/restrictions and geometry (spatial extents or geometry).”
¶ 53 “The blockchain transfer document is linked to a layer in a map generated by a mapping program (e.g., Esri’s ArcGIS). A layer is a visualization or representation of data which can be files, databases, webservices, etc. Layers are represented on a map, or mapping application (See FIG. 1, 112 and FIG. 2, 214) through a geospatial process (see FIG. 3, 316). In one embodiment, the layer does not contain the blockchain itself, but rather a link (e.g., an API) to the stored blockchain in a mapping company blockchain server. Access to the map may be provided to the public through a URL available at the country recorder, insurance company, realtors, etc. Upon access of a parcel in a map, the blockchain data will be retrieved from the map server using the link tag in an ownership layer associated with the parcel layer.”
¶ 54 “The geoblockchain layer may be linked to a location in just one layer, or may also be linked to other layers. It may be desirable to exclude thematic layers which may change over time. Thus, many years in the future, when the other layers of the map have changed, the geoblockchain can still be shown to correspond to a basic, rarely changed layer of the map. In one embodiment, multiple blocks of data from different sources are included in the same layer. E.g., that data could be flood plain or flood hazard data from FEMA, a title report from a title company, hazardous waste data, buried fuel, tanks, etc.”
¶ 55 “The GeoBlockchain can combine data from multiple authoritative sources. For example, the flood plain or flood hazard data from FEMA, hazardous waste locations from the EPA, title report from a licensed title insurance company, the license of the title insurance company from a regulator, the zoning map from the city, recorded CCRs from a HOA, etc. could be combined into a GeoBlockchain compilation.”
¶ 56 “This prototype dashboard visualizes the property locations on a map and can answer "where" the transaction occurred and "why" the event happened based on historic transaction events. The "what" can also be provided, indicating the rights conveyed. For example, a zoning map would show restrictions such as RRRs in land (rights, restrictions, responsibilities).”); and
transmitting, by the one or more computing devices, an electronic confirmation of ownership of the land parcel to the landowner (¶ 30, 32, 43, 52, 53, 58 wherein electronic confirmation of the ownership of the land Is transmitted to associated parties, such as, but not limited to, landowners).
In regards to claims 2, 11, 21, Papantoriou discloses the method of claim 1 (the system of claim 10; the non-transitory, tangible computer readable storage medium of claim 19), wherein the distributed ledger network comprises a permissioned blockchain network, wherein a municipality authority administers the permissioned blockchain network (¶ 9, 28, 35, 51, 53, 61, 77 wherein the distributed ledger network comprises a permissioned blockchain network, wherein a municipality authority administers the permissioned blockchain network).
In regards to claims 3, 12, Papantoriou discloses the method of claim 1 (the system of claim 10), further comprising adding, by the one or more computing devices, a second land parcel record involving a sale of the (Claim 3: land parcel or property to a new landowner; Claim 12: land parcel to a new landowner) as a new block to the distributed ledger, wherein the new block is linked to a hash of the block involving the landowner that owned the land parcel previously (¶ 26, 32, 33, 35, 43, 52, 53, 56 wherein the system manages a plurality of real estate transactions, i.e. adds one, two, or etc. land parcel record transactions, to the blockchain and wherein blocks are linked to a cryptographic hash of the block involving the landowner that owned the land parcel previously).
In regards to claims 4, 13, Papantoriou discloses the method of claim 1 (the system of claim 10), wherein the one or more Smart Contracts in the distributed ledger network is invoked to validate transaction data of a sale of the (Claim 4: land parcel or property; Claim 13: land parcel) and submit a result to the distributed ledger (¶ 28, 30, 33, 35, 40, 47, 53, 55, 88 wherein smart contracts are used to validate transactions and submitted to the blockchain).
In regards to claim 7, Papantoriou discloses the method of claim 1, wherein the land parcel record further includes a survey, an abstract of a title of the land parcel, title search results, title insurance, an acquisition date of the land parcel by a current landowner, current owner information for the land parcel, and previous owners information for the land parcel (¶ 26, 36, 43, 50, 53, 55, 56 wherein the land parcel record further includes a survey, an abstract of a title of the land parcel, title search results, title insurance, an acquisition date of the land parcel by a current landowner, current owner information for the land parcel, previous owners information for the land parcel).
In regards to claim 16, Papantoriou discloses the system of claim 10, wherein the land parcel record further includes an acquisition date of the land parcel by a current landowner, current owner information for the land parcel, or previous owners information for the land parcel, wherein owner information includes outstanding mortgages, unpaid Homeowners Association dues, unpaid property or income tax Liens, mechanic's liens, restrictions, lease, levy, easement, abstract of a title of the land parcel, and title insurance (¶ 26, 36, 43, 50, 53, 55, 56 wherein the land parcel record further includes a survey, an abstract of a title of the land parcel, title search results, title insurance, an acquisition date of the land parcel by a current landowner, current owner information for the land parcel, previous owners information for the land parcel.
Additionally, although many of the descriptive subject matter were found, the Examiner asserts that this was done for the purposes of compact prosecution and not required as the instant limitation is directed towards descriptive subject matter describing information and “written” information found in a record. The Examiner asserts that, in light of MPEP § 2111.04 and § 2111.05, the data identifying the information found in the records and owner information are labels for the information and add little, if anything, to the claimed invention and, thus, does not serve to distinguish over the prior art. Any differences related merely to the meaning and information conveyed through labels, which does not explicitly alter or impact the steps of the claimed invention, does not patentably distinguish the claimed invention from the prior art, in terms of patentability.).
In regards to claim 20, Papantoriou discloses the non-transitory, tangible computer readable storage medium of claim 19, wherein the operations further comprise:
adding a second land parcel record involving a sale of the land parcel to a new landowner as a new block to the distributed ledger, wherein the new block is linked to a hash of the block involving the landowner that owned the land parcel previously (¶ 26, 32, 33, 35, 43, 52, 53, 56 wherein the system manages a plurality of real estate transactions, i.e. adds one, two, or etc. land parcel record transactions, to the blockchain and wherein blocks are linked to a cryptographic),
wherein a smart contract in the distributed ledger network is invoked to validate transaction data of the sale of the land and submit a result to the distributed ledger (¶ 28, 30, 33, 35, 40, 47, 53, 55, 88 wherein smart contracts are used to validate transactions and submitted to the blockchain for the sale of land).
_____________________________________________________________________
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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.
Claims 22 – 26 are rejected under 35 U.S.C. 103 as being unpatentable over Papantoniou et al. (US PGPub 2022/0284432 A1) in view of Osceola County Property Appraiser (Procedure for Splitting or Merging Property), hereinafter referred to as Osceola.
In regards to claims 22, 23, 25, Papantoriou discloses the non-transitory, tangible computer readable storage medium of claim 19 (the method of claim 1; the system of claim 10), wherein the operations further comprise:
adding, as new blocks to the distributed ledger (Claim 23: by the one or more computing devices to the distributed ledger as new blocks), a second land parcel record and a third land parcel record […],
wherein the new blocks comprise a georeferenced map of the second land parcel that is derived from the georeferenced map of the land parcel,
wherein new blocks comprise a georeferenced map of the land parcel that is derived from the georeferenced map of the land parcel,
wherein the second georeferenced map and the third georeferenced map are formatted using the Geographical Information System,
wherein the new blocks are linked to a hash of the block involving the land parcel
(¶ 26, 32, 33, 35, 43, 52, 53, 56 wherein the system manages a plurality of real estate transactions, i.e. adds/updates/etc. one, two, or etc. land parcel record transactions, to the blockchain and wherein blocks are linked to a cryptographic hash of the block involving the landowner that owned the land parcel previously, as a non-limiting example. “A blockchain is a growing list of records, called blocks, that are linked (chained) using cryptography. Each block contains a cryptographic hash of the previous block, a timestamp, and transaction data (generally represented as a Merkle tree).”; ¶ 26, 28, 30, 32, 33, 35, 40, 43, 45, 50, 53, 55 wherein the system utilizes blockchain to receive and store land parcel records that comprise geocoded information for a legal description and land parcel or property in a municipality with a georeferenced map of the land parcel; ¶ 30, 40, 43, 53, 56, 57 wherein the system creates the georeferenced map based on the geocoded information; ¶ 28, 30, 40, 46 wherein the georeferenced map is formatted using a Geographical Information System
As a result, the system generates a georeferenced map from the geocoded information using information of the land parcel record and whenever changes are made to the record, the blockchain is updated with a new block that contains the new information, which includes, at least, a georeferenced map that the system can then retrieve so that it can be visualized/displayed to a user on a dashboard.
¶ 28 “The present invention provides a tool for the combination, and integration, of blockchain with GIS. This new GeoBlockchain (“GBC”) tool can be used to support the analysis of spatial temporal trends of blockchain transactions via a geospatially-enabled blockchain. For example, a blockchain application for real estate can provide a protocol that allows for a complete real estate transaction, which offers the same guarantees for both the signatories and for third parties as current procedures.”
¶ 30 “Geographic Information Systems (GIS), also known as spatial information systems, are digital systems for collecting, storing, analyzing, and visualizing spatial data.”
¶ 32 “Blockchain is a way to build trusted data in a distributed, unalterable ledger that records the history of immutable transactions. When a record is submitted to the blockchain it is stored in a distributed network system with multiple ledgers.”
¶ 33 “In example embodiments, the GBC tool of the present invention can be used for cadaster-land ownership and supply chain. A Cadaster is detailed recording of land information in a real estate system, which has comprehensive legal documentation, including the dimensions, and precise location of land parcels. Cadaster systems manage and control land ownership with diagrams, plans, maps, and charts to insure reliable facts about a specific land. This information forms the base attributes of GIS-based Cadaster Land Information Systems.”
¶ 34 “Land Information Systems use cadastral maps to show boundaries and ownership of land pieces and detailed information such as identifying numbers, district names, structure, boundaries, and the area size.”
¶ 40 “The mapping software (e.g., ArcGIS Enterprise) will leverage the spatial information from the blockchain provider, and it will transform, analyze, and visualize data from the blockchain and geospatial clouds in a GeoBlockchain dashboard 112. … Spatial data is the geographic representation of the land property parcel data that is exchanged from the blockchain procedure.”
¶ 52 “Land ownership can be described as parties, rights/restrictions and geometry (spatial extents or geometry).”
¶ 53 “The blockchain transfer document is linked to a layer in a map generated by a mapping program (e.g., Esri’s ArcGIS). A layer is a visualization or representation of data which can be files, databases, webservices, etc. Layers are represented on a map, or mapping application (See FIG. 1, 112 and FIG. 2, 214) through a geospatial process (see FIG. 3, 316). In one embodiment, the layer does not contain the blockchain itself, but rather a link (e.g., an API) to the stored blockchain in a mapping company blockchain server. Access to the map may be provided to the public through a URL available at the country recorder, insurance company, realtors, etc. Upon access of a parcel in a map, the blockchain data will be retrieved from the map server using the link tag in an ownership layer associated with the parcel layer.”
¶ 54 “The geoblockchain layer may be linked to a location in just one layer, or may also be linked to other layers. It may be desirable to exclude thematic layers which may change over time. Thus, many years in the future, when the other layers of the map have changed, the geoblockchain can still be shown to correspond to a basic, rarely changed layer of the map. In one embodiment, multiple blocks of data from different sources are included in the same layer. E.g., that data could be flood plain or flood hazard data from FEMA, a title report from a title company, hazardous waste data, buried fuel, tanks, etc.”
¶ 55 “The GeoBlockchain can combine data from multiple authoritative sources. For example, the flood plain or flood hazard data from FEMA, hazardous waste locations from the EPA, title report from a licensed title insurance company, the license of the title insurance company from a regulator, the zoning map from the city, recorded CCRs from a HOA, etc. could be combined into a GeoBlockchain compilation.”
¶ 56 “This prototype dashboard visualizes the property locations on a map and can answer "where" the transaction occurred and "why" the event happened based on historic transaction events. The "what" can also be provided, indicating the rights conveyed. For example, a zoning map would show restrictions such as RRRs in land (rights, restrictions, responsibilities).”).
Papantoriou discloses a system and method that utilizes blockchain to store and manage detailed (see, at least, ¶ 33) land parcel records and various types of real estate transaction. Although Papantoriou discloses various types of real estate transactions, Papantoriou fails to explicitly disclose all types of real estate transactions, such as, but not limited to, splitting or merging of land parcels.
To be more specific, Papantoriou fails to explicitly disclose:
adding, as new blocks to the distributed ledger, a second land parcel record and a third land parcel record involving a splitting of the land parcel into a second land parcel and a third land parcel
First, the Examiner asserts that what is included in the record, i.e. splitting or merging of a land parcel, is directed towards descriptive subject matter describing data, in this case, that the record includes information involving the splitting/merging of a land parcel. The claimed invention is not concerned with the actual splitting/merging of a land parcel, but to the description of “printed” subject matter that is intended to describe the contents of the record. Although the Examiner has provided an analysis in view of Osceola, this was not necessary as describing the data that is included in a record is insufficient to differentiate the claimed invention from that of Papantoriou. Nonetheless, in the interest of compact prosecution, the Examiner has provided Osceola to explicitly teach that such records are known and obvious to one of ordinary skill in the art of real estate records management.
Specifically, Osceola teaches that splitting/merging of land parcels is an established type of real estate transaction and one of ordinary skill in the art would have found it obvious that such transactions should be recorded with a local jurisdiction, especially since such transactions and records are used for tax purposes. It would have been obvious to one of ordinary skill in the art to include as many transaction types in the system and method of Papantoriou as this would provide a more complete record of a land parcel, as well as assist users who must have access to their land parcel record for tax purposes and to ensure that parcels meet zoning requirements.
(For support see: Pages 1, 3)
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention blockchain-based land parcel management system and method of Papantoriou with the ability to manage and store information for various real estate transactions, such as, but not limited to, splitting/merging of land parcels, as taught by Osceola, as this would provide a more complete record of a land parcel, as well as assist users who must have access to their land parcel record for tax purposes and to ensure that parcels meet zoning requirements.
In regards to claims 24, 26, Papantoriou discloses the method of claim 1 (the system of claim 10), further comprising:
adding, by the one or more computing devices to the distributed ledger as new blocks, a second land parcel record […],
generating a georeferenced map of the second land parcel […];
wherein the second land parcel record comprises a georeferenced map of the second land parcel,
wherein the third land parcel record comprises geocoded information of the third land parcel in the municipality with the georeferenced map of the third land parcel,
wherein the georeferenced map of the new second land parcel and the georeferenced map of the third land parcel are formatted using the Geographical Information System,
wherein the new block is linked to a hashes of the block involving the land parcel and the third land parcel
(¶ 26, 32, 33, 35, 43, 52, 53, 56 wherein the system manages a plurality of real estate transactions, i.e. adds/updates/etc. one, two, or etc. land parcel record transactions, to the blockchain and wherein blocks are linked to a cryptographic hash of the block involving the landowner that owned the land parcel previously, as a non-limiting example; ¶ 26, 28, 30, 32, 33, 35, 40, 43, 45, 50, 53, 55 wherein the system utilizes blockchain to receive and store land parcel records that comprise geocoded information for a legal description and land parcel or property in a municipality with a georeferenced map of the land parcel; ¶ 30, 40, 43, 53, 56, 57 wherein the system creates the georeferenced map based on the geocoded information; ¶ 28, 30, 40, 46 wherein the georeferenced map is formatted using a Geographical Information System).
Papantoriou discloses a system and method that utilizes blockchain to store and manage detailed (see, at least, ¶ 33) land parcel records and various types of real estate transaction. Although Papantoriou discloses various types of real estate transactions, Papantoriou fails to explicitly disclose all types of real estate transactions, such as, but not limited to, splitting or merging of land parcels.
To be more specific, Papantoriou fails to explicitly disclose:
adding, by the one or more computing devices to the distributed ledger as new blocks, a second land parcel record involving a second parcel that results from a merging of the land parcel into a second land parcel and a third land parcel
generating a georeferenced map of the second land parcel that is derived from the georeferenced map of the land parcel record and a georeferenced map of a third land parcel record
First, the Examiner asserts that what is included in the record, i.e. splitting or merging of a land parcel, is directed towards descriptive subject matter describing data, in this case, that the record includes information involving the splitting/merging of a land parcel. The claimed invention is not concerned with the actual splitting/merging of a land parcel, but to the description of “printed” subject matter that is intended to describe the contents of the record. Although the Examiner has provided an analysis in view of Osceola, this was not necessary as describing the data that is included in a record is insufficient to differentiate the claimed invention from that of Papantoriou. Nonetheless, in the interest of compact prosecution, the Examiner has provided Osceola to explicitly teach that such records are known and obvious to one of ordinary skill in the art of real estate records management.
Specifically, Osceola teaches that splitting/merging of land parcels is an established type of real estate transaction and one of ordinary skill in the art would have found it obvious that such transactions should be recorded with a local jurisdiction, especially since such transactions and records are used for tax purposes. It would have been obvious to one of ordinary skill in the art to include as many transaction types in the system and method of Papantoriou as this would provide a more complete record of a land parcel, as well as assist users who must have access to their land parcel record for tax purposes and to ensure that parcels meet zoning requirements.
(For support see: Pages 1, 3)
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention blockchain-based land parcel management system and method of Papantoriou with the ability to manage and store information for various real estate transactions, such as, but not limited to, splitting/merging of land parcels, as taught by Osceola, as this would provide a more complete record of a land parcel, as well as assist users who must have access to their land parcel record for tax purposes and to ensure that parcels meet zoning requirements.
Response to Arguments
Applicant's arguments filed 3/17/2026 have been fully considered but they are not persuasive.
Information Disclosure Statement
The objection to the IDS has been maintained as an IDS has not been filed to include references disclosed in the specification.
Rejection under 35 USC 101
The rejection under 35 USC 101 has been maintained.
The Examiner asserts that the claimed invention is not deeply rooted in technology, resolving an issue that arose in technology, nor is it improving technology, but is, in fact, directed towards the recitation of generic technology at a high level of generality and applying it to the abstract idea in order to maintain records. That is to say, the claimed invention is directed towards maintaining records and not towards the improvement of GIS or blockchain or resolving an issue that arose in GIS or blockchain. The claimed invention can, indeed, be performed by a human in their mind and/or through the aid of pen and paper as it is directed towards receiving (collecting) and validating (comparing) land records and, if the information is valid (rule), adding (writing) information into a record and transmitting (extra-solution activity) a confirmation (orally/written). The claimed invention is simply reciting a particular type of formatting using generic GIS technology and not directed towards improving GIS technology, resolving an issue that arose in GIS technology, or deeply rooted in GIS technology. Similarly, the claimed invention is simply reciting the use of generic blockchain and smart contract technology to store information for the benefits that blockchain technology provides, i.e. secure and immutable.
Finally, unlike Enfish where the claims were directed to a specific improvement to the computer’s functionality at the time of the invention and where Enfish explicitly defined the specific improvements along with the technical aspects of the improvements to demonstrate the improvements to existing technology, the Examiner asserts that the instant invention does not. In order to determine whether the claimed invention is directed towards an abstract idea and/or that it is “significantly more” than the abstract idea, Alice stated that the following considerations must be taken into account before making this determination. Specifically, in Enfish, LLC v Microsoft Corporation, Fiserv, Inc., Intuit, Inc., Sage Software, Inc., Jack Henry & Associates, Inc. the courts stated the following:
“We do not read Alice to broadly hold that all improvements in computer-related technology are inherently abstract and, therefore, must be considered at step two. Indeed, some improvements in computer-related technology when appropriately claimed are undoubtedly not abstract, such as a chip architecture, an LED display, and the like. Nor do we think that claims directed to software, as opposed to hardware, are inherently abstract and therefore only properly analyzed at the second step of the Alice analysis. Software can make non-abstract improvements to computer technology just as hardware improvements can, and sometimes the improvements can be accomplished through either route. We thus see no reason to conclude that all claims directed to improvements in computer-related technology, including those directed to software, are abstract and necessarily analyzed at the second step of Alice, nor do we believe that Alice so directs. Therefore, we find it relevant to ask whether the claims are directed to an improvement to computer functionality versus being directed to an abstract idea, even at the first step of the Alice analysis.”
“For that reason, the first step in the Alice inquiry in this case asks whether the focus of the claims is on the specific asserted improvement in computer capabilities (i.e., the self-referential table for a computer database) or, instead, on a process that qualifies as an “abstract idea” for which computers are invoked merely as a tool. … In this case, however, the plain focus of the claims is on an improvement to computer functionality itself, not on economic or other tasks for which a computer is used in its ordinary capacity.”
(Page 11)
Enfish provided a background on the state of the art, at the time of the invention, in the technology, namely, with regards to the management of information in a computer database. This served as reference material in order to identify the improvement or, more specifically, establish that the claimed invention of Enfish was deeply rooted in the technology and was seeking to remedy a problem that arose from the technology. That is to say, Enfish provided a background explanation with regards to the state of the art to establish the flaws that arose from data management and demonstrated that the inventive concept of Enfish laid with the improvement of this technology. It was established in Enfish that the claimed invention did not contain an abstract idea because it was not directed towards a fundamental economic practice, a method of organizing human activities, an idea of itself, or mathematical relationships/formulas because the inventive concept was directed towards the improvement of the technology, specifically, i.e. although the invention was directed towards the organization of information the invention of Enfish was not simply relying on or applying generic concepts known in the technical field or describing the use of generic devices and technologies to perform an abstract idea, but was, in fact, directed and seeking to improve upon the technology by addressing issues known in the technology. This was further made evident by the disclosure presented in the specification of Enfish, which the courts stated the following:
“The patents teach that multiple benefits flow from this design. First, the patents disclose an indexing technique that allows for faster searching of data than would be possible with the relational model. See, e.g., ’604 patent, col. 1 ll. 55–59; id. at col. 2 l. 66–col. 3 l. 6. Second, the patents teach that the self-referential model allows for more effective storage of data other than structured text, such as images and unstructured text. See, e.g., ’604 patent, col. 2 ll. 16–22; col. 2 ll. 46–52.”
(Page 7)
“Finally, the patents teach that the self-referential model allows more flexibility in configuring the database. See, e.g., ’604 patent, col. 2 ll. 27–29. In particular, whereas deployment of a relational database often involves extensive modeling and configuration of the various tables and relationships in advance of launching the database, Enfish argues that the self-referential database can be launched without such tasks and instead configured on-the-fly. See Oral Argument at 1:00–2:15 http://oralarguments.cafc.ucsourts.gov/default.aspx?fl=20 15-1244.mp3; see also ’604 patent, col. 7 ll. 10–22. For instance, the database could be launched with no or only minimal column definitions.”
(Page 7)
Here, the claims are not simply directed to any form of storing tabular data, but instead are specifically directed to a self-referential table for a computer database. … (“The present invention improves upon prior art information search and retrieval systems by employing a flexible, selfreferential table to store data.”)
(Pages 14 – 15)
The specification also teaches that the self-referential table functions differently than conventional database structures. According to the specification, traditional databases, such as “those that follow the relational model and those that follow the object oriented model,” ’604 patent, col. 1 ll. 37–40, are inferior to the claimed invention. While “[t]he structural requirements of current databases require a programmer to predefine a structure and subsequent [data] entry must conform to that structure,” id. at col. 2 ll. 10–13, the “database of the present invention does not require a programmer to preconfigure a structure to which a user must adapt data entry.” Id. at col 2 ll. 27–29. Moreover, our conclusion that the claims are directed to an improvement of an existing technology is bolstered by the specification’s teachings that the claimed invention achieves other benefits over conventional databases, such as increased flexibility, faster search times, and smaller memory requirements. See id. at col 2 ll. 23–27; see also Openwave Sys., Inc. v. Apple Inc., 808 F.3d 509, 513–14 (Fed. Cir. 2015) (finding that a specification’s disparagement of the prior art is relevant to determine the scope of the invention).
(Page 15)
In the case of the instant invention, the Examiner asserts that the specification lacks any disclosure of evidence to demonstrate that the invention is seeking to improve upon the technology or, more specifically, that the claimed invention is directed towards addressing and improving upon an issue that arose from the technology, but merely demonstrating that the claimed invention is directed towards the abstract idea and merely applying or utilizing generic computing devices performing their generic functions to carry out the activities in the technical field of real estate records management due to the benefits that computing devices provided, i.e. faster, more efficient, and etc.. The courts further stated:
“The Supreme Court has not established a definitive rule to determine what constitutes an “abstract idea” sufficient to satisfy the first step of the Mayo/Alice inquiry. See id. at 2357. Rather, both this court and the Supreme Court have found it sufficient to compare claims at issue to those claims already found to be directed to an abstract idea in previous cases. “[The Court] need not labor to delimit the precise contours of the ‘abstract ideas’ category in this case. It is enough to recognize that there is no meaningful distinction between the concept of risk hedging in Bilski and the concept of intermediated settlement at issue here.” Alice, 134 S. Ct. at 2357; see also OIP Techs., 788 F.3d at 1362. For instance, fundamental economic and conventional business practices are often found to be abstract ideas, even if performed on a computer. See, e.g., OIP Techs., 788 F.3d at 1362–63.”
(Page 10)
“Moreover, we are not persuaded that the invention’s ability to run on a general-purpose computer dooms the claims. Unlike the claims at issue in Alice or, more recently in Versata Development Group v. SAP America, Inc., 793 F.3d 1306 (Fed. Cir. 2015), which Microsoft alleges to be especially similar to the present case, Appellee’s Br. 18, see also Oral Argument at 15:40–18:15, the claims here are directed to an improvement in the functioning of a computer. In contrast, the claims at issue in Alice and Versata can readily be understood as simply adding conventional computer components to well-known business practices. See Alice, 134 S. Ct. at 2358–60; Versata Dev. Grp., 793 F.3d at 1333–34 (computer performed “purely conventional” steps to carry out claims directed to the “abstract idea of determining a price using organization and product group hierarchies”); see also Mortgage Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d 1314, 1324–25 (Fed. Cir. 2016) (claims attaching generic computer components to perform “anonymous loan shopping” not patent eligible); Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367–69 (Fed. Cir. 2015) (claims adding generic computer components to financial budgeting); OIP Techs., 788 F.3d at 1362–64 (claims implementing offer-based price optimization using conventional computer activities); Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 714–17 (Fed. Cir. 2014) (claims applying an exchange of advertising for copyrighted content to the Internet); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1354–55 (Fed. Cir. 2014) (claims adding generic computer functionality to the formation of guaranteed contractual relationships). And unlike the claims here that are directed to a specific improvement to computer functionality, the patent ineligible claims at issue in other cases recited use of an abstract mathematical formula on any general purpose computer, see Gottschalk v. Benson, 409 U.S. 63, 93 (1972), see also Alice, 134 S. Ct. at 2357–58, or recited a purely conventional computer implementation of a mathematical formula, see Parker v. Flook, 437 U.S. 584, 594 (1978); see also Alice, 134 S. Ct. at 2358, or recited generalized steps to be performed on a computer using conventional computer activity, see Internet Patents, 790 F.3d 1348–49 (claims directed to abstract idea of maintaining computer state without recitation of specific activity used to generate that result), Digitech Image Techs., LLC v. Electrs. For Imaging, Inc., 758 F.3d 1344, 1351 (Fed. Cir. 2014) (claims directed to abstract idea of “organizing information through mathematical correlations” with recitation of only generic gathering and processing activities).”
(Pages 16 – 17)
“In sum, the self-referential table recited in the claims on appeal is a specific type of data structure designed to improve the way a computer stores and retrieves data in memory. The specification’s disparagement of conventional data structures, combined with language describing the “present invention” as including the features that make up a self-referential table, confirm that our characterization of the “invention” for purposes of the § 101 analysis has not been deceived by the “draftsman’s art.” Cf. Alice, 134 S. Ct. at 2360. In other words, we are not faced with a situation where general-purpose computer components are added post-hoc to a fundamental economic practice or mathematical equation. Rather, the claims are directed to a specific implementation of a solution to a problem in the software arts. Accordingly, we find the claims at issue are not directed to an abstract idea.”
(Page 18)
As a result, the Examiner asserts that, in light of the applicant’s specification (see Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343, 1346 (Fed. Cir. 2015); see Genetic Techs. Ltd. v. Merial L.L.C., 2016 WL 1393573, at *5 (Fed. Cir. 2016) (inquiring into “the focus of the claimed advance over the prior art”)), the claimed invention does not lie with the improvement of a technology, identifying and resolving an issue that arose from the technology, or that the claimed invention is “deeply rooted in the technology”, but that the claimed invention is directed towards the abstract idea of real estate records management and merely utilizing generic computing devices and generic blockchain technology (see applicant specification at ¶ 2 – 6, 14, 15, 22, 23, 32) in order to perform the activities in the field of real estate records management. As was found in Alice Corp v CLS Bank, the claims in Alice Corp v CLS Bank also required a computer that processed streams of data, but nonetheless were found to be abstract. There is no “inventive concept” in the claimed invention's use of a general-purpose computing devices and generic blockchain technology to perform activities used in the technical field, in this case, real estate records management.
Consequently, the Examiner asserts that the claimed invention is, in fact, more closely directed related to the decision of, inter alia, TLI Communications, LLC v AV Automotive, LLC, in that the claimed invention is merely relying on the use of a generic computing device and generic blockchain technology to perform the abstract idea of real estate records management. As was done in TLI Communications, the Examiner refers to the specification to determine whether the claimed invention amounts to “significantly more” or whether the claimed invention is directed towards the improvement of the technological arts.
Turning to the specification, the Examiner finds that the invention relies on the use of a general-purpose computer that is being utilized to store, retrieve, and organize information that can be performed using pen and paper (Fig. 6; ¶ 2 – 6, 14, 15, 22, 23, 32 – 36 of the applicant’s specification regarding the description of generic computing devices, generic communication network, and reciting generic blockchain technology and applying it to the abstract idea for the benefits that it provides (e.g., more efficient, secure, and etc.)). The Examiner asserts that, unlike Enfish, whose focus was directed towards improving how a computer can more efficiently store and manage data, the claimed invention is not directed towards improving how the computer manages the information, but merely directed towards communicating and storing information by applying generic blockchain technology. Although the applicant has stated that the invention is supposed to be directed to an improved method of communicating, storing, and managing information, the Examiner asserts that the specification lacks sufficient disclosure or specificity of how this can be done or, more specifically, how the computer can be programmed to achieve this improvement other than simply reciting generic blockchain technology at a high level of generality and applying it to the abstract idea. As a result, the Examiner asserts that the claimed invention is similar to the analysis and decision of Electric Power Group, LLC v. Alstom S.A., where the CAFC stated that, “the claims do not go beyond requiring the collection, analysis, and display of available information in a particular field, stating those functions in general terms, without limiting them to technical means for performing the functions that are arguably an advance over conventional computer and network technology. The claims, defining a desirable information-based result and not limited to inventive means of achieving the result.” Further still, as was further discussed in Electric Power Group, LLC v. Alstom S.A., “there is a critical difference between patenting a particular concrete solution to a problem and attempting to patent the abstract idea of a solution to the problem in general.”
Further, the type of information that is being managed is insufficient to transform an abstract idea into a non-abstract idea or to demonstrate that the invention is “significantly more” than the abstract idea. Similar to Electric Power Group, LLC v. Alstom S.A., the claimed invention is simply limiting the claims to a particular environment and is, without more, insufficient to transform them into a patent-eligible applications of the abstract idea at their core. The Examiner asserts that the claims are directed towards the type of information and selecting information for collection, analysis, and display, which do nothing significant to differentiate a process from ordinary mental processes. The claims to not require a new source or type of information, or new techniques for analyzing it and, accordingly, “do not invoke any assertedly inventive programming”, but “merely require the selection and manipulation of information—to provide a “humanly comprehensible” amount of information useful for users.” The specification does not disclose how the desired result is achieved other than simply providing a high level of explanation and relying on the general use of generic devices and generic blockchain technology, i.e. the claims “do not require any nonconventional computer, network, or display, or even a ‘non-conventional and non-generic arrangement of known, conventional pieces,’ but merely call for performance of the claimed information collection, analysis, and display functions using a generic computing device, display, and network. … Nothing in the claims, understood in light of the specification, requires anything other than off-the-shelf, conventional computer, network, and display technology for gathering, sending, and presenting the desired information. … We have repeatedly held that invocations of computers and networks that are not even arguably invention are ‘insufficient to pass the test of an inventive concept in the application’ of an abstract idea.”
The specification continues on with disclosing how the disclosed generic computing environment and devices are utilized, for their intended purpose, in order to carry out the claimed invention or, more specifically, the abstract idea of real estate records management. It is clear from the applicant’s specification that the “claims here are not directed to a specific improvement to computer functionality. Rather, they are directed to the use of conventional or generic technology in a nascent but known environment, without any claim that the invention reflects an inventive solution to any problem by combining the two.” (Page 8 TLI Communications, LLC v AV Automotive, LLC) Similar to TLI Communications, the Examiner asserts that the instant invention does not describe any new computing device or communication network/infrastructure and “fails to provide any technical details for the tangible components, but instead predominately describes the system and methods in purely functional terms.” (Page 9 TLI Communications, LLC v AV Automotive, LLC) The specification simply describes the components in terms of performing generic computing functions and, accordingly, "”are not directed to a solution to a “technological problem” as was the case in Diamond v Diehr, 450 U.S. 175 (1981). Nor do the claims attempt to solve a ‘challenge particular to the Internet.’ DDR Holdings, LLC v Hotels.com, L.P., 773 F.3d 1245, 1256 – 57 (Fed. Cir. 2014); cf. Intellectual Ventures I, 792 f.3d at 1371 (because the patent claims at issue did not “address problems unique to the Internet,…DDR has no applicability.”) (Page 10 TLI Communications, LLC v AV Automotive, LLC) Such vague, functional descriptions of computing components/environment are insufficient to transform the abstract idea into a patent-eligible invention. (Page 14 TLI Communications, LLC v AV Automotive, LLC)
Instead, the claims, as noted, are simply directed to the abstract idea of real estate records management and applying generic blockchain technology that has been recited at a high level of generality. As a result, the Examiner asserts that the claims fail to recite any element that individually or as an ordered combination transform the abstract idea of real estate records management into a patent eligible application of that idea. Accordingly, the Examiner asserts that the claims’ recitation of generic computing components/environment fail to add an inventive concept sufficient to bring the abstract idea into the realm of patentability.
Additionally, the claimed invention is also directed towards the abstract idea of collecting data, recognizing data, and storing the recognized data in order to perform real estate records management. The Examiner asserts that the concept of data collection, recognition, and storage are activities that can be performed by humans in their mind and/or with the aid of pen and paper. As was already discussed above, the claimed invention is merely utilizing general purpose devices (computing device) to perform the steps of data retrieval, i.e. having a user receive a real estate transaction record, validating (comparing) the record against known/stored information, after validating (comparing), updating/synchronizing the information to ensure that copies of the records include the same content, and, based on the validation (comparison), add/store the record with other records and notifying a user confirming ownership of a land parcel.
Although one may argue that the human mind is unable to process and recognize the electronic stream of data that is being received, transmitted, stored, and etc. by the computing device, the Examiner asserts that this is insufficient to overcoming the rejection under 35 USC 101 (see Content Extraction and Transmission LLC v Wells Fargo Bank, National Association and Cyberfone where the system uses categories to organize, store, and transmit information, which was considered by the courts to be an abstract idea). The claims in Alice Corp v CLS Bank also required a computer that processed streams of data, but nonetheless were found to be abstract. There is no “inventive concept” in the claimed invention's use of a generic computing device and generic blockchain technology to perform activities used in the technical field, in this case, real estate records management. (Content Extraction and Transmission LLC v Wells Fargo Bank, National Association) At most, the claims attempt to limit the abstract idea of recognizing and storing information using the devices to a particular environment. Such a limitation has been held insufficient to save a claim in this context.
Further still, the steps of receiving and transmitting information between the computing device and the storage of the information are merely directed towards the concept of data gathering and transmitting are considered insignificant extra solution activities. Viewed as a whole, these additional claim elements do not provide meaningful limitations to transform the abstract idea into a patent eligible application of the abstract idea such that the claims amount to significantly more than the abstract idea itself.
Rejection under 35 USC 102
The Examiner asserts that the applicant’s arguments are directed towards newly amended limitations and are, therefore, considered moot. However, the Examiner has responded to the newly submitted amendments, which the arguments are directed to, in the rejection above, thereby addressing the applicant’s arguments.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure can be found in the attached PTO-892 Notice of References Cited:
Papantoniou et al. (US PGPub 2026/0022946 A1); Cheng-Shorland et al. (US Patent 12,586,139 B2); Strand (EP 3738094 B1); Agarwal et al. (US PGPub 2024/0037681 A1); Yerli (EP 3754589 A1); Yerli (US PGPub 2026/0044910 A1) – which disclose the use of blockchain technology to manage real estate relation information and transactions
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.
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GERARDO ARAQUE JR
Primary Examiner
Art Unit 3629
/GERARDO ARAQUE JR/Primary Examiner, Art Unit 3629 4/9/2026
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