Prosecution Insights
Last updated: October 23, 2026
Application No. 18/611,061

METHODS AND APPARATUS TO TRANSFORM PROCESS CONTROL DATA FOR USE IN A DISTRIBUTED CONTROL SYSTEM

Final Rejection §101§103
Filed
Mar 20, 2024
Priority
Nov 16, 2023 — provisional 63/599,732
Examiner
KOSSEK, MAGDALENA IZABELLA
Art Unit
2117
Tech Center
2100 — Computer Architecture & Software
Assignee
Emerson Electric Co.
OA Round
2 (Final)
71%
Grant Probability
Favorable
3-4
OA Rounds
7m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allowance Rate
12 granted / 17 resolved
+15.6% vs TC avg
Strong +31% interview lift
Without
With
+31.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
24 currently pending
Career history
48
Total Applications
across all art units

Statute-Specific Performance

§101
13.0%
-27.0% vs TC avg
§103
40.0%
+0.0% vs TC avg
§102
26.5%
-13.5% vs TC avg
§112
16.2%
-23.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 17 resolved cases

Office Action

§101 §103
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 action is made final. Claims 1-4, 6-12, and 14-22 filed on 08/27/2026 have been reviewed and considered by this office action. Claims 1, 9, and 17 have been amended. Claims 5 and 13 have been canceled. Claims 21 and 22 have been newly added. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Claims 1, 9, and 17 recite converting the control narrative from a first data format compatible with the programmable logic controller (PLC) to a second data format compatible with a distributed control system (DCS). FIG. 8 goes from generating the control narrative to storing and transmitting the control narrative; it does not show conversion of the control narrative between formats. Therefore, the conversion of the control narrative from a first data format compatible with the PLC to a second data format compatible with the DCS must be shown or the feature canceled from the claims. No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Response to Arguments Applicant’s arguments, filed 08/27/2026, regarding the rejections under 35 U.S.C. §§ 102 and 103 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Regarding the rejections under 35 U.S.C. § 101, Applicant asserts that the claimed invention is not directed to a mental process and constitutes a practical application. Examiner respectfully disagrees. The claims recite identifying a pattern based on PLC instructions and an output condition, comparing the pattern to stored patterns, determining a corresponding control narrative, and converting and transmitting the control narrative. This constitutes an evaluation that can be practically performed in the human mind. Applicant contends that the claims integrate the abstract idea into a practical application because the claims use a configuration graph database storing patterns as graph nodes and convert the control narrative for a DCS. However, the claims analyze data, compute stored information, determine a control narrative, convert the determined information into another data format, and transmit the determined information to a database, but do not recite any action taken based on that result. In particular, the claims do not control the DCS, modify operation of the DCS, or otherwise use the determined control narrative in a manner that improves the functioning of the system. Accordingly, Applicant’s arguments are not persuasive since the claimed invention does not reflect an improvement to a technology, but rather determines and reformats information about a system. Claiming how the determined information is used may be helpful in demonstrating integration into a practical application. Examiner suggests that Applicant amend the claims to direct the language of the limitation “transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS” in claim 1 and similar limitations in claims 9 and 17 to “transmit the control narrative to a second database associated with the DCS; and modify a configuration of the DCS in accordance with the control narrative.” 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, 6-12, and 14-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Step 1: Claims 1-4, 6-12, 14-16, 21, and 22 are directed to a machine or an article of manufacture. Claims 17-20 are directed to a process. With respect to claim 1: 2A Prong 1: The claim recites an abstract idea. Specifically: determine second instructions to control the process control system based on the output condition, the second instructions executable by a programmable logic controller (PLC); (Mental process – determining instructions based on an output condition is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) identify a pattern based on the second instructions and the output condition; (Mental process – identifying a pattern is an observation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) determine a control narrative associated with the process control system when the pattern matches at least one of the stored patterns in the first database, the control narrative corresponding to the at least one of the stored patterns; (Mental process – determining a control narrative when a pattern matches a stored pattern is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: interface circuitry; first instructions; and programmable circuitry to at least one of instantiate or execute the first instructions to: (Mere recitation of a generic computer component – see MPEP § 2106.05(b)(I)) access an output condition associated with a process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) query a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system; (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. (Insignificant extra-solution activity – transmitting a control narrative to a database represents post-solution activity – see MPEP § 2106.05(g)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: interface circuitry; first instructions; and programmable circuitry to at least one of instantiate or execute the first instructions to: (Mere recitation of a generic computer component – see MPEP § 2106.05(b)(I)) access an output condition associated with a process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) query a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system; (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. (Insignificant extra-solution activity – transmitting a control narrative to a database represents post-solution activity – see MPEP § 2106.05(g)) Therefore, the claim is ineligible. With respect to claim 2: 2A Prong 1: The claim recites an abstract idea. Specifically: identifying the pattern based on dependencies between the second output condition, the input data, and the first output condition. (Mental process – identifying a pattern is an observation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the output condition is a first output condition, wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to identify the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the output condition is a first output condition, wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to identify the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) Therefore, the claim is ineligible. With respect to claim 3: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the output condition indicates an operation of a field device of the process control system (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the output condition indicates an operation of a field device of the process control system (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 4: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the first database is a model database associated with an artificial intelligence (AI) model. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the first database is a model database associated with an artificial intelligence (AI) model. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 6: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the second instructions are associated with a graphical programming language. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the second instructions are associated with a graphical programming language. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 7: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the graphical programming language is associated with a ladder diagram. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the graphical programming language is associated with a ladder diagram. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 8: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to access the output condition by accessing the ladder diagram. (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to access the output condition by accessing the ladder diagram. (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) Therefore, the claim is ineligible. With respect to claim 9: 2A Prong 1: The claim recites an abstract idea. Specifically: determine second instructions to control the process control system based on the output condition, the second instructions executable by a programmable logic controller (PLC); (Mental process – determining instructions based on an output condition is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) identify a pattern based on the second instructions and the output condition; (Mental process – identifying a pattern is an observation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) determine a control narrative associated with the process control system when the pattern matches at least one of the stored patterns in the first database, the control narrative corresponding to the at least one of the stored patterns; (Mental process – determining a control narrative when a pattern matches a stored pattern is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: A non-transitory machine readable storage medium comprising first instructions to cause programmable circuitry to at least: (Mere recitation of a generic computer component – see MPEP § 2106.05(b)(I)) access an output condition associated with a process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) query a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system; (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. (Insignificant extra-solution activity – transmitting a control narrative to a database represents post-solution activity – see MPEP § 2106.05(g)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: A non-transitory machine readable storage medium comprising first instructions to cause programmable circuitry to at least: (Mere recitation of a generic computer component – see MPEP § 2106.05(b)(I)) access an output condition associated with a process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) query a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system; (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. (Insignificant extra-solution activity – transmitting a control narrative to a database represents post-solution activity – see MPEP § 2106.05(g)) Therefore, the claim is ineligible. With respect to claim 10: 2A Prong 1: The claim recites an abstract idea. Specifically: identifying the pattern based on dependencies between the second output condition, the input data, and the first output condition. (Mental process – identifying a pattern is an observation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: The non-transitory machine readable storage medium of claim 9, wherein the output condition is a first output condition, wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to identify the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: The non-transitory machine readable storage medium of claim 9, wherein the output condition is a first output condition, wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to identify the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) Therefore, the claim is ineligible. With respect to claim 11: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the output condition indicates an operation of a field device of the process control system. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the output condition indicates an operation of a field device of the process control system. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 12: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the first database is a model database associated with an artificial intelligence (AI) model. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the first database is a model database associated with an artificial intelligence (AI) model. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 14: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the second instructions are associated with a graphical programming language (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the second instructions are associated with a graphical programming language (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 15: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the graphical programming language is associated with a ladder diagram. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the graphical programming language is associated with a ladder diagram. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 16: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to access the output condition by accessing the ladder diagram. (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to access the output condition by accessing the ladder diagram. (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) Therefore, the claim is ineligible. With respect to claim 17: 2A Prong 1: The claim recites an abstract idea. Specifically: determining instructions to control the process control system based on the output condition, the instructions executable by a programmable logic controller (PLC); (Mental process – determining instructions based on an output condition is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) identifying a pattern based on the instructions and the output condition; (Mental process – identifying a pattern is an observation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) determining a control narrative associated with the process control system when the pattern matches at least one of the stored patterns in the first database, the control narrative corresponding to the at least one of the stored patterns; (Mental process – determining a control narrative when a pattern matches a stored pattern is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: accessing an output condition associated with a process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) querying a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) comparing the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system; (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) converting the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) transmitting the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. (Insignificant extra-solution activity – transmitting a control narrative to a database represents post-solution activity – see MPEP § 2106.05(g)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: accessing an output condition associated with a process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) querying a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) comparing the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system; (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) converting the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) transmitting the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. (Insignificant extra-solution activity – transmitting a control narrative to a database represents post-solution activity – see MPEP § 2106.05(g)) Therefore, the claim is ineligible. With respect to claim 18: 2A Prong 1: The claim recites an abstract idea. Specifically: identifying the pattern based on dependencies between the second output condition, the input data, and the first output condition. (Mental process – identifying a pattern is an observation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the output condition is a first output condition, further including identifying the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the output condition is a first output condition, further including identifying the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system; (Insignificant extra-solution activity (selecting a particular data source or type of data to be manipulated) – see MPEP § 2106.05(g)) Therefore, the claim is ineligible. With respect to claim 19: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the first database is a model database associated with an artificial intelligence (AI) model. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the first database is a model database associated with an artificial intelligence (AI) model. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 20: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the instructions are associated with a graphical programming language. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the instructions are associated with a graphical programming language. (Generally linking the use of a judicial exception to a particular technological environment or field of use – see MPEP § 2106.05(h)) Therefore, the claim is ineligible. With respect to claim 21: 2A Prong 2: The additional elements recited in the claim do not integrate the abstract idea into a practical application, individually or in combination. Additional elements: wherein the control narrative includes a human-readable, natural-language textual description of control logic of the process control system. (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) 2B: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Additional elements: wherein the control narrative includes a human-readable, natural-language textual description of control logic of the process control system. (Adding the words “apply it” (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea – see MPEP § 2106.05(f)) Therefore, the claim is ineligible. With respect to claim 22: 2A Prong 1: The claim recites an abstract idea. Specifically: perform a backward slicing process on the second instructions to determine dependencies within the second instructions; (Mental process – performing a backward slicing process is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III))determine the control narrative based on the dependencies and the at least one of the stored patterns in the model database; (Mental process – determining a control narrative based on dependencies and stored patterns is an evaluation that can be practically performed in the human mind, or by a human using a pen and paper as a physical aid – see MPEP § 2106.04(a)(2)(III)) Therefore, the claim is ineligible. 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 (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 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 1-4, 6-12, and 14-22 are rejected under 35 U.S.C. 103 as being unpatentable over Okahara (JP 5762154 B2) (Note: a machine translation is used for mapping, attached to this action), in view of Quiros Araya (US 2023/0004825 A1), and in view of Jetley et al. (US 2022/0091594 A1). Regarding claim 1, Okahara teaches an apparatus comprising: interface circuitry; first instructions; and programmable circuitry to at least one of instantiate or execute the first instructions ([0083]: “the information processing device 100 includes a CPU 911”; [0090]: “the 'information processing method' according to the present invention can be realized by the steps, procedures, and processes shown in the flowcharts”) to: access an output condition associated with a process control system ([0004]: “one might focus on a device where a failure has manifested, search the control program for the LANG (a circuit block in LD language) where this device acts as a coil (output), identify the devices (usually multiple) that act as contacts (input conditions) in that LANG”); determine second instructions to control the process control system based on the output condition, the second instructions executable by a programmable logic controller (PLC) ([0022]: “this control program intermediate code 1010 is a compilation product from the engineering environment and is also the target for download to the PLC device”; [0036]: “the device extraction unit 102 extracts the device from the control program intermediate code 1010… the dependency extraction unit 103 extracts dependencies from the control program intermediate code 1010”); identify a pattern based on the second instructions and the output condition ([0024]: “The dependency extraction unit 103 extracts descriptions of dependencies between devices within the control program. The dependencies extracted are, in the case of a control program written in LD language, for example, the dependency between device A specified by a contact and device B specified by a coil”; [0026]: “The edge structure storage unit 105 is an area that stores the dependencies between devices extracted by the dependency extraction unit 103. There are several types of dependencies between devices. Taking the LD language as an example, there are relationships such as the relationship between an A-contact and a coil (D1⇒D2), the relationship between a B-contact and a coil (D1⇒D2), the relationship in an arithmetic expression (D2=D1+1), and the relationship in a conditional expression (IF D1>0THEN D2=1). In all of these examples, device D2 depends on device D1. The dependency extraction unit 103 extracts the types of these dependencies and combinations of two or more target devices. The dependency type is stored as edge structure 1050”); query a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph ([0027]: “The connection information storage unit 106 is a storage area that maintains the connection relationships between the node structure 1040, which stores devices, and the edge structure 1050, which stores dependencies between devices”; [0030]: “The graph analysis unit 108 is an engine that performs graph analysis on closed, directed graphs according to the application. For example, the system can extract the range that can be influenced by the group of devices selected in the condition input unit 107 (all nodes reachable from the group of devices via directed edges), or conversely, it can extract the range that can be influenced by the device specified in the condition input unit 107 (nodes reachable from the device via directed edges in the reverse direction) in a stepwise manner”); determine a control narrative associated with the process control system when the pattern matches at least one of the stored patterns in the first database, the control narrative corresponding to the at least one of the stored patterns ([0041]: “The procedure for displaying the specifications of a specific node in Japanese (an example of natural language) by selecting that node in the graph visualized via the GUI is described below”; [0042]: “in process 405, the graph analysis unit 108 converts the directed edges originating from the target input/output device into Japanese. For example, if a specific device is 'Motor C (forward rotation)', the label name of the input device in question is 'Sensor A', and the type of directed edge it outputs is 'A-contact-coil', then the following explanatory statement will be created: 'Motor C (forward rotation) depends on Sensor A'. Furthermore, if the label for another input device is 'Emergency Stop Button B' and the edge type is 'B-contact-coil', then the following explanatory text will be created: 'Motor C (forward rotation) depends on Emergency Stop Button B'“). Okahara does not explicitly teach “compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system.” Quiros Araya further teaches compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system ([0035]: “The structure of the CEG is constructed to include knowledge based on historical data from projects that have been previously designed and analyzed by the CEG. The past knowledge obtained by the CEG may be analyzed to discover useful patterns… When a pattern is identified, either in a supervised or unsupervised manner, it can be applied to new contexts for various purposes including: validating existing designs by comparing the existing solution with the known pattern”; [0039]: “The CES identifies the pattern associated with the user's request and searches for the light tower pattern in the current CEG to find a match. In this example, a match is found”; [0038]: “The CES has analyzed multiple engineering projects from the past and stores this in a repository of past knowledge”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to adapt the apparatus of Okahara to incorporate the teachings of Quiros Araya so as to include comparing the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system. Doing so would allow past knowledge to be leveraged for validation with the aim of improving system productivity and quality (Quiros Araya, [0004]: “The CEG may be used to validate a design for the automation engineering project by comparing the CEG to a plurality of previously generated CEGs”; [0026]: “Through the reuse of engineering knowledge in the knowledge representation 117, a Cognitive Automation Engineering system 110 can improve the productivity and the quality of automation engineering projects”). Okahara and Quiros Araya do not explicitly teach “convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); and transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS.” Jetley further teaches convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS) ([0002]: “a control system (e.g., a programmable logic controller, PID controller, or a distributed control system) associated with the industrial process needs to be programmed based on requirements of the industrial process”; [0003]: “While the input/output tag lists and P&IDs are in a structural notation, and can be easily understood by the control system, the control narratives need to be interpreted and converted into control logic diagrams that can be provided as input to the control systems”; [0044]: “the processor generates a plurality of control library modules from the plurality of control logic blocks. The processor generates the control logic in a machine-readable format (e.g. eXtensible Markup language (XML format))”; [0074]: “the generated control logic is in a platform neutral format, which facilitates execution of the control logic on various types and configurations of control systems/controllers”); and transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS ([0047]: “the output interface communicates the control logic in the machine-readable format to the controller over a communication network for performing the process. The controller executes the control logic, to perform the industrial process associated with the control narrative received by the system 110”; [0022]: “The environment 100 shown in FIG. 1 shows a process plant (102) where a controller (114) is connected to a plurality of entities/process elements (116 a-n) for performing an industrial process. For example, in a pulp and paper process plant, a controller (or a distributed control system) may control operations of plurality of entities'). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to adapt the apparatus of Okahara in view of Quiros Araya to incorporate the teachings of Jetley so as to include converting the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS) and transmitting the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS. Doing so would allow automated delivery of control logic to target process controllers with the aim of improving reliability, decreasing execution time, and facilitating execution across diverse control hardware (Jetley, [00074]: “Disclosed method and system provides an efficient means to automatically derive control logic from a control narrative associated with an industrial process. The derived control logic is free from ambiguities and facilitates performance of the industrial process in a reliable manner. Further disclosed method is fast and saves time in execution of the industrial process. Further, the generated control logic is in a platform neutral format, which facilitates execution of the control logic on various types and configurations of control systems/controllers”). Further, Applicant's instant specification (see [0014]) recognizes that migrating process control applications between PLC-based architectures is challenging because control instructions and data formats may differ, and that migration often requires engineers to manually migrate data or develop scripts or programs to convert PLC-compatible data into data suitable for a DCS application. Regarding claim 2, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 1. Okahara further teaches wherein the output condition is a first output condition ([0068]: “when we obtain the output device from the device type of the node structure 1200, the one that is a “bit output” is output (ramp) 1106”; [0072]: “In this example, we assume that the user has selected node 1506 for output 1”). wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to identify the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system (FIG. 15 and [0072]: “the graph analysis unit 108 enumerates all nodes leading to the target region. In the example shown in Figure 15, the only adjacent directed edge leading to node 1506, which is the target region, is edge 1515. Therefore, this is added as a path first. Next, let's focus on the original node 1503 of edge 1515. The adjacent directed edges leading to this node are edge 1514 and edge 1510,” where the first output condition corresponds to node 1506 and the second output condition corresponds to internal device 1503); and identifying the pattern based on dependencies between the second output condition, the input data, and the first output condition ([0042]: “the graph analysis unit 108 performs graph analysis to extract subgraphs that include all nodes and edges that constitute the path leading to the specified node. In other words, the graph analysis unit 108 extracts all nodes and edges that may potentially affect the specified node. This process can be performed by traversing all directed edges backward from the target node, adding the found nodes and edges to the subgraph, and continuing until no new nodes are found”; [0068]: “node and destination node columns of the connection information table 1400 are checked to obtain the edge number and the edge type and logic of the edge structure 1300. This allows us to see what kind of edges connect the nodes displayed as a graph”; FIG. 16 and [0072]: “when targeting node 1606 of output 1, the area affected by this node is the part shown in black and with thick lines in Figure 16, namely process 1615, internal device 1603, process 1614, process 1610, and input device 1601”). Regarding claim 3, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 1. Okahara further teaches wherein the output condition indicates an operation of a field device of the process control system ([0017]: “the primary purpose of a control program is to instruct actual physical devices, such as driving a machine or applying voltage to an electronic device”; [0042]: “the graph analysis unit 108 extracts only the nodes that represent input/output devices within the created subgraph… For example, if a specific device is “Motor C (forward rotation)'“). Regarding claim 4, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 1. Okahara does not explicitly teach “wherein the first database is a model database associated with an artificial intelligence (AI) model.” Quiros Araya further teaches wherein the first database is a model database associated with an artificial intelligence (AI) model ([0005-0006]: “a cognitive system in communication with the computer-based engineering tool comprising… a machine learning module for analyzing knowledge extracted by the knowledge extraction module and identifying characteristics of the automation system… and a knowledge representation comprising a cognitive engineering graph (CEG), the CEG comprising a plurality of nodes representative of an element of the automation engineering project and at least on edge connecting two of the nodes, the at least one edge representative of a relationship between the connected nodes. The system may include a computer memory that stores a plurality of CEGs from previously designed projects in communication with the machine learning module for analyzing past knowledge”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to adapt the apparatus of Okahara in view of Quiros Araya and Jetley to incorporate Quiros Araya so as to include the first database being a model database associated with an artificial intelligence (AI) model. Doing so would allow artificial intelligence for automation with the aim of improving system productivity and quality (Quiros Araya, [0022]: “Embodiments described in this disclosure address bringing artificial intelligence (AI) to automation engineering tools to assist humans in design while increasing their productivity and ensuring high quality”). Regarding claim 6, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 1. Okahara further teaches wherein the second instructions are associated with a graphical programming language ([0003]: “Control programs created by programmers are often written in the five languages defined by the international standard IEC 61131-3, such as instruction lists (IL), ladder logic (LD), structured text (ST), function block diagrams (FBD), and sequential function charts (SFC)”). Regarding claim 7, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 6. Okahara further teaches wherein the graphical programming language is associated with a ladder diagram ([0003]: “Control programs created by programmers are often written in the five languages defined by the international standard IEC 61131-3, such as instruction lists (IL), ladder logic (LD), structured text (ST), function block diagrams (FBD), and sequential function charts (SFC)”). Regarding claim 8, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 7. Okahara further teaches wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to access the output condition by accessing the ladder diagram ([0004]: “one might focus on a device where a failure has manifested, search the control program for the LANG (a circuit block in LD language) where this device acts as a coil (output), identify the devices (usually multiple) that act as contacts (input conditions) in that LANG”). Regarding claim 9, Okahara teaches a non-transitory machine readable storage medium comprising first instructions to cause programmable circuitry to at least: access an output condition associated with a process control system ([0004]: “one might focus on a device where a failure has manifested, search the control program for the LANG (a circuit block in LD language) where this device acts as a coil (output), identify the devices (usually multiple) that act as contacts (input conditions) in that LANG”); determine second instructions to control the process control system based on the output condition, the second instructions executable by a programmable logic controller (PLC) ([0022]: “this control program intermediate code 1010 is a compilation product from the engineering environment and is also the target for download to the PLC device”; [0036]: “the device extraction unit 102 extracts the device from the control program intermediate code 1010… the dependency extraction unit 103 extracts dependencies from the control program intermediate code 1010”); identify a pattern based on the second instructions and the output condition ([0024]: “The dependency extraction unit 103 extracts descriptions of dependencies between devices within the control program. The dependencies extracted are, in the case of a control program written in LD language, for example, the dependency between device A specified by a contact and device B specified by a coil”; [0026]: “The edge structure storage unit 105 is an area that stores the dependencies between devices extracted by the dependency extraction unit 103. There are several types of dependencies between devices. Taking the LD language as an example, there are relationships such as the relationship between an A-contact and a coil (D1⇒D2), the relationship between a B-contact and a coil (D1⇒D2), the relationship in an arithmetic expression (D2=D1+1), and the relationship in a conditional expression (IF D1>0THEN D2=1). In all of these examples, device D2 depends on device D1. The dependency extraction unit 103 extracts the types of these dependencies and combinations of two or more target devices. The dependency type is stored as edge structure 1050”); query a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph ([0027]: “The connection information storage unit 106 is a storage area that maintains the connection relationships between the node structure 1040, which stores devices, and the edge structure 1050, which stores dependencies between devices”; [0030]: “The graph analysis unit 108 is an engine that performs graph analysis on closed, directed graphs according to the application. For example, the system can extract the range that can be influenced by the group of devices selected in the condition input unit 107 (all nodes reachable from the group of devices via directed edges), or conversely, it can extract the range that can be influenced by the device specified in the condition input unit 107 (nodes reachable from the device via directed edges in the reverse direction) in a stepwise manner”); determine a control narrative associated with the process control system when the pattern matches at least one of the stored patterns in the first database, the control narrative corresponding to the at least one of the stored patterns ([0041]: “The procedure for displaying the specifications of a specific node in Japanese (an example of natural language) by selecting that node in the graph visualized via the GUI is described below”; [0042]: “in process 405, the graph analysis unit 108 converts the directed edges originating from the target input/output device into Japanese. For example, if a specific device is 'Motor C (forward rotation)', the label name of the input device in question is 'Sensor A', and the type of directed edge it outputs is 'A-contact-coil', then the following explanatory statement will be created: 'Motor C (forward rotation) depends on Sensor A'. Furthermore, if the label for another input device is 'Emergency Stop Button B' and the edge type is 'B-contact-coil', then the following explanatory text will be created: 'Motor C (forward rotation) depends on Emergency Stop Button B'“). Okahara does not explicitly teach “compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system.” Quiros Araya further teaches compare the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system ([0035]: “The structure of the CEG is constructed to include knowledge based on historical data from projects that have been previously designed and analyzed by the CEG. The past knowledge obtained by the CEG may be analyzed to discover useful patterns… When a pattern is identified, either in a supervised or unsupervised manner, it can be applied to new contexts for various purposes including: validating existing designs by comparing the existing solution with the known pattern”; [0039]: “The CES identifies the pattern associated with the user's request and searches for the light tower pattern in the current CEG to find a match. In this example, a match is found”; [0038]: “The CES has analyzed multiple engineering projects from the past and stores this in a repository of past knowledge”). The reasons to combine Quiros Araya into Okahara are the same as articulated in the rejection of claim 1 above. Okahara and Quiros Araya do not explicitly teach “convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); and transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS.” Jetley further teaches convert the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS) ([0002]: “a control system (e.g., a programmable logic controller, PID controller, or a distributed control system) associated with the industrial process needs to be programmed based on requirements of the industrial process”; [0003]: “While the input/output tag lists and P&IDs are in a structural notation, and can be easily understood by the control system, the control narratives need to be interpreted and converted into control logic diagrams that can be provided as input to the control systems”; [0044]: “the processor generates a plurality of control library modules from the plurality of control logic blocks. The processor generates the control logic in a machine-readable format (e.g. eXtensible Markup language (XML format))”; [0074]: “the generated control logic is in a platform neutral format, which facilitates execution of the control logic on various types and configurations of control systems/controllers”); and transmit the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS ([0047]: “the output interface communicates the control logic in the machine-readable format to the controller over a communication network for performing the process. The controller executes the control logic, to perform the industrial process associated with the control narrative received by the system 110”; [0022]: “The environment 100 shown in FIG. 1 shows a process plant (102) where a controller (114) is connected to a plurality of entities/process elements (116 a-n) for performing an industrial process. For example, in a pulp and paper process plant, a controller (or a distributed control system) may control operations of plurality of entities'). The reasons to combine Jetley into Okahara in view of Quiros Araya are the same as articulated in the rejection of claim 1 above. Regarding claim 10, Okahara in view of Quiros Araya and Jetley teaches the non-transitory machine readable storage medium of claim 9. Okahara further teaches wherein the output condition is a first output condition ([0068]: “when we obtain the output device from the device type of the node structure 1200, the one that is a “bit output” is output (ramp) 1106”; [0072]: “In this example, we assume that the user has selected node 1506 for output 1”). wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to identify the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system (FIG. 15 and [0072]: “the graph analysis unit 108 enumerates all nodes leading to the target region. In the example shown in Figure 15, the only adjacent directed edge leading to node 1506, which is the target region, is edge 1515. Therefore, this is added as a path first. Next, let's focus on the original node 1503 of edge 1515. The adjacent directed edges leading to this node are edge 1514 and edge 1510,” where the first output condition corresponds to node 1506 and the second output condition corresponds to internal device 1503); and identifying the pattern based on dependencies between the second output condition, the input data, and the first output condition ([0042]: “the graph analysis unit 108 performs graph analysis to extract subgraphs that include all nodes and edges that constitute the path leading to the specified node. In other words, the graph analysis unit 108 extracts all nodes and edges that may potentially affect the specified node. This process can be performed by traversing all directed edges backward from the target node, adding the found nodes and edges to the subgraph, and continuing until no new nodes are found”; [0068]: “node and destination node columns of the connection information table 1400 are checked to obtain the edge number and the edge type and logic of the edge structure 1300. This allows us to see what kind of edges connect the nodes displayed as a graph”; FIG. 16 and [0072]: “when targeting node 1606 of output 1, the area affected by this node is the part shown in black and with thick lines in Figure 16, namely process 1615, internal device 1603, process 1614, process 1610, and input device 1601”). Regarding claim 11, Okahara in view of Quiros Araya and Jetley teaches the non-transitory machine readable storage medium of claim 9. Okahara further teaches wherein the output condition indicates an operation of a field device of the process control system ([0017]: “the primary purpose of a control program is to instruct actual physical devices, such as driving a machine or applying voltage to an electronic device”; [0042]: “the graph analysis unit 108 extracts only the nodes that represent input/output devices within the created subgraph… For example, if a specific device is “Motor C (forward rotation)'“). Regarding claim 12, Okahara in view of Quiros Araya and Jetley teaches the non-transitory machine readable storage medium of claim 9. Okahara does not explicitly teach “wherein the first database is a model database associated with an artificial intelligence (AI) model.” Quiros Araya further teaches wherein the first database is a model database associated with an artificial intelligence (AI) model ([0005-0006]: “a cognitive system in communication with the computer-based engineering tool comprising… a machine learning module for analyzing knowledge extracted by the knowledge extraction module and identifying characteristics of the automation system… and a knowledge representation comprising a cognitive engineering graph (CEG), the CEG comprising a plurality of nodes representative of an element of the automation engineering project and at least on edge connecting two of the nodes, the at least one edge representative of a relationship between the connected nodes. The system may include a computer memory that stores a plurality of CEGs from previously designed projects in communication with the machine learning module for analyzing past knowledge”). The reasons to combine Quiros Araya into Okahara in view of Quiros Araya and Jetley are the same as articulated in the rejection of claim 4 above. Regarding claim 14, Okahara in view of Quiros Araya and Jetley teaches the non-transitory machine readable storage medium of claim 9. Okahara further teaches wherein the second instructions are associated with a graphical programming language ([0003]: “Control programs created by programmers are often written in the five languages defined by the international standard IEC 61131-3, such as instruction lists (IL), ladder logic (LD), structured text (ST), function block diagrams (FBD), and sequential function charts (SFC)”). Regarding claim 15, Okahara in view of Quiros Araya and Jetley teaches the non-transitory machine readable storage medium of claim 14. Okahara further teaches wherein the graphical programming language is associated with a ladder diagram ([0003]: “Control programs created by programmers are often written in the five languages defined by the international standard IEC 61131-3, such as instruction lists (IL), ladder logic (LD), structured text (ST), function block diagrams (FBD), and sequential function charts (SFC)”). Regarding claim 16, Okahara in view of Quiros Araya and Jetley teaches the non-transitory machine readable storage medium of claim 15. Okahara further teaches wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to access the output condition by accessing the ladder diagram ([0004]: “one might focus on a device where a failure has manifested, search the control program for the LANG (a circuit block in LD language) where this device acts as a coil (output), identify the devices (usually multiple) that act as contacts (input conditions) in that LANG”). Regarding claim 17, Okahara teaches a method comprising: accessing an output condition associated with a process control system ([0004]: “one might focus on a device where a failure has manifested, search the control program for the LANG (a circuit block in LD language) where this device acts as a coil (output), identify the devices (usually multiple) that act as contacts (input conditions) in that LANG”); determining instructions to control the process control system based on the output condition, the instructions executable by a programmable logic controller (PLC) ([0022]: “this control program intermediate code 1010 is a compilation product from the engineering environment and is also the target for download to the PLC device”; [0036]: “the device extraction unit 102 extracts the device from the control program intermediate code 1010… the dependency extraction unit 103 extracts dependencies from the control program intermediate code 1010”); identifying a pattern based on the instructions and the output condition ([0024]: “The dependency extraction unit 103 extracts descriptions of dependencies between devices within the control program. The dependencies extracted are, in the case of a control program written in LD language, for example, the dependency between device A specified by a contact and device B specified by a coil”; [0026]: “The edge structure storage unit 105 is an area that stores the dependencies between devices extracted by the dependency extraction unit 103. There are several types of dependencies between devices. Taking the LD language as an example, there are relationships such as the relationship between an A-contact and a coil (D1⇒D2), the relationship between a B-contact and a coil (D1⇒D2), the relationship in an arithmetic expression (D2=D1+1), and the relationship in a conditional expression (IF D1>0THEN D2=1). In all of these examples, device D2 depends on device D1. The dependency extraction unit 103 extracts the types of these dependencies and combinations of two or more target devices. The dependency type is stored as edge structure 1050”); querying a configuration graph database to access the pattern, the configuration graph database storing the pattern as nodes in a graph ([0027]: “The connection information storage unit 106 is a storage area that maintains the connection relationships between the node structure 1040, which stores devices, and the edge structure 1050, which stores dependencies between devices”; [0030]: “The graph analysis unit 108 is an engine that performs graph analysis on closed, directed graphs according to the application. For example, the system can extract the range that can be influenced by the group of devices selected in the condition input unit 107 (all nodes reachable from the group of devices via directed edges), or conversely, it can extract the range that can be influenced by the device specified in the condition input unit 107 (nodes reachable from the device via directed edges in the reverse direction) in a stepwise manner”); determining a control narrative associated with the process control system when the pattern matches at least one of the stored patterns in the first database, the control narrative corresponding to the at least one of the stored patterns ([0041]: “The procedure for displaying the specifications of a specific node in Japanese (an example of natural language) by selecting that node in the graph visualized via the GUI is described below”; [0042]: “in process 405, the graph analysis unit 108 converts the directed edges originating from the target input/output device into Japanese. For example, if a specific device is 'Motor C (forward rotation)', the label name of the input device in question is 'Sensor A', and the type of directed edge it outputs is 'A-contact-coil', then the following explanatory statement will be created: 'Motor C (forward rotation) depends on Sensor A'. Furthermore, if the label for another input device is 'Emergency Stop Button B' and the edge type is 'B-contact-coil', then the following explanatory text will be created: 'Motor C (forward rotation) depends on Emergency Stop Button B'“). Okahara does not explicitly teach “comparing the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system.” Quiros Araya further teaches comparing the pattern in the configuration graph database to stored patterns in a first database, the stored patterns associated with at least one other process control system ([0035]: “The structure of the CEG is constructed to include knowledge based on historical data from projects that have been previously designed and analyzed by the CEG. The past knowledge obtained by the CEG may be analyzed to discover useful patterns… When a pattern is identified, either in a supervised or unsupervised manner, it can be applied to new contexts for various purposes including: validating existing designs by comparing the existing solution with the known pattern”; [0039]: “The CES identifies the pattern associated with the user's request and searches for the light tower pattern in the current CEG to find a match. In this example, a match is found”; [0038]: “The CES has analyzed multiple engineering projects from the past and stores this in a repository of past knowledge”). The reasons to combine Quiros Araya into Okahara are the same as articulated in the rejection of claim 1 above. Okahara and Quiros Araya do not explicitly teach “converting the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS); and transmitting the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS.” Jetley further teaches converting the control narrative from a first data format compatible with the PLC to a second data format compatible with a distributed control system (DCS) ([0002]: “a control system (e.g., a programmable logic controller, PID controller, or a distributed control system) associated with the industrial process needs to be programmed based on requirements of the industrial process”; [0003]: “While the input/output tag lists and P&IDs are in a structural notation, and can be easily understood by the control system, the control narratives need to be interpreted and converted into control logic diagrams that can be provided as input to the control systems”; [0044]: “the processor generates a plurality of control library modules from the plurality of control logic blocks. The processor generates the control logic in a machine-readable format (e.g. eXtensible Markup language (XML format))”; [0074]: “the generated control logic is in a platform neutral format, which facilitates execution of the control logic on various types and configurations of control systems/controllers”); and transmitting the control narrative to a second database associated with the DCS, the control narrative to modify a configuration of the DCS ([0047]: “the output interface communicates the control logic in the machine-readable format to the controller over a communication network for performing the process. The controller executes the control logic, to perform the industrial process associated with the control narrative received by the system 110”; [0022]: “The environment 100 shown in FIG. 1 shows a process plant (102) where a controller (114) is connected to a plurality of entities/process elements (116 a-n) for performing an industrial process. For example, in a pulp and paper process plant, a controller (or a distributed control system) may control operations of plurality of entities'). The reasons to combine Jetley into Okahara in view of Quiros Araya are the same as articulated in the rejection of claim 1 above. Regarding claim 18, Okahara in view of Quiros Araya and Jetley teaches the method of claim 17. Okahara further teaches wherein the output condition is a first output condition ([0068]: “when we obtain the output device from the device type of the node structure 1200, the one that is a “bit output” is output (ramp) 1106”; [0072]: “In this example, we assume that the user has selected node 1506 for output 1”), further including identifying the pattern by: accessing input data associated with the first output condition, the input data including a second output condition associated with the process control system (FIG. 15 and [0072]: “the graph analysis unit 108 enumerates all nodes leading to the target region. In the example shown in Figure 15, the only adjacent directed edge leading to node 1506, which is the target region, is edge 1515. Therefore, this is added as a path first. Next, let's focus on the original node 1503 of edge 1515. The adjacent directed edges leading to this node are edge 1514 and edge 1510,” where the first output condition corresponds to node 1506 and the second output condition corresponds to internal device 1503); and identifying the pattern based on dependencies between the second output condition, the input data, and the first output condition ([0042]: “the graph analysis unit 108 performs graph analysis to extract subgraphs that include all nodes and edges that constitute the path leading to the specified node. In other words, the graph analysis unit 108 extracts all nodes and edges that may potentially affect the specified node. This process can be performed by traversing all directed edges backward from the target node, adding the found nodes and edges to the subgraph, and continuing until no new nodes are found”; [0068]: “node and destination node columns of the connection information table 1400 are checked to obtain the edge number and the edge type and logic of the edge structure 1300. This allows us to see what kind of edges connect the nodes displayed as a graph”; FIG. 16 and [0072]: “when targeting node 1606 of output 1, the area affected by this node is the part shown in black and with thick lines in Figure 16, namely process 1615, internal device 1603, process 1614, process 1610, and input device 1601”). Regarding claim 19, Okahara in view of Quiros Araya and Jetley teaches the method of claim 17. Okahara does not explicitly teach “wherein the first database is a model database associated with an artificial intelligence (AI) model.” Quiros Araya further teaches wherein the first database is a model database associated with an artificial intelligence (AI) model ([0005-0006]: “a cognitive system in communication with the computer-based engineering tool comprising… a machine learning module for analyzing knowledge extracted by the knowledge extraction module and identifying characteristics of the automation system… and a knowledge representation comprising a cognitive engineering graph (CEG), the CEG comprising a plurality of nodes representative of an element of the automation engineering project and at least on edge connecting two of the nodes, the at least one edge representative of a relationship between the connected nodes. The system may include a computer memory that stores a plurality of CEGs from previously designed projects in communication with the machine learning module for analyzing past knowledge”). The reasons to combine Quiros Araya into Okahara in view of Quiros Araya and Jetley are the same as articulated in the rejection of claim 1 above. Regarding claim 20, Okahara in view of Quiros Araya and Jetley teaches the method of claim 17. Okahara further teaches wherein the instructions are associated with a graphical programming language ([0003]: “Control programs created by programmers are often written in the five languages defined by the international standard IEC 61131-3, such as instruction lists (IL), ladder logic (LD), structured text (ST), function block diagrams (FBD), and sequential function charts (SFC)”). Regarding claim 21, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 1. Okahara further teaches wherein the control narrative includes a human-readable, natural-language textual description of control logic of the process control system ([0041]: “The procedure for displaying the specifications of a specific node in Japanese (an example of natural language) by selecting that node in the graph visualized via the GUI is described below, based on Figure 4”; [0042]: “if a specific device is 'Motor C (forward rotation)', the label name of the input device in question is 'Sensor A', and the type of directed edge it outputs is 'A-contact-coil', then the following explanatory statement will be created: 'Motor C (forward rotation) depends on Sensor A'. Furthermore, if the label for another input device is 'Emergency Stop Button B' and the edge type is 'B-contact-coil', then the following explanatory text will be created: 'Motor C (forward rotation) depends on Emergency Stop Button B'. In process 406, these explanatory sentences are presented to the user one sentence at a time by the result output unit 109”). Regarding claim 22, Okahara in view of Quiros Araya and Jetley teaches the apparatus of claim 4. Okahara further teaches wherein the first instructions, when executed or instantiated by the programmable circuitry, further cause the programmable circuitry to: perform a backward slicing process on the second instructions to determine dependencies within the second instructions ([0019]: “A common program analysis technique similar to the method in this embodiment is called 'flow graphing.' As mentioned above, this represents the dependencies between processes (controls) within a program, as used in program slicing techniques (Non-Patent Document 1), etc., using a directed graph”; [0042]: “the graph analysis unit 108 performs graph analysis to extract subgraphs that include all nodes and edges that constitute the path leading to the specified node. In other words, the graph analysis unit 108 extracts all nodes and edges that may potentially affect the specified node. This process can be performed by traversing all directed edges backward from the target node, adding the found nodes and edges to the subgraph, and continuing until no new nodes are found”); and determine the control narrative based on the dependencies and the at least one of the stored patterns in the model database ([0026]: “The edge structure storage unit 105 is an area that stores the dependencies between devices extracted by the dependency extraction unit 103. There are several types of dependencies between devices. Taking the LD language as an example, there are relationships such as the relationship between an A-contact and a coil (D1⇒D2), the relationship between a B-contact and a coil (D1⇒D2), the relationship in an arithmetic expression (D2=D1+1), and the relationship in a conditional expression (IF D1>0THEN D2=1). In all of these examples, device D2 depends on device D1. The dependency extraction unit 103 extracts the types of these dependencies and combinations of two or more target devices. The dependency type is stored as edge structure 1050”; [0042]: “in process 405, the graph analysis unit 108 converts the directed edges originating from the target input/output device into Japanese. For example, if a specific device is 'Motor C (forward rotation)', the label name of the input device in question is 'Sensor A', and the type of directed edge it outputs is 'A-contact-coil', then the following explanatory statement will be created: 'Motor C (forward rotation) depends on Sensor A'. Furthermore, if the label for another input device is 'Emergency Stop Button B' and the edge type is 'B-contact-coil', then the following explanatory text will be created: 'Motor C (forward rotation) depends on Emergency Stop Button B'“). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 2020/0272644 A1: Storing graph nodes and relationships for an industrial automation environment, including PLC nodes, database prediction queries, patterns, and an experience database US 2019/0227513 A1: Analyzing a PLC logic program by dividing ladder logic into segments or chunks, identifying features such as inputs, outputs, and/or specific memory arrangements, classifying those features, and writing data objects to an analysis result repository US 2014/0013304 A1: Creating a code relationship graph, using control flow analysis and data flow analysis to identify a matching code subset, and using a previously generated description to describe the matching code subset US 2007/0061786 A1: Converting process control data between data formats, importing modified process control data into a control system database, and storing the modified process control data for use in configuring a process control system US 2025/0085931 A1: An industrial IDE with a project conversion component and generative AI model that converts industrial control code from a first format to a second format and generates human-readable comments that provide a functional summary or label Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Magdalena Kossek whose telephone number is (571)272-5603. The examiner can normally be reached Mon-Fri 8:00-5:00 EST. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Robert Fennema can be reached on (571)272-2748. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /M.I.K./Examiner, Art Unit 2117 /ROBERT E FENNEMA/Supervisory Patent Examiner, Art Unit 2117
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Prosecution Timeline

Mar 20, 2024
Application Filed
Jun 03, 2026
Non-Final Rejection mailed — §101, §103
Aug 27, 2026
Response Filed
Oct 08, 2026
Final Rejection mailed — §101, §103 (current)

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