DETAILED ACTIONNotice 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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination (RCE) under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed has been entered.
Claim Rejections - 35 USC § 101
35 U.S.C. § 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 rejected under 35 U.S.C. § 101 are directed to an abstract idea without significantly more.
The claims do not provide significantly more than the judicial exception under the subject matter eligibility two-part statutory analysis, as provided below.
Regarding Step 1,
Step 1 addresses whether the claims are directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter according to MPEP §2106.03. Claims 1-20 all fall within one of the four statutory categories.
Regarding Step 2A [prong 1],
The claimed invention recites an abstract idea according to MPEP §2106.04. Independent claim 1, also representative of independent claims 12 and 16 for the same abstract features, is underlined below which recite the following claim limitations, as an abstract idea.
Claims 1 & 12 and 16 for an automation rule creation collaboration system comprising:
indicating a selection of a trigger component and a first action component for an automation rule, the trigger component associated with a change to a first object;
causing generation of a first one or more graphical elements representing the selected trigger component and the selected first action component in a proposed automation rule flow;
determining a first set of compatible action components for the selected first action component based at least in part on, for each action component of the first set of compatible action components, an ordering of the action component within the proposed automation rule flow and a compatibility between the action component and the selected first action component; and causing generation of a first set of graphical elements in the proposed automation rule flow, each graphical element of the first set of graphical elements corresponding to a respective compatible action component of the first set of compatible action components;
in response to receiving a second input of the graphical user interface indicating a selection of a particular compatible action component from the first set of compatible action components: causing generation of a second graphical element representing the selected compatible action component, the second graphical element displayed with the first one or more graphical elements in the proposed automation rule flow;
…to save an automation rule that includes at least the selected trigger component, the first action component, the selected compatible action component, and an object identifier: generating a service that performs an operation in response to an event satisfying the selected trigger component, wherein the operation corresponds to the action component, and the operation is performed on a set of objects selected using the object identifier,
the compatibility determined based at least in part on whether one or more entity context requirements of each compatible action component of the set of compatible action components can be satisfied at a position following the selected trigger component;
The underlined claim limitations, under its broadest reasonable interpretation, fall under “Certain Methods of Organizing Human Activities” grouping of abstract ideas, and includes at least managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions). See MPEP §2106.04(a)(2)(II).
But for the recitation of generic implementation of computer system components, the claimed invention merely recites a process for managing personal behavior/relationships or interactions between people because the claimed steps recite designing an workflow using rules and graphical elements proposed in the rule workflow and manage collaboration. Accordingly, since the claimed invention describes a process that falls under “Certain Methods of Organizing Human Activities” grouping, the claimed invention recites an abstract idea.
Regarding Step 2A [prong 2],
The judicial exception is not integrated into a practical application according to MPEP §2106.04(d). The claims 1, 12 and 16 include the following additional elements:
A computer-implemented method causing generation of a graphical user interface of the collaboration system, the graphical user interface including an input field for receiving user input; in response to receiving a first/second/third input of the first graphical user interface;
An interface to communicate with at least one client device;
In particular, the additional elements cited above beyond the abstract idea are recited at a high-level of generality and simply equivalent to a generic recitation and basic functionality that amount to no more than mere instructions to apply the judicial exception using generic computer technology components.
The claimed invention merely provides an abstract-idea-based-solution implemented with generic computer processes and components recited at a high-level of generality (receiving, storing, determining, and comparing data) using computer instructions to implement the abstract idea on a computer, and merely “apply it” without any meaningful technological limits or any improvement to technology, technical field or improvement to the functioning of the computer itself.
Therefore, the additional elements fail to integrate the recited abstract idea into any practical application since they do not impose any non-generic meaningful limits on practicing the abstract idea. Thus, the claimed invention is directed to an abstract idea.
Regarding Step 2B,
The claimed invention does not include additional elements that are sufficient to amount to significantly more than the judicial exception. See MPEP §2106.05.
As discussed above, the claimed additional elements recited above amounts to no more than mere instructions to implement the abstract idea by adding the words “apply it” using generic computer components and functionality. See MPEP §2106.05(h). Mere instructions to apply the judicial exception using generic computer components are insufficient to provide an inventive concept. Furthermore, the claimed additional elements merely limit the abstract idea to be executed in a computer environment, thus do nothing more than generally linking the use of a judicial exception to a particular technological environment or field of use. See MPEP §2106.05(h).
Considered as an ordered combination, the additional elements are claimed at a high-level of generality and add nothing that is not already present when the steps are considered separately. The sequence of the claimed limitations is equally generic and otherwise held to be abstract since the combination of these additional elements is no more than mere instructions to apply the judicial exception using generic computer components operating in their ordinary and generic capacities of what is typically expected of computers storing and updating data, and receiving and transmitting data between generic computer devices. The claimed invention is not patent eligible because the additional elements are merely invoked as tools to receive and output data, and update software tool with updated data to execute the abstract idea and thus are insufficient to amount to an inventive concept significantly more than the judicial exception.
As for dependent claims, they merely further narrow and reiterate the same abstract ideas for storing and updating data, and receiving and transmitting data using generic data storage and transmittal techniques with the same additional elements as recited above which provide nothing more than applying the abstract idea using generic computer technology components. Furthermore dependent claims comprise the following additional elements:
A second GUI and generative output engine
These additional elements do not provide any improvement to technology, technical field or improvement to the functioning of the computer itself, and at best simply applying the abstract idea executed in a general-purpose computer environment. Therefore the dependent claims are also directed to ineligible subject matter since they do not provide significantly more than the abstract idea itself.
Thus, after considering all claim elements in Claims 1-20 both individually and as an ordered combination, it has been determined that the claimed invention as a whole, is not enough to transform the abstract idea into a patent-eligible invention since nothing in the claim limitations provide significantly more than the abstract idea under 35 U.S.C. § 101.
Response to Amendment & Arguments
Applicant’s amendment and arguments are unpersuasive. Regarding the 35 USC 101 rejection, Applicant argues the following:
“Before turning to each prong, the Assignee respectfully submits a framing observation. Under MPEP 2106, eligibility is evaluated with the claims considered as a whole and with all limitations given weight at each stage of the analysis. In this instance, the Office Action considers the "compatibility determination" and the "service generation" limitations as part of the recited abstract idea, and considers the "graphical user interface" and the "interface" as additional elements. The Assignee respectfully submits that, when all limitations are considered together, the independent claims recite and are directed to a machine-implemented rule builder. This rule builder constrains rule construction, in real time, through machine-side analysis of entity context requirements. This machine-controlled operation results in generation of an executable service on a collaboration system.”
Examiner respectfully disagrees. Using a computer or generic “machine-controlled” rule builder is not eligible subject matter under 35 USC 101, which has a 2-prong analysis where the abstract idea features are provided and the technology (additional elements) are emphasized and analyzed as a whole to determine whether the claimed invention is significantly more than the abstract idea. Implementing an abstract idea on a computer is not eligible subject matter just because a computer is used to automate the rules. Automating rules is not a specific technology it is an abstract idea being implemented at a high-level of generality using additional elements (generic computer technology). There is no specific improvement being provided to any GUI technology itself.
The Applicant further argues “Claim 12 further recites the centralized automation rule service as the integration point between platforms. Finally, the claims do not end in merely creating data for an arbitrary purpose.” Examiner respectfully disagrees. The purpose of rule creation using computer platforms or merging or integrating them between computer platforms for a specific purpose does not alleviate the fact that the claimed invention merely provides an abstract-idea-based-solution implemented with generic computer processes and components recited at a high-level of generality (receiving, storing, determining, and collecting, displaying, processing data) using computer instructions to implement the abstract idea on a computer, and merely “apply it” without any meaningful technological limits or any improvement to technology, technical field or improvement to the functioning of the computer itself.
Conclusion
The relevant prior art made of record not relied upon but considered pertinent to applicant's disclosure can be found in the current and/or previous PTO-892 Notice of References Cited. Any inquiry concerning this communication or earlier communications from the Examiner should be directed to LAURA YESILDAG whose direct telephone number is (571) 270-5066 and work schedule is generally Monday-Friday, from 9:00 AM - 5:00 PM ET.
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/LAURA YESILDAG/Primary Examiner, Art Unit 3629
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