CTFR 18/617,942 CTFR 97084 DETAILED ACTION Notice of AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. Response to Arguments Applicant’s amendments and arguments filed 04/07/2026, with respect to claim(s) 1-20 have been fully considered. Applicant amended independent claims 1, 9 , 17 and cancelled claims 6-8, 14-16. Applicant’s arguments in pages 8-9, filed 04/07/2026, with respect to 35 U.S.C 101 rejections of Claims 1-20 have been fully considered but they are not persuasive. Applicant added dependent claims 6-8 with independent claim 1, dependent claims 14-16 with independent claim 9, similar features of claim 8 with independent claim 17. Applicant argued that the amended claims recite, (a) constructing a dependency graph of one or more actions from the process flow; (b) annotating the dependency graph with a partial order tag to each action, wherein the partial order tag defines an order for the actions "at least one of in time or as a delta-cycle"; (c) executing the one or more actions sequentially or in parallel to generate a stored output feature; and (d) creating a log documenting the actions and the sequence of their execution, these operations involve constructing and manipulating computer data structures (i.e., dependency graphs with partial order annotations including delta-cycles for discrete event simulation) executing actions in parallel, and generating execution logs. None of these operations can practically be performed in the human mind. Applicant also argued that this is a technical concept from discrete event simulation used to define the order of actions to be executed at a single timestamp, not a mental process and the ordered combination as whole involve a process which cannot be performed by a human. Examiner respectfully disagrees. The way the claim language is written, doesn’t mention that these operations involve constructing and manipulating computer data structures or anything about discrete event simulation which is used to define the order of actions to be executed at a single timestamp. The claim mentions constructing a dependency graph, of one or more actions, annotating the graph with order of actions, executing the action sequentially or in parallel and creating a log documentation of the sequence of the execution, which can be done with the aid of pen and paper. Dependency graph is a visual or mathematical map that shows how different items are connected with each other, which uses nodes connected by edges. Nothing in the above steps precludes the step from practically being performed by a human. Additionally, the mere nominal recitation of a generic computer appliance does not take the claim limitation out of the mental processes grouping. Applicant further argued that the claims as amended, provide a specific technical improvement: automating the creation of training data for digital twins by using an LLM. But no where in the claims it has been mentioned that the training data creation is automated. Applicant cited different paragraph from specification to establish that this invention provides a concrete improvement to the technology of digital twin creation by automating, but the claim language didn’t reflect any of those improvements. The use of a computer does not preclude performance of the invention via pen and paper or in a person’s mind. Also, the use of a computer or other machinery in its ordinary capacity to perform a task or simply adding a general purpose computer to an abstract idea, does not integrate a judicial exception into a practical application. Here the computer is the machine that is merely an object on which the method operates, which does not integrate the exception into a practical application or provide significantly more. Thus, 35 U.S.C 101 rejections of Claims 1-5, 9-13, 17-20 have been maintained. Applicant’s arguments filed 04/07/2026, with respect to claim(s) 1-5, 9-13, 17-20, under 35 U.S.C. 103 have been fully considered and they are persuasive. Therefore, the 35 U.S.C. 103 rejection has been withdrawn. Claim Rejections - 35 USC § 101 07-04-01 AIA 07-04 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 1-5, 9-13, 17-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The Independent claims 1, 9 recite “a system for training a digital twin of a system-under-test, comprising: processing circuitry”; “and memory, with instructions stored thereon which, when performed by the processing circuitry cause the processing circuitry to: receive multiple inputs with information corresponding to the system-under-test”; “provide the multiple inputs as a data input to a large language model”; “configure an experiment with the large language model, based on the multiple inputs”; “configure a process flow for the experiment, using data output generated from the large language model , wherein to configure the process flow includes to construct a dependency graph of one or more actions ”; “generate a training data set using the experiment and the process flow, wherein the training data set includes a stored input feature and a stored output feature”; “annotate the dependency graph with a partial order tag to each of the one or more actions, wherein the partial order tag defines an order for the one or more actions at least one of in time or as a delta-cycle”; “execute the one or more actions sequentially or in parallel to generate the stored output feature; create a log documenting the one or more actions, including a sequence in which the one or more actions were executed ”; “and configure a digital twin of the system-under-test using the training data set”. The limitations above as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process, as this could be performed in the human mind or with the aid of pen and paper. The limitation of " receive ... ", "provide ... ", "configure ... ", “generate..”, as drafted covers mental activities. More specifically, a human can receive/obtain multiple information regarding a system under test. One can generate an experiment or test by using those information and can configure the process flow ( steps for performing the experiment), creating a dependency graph of one or more actions, annotating the actions in the graph with sequences, executing the actions and generating log documentation of actions with sequence and configuring as training data to mimic the system under test . All the steps above are examples of observation and evaluation that could be performed in the human mind or with the aid of pencil and paper. The claims recite the additional limitation of “large language model”, “processing circuitry”, “memory”, “ non transitory computer readable medium” for performing the method. All those are recited at a high level of generality and are recited as performing generic computer functions routinely used in computer applications. The current specification in paragraph [0041] specifies large language model as any trained model with the ability to achieve general-purpose language generation, natural language processing, classification, or the like, which is generic and can be any trained model, which is not sufficient to amount to significantly more than the judicial exception. Specification in paragraphs [0046]-[0048],[0065], clearly specifies “processor”, “processing circuitry”, “memory” and “ non transitory computer readable storage medium” as performing generic computer functions that are well-understood, routine and conventional activities amount to no more than implementing the abstract idea with a computerized system. The claims as drafted, are not patent eligible. Thus, taken alone, the additional elements do not amount to significantly more than the above identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. Claims 1 and 9 are therefore not drawn to eligible subject matter as they are directed to an abstract idea without significantly more than the abstract idea. The Independent claim 17 recites “A system for creating a digital twin of a system-under-test, comprising: processing circuitry”; “and memory, with instructions stored thereon which, when performed by the processing circuitry cause the processing circuitry to: receive multiple inputs with information corresponding to the system-under-test”; “provide the multiple inputs as a data input to a large language model”; “configure an experiment with the large language model, based on the multiple inputs”; “configure a process flow for the experiment, using data output generated from the large language model, wherein to configure the process flow includes to construct a dependency graph of one or more actions”; “generate a training data set using the experiment and the process flow, wherein the training data set includes a stored input feature and a stored output feature”; “annotate the dependency graph with a partial order tag to each of the one or more actions , wherein the partial order tag defines an order for the one or more actions at least one of in time or as a delta-cycle”; “execute the one or more actions sequentially or in parallel to generate the stored output feature”; “create a log documenting the one or more actions, including a sequence in which the one or more actions were executed”; “and output a digital twin of the system-under-test using the training data set”. The limitations above as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process, as this could be performed in the human mind or with the aid of pen and paper. The limitation of " receive ... ", "provide ... ", "configure ... ", “generate..”, ”annotate..”, “execute..” as drafted covers mental activities. More specifically, a human can receive/obtain multiple information regarding a system under test. One can generate an experiment or test by using those information and can configure the process flow ( steps for performing the experiment), can generate a dependency graph based on the relationship between the steps, annotate the dependency graph, performing the actions sequentially, creating logs, generating training data with the experiment and the process flow , which can be used to mimic the system under test . All the steps above are examples of observation and evaluation that could be performed in the human mind or with the aid of pencil and paper. The claim recites the additional limitation of “large language model”, “processing circuitry”, “memory”, “ non transitory computer readable medium” for performing the method. All those are recited at a high level of generality and are recited as performing generic computer functions routinely used in computer applications. The current specification in paragraph [0041] specifies large language model as any trained model with the ability to achieve general-purpose language generation, natural language processing, classification, or the like, which is generic and can be any trained model, which is not sufficient to amount to significantly more than the judicial exception. Specification in paragraphs [0046]-[0048],[0065], clearly specifies “processor”, “processing circuitry”, “memory” and “ non transitory computer readable storage medium” as performing generic computer functions that are well-understood, routine and conventional activities amount to no more than implementing the abstract idea with a computerized system. The claim as drafted, is not patent eligible. Thus, taken alone, the additional elements do not amount to significantly more than the above identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. Claim 17 is therefore not drawn to eligible subject matter as they are directed to an abstract idea without significantly more than the abstract idea. Claims 2, 10 and 18 recite the additional limitation of ” wherein a first input of the multiple inputs includes a natural language description of the experiment, wherein a second input of the multiple inputs includes application programming interface documentation of the system-under-test, and wherein a third input of the multiple inputs includes one or more rules defining an input and an output for one or more actions used to configure the experiment ” , where multiple inputs are described as natural language description, documentation and rules, which could be an observation or evaluation and could be performed in the human mind or with the aid of pen and paper. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception, as claims 2, 10 and 18 do not recite any additional limitations. The claims as drafted, are not patent eligible. Claims 3 and 11 recite “wherein to configure the experiment includes to use the natural language description of the experiment to generate a plurality of augmented experiments in real-time, wherein the plurality of augmented experiments are permutations of the experiment determined from a natural language description of the experiment and a description of two or more modifications to be made to the experiment”, to determine that the configured experiment/test includes natural language description and is generated from real time, modifying the parameters of the experiment, is an evaluation, observation and could be performed in the human mind or with the aid of pen and paper. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception, as claims 3 and 11 do not recite any additional limitations. The claims as drafted, are not patent eligible. Claims 4, 12 and 20 recite “wherein the training data set is generated via a command that causes the processing circuitry to iterate through the plurality of augmented experiments using a set of generated prompts”, where generating training data from iteration of experiment could be performed with the aid of pen and paper. The claims recite additional limitation of processing circuitry, which is specified in specification in paragraph [0046], [0065] as performing generic computer functions that are well-understood, routine and conventional activities amount to no more than implementing the abstract idea with a computerized system. The claims as drafted, are not patent eligible. Claims 5 and 13 recite “wherein the training data set is generated, at least in part by translating the natural language description of the experiment to one or more application programming interface calls”, where generating training data by translating natural language description to one or more API calls, could be performed with the aid of pen and paper. The claims recite additional limitation of application programming interface, which is generic and not sufficient to amount to significantly more than the judicial exception The claims as drafted, are not patent eligible. Claim 19 recites “wherein to configure the experiment includes to use the natural language description of the experiment to generate a plurality of augmented experiments in real-time, wherein the plurality of augmented experiments are permutations of the experiment determined from a natural language description of the experiment and a description of two or more modifications to be made to the experiment, and wherein the training data set is generated, at least in part by translating the natural language description of the experiment to one or more application programming interface calls”, to determine that the configured experiment/test includes natural language description and is generated from real time, modifying the parameters of the experiment, is an evaluation, observation and could be performed in the human mind or with the aid of pen and paper. Generating training data by translating natural language description to one or more API calls, could be performed with the aid of pen and paper. The claims recite additional limitation of application programming interface, which is generic and not sufficient to amount to significantly more than the judicial exception The claim as drafted, is not patent eligible. Allowable Subject Matter Claims 1-5, 9-13 and 17-20 contain subject matter that is allowable over the prior art of record. They would be considered allowable if rewritten to overcome the rejection(s) under 35 U.S.C. 101, set forth in this Office action and to include all of the limitations of the base claim and any intervening claims. Conclusion 07-40 AIA 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to NADIRA SULTANA whose telephone number is (571)272-4048. The examiner can normally be reached M-F,7:30 am-5:00pm. 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, Paras D. Shah can be reached on (571) 270-1650. 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. 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If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /NADIRA SULTANA/Examiner, Art Unit 2653 /Paras D Shah/Supervisory Patent Examiner, Art Unit 2653 06/04/2026 Application/Control Number: 18/617,942 Page 2 Art Unit: 2653 Application/Control Number: 18/617,942 Page 3 Art Unit: 2653 Application/Control Number: 18/617,942 Page 4 Art Unit: 2653 Application/Control Number: 18/617,942 Page 5 Art Unit: 2653 Application/Control Number: 18/617,942 Page 6 Art Unit: 2653 Application/Control Number: 18/617,942 Page 7 Art Unit: 2653 Application/Control Number: 18/617,942 Page 8 Art Unit: 2653 Application/Control Number: 18/617,942 Page 9 Art Unit: 2653 Application/Control Number: 18/617,942 Page 10 Art Unit: 2653
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