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 .
Status of Claims
Claims 1-20 are pending and examined herein per Applicant’s 12/30/2025 submission to the Office.
Claims 1-7, 10, 12-16, 18, and 20 were amended. No claims were canceled, withdrawn or newly added.
Response to Arguments
Applicant's arguments filed 35 USC § 101 have been fully considered but they are not persuasive. Applicant’s arguments were addressed in the 04/29/2026 interview with Applicant’s representative Attorney Boris A. Matvenko.
Response to Amendment
Applicant’s amendments to the claims are sufficient to overcome the 35 USC § 102/103 rejections of the previous Office action.
Claim Objections
Claim 5 and 14 objected to because of the following informalities: Applicant amended the claims to read “upon the the one or more”, see the next to last line in each claim. The second amended “the” is assumed to be an oversight in editing that does not materially effect the Office’s understanding of the claimed limitation. Appropriate correction is required.
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 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea (i.e. certain methods of organizing human activity) without practical application or significantly more when the elements are considered individually and as an ordered combination.
Step 1: Is the claimed invention to a process, machine, manufacture or composition of matter?
Yes, the claims fall within at least one of the four categories of patent eligible subject. Claims 1-9 are to a computer-implemented method; claims 10-17 are to a system; and claims 18-20 are to a non-transitory computer-readable storage medium.
Step 2A, prong 1: Does the claim recite an abstract idea, law or nature, or natural phenomenon?
Yes, the claims are found to recite an abstract idea. Specifically, the abstract idea of certain methods of organizing human activity and mental processes.
Where certain methods of organizing human activity include fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions) (see MPEP § 2106.04(a)(2), subsection II).
Where mental processes relates to concepts performed in the human mind (including an observation, evaluation, judgment, opinion) (see MPEP § 2106.04(a)(2), subsection III).
Claim 1 (as a representative claim) recites the following, where the limitations found to contain elements of the abstract idea are in bold italics:
1. A computer-implemented method, comprising:
selecting, using at least one processor, at least one machine learning model from a plurality of machine learning models based on at least one parameter associated with an electronic document;
extracting, using the at least one processor, one or more document portions from the electronic document the using at least one machine learning model;
identifying, using the at least one processor, one or more entities in the one or more document portions of the electronic document;
sending, using the at least one processor, the one or more entities to a generative artificial intelligence (AI) model, wherein the generative AI model is configured to generate one or more rules defining one or more obligations associated with the one or more entities;
encoding, using the at least one processor, the one or more rules and providing the one or more encoded rules to an obligation management system for executing, the obligation management system is configured to execute the one or more encoded rules to monitor compliance with the one or more obligations by the one or more entities, wherein monitoring of compliance by the obligation management system includes receiving data associated with one or more events from the one or more entities;
detecting, using the at least one processor, an event in the one or more events based on the data received from the obligation management system and identifying at least one rule in the one or more rules corresponding to the detected event;
determining, using the at least one processor, compliance of the detected event with the at least one rule by comparing data associated with the detected event with one or more conditions associated with the at least one rule; and
transmitting, using the at least one processor, an alert representative of a determination of the compliance and generating, in response to the transmitting, a graphical user interface representative of the determination of the compliance of the detected event with the at least one rule.
The instant specification describes the claimed entities as “Obligations may refer to responsibilities and associated actions that each entity (e.g., party to an agreement, specific term/condition in an agreement, specific requirement in the agreement, etc.) must fulfill to comply with a particular agreement.” (Spec. [27]) and “one or more entities (e.g., parties, terms and/or conditions, specific requirements, etc.)” (Spec. [30]). The Office finds that the claimed invention is to the use of generic computing components to implement an agreement – encoding rules base on extracted document data – which is a business process of a commercial or legal interactions. Where the specification discloses “ML model(s) 208 to find and retrieve specific clauses related to shipping, payment, termination, governing law, liabilities, etc. This may allow for generation of one or more rules that may be used for tracking compliance with obligations that may be associated with the agreements” (Spec. [88]). Where the agreement drives what needs to be governed by rules and what needs to be tracked as an obligation. An agreement is a the basis of a legal interactions. The rules generation and obligation tracking is simply the electronic fulfillment or management of the agreement to ensure that it is properly carried out.
Thus the claims fall into the abstract bucket of certain methods of organizing human activity – the organizing of legal/commerical interactions.
Step 2A, prong 2: Does the claim recite additional elements that integrate the judicial exception into a practical application?
No, the claimed invention does not recite additional elements that integrate the abstract idea into a practical application. Where a practical application is described as integrating the abstract idea by applying it, relying on it, or using the abstract idea in a manner that imposes a meaningful limit on it such that the claim is more than a drafting effort designed to monopolize it, see October 2019: Subject Matter Eligibility at p. 11.
The identified judicial exception is not integrated into a practical application. In particular, the claims recites the additional limitations see non-bold-italicized elements above. The send elements are determined to be old and well know functions of a computer.
Where 2106.05(g) MPEP states, “term "extra-solution activity" can be understood as activities incidental to the primary process or product that are merely a nominal or tangential addition to the claim. Extra-solution activity includes both pre-solution and post-solution activity. An example of pre-solution activity is a step of gathering data for use in a claimed process, e.g., a step of obtaining information about credit card transactions, which is recited as part of a claimed process of analyzing and manipulating the gathered information by a series of steps in order to detect whether the transactions were fraudulent. An example of post-solution activity is an element that is not integrated into the claim as a whole, e.g., a printer that is used to output a report of fraudulent transactions, which is recited in a claim to a computer programmed to analyze and manipulate information about credit card transactions in order to detect whether the transactions were fraudulent.”
The Office finds that merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea; adding insignificant extra solution activity to the judicial exception; or only generally linking the use of the abstract idea to a particular technological environment or field is not sufficient to integrate the judicial exception into a practical application.
Step 2B: Does the claim recite additional elements that amount to significantly more than the abstract idea?
No, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception, when considered individually and as part of the ordered combination. The claimed invention is determined to use generic, general-purpose, or off-the-shelf computing components, see Spec [247] and [249].
Where 2106.05(d)(I)(2) of the MPEP states, “A factual determination is required to support a conclusion that an additional element (or combination of additional elements) is well-understood, routine, conventional activity. Berkheimer v. HP, Inc., 881 F.3d 1360, 1368, 125 USPQ2d 1649, 1654 (Fed. Cir. 2018). However, this does not mean that a prior art search is necessary to resolve this inquiry. Instead, examiners should rely on what the courts have recognized, or those in the art would recognize, as elements that are well-understood, routine, conventional activity in the relevant field when making the required determination. For example, in many instances, the specification of the application may indicate that additional elements are well-known or conventional. See, e.g., Intellectual Ventures v. Symantec, 838 F.3d at 1317; 120 USPQ2d at 1359 ("The written description is particularly useful in determining what is well-known or conventional"); Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343, 1348, 115 USPQ2d 1414, 1418 (Fed. Cir. 2015) (relying on specification’s description of additional elements as "well-known", "common" and "conventional"); TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 614, 118 USPQ2d 1744, 1748 (Fed. Cir. 2016) (Specification described additional elements as "either performing basic computer functions such as sending and receiving data, or performing functions ‘known’ in the art.").”
These limitations do NOT offer an improvement to another technology or technical field; improvements to the functioning of the computer itself; apply the judicial exception with, or by use of, a particular machine; effect a transformation or reduction of a particular article to a different state or thing; add a specific limitation other than what is well-understood, routine and conventional in the field, or add unconventional steps that confine the claim to a particular useful application; or other meaningful limitations beyond generally linking the use of the judicial exception to a particular technological environment. Therefore, these additional limitations when considered individually or in combination do not provide an inventive concept that can transform the abstract idea into patent eligible subject matter.
The other independent claims recite similar limitations and are rejected for the same reasoning given above.
The dependent claims do not further limit the claimed invention in such a way as to direct the claimed invention to statutory subject matter.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Varanashi (US 2026/0111769 A1) teaches User uploads professional code document (PDF, text, institutional website) [2668] System extracts rules and requirements [2669] System structures rules with scope metadata (AppliesTo, ExemptWhen conditions) [2670] User reviews and approves rule interpretations [2671] Code becomes available for activation.
Anders et al (US 2022/0058336 A1) teaches requirements may be represented, e.g., by one or more sets of configurable rules, such that each rule may specify valid values or ranges for various data items extracted from the document.
Brisimi et al (US 2020/0125659 A1) teaches techniques for automatically extracting policy rules and requirements from unstructured policy documents and converting them into a formalized computer readable format can initially involve identifying an unstructured representation of a policy rule or requirement included in an unstructured policy document and generating one or more candidate interpretations of the policy rule or requirement.
THIS ACTION IS MADE FINAL. 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 FOLASHADE ANDERSON whose telephone number is (571)270-3331. The examiner can normally be reached Monday to Thursday 12:00 P.M. to 6:00 P.M. CST.
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/FOLASHADE ANDERSON/Primary Examiner, Art Unit 3623
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