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 in response to the communication filed on May 26, 2026.
Claims 1-10 are pending in this action.
The applicant’s arguments with respect to claims 1-10 have been fully considered but they are not deemed to be persuasive. For examiner’s response to the applicant’s arguments or comments, see the detailed discussion in the Response to the Arguments section.
Response to Arguments
Applicant's arguments filed on May 26, 2026 have been fully considered but they are not persuasive.
The applicant’s argument regarding rejection under 35 U.S.C. §101 as follows:
"Large action model (LAM)" is "powered by artificial intelligence and trained to interact with applications and/or devices without most if not all of the manual steps required in the conventional ways of using these applications and/or devices." (See paragraph [0064] of the published application, emphasis added).
The same paragraph further explains "Typically, a user needs to manually select an application (e.g., a ride hailing application) on his device and input a number of parameters (e.g., pick up location, destination, vehicle type, scheduled time for the ride) to complete the task. Sometime, the application requires authentication and payment verification, which further complicates the process. A different task (e.g., purchasing movie tickets) would require user's manual interaction with a different application that may be designed very differently from the ride hailing application. The LAM enables a much simpler way for the user to interact with these applications by automating most if not all of the steps typically performed manually by the user."
The claims therefore recite a specific technological architecture in which executable code generated by a trained action model is executed to instantiate an agent host that performs interactions with an application instead of a human user. Such operations are rooted in computer technology and cannot practically be performed in the human mind or with pen and paper.
The Office Action oversimplifies the claims by characterizing them merely as "generating executable code." However, the Federal Circuit has repeatedly warned against describing claims at an unduly high level of abstraction untethered from the actual claim language. See, e.g., Enfish, LLC V. Microsoft Corp. and McRO, Inc. V. Bandai Namco Games America Inc.
Here, claim 1 is directed to a specific improvement in automated application interaction through the use of a trained large action model and dynamically initialized agent host infrastructure. The claimed invention enables automated execution of application interactions based on user intention without requiring manually authored automation scripts or predefined workflows. This constitutes a technological improvement in human-computer interaction and automated software control. The Office Action further asserts that the claims merely recite generic computer implementation. Applicant respectfully disagrees. The claimed large action model is not recited merely as a generic computer component. Rather, the LAM is specifically trained using demonstrations to interact with applications and generates executable code that is executed to initialize an agent host. The ordered combination of the recited limitations provides a non- conventional arrangement for automated software interaction.
For at least the reasons discussed above, claim 1 and its dependent claims are directed to patent-eligible subject matter under 35 U.S.C. § 101.
The Examiner’s response:
The examiner disagrees with applicant’s arguments because of the following reasons:
1) the applicant’s claim is drawn to a process (a series of steps or acts), steps are recited, training a large action model (LAM) to interact with the application using demonstrations; receiving a user intention; generating, by the LAM, executable code in response to the user intention; and executing the executable code to initialize an agent host configured to interact with the application.
The claim does not put any limitation as to how the training of the LAM is performed, how by the LAM, an executable code is generated (technical way) in response to the user interaction (mantel step); and executing the executable code to initialize an agent host configured to interact with the application (another mental step).
These steps are all recited as being performed by an operating system that is a computer. The recited computer is recited at a high level of generality, i.e., as a generic computer performing generic computer functions.
Claim Interpretation: Under the broadest reasonable interpretation, the terms of the claim are presumed to have their plain meaning consistent with the specification as it would be interpreted by one of ordinary skill in the art. See MPEP 2111.
2) This judicial exception is not integrated into a practical application because claims broadly recite the result (training a large action model (LAM), generating, by LAM, executable code and executing the executable code), rather than sufficiently claiming a technical means of achieving the result. See Two-Way Media Ltd. V. Comcast Cable Commons, LLC, 874 F.3d 1329, 1337 (Fed. Cir. 2017) ("The claim requires the functional results but does not sufficiently describe how to achieve these results in a non-abstract way.").
The claims recite a Judicial exception relating to "generating, by LAM, executable code, along with a generic LAM that simply used as tool to implement the abstract idea". Here the claims do not change the underlying or other technology, rather the claimed techniques playing using LAM as pedagogical tool. The claimed additional elements - - large action model - -"merely use a computing as a tool to perform an abstract idea" or "do no more than generally link the use of a judicial exception to a particular technological environment." Memorandum, 84 Fed. Reg. at 55; see Customedia Techs., LLC V. Dish Network Corp., No. 2018-2239, 2020 WL 1069742, at *3 (Fed. Cir. Mar. 6, 2020) ("We have held that it is not enough, however, to merely improve a fundamental practice or abstract process by invoking a computer merely as a tool.").
According to MPEP 2106.04(d)(1), a claim is not directed to the judicial exception if claim recites additional elements that includes the components or steps of the invention that provide the improvement, which would integrated the judicial exception into a practical application. Therefore, according to MPEP 2106.05, pending claims do not integrate a judicial exception into a practical application (“The courts have also identified limitations that did not integrate a judicial exception into a practical application:
• Merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f);
• Adding insignificant extra-solution activity to the judicial exception, as discussed in MPEP § 2106.05(g); and
• Generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h).”). The claim is not patent eligible.
For at least the reasons discussed above, the examiner believes that the claim 1 and its dependent claims are directed to patent-ineligible subject matter under 35 U.S.C. § 101.
The applicant’s argument regarding rejection under 35 U.S.C. §102 as follows:
Applicant respectfully traverses the anticipation rejection based on Gandhi. To anticipate a claim under §102, a single reference must disclose every claim limitation arranged as in the claim. Gandhi fails to disclose at least the following limitations of claim 1.
First, Gandhi fails to disclose "training a large action model (LAM) to interact with the application using demonstrations" The Office Action equates Gandhi's alleged "LLM" with the claimed "LAM." However, a large language model is not the same as a large action model. The claimed LAM is specifically trained to perform application interactions using demonstrations. A large action model is fundamentally directed to executable action generation and application interaction behavior, rather than merely natural language processing. Gandhi's disclosure concerning an LLM processing natural language commands does not disclose or necessarily imply: a large action model trained through demonstrations; or training the model to interact with an application using demonstrations.
Second, Gandhi fails to disclose "executing the executable code to initialize an agent host configured to interact with the application." The Office Action cites paragraph [0029] of Gandhi for this limitation. However, Applicant respectfully submits that Gandhi does not disclose executing generated executable code to initialize an agent host as claimed. Rather, Gandhi appears to disclose using an LLM to interpret commands or generate automation-related outputs. Such disclosures are materially different from the claimed architecture in which generated executable code is executed to initialize an agent host configured for application interaction. The claimed "agent host" is a specific structural and functional component that is absent from Gandhi. The cited portions of Gandhi therefore fail to disclose the claimed training limitation.
For at least the reasons provided above, the rejection of claim 1 and its dependent claims 2-9 under 35 U.S.C. 102 should be withdrawn.
The Examiner’s response:
The application’s arguments that a large language model is not same as a large action model, is not persuasive, because applicant’s LAM and reference’s LLM are works similarly, therefore LAM and LLM are same.
Gandhi's disclosure concerning an LLM processing natural language commands does disclose: a large action model trained through demonstrations; or training the model to interact with an application using demonstrations (see paragraph 0068).
Gandhi does disclose executing generated executable code to initialize an agent host as claimed (Paragraph 0068, and 0090-0091).
The examiner believes that the Gandhi discloses claimed limitations.
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 1-10 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claim(s) recite(s) an abstract idea of generating, by LAM, executable code. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the claims directed to an abstract idea of generating, by LAM, executable code. The claim is drawn to process (a series of steps or acts) that similar to an idea 'Of itself such as an instantiated concept, plan or scheme, as well as a mental process (thinking) that "can be performed in the human mind, or by a human using a pen and paper'.
The claim does not require that the method be implemented by a particular machine. The method does not require a particular transformation of a particular article. There is not transformation of a physical objects or data into a different state or thing. This generating, by LAM, executable code is similar to delivering user-selected media content to a portable devices found by the courts to be abstract idea (Affinity Labs of Tex., LLC V. Amazon.com Inc., 120 USPQ2d 1210 (Fed. Cir. 2016)) and also displaying certain results of the collection and analysis found by the courts to be abstract idea (Elec. Power Grp., LLC V. Alstom S.A., 119 USPQ2d 1739 (Fed. Cir. 2016).
This judicial exception is not integrated into a practical application because claims broadly recite the result (training a large action model, generating, by LAM, executable code and executing the executable code), rather than sufficiently claiming a technical means of achieving the result. See Two-Way Media Ltd. V. Comcast Cable Commons, LLC, 874 F.3d 1329, 1337 (Fed. Cir. 2017) ("The claim requires the functional results but does not sufficiently describe how to achieve these results in a non-abstract way.").
The claims recite a Judicial exception relating to " training a large action model, generating, by LAM, executable code, along with a generic operating system that simply used as tool to implement the abstract idea". Here the claims do not change the underlying or other technology, rather the claimed techniques playing using operating system as pedagogical tool. The claimed additional elements - -operating system- -"merely use a computing as a tool to perform an abstract idea" or "do no more than generally link the use of a judicial exception to a particular technological environment." Memorandum, 84 Fed. Reg. at 55; see Customedia Techs., LLC V. Dish Network Corp., No. 2018-2239, 2020 WL 1069742, at *3 (Fed. Cir. Mar. 6, 2020) ("We have held that it is not enough, however, to merely improve a fundamental practice or abstract process by invoking a computer merely as a tool.").
Accordingly, claims 1-10 do not integrate the judicial exception into a practical application. See Memorandum, 84 Fed. Reg. at 54. As the claim recites a judicial exception and fails to integrate the exception into a practical application, the claim is "directed to the judicial exception." Id. at 54.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements are simply a generic operating system. The claim amounts to no more than training a large action model, and generating, by LAM, executable code. Taking the claimed elements either individually or as ordered combination, that transform claims into patent-eligible application, since claims merely recite use of already existing computer-based generating, by LAM, executable code, and there is no "inventive concept" in play using LAM well- understood, routine, and conventional activities commonly used in industry of teaching, since claims, at most, attempt to limit abstract idea to particular technological environment, and such limitation has been held insufficient to save claims in this context, and since dependent claims are not rendered patent-eligible by recitation of additional steps, such as video recording or document object model; demonstrations originate from user; LAM to interact with the application, even though additional limitations may narrow scope of claims. The claim as a whole does not amount to significantly more than the abstract idea itself. Accordingly, claims 1-10, are ineligible.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claim(s) 1-9 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Gandhi et al. (US 2024/0378399).
As per claim 1, Gandhi discloses, a method of emulating a user's interactions with an application, the method comprising:
training a large action model (LAM) to interact with the application using demonstrations (Paragraphs 0002 and 0068, here claimed "LAM" is "LLM");
receiving a user intention (Paragraph 0004, natural language command is "user intention");
generating, by the LAM, executable code in response to the user intention (Paragraphs 0029 and 0068, executable code is generated by LLM); and
executing the executable code to initialize an agent host configured to interact with the application (Paragraphs 0029 and 0090-0091)).
As per claim 2, Gandhi discloses, wherein demonstrations comprise a video recording or a document object model (DOM) change stream (Paragraph 0030).
As per claim 3, Gandhi discloses, wherein the demonstrations originate from a user or an external labeling force (Paragraph 0029).
As per claim 4, Gandhi discloses, wherein training the LAM to interact with the application using the demonstrations comprises converting the demonstrations into intermediate representations (IRs) (Paragraph 0029).
As per claim 5, Gandhi discloses, wherein the IRs comprise one or more of UI definitions, classifications, and VRDs (Paragraph 0029).
As per claim 6, Gandhi discloses, wherein the user intention comprises a sequence of UI actions on the application (Paragraph 0029).
As per claim 7, Gandhi discloses, wherein the agent host comprises a containerized environment (Paragraph 0095).
As per claim 8, Gandhi discloses, wherein initializing the agent host comprises implementing the containerized environment as a Docker container or a Virtual Machine (VM) (Paragraph 0095).
As per claim 9, Gandhi discloses, wherein the containerized environment comprises a runtime environment for the executable code (Paragraph 0029).
Claim Rejections - 35 USC § 103
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.
Claim(s) 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Gandhi et al. (US 2024/0378399) as applied to claim 1 above, and further in view of Brunet et al. (US 2014/0195965).
As per claim 10, Ghandhi does not explicitly disclose, but Brunet discloses, wherein the agent host is configured to emulate the signature of a user device, the signature comprising one or more of login session, IP, and request header (Paragraph 0088).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the invention of Gandhi by including signature comprising a login session as taught by Brunet so as to system provides integrated user administration, event management and report capability (Abstract).
Conclusion
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.
Contact Information
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Abul K. Azad whose telephone number is (571) 272-7599. If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Bhavesh Mehta, can be reached at (571) 272-7453.
Any response to this action should be mailed to:
Commissioner for Patents
P.O. Box 1450
Alexandria, VA 22313-1450
Or faxed to: (571) 273-8300.
Hand-delivered responses should be brought to 401 Dulany Street, Alexandria, VA-22314 (Customer Service Window).
Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free).
June 27, 2026
/ABUL K AZAD/Primary Examiner, Art Unit 2656
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