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 were previously pending and subject to a final office action mailed 11/14/2025. Claims 1, 10, & 19 were amended in a reply filed 02/17/2026. Claims 1 – 20 are currently pending and subject to the final non-office action below.
Continued Examination Under 37 CFR 1.114
A request for continued examination 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 after final rejection on 02/17/2026 has been entered.
Response to Arguments
Applicant’s arguments filed 02/17/2026 with respect to the previous rejection of the claims under 35 USC 101 have been considered but are not persuasive.
Applicant initially argues, on pg. 11, that the claims are not directed to an abstract idea.
Examiner respectfully disagrees. In particular, the limitations of “determining an accreditation of a review entity of a computing product: for each reduced… document of the second set of electronic documents: calculating an anonymity score of the… document based on publicly available data of the entity; calculating a content specificity score of the… document based on a text analysis of the… document with respect to the computing product; calculating a perspective view score of the… document based on a sentiment of the… document; calculating a usage context score of the… document based on workload mentions within the… document; calculating a reliability score of the… document based on i) the anonymity score of the… document, ii) the content specificity score of the… document, iii) the perspective view score of the… document, and iv) the usage context score of the… document; calculating an acceptance score of the… document based on user-interaction data of a plurality of users with the… document; calculating a credibility score of the… electronic document based on a weighted average of the reliability score and the acceptance score; updating, based on the credibility score of each of the… documents, a product profile of the computing product…; and generating a plurality of permutated layouts of the computing product based on a thermal layout of computing components of the computing product of the product profile; identifying a particular permutated layout of the computing product based on a maximized computing capability of the computing product; and generating a build of the particular permutated layout of the computing product to increase an airflow at the computing product” are processes that, under the broadest reasonable interpretation, cover performance of the limitation in a business relation or commercial interaction, as well as the “Mental Processes,” and “Mathematical concepts” groupings of abstract ideas. That is, the above functions encompass adjusting product profiles based on evaluating the credibility of review sources and generating computing device configurations.
The analysis of gathered industry information to adjust product profiles based on the credibility of review sources would be performed during marketing or sales activities or behaviors, as well as in business relations. Accordingly, the claims recite an abstract idea that falls within the “Certain Methods of Organizing Human Activity.”
The above functions also cover performance of the limitations in the human mind, or by a human using a pen and paper, but for the recitation of generic computer components, and therefore fall within the "Mental Processes" grouping of abstract ideas, which includes concepts performed in the human mind (including an observation, evaluation, judgment, or opinion). The evaluation of authorial credibility of subjective source material (e.g., electronic documents) and evaluation of extracted sentiment could be performed in the human mind, or by a human using a pen and paper, as could the functionality of generating computing device configurations based on a thermal layout of computing components, maximized computing capability, and increasing an airflow at the computing product.
Additionally, the calculating of a content specificity score, perspective view score, usage context score, reliability score, acceptance score, and credibility score covers performance of the limitations within mathematical relationships, mathematical formulas or equations, or mathematical calculations, and therefore falls within the “Mathematical concepts” grouping of abstract ideas.
Accordingly, the claims recite abstract ideas that fall within the “Certain Methods of Organizing Human Activity,” “Mental Processes,” and “Mathematical concepts” groupings of abstract ideas.
Applicant next argues, on pg. 12, that the claim as a whole integrates the judicial exception into a practical application because “Claim 1 is also directed to an improvement in the functioning of a computer, or an improvement to other technology or technical field. Specifically, the claimed invention facilitates improved analysis of electronic documents for further processing.”
Examiner respectfully disagrees that the claims are directed to an improvement in the functioning of a computer, or an improvement to other technology or technical field. In particular, the additional computer-related elements of “computer-implemented,” “information handling system,” “processor,” “memory media storing instructions executable by the processor,” “non-transitory computer-readable medium storing software comprising instructions,” and “one or more computers” are recited at a high-level of generality, such that, when viewed as whole/ordered combination, amount to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)). The additional element of “stored at a storage device” is insignificant, extra-solution activity that is appended to the abstract idea (see MPEP 2106.05(g)). The additional element of “electronic {document}” is recited at a high-level of generality, such that, when viewed as whole/ordered combination, amounts to no more than merely generally linking the judicial exception to a particular technological environment or field of use (see MPEP 2106.04(d)(I) & MPEP 2106.05(h)).
The additional element of “receiving a plurality of electronic documents, each electronic document of the plurality of documents associated with the entity; for each electronic document of the plurality of documents: identifying elements of the electronic document, including scripts; reducing the electronic document by i) removing portions of the electronic document related to headers, footers, navigation panes, and scripts that do not expose functionality of the electronic document and ii) maintaining the elements that expose functionality of the electronic document related to HTML tags, HTML elements, and scripts related to the computing product” is insignificant, pre-solution activity (i.e., data gathering) that is appended to the abstract idea (see MPEP 2106.05(g)), as well as merely generally linking the judicial exception to a particular technological environment or field of use (see MPEP 2106.04(d)(I) & MPEP 2106.05(h)). Furthermore, under Step 2B, this pre-solution activity is similar to functionality found by the courts to be well-understood, routine, and conventional activities (See MPEP § 2106.05(d)(II), noting “Receiving or transmitting data over a network, e.g., using the Internet to gather data,” “Electronically scanning or extracting data from a physical document,” and “Arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price”), and thus does not amount to significantly more.
Furthermore, as per Enfish, “the first step in the Alice inquiry in this case asks whether the focus of the claims is on the specific asserted improvement in computer capabilities (i.e., the self-referential table for a computer database) or, instead, on a process that qualifies as an “abstract idea” for which computers are invoked merely as a tool. As noted infra, in Bilski and Alice and virtually all of the computer-related § 101 cases we have issued in light of those Supreme Court decisions, it was clear that the claims were of the latter type—requiring that the analysis proceed to the second step of the Alice inquiry, which asks if nevertheless there is some inventive concept in the application of the abstract idea.” See Alice, 134 S. Ct. at 2355, 2357–59. In this case, however, the plain focus of the claims is not to an improvement to computer functionality itself, but “on economic or other tasks (i.e., adjusting product profiles based on evaluating the credibility of review sources) for which a computer is used in its ordinary capacity.” The instant claims are directed a judicial exception, which invokes generic computer components as a mere tool for implementation, rather to an improvement thereof. The claims are not directed to an improvement in the functionality of a computing device or other technology; thus, the claims are directed to a judicial exception without significantly more, and the 101 rejection is maintained.
Applicant next argues, on pg. 12, that the claim as a whole integrates the judicial exception into a practical application because “The improvement in the functioning of the computer by the claimed invention includes "generating a plurality of permutated layouts of the computing product based on a thermal layout of computing components of the computing product of the product profile; identifying a particular permutated layout of the computing product based on a maximized computing capability of the computing product; and generating a build of the particular permutated layout of the computing product to increase an airflow at the computing product.".”
Examiner respectfully disagrees that the claims are directed to an improvement in the functioning of a computer, or an improvement to other technology or technical field, because these limitations are a part of the recited judicial exception itself. That is, generating computing device configurations based on a thermal layout of computing components, maximized computing capability, and increasing an airflow at the computing product covers performance of the limitations in the human mind, or by a human using a pen and paper, but for the recitation of generic computer components, and therefore fall within the "Mental Processes" grouping of abstract ideas, which includes concepts performed in the human mind (including an observation, evaluation, judgment, or opinion). Therefore, the claims recite a judicial exception without additional elements that would integrate the recited judicial exception into a practical application.
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 without significantly more.
Step 1
Claims 1 – 9 are directed to a method (i.e., a process). Claims 10 – 18 are directed to a machine (i.e., system). Claims 19 – 20 are directed to a product. Therefore, claims 1 – 20 all fall within the one of the four statutory categories of invention.
Step 2A, Prong One
Independent claims 1, 10, & 19 substantially recite: “determining an accreditation of a review entity of a computing product: for each reduced… document of the second set of electronic documents: calculating an anonymity score of the… document based on publicly available data of the entity; calculating a content specificity score of the… document based on a text analysis of the… document with respect to the computing product; calculating a perspective view score of the… document based on a sentiment of the… document; calculating a usage context score of the… document based on workload mentions within the… document; calculating a reliability score of the… document based on i) the anonymity score of the… document, ii) the content specificity score of the… document, iii) the perspective view score of the… document, and iv) the usage context score of the… document; calculating an acceptance score of the… document based on user-interaction data of a plurality of users with the… document; calculating a credibility score of the… electronic document based on a weighted average of the reliability score and the acceptance score; updating, based on the credibility score of each of the… documents, a product profile of the computing product…; and generating a plurality of permutated layouts of the computing product based on a thermal layout of computing components of the computing product of the product profile; identifying a particular permutated layout of the computing product based on a maximized computing capability of the computing product; and generating a build of the particular permutated layout of the computing product to increase an airflow at the computing product.”
The limitations stated above are processes that, under the broadest reasonable interpretation, cover performance of the limitation in a business relation or commercial interaction as well as in a mathematical calculation. That is, the functions in the context of claims 1, 10, & 19 encompass adjusting product profiles based on evaluating the credibility of review sources and generating computing device configurations. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in a commercial interaction, or while managing personal behavior or relationships or interactions between people, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas e.g., “commercial or legal interactions (including marketing or sales activities or behaviors; business relations, and following rules or instructions).” Also, if a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the human mind, or by a human using a pen and paper, but for the recitation of generic computer components, then it falls within the "Mental Processes" grouping of abstract ideas, which includes concepts performed in the human mind (including an observation, evaluation, judgment, or opinion). Additionally, if a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in mathematical relationships, mathematical formulas or equations, mathematical calculations (e.g., calculating scores), then it falls within the “Mathematical concepts” grouping of abstract ideas. Accordingly, the claims recite abstract ideas that fall within the “Certain Methods of Organizing Human Activity,” “Mental Processes,” and “Mathematical concepts” groupings of abstract ideas.
Step 2A, Prong Two
The judicial exception is not integrated into a practical application. Claims 1, 10, & 19, as a whole, amount to: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent), (ii) adding insignificant extra-solution activity to the judicial exception, as well as (iii) generally linking the recited judicial exception to a particular field or technological environment. Claim 1 recites the additional computer-related element of: “computer-implemented.” Claim 10 recites the additional computer-related elements of: “information handling system,” “processor,” and “memory media storing instructions executable by the processor.” Claim 19 recites the additional computer-related elements of: “non-transitory computer-readable medium storing software comprising instructions” and “one or more computers.” In addition, claims 1, 10, & 19 recite the additional elements of: “electronic {document},” “stored at a storage device,” and “receiving a first set of electronic documents, each electronic document of the first set of electronic documents associated with the entity; training, at a first time, an electronic document crawling model based on the first set of electronic documents, including: for each electronic document of the plurality of documents: identifying elements of the electronic document, including scripts; reducing the electronic document by i) removing portions of the electronic document related to headers, footers, navigation panes, and scripts that do not expose functionality of the electronic document and ii) maintaining the elements that expose functionality of the electronic document related to HTML tags, HTML elements, and scripts related to the computing product; receiving, at a second time after the first time, a second set of electronic documents, each electronic document of the second set of documents associated with the entity; applying the electronic document crawling model to reduce the second set of electronic documents.”
The additional computer-related elements of “computer-implemented,” “information handling system,” “processor,” “memory media storing instructions executable by the processor,” “non-transitory computer-readable medium storing software comprising instructions,” and “one or more computers” are recited at a high-level of generality, such that, when viewed as whole/ordered combination, amount to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
The additional element of “stored at a storage device” is insignificant, extra-solution activity that is appended to the abstract idea (see MPEP 2106.05(g)). Accordingly, this additional element does not integrate the abstract idea into a practical application it does not impose any meaningful limits on practicing the abstract idea.
The additional element of “electronic {document}” is recited at a high-level of generality, such that, when viewed as whole/ordered combination, amounts to no more than merely generally linking the judicial exception to a particular technological environment or field of use (see MPEP 2106.04(d)(I) & MPEP 2106.05(h)).
The additional elements of “receiving a first set of electronic documents, each electronic document of the first set of electronic documents associated with the entity; training, at a first time, an electronic document crawling model based on the first set of electronic documents, including: for each electronic document of the plurality of documents: identifying elements of the electronic document, including scripts; reducing the electronic document by i) removing portions of the electronic document related to headers, footers, navigation panes, and scripts that do not expose functionality of the electronic document and ii) maintaining the elements that expose functionality of the electronic document related to HTML tags, HTML elements, and scripts related to the computing product; receiving, at a second time after the first time, a second set of electronic documents, each electronic document of the second set of documents associated with the entity; applying the electronic document crawling model to reduce the second set of electronic documents” is insignificant, pre-solution activity (i.e., data gathering) that is appended to the abstract idea (see MPEP 2106.05(g)), as well as merely generally linking the judicial exception to a particular technological environment or field of use (see MPEP 2106.04(d)(I) & MPEP 2106.05(h)).
Additionally, the additional elements of “training, at a first time, an electronic document crawling model” and “applying the electronic document crawling model” amount to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Accordingly, the additional elements as recited in claims 1, 10, & 19 of: “computer-implemented,” “information handling system,” “processor,” “memory media storing instructions executable by the processor,” “non-transitory computer-readable medium storing software comprising instructions,” “one or more computers,” “electronic {document},” “stored at a storage device,” and “receiving a first set of electronic documents, each electronic document of the first set of electronic documents associated with the entity; training, at a first time, an electronic document crawling model based on the first set of electronic documents, including: for each electronic document of the plurality of documents: identifying elements of the electronic document, including scripts; reducing the electronic document by i) removing portions of the electronic document related to headers, footers, navigation panes, and scripts that do not expose functionality of the electronic document and ii) maintaining the elements that expose functionality of the electronic document related to HTML tags, HTML elements, and scripts related to the computing product; receiving, at a second time after the first time, a second set of electronic documents, each electronic document of the second set of documents associated with the entity; applying the electronic document crawling model to reduce the second set of electronic documents,” when viewed as a whole/ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Thus, claims 1, 10, & 19 are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent), (ii) adding insignificant extra-solution activity to the judicial exception, as well as (iii) generally linking the recited judicial exception to a particular field or technological environment, and do not provide integration of the recited abstract ideas into a practical application. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)); and (ii) adding insignificant extra-solution activity (e.g., pre-solution activity, such as mere electronic scanning) to the judicial exception (See MPEP2106.05(g)), as well as (iii) generally linking the recited judicial exception to a particular technological environment or field of use (See MPEP 2106.05(I)(A) & MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
The extrasolution activity of “stored at a storage device” is similar to functionality found by the courts to be well-understood, routine, and conventional activities (See MPEP § 2106.05(d)(II), noting “Electronic recordkeeping,” and “Storing and retrieving information in memory”), and thus does not amount to significantly more.
The pre-solution activity of “receiving a first set of electronic documents, each electronic document of the first set of electronic documents associated with the entity; training, at a first time, an electronic document crawling model based on the first set of electronic documents, including: for each electronic document of the plurality of documents: identifying elements of the electronic document, including scripts; reducing the electronic document by i) removing portions of the electronic document related to headers, footers, navigation panes, and scripts that do not expose functionality of the electronic document and ii) maintaining the elements that expose functionality of the electronic document related to HTML tags, HTML elements, and scripts related to the computing product; receiving, at a second time after the first time, a second set of electronic documents, each electronic document of the second set of documents associated with the entity; applying the electronic document crawling model to reduce the second set of electronic documents” is similar to functionality found by the courts to be well-understood, routine, and conventional activities (See MPEP § 2106.05(d)(II), noting “Receiving or transmitting data over a network, e.g., using the Internet to gather data,” “Electronically scanning or extracting data from a physical document,” and “Arranging a hierarchy of groups, sorting information, eliminating less restrictive pricing information and determining the price”), and thus does not amount to significantly more.
Therefore, the additional elements of “computer-implemented,” “information handling system,” “processor,” “memory media storing instructions executable by the processor,” “non-transitory computer-readable medium storing software comprising instructions,” “one or more computers,” “electronic {document},” “stored at a storage device,” and “receiving a first set of electronic documents, each electronic document of the first set of electronic documents associated with the entity; training, at a first time, an electronic document crawling model based on the first set of electronic documents, including: for each electronic document of the plurality of documents: identifying elements of the electronic document, including scripts; reducing the electronic document by i) removing portions of the electronic document related to headers, footers, navigation panes, and scripts that do not expose functionality of the electronic document and ii) maintaining the elements that expose functionality of the electronic document related to HTML tags, HTML elements, and scripts related to the computing product; receiving, at a second time after the first time, a second set of electronic documents, each electronic document of the second set of documents associated with the entity; applying the electronic document crawling model to reduce the second set of electronic documents,” as recited in claims 1, 10, & 19, fail to integrate the recited abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claims adds significantly more (i.e., an inventive concept) to the abstract idea. There is no indication that the combination of elements, taken both individually and as an ordered combination, improves the functioning of a computer or improves any other technology. Thus, the claims are not patent eligible.
Furthermore, dependent claims 2 – 9, 11 – 18, & 20 are merely directed to the particulars of the abstract idea and likewise do not add significantly more to the above-identified judicial exception. The additional element of “video associated with the electronic document” in claims 5 & 14 amounts to no more than merely generally linking the judicial exception to a particular technological environment or field of use (see MPEP 2106.04(d)(I) & MPEP 2106.05(h)). The limitations of the claims, when considered both individually and as an ordered combination, do not transform the abstract idea that they recite into patent-eligible subject matter because the claims simply instruct the practitioner to implement the abstract idea with generic computer components that conduct generic computer functions within a certain field of use, and thus are ineligible.
Conclusion
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/BRYAN J KIRK/Examiner, Art Unit 3628