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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 on 17 August 2026 has been entered.
Response to Amendment
This communication is in response to the amendment filed on 17 August 2026.
Claims 1, 6, 10, 15 and 19 are amended.
Claims 1-20 have been examined.
Response to Arguments
In response to Applicant’s remarks filed on 17 August 2026:
a. Applicant's arguments with respect to the 35 U.S.C. 101 rejections of the pending claims have been fully considered but are not deemed persuasive.
On pages 8-12 of Applicant’s remarks, Applicant argues against the 35 U.S.C. 101 rejections of the pending claims. Applicant argues that claim 1 does not recite an abstract idea under Step 2A, Prong One; does recite a practical application under Step 2A, Prong Two; and/or does recite significantly more than an abstract idea under Step 2B.
The Office respectfully disagrees with the above remarks. With regards to the analysis at Step 2A, Prong One; Applicant asserts that amending the claims to recite a graph database stored in a non-transitory memory of a computer system (emphasis is Applicant’s) renders the operations of defining, selecting, linking, and populating unable to be performed in the human mind (remarks, pages 8-9) and hence the claims are patent eligible. Applicant is advised that “Claims that amount to nothing more than an instruction to apply the abstract idea using a generic computer do not render an abstract idea eligible,” MPEP 2106.05(f) citing Alice Corp., 573 U.S. at 223, 110 USPQ2d at 1983. The claimed “stored in a non-transitory memory of a computer system” is a high-level, generic recitation of computing components performing a generic computing function (i.e. storing information). This is insufficient to render patent ineligible claims eligible. See MPEP 2106.05(f). Claim 1, when interpreted under the broadest reasonable interpretation (BRI), recites a mentally performable abstract idea in the defining, selecting, linking, and populating operations, as detailed below in the claim rejections under 35 U.S.C. 101.
With regards to analysis at Step 2A, Prong Two; Applicant asserts that the newly-added limitation related to “internal-node repeatable graph data structure” is an additional element, beyond the abstract idea, that amounts to more than generic computer implementation and renders the claim patent eligible (remarks, pages 9-10). The Office respectfully disagrees with the above remarks. The newly-added “internal nodes grouped together” limitation is merely a description of a particular data structure. Given that the BRI of the claims encompasses a simple graph database, as detailed below in the claim rejections under 35 U.S.C. 101, a human could, with the aid of pencil and paper, mentally visualize a graph database whose nodes are as described in amended claim 1. Hence, the claimed “defining” limitation of claim 1, including its newly-added “internal nodes grouped together” limitation, is an abstract idea under the “Mental Processes” grouping.
Also with regards to analysis at Step 2A, Prong Two; Applicant asserts a practical application provided by alleged additional elements in the form of the a) non-transitory computer memory and b) the “internal node repeatable graph data structure.” Applicant asserts that these are additional elements and that these additional elements operate in combination with the claimed defining, selecting, linking, and populating to improve the functioning of the graph database itself (remarks, pages 10-11). The Office respectfully disagrees with the above remarks. As set forth above, the claimed non-transitory computer memory is a generic computer component performing the generic computing function of data storage, and the claimed “internal node repeatable graph data structure” is an arrangement of data that could be mentally visualized by a human aided by pencil and paper. Hence, neither of these claim elements can be deemed a practical application. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent generic computer implementation. These claims are directed to an abstract idea, and Applicant’s analogy to Core Wireless (remarks, page 10) is improper.
With regards to Applicant’s analogy to the Enfish ruling (remarks, pages 11-12),
Given that the BRI of the claims encompasses a simple case, as set forth above, a human could, with the aid of pencil and paper, mentally perform the claimed “selecting,” “linking,” and “populating,” as detailed below in the claim rejections under 35 U.S.C. 101. In the Enfish ruling, the Court found the claims at issue to be “directed to a specific improvement to the way computers operate, embodied in the self-referential table” (Enfish, LLC v. Microsoft Corporation, page 12, first full paragraph). The Court added that “Here, the claims are not simply directed to any form of storing tabular data, but instead are specifically directed to a self-referential table for a computer database” (Ibid., page 14, last paragraph, emphasis is the Court’s). In other words, the Enfish ruling was based on a conclusion that the specific data structure recited in the claims was unique to computer databases. In the instant case, Applicant makes no argument for the claimed data structure being unique to computers other than the newly-added limitation of “stored in a non-transitory memory of a computer system.” Barring this limitation, claim 1’s graph database, when interpreted under the BRI, can be fully visualized in the human mind and/or drawn out on a piece of paper. Hence, unlike the self-referentiable table in Enfish, the graph database of instant claim 1 is in no way unique to computers. Claim 1 does not recite an improvement to computer technology but rather broadly recites a data structure that has a history of extensive study and application outside of computer technology1. These claims are not patent eligible.
Claims 10 and 19 recite limitations similar to those of claim 1 and are ineligible under 35 U.S.C. 101 for the same reasons that claim 1 is ineligible, as set forth above.
Claims 2-9, 11-18, and 20 are ineligible under 35 U.S.C. 101 for the same reasons that claims 1, 10, and 19 are ineligible, as set forth above, and for the additional reasons detailed below in the claim rejections under 35 U.S.C. 101.
In addition, on pages 12-13 of Applicant’s remarks, Applicant argues against the 35 U.S.C. 101 rejections of the pending claims. Applicant argues that amended claims 6 and 15 recite a practical application under Step 2A, Prong Two and/or recite significantly more than an abstract idea under Step 2B. In support of this argument, Applicant points to the newly-added limitations of claims 6 and 15 and asserts “The amended claims now recite a particular way of achieving the result rather than the result itself” and “These operations are inherently machine-to-machine and cannot be performed mentally or with pencil and paper” (remarks, page 13).
The Office respectfully disagrees with the above remarks. Claims 6 and 15 recite identifying object categories, defining the nodes and fields for each identified object category, and populating the graph database. Given that the BRI of the claims encompasses a simple case, as detailed below in the claim rejections under 35 U.S.C. 101, a human could, with the aid of pencil and paper, mentally perform the claimed identifying, defining, and parsing operations, as claimed. Hence, these operations are an abstract idea under the “Mental Processes” grouping. Other than the abstract idea limitations, these claims recite the following:
receiving an application programming interface (API) documentation that is as described in the claims; and
using the API to populate the graph database in the manner described in the claims.
With regards to (a), this high-level, generic receipt of API documentation is mere data gathering, which has been deemed by the courts to be insignificant extra-solution activity. See MPEP 2106.05(g). In addition, the courts have deemed receiving data to be well-understood, routine, and conventional activity, as in the following cases: Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015) (storing and retrieving information in memory). See MPEP 2106.05(d)(II). Hence, limitation (a) cannot be deemed a practical application nor an inventive concept. With regards to (b), this limitation is recited at a high level of generality and amounts to mere instructions to apply the abstract idea on a general purpose computer, which cannot provide a practical application nor an inventive concept. See MPEP 2106.05(f). Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent insignificant extra-solution activity; well-understood, routine, and conventional subject matter; and/or generic computer implementation. Hence, the claim as a whole, looking at the additional elements individually and in combination, does not amount to a practical application nor significantly more than the abstract idea. These claims are not patent eligible.
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.
As to claims 1, 10, and 19, these claims recite a “graph database.” The following definitions of the term “database” help clarify the broadest reasonable interpretation (BRI) of this term:
“a usually large collection of data organized especially for rapid search and retrieval2”
“A collection of data arranged for ease and speed of search and retrieval.3”
"A database is an organized collection of structured information, or data, typically stored electronically in a computer system4."
"A database is an organized collection of information that can be searched, sorted, and updated. This data is often stored electronically in a computer system called a database management system (DBMS)5."
Notably, a database is defined as “typically” or “often” being stored electronically, implying that it is not necessarily so. These definitions make clear that the BRI of the term “database” encompasses an organized collection of data/information even if not stored electronically. Hence, the BRI of the term “database” encompasses an organized collection of data/information mentally visualized and/or written out on pieces of paper by a human. Under the BRI, the claimed “graph database” encompasses something as simple as a graph data structure mentally visualized and/or drawn out on a piece of paper. In addition, these claims recite the following:
defining plural templates of the graph database, each of the plural templates corresponding to a respective object category in a process, wherein each of the plural templates including nodes comprising (i) an anchor node defining identifying attributes of an object in the object category of the respective template and (ii) N other nodes linked to the anchor node and respectively defining descriptive attributes of the object in the object category of the respective template, N being a non-negative integer, and wherein the nodes of each respective template are internal nodes grouped together in the graph database as a repeatable graph data structure of the respective template, a node formed for another one of the plural templates being an external node.
The claims do not specify the number of templates or nodes to be defined other than using the plural form of the word (i.e. “templates” and “nodes”), which encompasses just two under the broadest reasonable interpretation (BRI). Under the BRI, the claims encompass a simple case of just two templates, each template having just one anchor node and just two linked nodes. In total, the simple case encompassed by the BRI of the claims has just two templates, just two anchor nodes, and just four linked nodes (i.e. two for each of the two anchor nodes). Furthermore, the claimed defining of templates amounts to no more than a specification, which can be mentally performed by a human with the aid of pencil and paper. For example, a human could mentally visualize a couple of templates and their corresponding nodes, as well as specification of internal and external nodes, as claimed. A human could also draw out these templates and nodes on a piece of paper. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with a pencil and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas.
The claims also recite the following:
selecting a first template of the plural templates to represent a first object corresponding to the object category of the first template and selecting a second template of the plural templates to represent a second object corresponding to the object category of the second template.
The claimed selecting amounts to no more than an evaluation or judgement, i.e. evaluating/judging the templates to select first and second templates as claimed. A human could, with the aid of pencil and paper, mentally perform the claimed selecting; i.e. evaluating/judging the templates to select first and second templates, as claimed. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
The claims also recite the following:
linking the first template of the plural templates to the second template of the plural templates by storing relationship data between a node of the first template and a node of the second template.
A human can mentally perform the claimed linking with the aid of pencil and paper. For example, a human could mentally visualize the first and second templates as being linked based on a relationship between their nodes. A human could also draw out on a piece of paper such a link/relationship. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping.
The claims also recite the following:
populating the first template and the second template by parsing received data of the first object and the second object.
The BRI of the claimed “received data” encompasses a simple dataset having just a few data records. With the aid of pencil and paper, a human could parse this simple dataset and populate the first and second templates in the manner claimed, e.g. by writing down the parsed data in the appropriate locations on the piece of paper having the first and second templates. Hence, this limitation is also an abstract idea under the “Mental Processes” grouping. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. Other than the abstract idea, the claims recite the following:
a) one or more processors; and
b) memory of a computer system storing a graph database and/or instructions;
c) “A non-transitory computer readable medium storing thereon computer executable instructions.”
Limitations (a) through (c) are recited at a high level of generality, i.e. as generic computer components performing generic computing functions. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent generic computer implementation. Hence, the claims as a whole, looking at the additional elements individually and in combination, do not integrate the abstract idea into a practical application. These claims are directed to an abstract idea.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, additional elements (a) through (c) amount to no more than mere field of use limitations and instructions to apply the exception using generic computer components. Mere instructions to apply an exception using conventional computer components and functions cannot provide an inventive concept. Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent generic computer implementation. Hence, the claims as a whole, looking at the additional elements individually and in combination, do not amount to significantly more than the abstract idea. These claims are not patent eligible.
As to dependent claims 2, 4, 9, 11, 13, 18, and 20, these claims merely describe particular types of data objects (claims 2, 11, and 20) or particular node attributes (claims 4, 9, 13, and 18) upon which to apply the invention. This amounts to no more than an attempt to link the abstract idea to a particular field of use and/or technological environment, which cannot provide a practical application nor an inventive concept. See MPEP 2106.05(h).
As to dependent claims 3, 5, 7, 8, 12, 14, 16, and 17, these claims recite anchor nodes (claims 3 and 12), certain types of relationships between templates (claims 5 and 14), selecting the first template by selecting a particular sub-template (claims 7 and 16), or displaying templates based on defined display configurations (claims 8 and 17). However, given that the BRI of the claims encompasses a simple case, as set forth above, nothing in these claims goes beyond what a human could mentally perform with the aid of pencil and paper. Hence, these claims remain directed to an abstract idea without significantly more.
As to dependent claims 6 and 15, these claims recite identifying object categories, defining the nodes and fields for each identified object category, and populating the graph database. Given that the BRI of the claims encompasses a simple case, as set forth above, a human could, with the aid of pencil and paper, mentally perform the claimed identifying, defining, and parsing operations, as claimed. Hence, the operations are an abstract idea under the “Mental Processes” grouping.
Other than the abstract idea limitations, these claims recite:
receiving an application programming interface (API) documentation that is as described in the claims;
using the API to populate the graph database in the manner described in the claims.
With regards to (a), this high-level, generic receipt of API documentation is mere data gathering, which has been deemed by the courts to be insignificant extra-solution activity. See MPEP 2106.05(g). In addition, the courts have deemed receiving data to be well-understood, routine, and conventional activity, as in the following cases: Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network); Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015) (storing and retrieving information in memory). See MPEP 2106.05(d)(II). Hence, limitation (a) cannot be deemed a practical application nor an inventive concept. With regards to (b), this limitation is recited at a high level of generality and amounts to mere instructions to apply the abstract idea on a general purpose computer, which cannot provide a practical application nor an inventive concept. See MPEP 2106.05(f). Looking at the additional elements as a whole adds nothing beyond the additional elements considered individually—they still represent insignificant extra-solution activity; well-understood, routine, and conventional subject matter; and/or generic computer implementation. Hence, the claim as a whole, looking at the additional elements individually and in combination, does not amount to a practical application nor significantly more than the abstract idea. These claims are not patent eligible.
Contact Information
Any inquiry concerning this communication or earlier communications from the examiner should be directed to UMAR MIAN whose telephone number is (571)270-3970. The examiner can normally be reached Monday to Friday, 10 am to 6:30 pm.
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, Tony Mahmoudi can be reached on (571) 272-4078. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/Umar Mian/
Primary Examiner, Art Unit 2163
1 “graph theory, branch of mathematics concerned with networks of points connected by lines…The history of graph theory may be specifically traced to 1735, when the Swiss mathematician Leonhard Euler solved the Königsberg bridge problem.”
“graph theory.” Encyclopaedia Britannica. Published 23 May 2025 by Encyclopaedia Britannica, Inc. Accessed 6 Jan 2026 from https://www.britannica.com/topic/graph-theory
“The study of graphs is known as graph theory, and was first systematically investigated by D. König in the 1930s.”
Weisstein, Eric W. "Graph." From MathWorld--A Wolfram Web Resource. Accessed 16 June 2025 from https://mathworld.wolfram.com/Graph.html
2 “Database.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/database. Accessed 9 Jun. 2026.
3 “Database.” The American Heritage® Dictionary of the English Language, Fifth Edition copyright ©2022 by HarperCollins Publishers. Accessed 9 Jun. 2026.
4 "What Is a Database?" Published 4 Nov 2020 by Oracle.com. Accessed 9 June 2026 from https://www.oracle.com/database/what-is-database/
5 "What Is a Database?" Published 1 Dec 2025 by Coursera.org. Accessed 9 June 2026 from https://www.coursera.org/articles/what-is-database
