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 .
Response to Amendment
This communication is in response to the amendment filed on 26 March 2026.
No claims are canceled.
No claims are amended.
Claims 1-20 have been examined.
Response to Arguments
In response to Applicant’s remarks filed on 26 March 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 7-14 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. Applicant lists the operations performed by claim 1 with regards to “plural templates of the graph database,” i.e. defining, selecting, linking, and populating the templates. Applicant then summarily concludes that “A human cannot define a multi-node template architecture in a graph database, link templates by storing inter-node relationship data, and parse received data to automatically populate template attributes without using a machine” (remarks, paragraph spanning pages 7-8). Applicant is advised of the following:
“Claims in a pending application must be ‘given their broadest reasonable interpretation consistent with the specification.’” MPEP § 2111 citing Phillips v. AWH Corp., 415 F.3d 1303, 1316, 75 USPQ2d 1321, 1329 (Fed. Cir. 2005)..
With regards to subject matter eligibility analysis, “It is essential that the broadest reasonable interpretation (BRI) of the claim be established prior to examining a claim for eligibility. The BRI sets the boundaries of the coverage sought by the claim and will influence whether the claim seeks to cover subject matter that is beyond the four statutory categories or encompasses subject matter that falls within the exceptions.” MPEP 2106(II).
“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.
In making the conclusory statement “A human cannot…”, Applicant has failed to construe the claims under the broadest reasonable interpretation (BRI). Instant claim 1 recites a “graph database.” The following definitions of the term “database” help clarify the BRI of this term:
“a usually large collection of data organized especially for rapid search and retrieval1”
“A collection of data arranged for ease and speed of search and retrieval.2”
"A database is an organized collection of structured information, or data, typically stored electronically in a computer system3."
"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)4."
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 a simple graph data structure mentally visualized and/or drawn out on paper. These claims also 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.
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 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. Given that the BRI of the claims encompasses a simple case, as set forth above, a human can mentally perform the claimed “selecting,” “linking,” and “populating,” as detailed below in the claim rejections under 35 U.S.C. 101. Hence, the claimed “defining,” “selecting,” “linking,” and “populating” are abstract ideas under the “Mental Processes” grouping.
Applicant further argues that the Office has improperly interpreted the BRI of the claimed “graph database” to be “unreasonably broad and inconsistent with the specification” (remarks, page 8 last paragraph). Applicant asserts that “The specification of the present application unambiguously describes a "graph database" as a machine-implemented data structure” (remarks, page 9, third paragraph). In support of this argument, Applicant cites para. 0004 and 0018 of Applicant’s published specification as teaching “that graph databases are computer-based systems” (Ibid.). Applicant also cites para. 0028-0029 of the published specification and the abstract as “describ[ing] the invention as providing a technical solution operating within this machine-implemented graph database environment” (Ibid.). Notably, Applicant’s remarks highlight what the instant specification describes (Applicant’s wording), as opposed to focusing the remarks on what the instant specification defines as the meaning of a “graph database.” Applicant’s specification defines a “graph database” as follows:
“A data store that uses graph theory to organize data as relations between objects is known as a “graph database.” In a graph database, data items are generally represented by nodes and relationships between the data items are generally represented by links.”
Applicant’s published specification, para. 0003, emphasis added.
Nothing in this definition limits a graph database to be a machine-implemented data structure, as Applicant alleges. To the contrary, the above definition of “graph database” encompasses any store of data that uses graph theory to organize data in the manner claimed. Furthermore, it is important to note that graph data structures comprised of nodes and edges (a.k.a. “connections” or “linkages”) such as the one recited in claim 1 have been the subject of theoretical study in mathematics for decades prior to the modern computer era5. As set forth above, the BRI of the term “database” encompasses an organized collection of data/information, including non-electronic forms of storage (e.g. mental visualization and/or pencil and paper). Therefore, the BRI of the claimed “graph database” set forth by the Office is both consistent with the definition of this term as explicitly stated in Applicant’s own specification and as the term is used in the relevant scientific fields. Furthermore, “Though understanding the claim language may be aided by explanations contained in the written description, it is important not to import into a claim limitations that are not part of the claim. For example, a particular embodiment appearing in the written description may not be read into a claim when the claim language is broader than the embodiment.” Superguide Corp. v. DirecTV Enterprises, Inc., 358 F.3d 870, 875, 69 USPQ2d 1865, 1868 (Fed. Cir. 2004). See also Liebel-Flarsheim Co. v. Medrad Inc., 358 F.3d 898, 906, 69 USPQ2d 1801, 1807 (Fed. Cir. 2004). See MPEP § 2111.01. Hence, the fact that the specification describes certain machine implementations of a graph database does not limit the claim interpretation because said descriptions do not constitute a limiting definition. In conclusion, the BRI of the claimed “graph database” encompasses a simple graph data structure mentally visualized by a human or drawn out on a piece of paper, and accordingly, claim 1 recites an abstract idea as detailed below in the claim rejections under 35 U.S.C. 101.
With regards to the analysis under Step 2A, Prong Two; Applicant asserts that “independent claim 1 is directed to a practical application: the structured creation, linking, and population of graph database objects using defined template architectures” (remarks, paragraph spanning pages 11-12). Applicant also asserts that “the specific ordered combination of template definition with anchor and descriptive nodes, inter-template linking via stored node relationship data, and automated template population through data parsing produces a concrete technological improvement to graph database functionality: it transforms the database from an unstructured collection of individually-accessed nodes and links into a structured, template-driven system capable of efficient object instantiation and relational modeling” (remarks, page 13, first full paragraph). Applicant is advised that “It is important to note, the judicial exception alone cannot provide the improvement. The improvement can be provided by one or more additional elements…In addition, the improvement can be provided by the additional element(s) in combination with the recited judicial exception.” MPEP 2106.05(a) (emphasis added). As detailed below in the claim rejections under 35 U.S.C. 101, the “defining,” “selecting,” “linking,” and “populating” of claim 1 are all mentally performable abstract idea limitations. Also as detailed below in the claim rejections under 35 U.S.C. 101, the claims recite additional elements that are generic computer components (e.g. “computer,” “one or more processors,” etc.) recited at a high level of generality. These generic computer components amount 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). Hence, Applicant’s purported practical application consists entirely of abstract idea limitations, and the recitation of the generic computing components amounts to mere instructions to implement the abstract idea on a computer. Implementing an abstract idea on a generic computer does not integrate the abstract idea into a practical application in Step 2A Prong Two. See MPEP 2106.05(f).
Applicant also makes analogy to the Enfish ruling (remarks, page 12). 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, claim 1’s “graph database” is in no way unique to computers. To the contrary, graph data structures comprised of nodes and edges (a.k.a. “connections” or “linkages”) such as the one recited in claim 1 have been the subject of theoretical study in mathematics for decades prior to the modern computer era6. Hence, contrary to Applicant’s assertion, instant claim 1 is not unique to the operation of computing systems, and analogy to Enfish is improper. 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 technology.
With regards to the analysis under Step 2B, Applicant asserts that “The subject matter of the claims is rooted in computer technology in order to overcome problems specifically arising in the realm of graph databases, which qualifies the claims as patent-eligible subject matter” (remarks, page 13, last full paragraph). For the reasons, set forth above, the subject matter of claim 1 is not rooted in computer technology. When interpreted under the BRI, claim 1’s “graph database” encompasses a simple data structure that can be mentally visualized by a human being and can be drawn out on a piece of paper. For this simple data structure encompassed by the BRI of the claim, claim 1’s “defining,” “selecting,” “linking,” and “populating” limitations can be mentally performed by a human with the aid of pencil and paper. Claim 1’s recitation of “one or more processors” (and similar generic computer components recited by other claims, as detailed below in the claim rejections under 35 U.S.C. 101) amounts to mere instructions to apply the abstract idea on a generic computer, which cannot be deemed an inventive concept. See MPEP 2106.05(f). Claim 1 is 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 page 14 of Applicant’s remarks, Applicant asserts the following:
“Dependent claim 6 requires machine-parsing of machine-readable API documentation (e.g., Graph QL or RESTful APIs to automatically generate the plural templates and to populate the graph database via programmatic API calls, including synchronization with an external system. Dependent claim 6 requires specific computer functionality-protocol-driven ingestion and automated network transactions-beyond pencil-and-paper, thereby integrating the exception into a practical application.”
Remarks, page 14, third full paragraph.
The Office respectfully disagrees with the above remarks. Claim 6 recites features for utilizing an application programming interface (API) to populate the database. These features are recited at a high level of generality and the language of this claim is results-oriented language. For example, claim 6 recites “defining the
plural templates based on the API document” and “using the API to populate the graph database,” but claim 6 does not recite how said defining and populating are performed. Claim 6 covers all ways of achieving the desired result and hence is directed to the idea of a solution rather than a specific, technical process for achieving the solution. “Indeed, the claim language here provides only a result-oriented solution, with insufficient detail for how a computer accomplishes it. Our law demands more. See Elec. Power Grp., 830 F.3d at 1356 (cautioning against claims “so result focused, so functional, as to effectively cover any solution to an identified problem”).” Intellectual Ventures I v. Capital One Fin. Corp., 850 F.3d 1332, 121 USPQ2d 1940 (Fed. Cir. 2017). Therefore, claim 6 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).
b. Applicant's arguments with respect to the 35 U.S.C. 103 rejections of the pending claims are deemed persuasive, and accordingly, these rejections are withdrawn.
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 retrieval7”
“A collection of data arranged for ease and speed of search and retrieval.8”
"A database is an organized collection of structured information, or data, typically stored electronically in a computer system9."
"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)10."
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.
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 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 can mentally perform the claimed selecting—i.e. evaluating/judging the templates to select first and second templates as claimed—with the aid of pencil and paper. 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) a memory storing 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 features for utilizing an application programming interface (API) to populate the database. These features are recited at a high level of generality and the language of these claims is results-oriented language. For example, claim 6 recites “defining the plural templates based on the API document” and “using the API to populate the graph database,” but claim 6 does not recite how said defining and populating are performed. These claims cover all ways of achieving the desired result and hence are directed to the idea of a solution rather than a specific, technical process for achieving the solution. “Indeed, the claim language here provides only a result-oriented solution, with insufficient detail for how a computer accomplishes it. Our law demands more. See Elec. Power Grp., 830 F.3d at 1356 (cautioning against claims “so result focused, so functional, as to effectively cover any solution to an identified problem”).” Intellectual Ventures I v. Capital One Fin. Corp., 850 F.3d 1332, 121 USPQ2d 1940 (Fed. Cir. 2017). Therefore, these claims amount 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).
Conclusion
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.
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 “Database.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/database. Accessed 9 Jun. 2026.
2 “Database.” The American Heritage® Dictionary of the English Language, Fifth Edition copyright ©2022 by HarperCollins Publishers. Accessed 9 Jun. 2026.
3 "What Is a Database?" Published 4 Nov 2020 by Oracle.com. Accessed 9 June 2026 from https://www.oracle.com/database/what-is-database/
4 "What Is a Database?" Published 1 Dec 2025 by Coursera.org. Accessed 9 June 2026 from https://www.coursera.org/articles/what-is-database
5 “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
6 “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
7 “Database.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/database. Accessed 9 Jun. 2026.
8 “Database.” The American Heritage® Dictionary of the English Language, Fifth Edition copyright ©2022 by HarperCollins Publishers. Accessed 9 Jun. 2026.
9 "What Is a Database?" Published 4 Nov 2020 by Oracle.com. Accessed 9 June 2026 from https://www.oracle.com/database/what-is-database/
10 "What Is a Database?" Published 1 Dec 2025 by Coursera.org. Accessed 9 June 2026 from https://www.coursera.org/articles/what-is-database
Prosecution Insights