DETAILED ACTION
This action is in response to the amendment filed 17 February 2026.
Claims 1 – 20 are pending and have been examined.
This action has been made FINAL.
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 Arguments
35 USC 101
Applicant's arguments filed 17 February 2026 have been fully considered but they are not persuasive.
Applicant argues “Applicant respectfully submits that, inter alia, the claim limitations cannot practically be performed in the human mind, and therefore do not recite a mental process. "Claims do not recite a mental process when they do not contain limitations that can practically be performed in the human mind, for instance when the human mind is not equipped to perform the claim limitations."…For example, the limitations of the claims are not practically performed in the human mind because the limitations of the claims-such as decomposing the set of context values into one or more context documents, and storing a decomposed fab process record-involve intricate computations that occur at a scale and complexity that exceed the natural capabilities of human cognition”. Examiner respectfully disagrees.
Here, none of the alleged complexities of the claimed invention, such as “decomposing the set of context values into one or more context documents, and storing a decomposed fab process record-involve intricate computations that occur at a scale and complexity that exceed the natural capabilities of human cognition” are recited in Applicant’s claims. It merely recites the step of decomposing records, which, according to Applicant’s disclosure, amounts to decomposing or separating a record into three separate categories (paragraph [0030]). Further, storing data is an additional element (which is merely insignificant extra solution activity).
Applicant argues “Additionally, even if, arguendo, the claims recite a judicial exception (which Applicant asserts they do not), the claims as a whole are patent eligible when the judicial exception is integrated into a practical application of that exception. M.P.E.P. § 2106.04(d)(I). Here, the claims are directed to improvements in managing data produced by a semiconductor fabrication plant ( or multiple plants). Specifically, the claims are directed to improvements in storing data, comprising measured data and data and context data, from semiconductor fabrication plants by decomposing the context data into context documents based on the type of context value. Accordingly, the system is able to utilize context values to "quickly infer inventory-style information (e.g., listing unique recipes) or quickly query based on the structure of the context (e.g., using distinct keys over all context values 206)." See Specification, [0028]”. Examiner respectfully disagrees.
Applicant has not shown how the claimed invention itself, which merely uses generic computer hardware to receive data, decompose (e.g., separate) data based on context, and then storing the data, provides any of the alleged improvements as recited in paragraph [0028] and argued by Applicant. See MPEP 2106.05(a)- “After the examiner has consulted the specification and determined that the disclosed invention improves technology, the claim must be evaluated to ensure the claim itself reflects the disclosed improvement in technology. Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307, 1316, 120 USPQ2d 1353, 1359 (Fed. Cir. 2016)”.
Further, as stated by the Court in Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 115 U.S.P.Q.2d 1636 (Fed. Cir. 2015) – “Nor, in addressing the second step of Alice, does claiming the improved speed or efficiency inherent with applying the abstract idea on a computer provide a sufficient inventive concept. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted))”.
Applicant argues “Moreover, assuming, arguendo, that the claims are directed to a judicial exception (which Applicant asserts they do not), the claims recite significantly more than the abstract idea itself. The Office Action alleges that the "Applicant's specification, at, e.g., paragraphs [0041]-[0049], provides evidence of generic computer hardware performing generic, well-known computer functions." Office Action, at 5. The Office Action's analysis assumes that signal-processing innovations are ineligible under Section 101 absent novel hardware. That premise is unsupported by current U.S. law and the M.P.E.P. Further, the fab record management computing system 102 (FIG. 1 of the present application) contains improvements to the functioning of various computing devices or collection of computer hardware, which render the the specific components are configured to store decomposed records from fab plants in a way that increases efficiency of storage usage while also increasing the speed of queries for information, in such a way that the claims are patent eligible under well-established case law. See, e.g., Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335-36, 118 USPQ2d 1684, 1689 (Fed. Cir. 2016); McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299, 1314-16, 120 USPQ2d 1091, 1102-03 (Fed. Cir. 2016); Visual Memory, LLC v. NVIDIA Corp., 867 F.3d 1253, 1259-60, 123 USPQ2d 1712, 1717 (Fed. Cir. 2017). Here, for example, the system has increased compute efficiency (e.g., reduced processing loads, reduced storage requirements, and/or reduced compute overhead) over that of conventional systems for storing and retrieving fabrication plant data that implement relational database or document-oriented organization. Instead of representing the context documents as mutable files within the decomposed fab process record, the decomposed fab process record may include a representation of the measured values and the context documents (e.g., to the associated immutable document instead of including the information itself or a reference to a mutable document). See Specification at [0038]. This allows the system to conserve storage space and improve the database searching speed. Examiner respectfully disagrees.
While Applicant argues that “the Office Action's analysis assumes that signal-processing innovations are ineligible under Section 101 absent novel hardware”, this is not the purpose of step 2B of the eligibility analysis; it is to search for an inventive concept, and to see if the claim elements amount to significantly more than the judicial exception itself. While Applicant further argues that “Further, the fab record management computing system 102 (FIG. 1 of the present application) contains improvements to the functioning of various computing devices or collection of computer hardware, which render the the specific components are configured to store decomposed records from fab plants in a way that increases efficiency of storage usage while also increasing the speed of queries for information, in such a way that the claims are patent eligible under well-established case law”, the additional elements analyzed in step 2B do not provide any of these said improvements. The additional elements analyzed in Step 2B provide for no more than applying the judicial exception using generic computer hardware. This is explicitly supported by Applicant’s specification, at paragraph [0041], which states that “The illustrated fab record management computing system 102 may be implemented by any computing device or collection of computing devices, including but not limited to a desktop computing device, a laptop computing device, a mobile computing device, a server computing device, a computing device of a cloud computing system, and/or combinations thereof”. The use of a generic computer, in and of itself, does not amount to significantly more, nor does Applicant’s claims provide for any of the alleged improvements, e.g. the system has increased compute efficiency (e.g., reduced processing loads, reduced storage requirements, and/or reduced compute overhead) over that of conventional systems for storing and retrieving fabrication plant data that implement relational database or document-oriented organization. Instead of representing the context documents as mutable files within the decomposed fab process record, the decomposed fab process record may include a representation of the measured values and the context documents (e.g., to the associated immutable document instead of including the information itself or a reference to a mutable document), as argued by Applicant1.
Further, it is unclear what ‘signal processing’ is occurring in the claim, as it is merely employing a computer to ‘decompose’ documents and store documents.
The 35 USC 101 rejection of the amended claims is maintained.
35 USC 103
Applicant’s arguments, see page 12, filed 17 February 2026, with respect to the 35 USC 103 rejections of the claims have been fully considered and are persuasive. The 35 USC 103 rejection of claims 1, 2, and 4 has been 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 non-statutory subject matter. The claimed invention, when the claims are taken as a whole, is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 1: The claims recite a process and non-transitory computer readable medium. (Step 1: YES).
Step 2A – 1: The claims recite a Judicial Exception. Exemplary independent claim 1 recites the limitations of: receiving, by a computing system, an incoming data record generated by a semiconductor fabrication plant, wherein the incoming data record includes at least one measured value and a set of context values [i.e., data gathering];
decomposing, by the computing system, the set of context values into one or more context documents based on the type of context value; and
storing, by the computing system in a data store, a decomposed fab process record that includes a representation of the at least one measured value and the one or more context documents [i.e., saving data].
This limitation (bolded and italicized), as drafted, is a process that, under its broadest reasonable interpretation, covers mental process groupings of abstract ideas because it covers concepts performed in the human mind, including observation, evaluation, judgment, and opinion, but for the recitation of generic computer components. See MPEP 2106.04(a)(2) III. Nothing in the claim element precludes the step from practically being performed in the mind, as the limitation requires the evaluation and judgement to determine documents. (Step 2A, Prong One: YES)
Step 2A – 2: This judicial exception is not integrated into a practical application, and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Exemplary independent claim 1 recites the additional element of receiving, by a computing system, an incoming data record generated by a semiconductor fabrication plant, wherein the incoming data record includes at least one measured value and a set of context values, however this is recited at a high level of generality, as the claim puts no limits on how the computer receives the data, and the content of the data received does not affect the step of receiving, and amounts to insignificant extra-solution activity. See MPEP 2106.05(g). The claim further recites the additional element of storing, by the computing system in a data store, a decomposed fab process record that includes a representation of the at least one measured value and the one or more context documents, however this is also recited at a high level of generality, as the claim puts no limits on how the computer stores the data, and what is being stored does not affect the step of storing2, and also amounts to insignificant extra-solution activity. See MPEP 2106.05(g). The claim further recites the additional elements of a computing system and a data store, however The computer is recited at a high level of generality, and the computer is used as a tool to perform the generic computer function of receiving and storing data, and the data store is also recited at a high level of generality, and is merely used as a tool to perform the generic computer function of storing data. See MPEP 2106.05(f).
Further, the claims do not provide for or recite any improvements to the functioning of a computer, or to any other technology or technical field; applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition; applying the judicial exception with, or by use of, a particular machine; effecting a transformation or reduction of a particular article to a different state or thing; or applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception.
Even when viewed in combination, these additional elements do not integrate the recited judicial exception into a practical application (Step 2A, Prong Two: NO). The claim is directed to the abstract idea. (Step 2A: YES).
The dependent claims have the same deficiencies as their parent claims as being directed towards an abstract idea, as the dependent claims merely narrow the scope of their parent claims, and it has been held that “[i]n defining the excluded categories, the Court has ruled that the exclusion applies if a claim involves a natural law or phenomenon or abstract idea, even if the particular natural law or phenomenon or abstract idea at issue is narrow.” (buySAFE, Inc. v. Google, Inc., 765 F.3d 1350. )
Turning to the dependent claims, none of the claimed features of the dependent claims further limit the claimed invention in such a way to direct the claimed invention to statutory subject matter (e.g. change the scope of the claimed invention as to no longer be directed towards an abstract idea, or include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements or combination of elements in the claims other than the abstract idea per se), nor do they add limitations that, when taken as a combination, result in the claim as a whole amounting to significantly more than the judicial exception. In respect to exemplary dependent claims 2 – 9:
Claim 2 merely further describes data that is stored;
Claim 3 merely further describes data that is stored;
Claim 4 merely describes the documents that are determined;
Claims 5 – 9 merely further describe data that is stored;
Step 2B: The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, explained with respect to Step 2A, Prong Two, the additional elements or combination of elements in the claims other than the abstract idea per se amount to no more than mere instructions to implement the idea on a computer, or the recitation of generic computer structure that serves to perform generic computer functions previously known to the industry3 [e.g. performing repetitive calculations; receiving, processing, and storing data; electronically scanning or extracting data from a physical document; electronic recordkeeping; automating mental tasks; receiving or transmitting data over a network, e.g., using the Internet to gather data] .
Applicant’s specification, at, e.g., paragraphs [0041]-[0049], provides evidence of generic computer hardware performing generic, well-known, computer functions.
Viewed as a whole, these additional claim elements, both individually and in combination, do not provide meaningful limitations to transform the above identified abstract idea into a patent eligible application of the abstract idea such that the claims amount to significantly more (e.g. improvements to another technology or technical fields, improvements to the functioning of the computer itself, or meaningful limitations beyond generally linking the use of an abstract idea to a particular technological environment) than the abstract idea itself. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation4.
Therefore, the claims are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. See Alice Corporation Pty. Ltd. v. CLS Bank International, 573 U.S. No. 13–298.
Subject Matter Not Rejected Over Prior Art
Claims 1 – 20 do not stand rejected under 35 USC 102 or 103.
The closest prior art of record includes Yamazaki, Jin, Haddad et al. (U.S. 2023/0185783) which is directed to and discloses hash-based duplicate data element systems and methods; Akkapeddi et al. (U.S.2023/0421605) which is directed to and discloses document retention and generation at the edge; Bhaskar et al. (U.S.2009/0080759) which is directed to and discloses systems and methods for creating persistent data for a wafer and for using persistent data for inspection-related functions; Beecham (U.S. 2019/0340379) which is directed to and discloses an immutable bootloader and firmware validator; Wood (U.S. 2005/0269417) which is directed to and discloses methods for encoding and decoding information; Martynov (U.S. 2017/0109258) which is directed to and discloses smart logging of trace data for storage systems; Choi (U.S. 2024/0085891) which is directed to and discloses virtual metrology methods for wafers, prediction methods for circuit characteristics of wafers and process control systems; and Lee (U.S.2020/0249651) which is directed to and discloses a system and method for generating machine learning model with trace data.
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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALAN S MILLER whose telephone number is (571)270-5288. The examiner can normally be reached on M-F 10am-6pm. Examiner’s fax phone number is (571) 270-6288.
Examiner interviews are available via telephone 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, Beth Boswell can be reached at (571) 272-6737. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/ALAN S MILLER/Primary Examiner, Art Unit 3625
1 See MPEP 2106.05 I. B. The Court identified the additional elements in the claim, e.g., by noting that the method claims recited steps of using a computer to "create electronic records, track multiple transactions, and issue simultaneous instructions", and that the product claims recited hardware such as a "data processing system" with a "communications controller" and a "data storage unit" (573 U.S. at 224-26, 110 USPQ2d at 1984-85); The Court considered the additional elements individually, noting that all the computer functions were "‘well-understood, routine, conventional activit[ies]’ previously known to the industry," each step "does no more than require a generic computer to perform generic computer functions", and the recited hardware was purely functional and generic" (573 U.S. at 225-26, 110 USPQ2d at 1984-85); and The Court considered the additional elements "as an ordered combination," and determined that "the computer components … ‘[a]dd nothing … that is not already present when the steps are considered separately’" and simply recite intermediated settlement as performed by a generic computer." 573 U.S. at 225 (citing Mayo, 566 U.S. at 79, 101 USPQ2d at 1972).
2 It is noted, for example, that there is no recitation in the claim of the creation of a decomposed fab process record, merely that one exists and that it is saved.
3 “It is well-settled that mere recitation of concrete, tangible components is insufficient to confer patent eligibility to an otherwise abstract idea. Rather, the components must involve more than performance of “‘well understood, routine, conventional activit[ies]’ previously known to the industry.” Alice, 134 S. Ct. at 2359 (quoting Mayo, 132 S.Ct. at 1294)”. Id, pages 10-11. “Likewise, the server fails to add an inventive concept because it is simply a generic computer that “administer[ s]” digital images using a known “arbitrary data bank system.” Id. at col. 5 ll. 45–46. But “[f]or the role of a computer in a computer-implemented invention to be deemed meaningful in the context of this analysis, it must involve more than performance of ‘well-understood, routine, [and] conventional activities previously known to the industry.’” Content Extraction, 776 F.3d at 1347–48 (quoting Alice, 134 S. Ct at 2359). “These steps fall squarely within our precedent finding generic computer components insufficient to add an inventive concept to an otherwise abstract idea. Alice, 134 S. Ct. at 2360 (“Nearly every computer will include a ‘communications controller’ and a ‘data storage unit’ capable of performing the basic calculation, storage, and transmission functions required by the method claims.”); Content Extraction, 776 F.3d at 1345, 1348 (“storing information” into memory, and using a computer to “translate the shapes on a physical page into typeface characters,” insufficient confer patent eligibility); Mortg. Grader, 811 F.3d at 1324–25 (generic computer components such as an “interface,” “network,” and “database,” fail to satisfy the inventive concept requirement); Intellectual Ventures I, 792 F.3d at 1368 (a “database” and “a communication medium” “are all generic computer elements”); BuySAFE v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014) (“That a computer receives and sends the information over a network—with no further specification—is not even arguably inventive.”)”. TLI Communications LLC v. AV Automotive L.L.C., (No. 15-1372, (Fed. Cir. May 17, 2016)), at *12-13.
See additionally MPEP 2106.05(d).
4 “Nor, in addressing the second step of Alice, does claiming the improved speed or efficiency inherent with applying the abstract idea on a computer provide a sufficient inventive concept. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted))”. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 115 U.S.P.Q.2d 1636 (Fed. Cir. 2015).
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