He 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 are pending and presented to be examined upon their merits.
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.
In the instant case, claim 1 is directed to a method of processing a transaction record and claim 11 is directed to system or manufacture for processing a transaction record
Claim 1 is directed to the abstract idea of, “processing a transaction record and/or managing billing records” which is grouped under certain methods of certain methods of organizing human activity because the claims involve billing activity which under the broadest reasonable interpretation relate to fundamental economic practices such as managing financial transactions between peoples as well as sales activities- in prong one of step 2A (See 2019 Revised Patent Subject Matter Eligibility Guidance).
Claim 1 recites “detecting a trigger event relating to a transaction record, the trigger event indicating the transaction record should be processed; generating,…, a second … table that includes values from predetermined fields of the first … table related to the transaction record; creating,…, a editable billing item, the editable billing item including price and quantity data from the transaction data; creating a billing document request based on the editable billing item; an sending the billing document…”
Accordingly, the claim recites an abstract idea (See 2019 Revised Patent Subject Matter Eligibility Guidance).
This judicial exception is not integrated into a practical application because, when analyzed under prong two of step 2A (See 2019 Revised Patent Subject Matter Eligibility Guidance), the additional elements of the claim such as “hardware-based processor”, “processor”, “ERP system” “graphical user interface (“GUI”)” are recited at a high level of generality and represent the use of a computer as a tool to perform an abstract idea and/or does no more than generally link the abstract idea to a particular field of use. Therefore, the additional elements do not integrate the abstract idea into a practical application as they do no more than represent a computer system performing functions that correspond to processing a transaction record and/or managing billing records.
When analyzed under step 2B (See 2019 Revised Patent Subject Matter Eligibility Guidance), the claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception itself. Viewed as a whole, the combination of elements recited in the claims merely describe the concept of managing billing records using computer technology (e.g. well-known, routine and conventional ERP system-see specification [¶0001]). Therefore, the use of these additional elements does no more than employ a computer as a tool to automate and/or implement the abstract idea, which cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)).
Hence, claim 1 is not patent eligible.
Claims 2-10, further describe steps of implementing the judicial exception and do not provide additional elements that are sufficient to amount to significantly more than the judicial exception itself.
Independent claim 11 is rejected also because it provides a non-transitory, computer-readable medium for processing transaction records that does no more than generally link the abstract idea to a particular field of use and merely represents a computer system performing functions that correspond to implementation of the abstract idea (i.e., processing a transaction record and/or managing billing records) similarly described in claim 1.
Clams 12-20, further describe steps of implementing the judicial exception and do not provide additional elements that are sufficient to amount to significantly more than the judicial exception itself.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claim(s) 1 and 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Roth et al (US 2005/0154742) in view of Mahanta et al (US 2023/0342357).
Regarding claim 1, Roth discloses a method [¶0002] for processing a transaction record (Fig. 16A-B) from an enterprise resource planning (ERP) system [¶0134] and [¶0159], comprising:
detecting a trigger event relating to a transaction record, the trigger event indicating that the transaction record should be processed;(Fig. 15A)[see ¶0156-wherein the application (item# 142 may accept user and system input to an application transaction table (item#142a) that will trigger a change to an application detail table (item# 142b)]
generating, from a first virtual table stored at an ERP database of the ERP system (Fig. 27)[¶0205], a second virtual table that includes values from predetermined fields of the first virtual table related to the transaction record; [¶0054-suggesting that the plurality of tables are stored in a database of a typical ERP system; and (Fig. 27) ¶0205-listing (item# 270) of tables of the system database)];
creating an editable billing item, the editable billing item including price and quantity data from the transaction data; (item# 210)[¶0172-wherein “editable” herein is interpreted as the system may generate an invoice that can be modified (i.e., bill] as part of an update method- or the table updated [¶0179] see also ¶0150; ¶0158; and ¶0173- wherein an accounts receivable record is made in the invoice stage)
Roth fails to disclose, but Mahanta discloses creating a billing document request based on the editable billing item; and sending the billing document request to the ERP system.[see (Fig. 3)(item# 330)¶0036-the project billing BDR (billing document request)]
It would have been obvious before the effective filing date of the invention for Roth to have recognized the advantages of creating a billing document request, as enunciated in Mahanta. The motivation would be to provide more efficient database operations.
Regarding claim 11, Roth discloses a non-transitory, computer-readable medium containing instructions that, when executed by a hardware-based processor (item# 78-computer with hard disk drive)[¶0138], causes the processor to perform stages for processing a transaction record from an enterprise resource planning (ERP) system, the stages comprising:
detecting a trigger event relating to a billing transaction, the trigger event indicating that the transaction record should be processed; (Fig. 15A)[see ¶0156-wherein the application (item# 142 may accept user and system input to an application transaction table (item#142a) that will trigger a change to an application detail table (item# 142b)]
generating, from a first virtual table stored at an ERP database of the ERP system, a second virtual table that includes values from predetermined fields of the first virtual table related to the transaction record; [¶0054-suggesting that the plurality of tables are stored in a database of a typical ERP system; and (Fig. 27) ¶0205-listing (item# 270) of tables of the system database)]
creating, using the second virtual table, an editable billing item, the editable billing item including price and quantity data from the transaction data; (item# 210)[¶0172-wherein “editable” herein is interpreted as the system may generate an invoice that can be modified (i.e., bill] as part of an update method- or the table updated [¶0179] see also ¶0150; ¶0158; and ¶0173- wherein an accounts receivable record is made in the invoice stage)
Roth fails to disclose, but Mahanta discloses creating a billing document request based on the editable billing item; and sending the billing document request to the ERP system.[see (Fig. 3)(item# 330)¶0036-the project billing BDR (billing document request)]
It would have been obvious before the effective filing date of the invention for Roth to have recognized the advantages of creating a billing document request, as enunciated in Mahanta. The motivation would be to provide more efficient database operations.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Shak et al (US 2017/0236218) discloses system and method for implementing unified bill and unified rating operations.
Shaaban (WO 2016/029194) discloses a system and method for inter-company billing processing
(CN 117670564) discloses invoice billing method and system compatible with multiple database extracting invoice data
Fleming et al (US 20220083974) discloses interactive parts drawing with a real-time bill of materials
Any inquiry concerning this communication or earlier communications from the examiner should be directed to DANIEL S FELTEN whose telephone number is (571)272-6742. The examiner can normally be reached Flex.
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DANIEL S. FELTEN
Examiner
Art Unit 3692
/DANIEL S FELTEN/Primary Examiner, Art Unit 3692