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 .
Acknowledgment
The Applicant’s amendment/request for reconsideration dated 04/07/2026 is acknowledged.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 03/10/2026 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
Status of Claims
Claims 1, 6, 11 and 16 have been amended.
Claims 1-20 are pending and presented to be examined upon their merits.
Response to Arguments
Regarding 35 U.S.C. 101 Rejections
The 35 U.S.C. 101 is maintained. Wherein independent claims 1 and 11 now recite, “responsive to receiving a change to the transaction record, updating the editable billing item without reprocessing other transaction records or other billing documents”, it is maintained that the specification defines updating the editable billing item as adding a subitem to the corresponding editable billing items. It is maintained that this function does not amount to significantly more than the judicial exception in that it represents an element performing a function that is similar to either [1] receiving processing and storing data and/or [2] electronic recordkeeping. The courts have recognized that both these computer functions to be well understood routine and conventional being claimed in generic manner. Here the newly amended claim language of, “updating” as interpreted from the specification, “…by adding a subitem to an editable items,” [see specification 0044-0045] can be interpreted as equivalent to merely storing additional data within a database according to certain criteria.
Regarding 35 U.S.C. 103a Rejections
The Applicant’s Amendments/Remarks are acknowledged. Independent claims 1 and 11 now recite, “responsive to receiving a change to the transaction record, updating the editable billing item without reprocessing other transaction records or other billing documents”. According to the specification, “[0044] In an example, editable billing items can be stored until the end of the billing cycle. This allows for manual review and changes at any time during the billing cycle. Whenever a change is made, rather than reprocessing the entire billing item or reprocessing all billing items at once, the billing calculation application can simply update the editable billing item.
[0045] The editable billing item also allows for quicker updates whenever a change occurs that affects multiple billing items. As an example, if the final contracted price changes during the billing cycle from the preliminary contracted price, the price change can be automatically added to the relevant billing items by adding a subitem to the corresponding editable billing items. The billing calculation application can identify the relevant billing items by matching key fields in the change record to corresponding key fields in the editable billing item. For example, the billing calculation application can match fields from the change record to the relevant editable billing item, such as the client name or ID, project or subproject name or ID, material ID, and so on. The billing calculation application can do this as soon as the change record is loaded into the database, as opposed than waiting for the end of the billing cycle. The original records do not require reprocessing. Also, Users can view up-to-date information about all submitted billing items in the billing calculation application. Users do not have to wait until the end of the billing cycle to view this information. “
In paragraph [0044] of the Applicant’s specification, it describes the function of ‘updating’ “…without reprocessing other transaction records or other billing documents”, as where the billing application can simply update the editable billing items, as in Paragraph [0045], by a price change that is automatically added to the relevant billing items. The specification also suggests that the added item is provided so that users do not have to wait to the end of the billing cycle to view the information.
It should be noted that references in determining obviousness are not read in isolation but what they fairly teach in combination with prior art as a whole. Thus it is maintained that wherein the Applicant’s specification describes the function of updating as automatically adding billing items to corresponding editable billing items via the billing calculation application, the Roth reference equivalently describes an update method based upon “triggers” being a part of the business software application including a data update process [¶0167-¶0168] and in particular the dependent stage update method in reference to FIG. 19B that illustrates a sale order wherein an update is saved as a trigger to a database [see ¶0170, ¶0172- “….Generally, an Update Method is a series of update, insert or delete statements that makeup a database transaction”, ¶0173-“…efficiency of processing application transactions and performance of the system, application transactions are handled on the server, using table triggers, database stored procedures or both.”]
Thus the 35 U.S.C. 103 is maintained.
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;
…updating the editable billing item without reprocessing other transaction records or other billing documents;
creating a billing document request based on the editable billing item;
an sending the billing document…updating the editable item without reprocessing other transaction records or other billing documents”
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)
responsive to receiving a change to the transaction record, updating the editable billing item without reprocessing other transaction records or other billing documents [see ¶0170. ¶0172- generating an invoice via the “update method” being a series of insert or delete statements that can be translated into Structured Query language (“SQL”) statements that make up a database transaction. SQL is a universal programming language used by Roth to create, update, manage and retrieve data. see also, ¶0172- “….Generally, an Update Method is a series of update, insert or delete statements that makeup a database transaction”, ¶0173-“…efficiency of processing application transactions and performance of the system, application transactions are handled on the server, using table triggers, database stored procedures or both.”]
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
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 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
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