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 .
This Office Action is responsive to Applicant's amendment filed on 3 March 2026. Currently Claims 1-5, 7-14, 16-23, 25, and 26 are pending and have been examined. Claims 6, 15, and 24 were previously canceled. The Examiner notes that the 101 rejection has been maintained.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3 March 2026 has been entered.
Terminal Disclaimer
The Examiner acknowledges the Terminal Disclaimer filed 3 March 2026 and the Double Patenting rejection has been withdrawn.
Response to Arguments
Applicant's arguments filed on 3 March 2026 have been fully considered but they are not persuasive.
The Applicant argues on pages 13-14 that “The 2019 PEG requires proper identification of an enumerated grouping Under the 2019 Patent Eligibility Guidance, at Step 2A Prong l, the Examiner must identify whether the claim recites a judicial exception that falls within one of three enumerated groupings: (l) mathematical concepts, (2) certain methods of organizing human activity, or (3) mental processes. If the claim is not directed to an abstract idea identified in these groupings, the claim qualifies as eligible subject matter. The Examiner asserts the claims are directed to both a mental process and a method of organizing human activity. Applicant respectfully submits that neither grouping applies to the claims as recited.
The claims do not recite a mental process: The Examiner asserts that the independent claims recite "the limitation of risk data navigation to investigate and evaluate financial trade and business-related risks" and that this limitation, "under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components." The Examiner further states that
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other than reciting a processor, nothing in the claim precludes the determining step from practically being performed in the human mind" and that "the underlying claimed invention is described as a concept that is performed in the human mind and/or with the aid of a pen and paper." This characterization is erroneous because it improperly abstracts the claims to a level of generality that ignores the actual claim limitations, and because several of the recited steps cannot practically be performed in the human mind or with pen and paper.
Automatic traversal of a graph database cannot be performed mentally: The claims recite that the computer is configured to "automatically, as operated by the rules, perform graph traversal from the starting node along a pathway and, stop graph traversal of the pathway at any node that has the particular node type, wherein the pathway from the starting node to the end node is identified to be a relevant pathway for the starting node, and repeating the automatic graph traversal to identify additional relevant pathways for the starting node, whereby one or more relevant pathways are identified to be associated with corresponding starting nodes." This limitation requires the system, without human intervention, to computationally traverse an exponentially large number of potential paths through a graph database and identify relevant surfaced pathways based on defined rules. A person cannot practically perform automatic traversal of a graph database in their mind or with pen and paper. As the MPEP itself acknowledges, claims do not recite a mental process "when the human mind is not equipped to perform the claim limitations," providing examples such as "network monitoring, data encryption for communication, or rendering images." Automatic graph traversal across a database computationally identifying surfaced pathways from starting nodes to endpoint nodes pursuant to defined rules is analogous to these examples. A graph naturally presents an exponentially large number of path traversals to find relevant paths, and the system applies an algorithm to identify relevant paths and associates those discovered paths with corresponding starting nodes. This is not a task the human mind is equipped to perform”.
The Examiner Respectfully disagrees.
With respect to the argument the Examiner notes that Applicant's argument that the automatic graph traversal limitation cannot practically be performed in the human mind has been fully considered but is not persuasive. As previously explained in both the Final Office Action and the Advisory Action, the broadest reasonable interpretation of the claim language "automatically, as operated by the rules, perform graph traversal from the starting node along a pathway and stop graph traversal of the pathway at any node that has the particular node type" covers the mental process of navigating from one concept to another concept and stopping when a particular type of concept is reached. The word "automatically" does not preclude mental performance a person can automatically, meaning without conscious deliberation, traverse conceptual relationships in their mind. This is precisely what compliance analysts have done long before computers existed: reviewing files, following relational leads between entities, and stopping when a sanctioned entity is identified. The traversal of relationships between entities to identify connections to sanctioned actors is fundamentally a process of human reasoning and judgment about relationships, and the claims do not recite any specific algorithm, computer architecture, or processing technique that would structurally distinguish this process from that mental activity.
Applicant's reliance on the MPEP's examples of non-mental processes network monitoring, data encryption, and rendering images is misplaced. Each of those examples involves specific technical operations that have no meaningful mental analog. Network monitoring involves real-time packet capture and analysis of data transmission protocols at a technical level. Data encryption involves applying specific mathematical transformations to data for defined security purposes. Rendering images involves specific pixel-level manipulation and display buffer operations. None of these can be conceptually reduced to a process of observation, evaluation, and judgment. By contrast, the claimed "automatic graph traversal" under its broadest reasonable interpretation simply involves following relationships from one entity to another and stopping when a particular type of entity is found. This is conceptually equivalent to an analyst reviewing a set of relationship records and following connections until a target entity type is identified, which is a mental process of investigation that does not require any specific technical implementation beyond what the human mind and pen and paper can accomplish conceptually.
Applicant's argument regarding the "exponentially large number of path traversals" speaks to the scale and efficiency of the process, not to whether the underlying concept is mental in nature. The MPEP guidance makes clear that the relevant inquiry at Step 2A Prong 1 is whether the claim limitation can practically be performed in the human mind, not whether it can be performed efficiently or quickly. The scale of the data being processed is a natural consequence of using a computer as a tool to perform a process that is conceptually mental in nature, and this does not transform the abstract idea into patent-eligible subject matter. As noted in the Advisory Action, the exponential scale referenced by Applicant relates to efficiency and speed, not to whether the process is mental in nature. Moreover, the claim does not recite any specific algorithm, specific data structure, or specific computational architecture that would constitute a technical implementation going beyond the generic performance of the underlying mental process using generic computer components.
Furthermore, the claim's recitation of a generic "computer configured to" perform these steps and the use of a generic processor do not remove the claim from the mental process grouping. The mere nominal recitation of a generic processor does not take the claim limitation out of the mental processes grouping, as the Supreme Court made clear in Alice Corp. v. CLS Bank Int'l and as reflected throughout the 2019 PEG. The key question is whether the claim, under its broadest reasonable interpretation, covers performance of the concept in the human mind but for the recitation of generic computer components and it does. The Examiner has reviewed the claim as drafted and determined that the underlying concept of navigating relational data about entities and stopping traversal upon reaching a designated entity type remains a process of observation, evaluation, and judgment that can be performed mentally, with the computer serving merely as the mechanism for performing that concept. Accordingly, the rejection has been maintained.
The Applicant argues on page 14 that “storing graph data in nonvolatile memory using a graph data structure is inherently computational. The claims recite "a database configured to store, in nonvolatile memory, a graph, pursuant to one or more data models, using a graph data structure comprising edges, nodes, and attributes." Nonvolatile memory and a graph data structure are specific computer-science constructs. A person cannot "store" data "in nonvolatile memory" using "a graph data structure" in their mind or with pen and paper. The Examiner acknowledges these are "additional elements" but dismisses them as conventional. However, the inquiry at Step 2A Prong I is whether the limitation can practically be performed in the human mind not whether the limitation is conventional. Conventionality is a consideration at Step 2A Prong 2 and Step 2B, not at Prong l. Even well-known computer operations are not mental processes if they cannot be performed mentally”.
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the recitation of storing data in nonvolatile memory using a graph data structure cannot be performed mentally, and therefore removes the claims from the mental process grouping at Step 2A Prong 1, has been fully considered but is not persuasive. Applicant is correct that the conventionality of a limitation is not the relevant inquiry at Step 2A Prong 1, and the Examiner does not dispute that general principle. However, Applicant misinterprets how the 2019 PEG framework operates with respect to claims that contain both limitations directed to an abstract idea and limitations that are not themselves abstract. The presence of one or more limitations in a claim that cannot be performed mentally does not automatically remove the entire claim from Step 2A Prong 1 consideration. Under the 2019 PEG, the inquiry at Step 2A Prong 1 is whether the claim recites a judicial exception meaning whether any limitation or combination of limitations falls within an enumerated grouping. Where a claim recites a core concept that constitutes a mental process, the existence of additional elements that are computational in nature does not negate the identification of the judicial exception at Prong 1; rather, those additional elements are evaluated at Step 2A Prong 2 to determine whether they integrate the exception into a practical application, and again at Step 2B to determine whether they amount to significantly more than the exception itself. Collapsing that framework by treating all claim limitations as if they must collectively be performable mentally before a mental process can be identified would render the subsequent analytical steps meaningless and is not consistent with the 2019 PEG or the Alice/Mayo framework as applied by the courts.
With respect to the specific limitation of storing data in nonvolatile memory using a graph data structure, the Examiner's position is that the broadest reasonable interpretation of this limitation encompasses maintaining records of entities and their relationships using a structured format a concept that can be represented with pen and paper through organizational charts, relationship diagrams, or family trees, all of which are data structures comprising nodes, edges, and attributes in conceptual form. The specification does not describe any particular, unconventional data structure or storage methodology that would distinguish the claimed graph data structure from conventional data organization techniques. The claim recites that the database stores a graph comprising edges, nodes, and attributes pursuant to data models, which under its broadest reasonable interpretation describes the well-understood concept of organizing relational information in a structured manner. The recitation of "nonvolatile memory" is a generic computer component performing a generic data storage function and does not, by itself, constitute a technical limitation that transforms the nature of what is being stored and why.
Furthermore, even accepting Applicant's contention that storing data in nonvolatile memory using a graph data structure cannot literally be performed in the human mind, the Examiner notes that this limitation is properly treated as one of the additional elements of the claim that must be evaluated at Step 2A Prong 2 and Step 2B. The core concept that the claim is directed to navigating relational data about entities to identify connections relevant to financial crime and sanctions compliance evaluation remains a mental process or method of organizing human activity regardless of whether certain implementing limitations require computational execution. The use of a computer and nonvolatile memory to store the information used in that mental process does not change the nature of the underlying judicial exception being claimed; it merely provides the computational environment in which the abstract process is performed. This is precisely the type of "apply it" implementation that courts have consistently found insufficient to confer patent eligibility under 101. Accordingly, the rejection is maintained.
The Examiner notes on pages 14-15 that “providing an interactive visual workspace with dynamic graphical representations is not a mental process. The claims require the computer to "provide a visual workspace adapted to allow a user to interact with graphic representations of nodes and edges," to " communicate that the selected node has one or more of the relevant pathways," and to "interactively add one of the communicated one or more of the relevant pathways to the visual workspace and in response, display, in the visual workspace, the selected relevant pathway using separate visual graphical elements for nodes and edges illustrating a connected pathway from the selected node to other nodes." An interactive, dynamic visual workspace that responds to user input by displaying and updating graphical elements cannot be performed in the human mind. A static drawing on paper does not "respond" to user interaction, does not dynamically update, and does not "communicate" pathway associations through interactive selection mechanisms. These are inherently computer-implemented operations that have no pen-and-paper analog.”
The Examiner respectfully disagrees
With respect to the argument the Examiner notes that Applicant's argument that the interactive visual workspace limitations cannot be performed in the human mind and therefore remove the claims from the mental process grouping has been fully considered but is not persuasive. As previously addressed in the Advisory Action, the broadest reasonable interpretation of "provide a visual workspace adapted to allow a user to interact with graphic representations of nodes and edges" and "interactively add one of the communicated one or more of the relevant pathways to the visual workspace and in response, display, in the visual workspace, the selected relevant pathway using separate visual graphical elements for nodes and edges" encompasses presenting information to a user and allowing the user to select what information to view. This is analogous to a person reviewing documents and selecting which documents to examine more closely, or an analyst creating a visual diagram on paper and adding elements as their investigation progresses. The fundamental concept underlying these limitations presenting relational information visually and allowing a user to selectively explore that information is a process of information presentation and user-directed evaluation that has been performed by compliance analysts, investigators, and researchers long before computers existed, whether through physical relationship charts, annotated diagrams, or manually assembled visual representations of entity connections.
Applicant's characterization that a static drawing on paper does not "respond" to user interaction or "dynamically update" conflates the technical implementation of the concept with the concept itself. The relevant inquiry at Step 2A Prong 1 is not whether the precise mechanical implementation of a limitation can be replicated with pen and paper, but rather whether the underlying concept recited by the limitation can practically be performed in the human mind or through mental steps. The concept of viewing a representation of relational data, selecting a pathway of interest, and then examining that pathway in greater detail is precisely the type of investigative mental process that analysts perform when reviewing relationship diagrams and deciding which connections to explore further. The fact that the claimed implementation uses a computer to dynamically render and update graphical elements does not change the nature of the underlying concept being claimed.
Furthermore, the claims do not recite any specific technical details about how the visual workspace is implemented, how the graphical elements are rendered, what specific display mechanisms are employed, or what makes the interaction "interactive" beyond generic display and selection functions. The specification describes this functionality as allowing users to "visually see the data in this form because it provides the user with a different comprehension of the interrelationships from the visual view" which characterizes the benefit in terms of human cognitive understanding, not in terms of a technical improvement to computer display technology. This confirms that the visual workspace limitations are directed to facilitating the mental process of evaluation and judgment by presenting information in a useful form, not to improving how computers technically render or process graphical data. The visual representation of data to aid human understanding is a form of presenting information to facilitate mental processes of evaluation and judgment, which falls squarely within the mental process grouping regardless of whether the specific implementation requires a computer to execute.
Applicant's argument is also unavailing because, as noted previously, the presence of limitations that cannot be performed entirely in the human mind does not preclude a finding that the claim recites a mental process at Step 2A Prong 1. The framework requires identifying whether the claim recites a judicial exception, and the core concept of navigating relational data and selectively presenting identified pathways to a user for compliance evaluation remains a mental process. The visual workspace limitations, to the extent they involve computational execution beyond what can be performed mentally, are properly treated as additional elements subject to evaluation at Step 2A Prong 2 and Step 2B. As previously determined, these additional elements generic display functionality, generic user interface interaction, and generic graphical rendering amount to no more than generic computer components performing generic computer functions that do not integrate the abstract idea into a practical application or provide significantly more than the exception itself. The specification does not identify any technical problem with existing user interface or graph visualization technology that the claimed visual workspace solves, nor does it explain how the visual workspace technically improves upon conventional display technology. The improvement described is the business value of having pre-identified relevant pathways available for selective display, not an improvement to how computer display technology functions. Accordingly, the rejection is maintained.
The Examiner argues on page 15 that “the examiner conflates the Prong 1 and Prong 2 analyses. The Examiner's analysis improperly strips the claims of their technical limitations at Prong I and then characterizes those same limitations as "additional elements" at Prong 2 that are merely "generic" or "conventional." However, Step 2A Prong I requires the Examiner to determine whether the claim, as recited, practically can be performed in the human mind. The Examiner cannot strip out the specific computational steps recited in the claims automatic graph traversal, storage of data in nonvolatile memory using a graph data structure, interactive visual workspace display and then conclude that what remains is a mental process. The MPEP instructs that claims must be evaluated "as a whole" to determine whether they recite a mental process. See MPEP 2106 4 11(2) ("In Prong Two, examiners evaluate whether the claim as a whole integrates the exception into a practical application of that exception.). NAPEP 2106 05 ("If the claim as a whole does recite significantly more than the exception itself, the claim is eligible (Step 2B YES) at Pathway C, and the eligibility analysis is complete."). Here, the claims as a whole recite an integrated computer system that stores graph data in a specific data structure, automatically traverses that data pursuant to defined rules, associates discovered pathways with starting nodes, and provides an interactive visual workspace for exploring those pathways. No part of this integrated process can practically be performed in the human mind.”
The Examiner respectfully disagrees
With respect to the argument the Examiner notes that the Applicant's argument that the Examiner has improperly conflated the Step 2A Prong 1 and Prong 2 analyses by stripping technical limitations from the claims at Prong 1 and then characterizing those same limitations as additional elements at Prong 2 has been fully considered but is not persuasive. As an initial matter, the Examiner has not ignored or stripped any claim limitations from the analysis. The Examiner has considered all claim language including the graph data structure comprising edges, nodes, and attributes; the set of rules for controlling graph traversal including selecting starting nodes, designating endpoint node types, and ending traversal; the automatic graph traversal from starting nodes along pathways; the storing of relevant pathways; the providing of a visual workspace; the communicating of relevant pathways to users; and the interactively adding of pathways to the visual workspace with graphical representations. Each of these limitations has been identified, considered, and evaluated. The Alice/Mayo framework, as established by the Supreme Court and reflected in the 2019 PEG, specifically requires a two-step analytical process in which the examiner first identifies what judicial exception is recited by the claim and then separately evaluates whether additional elements beyond that exception integrate it into a practical application or provide significantly more. This structural analytical separation is not conflation it is the required methodology mandated by the Supreme Court in Alice Corp. v. CLS Bank Int'l and Mayo Collaborative Services v. Prometheus Laboratories, and as reflected throughout MPEP 2106.
Applicant's argument mischaracterizes what the Prong 1 analysis requires. The 2019 PEG does not instruct examiners to evaluate at Prong 1 whether every single limitation of the claim as a whole can be performed in the human mind. Rather, Prong 1 asks whether the claim recites a judicial exception that is, whether any limitation or combination of limitations within the claim falls within one of the enumerated groupings of abstract ideas. As the Supreme Court explained in Alice, even after determining that a claim recites an abstract idea, the Court still considered whether the computer implementation of that idea provided something more. The Court specifically identified additional elements in the claim, considered those additional elements individually, and then considered them as an ordered combination to determine whether they added significantly more than the abstract idea. This is precisely the analytical structure the Examiner has followed here. Identifying which limitations recite the judicial exception and which constitute additional elements is not stripping language from the claim it is the required first step of the framework that allows the examiner to then evaluate whether those additional elements provide the necessary integration or inventive concept.
Furthermore, Applicant's citation to MPEP 2106.05 regarding evaluation of claims "as a whole" supports the Examiner's approach rather than contradicting it. MPEP 2106.05(a) instructs that when evaluating improvements to technology, examiners must look at the claim as a whole meaning the claim should be evaluated as an ordered combination without ignoring the requirements of individual steps, and examiners should be careful to avoid oversimplifying the claims by looking at them generally and failing to account for their specific requirements. The Examiner has done precisely this. The Office Action identified specific claim limitations, explained whether each constitutes a judicial exception or an additional element, evaluated those elements individually, and then evaluated them in combination. The conclusion reached that the ordered combination of elements describes the application of conventional graph database technology, conventional traversal rules, and conventional visual interface functionality to the business problem of financial crime compliance investigation is based on consideration of all claim elements together, not on stripping any limitation from the analysis.
Applicant's assertion that "no part of this integrated process can practically be performed in the human mind" conflates the technical implementation of the claimed system with the underlying concept to which the claims are directed. The relevant question under the 2019 PEG is not whether each specific technical implementation step can be performed mentally, but whether the underlying concept that the claim is directed to constitutes a mental process or method of organizing human activity. As the Supreme Court cautioned in Alice, courts must be careful not to allow patent protection for abstract ideas merely because they are implemented on a computer. The question is whether the claims purport to improve computer capabilities or instead invoke computers merely as a tool to perform an existing process. Here, the claims invoke graph databases, traversal algorithms, and visual interfaces as tools to perform the existing process of financial crime compliance investigation navigating relational data about entities, identifying relevant connections to sanctioned actors, and presenting those connections to a user for evaluation. This underlying process is a mental process of investigation and a method of organizing human commercial compliance activity regardless of whether the specific computer implementation of that process requires computational execution of certain steps. The integrated nature of the claimed system does not change the character of the underlying concept to which the claims are directed, and the combination of generic computer components performing generic computer functions does not transform that concept into patent-eligible subject matter. Accordingly, the rejection is maintained.
The Applicant argues on pages 15-16 that “The Examiner's own cited examples undermine the mental process grouping. The Examiner acknowledges that the MPEP identifies "network monitoring, data encryption for communication, or rendering images" as examples of processes the human mind is not equipped to perform. The claimed steps of automatic graph traversal computationally traversing an exponentially large number of potential paths through a database and dynamic interactive visual display rendering graphical representations of nodes and edges and updating those representations in response to user interaction are more closely analogous to network monitoring and rendering images than they are to simple evaluation, judgment, or observation. The Examiner provides no reasoned explanation for why automatic graph traversal and interactive visual rendering fall on the "mental process" side of the line rather than the "not equipped to perform" side”.
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the claimed automatic graph traversal and interactive visual rendering are more analogous to the MPEP's examples of non-mental processes network monitoring, data encryption, and rendering images than to mental processes of evaluation, judgment, or observation has been fully considered but is not persuasive. The distinction between the MPEP examples cited by Applicant and the claimed operations is not one of computational complexity or the involvement of a computer, but rather one of whether the underlying concept has a meaningful mental analog. Each of the MPEP examples Applicant cites involves specific technical operations that are fundamentally incompatible with mental performance not merely because of scale or efficiency considerations, but because the operations themselves have no conceptual equivalent that can be performed through observation, evaluation, or judgment. Network monitoring involves real-time capture, parsing, and analysis of data transmission protocols at the packet level operations that are defined entirely by technical specifications governing data transmission and that have no analog in human cognitive processes. Data encryption involves applying specific mathematical transformations, such as cryptographic algorithms, to data for security purposes operations that are defined by precise mathematical structures and that cannot be conceptually reduced to human reasoning. Rendering images involves specific pixel-level manipulation, color space calculations, and display buffer operations that are defined entirely by hardware and software specifications governing how digital signals are converted to visual output. None of these operations can be characterized as observation, evaluation, or judgment in any meaningful sense, which is precisely why the MPEP identifies them as operations the human mind is not equipped to perform.
By contrast, the claimed "automatic graph traversal" under its broadest reasonable interpretation as the claims are drafted involves following relationships from one entity to another through a graph and stopping when a particular type of entity is reached. The claims do not recite any specific algorithm for performing this traversal, do not specify any particular computational architecture, do not describe any specific data processing technique that distinguishes the claimed traversal from conventional graph search operations, and do not explain how the traversal is implemented in any technically specific manner beyond the functional description of its outcome. As noted in the Advisory Action, the claims recite that the system "automatically, as operated by the rules, perform graph traversal from the starting node along a pathway and stop graph traversal of the pathway at any node that has the particular node type" this is, under its broadest reasonable interpretation, simply following relationships from one concept to another and stopping when a particular type of concept is encountered. This is conceptually equivalent to an analyst reviewing relationship records, following leads from one entity to connected entities, and stopping when a sanctioned entity type is identified. The fact that a computer can perform this process across an exponentially larger dataset than a human analyst could manually review speaks to the efficiency and scale of the computer implementation, not to whether the underlying concept is mental in nature. Scale and efficiency are not the operative criteria for distinguishing mental processes from non-mental processes under the 2019 PEG.
Similarly, the claimed interactive visual display providing a workspace where a user can view graphical representations of nodes and edges and selectively add pathways to the workspace is conceptually equivalent to an analyst maintaining a visual diagram of entity relationships and selectively adding connections as their investigation develops. The claims do not recite any specific rendering technique, any specific display mechanism, any specific graphical processing operation, or any specific technical detail about how the visual workspace is implemented beyond the generic functional description of displaying graphical elements and responding to user selection. This distinguishes the claimed visual workspace from the MPEP example of rendering images, which involves technically specific pixel-level and display buffer operations that have no mental analog. The claimed visual workspace, as drafted, describes the generic concept of presenting relationship information visually and allowing a user to choose what to examine a concept with a clear and direct mental and pen-and-paper analog in the form of relationship diagrams and investigative charts.
Applicant's argument essentially asks the Examiner to treat computational scale and the use of a computer as sufficient to transform any process into a non-mental one. This position is inconsistent with Alice and with the 2019 PEG, which makes clear that using a computer to perform a process that is otherwise mental in nature does not remove the claim from the mental process grouping. The Examiner has provided a reasoned explanation grounded in the specific nature of the claimed operations as drafted and their relationship to the MPEP examples, and that explanation is consistent with the applicable legal framework. The claims do not recite the specific technical implementation details that would be necessary to bring them within the category of operations the human mind is not equipped to perform, and the absence of such details is itself a basis for maintaining the rejection. Accordingly, the rejection is maintained.
The Applicant argues on page 16 that “The claims do not recite a method of organizing human activity. The Examiner also asserts that the claims recite "the method of organizing human activity related to commercial compliance." This grouping is likewise improper. The "certain methods of organizing human activity" grouping encompasses: (a) fundamental economic principles or practices, (b) commercial or legal interactions, and (c) managing personal behavior or relationships or interactions between people. MPEP 2106.04(a)(2)(II). The Examiner's assertion that the claims fall within this grouping is based on the characterization that the claims relate to "financial crime compliance." However, the claims do not recite any fundamental economic principle, commercial transaction, or method of managing personal behavior. The claims recite a specific computer-implemented system that stores graph data, automatically traverses pathways, and provides an interactive visual workspace. The fact that the claimed system may be used in the field of financial crime compliance does not convert the technical claim limitations into a method of organizing human activity. The application of a claimed system to a particular field of use does not transform the nature of what is claimed. See MPEP 2106 05(h). The claim limitations themselves graph data structures, automatic traversal algorithms, interactive visual workspaces are technological in nature and do not organize human activity. The Examiner appears to rely on the preamble language referencing "financial crime or other business-related risks" to support this grouping. However, a preamble describing the field of use does not cause the claims to recite a method of organizing human activity. The body of each independent claim is directed to technical operations: storing data in a graph data structure, defining traversal rules, automatically traversing pathways, and providing an interactive visual workspace. None of these operations constitute the organization of human activity”.
The Examiner respectfully disagrees
With respect to the argument the Examiner notes that the Applicant's argument that the claims do not recite a method of organizing human activity because the claim limitations are technological in nature and the preamble's reference to financial crime compliance is merely a field of use designation has been fully considered but is not persuasive.
As an initial matter, the Examiner's identification of the claims as reciting a method of organizing human activity is not based solely on the preamble language referencing "financial crime or other business-related risks," as Applicant suggests. Rather, the determination is based on the combination of the preamble and the claim body, which together describe a system whose entire purpose and function is directed to organizing the human activity of commercial compliance investigation. The preamble is part of the claim and is relevant to understanding what the claim is directed to. The preamble "A computer-implemented system for providing a visual interactive software tool that permits users to investigate and evaluate financial crime or other business-related risks" is not merely a field of use designation it describes the purpose and function of the claimed system. The claim body implements this stated purpose through limitations directed to navigating relationship data to surface pathways of interest, communicating those pathways to users, and enabling users to selectively explore them for the purpose of evaluating financial crime and sanctions-related risks. This is organizing the human activity of commercial compliance analysis, which falls squarely within the "commercial or legal interactions" sub-grouping of methods of organizing human activity under MPEP 2106.04(a)(2)(II).
Applicant's argument that the claim limitations themselves graph data structures, automatic traversal, interactive visual workspaces are technological in nature and therefore cannot constitute a method of organizing human activity misapprehends the nature of the inquiry. The question is not whether the individual technical components recited in the claim are themselves technological, but rather whether the claim as a whole is directed to organizing human activity. A claim that uses technological components to implement a method of organizing human activity is still directed to a method of organizing human activity under Step 2A Prong 1. As MPEP 2106.04(a)(2) expressly recognizes, methods of organizing human activity can be performed on a computer the use of a computer to implement such a method does not remove it from the enumerated grouping. The specification repeatedly and consistently describes the invention in terms of financial crime compliance, sanctions compliance, regulatory compliance, and evaluating business risks. The specification states that the system allows "financial institutions, multinational corporations, legal professionals, and other stakeholders" to "evaluate their possible exposure to financial crime or sanctions-related risks." These are inherently commercial and legal interactions the paradigmatic example of the methods of organizing human activity grouping.
Furthermore, Applicant's reliance on MPEP 2106.05(h) regarding field of use limitations is misplaced in this context. Section 2106.05(h) is relevant at Step 2A Prong 2 and Step 2B when evaluating whether a field of use limitation meaningfully limits the abstract idea so as to integrate it into a practical application or provide significantly more. It does not speak to the Step 2A Prong 1 determination of whether the claim recites a judicial exception in the first instance. The Examiner's determination that the claims recite a method of organizing human activity is not based solely on a field of use limitation it is based on the substantive content of the claim limitations themselves, which describe a system for navigating relationship data about entities to determine compliance with sanctions regulations and assess financial crime risks. Navigating data about entities and their relationships to determine compliance with commercial and legal regulatory requirements is organizing the human activity of commercial compliance, regardless of whether that activity is implemented using a graph data structure or an interactive visual workspace.
Applicant's assertion that none of the recited operations storing data in a graph data structure, defining traversal rules, automatically traversing pathways, and providing an interactive visual workspace constitute the organization of human activity must be evaluated in context. While these operations may be described at a level of technical abstraction, the claim as a whole, including the preamble that defines the purpose of each of these operations, is directed to enabling users to investigate and evaluate financial crime and business-related risks by navigating relationship data. The claim limitations are not directed to improving graph database technology or graph traversal algorithms in the abstract they are specifically directed to surfacing pathways of interest for compliance investigation purposes and presenting those pathways to users for evaluation. As the specification makes clear, the system is designed to allow compliance analysts to "quickly and cogently understand risk using a visualization of one or more corridors" and to evaluate "financial crime and sanctions compliance issues at institutions." The entire integrated system, as claimed, is directed to organizing the commercial compliance activities of financial institutions and their analysts, which constitutes a method of organizing human activity relating to commercial or legal interactions under the established framework. Accordingly, the rejection is maintained.
The Applicant argues on page 17 that “Because the claims do not fall within any enumerated grouping, they are Patent Eligible. The 2019 PEG is clear: "If the claim does not recite an abstract idea identified in Section I, the claim is not 'directed to' a judicial exception under revised Step 2A, and the claim qualifies as eligible subject matter." As demonstrated above, the claims do not recite a mental process because the recited steps automatic graph traversal, storage in nonvolatile memory using a graph data structure, and interactive visual workspace display cannot practically be performed in the human mind or with pen and paper. The claims likewise do not recite a method of organizing human activity because the claim limitations are directed to specific computer-implemented technical operations, not to organizing human behavior or commercial interactions. Accordingly, the 101 rejection should be withdrawn because the Examiner has failed to establish that the claims fall within any enumerated abstract idea grouping at Step 2A Prong l, and the analysis need proceed no further”.
The Examiner respectfully disagrees
With respect to the argument the Examiner notes that the Applicant's argument that the claims do not fall within any enumerated abstract idea grouping and therefore qualify as patent-eligible subject matter without further analysis has been fully considered but is not persuasive. Applicant's argument in this section is expressly contingent upon the success of the arguments presented in the previous Arguments, asserting that because the claimed steps cannot practically be performed in the human mind and because the claim limitations are directed to specific computer-implemented technical operations rather than to organizing human behavior, neither the mental process grouping nor the methods of organizing human activity grouping applies. As the Examiner has addressed each of those underlying arguments in detail above and has explained why each is unpersuasive, Applicant's conclusory assertion that neither grouping applies necessarily fails for the same reasons. The Examiner incorporates by reference the full analysis provided in response to Arguments 1 through 6 and does not repeat that analysis here in its entirety, but addresses the overarching framing of this argument directly.
The 2019 PEG provision Applicant quotes that if a claim does not recite an abstract idea identified in the enumerated groupings it qualifies as eligible subject matter is legally correct as a statement of the framework. However, the operative question is whether the Examiner has properly established that the claims do recite an abstract idea within one or more of the enumerated groupings, and the Examiner submits that this has been properly established for both the mental process grouping and the methods of organizing human activity grouping. As explained in response the previous arguments, the core concept recited by the independent claims navigating relational data about entities through defined rules to identify connections relevant to financial crime and sanctions compliance evaluation, and presenting those identified connections to a user for selective exploration constitutes a mental process under its broadest reasonable interpretation because it covers the mental steps of observation, evaluation, and judgment that compliance analysts have performed long before computers existed. As explained in response to the previous arguments, the same core concept also constitutes a method of organizing human activity relating to commercial or legal interactions because the entire claimed system, viewed as a whole including the purpose defined in the preamble and implemented through the claim body, is directed to organizing the commercial compliance activities of financial institutions and their analysts.
Applicant's position that the recited steps cannot practically be performed in the human mind rests on characterizing the claims at the level of their specific technical implementation rather than at the level of the underlying concept to which they are directed. As the Examiner has explained, the relevant inquiry is not whether the precise computational implementation can be replicated mentally but whether the underlying concept covers performance in the human mind but for the recitation of generic computer components. The claims do not recite specific algorithms, specific computational architectures, specific rendering techniques, or any other technically specific implementation details that would distinguish the claimed operations from the generic performance of the underlying mental concept using generic computer components. The absence of such technically specific implementation details is itself significant it reflects that the claims are directed to the concept of navigating relational data to identify compliance-relevant pathways and presenting them to users, implemented using whatever generic computer technology is available to perform those functions, rather than to any specific technical improvement to graph database technology, graph traversal algorithms, or visual interface technology.
Moreover, even if Applicant were correct that the claims do not fall neatly within a single enumerated grouping, the 2019 PEG also instructs that when a claim recites multiple abstract ideas, examiners should consider the limitations together as a single abstract idea for further analysis rather than treating them as separate abstract ideas. The Examiner has properly identified that the claims recite both mental processes and methods of organizing human activity related to financial crime compliance, and has evaluated the full combination of claim limitations accordingly. The determination that the claims are directed to abstract ideas is not based on any single limitation in isolation but on the character of the claims as a whole, which is directed to using generic computer technology to perform the business process of financial crime compliance investigation. This determination is consistent with the applicable legal framework, the case law discussed throughout the prosecution history, and the 2019 PEG as applied by the Office.
Applicant has not presented any new arguments or evidence in this section beyond restating the positions advanced in the previous arguments, all of which have been fully considered and found unpersuasive. The Examiner has properly established at Step 2A Prong 1 that the claims recite judicial exceptions within the enumerated groupings of mental processes and methods of organizing human activity, and the analysis appropriately proceeds to Step 2A Prong 2 and Step 2B where it has been determined that the additional elements do not integrate the exceptions into a practical application and do not provide significantly more than the exceptions themselves. Accordingly, the rejection is maintained.
The Applicant argues on 17 that “even if the claims were found to recite an Abstract Idea, the claims are directed to technical problems rooted in computer technology. Even if the Examiner were correct that the claims recite an abstract idea (which Applicant does not concede), the claims are nonetheless patent eligible because they are directed to solving technical problems rooted in computer technology, and the claims recite a specific technical architecture that addresses those problems. Applicant respectfully submits the following analysis under Step 2A Prong 2 and Step 2B in the alternative”.
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that even if the claims recite an abstract idea, they are nonetheless patent eligible because they are directed to solving technical problems rooted in computer technology and recite a specific technical architecture that addresses those problems has been fully considered but is not persuasive. The Examiner respectfully disagrees and the rejection is maintained.
As an initial matter, the Examiner notes that this argument has been raised and addressed extensively throughout the prosecution history of this application, including in the Final Office Action and the Advisory Action, and the substantive positions advanced by Applicant in support of this contention have not changed in any material respect that would warrant a different conclusion. The Examiner addresses Applicant's argument here in the context of Step 2A Prong 2 and Step 2B as Applicant has framed it, incorporating the analysis from the previous arguments and the prior Office Actions.
Under Step 2A Prong 2, the question is whether the additional elements of the claim, considered individually and in combination, integrate the identified judicial exception into a practical application. An integration into a practical application requires that the additional elements impose a meaningful limit on the judicial exception such that the claim is not directed to the exception itself. One way to establish such integration is to demonstrate that the claim reflects an improvement to the functioning of a computer or to another technology or technical field, as discussed in MPEP 2106.05(a). However, as the Examiner has consistently maintained throughout prosecution, the claims here do not reflect any such improvement, and Applicant's characterization of the alleged technical problems and their solutions does not withstand scrutiny under the applicable legal standards.
With respect to the alleged technical problems, Applicant has previously argued that the specification identifies technical problems rooted in computer technology including what Applicant characterizes as a combinatorial explosion problem in graph traversal and an information overload or hairball problem in graph visualization. As addressed in the Advisory Action, the Examiner maintains that the specification's characterization of these problems is framed in terms of business challenges, not technical challenges. The specification states that existing systems "have been found thus far to be inadequate in providing the institution with a cogent and quick representation of the risk as new situations arise" and that "understanding and assessing the information down to relevant parts has been difficult to achieve." These statements describe the business problem of helping compliance analysts evaluate risk more efficiently they do not identify technical problems with graph database technology or computer visualization technology that the claimed invention overcomes. The combinatorial explosion Applicant references is simply the well-known mathematical reality that relationships grow exponentially in graph data this is not a technical problem with computers but rather a fundamental characteristic of relationship data that exists regardless of whether a computer is involved. The hairball problem similarly describes the challenge of presenting large amounts of interconnected information in an understandable way, which is an information presentation challenge, not a technical limitation of computer display technology. Tangled, difficult-to-follow relationship diagrams have existed in paper form for as long as people have drawn relationship charts, and the computer simply allows more relationships to be shown simultaneously this is a difference in scale, not a unique technical problem arising from computer technology.
With respect to the alleged technical solution, Applicant has argued that the claims recite a specific technical architecture comprising node-type-based traversal termination, computation and incremental storage of pathways, and selective path navigation through a visual workspace. As addressed in the Advisory Action, the Examiner maintains that these characterizations describe desired functional results at a high level of abstraction rather than a specific technical architecture. Defining a particular node type to end graph traversal means stopping the search when a certain type of entity is found this is a logical search criterion, not a technical architectural feature, and the claims do not explain any technical innovation in how this is implemented in a way that improves graph database technology. Computation and incremental storage of pathways is conventional data caching selecting and storing search results as they are found is a well-understood, routine, and conventional computer function that does not constitute a specific technical architecture. Selective path navigation through a visual workspace is simply allowing users to choose which information to view this is generic user interface functionality that does not recite any specific interface elements, display mechanisms, interaction techniques, or technical details about how the workspace addresses any alleged technical problem.
The critical deficiency that runs through all of Applicant's technical improvement arguments is the distinction between improving the technical functioning of computer technology and using computer technology to improve a business process. As consistently maintained throughout prosecution, the specification does not identify any shortcoming in existing graph database technology, graph traversal algorithms, or computer visualization technology that the claimed invention overcomes. The specification does not explain how the claimed traversal algorithm differs technically from known graph search algorithms such as breadth-first or depth-first search with pruning, does not explain how the claimed data structure provides technical advantages over conventional graph databases, and does not explain how the claimed visual workspace technically improves upon conventional display technology. The improvements described throughout the specification are improvements in how business information is organized and presented to humans for compliance evaluation purposes these are improvements to the business process of financial crime compliance investigation, not improvements to computer technology itself.
This distinction is well established in the case law. In Enfish, LLC v. Microsoft Corp., the claims recited a specific self-referential table data structure that improved the way the computer itself stores and retrieves data in memory the improvement was to computer functionality itself. In McRO, Inc. v. Bandai Namco Games Am. Inc., the claims recited specific rules that enabled automation of animation tasks that previously could only be performed subjectively by humans, improving the technological process of computer animation. In both cases, the specifications provided technical explanations of how the claimed inventions improved existing computer technology, and the claims reflected those improvements. Here, by contrast, the specification describes using conventional graph database technology and conventional graph traversal techniques to organize and present financial crime relationship information more efficiently to users. As noted in MPEP 2106.05(a), citing BSG Tech LLC v. Buyseasons, Inc., an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality. The claimed system improves the quality and organization of compliance information available to users it does not improve how graph databases or user interfaces function technologically.
Furthermore, as noted in MPEP 2106.05(f), claims that recite only the idea of a solution or outcome that is, claims that fail to recite details of how a solution to a problem is accomplished do not integrate a judicial exception into a practical application. The present claims recite functional results at a high level of generality: selectively identify relevant pathways, stop graph traversal, assist the user to efficiently self-navigate. These are outcome-based limitations that describe what the system does without explaining how the graph traversal algorithm is technically improved, how the data structure technically enhances database functionality, or how the visual workspace technically improves upon conventional display technology. The claims do not need to recite every implementation detail, but they must recite the specific claimed solution to a technical problem and here, as the Examiner has consistently maintained, the claims recite a business solution to a business problem using generic computer technology, not a technical solution to a technical problem.
Under Step 2B, the additional elements of the claim the generic processor, the generic graph database, the generic graph data structure, the generic traversal rules, the generic visual workspace, and the generic display functionality do not amount to significantly more than the identified judicial exceptions. Each of these elements is a well-understood, routine, and conventional computer component or computer function as of the priority date of this application. Storing data in databases, traversing data relationships, identifying items meeting search criteria, storing search results, displaying information to users, and allowing users to select information to view are all well-understood, routine, and conventional computer functions that were conventional in computer science well before the filing date of the original parent application. The combination of these conventional elements does not produce a non-conventional result that amounts to significantly more than the abstract idea it produces the expected result of using conventional computer technology to perform the business process of compliance investigation. Accordingly, the rejection is maintained.
The Applicant argues on pages 17-20 that “the specification identifies technical problems rooted in computer technology, not merely business problems. The Examiner characterizes the claims as directed to the "business problem of how to help users investigate financial crime relationships more efficiently." The Examiner further asserts that "the specification does not identify any technical problem with existing graph databases or graph traversal algorithms." Applicant respectfully submits that this characterization fundamentally misapprehends the nature of the problems identified in the specification and conflates the application domain with the nature of the problems themselves.
While the specification describes the invention in the context of financial crime compliance, the problems the invention addresses are technical problems that arise from the inherent characteristics of graph data structures and the computational challenges of presenting complex graph relationships to users. A problem described in business terms does not cease to be a technical problem simply because it is situated in a business context. What matters under the 101 inquiry is whether the root cause of the problem is technical and here, it plainly is”.
The specification states: "There are a number of existing systems but they have been found thus far to be inadequate in providing the institution with a cogent and quick representation of the risk as new situations arise. There is a tremendous amount of information, and understanding and assessing the information down to relevant parts has been difficult to achieve. The efficiency in providing such services and the way the information is interactively made available have also been inadequate. " 1140 (emphasis added).
The specification further states: "As new nodes are added to the system, a computer implemented process is implemented that traverses pathways from the new node to a node that is identified on a sanctions list and which relies on rules that identify only a subset of pathways for use by the customers. Thus, for example, in some embodiments, the system incrementally adds corridors and stores them instead of traversing the entire graph
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This technique also supports an interactive graphical interface of the system which provides an interactive tool for users to quickly and cogently understand risk using a visualization of one or more corridors This technique quickly adapts (he source data and in operation, quickly surfaces (he relevant information in a visual way for understanding by those in charge of evaluating financial crime and sanctions compliance issues at institutions. The known prior art is not able to accomplish such powerful results. " 1155 (emphasis added).
These statements, while framed in the language of the application domain, identify problems whose root causes are technical in nature. The problems are rooted in technology, not business or risk assessment. Large data sets are at least one reason for the rise of graphs (nodes/edges) and graph visualization, but as noted, graph visualization leads to the hairball problem. To demonstrate that these passages describe technical problems rather than business problems, Applicant rewrites the relevant specification language below by making it domain-agnostic, which highlights that the described problems are not tied exclusively to business or risk and that those of ordinary skill in the art would understand them as such.
"There are a number of existing systems but they have been found thus far to be inadequate in providing a cogent and quick representation of a type of relational information as new situations arise. There is a tremendous amount of information, and understanding and assessing the information down to relevant parts has been difficult to achieve. The efficiency in providing such services and the way the information is interactively made available have also been inadequate." 1140 (edited) "As new nodes are added to the system, a computer implemented process is implemented that traverses pathways from the new node to a node that is identified on a node type list and which relies on rules that identify only a subset of pathways for use by the customers. Thus, for example, in some embodiments, the system incrementally adds corridors and stores them instead of traversing the entire graph. This technique also supports an interactive graphical interface of the system which provides an interactive tool for users to quickly and cogently understand risk a type of relational information using a visualization of one or more corridors. This technique quickly adapts the source data and in operation, quickly surfaces the relevant information in a visual way for understanding by those in Charge of evaluating desired
The known prior art is not able to accomplish such powerful results." 1155. (edited).
When the domain-specific terms are removed, the technical character of these disclosures becomes evident. The specification describes a system that traverses pathways from a node to a designated node type, uses rules to identify a subset of pathways, incrementally adds and stores the subset of pathways, and supports an interactive graphical interface for quickly surfacing relevant information visually. These are descriptions of technical operations on technical data structures not descriptions of a business process.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that Applicant's argument that the specification identifies technical problems rooted in computer technology, supported by specific citations to the specification and a domain-agnostic rewrite of those passages intended to demonstrate their technical character, has been fully considered but is not persuasive. The Examiner acknowledges Applicant's methodological approach of rewriting the specification passages in domain-agnostic terms to highlight their alleged technical character, and appreciates the effort to demonstrate that the identified problems are not exclusively tied to the financial crime compliance domain. However, this approach does not overcome the fundamental deficiency in the specification's disclosure, which is not that the problems are described using domain-specific language, but rather that the specification fails to identify any specific technical limitation of existing graph database technology, graph traversal algorithms, or computer visualization technology, and fails to explain in technically sufficient detail how the claimed invention provides a technical solution to any such limitation. Removing domain-specific language from the specification passages does not add technical disclosure that is not present in the specification as filed, and the question of whether the specification provides sufficient technical detail to establish a technological improvement must be answered based on what the specification actually discloses, not on what it might be made to appear to disclose through rephrasing.
Turning to the specific specification passages Applicant cites, paragraph 40 states that existing systems "have been found thus far to be inadequate in providing the institution with a cogent and quick representation of the risk as new situations arise," that "there is a tremendous amount of information, and understanding and assessing the information down to relevant parts has been difficult to achieve," and that "the efficiency in providing such services and the way the information is interactively made available have also been inadequate." Even when rewritten in domain-agnostic terms as Applicant proposes, these statements describe functional inadequacies of existing systems in terms of what they fail to deliver to users cogent and quick representations, efficient surfacing of relevant information, and adequate interactive availability of information. These are descriptions of user-facing functional shortcomings, not technical problems with the underlying computer technology. The specification does not identify what specific technical characteristic of existing graph databases causes them to be unable to provide cogent and quick representations, does not identify what specific technical deficiency in existing graph traversal algorithms makes it difficult to surface relevant information efficiently, and does not identify what specific technical limitation of existing interactive visualization systems makes them inadequate for presenting relational information. The inadequacies described are experienced by users attempting to understand and assess large amounts of relational information these are information comprehension and presentation challenges, which are distinct from technical limitations of the underlying computer technology regardless of how the passages are framed.
With respect to paragraph [0055], which states that "the system incrementally adds corridors and stores them instead of traversing the entire graph" and that "this technique quickly adapts the source data and in operation, quickly surfaces the relevant information in a visual way," the Examiner acknowledges that this passage describes a computational approach of incremental pathway storage rather than full graph traversal. However, as addressed in the previous arguments, incremental storage of identified results rather than repeatedly traversing an entire dataset is a well-understood, routine, and conventional database optimization technique it is the well-known concept of caching or pre-computing query results to improve retrieval speed. The specification does not explain how this approach differs technically from known database caching and pre-computation techniques, does not identify any specific technical innovation in the incremental storage methodology, and does not describe any technical advantage over conventional approaches beyond the functional outcome of faster information retrieval. Stating that a system stores results incrementally rather than recomputing them on demand describes a functional design choice, not a technical innovation in database technology. Furthermore, the specification's characterization that "the known prior art is not able to accomplish such powerful results" is a conclusory assertion without technical support it does not identify what specific technical limitation of prior art systems prevents them from implementing incremental pathway storage, nor does it explain in technically specific terms why the claimed approach overcomes any such limitation.
Applicant's domain-agnostic rewrite, while creative, ultimately demonstrates the Examiner's point rather than undermining it. When the domain-specific terms are removed and replaced with generic equivalents substituting "type of relational information" for "financial crime risk" and "node type list" for "sanctions list" the resulting passages describe operations that are generic to any graph database system: traversing pathways from a node to a designated node type, using rules to identify a subset of pathways, incrementally storing that subset, and providing an interactive graphical interface for displaying the results. The fact that these operations can be described generically without reference to any specific domain confirms the Examiner's position that the specification describes applying generic graph database and visualization technology to a specific domain, rather than identifying and solving a technical problem with the underlying technology. As MPEP 2106.05(a) makes clear, citing BSG Tech LLC v. Buyseasons, Inc., an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality. The claimed system improves what information is surfaced and how it is presented to users it does not improve how the underlying graph database technology, traversal algorithms, or visualization systems technically function.
The standard established by MPEP 2106.05(a) requires that the specification provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing a technological improvement, and that such improvement would be apparent from the specification's technical disclosure rather than from attorney argument about what the specification implies. As the Federal Circuit held in Affinity Labs of Texas v. DirecTV, LLC, claims are ineligible where the specification fails to provide details regarding the manner in which the invention accomplished the alleged improvement. Here, the specification describes what the system does surfaces a subset of pathways for display rather than the entire graph without explaining how this is technically accomplished in a manner that improves upon conventional graph database or traversal technology. The absence of technically specific disclosure explaining how the claimed approach differs from and improves upon known graph search algorithms such as breadth-first or depth-first search with pruning, how the claimed data structure provides technical advantages over conventional graph databases, or how the claimed visual workspace technically improves upon conventional interactive visualization systems is a deficiency in the specification's disclosure that cannot be remedied through argument. The burden has shifted to Applicant to provide persuasive arguments supported by evidence, such as a declaration under 37 CFR 1.132 providing testimony from one of ordinary skill in the art regarding how the specification's disclosures would be understood as reflecting a technological improvement, and Applicant has not provided such evidence. Accordingly, the rejection is maintained.
The Applicant argues on page 20 that “the problem of combinatorial explosion in graph traversal. The specification expressly discloses that "the graph database 105 may store a large number of nodes and edges, their combinations may produce an enormous number of pathways." This is not a business observation it is a statement about the computational properties of graph data structures. The combinatorial explosion of paths in a graph is a well-known technical problem in computer science. As the number of nodes and edges in a graph grows, the number of possible pathways increases exponentially, rendering exhaustive traversal computationally infeasible. The specification identifies this technical reality and explains that the system "control[s] the number of iterations performed by the software engine 135 to save processing time and power consumption." Processing time and power consumption are quintessentially technical metrics they have nothing to do with business processes and everything to do with the computational demands placed on computer hardware.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that Applicant's argument that the specification's disclosure of combinatorial explosion in graph traversal identifies a genuine technical problem rooted in computer science, evidenced by the specification's reference to controlling iterations to save processing time and power consumption, has been fully considered but is not persuasive. The Examiner acknowledges that combinatorial explosion is a well-known concept in computer science and that the specification does contain the language Applicant cites that the graph database "may store a large number of nodes and edges" whose "combinations may produce an enormous number of pathways" and that controlling the number of iterations performed by the software engine serves "to save processing time and power consumption." The Examiner does not dispute that these are real computational considerations. However, the existence of a computational consideration in the specification does not, by itself, establish that the claimed invention provides a technical solution to a technical problem rooted in computer technology within the meaning of the patent eligibility framework. The relevant inquiry is not merely whether a technical phenomenon is mentioned in the specification, but whether the specification identifies a specific technical limitation of existing computer technology that the claimed invention overcomes through a specific technical solution, and whether the claims themselves reflect that technical solution. On both counts, the present application falls short of the required showing.
With respect to the nature of the alleged technical problem, the combinatorial explosion of paths in a graph is, as Applicant correctly notes, a well-known mathematical reality inherent to graph structures. It is precisely because it is a well-known and fundamental characteristic of graph data not a deficiency unique to any particular graph database implementation or graph traversal algorithm that it does not constitute a technical problem with existing computer technology in the relevant sense. Every graph traversal system, whether conventional or otherwise, operates in the context of this mathematical reality. The specification does not identify any specific technical limitation of existing graph database systems or graph traversal algorithms that causes them to be unable to handle this combinatorial reality it simply acknowledges that large graphs have many possible pathways and that the system limits traversal to manage this. The acknowledgment that large datasets produce computational challenges does not identify a technical problem with the underlying technology any more than acknowledging that sorting a large dataset takes more time than sorting a small one would identify a technical problem with sorting algorithms. These are natural consequences of computational scale, not technical deficiencies of existing computer technology that require a novel technical solution.
With respect to the specification's reference to saving processing time and power consumption, the Examiner maintains that these references describe the natural consequences of performing less computation, not a technical improvement to computer technology. As addressed in the previous arguments, any process that reduces the amount of computation performed will inherently reduce processing time and power consumption this is a mathematical inevitability, not a technological achievement. The specification does not explain any technical innovation that achieves these efficiencies beyond the straightforward observation that limiting the scope of traversal by stopping at certain node types and limiting degrees of separation reduces the number of paths that must be evaluated. This is the functional equivalent of saying that searching fewer documents is faster than searching more documents it is true, but it does not represent a technological improvement to search technology. The specification does not describe any novel algorithmic approach to managing computational complexity, does not explain how the claimed traversal rules differ technically from known pruning techniques used in conventional graph search algorithms, and does not identify any specific technical innovation in how processing time and power consumption are managed beyond the generic observation that limiting traversal scope reduces computational load.
This is a critical distinction from cases where courts have found genuine technical improvements based on computational efficiency. In cases such as Enfish and McRO, the specifications provided technically specific explanations of how the claimed approaches achieved computational improvements that were not achievable using conventional techniques the improvement was to the technical mechanism itself, not merely to the scope of what was computed. Here, the specification describes a business decision about what data is relevant for compliance analysis pathways that reach a designated node type within a maximum number of traversal steps and then notes that applying this business-driven scope limitation has the incidental effect of reducing processing time and power consumption. The efficiency gains described are byproducts of the business decision about what information is relevant, not the result of any technical innovation in how graph traversal or data storage is implemented. Processing time and power consumption are indeed technical metrics, but their reduction as a consequence of performing less computation does not establish a technological improvement when the reduction results from a business-driven decision about computational scope rather than from a technically novel approach to computation itself.
Furthermore, the claims themselves do not reflect any specific technical solution to the combinatorial explosion problem. The claims recite, at a high level of generality, that the system defines rules to select a starting node, designate a particular node type to end traversal, and end traversal using that node type, and that the system automatically performs graph traversal and stops at any node having the particular node type. These are functional descriptions of the outcome of the traversal process they describe what the system does in terms of its results without reciting any specific algorithmic approach, any specific computational architecture, any specific data structure optimization, or any other technically specific mechanism for addressing the combinatorial explosion problem. As noted in MPEP 2106.05(f), claims that recite only the idea of a solution or outcome without reciting details of how the solution is accomplished do not integrate a judicial exception into a practical application. The claims here recite the desired outcome of efficiently identifying relevant pathways without reciting the specific technical means by which the combinatorial explosion problem is addressed at the algorithmic or architectural level. This absence of technically specific claim language describing the solution to the alleged technical problem is itself a basis for maintaining the rejection, as it confirms that the claims are directed to the functional result of the business decision about what pathways are relevant rather than to any specific technical improvement in graph traversal technology. Accordingly, the rejection is maintained.
The Applicant argues on pages 20-21 that “Second, the problem of information overload in graph visualization the hairball problem
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The specification's statement that prior systems were "inadequate in providing… a cogent and quick representation" and that "the way the information is interactively made available" was "inadequate" identifies a problem that arises directly from the technical challenge of presenting complex graph data to users through a computer interface. As described in Section A above, when a graph contains enormous numbers of nodes, edges, and pathways, displaying all relationships simultaneously on a computer display produces a "hairball" a tangled mass of nodes and links that is impossible to analyze. This is a recognized technical problem in the field of data visualization and human computer interaction it is a problem that exists only in the context of computer technology and cannot arise outside the computing environment. The need for a "cogent" representation is not merely a business preference; it reflects the technical reality that uncontrolled graph visualization produces displays that are functionally useless because the human visual system cannot process the volume of information presented.
The Examiner's insistence that these must be characterized exclusively as "business problems" ignores the well-established principle that a problem situated in a business context may nonetheless be a technical problem at its core. The Federal Circuit has repeatedly looked past the business application of an invention to examine whether the underlying problem and solution are technical in nature.
Moreover, the specification expressly contemplates that the technology is not limited to financial crime or any single business application. The specification states: embodiments described herein are primarily described in the context of providing a tool for evaluating prospective financial crime and sanctions-related risks for businesses considering commercial dealings, but it should be understood that applications in other areas including application of particular features in other areas are contemplated." Ill 14. It further states: "applications of the technology to other fields are also contemplated." Ill 17. And: "Embodiments illustrated herein are directed to financial crime and sanctions-related solutions and have particular suitability to solving and assisting users with financial crime and sanctions compliance related issues. It should be understood that described features or systems can have broader or different applications." 1156. Such applications are known and include drug discovery and cybersecurity. The technical problems addressed by the claims combinatorial explosion in graph traversal and the hairball problem in graph visualization are domain-agnostic technical problems that arise whenever large, richly connected graph data sets must be traversed and visually presented
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.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the hairball problem in graph visualization constitutes a recognized technical problem rooted in computer technology that exists only in the computing environment, and that the specification's broader application statements demonstrate the domain-agnostic technical nature of the claimed invention, has been fully considered but is not persuasive.
The Examiner acknowledges that information overload in graph visualization is a recognized challenge in the field of data visualization and human-computer interaction, and does not dispute that displaying large numbers of nodes, edges, and pathways simultaneously on a computer display can produce cluttered and difficult-to-analyze visualizations. However, as addressed in the previous arguments, the existence of a recognized challenge in a technical field does not automatically establish that the claimed invention provides a specific technical solution to a specific technical problem within the meaning of the patent eligibility framework. The relevant inquiry remains whether the specification identifies a specific technical limitation of existing computer visualization technology and explains in technically sufficient detail how the claimed invention overcomes that limitation through a technical solution that is reflected in the claims. The present specification and claims do not satisfy this standard with respect to the hairball problem any more than they do with respect to the combinatorial explosion problem addressed previously.
With respect to the nature of the hairball problem as a technical versus business problem, the Examiner maintains that while the challenge of presenting large amounts of interconnected graph data in a comprehensible visual form does arise in the context of computer visualization systems, it is not a problem that exists exclusively in the computer context as Applicant asserts. Complex and difficult-to-follow relationship diagrams have existed in non-computer contexts for as long as people have drawn network diagrams, organizational charts, relationship maps, and other visual representations of interconnected information. Investigators, analysts, and researchers working with paper-based relationship charts have long faced the challenge of managing information overload when the number of relationships to be represented exceeds what can be clearly displayed on a page or comprehended at a glance. The computer does not create this problem it simply allows larger datasets to be represented, which means the challenge manifests at a greater scale in the computer context. This is a difference in scale and magnitude, not a qualitatively different technical problem unique to computer technology. The Federal Circuit addressed an analogous situation in the context of the present application's prosecution history, noting that the challenge of understanding complex relationships in large datasets existed before computers and that the computer simply allows larger datasets to be analyzed. A problem that exists in non-computer contexts and is merely amplified by the use of computers is not a technical problem rooted in computer technology in the sense required by the patent eligibility framework.
Furthermore, the specification's description of the hairball problem and its solution does not provide the technically specific disclosure necessary to establish a technological improvement to computer visualization technology. The specification states that prior systems were inadequate in providing a cogent and quick representation of relational information and that the way information is interactively made available was inadequate. As addressed in the previous arguments, these statements describe functional shortcomings experienced by users they do not identify specific technical limitations of existing computer visualization systems such as rendering bottlenecks, display buffer constraints, pixel-level processing inefficiencies, or other technically specific deficiencies of computer display technology. The specification's solution to the information overload problem is to pre-identify a subset of relevant pathways through the traversal and rule-application process and then allow users to selectively add those pre-identified pathways to the visual workspace rather than displaying all relationships simultaneously. This is an organizational and informational approach to managing what is displayed it is a decision about which information to present to users, not a technical improvement to how computer visualization systems render or process graphical information. The improvement is in the selection and organization of the information content presented to users, which as previously noted is an improvement to the information stored and presented by the system rather than an improvement to the technical functionality of the visualization system itself. As MPEP 2106.05(a) makes clear, citing BSG Tech LLC v. Buyseasons, Inc., an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality, and the same principle applies to improvements in the information displayed by a visualization system versus improvements to the technical functionality of the visualization system itself.
The claims similarly fail to recite any specific technical solution to the hairball problem at the level of computer visualization technology. The claims recite that the system provides a visual workspace adapted to allow a user to interact with graphic representations of nodes and edges and to selectively add relevant pathways to that workspace, displaying them using separate visual graphical elements for nodes and edges. These are generic functional descriptions of displaying information and allowing user selection they do not recite any specific rendering technique, any specific display mechanism, any specific approach to managing visual complexity at the pixel or display buffer level, or any other technically specific implementation detail that would distinguish the claimed visual workspace from conventional graph visualization systems. The claims describe what information is displayed and how users interact with it at a high functional level, without reciting how the display technology is technically improved to address the hairball problem. As consistently noted throughout prosecution, the claims describe generic display and selection functionality applied to pre-identified pathway information, which is generic user interface functionality that does not constitute a technical improvement to computer visualization technology.
With respect to Applicant's argument that the specification's statements about broader applications beyond financial crime compliance demonstrate the domain-agnostic technical character of the claimed invention, the Examiner respectfully submits that this argument cuts against Applicant's position rather than supporting it. The specification's acknowledgment that the described features can have broader or different applications and that applications in other areas are contemplated confirms that the claims are not tied to any specific technical implementation that would constitute a technological improvement they describe a generic approach to graph traversal and visualization that can be applied across multiple domains precisely because it relies on conventional, domain-agnostic computer technology. The breadth of potential application reflects the generic nature of the claimed approach, not its technical specificity. A claim that broadly covers the application of conventional graph database technology and conventional visualization techniques to any domain where large connected datasets must be traversed and presented to users is directed to the generic use of those conventional technologies, not to a specific technical improvement to them. The Federal Circuit and the Supreme Court have consistently cautioned against allowing broad patent protection for the application of conventional technology to new domains, regardless of how many domains that application might cover.
Applicant's observation that the technical problems of combinatorial explosion and the hairball problem are domain-agnostic and arise whenever large, richly connected graph datasets must be traversed and visually presented is accurate as a factual matter, but does not support the conclusion Applicant draws from it. The fact that these challenges are domain-agnostic means that they are general characteristics of working with large graph data they are not specific technical problems with existing computer technology that the claimed invention overcomes through a specific technical solution. The claimed invention addresses these general challenges through the business decision of limiting traversal scope to pathways of compliance relevance and pre-identifying those pathways for selective user display. This is a domain-specific application of conventional graph database and visualization technology to manage the information presented to compliance analysts, not a technical innovation in graph traversal algorithms or visualization systems that would benefit any domain in which large graph datasets are processed. The domain-agnostic nature of the underlying challenges does not transform the claimed domain-specific application of conventional technology into a technical improvement to that technology. Accordingly, the rejection is maintained.
The Applicant argues on pages 21-23 that “the technical problems are rooted in computer technology under DDR Holdings and Amdocs. As stated in DDR Holdings, LLC v. Hotels.com„ L.P. 773 F.3d 1245 (Fed. Cir. 2014), to the extent the claims "address a business challenge it is a challenge particular to the Internet," (id. at 1257) and is not directed to "applying a known business process." (id. at 1259). "The claimed solution is rooted in computer technology in order to overcome a problem specifically arising in the realm of computer networks." Id. at 1257. The same is true here. The hairball effect arises from graph visualization caused by large richly connected graph data sets in the computer realm and computer interfaces. These problems do not exist outside the computer context. There is no analog to a "hairball" in the non-computer world the problem arises specifically and exclusively from the attempt to visualize large graph data sets on a computer display. The problems are rooted in computer technology because it is in the computer or software context and it can only be in that context. It is not manageable or useful otherwise. The problem resides in that context and arises from the application of the technology in that context.
The Federal Circuit's decision in Amdocs (Israel) Ltd. v. Openet Telecom. Inc. 841 F.3d 1288 (Fed. Cir. 2016), is also directly instructive. In Amdocs, the Federal Circuit affirmed that a system designed to solve an accounting and billing problem faced by network service providers was patent-eligible. Id. Although this was a business problem, it was also a "technological" problem due to "massive records flows" that "required massive databases." Id. at 1300. This is similar to the technical problem arising from the large data sets in the present application. The claims were directed to a system for processing network accounting data, an activity that could be characterized as a "business process" of network billing. But the Federal Circuit found the claims patent-eligible because the specification described technical problems with existing data processing systems and the claims recited a specific technical architecture, a distributed processing system that handled data closer to the source, to address those problems. The court looked to the specification to understand the technical character of the claimed invention, finding that the specific architectural approach constituted an improvement to computer technology.
The present claims are closely analogous to Amdocs in both the nature of the technical problem and the character of the technical solution.
In Amdocs the technical problem was the challenge of processing massive amounts of network data efficiently using a centralized architecture, which created processing bottlenecks. Here, the technical problem is the challenge of traversing and presenting data from a graph database that "may store a large number of nodes and edges" whose "combinations may produce an enormous number of pathways," creating computational demands that consume excessive processing time and power consumption." Both involve the technical challenge of managing data at scale in a manner that exceeds the capacity of straightforward approaches. The problems arise because they exist in the computer or software context and can only exist in that context. Like the massive record flows in Amdocs the combinatorial explosion and hairball problem here are inherently computational they are not problems that can be addressed by human activity or pen and-paper methods.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the claimed invention is analogous to DDR Holdings and Amdocs because the alleged technical problems of combinatorial explosion and the hairball effect are rooted in computer technology and cannot exist outside the computer context has been fully considered but is not persuasive. The Examiner has carefully considered both DDR Holdings, LLC v. Hotels.com, L.P., and Amdocs (Israel) Ltd. v. Openet Telecom, Inc., and submits that both cases are distinguishable from the present application in ways that are fundamental to the patent eligibility analysis. While Applicant draws surface-level analogies between the scale of data involved in Amdocs and the large graph datasets described in the present specification, and between the Internet-specific problem in DDR Holdings and the alleged computer-specific nature of the hairball problem, these analogies do not withstand careful scrutiny under the applicable legal framework when applied to the actual claims and specification before the Examiner.
Turning first to DDR Holdings, the Federal Circuit found the claims patent eligible because they addressed a problem that was particular to the Internet specifically, the challenge of retaining website visitors who click on third-party merchant links, which would otherwise navigate the visitor away from the host website. The court found that this problem arose specifically from the architecture of the Internet and the way web browsers navigate between websites, and that the claimed solution generating a composite webpage that maintains the look and feel of the host website while displaying third-party merchant content was rooted in computer technology because it overrode the routine and conventional sequence of events ordinarily triggered by clicking a hyperlink on the Internet. The key to the DDR Holdings analysis was that the problem was not merely a business problem that happened to arise in an Internet context, but rather a problem that was created by the specific technical architecture of the Internet itself the hyperlink navigation mechanism that causes browsers to leave a host website and that the claimed solution addressed that specific technical mechanism in a non-conventional way. The claims in DDR Holdings recited specific technical steps for how the composite webpage was generated and served that departed from the conventional operation of Internet hyperlinks, not merely a functional description of the desired outcome.
The present claims are not analogous to DDR Holdings in any of these critical respects. As addressed in the previous arguments, the challenge of managing information overload in relationship data is not a problem created by the specific technical architecture of graph database systems or graph visualization technology in the way that the hyperlink navigation problem was created by the specific technical architecture of the Internet. The challenge of presenting large amounts of interconnected relationship information in a comprehensible form predates computer graph visualization systems and arises in any context where complex relationship data must be represented, whether on paper, in tabular form, or through computer visualization. Furthermore, and most critically, the claims do not recite any specific technical mechanism that addresses the hairball problem by departing from the conventional operation of graph visualization systems in a non-conventional way they recite generic functional descriptions of displaying pre-identified pathway information and allowing user selection, which is precisely the conventional operation of graph visualization and user interface systems. The absence of specific technical claim language describing a non-conventional technical approach to the alleged problem is a fundamental distinction from DDR Holdings that cannot be overcome through argument about the nature of the problem alone.
Turning to Amdocs, the Federal Circuit's decision rested on several specific features of the claims and specification that are absent here. In Amdocs, the specification identified specific technical problems with existing centralized network accounting architectures namely that centralized processing of massive network data flows created processing bottlenecks that could not be overcome within the constraints of available network bandwidth and processing capacity. Critically, the specification in Amdocs provided technically specific disclosure of how the claimed distributed processing architecture addressed these bottlenecks by processing data close to its source rather than transmitting it to a central processor, and the claims reflected this specific architectural approach by reciting the distributed processing components and their technical relationships. The Federal Circuit found the claims patent eligible not merely because the problem involved large amounts of data, but because the specification identified specific technical limitations of existing centralized architectures and the claims recited a specific non-conventional technical architecture distributed processing close to the data source that addressed those limitations in a technically specific way. The claims in Amdocs were not merely functional descriptions of the desired outcome of efficient network data processing; they recited the specific distributed architectural components and their technical relationships that achieved that outcome in a non-conventional manner.
The present claims are not analogous to Amdocs in any of these critical respects. Applicant's analogy focuses on the scale of the data involved noting that both Amdocs involved massive network data flows and the present application involves large graph datasets with enormous numbers of potential pathways. However, the scale of the data involved was not the basis for patent eligibility in Amdocs it was the specific technical architecture that addressed the processing bottlenecks created by that scale that made the claims patent eligible. The Federal Circuit did not hold that any claim directed to processing large datasets is patent eligible; it held that the specific distributed processing architecture recited in those particular claims constituted a non-conventional technical solution to a specific technical problem with existing centralized processing architectures. The present claims do not recite any analogous specific technical architecture. As addressed in the previous arguments, the claims recite generic functional descriptions of storing data in a graph data structure, defining traversal rules, automatically traversing pathways, and providing an interactive visual workspace one of which constitutes a specific non-conventional technical architectural approach to addressing the computational challenges of large graph datasets. The claims do not specify how the traversal is implemented algorithmically, do not recite any specific architectural approach to managing computational complexity, do not describe any specific technical mechanism for addressing the hairball problem in visualization beyond the generic concept of selectively displaying pre-identified pathways, and do not explain how any of these functional operations are implemented in a technically non-conventional manner that departs from known approaches to graph database and visualization technology.
Furthermore, the specification in the present application does not provide the technically specific disclosure that supported the Amdocs finding of patent eligibility. The Amdocs specification identified specific technical limitations of existing centralized network accounting architectures in technically specific terms and explained in technically specific terms how the distributed processing architecture overcame those limitations. The present specification, as addressed in the previous arguments, describes the inadequacy of existing systems in functional and user-facing terms systems are inadequate in providing cogent and quick representations of risk, and information is difficult to assess down to relevant parts without identifying specific technical limitations of existing graph database systems or graph traversal algorithms. The specification describes the claimed solution in terms of its functional outcomes the system surfaces relevant pathways quickly and efficiently and enables users to navigate the data visually without providing technically specific explanations of how the claimed traversal and visualization approach improves upon the technical operation of existing graph database and visualization systems. This absence of technically specific disclosure is a fundamental distinction from Amdocs that cannot be bridged by the analogy to large data scale alone.
Applicant's assertion that the combinatorial explosion and hairball problems are inherently computational and cannot be addressed by human activity or pen-and-paper methods has been addressed in the previous arguments and the Examiner maintains that position here. The mathematical reality that the number of possible paths through a graph grows exponentially with graph size is a characteristic of graph structures that exists regardless of whether they are implemented computationally, and the challenge of presenting complex relationship information comprehensibly is a challenge that exists in non-computer contexts as well. Neither of these challenges constitutes a problem created by the specific technical architecture of computer systems in the manner that the hyperlink navigation problem in DDR Holdings was created by the specific technical architecture of the Internet. The fact that these challenges are more pronounced at the scale enabled by computer systems does not transform them into computer-specific technical problems of the type recognized as supporting patent eligibility under DDR Holdings and Amdocs. Accordingly, the rejection is maintained.
The Applicant argues on pages 23-24 that “the claim generality alone does not preclude Patent Eligibility. The Examiner asserts that the claims are not patent eligible because they are recited at a high level of generality, citing Electric Power Group. LLC v. Alstom S.A.. 830 F.3d 1350 (Fed. Cir. 2016). However, claim generality is not determinative of patent eligibility. Numerous Federal Circuit decisions involve claims written at a high level of generality that nevertheless satisfied the patent eligibility requirements because the claims recited a technical improvement. See Enfish LLC v. Microsoft Corp., 822 F.3d 1327, 1336 (Fed. Cir. 2016); McRO Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299, 1316 (Fed. Cir. 2016); Data Engine Technologies LLC v. Google LLC, 906 F.3d 999, 1009 (Fed. Cir. 2018).
For example, in Data Engine, Claim 1 of the '259 patent was held to be patent eligible despite the absence of any implementation details in the claim language. The court found that the claim recited a specific technical solution the use of tab identifiers with descriptive names as page coordinates for navigating three-dimensional spreadsheets that constituted an improvement to computer functionality, even though the claim did not detail the underlying mechanisms by which those references were interpreted or resolved. See Data Engine, 906 F.3d at 1007-09. Similarly, in Enflsh, the court found eligibility where the claims described a self-referential table that improved how the computer stores and retrieves data in memory, without requiring extensive implementation specifics. Enfish, 822 F 3d at 1335-36. In McRO, the court held that claims incorporating particular rules enabling the automation of specific animation tasks were patent eligible because they improved an existing technological process, notwithstanding the generality of the claim language.
McRO, 837 F.3d at 1314-16.
These cases establish that where claims recite a technical improvement whether to the functioning of a computer or to any other technology or technical field the Examiner cannot rely on the purported simplicity or generality of the claim language to conclude that the claims are not patent eligible. The relevant inquiry under the Alice / Mayo framework is whether the claims, considered as a whole, are directed to an improvement in technology, not whether they recite implementation details at a particular level of specificity. Accordingly, asserting that the claims are at a high level of generality does not negate that there is a technical improvement, and such an assertion alone is insufficient to sustain a rejection under 35 U.S.C. 101
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The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that claim generality alone does not preclude patent eligibility, supported by citations to Enfish, McRO, and Data Engine, has been fully considered but is not persuasive. The Examiner agrees with Applicant's statement of the general legal principle claim generality alone is not determinative of patent eligibility, and the Examiner does not maintain the rejection solely on the basis that the claims are written at a high level of generality. As previously addressed throughout prosecution, the basis for the rejection is not that the claims are too general, but rather that the claims, at whatever level of generality they are written, are directed to abstract ideas mental processes and methods of organizing human activity without reciting additional elements that integrate those abstract ideas into a practical application or provide significantly more. The Examiner acknowledges this distinction and addresses Applicant's cited authorities directly to explain why they support the Examiner's position rather than undermining it.
Applicant's reliance on Enfish, McRO, and Data Engine is misplaced because each of those cases involved claims that, regardless of their level of generality, recited a specific technical solution to a specific technical problem with existing computer technology and crucially, the specifications in each case provided technically specific disclosure that allowed one of ordinary skill in the art to recognize the claimed invention as constituting a technological improvement. The present claims and specification do not satisfy this standard, and the level of claim generality is relevant not as an independent basis for rejection but as evidence of the absence of a specific technical solution to a specific technical problem.
In Enfish, the claims recited a specific self-referential table data structure a particular way of organizing data in computer memory in which a table could define itself using its own rows, allowing the computer to store and retrieve data more efficiently than conventional relational database models. The technical problem was a specific limitation of conventional relational database architectures in organizing certain types of data in computer memory, and the technical solution was a specific data structure that improved how the computer itself organized and accessed that data. The specification provided technically specific disclosure explaining how the self-referential table differed from conventional relational database models and why it provided concrete technical advantages in memory organization and data retrieval. The claims were patent eligible not because of any particular level of generality or specificity, but because they recited a specific technical solution the self-referential table to a specific technical problem with existing computer memory organization, and the specification supported that finding with technically specific disclosure. The present claims do not recite any analogous specific data structure that improves how the computer itself organizes or accesses data. The claimed graph data structure comprising edges, nodes, and attributes is a conventional graph database structure, not a novel data structure that improves computer memory organization or data retrieval in a technically specific way. The specification does not identify any technical limitation of conventional graph database structures that the claimed data structure overcomes, and does not explain in technically specific terms how the claimed structure improves upon conventional graph database technology.
In McRO, the claims recited specific rules a specific set of morph weight sets and phoneme sequences that enabled the computer to automate lip synchronization tasks in character animation that previously could only be performed subjectively by human animators. The technical problem was a specific limitation of existing computer animation technology its inability to automate tasks that required subjective human judgment about the relationship between phoneme sequences and facial movements and the technical solution was a specific set of rules that replaced that subjective human judgment with an automated computational process. The specification provided technically specific disclosure explaining how the particular rules enabled the automation of these specific animation tasks in a manner that had not previously been achievable computationally. The claims were patent eligible because they recited specific rules that improved an existing technological process of computer animation in a technically specific and previously unachievable way. The present claims do not recite any analogous specific rules that enable the computer to perform a task previously achievable only through subjective human judgment. The claimed rules for controlling graph traversal selecting a starting node, designating a particular node type to end traversal, and ending traversal at that node type are functional parameters of any graph traversal algorithm, not specific rules that enable the computer to perform a previously unachievable technical operation. As addressed in the previous arguments, these are standard parameters of conventional graph search algorithms defining where to start, where to stop, and what criteria to use for path selection and the claims do not explain how these rules are implemented in any technically innovative manner that departs from conventional graph traversal approaches.
In Data Engine, the claims recited a specific technical mechanism tab identifiers with descriptive names used as page coordinates in formulas for navigating multi-dimensional spreadsheet data stored in computer memory. The technical problem was a specific computer-based challenge of enabling users to reference cells across multiple two-dimensional page arrays when those pages are part of a three-dimensional matrix stored in computer memory, which is a problem that arises specifically from the way computers store and organize multi-dimensional data structures and that does not exist outside the computer context. The technical solution was a specific mechanism using descriptive tab names as page coordinates in cross-page cell references that addressed this computer-specific problem in a technically specific way. The Federal Circuit found the claims patent eligible because they recited a specific technical solution to a problem unique to computer-based multi-dimensional data structures, even though the claims did not recite implementation details such as how the tab identifiers were rendered or how the formula parser resolved the references. As addressed in the previous arguments, the present claims are not analogous to Data Engine because the problems identified in the specification are not problems unique to computer technology in the relevant sense, and the claims do not recite a specific technical solution to any computer-specific problem. The challenge of navigating complex relationship data to identify relevant connections is not a problem that arises specifically from the way computers store or organize graph data it is a challenge that exists independently of the computer context and that the claimed system addresses by applying conventional graph database and visualization technology to organize and present compliance information to users.
The common thread running through Enfish, McRO, and Data Engine that distinguishes them from the present case is not the level of claim generality but the presence of a specific technical solution to a specific technical problem, supported by technically specific specification disclosure. In each of those cases, the claims recited the specific technical mechanism the self-referential table, the specific morph weight rules, the tab identifier coordinate system that constituted the technical improvement, and the specifications explained in technically specific terms how those mechanisms improved upon existing technology. The present claims recite functional outcomes selectively identify relevant pathways, stop graph traversal, assist the user to efficiently self-navigate without reciting the specific technical mechanism by which those outcomes are achieved in a manner that improves upon conventional graph database or visualization technology. And the present specification describes the business value of those functional outcomes compliance analysts can more efficiently investigate financial crime relationships without providing technically specific disclosure of how the claimed approach improves upon the technical operation of existing graph database systems, traversal algorithms, or visualization technology.
The Examiner therefore maintains that the rejection is not based on claim generality per se, but on the absence of a specific technical solution to a specific technical problem that is reflected in the claims and supported by technically specific specification disclosure. Claim generality is relevant as evidence of this absence the functional, outcome-based nature of the claim language is consistent with and reflective of the fact that the claims are directed to the desired business outcome of efficient compliance investigation rather than to any specific technical mechanism for improving graph database or visualization technology. The level of generality at which the claims are written makes it impossible to identify any specific technical improvement to computer technology that the claims reflect, which is precisely the type of claiming that courts have found insufficient to establish patent eligibility regardless of the level of generality involved. Accordingly, the rejection is maintained.
The Applicant argues on pages 24-25 that “claims recite a specific technical architecture that solves these technical problems. The technical solution is described in the specification and recited in the claims. For ease of discussion, the claims are discussed in abbreviated form to address the patent eligibility rejection. The discussion is not intended to alter the claim language.
Applicant quotes again the above paragraph 55 with the domain-agnostic markings: "As new nodes are added to the system, a computer implemented process is implemented that traverses pathways from the new node to a node that is identified on a node type list and which relies on rules that identify only a subset of pathways for use by the customers. Thus, for example, in some embodiments, the system incrementally adds corridors and stores them instead of traversing the entire graph. This technique also supports an interactive graphical interface of the system which provides an interactive tool for users to quickly and cogently understand ask a type of relational information using a visualization of one or more corridors. This technique quickly adapts the source data and in operation, quickly surfaces the relevant information in a visual way for understanding by those in charge of evaluating desired applications. The known prior art is not able to accomplish such powerful results." 1155 (edited).
This paragraph discusses the use of nodes and edges, the use of graph database technology. A set of rules that control path traversal are also discussed that includes the designation and use of a node type. The traversal using the rules identifies certain associated pathways for the starting node. Further, the paragraph describes having an interactive visual display that the user can selectively add the found associated pathways for a starting node in the display.
In Amdocs the technical solution was a distributed architecture that processed records close to the source rather than centralizing everything. Here, the technical solution is an integrated architecture comprising three components, each of which addresses a distinct technical dimension of the problem.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the argument as presented appears to be incomplete, as Applicant indicates that the claims recite an integrated architecture comprising three components that each address a distinct technical dimension of the problem but does not complete the identification or description of those three components in the argument as submitted. The Examiner will respond to the substance of the argument as presented and reserves the right to address any additional components or arguments when they are fully presented. To the extent Applicant intends to supplement this argument, the Examiner encourages Applicant to present the complete argument so that it may be fully considered.
With respect to the argument as presented, Applicant's contention that specification paragraph [0055], read in domain-agnostic form, describes a specific technical architecture analogous to the distributed processing architecture found patent eligible in Amdocs has been fully considered but is not persuasive. The Examiner respectfully disagrees and the rejection is maintained.
As an initial matter, the Examiner notes that Applicant's reliance on the domain-agnostic rewrite of specification paragraph [0055] has been addressed in the previous arguments, and the Examiner incorporates that analysis here. The rewriting of specification language in domain-agnostic terms does not add technical disclosure that is not present in the specification as filed, and the question of whether the specification provides sufficient technical detail to establish a technological improvement must be answered based on what the specification actually discloses. Paragraph [0055], whether read in its original form or in Applicant's domain-agnostic rewrite, describes functional operations and their business outcomes the system traverses pathways using rules, identifies a subset of relevant pathways, stores them incrementally rather than traversing the entire graph, and provides an interactive visual interface for displaying those pathways. These are functional descriptions of what the system does and why it is useful, not technically specific descriptions of how the system implements these operations in a manner that improves upon conventional graph database, traversal, or visualization technology.
Applicant's analogy to Amdocs fundamentally misapprehends what made the Amdocs architecture patent eligible. As addressed in the previous arguments, the Federal Circuit in Amdocs did not find patent eligibility merely because the claims involved a multi-component system architecture that addressed a problem of data processing at scale. The eligibility finding in Amdocs rested on the specific technical nature of the architectural solution a distributed processing system that processed network accounting records close to their source rather than transmitting them to a centralized processor which addressed specific technical bottlenecks in existing centralized network accounting architectures that arose from limitations in network bandwidth and centralized processing capacity. The Amdocs specification provided technically specific disclosure of how the distributed architecture overcame those specific technical bottlenecks, and the claims reflected that specific architectural approach by reciting the distributed processing components and their technical relationships in a manner that distinguished the claimed architecture from conventional centralized approaches. The eligibility of the Amdocs claims was grounded in the technical specificity of both the identified problem and the claimed solution, not merely in the fact that a multi-component architecture was recited.
The present claims and specification do not satisfy the Amdocs standard in any of these critical respects. Applicant characterizes the claimed architecture as comprising three components that each address a distinct technical dimension of the problem, but even accepting this characterization for the purpose of argument, the mere organization of claim limitations into three labeled components does not constitute a specific technical architecture in the sense relevant to the patent eligibility analysis. The relevant question is not whether the claim elements can be organized into a multi-component architecture, but whether each component recites a specific technical mechanism that addresses a specific technical limitation of existing technology in a non-conventional way, and whether the combination of components produces a technical result that goes beyond the expected combination of their individual functions. As the Examiner has consistently maintained throughout prosecution, the claim limitations storing data in a graph data structure, defining traversal rules based on node types and maximum traversal depth, automatically traversing pathways and stopping at designated node types, storing identified pathways, providing a visual workspace, and enabling selective addition of pathways to that workspace are each individually conventional computer functions, and their combination produces the expected result of using conventional computer technology to perform the business process of compliance investigation.
Furthermore, the specification does not provide the technically specific architectural disclosure that would be necessary to establish that the combination of these elements constitutes a non-conventional technical architecture. The specification describes the functional purpose and business value of each component of the claimed system without explaining in technically specific terms how any component is implemented in a manner that departs from conventional approaches to graph database management, graph traversal, or interactive visualization. As addressed in the previous arguments, the specification does not explain how the claimed traversal rules differ technically from known pruning techniques in conventional graph search algorithms, does not explain how the incremental pathway storage differs technically from conventional database caching and pre-computation, and does not explain how the visual workspace implements any specific technical improvement to conventional graph visualization systems. Without this technically specific disclosure, the characterization of the claimed elements as constituting a specific technical architecture does not establish that the architecture reflects a technological improvement rather than the application of conventional technology to a business problem.
The Examiner further notes that Applicant's description of paragraph [0055] as discussing the use of nodes and edges, graph database technology, traversal rules, node type designation, pathway identification, and interactive visual display confirms rather than undermines the Examiner's position. Each of these elements graph databases with nodes and edges, rule-based traversal, node type designation, pathway storage, and interactive visual display is a conventional element of graph database and visualization technology. The description in paragraph [0055] of how these conventional elements are combined to surface relevant pathways for compliance analysts is a description of the application of conventional technology to a business problem, not a description of a specific technical architecture that improves upon conventional technology. As MPEP 2106.05(a) makes clear, an improvement to the information stored and surfaced by a database is not equivalent to an improvement in the database's functionality, and the claimed system's ability to surface a relevant subset of pathways for compliance analysis improves the organization and presentation of compliance information, not the technical functioning of the underlying graph database, traversal, or visualization technology.
The Examiner will fully consider the additional arguments Applicant presents below regarding the three components of the alleged technical architecture once those arguments are completely submitted. However, based on the argument as presented and the consistent analysis maintained throughout prosecution, the Examiner submits that the characterization of the claimed elements as constituting a specific technical architecture does not overcome the fundamental deficiency identified throughout this prosecution the absence of a specific technical solution to a specific technical problem with existing computer technology that is reflected in the claims and supported by technically specific specification disclosure. Accordingly, the rejection is maintained.
The Applicant argues on page 25 that “(l) node-type-based traversal termination. The claims recite a system that defines "a particular node type to end graph traversal of a pathway" and that performs traversal by stopping "at any node that has the particular node type." The specification explains that a type of node is specified or designated within the system as having different properties than other nodes. This is a specific data structure mechanism a particular type of node with particular properties that constrains the behavior of the traversal algorithm. It is not a generic description of "where to stop searching"; rather, it defines a specific architectural relationship between a data structure (the designated node type) and a processing operation (the traversal algorithm), whereby the data structure itself controls the behavior of the algorithm. This is analogous to the self-referential table in Enfish„ LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016), where a specific data structure improved how the computer stored and retrieved data”.
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the node-type-based traversal termination limitation constitutes a specific technical architectural component analogous to the self-referential table in Enfish, whereby a specific data structure controls the behavior of a traversal algorithm, has been fully considered but is not persuasive. Applicant's characterization of the node-type-based traversal termination as defining a specific architectural relationship between a data structure and a processing operation whereby the designated node type with particular properties controls the behavior of the traversal algorithm is an attorney argument about what the claim limitation implies rather than a technically specific description of what the claim limitation actually recites. The claim language states that the system defines "a particular node type to end graph traversal of a pathway" and performs traversal by stopping "at any node that has the particular node type." Under its broadest reasonable interpretation, this limitation recites the functional concept of designating a category of nodes as traversal endpoints and stopping traversal when a node of that category is encountered. This is a logical search criterion a stopping condition for a graph search operation not a specific data structure mechanism that controls the technical behavior of a traversal algorithm in any technically unconventional way. Defining a stopping condition for a graph traversal based on a property of the nodes encountered is a standard parameter of any graph search algorithm, and the claim does not explain how this stopping condition is implemented at the algorithmic or architectural level in any manner that departs from conventional graph traversal approaches.
Applicant's analogy to the self-referential table in Enfish is not persuasive and misapprehends what made the self-referential table a specific technical architectural improvement. In Enfish, the self-referential table was a specific, novel data structure in which a table stored information about its own columns as rows within the same table, allowing the computer to define and modify the structure of the database using the same data storage mechanism used for all other data. This was technically unconventional because conventional relational database models required separate metadata structures to define the schema of a table, and the self-referential table replaced that separate metadata architecture with a unified structure that improved how the computer itself organized and accessed data in memory. The Federal Circuit found this patent eligible because the specification provided technically specific disclosure explaining how the self-referential table differed from conventional relational database models at a structural level and why it provided concrete technical advantages in computer memory organization and data retrieval that were not achievable using conventional database architectures. The improvement was to the technical mechanism by which the computer stored and accessed data not to what data was stored or how that data was used for a business purpose.
The claimed node-type-based traversal termination is not analogous to the self-referential table in any of these technically critical respects. The designation of a node type as a traversal endpoint does not constitute a novel data structure that improves how the computer organizes or accesses data in memory. The specification describes the corridor endpoint node as a type of node that is specified or designated within the system as having different properties than other nodes, such that traversal stops when such a node is reached. This is a conventional labeling or classification of data elements assigning a property or attribute to certain nodes that marks them as traversal endpoints which is a standard feature of graph database systems and graph traversal algorithms. The specification does not explain how the designated node type data structure differs technically from conventional node classification or labeling mechanisms in graph databases, does not identify any technical limitation of existing node classification approaches that the claimed node type designation overcomes, and does not explain how the relationship between the designated node type data structure and the traversal algorithm is implemented in any technically unconventional manner. As addressed in the previous arguments, defining stopping criteria for a graph traversal whether based on node type, node depth, edge weight, or any other node or edge property is a standard functional parameter of any graph traversal algorithm, and the claims do not recite any specific technical innovation in how this stopping criterion is implemented at the algorithmic level.
The critical distinction between the present claims and Enfish becomes apparent when the question posed by the Federal Circuit in Enfish is applied here: is the claim directed to an improvement to computer functionality itself, or is it directed to use of a computer as a tool to perform a process that is not itself a technological improvement? In Enfish, the self-referential table improved computer functionality itself it changed how the computer organized and accessed data in memory in a technically specific way that provided concrete advantages in computer performance. Here, the designation of a node type as a traversal endpoint does not improve how the computer stores or retrieves data, does not improve how the graph traversal algorithm functions at a technical level, and does not provide any concrete technical advantage in computer performance beyond the natural consequence of performing a more limited search. The designation of corridor endpoint nodes improves what information is identified and surfaced for compliance analysis it is a business decision about which relationships are relevant for compliance purposes not a technical improvement to how graph database systems or traversal algorithms function. As consistently maintained throughout prosecution and as reflected in MPEP 2106.05(a) citing BSG Tech LLC v. Buyseasons, Inc., an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality, and the same principle applies here an improvement to which nodes are designated as traversal endpoints for compliance purposes is not equivalent to an improvement in how the graph traversal algorithm technically functions.
Furthermore, the specification's description of the corridor endpoint node confirms that its significance is substantive rather than technical. The specification explains that a corridor endpoint node is a node that is identified on a sanctions list that is, it represents a sanctioned entity and that this designation enables the software engine to find paths and corridors accordingly. The designation of certain nodes as corridor endpoint nodes is driven by their substantive compliance significance, they represent entities on sanctions lists not by any technical property that improves the functioning of the graph database or traversal algorithm. The technical operation of stopping traversal when a node of a particular type is encountered is the same regardless of whether the node type represents a sanctioned entity, a node at a maximum traversal depth, or any other category of nodes the technical mechanism is conventional graph traversal with a stopping condition, and the novelty, if any, lies in the business decision to designate sanctions-listed entities as the stopping criterion, not in any technical improvement to the traversal mechanism itself. Accordingly, the rejection is maintained.
The Applicant argues on page 25 that “computation and incremental storage of pathways. The specification explains that "the system incrementally adds corridors and stores them." As new nodes are added, "a computer implemented process is implemented that traverses pathways from the new node" and the "resulting pathways that are found are considered 'corridors' and are saved by the system in the graph database." This computation and incremental storage approach directly addresses the combinatorial explosion problem by computing and caching relevant pathways before a user requests them, thereby avoiding the need for expensive on-demand traversal of the entire graph at query time. As previously explained, "this preprocessing and storage also reduce the time needed to find such relevant paths when the user is working in the investigative workspace because it is saved and readily retrievable." Response to October 4, 2025 Office Action, page 10. This is not merely
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conventional database optimization" as the Examiner suggests, but rather a specific architectural decision about when and how traversal occurs shifting computation from query time to data ingestion time, with the stored pathways serving as a navigational data structure for the user interface”.
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the computation and incremental storage of pathways constitutes a specific architectural decision that shifts computation from query time to data ingestion time, thereby addressing the combinatorial explosion problem through a non-conventional technical approach that goes beyond conventional database optimization, has been fully considered but is not persuasive. The Examiner has carefully considered Applicant's characterization of the incremental pathway storage as a specific architectural decision about when and how traversal occurs, with stored pathways serving as a navigational data structure for the user interface. While Applicant frames this as a novel architectural approach distinct from conventional database optimization, this characterization describes a well-understood, routine, and conventional computer science concept pre-computation and caching of query results at data ingestion time to avoid repeated on-demand computation at query time. This concept, variously described in the computer science literature as pre-computation, materialized views, eager evaluation, or result caching, has been a standard database optimization technique for decades. The fundamental architectural pattern of computing results when data is ingested and storing those results for later retrieval rather than recomputing them on demand at query time is a basic and well-known approach to improving data retrieval performance in database systems. The specification's description of the system incrementally adding corridors and storing them as new nodes are added, rather than traversing the entire graph on demand, describes this conventional pre-computation and caching pattern applied to graph pathway data, not a novel technical architectural innovation.
Applicant's attempt to distinguish the claimed incremental storage from conventional database optimization by characterizing it as a specific architectural decision about the timing of computation does not establish a technological improvement in the sense required by the patent eligibility framework. The characterization that computation is shifted from query time to data ingestion time accurately describes what the specification discloses, but this shift in computational timing is itself the definition of pre-computation and caching the conventional technique the Examiner has identified. Every pre-computation and caching system makes precisely this architectural decision: performing computation at data ingestion or preparation time and storing the results so that they can be retrieved quickly at query time without repeating the computation. The claimed system applies this conventional architectural pattern to the specific domain of graph pathway data for compliance analysis. Applying a well-known architectural pattern to a new type of data or a new application domain does not transform that conventional pattern into a novel technical architectural innovation, any more than applying a well-known sorting algorithm to a new type of data transforms that algorithm into a novel technical contribution.
The contrast with the Amdocs distributed processing architecture that Applicant has cited throughout these arguments is instructive in this context. As addressed in the previous arguments, the Amdocs architecture was patent eligible not because it made a general architectural decision about when and where computation occurred, but because it implemented a specifically non-conventional distributed processing approach that addressed specific technical bottlenecks in existing centralized network accounting architectures arising from limitations in network bandwidth and centralized processing capacity. The distributed processing architecture in Amdocs was technically specific and non-conventional it departed from the prevailing centralized approach in a technically defined way that addressed specific technical constraints of existing systems. By contrast, the claimed incremental storage approach applies the conventional pre-computation and caching pattern to graph pathway data without departing from that conventional pattern in any technically specific or non-conventional way. The specification does not explain how the claimed incremental storage differs technically from conventional database pre-computation and caching approaches, does not identify any specific technical limitation of conventional caching techniques that the claimed approach overcomes, and does not describe any technical innovation in how the pre-computation is implemented at the algorithmic or architectural level.
Furthermore, and critically, the claims themselves do not reflect the specific architectural decision Applicant describes. The claim language recites that the system performs automatic graph traversal, identifies relevant pathways, stores them for retrieval, and repeats the traversal to identify additional relevant pathways. This is a functional description of the outcome of the pre-computation process pathways are identified and stored without reciting any specific technical mechanism for how the pre-computation is implemented, how the stored pathways are organized as a navigational data structure, how the incremental update process is triggered and managed as new nodes are added, or how the stored pathway data structure interfaces with the visual workspace to enable user navigation. As consistently noted throughout prosecution and as reflected in MPEP 2106.05(f), claims that recite only the idea of a solution or outcome without reciting details of how the solution is accomplished do not integrate a judicial exception into a practical application. The claims recite the desired outcome of having relevant pathways identified and stored for retrieval without reciting the specific technical mechanisms by which the pre-computation and storage are implemented in any manner that goes beyond conventional database pre-computation and caching.
Applicant's characterization of the stored pathways as serving as a navigational data structure for the user interface is similarly unavailing. The specification describes the stored corridors as pre-identified pathways that are available for users to select and add to the visual workspace. This describes the functional role of the stored data in the user-facing application it is data that has been pre-organized for user navigation but does not establish that the storage mechanism constitutes a technically novel navigational data structure in the sense of Enfish's self-referential table. As addressed in the previous arguments, an improvement to the organization of information stored by a database for user access is not equivalent to an improvement in the technical functioning of the database or storage system itself. The stored pathways improve what information is available to compliance analysts for navigation and investigation they do not improve how the underlying graph database technically stores, organizes, or retrieves data. The navigational value of the stored pathways is a function of their compliance relevance they represent pre-identified connections to sanctioned entities not of any technical innovation in the data structure or storage mechanism used to maintain them.
The Examiner further notes that Applicant's reliance on the statement from the response to the October 4, 2025 Office Action that preprocessing and storage reduce the time needed to find relevant paths does not establish a technological improvement. As addressed in the previous arguments, any pre-computation and caching approach reduces retrieval time compared to on-demand computation this is the expected and natural consequence of the conventional caching pattern, not evidence of a technological improvement to computer technology. The reduction in retrieval time is a byproduct of applying a conventional optimization technique, not the result of any technical innovation in how graph traversal or data storage is implemented. Processing time and retrieval speed improvements that result from performing less computation on demand are natural consequences of conventional caching, not independent indicators of technological improvement when the only advancement is applying a well-known architectural pattern to a new data type. Accordingly, the rejection is maintained.
The Applicant argues on pages 25-27 that “selective path navigation through the visual workspace. The claims recite that the system is configured to "provide a workspace comprising a visual workspace adapted to allow a user to interact with graphic representations of nodes and edges and selectively add nodes, edges, or groups of nodes and edges to the visual workspace," and that "in response to a user selecting a node, communicate that the selected node has one or more of the relevant pathways" and "interactively add one of the communicated one or more of the relevant pathways to the visual workspace." The specification describes in detail how this operates: the interface "generates a related list that includes a list of corridors… and other connected nodes under subject groupings. The user can interact with the interface to select a corridor and add it to the workspace. The user can select other corridors from the list and add to the workspace and display it." 1155. Furthermore, "[t]he interface permits the user to select individual nodes that are in the workspace and in response, lists of related information including corridors that are associated with that node, and other connected nodes, and the user can similarly add those to the workspace. "1155.
This selective pathway navigation mechanism directly addresses the second technical problem the hairball problem in graph visualization. Rather than displaying the entire graph or all relationships simultaneously (which would produce a hairball rendering the display incomprehensible), the system allows the user to incrementally build a comprehensible view by selectively adding computed pathways (from the node type process) to the visual workspace. Each associated pathway, when added, is "displayed using separate visual graphical elements for nodes and edges illustrating a connected pathway from the selected node to other nodes." When a user selects a displayed node, the system communicates available pathways associated with that node, enabling the user to discover previously unknown relationships by navigating from node to node through the computed pathway structure.
The claims include directly corresponding language. Claim 1 recites the implementation of a graph data structure, storing data pursuant to data models using the graph data structure, configuring a set of rules that includes designating a node type to end graph traversal of a pathway from a selected starting node, applying the stored graph to find associated pathways for the particular starting node, providing a visual workspace, and in response to selecting a node, communicating the node's found associated pathways, and allowing the user to add one of the found associated pathways to the workspace.
As noted, the solution involves using a node type and allowing the user to have a visual interface that provides access to found pathways (connections to that type of node) to the workspace to generate graph visualization in a personal and custom way. This avoids the hairball problem and surfaces paths and related relationships relevant to the user in a cleaner, quicker way. The specification explains that "[t]his technique quickly adapts the source data and in operation, quickly surfaces the relevant information in a visual way.
This is not merely "displaying information to a user." It is a specific technical mechanism whereby: (a) computed pathways are associated with nodes in the graph database; (b) when a user selects a node in the workspace, the system retrieves and presents the associated pathways as selectable options; (c) upon selection, the system generates and displays visual graphical elements for the selected pathways; and (d) edge connections are automatically maintained as the workspace is built up incrementally. This is an integrated technical architecture for managing display complexity in large graphs a technical solution to the hairball problem. As in Amdocs the individual components here (graph databases, traversal algorithms, visual interfaces) may be known. But the Amdocs court did not require that every individual component be novel it found eligibility in the specific architecture that combined these components to solve a technical problem. Similarly, here, it is the specific integrated architecture designated endpoint node types controlling traversal termination, incremental associated pathway storage, and selective associated pathway-based UI navigation that constitutes the technical improvement.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that Applicant's argument that the selective pathway navigation mechanism constitutes a specific technical architecture that directly addresses the hairball problem in graph visualization, and that the integrated combination of the three architectural components node-type-based traversal termination, incremental pathway storage, and selective visual workspace navigation constitutes a non-conventional technical solution analogous to the distributed architecture in Amdocs, has been fully considered but is not persuasive. Addressing first the selective pathway navigation mechanism as an individual component, Applicant characterizes this limitation as a specific technical mechanism comprising four distinct technical operations: associating computed pathways with nodes in the graph database, retrieving and presenting associated pathways as selectable options when a user selects a node, generating and displaying visual graphical elements for selected pathways, and automatically maintaining edge connections as the workspace is built up incrementally. While Applicant frames these as technically specific operations, each of these characterizations describes a generic user interface function at a level of abstraction that does not correspond to any technically specific implementation detail recited in the claims or disclosed in the specification. The claim language recites that the system provides a visual workspace adapted to allow user interaction with graphic representations of nodes and edges, communicates that a selected node has relevant pathways, and interactively adds a selected pathway to the visual workspace with display of graphical elements for nodes and edges. Under the broadest reasonable interpretation, these limitations describe generic display and selection functionality presenting information to a user, allowing the user to choose what to view, and updating the display in response to user selection. These are fundamental and conventional user interface operations that have been performed by interactive computer systems since well before the priority date of this application.
The specification passages Applicant cites confirm rather than contradict this characterization. The specification describes the interface as generating a list of corridors and connected nodes, allowing the user to select a corridor and add it to the workspace, and in response to selecting a node, listing related information including associated corridors and connected nodes that the user can add to the workspace. This describes conventional list-based selection and display functionality presenting a user with a list of options derived from pre-computed data and allowing the user to select items from that list for display. As addressed in the previous arguments, the visual workspace limitations describe the generic concept of presenting relationship information visually and allowing a user to selectively explore that information, which is a concept with a direct analog in the non-computer context of relationship diagrams and investigative charts. The fact that the display is dynamic and responds to user interaction does not transform this conventional display and selection functionality into a specific technical architectural component that addresses the hairball problem in a technically novel way, as the claims do not recite any specific rendering technique, any specific display algorithm, any specific mechanism for managing visual complexity at the technical level of computer graphics or display processing, or any other technically specific implementation detail that would distinguish the claimed visual workspace from conventional interactive graph visualization systems.
Applicant's characterization of the selective navigation as directly addressing the hairball problem by allowing users to incrementally build a comprehensible view rather than displaying the entire graph simultaneously is an accurate functional description of what the system does, but does not establish a technological improvement to computer visualization technology. As addressed in the previous arguments, the approach of selectively presenting a subset of available information to users rather than presenting all available information simultaneously is a conventional user interface design principle it is the organizational concept of progressive disclosure, which has been a standard user interface design approach for decades. Allowing users to choose which information to view rather than displaying everything at once is a generic user interface decision that improves the user experience of working with large datasets without constituting a technical improvement to how computer visualization systems render or process graphical information. The improvement is in the organization of what information is presented to users and in what sequence, not in how the computer technically renders or displays that information. As consistently maintained throughout prosecution, this is an improvement to the business process of compliance investigation making it easier for analysts to navigate and understand complex relationship data not an improvement to how computer visualization technology technically functions.
Turning to Applicant's overarching argument that the integrated combination of the three architectural components constitutes a non-conventional technical solution analogous to Amdocs, the Examiner maintains that this argument does not overcome the fundamental deficiencies identified throughout prosecution. Applicant correctly notes that the Amdocs court did not require every individual component to be novel, finding eligibility in the specific architecture that combined known components to solve a technical problem. The Examiner does not dispute this principle. However, the Amdocs analysis required not merely that known components be combined in a multi-component architecture, but that the specific combination constitute a non-conventional technical solution to a specific technical problem with existing computer technology, supported by technically specific specification disclosure. As addressed in the previous arguments, the Amdocs distributed architecture was non-conventional because it departed from the prevailing centralized approach in a technically defined way that addressed specific technical constraints network bandwidth limitations and centralized processing bottlenecks that could not be overcome using conventional centralized architectures. The claims in Amdocs reflected this specific non-conventional architectural approach by reciting the distributed processing components and their technical relationships in a manner that defined the specific technical mechanism by which the bottleneck problem was addressed.
The present claims do not satisfy the Amdocs standard because the combination of the three alleged architectural components does not constitute a non-conventional technical architecture in any technically specific sense. As addressed individually in the previous arguments, each component node-type-based traversal termination, incremental pathway storage, and selective visual workspace navigation describes either a conventional graph database and traversal operation or a conventional user interface function. The combination of these conventional components produces the expected result of a graph database system that pre-computes and stores a subset of relevant pathways based on node type criteria and presents those pathways to users through a selective interactive interface. This is precisely the type of combination of conventional components to achieve a predictable result that the Supreme Court in Alice identified as insufficient to confer patent eligibility. The combination does not produce a technically unexpected or non-conventional result it produces the expected functional outcome of using conventional graph database technology, conventional pre-computation and caching, and conventional user interface design to organize and present compliance information to analysts. The technical interactions between the components are conventional the traversal rules determine which pathways are stored, the stored pathways are retrieved in response to user node selection, and the retrieved pathways are displayed using conventional graphical elements and none of these interactions reflects a technically non-conventional architectural relationship that departs from how conventional graph database and visualization systems operate.
The specification's description of the integrated system similarly does not provide the technically specific architectural disclosure that supported the Amdocs eligibility finding. As addressed in the previous arguments, the specification describes the functional purpose and business value of the integrated system it surfaces relevant compliance pathways quickly and enables analysts to efficiently investigate financial crime relationships without explaining in technically specific terms how the combination of the three components addresses any specific technical limitation of existing graph database or visualization technology in a non-conventional way. The specification does not identify any technical bottleneck or architectural constraint in existing graph database or visualization systems that the claimed integrated architecture overcomes, does not explain how the specific architectural relationships between the three components produce technical advantages that are not achievable through conventional combinations of graph database, caching, and visualization technology, and does not provide any technically specific disclosure that would allow one of ordinary skill in the art to recognize the claimed architecture as constituting a technological improvement rather than the application of conventional technology to a business problem.
Applicant's argument that the integrated architecture constitutes a technical improvement because the individual components work together in a coordinated way to address both the combinatorial explosion problem and the hairball problem does not establish patent eligibility under the applicable framework. The coordination between the components traversal rules define relevant pathways, those pathways are pre-computed and stored, and stored pathways are selectively presented through the visual interface is the straightforward and expected coordination between the data processing, data storage, and user interface layers of any conventional database application. This layered architectural pattern, in which data is processed and stored at the backend and selectively presented to users through a frontend interface, is the conventional architecture of virtually every interactive database application. Applying this conventional layered architecture to the specific domain of graph pathway data for compliance analysis does not transform the conventional architecture into a novel technical solution, regardless of how the components are labeled or how the coordination between them is characterized. The domain-specific application of a conventional architectural pattern to a new type of data is precisely the type of application of conventional technology to a business problem that the Supreme Court in Alice and the Federal Circuit in cases such as Electric Power Group and BSG Tech have consistently found insufficient to establish patent eligibility. Accordingly, the rejection is maintained.
The Applicant argues on pages 27-29 that “the user interface features are themselves a technical improvement, as in Core Wireless and Data Engine. The Examiner characterizes the visual workspace as "a conventional user interface… that displays conventional graphical representations of nodes and edges" and asserts that the specification "does not explain any technical improvement to user interface technology." The Examiner further characterizes the "self-navigation" feature as merely describing c c a business benefit (helping users discover relationships they didn't know about) rather than a technical improvement." Office Action at pp. 25 and 30.
This characterization is inconsistent with the Federal Circuit's holdings in Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc, and Data Engine Technologies LLC v. Google LLC.. In Core Wireless the court found patent-eligible claims directed to "an improved user interface for electronic devices" that provided "a particular manner of summarizing and presenting information in electronic devices." The improvement was in how the interface allowed users to access application information specifically, through a summary display that permitted launching applications without fully opening them. In Data Engine. the court found patent-eligible claims that provided "a particular manner of navigating a three-dimensional spreadsheet." The improvement was in how users could navigate multi-dimensional data structures through tab identifiers with descriptive names.
The present claims recite an analogous improvement to user interface technology: a specific and particular manner of navigating complex graph data through selective associated pathway addition. The Examiner's assertion that Data Engine addressed a problem that "did not exist outside the computer context" applies equally here-the hairball problem exists only in computer graph visualization and has no non-computer analog. The claimed visual workspace does not merely display graph data - it provides a specific technical mechanism for managing display complexity that enables users to incrementally build a comprehensible view of a potentially vast graph, thereby avoiding the hairball problem. The system communicates available associated pathways when a user selects a node, permits the user to add selected associated pathways to the workspace, and dynamically generates visual representations of the added associated pathways including nodes, edges, and maintained edge connections. This is not "standard graph visualization, "it is a specific navigational architecture that integrates computed associated pathways data with an interactive workspace to enable controlled, incremental exploration of complex graph relationships.
The claims further recite that the system is "configured to assist the user to efficiently self-navigate the data through the relevant pathways in the visual workspace." The Examiner characterizes this as a "business benefit," but it is more properly understood as describing the technical function of the claimed architecture: the computed pathways, when made selectable to add in the visual workspace, create a navigational structure that allows the user to move through the graph by selecting nodes and adding associated pathways a self-directed exploration mechanism that is enabled by the integration of the computation and the selective display mechanism.
Like the tab identifiers in Data Engine that enabled navigation of three-dimensional spreadsheet data, and like the application summaries in Core Wireless that enabled access to application information without fully opening applications, the selective associated pathway navigation mechanism claimed here provides a specific and particular manner of navigating complex data structures that constitutes a technical improvement to user interface technology.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the claimed visual workspace and selective pathway navigation mechanism constitute a technical improvement to user interface technology analogous to the improvements found patent eligible in Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., and Data Engine Technologies LLC v. Google LLC, has been fully considered but is not persuasive. The Examiner respectfully disagrees and the rejection is maintained.
The Examiner has carefully considered both Core Wireless and Data Engine throughout the prosecution history of this application, and maintains that both cases are distinguishable from the present application in ways that are fundamental to the patent eligibility analysis. While Applicant draws analogies between the navigational improvements found in those cases and the selective pathway navigation claimed here, these analogies do not withstand careful scrutiny when the actual technical specificity of the claims and specifications in those cases is compared to the present claims and specification.
In Core Wireless, the Federal Circuit found the claims patent eligible because they were directed to a specific improvement to how computing devices present application information to users. The claims recited a specific user interface structure a summary window that displayed a limited list of data from an application and that was accessible from the main menu while the application was in an unlaunched state, with specific data fields in the summary that were selectable to launch the application directly to the relevant function. This was a specific technical solution to a problem that arose specifically from the constraints of computing devices with limited screen space and the technical challenge of accessing application data without the computational overhead of fully launching the application. The specification in Core Wireless provided technically specific disclosure explaining how the summary window was structured, what specific data fields it contained, and how the selectable data fields interfaced with the application launch mechanism to enable direct access to specific application functions without fully opening the application. The Federal Circuit found this constituted an improvement to the functioning of computers because it addressed a specific technical challenge of presenting application information on devices with limited screen space in a way that reduced the computational overhead of accessing application data the improvement was to how the computing device technically presented and provided access to application information, not merely to what information was presented or how useful it was to users.
The present claims do not recite any analogous specific user interface structure. The claim language recites that the system provides a visual workspace adapted to allow user interaction with graphic representations of nodes and edges, communicates that a selected node has relevant pathways, and interactively adds a selected pathway to the visual workspace with display of graphical elements for nodes and edges. Unlike the Core Wireless claims, which recited specific structural features of the summary window its accessibility from the main menu while the application is unlaunched, its display of a limited list of data, its specific selectable data fields enabling direct application launch the present claims describe the visual workspace only at the level of generic functional description. The claims do not recite any specific structural features of the visual workspace, do not specify any particular display mechanism or rendering approach, do not describe any specific technical interface between the stored pathway data and the workspace display mechanism, and do not explain how the workspace is technically structured to manage display complexity in any manner that departs from conventional interactive graph visualization systems. The absence of this technical specificity in the claim language is a fundamental distinction from Core Wireless that cannot be remedied through attorney argument about what the claims imply or what the specification describes at a functional level.
In Data Engine, the Federal Circuit found the claims patent eligible because they recited a specific technical mechanism tab identifiers with descriptive names used as page coordinates in formulas for addressing a problem that arose specifically from the technical challenge of enabling users to reference cells across multiple two-dimensional page arrays when those pages are part of a three-dimensional matrix stored in computer memory. As addressed in the previous arguments, this was a problem that arose specifically from the technical architecture of three-dimensional spreadsheet data structures in computer memory from the challenge of referencing cells across page dimensions in a multi-dimensional data structure and the claimed solution was a technically specific mechanism that addressed that computer-specific structural challenge. The claims in Data Engine recited the specific technical elements of the solution the tab identifiers, the descriptive names, their use as page coordinates in formulas which provided a specific technical mechanism for cross-page cell referencing that was not achievable through conventional two-dimensional spreadsheet techniques. The Federal Circuit found these claims patent eligible because they recited a specific technical solution to a problem arising from the specific technical architecture of multi-dimensional computer data structures.
Applicant argues that the present claims are analogous to Data Engine because the hairball problem, like the multi-dimensional navigation problem in Data Engine, exists only in the computer context. As addressed in the previous arguments, the Examiner maintains that the hairball problem is not exclusively a computer-specific problem in the relevant sense the challenge of presenting complex relationship information comprehensibly has existed in non-computer contexts and is a difference in scale rather than a qualitatively different technical problem arising from the specific technical architecture of computer systems. However, even setting aside this distinction and assuming for the sake of argument that the hairball problem arises specifically in the computer context, the present claims still do not satisfy the Data Engine standard because they do not recite any specific technical mechanism for addressing the hairball problem that is analogous to the tab identifier mechanism in Data Engine. The Data Engine claims were patent eligible not merely because they addressed a computer-specific problem, but because they recited a specific technical solution the tab identifier coordinate system that addressed the computer-specific problem through a technically defined mechanism reflected in the claim language. The present claims recite the generic concept of selectively adding pre-identified pathways to a visual workspace without reciting any specific technical mechanism for how the selective display manages visual complexity, how the pathway data is technically structured to interface with the workspace display, how the graphical elements are generated and rendered, or how edge connections are technically maintained as the workspace is built up. The claims describe what the visual workspace does allows selective pathway addition and displays graphical elements without reciting how it technically achieves this in any manner that goes beyond conventional interactive graph visualization functionality.
Applicant's characterization of the selective pathway navigation as providing a specific and particular manner of navigating complex graph data analogous to the specific manner of navigating three-dimensional spreadsheets in Data Engine does not overcome this fundamental distinction. The tab identifier mechanism in Data Engine was specific and particular in a technically defined sense it specified a particular structural solution to a particular structural problem in multi-dimensional data storage, using descriptive names as page coordinates in a specific cross-referencing syntax. The selective pathway navigation claimed here is specific and particular only in a functional and domain-specific sense it specifies that users navigate graph data by selectively adding pre-identified compliance-relevant pathways to a visual workspace. This functional specificity does not constitute technical specificity of the type required by Data Engine because it describes what users do with the system and what information they access, not how the system technically implements the navigational functionality in a manner that improves upon conventional graph visualization technology. As consistently maintained throughout prosecution, the claims describe generic display and selection functionality applied to pre-identified pathway data, which is the conventional operation of interactive graph visualization systems without any specific technical mechanism that constitutes an improvement to user interface technology.
With respect to Applicant's argument that the self-navigation feature describes a technical function of the claimed architecture rather than merely a business benefit, the Examiner maintains that the characterization of self-navigation as enabling users to discover previously unknown relationships by navigating from node to node through computed pathway structures describes the business value of the system helping compliance analysts explore financial crime relationships not a technical function that improves how the user interface technology operates. The claim language that the system is configured to assist the user to efficiently self-navigate the data through relevant pathways in the visual workspace is a functional result description it describes the outcome of using the system from the user's perspective not a technical specification of how the user interface implements navigation in a technically improved manner. This is precisely the type of outcome-based claiming that MPEP 2106.05(f) identifies as insufficient to integrate a judicial exception into a practical application, as the claim recites the desired result of efficient user navigation without reciting the specific technical mechanism by which that result is achieved in a manner that improves upon conventional user interface technology. Accordingly, the rejection is maintained.
The Applicant argues on page 29 that “the technical improvements are measurable in technical terms. The specification identifies the benefits of the claimed invention in terms that are unmistakably technical: the system saves "processing time and power consumption"1169; the computation and storage of (relevant) pathways reduce the time needed to find such relevant paths when the user is working in the investigative workspace because it is saved and readily retrievable; and the incremental associated pathway storage approach avoids the need for "traversing the entire graph." 1155 Processing time, power consumption, and retrieval latency are technical performance metrics that describe improvements to how the computer system operates, not improvements to a business process.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that Applicant's argument that the specification's references to saving processing time and power consumption, reducing retrieval latency, and avoiding traversal of the entire graph constitute measurable technical improvements that demonstrate the claimed invention improves how the computer system operates rather than merely improving a business process has been fully considered but is not persuasive.
The Examiner acknowledges that processing time, power consumption, and retrieval latency are indeed technical performance metrics that describe computational characteristics of computer systems. The Examiner does not dispute that these are technical in nature as metrics. However, the mere invocation of technical performance metrics in a specification does not establish that a claimed invention constitutes a technological improvement for purposes of the patent eligibility analysis. The relevant inquiry is not whether technical metrics are mentioned in the specification, but whether the claimed invention achieves improvements in those metrics through a specific technical innovation in how the underlying computer technology operates, as opposed to achieving those improvements as a natural and expected consequence of performing less computation or applying a conventional optimization technique. As addressed in the previous arguments, the specification's references to processing time and power consumption savings describe the natural consequences of limiting traversal scope and pre-computing results they do not reflect any technical innovation in how graph traversal algorithms, database systems, or computer hardware operate.
This distinction is critical and is well illustrated by comparing the present specification's performance metric references to specifications that courts have found sufficient to establish technological improvement. In cases such as Enfish and McRO, the performance improvements described in the specifications were direct consequences of specific technical innovations in how the computer performed its operations the self-referential table in Enfish improved memory organization and data retrieval through a specific structural innovation in database architecture, and the specific rules in McRO enabled automation of animation tasks through a technically defined computational process that replaced subjective human judgment. The performance improvements in those cases were attributable to specific technical mechanisms that changed how the computer performed its operations in a technically non-conventional way. By contrast, the performance improvements described in the present specification reduced processing time, lower power consumption, and faster retrieval are attributable to the straightforward and conventional decision to pre-compute and store a subset of results rather than computing the full result set on demand. As addressed in the previous arguments, this is the well-known pre-computation and caching pattern, and any system that implements this conventional pattern will achieve analogous processing time and power consumption savings as a natural consequence of performing less computation on demand. The performance metric improvements described in the specification are therefore evidence of the application of a conventional optimization technique, not evidence of a technical innovation that improves how computer technology operates.
The Federal Circuit's analysis in Electric Power Group, LLC v. Alstom S.A., is directly instructive on this point. In Electric Power Group, the claims were directed to collecting, analyzing, and displaying power grid data in real time, and the specification described the system's ability to perform these operations efficiently across large datasets. The Federal Circuit found the claims ineligible despite the fact that the system operated on large amounts of data and achieved performance improvements over manual analysis, because the claims did not recite any specific technical innovation in how the data collection, analysis, or display was implemented they described the desired functional outcome of efficient power grid monitoring without reciting a specific technical mechanism that improved how computer technology performed those operations. The court specifically noted that the claims did not improve the functioning of the computer itself or improve any other technology or technical field. The present claims are analogous to those in Electric Power Group in this critical respect they describe the desired functional outcome of efficiently surfacing relevant compliance pathways without reciting a specific technical mechanism that improves how graph database technology, traversal algorithms, or visualization systems technically operate.
Furthermore, the specific performance metric references Applicant cites do not establish the level of technical disclosure required by MPEP 2106.05(a) to demonstrate a technological improvement. As consistently noted throughout prosecution, MPEP 2106.05(a) requires that the specification provide sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing a technological improvement, and that such improvement must be apparent from the specification's technical disclosure rather than from attorney argument. The specification's statement that the system saves processing time and power consumption by controlling the number of iterations performed by the software engine is a generic and conclusory assertion of efficiency improvement it does not explain what specific technical innovation achieves these savings beyond the straightforward observation that limiting traversal scope reduces the number of iterations performed. Similarly, the specification's statement that incremental pathway storage reduces the time needed to find relevant paths because the results are saved and readily retrievable is a generic description of the expected benefit of caching it does not explain any specific technical innovation in how the caching is implemented that goes beyond the conventional pre-computation pattern. And the specification's statement that the system avoids traversing the entire graph by storing incremental results describes the conventional behavior of any pre-computation and caching system it does not identify any specific technical mechanism that achieves this result in a non-conventional way.
The Examiner also notes that Applicant's argument proves too much. Under Applicant's reasoning, any claim that describes using a computer to perform a process more efficiently than manual methods, with attendant savings in processing time and computational resources, would qualify as a technological improvement merely by virtue of those efficiency gains. This reasoning would effectively eliminate the patent eligibility distinction between claims that use conventional computer technology to implement a business process more efficiently and claims that genuinely improve the technical functioning of computer technology a distinction that the Supreme Court in Alice and the Federal Circuit in numerous subsequent decisions have consistently emphasized as fundamental to the patent eligibility analysis. Processing time and power consumption improvements that result from applying conventional optimization techniques to a business process do not transform that business process application into a technological improvement, any more than the efficiency gains from automating a manual business process on a computer transform that automation into a technological improvement. The relevant question remains whether the efficiency improvements result from a specific technical innovation in how the underlying computer technology operates, and as addressed throughout prosecution, the present specification and claims do not establish any such specific technical innovation. Accordingly, the rejection is maintained.
The Applicant argues on page 29 that “the Examiner's characterization of the claimed features as "Conventional" Is Unfounded. The Examiner asserts that the claimed features represent "conventional graph database technology" and "conventional graph traversal techniques." However, the Examiner has not identified any prior art that discloses the specific claimed architecture: a system that (l) designates a particular node type with different properties to function as a traversal termination condition, (2) uses that designated node type to compute and incrementally store relevant pathways, and (3) integrates those stored pathways into a visual workspace where users can selectively add pathways to navigate the graph and avoid the hairball problem. The Examiner's reliance on a general book about graphic design principles (The Visual Display of Quantitative Information by Tufte) does not establish that any of these specific technical features are conventional, as that book "does not have to do with graph theory, graphical user interfaces, graph databases, graph data structures, interactive node graph interfaces, or structuring systems that enable rapid navigation of data to uncover relevant information.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the Examiner's characterization of the claimed features as conventional is unfounded because no prior art has been identified disclosing the specific claimed architecture, and that the Examiner's reliance on Tufte's book on graphic design principles does not establish conventionality of the specific technical features claimed, has been fully considered but is not persuasive. As an initial and fundamental matter, Applicant's argument conflates the role of conventionality in the patent eligibility analysis with the role of prior art in a patentability analysis under 35 U.S.C. 102 and 103. The absence of a prior art reference that discloses every element of the specific claimed combination is not dispositive of whether the additional elements of a claim are well-understood, routine, and conventional for purposes of the 101 analysis. As the Supreme Court made clear in Alice Corp. v. CLS Bank Int'l, and as reflected throughout the 2019 PEG and MPEP 2106.05(d), the question of whether additional elements amount to significantly more than the identified judicial exception is distinct from the question of whether those elements are novel or non-obvious over the prior art. A claim can fail the 101 analysis even if no single prior art reference discloses every element of the claimed combination, because the 101 inquiry focuses on whether the additional elements reflect a genuine technological improvement or merely represent the conventional application of well-understood computer technology to implement an abstract idea. The Examiner's determination that the claimed elements are conventional is therefore not required to be supported by a specific prior art reference disclosing the identical claimed combination it is a determination about whether the individual elements and their combination reflect the kind of inventive concept that would transform the abstract idea into patent-eligible subject matter.
Furthermore, the Examiner notes that the conventionality determination at Step 2B is supported by the nature of the claimed elements themselves as recited in the claims and described in the specification, independent of any specific prior art citation. As addressed throughout prosecution and in the previous arguments, the claimed elements graph databases with nodes, edges, and attributes; rule-based graph traversal with starting node selection and stopping conditions based on node type; storage of identified traversal results; and interactive visual display of graph data with selective user navigation are each individually well-understood and routine computer science concepts that were conventional in the field of graph database technology and computer visualization well before the priority date of the original parent application in this family, which dates to September 2017. The Examiner could take official notice, consistent with MPEP 2106.05(d), that graph data structures, graph traversal algorithms including rule-based traversal with configurable stopping conditions, database pre-computation and caching of query results, and interactive visual graph displays were all well-understood, routine, and conventional in computer science as of that priority date. Each of these elements is described in standard computer science literature, implemented in widely available graph database systems and visualization tools, and routinely employed by practitioners in the field. The absence of a specific prior art reference combining all of these elements in the precise configuration claimed does not establish that any individual element or their combination reflects a technical innovation beyond their conventional application.
With respect to the Examiner's citation of Tufte's work, the Examiner has previously acknowledged, as addressed in the Final Office Action and Advisory Action, that Tufte's book on the visual display of quantitative information does not address graph theory, graph databases, or graph data structures in the computer science sense, and that the citation was intended to establish the well-established nature of data visualization principles rather than to demonstrate the conventionality of specific graph database or traversal technology. The Examiner acknowledges Applicant's criticism that Tufte is not the most precisely targeted reference for establishing the conventionality of computer-implemented graph database and visualization technology, and does not rely solely on Tufte for the conventionality determination. As noted in the Advisory Action, the Examiner's position is that the conventionality of graph data structures, graph traversal, data storage, and interactive visual displays in computer science is a matter of which the Examiner could take official notice, and the Tufte citation was offered as context regarding the long-standing nature of data visualization principles rather than as the primary basis for the conventionality finding and a direct rejection (i.e. as prior art). The imprecision of the Tufte citation does not undermine the substance of the conventionality determination, which rests on the well-known and widely practiced nature of each of the claimed computer science concepts in the field as of the priority date.
Addressing Applicant's characterization of the specific claimed architecture a system that designates a particular node type as a traversal termination condition, uses that designation to compute and incrementally store relevant pathways, and integrates those stored pathways into a visual workspace for selective user navigation the Examiner maintains that this characterization describes the combination of individually conventional elements in a manner that produces the expected result of their combination rather than a non-conventional technical architecture. As addressed in the previous arguments regarding each individual component, node type designation as a traversal stopping criterion is a standard functional parameter of graph traversal algorithms; pre-computation and incremental storage of traversal results is the conventional caching and pre-computation pattern; and selective display of pre-computed results through an interactive visual interface is conventional user interface design. The combination of these conventional elements to produce a system that pre-identifies compliance-relevant pathways and makes them available for selective user exploration is the straightforward and expected result of combining these conventional elements it does not produce a non-conventional technical result that goes beyond what would be expected from their combination.
The Examiner further notes that even in cases where courts have found patent eligibility based on the combination of individually known elements, as in BASCOM Global Internet Services v. AT&T Mobility LLC, the eligibility finding required that the specific combination reflect a non-conventional and non-generic arrangement of the known components that provided an inventive concept beyond the abstract idea itself. In BASCOM, the court found that the specific location of the filtering tool on a remote ISP server, rather than on individual local computers, was a non-conventional technical choice that allowed the filtering to be customized for individual users in a way that was not achievable through conventional local filtering implementations. The non-conventional nature of the specific architectural choice where the filtering was implemented and why that location provided technical advantages not available through conventional approaches was grounded in specific technical disclosure in the specification explaining why the particular architectural arrangement was technically advantageous over conventional approaches. Here, by contrast, the specification does not identify any specific technical reason why the particular combination of node-type traversal termination, incremental pathway storage, and selective visual workspace navigation produces technical advantages that are not achievable through conventional combinations of graph database, caching, and visualization technology. The specification describes the business value of the combination compliance analysts can more efficiently investigate financial crime relationships without providing technically specific disclosure of why the particular architectural arrangement produces non-conventional technical results. This absence of technically specific disclosure explaining the non-conventional technical advantages of the specific combination is a deficiency that cannot be remedied through attorney argument characterizing the combination as a specific technical architecture, and Applicant has not submitted any declaration under 37 CFR 1.132 providing evidence from one of ordinary skill in the art that would establish the non-conventional nature of the claimed combination. Accordingly, the rejection is maintained.
The Applicant argues on page 30 that “The claim preamble does not limit the technical character of the claims. Applicant's claimed invention includes a phrase in the preamble related to using the technology for investigating and evaluating financial crime or other business related risks. However, the claim language does not make or use any reference to business or risks in its operative features. The Examiner asserts that the preamble "defines the purpose and field of use of the claimed invention, which is highly relevant to determining whether the claim is directed to an abstract idea applied to a specific field versus a technological improvement." However, the claims recite technology that can be applied to that application, among others. The patent specification specifically states that "[e]mbodiments described herein are primarily described in the context of providing a tool for evaluating prospective financial crime and sanctions-related risks for businesses considering commercial dealings, but it should be understood that applications in other areas including application of particular features in other areas are contemplated." It also states: "Applications of the technology to other fields are also contemplated." The specification also states, "Embodiments illustrated herein are directed to financial crime and sanctions-related solutions and have particular suitability to solving and assisting users with financial crime and sanctions compliance related issues. It should be understood that described features or systems can have broader or different applications." Such applications are known and include drug discovery and cybersecurity.
During prosecution, Applicant offered to delete that language from the claim preamble but the Examiner indicated it was not helpful. The Examiner then, however, relied on that language in establishing the abstract idea characterization.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the preamble language referencing financial crime or other business-related risks does not limit the technical character of the claims, that the specification contemplates broader applications beyond financial crime compliance, and that the Examiner improperly relied on preamble language after indicating it was not helpful when Applicant offered to delete it, has been fully considered but is not persuasive.
Addressing first the procedural point regarding Applicant's offer to delete the preamble language, the Examiner acknowledges that during prosecution Applicant offered to remove the financial crime reference from the preamble and that the Examiner indicated such a deletion would not overcome the rejection. The Examiner's statement that deletion of the preamble language would not be helpful was accurate and remains accurate the rejection is not based solely or even primarily on the preamble language, and deletion of that language would not change the fundamental basis of the rejection. However, Applicant's characterization that the Examiner indicated the preamble language was irrelevant and then subsequently relied on it to characterize the abstract idea misrepresents the Examiner's position. The Examiner's statement that deletion would not help was a statement that the rejection would survive even without the preamble language it was not a statement that the preamble language is irrelevant to the eligibility analysis or that the Examiner would refrain from considering it. These are fundamentally different propositions, and conflating them does not establish any inconsistency in the Examiner's position. The preamble is part of the claim as written, and the Examiner is required to consider all claim language including the preamble in performing the eligibility analysis. The fact that deletion of the preamble language would not overcome the rejection does not mean the preamble is without relevance it means the rejection has independent bases that extend beyond the preamble characterization.
Turning to the substantive argument regarding the role of the preamble in the eligibility analysis, the Examiner maintains the position set forth in the Final Office Action and Advisory Action that the preamble language is relevant to understanding what the claim is directed to for purposes of the Step 2A Prong 1 analysis. Applicant's argument that the claim body's operative features make no reference to business or risks and therefore the preamble should be disregarded in the eligibility characterization misapprehends the role of the preamble in the Alice/Mayo framework. The 2019 PEG and the applicable case law do not limit the Step 2A analysis to the operative limitations of the claim body while disregarding the preamble the framework requires that the claim be evaluated as a whole, which includes the preamble to the extent it gives life and meaning to the claim. The preamble in each independent claim "A computer-implemented system for providing a visual interactive software tool that permits users to investigate and evaluate financial crime or other business-related risks" does more than merely identify a field of use. It defines the purpose and function of the entire claimed system, establishing that every operative limitation in the claim body is directed to implementing that stated purpose. The claim body's limitations storing graph data, defining traversal rules, automatically traversing pathways, storing relevant pathways, providing a visual workspace, communicating relevant pathways to users, and enabling selective pathway addition are all directed to implementing the system whose purpose is defined in the preamble. The preamble is therefore not a mere field of use designation that can be set aside; it is the statement of what the claimed system is for, which is directly relevant to determining whether the claim is directed to an abstract idea or to a technological improvement.
Furthermore, the Examiner's identification of the claims as reciting mental processes and methods of organizing human activity is not dependent solely on the preamble language. As addressed throughout prosecution and in the previous arguments, the claim body limitations themselves navigating relational data about entities through defined rules, identifying relevant connections, storing those connections, and presenting them to users for selective exploration describe operations that constitute mental processes and methods of organizing human commercial compliance activity independent of the preamble's explicit reference to financial crime. The preamble contextualizes and confirms the character of those operations, but the abstract idea characterization does not rest on the preamble alone. As addressed in the Advisory Action, the claim limitations themselves describe navigating data about entities and their relationships to determine compliance with sanctions regulations and assess financial crime risks this is organizing the human activity of commercial compliance whether or not the word "financial crime" appears in the preamble.
With respect to Applicant's argument that the specification contemplates broader applications beyond financial crime compliance including drug discovery and cybersecurity and that the technology is therefore not limited to organizing human commercial compliance activity, the Examiner maintains that this argument does not overcome the rejection for reasons addressed in the previous arguments. The specification's acknowledgment that the described technology can have broader applications does not change what is actually claimed in the pending claims. The claims as written recite a system for providing a visual interactive software tool that permits users to investigate and evaluate financial crime or other business-related risks. Regardless of what broader applications the technology might support, the claims as written are specifically directed to investigating and evaluating financial crime and business-related risks, and the eligibility analysis must be based on the claims as written rather than on potential alternative applications that are not recited in the claims. As addressed in the Advisory Action, the Applicant's citation to the specification's statements about broader applications does not change what is actually claimed the claims as written are specifically directed to investigating and evaluating financial crime and business-related risks.
Moreover, Applicant's suggestion that the preamble should be treated as a mere field of use limitation that does not affect the eligibility analysis actually supports the Examiner's position rather than undermining it. If the preamble language is treated as a field of use limitation under MPEP 2106.05(h), then the financial crime compliance application is a field of use limitation applied to an underlying abstract idea of navigating relational data to identify relevant connections and as consistently maintained throughout prosecution, applying an abstract idea to a specific field of use does not integrate the exception into a practical application or provide significantly more than the exception itself. A field of use limitation that restricts an abstract idea to a particular domain financial crime compliance, drug discovery, or cybersecurity does not meaningfully limit the abstract idea because the abstract idea remains fully intact within that domain, and the claimed system performs no technical function beyond the generic application of conventional computer technology to implement the abstract idea within the specified field. Whether the preamble is treated as limiting and relevant to the abstract idea characterization or as a non-limiting field of use designation, the result under the 101 analysis is the same the claims are directed to abstract ideas without additional elements that integrate those ideas into a practical application or provide significantly more. Accordingly, the is maintained.
The Applicant argues on pages 30-31 that “claim language may not be ignored during evaluation. Applicant asserts that it is also legal error to evaluate the claim, at least under 2B, without considering the claim as a whole including all of the claim language. See MPEP 2106.04(11)(2) ("In Prong Two, examiners evaluate whether the claim as a whole integrates the exception into a practical application of that exception.") MPEP 2106.05 ("If the claim as a whole does recite significantly more than the exception itself, the claim is eligible (Step 2B: YES) at Pathway C, and the eligibility analysis is complete. As such, the Examiner cannot ignore language in the claims that the Examiner considers to be abstract or non-technical with respect to evaluating the full combination of the claim features. It should be emphasized that the Alice analysis does not say or establish that identifying that something can be performed in the brain means that in the Step 2A Prong 2 or Step 2B, claim features can be ignored in the evaluation.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the Examiner has committed legal error by ignoring claim language in the eligibility evaluation, and that identifying claim limitations as performable mentally does not permit those limitations to be disregarded when evaluating the claim as a whole at Step 2A Prong 2 and Step 2B, has been fully considered but is not persuasive. As an initial matter, the Examiner has not ignored any claim language at any step of the eligibility analysis. The Examiner has considered all claim language including the graph data structure comprising edges, nodes, and attributes; the set of rules for controlling graph traversal including selecting starting nodes, designating endpoint node types, and ending traversal; the automatic graph traversal from starting nodes along pathways; the storing of relevant pathways; the providing of a visual workspace; the communicating of relevant pathways to users; and the interactively adding of pathways to the visual workspace with graphical representations. Each of these limitations has been identified, considered, and evaluated both individually and in combination at each step of the Alice/Mayo framework as implemented through the 2019 PEG. The consistency of the rejection analysis across multiple Office Actions reflects that the Examiner's position has not changed after considering Applicant's arguments, not that the Examiner has failed to consider claim language.
Applicant's legal premise that identifying claim limitations as reciting abstract ideas does not permit those limitations to be disregarded in the overall evaluation is correct as a statement of the applicable framework, and the Examiner does not dispute it. However, Applicant's argument mischaracterizes what the Examiner has done. The Alice/Mayo framework, as established by the Supreme Court and reflected in the 2019 PEG, specifically requires a structured analytical process in which the Examiner first identifies which claim limitations recite the judicial exception and which constitute additional elements beyond the exception, and then evaluates whether those additional elements considered individually and in combination integrate the exception into a practical application or provide significantly more. This structural analytical separation is the required methodology, not an error. Identifying certain limitations as reciting abstract ideas and other limitations as additional elements is not the same as ignoring the limitations identified as abstract those limitations remain part of the claim and are considered as part of the judicial exception that must be evaluated in the subsequent steps. As the Supreme Court explained in Alice, even after determining that intermediated settlement was an abstract idea, the Court still considered whether the computer implementation of that idea provided something more the abstract idea limitations were not ignored but were treated as the judicial exception against which the additional elements were evaluated.
The Examiner has properly applied this framework here. At Step 2A Prong 1, the Examiner identified the judicial exception recited by the claims the mental process of navigating relational data about entities to identify relevant connections for compliance evaluation and the method of organizing human commercial compliance activity. At Step 2A Prong 2, the Examiner evaluated whether the additional elements the graph database, the graph data structure, the traversal rules, the nonvolatile memory storage, the visual workspace, and the graphical display functionality considered individually and in combination as an ordered whole, integrate the identified exceptions into a practical application. The Examiner determined that they do not, because these additional elements are generic computer components performing generic computer functions that amount to mere instructions to apply the exception using conventional technology, and because the specification does not provide technically specific disclosure establishing that the claimed combination reflects a technological improvement to computer technology. At Step 2B, the Examiner evaluated whether the additional elements, individually and in combination, amount to significantly more than the judicial exceptions, and determined that they do not, because each element is well-understood, routine, and conventional, and their combination produces the expected result of applying conventional technology to a business problem rather than a non-conventional technical result. This analysis considered all claim language the identification of certain limitations as reciting abstract ideas did not cause those limitations to disappear from the analysis but rather established the judicial exception against which the additional elements were measured.
Applicant's assertion that identifying something as performable in the brain does not permit it to be treated as an additional element at Step 2A Prong 2 or Step 2B conflates the analytical categories of the framework. At Step 2A Prong 1, the Examiner identifies which limitations recite the judicial exception in this case, limitations directed to the mental process of navigating relational compliance data. At Step 2A Prong 2 and Step 2B, the Examiner evaluates the additional elements meaning the elements beyond the identified judicial exception to determine whether they provide the necessary integration or inventive concept. The limitations identified as reciting the judicial exception are not treated as additional elements at Prong 2 or Step 2B; rather, they constitute the abstract idea itself, and the additional elements are evaluated against that abstract idea. This is not ignoring the limitations identified as abstract it is treating them as what they are, the judicial exception, and evaluating whether the remaining elements of the claim transform the exception into patent-eligible subject matter. As addressed in the previous arguments, this is precisely the methodology mandated by the Supreme Court in Alice, which identified intermediated settlement as the abstract idea and then evaluated whether the additional computer implementation elements provided something more.
Furthermore, Applicant's argument that the Examiner's broadest reasonable interpretation ignores significant claim language is unfounded. As addressed in the previous arguments, the Examiner has characterized the claims under their broadest reasonable interpretation as reciting conventional database and user interface technology applied to the business problem of financial crime compliance analysis. This characterization does not ignore any claim language it reflects the Examiner's determination that all of the recited technical elements, when given their broadest reasonable interpretation consistent with the specification, describe conventional computer components and functions. The graph data structure comprising edges, nodes, and attributes is a conventional graph database structure. The set of rules for controlling graph traversal including starting node selection, endpoint node type designation, and traversal termination is a conventional rule-based graph traversal configuration. The automatic traversal and pathway storage is conventional graph search and result caching. The visual workspace with graphical representations of nodes and edges is a conventional interactive graph visualization interface. None of these characterizations ignores the claim language they reflect the Examiner's determination of what that language means under its broadest reasonable interpretation and why it describes conventional technology rather than a technological improvement.
Applicant's citation to MPEP 2106.04(11)(2) and MPEP 2106.05 regarding evaluation of claims as a whole at Prong 2 and Step 2B supports the Examiner's approach rather than contradicting it. MPEP 2106.05(a) instructs that when evaluating improvements to technology, examiners must look at the claim as a whole meaning the claim should be evaluated as an ordered combination without ignoring the requirements of individual steps. The Examiner has done precisely this the Step 2A Prong 2 analysis evaluated the additional elements as an ordered combination, considering not only each element individually but also the specific combination of graph database storage, rule-based traversal, incremental pathway storage, and selective visual workspace navigation as an integrated system, and determined that this ordered combination describes the application of conventional technology to a business problem rather than a technological improvement. The conclusion that the ordered combination does not provide the necessary integration or inventive concept is based on consideration of all claim elements together, not on ignoring any limitation. Accordingly, the rejection is maintained.
The Applicant argues on pages 31-32 that “the Examiner's assertion that all claim language was considered is conclusory and unsupported by any revision to the substantive analysis. Applicant argued in its November 4, 2025, Response that the Examiner's 101 analysis improperly ignored significant claim language, particularly under Step 2A Prong 2 and Step 2B. Applicant explained that the MPEP requires the claim to be evaluated "as a whole," which
"explicitly means all of the claim language," and that the Examiner's characterization of the claims
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simply ignores significant amount of language in the claim," including the algorithm, structures, interface, data structure, and many other features. Applicant cited MPEP 2106.04(11)(2), MPEP
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2106.05, and Phillips v. AWH Corp., 415 F.3d 1303 (Fed. Cir. 2005), among other authorities, in support of this position.
In the December 4, 2025, Final Office Action at page 14, the Examiner responded by stating that "[t]he Examiner has not ignored claim language; rather, the Examiner has properly applied the Alice/Mayo framework which requires identifying judicial exceptions and then evaluating whether additional elements, considered individually and in combination, integrate the exception into a practical application or provide significantly more." The Examiner further asserted on page 16 that he "has considered all claim language including: the graph data structure comprising edges, nodes, and attributes; the set of rules for controlling graph traversal including selecting starting nodes, designating endpoint node types, and ending traversal; the automatic graph traversal from starting nodes along pathways; storing relevant pathways; providing a visual workspace; communicating relevant pathways to users; and interactively adding pathways to the visual workspace with graphical representations.
Applicant respectfully submits that the Examiner's response is a conclusory assertion that is not borne out by any corresponding revision to the substantive rejection. While the Examiner recites a list of claim elements in the Response to Arguments section, the actual rejection analysis under Step 2A Prong 2 and Step 2B remains materially unchanged from the prior Office Action. As detailed below, this disconnect demonstrates that the Examiner has not, in fact, meaningfully considered all of the claim language as required by the MPEP
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The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the Examiner's assertion of having considered all claim language is a conclusory statement unsupported by any corresponding revision to the substantive rejection analysis, and that the consistency of the rejection across multiple Office Actions demonstrates that claim language was not meaningfully considered, has been fully considered but is not persuasive. Applicant's argument rests on a fundamental misunderstanding of what meaningful consideration of claim language requires and what the consistency of a rejection across multiple Office Actions demonstrates. Applicant implies that if the Examiner's substantive rejection analysis remained materially unchanged after Applicant raised arguments about allegedly ignored claim language, this consistency is itself evidence that the claim language was not meaningfully considered. This reasoning inverts the logic of the examination process. The consistency of the rejection analysis across Office Actions reflects that the Examiner considered Applicant's arguments and found them unpersuasive that the claim language, when properly evaluated under the Alice/Mayo framework and the 2019 PEG, continues to support the same conclusion regardless of how Applicant characterizes it. A rejection that changes substantively in response to every argument would reflect an examiner who abandons well-reasoned positions under argumentative pressure rather than one who meaningfully evaluates claim language. The Examiner's position has remained consistent because the claim language has not changed in any material respect that would alter the eligibility analysis, and the arguments Applicant has advanced have not identified any error in the Examiner's application of the framework to the actual claim language.
Furthermore, the requirement that the Examiner consider claim language as a whole does not impose an obligation to revise the substantive rejection analysis in response to every argument Applicant raises about individual claim limitations. Meaningful consideration of claim language means that the Examiner evaluates all limitations and explains why they do not overcome the rejection it does not mean that the Examiner must find new reasons for eligibility in every claim limitation Applicant highlights, or that the absence of such newly discovered reasons constitutes evidence of inadequate consideration. The Examiner has explained, consistently and in detail across multiple Office Actions, why each of the claim limitations Applicant identifies the graph data structure, the traversal rules, the automatic traversal, the incremental pathway storage, the visual workspace, and the selective navigation functionality represents a conventional computer component or function that does not integrate the identified abstract ideas into a practical application or provide significantly more. The fact that this explanation leads to the same conclusion each time it is applied to the same claim language is a reflection of the strength and consistency of the rejection, not evidence of inadequate consideration.
Applicant's characterization that the Examiner merely recites a list of claim elements in the response to arguments section without addressing them substantively in the rejection analysis is inaccurate. The Final Office Action and the Advisory Action each contain detailed substantive analysis addressing the specific claim limitations Applicant identifies. As addressed in the previous arguments throughout this prosecution, the Examiner has explained in specific terms why the graph data structure comprising edges, nodes, and attributes is a conventional graph database structure that does not constitute a technological improvement; why the set of rules for controlling graph traversal including starting node selection and endpoint node type designation represents conventional rule-based traversal parameters rather than a specific technical architectural innovation; why the automatic traversal and incremental pathway storage constitutes conventional pre-computation and caching rather than a non-conventional technical solution to the combinatorial explosion problem; why the visual workspace with graphical representations of nodes and edges implements conventional interactive graph visualization functionality rather than a specific technical improvement to user interface technology; and why the selective pathway navigation describes generic display and selection functionality rather than a specific technical mechanism analogous to the improvements found patent eligible in Core Wireless and Data Engine. Each of these explanations directly engages with the specific claim language Applicant identifies and explains in substantive terms why that language, under its broadest reasonable interpretation, describes conventional technology applied to a business problem rather than a technological improvement.
Applicant's argument essentially asks the Examiner to demonstrate consideration of claim language by reaching different conclusions about individual limitations than those consistently reached throughout prosecution. This confuses the act of consideration with the outcome of consideration. The Examiner has considered every claim limitation Applicant has highlighted and has explained in substantive terms why each limitation, individually and in combination, does not overcome the rejection. That this consideration consistently leads to the conclusion that the claims are directed to abstract ideas without significantly more reflects the nature of the claims as drafted they describe the application of conventional graph database and visualization technology to the business problem of financial crime compliance investigation using functional, outcome-based language that does not recite any specific technical mechanism that would constitute a technological improvement. The consistency of this conclusion across multiple rounds of examination is attributable to the consistency of the claims, not to any failure of the Examiner to meaningfully engage with the claim language.
The Examiner further notes that to the extent Applicant believes specific claim limitations have not been adequately addressed in the rejection analysis, the appropriate response is to identify the specific limitations and explain specifically why they constitute a technological improvement under the applicable legal standards which is precisely what the 2019 PEG contemplates when it notes that the burden shifts to Applicant to provide persuasive arguments supported by evidence when the Examiner concludes the disclosed invention does not improve technology. As addressed throughout prosecution, Applicant has advanced numerous arguments regarding specific claim limitations and the Examiner has addressed each of those arguments in substantive detail. To the extent Applicant contends that the responses to those arguments are inadequate, Applicant has not identified any specific claim limitation that was raised in the November 4, 2025 response and left unaddressed in the December 4, 2025 Final Office Action the argument here is a general assertion of inadequacy rather than a specific identification of unaddressed claim language. The Examiner has provided detailed Step 2A and Step 2B analysis addressing how the claim limitations relate to the identified abstract ideas and why they do not provide integration into a practical application or amount to significantly more, and that analysis constitutes meaningful consideration of all claim language as required by the MPEP and the applicable legal framework. Accordingly, the rejection is maintained.
The Applicant argues on pages 31-32 that “The identification of "Additional Elements" is unchanged. At the heart of the Step 2A Prong 2 and Step 2B analysis is the identification of what constitutes "additional elements" beyond the judicial exception, that is, what is "more" in the claim. In the August 4, 2025 Office Action (at page 5), the Examiner identified the following additional elements: "store graph data, receive data input, traverse pathways, display a visual graphical element, display a list, and display a set of options." The Examiner characterized these as "recited at a high level of generality (i.e., as a general means of analyzing information), and amounts to mere data management, which is a form of insignificant extra-solution activity." Id.
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In the December 4, 2025, Final Office Action (at page36), in which the Examiner claims to have considered all claim language, the identification and characterization of additional elements is identical. The Examiner again identifies the additional elements as: store graph data, receive data input, traverse pathways, display a visual graphical element, display a list, and display a set of options." The Examiner again characterizes these as "recited at a high level of generality (i.e., as a general means of analyzing information), and amounts to mere data management, which is a form of insignificant extra-solution activity." There is no revision, update, or supplementation of this analysis.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the identification and characterization of additional elements at Step 2A Prong 2 and Step 2B remained word-for-word identical between the August 4, 2025 Office Action and the December 4, 2025 Final Office Action, and that this identity demonstrates that the Examiner did not meaningfully revise the analysis in response to Applicant's arguments, has been fully considered and is acknowledged in part. The Examiner recognizes that the additional elements language in the rejection body itself was not revised between the two Office Actions, and the Examiner addresses this directly and substantively below. Notwithstanding this acknowledgment, the rejection is maintained for the reasons set forth herein.
The Examiner acknowledges that the specific language used to identify and characterize the additional elements in the Step 2A Prong 2 and Step 2B portions of the rejection body remained materially unchanged between the August 4, 2025 Office Action and the December 4, 2025 Final Office Action. The Examiner further acknowledges that Applicant's argument raises a legitimate observation about the structure of the rejection analysis that the additional elements were identified at a high level of generality as "store graph data, receive data input, traverse pathways, display a visual graphical element, display a list, and display a set of options" without being updated to reflect the more detailed claim language that Applicant highlighted in the November 4, 2025 response. The Examiner notes, however, that this observation goes to the presentation of the rejection rather than to its substantive correctness, and that the detailed analysis supporting the rejection was provided in the Response to Arguments section of the Final Office Action, which addressed Applicant's specific arguments about individual claim limitations in substantive detail. The advisory action similarly provided extensive additional analysis in response to Applicant's after-final arguments. The rejection body's high-level characterization of the additional elements was intended as a summary of the functional categories into which the claim limitations fall, not as an exhaustive enumeration of every individual claim limitation and as explained in the Advisory Action, the categories were intended to comprehensively encompass all claim limitations by their functional role.
Nevertheless, the Examiner takes Applicant's point seriously and provides the following more detailed identification and characterization of the additional elements to ensure the rejection analysis fully and expressly addresses all claim language at the level of specificity Applicant has raised throughout prosecution. The additional elements of the independent claims, beyond the identified judicial exceptions of mental processes and methods of organizing human activity, are as follows. First, the recitation of a computer configured to receive data from various sources and a database configured to store, in nonvolatile memory, a graph pursuant to one or more data models using a graph data structure comprising edges, nodes, and attributes represents a generic computer component a conventional graph database with conventional nonvolatile memory storage performing the generic computer function of data storage. This element is well-understood, routine, and conventional as of the priority date, as graph databases storing nodes, edges, and attributes in nonvolatile memory are a standard and widely practiced computer science technology that predates this application. Second, the recitation of defining a set of rules for controlling graph traversal configured to selectively identify relevant pathways, including selecting a starting node, designating a particular node type to end graph traversal, and ending traversal using that node type, represents a conventional rule-based graph traversal configuration. Defining stopping criteria for graph traversal based on node type is a standard functional parameter of conventional graph search algorithms, and the claims do not recite any specific algorithmic implementation of these rules that would constitute a technological improvement over conventional graph traversal techniques. Third, the recitation of automatically performing graph traversal from the starting node along pathways, stopping at any node having the particular node type, identifying the pathway as relevant, storing it for retrieval, and repeating the traversal to identify additional relevant pathways represents a conventional graph search and result caching operation. As addressed in the previous arguments, the pre-computation and incremental storage of traversal results is the well-known and conventional caching pattern applied to graph pathway data, not a non-conventional technical architectural innovation. Fourth, the recitation of providing a visual workspace adapted to allow user interaction with graphic representations of nodes and edges, selectively adding nodes, edges, or groups thereof to the workspace, communicating relevant pathways associated with a selected node, and interactively adding a selected pathway to the workspace with display of separate visual graphical elements for nodes and edges represents conventional interactive graph visualization and user interface functionality. As addressed in the previous arguments, these are generic display and selection operations that describe the conventional functionality of interactive graph visualization systems without reciting any specific technical mechanism that constitutes an improvement to user interface technology. Fifth, the recitation that the computer assists the user to efficiently self-navigate the data through relevant pathways in the visual workspace is a functional result description that characterizes the intended user experience outcome rather than a specific additional technical element that provides integration or significantly more.
Evaluating these additional elements individually and in combination under Step 2A Prong 2, none of them integrates the identified judicial exceptions into a practical application. The conventional graph database with nonvolatile memory storage is a generic data storage component that merely provides the computational environment for performing the abstract process of navigating compliance relationship data. The conventional rule-based traversal configuration describes the application of standard graph search parameters to define which pathways are relevant for compliance purposes this is the abstract idea of identifying relevant compliance relationships implemented using conventional traversal technology, not a technological improvement to traversal algorithms. The conventional pre-computation and caching of identified pathways is a routine database optimization technique applied to graph pathway data, not a specific technical architectural innovation that addresses the combinatorial explosion problem through a non-conventional technical mechanism. The conventional interactive graph visualization workspace is a generic user interface that presents the pre-computed compliance pathway data to users through standard display and selection functionality, not a specific technical mechanism that constitutes an improvement to user interface technology of the type found in Core Wireless or Data Engine. Together, these additional elements describe the application of a conventional layered database application architecture data storage, rule-based query processing, result caching, and interactive user interface to the business problem of financial crime compliance investigation. This combination produces the expected result of using conventional computer technology to implement a business process, not a non-conventional technical result that would integrate the abstract ideas into a practical application.
Under Step 2B, the additional elements individually and in combination do not amount to significantly more than the identified judicial exceptions. Each element is well-understood, routine, and conventional in the field of graph database and visualization technology as of the priority date of this application, and their combination in a layered application architecture produces a conventionally expected result. The specification does not identify any specific technical problem with existing graph database or visualization technology that the combination of these conventional elements overcomes in a technically non-conventional way, and the claims do not recite any specific technical mechanism that would distinguish the claimed combination from the conventional application of these well-known elements to a new business domain. As consistently maintained throughout prosecution, the Examiner could take official notice that graph data structures, rule-based graph traversal, database pre-computation and caching, and interactive visual graph displays were all well-understood, routine, and conventional in computer science as of the original priority date of this application family.
The Examiner notes that the more detailed additional elements analysis provided above is consistent with and substantively equivalent to the high-level characterization provided in the prior Office Actions the additional detail confirms rather than changes the conclusion that the additional elements do not integrate the abstract ideas into a practical application or provide significantly more. The consistency of the conclusion reflects the nature of the claims, which describe the application of individually conventional computer science elements in a conventionally expected combination to implement the business process of compliance investigation. Accordingly, the rejection is maintained.
The Applicant argues on pages 32-33 that the “specific claim limitations remain unaddressed in the rejection. Applicant's claims recite far more than the generic functions of storing, receiving, traversing, and displaying. Among other things, the claims recite a defined set of rules for controlling graph traversal that are configured to: (i) select a starting node for graph traversal; (ii) designate a particular node type to end graph traversal of a pathway; (iii) define, using node or edge attributes, which nodes or edges are permitted to be traversed; and (iv) end the traversal of the pathway using the particular node type. The claims further recite that the system automatically performs graph traversal from the starting node along a pathway and stops graph traversal at any node that has the particular node type, identifies the pathway as a relevant pathway, and repeats the automatic graph traversal to identify additional relevant pathways. The claims also recite providing a visual workspace adapted to allow a user to interact with graphic representations and selectively add nodes, edges, or groups thereof; communicating that a selected node has one or more relevant pathways; and interactively adding a relevant pathway to the visual workspace with separate visual graphical elements for nodes and edges illustrating a connected pathway.
None of these specific limitations are individually addressed or evaluated in the rejection portion of the December 4, 2025 Final Office Action. Instead, they are collapsed into the same high level characterization of "store graph data, receive data input, traverse pathways, display a visual graphical element, display a list, and display a set of options" that appeared in the prior Office Action a characterization that strips the claims of their specificity and treats detailed technical features as though they were generic data management functions.
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the specific claim limitations recited in the independent claims including the defined set of traversal rules, the node-type-based traversal termination, the attribute-based traversal constraints, the automatic traversal and pathway identification, the repeating traversal for additional pathways, the interactive visual workspace with selective pathway addition, the communication of relevant pathways upon node selection, and the interactive display of connected pathways using separate graphical elements are not individually addressed in the rejection body but are instead collapsed into a high-level characterization that strips the claims of their specificity has been fully considered and is acknowledged in the same manner as addressed in response to previous argument. As noted in that response, the Examiner acknowledges that the additional elements identified in the rejection body were characterized at a functional summary level rather than at the granular level of each individual claim limitation, and the Examiner provided a more detailed additional elements analysis in the response to the previous argument that expressly addresses the specific limitations Applicant identifies. The Examiner incorporates that analysis by reference here and supplements it with the following specific responses to the individual limitations Applicant highlights in this argument.
With respect to the defined set of rules configured to select a starting node for graph traversal, designate a particular node type to end graph traversal of a pathway, define using node or edge attributes which nodes or edges are permitted to be traversed, and end the traversal using the particular node type, the Examiner maintains that these rule configurations, individually and in combination, represent conventional parameters of rule-based graph traversal algorithms. As addressed in the previous arguments, defining starting conditions, stopping conditions based on node type, and traversal constraints based on node or edge attributes are standard functional parameters of graph search algorithms they define where traversal begins, what criteria determine when it ends, and what elements of the graph are eligible to be traversed. These are the fundamental configurable parameters of any rule-governed graph search operation, and the claims do not recite any specific algorithmic implementation of these parameters, any specific data structure for encoding these rules, or any specific technical mechanism for applying these constraints during traversal that would constitute a technological improvement over conventional rule-based graph traversal. The specification describes these rules in functional terms what they accomplish in terms of pathway selection and traversal termination without providing technically specific disclosure of how they are implemented in any manner that departs from conventional graph traversal configuration. Under the broadest reasonable interpretation, these rule configurations describe the logical criteria governing a graph search operation, which is a conventional and well-understood graph database function as of the priority date of this application.
With respect to the limitation that the system automatically performs graph traversal from the starting node along a pathway, stops graph traversal at any node having the particular node type, identifies the pathway as a relevant pathway, stores it for retrieval, and repeats the automatic graph traversal to identify additional relevant pathways, the Examiner maintains that this limitation describes the conventional execution of a rule-governed graph search algorithm with pre-computation and caching of results. As addressed in the previous arguments, automatically traversing a graph from a starting node and stopping when a node of a designated type is encountered is the standard execution of a graph search with a defined stopping criterion it is the conventional operation of graph traversal algorithms applied to the specific domain of compliance pathway identification. The identification and storage of discovered pathways for subsequent retrieval is the conventional pre-computation and caching pattern applied to graph search results. The repetition of the traversal to identify additional relevant pathways is the standard iterative execution of a graph search algorithm across multiple starting nodes or multiple traversal paths. Each of these operations describes the conventional behavior of a graph search and caching system, and the combination of these conventional operations produces the expected result of pre-computing and storing a set of compliance-relevant pathways it does not produce a non-conventional technical result that would constitute a technological improvement over conventional graph database and search technology. The claim language describing these operations, while more specific than the high-level summary characterization of traverse pathways used in the prior rejection body, does not recite any specific algorithmic innovation, any specific data structure improvement, or any specific computational mechanism that would distinguish the claimed traversal and storage operations from the conventional performance of these well-known computer science functions.
With respect to the limitation of providing a visual workspace adapted to allow a user to interact with graphic representations of nodes and edges and selectively add nodes, edges, or groups thereof to the visual workspace, the Examiner maintains that this describes conventional interactive graph visualization functionality. Interactive workspaces that allow users to add, view, and manipulate graphical representations of nodes and edges are a standard feature of graph visualization tools and network diagram software. The ability to selectively add nodes and edges to a visual workspace rather than displaying the entire graph simultaneously is a conventional user interface design principle progressive disclosure and selective content display are well-established interaction design patterns implemented in numerous graph visualization systems. The claim language describes this functionality at the level of what users can do with the workspace interact with graphical representations and selectively add elements without reciting any specific technical mechanism for implementing the workspace, any specific rendering approach for the graphical elements, or any specific technical feature of the workspace that constitutes an improvement to user interface technology beyond the generic provision of interactive graph display and selection functionality.
With respect to the limitation of communicating that a selected node has one or more relevant pathways in response to a user selecting that node, the Examiner maintains that this describes a conventional database query and display operation when a user selects a data element, the system retrieves and presents associated data records. This is the standard behavior of any interactive database application that presents associated records in response to user selection of a primary record. The specific content being communicated that the selected node has relevant pathways is determined by the pre-computed pathway data stored during the traversal and caching process described above, and the communication of that information to the user is a conventional data retrieval and display operation. The claim does not recite any specific technical mechanism for how the pathway association is stored, retrieved, or communicated that would constitute a technological improvement over conventional data retrieval and display functionality.
With respect to the limitation of interactively adding a selected relevant pathway to the visual workspace and displaying it using separate visual graphical elements for nodes and edges illustrating a connected pathway from the selected node to other nodes, the Examiner maintains that this describes conventional graph visualization rendering displaying a graph pathway as a series of node and edge graphical elements is the standard method of visualizing graph data in interactive graph display systems. The use of separate visual graphical elements for nodes and edges is the conventional approach to graph visualization, in which nodes are represented by one type of graphical element such as circles or icons and edges are represented by another type such as lines or arrows. The claim does not recite any specific technical innovation in how these graphical elements are rendered, how the visual representation of the pathway is generated, or how the display is updated in response to user selection beyond the generic description of displaying conventional node and edge graphical elements. This is the conventional rendering of graph pathway data in an interactive visualization workspace, not a specific technical mechanism constituting an improvement to user interface or visualization technology.
Evaluating all of these specific limitations together as an ordered combination, the Examiner maintains that the combination describes the application of a conventional graph database system with conventional rule-based traversal, conventional pre-computation and caching of results, and conventional interactive graph visualization and user selection functionality to the business problem of identifying and presenting compliance-relevant pathways for financial crime investigation. The specific claim language, while more granular than the high-level summary characterization used in the prior rejection body, does not recite any specific technical mechanism at any level of the claimed system that would constitute a technological improvement over conventional graph database, traversal, or visualization technology. Each specific limitation describes a conventional computer science function applied to compliance-relevant graph pathway data, and their combination in an ordered architecture produces the expected result of a conventional layered database application performing compliance pathway identification and presentation. As consistently maintained throughout prosecution, this is the application of conventional technology to a business problem, not a technological improvement that would integrate the identified abstract ideas into a practical application or provide significantly more than those abstract ideas. Accordingly, the rejection is maintained.
The Applicant argues on pages 32-33 that “the response to arguments and the rejection are inconsistent. This creates an internal inconsistency in the Final Office Action. In the Response to `Arguments on page 16, the Examiner enumerates specific claim features including "the set of rules for controlling graph traversal including selecting starting nodes, designating endpoint node types, and ending traversal" and "interactively adding pathways to the visual workspace with graphical representations." Yet in the rejection itself, the operative portion of the Office Action that constitutes the actual 101 analysis, these same features are not evaluated. The additional elements analysis continues to identify only generic functions, and the Step 2B analysis likewise carries forward the same boilerplate language that "the additional element in the claim amounts to no more than mere instructions to apply the exception using a generic computer component.
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The dependent claims analysis is also unchanged. In both the August 4, 2025 Office Action and the December 4, 2025 Final Office Action, Claims 2, 3, 7, 8, 10, 12, 16, 17, 19, 21, 25, and 26 are characterized as "insignificantly extra solution activity," and Claims 4, 5, 9, 13, 14, 18, 22, and 23 are characterized as directed to "non-functional data labels." No revision or additional analysis of the dependent claims was provided.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that there is an internal inconsistency in the Final Office Action between the Response to Arguments section and the rejection body, and that the dependent claims analysis was inadequate, has been fully considered but is not persuasive. As a threshold matter, Applicant's argument focuses on the presentation and organization of the Office Action rather than on the substantive merits of the rejection itself. The Alice/Mayo framework does not require that every specific claim phrase be individually enumerated in the operative rejection body it requires that the examiner identify the judicial exception, evaluate whether additional elements integrate that exception into a practical application, and determine whether those elements provide significantly more. The Examiner has satisfied each of these requirements through the totality of the Office Action, including the detailed Response to Arguments sections across multiple Office Actions that have addressed the specific claim limitations Applicant identifies. The characterization of the additional elements at a functional summary level in the rejection body accurately reflects the substantive conclusion that is fully supported by the detailed analysis provided throughout the prosecution history of this application, and Applicant's attempt to characterize a presentational organization choice as a substantive legal deficiency does not identify any error in the Examiner's application of the eligibility framework.
The critical point that Applicant's argument obscures is that the consistency of the additional elements characterization across multiple Office Actions is not evidence of inadequate analysis it is evidence that the specific claim limitations, when properly evaluated under the broadest reasonable interpretation, consistently reduce to the same functional categories of conventional computer operations. The fact that the detailed traversal rules, the node-type endpoint designation, the automatic traversal and pathway storage, and the interactive visual workspace navigation all reduce to the functional categories of storing graph data, traversing pathways, displaying graphical elements, displaying lists, and displaying sets of options is not a presentational shortcut it is the substantive conclusion of the eligibility analysis. Each of the specific limitations Applicant identifies performs one of these generic computer functions when evaluated under its broadest reasonable interpretation. The set of rules for controlling graph traversal including selecting starting nodes, designating endpoint node types, and ending traversal is, under its broadest reasonable interpretation, a conventional rule configuration for a graph traversal operation it defines the parameters of the traversal in terms of where it starts, what type of node ends it, and what constraints govern it, which are the standard configurable parameters of any rule-based graph search. The interactively adding of pathways to the visual workspace with graphical representations is, under its broadest reasonable interpretation, a conventional display and selection operation it presents pre-computed pathway data to users through standard graph visualization rendering and allows users to choose which pathways to view. These characterizations are not the result of ignoring claim language they are the result of applying the broadest reasonable interpretation standard to specific claim language and determining that the language, however specifically it is drafted, describes operations that are well-understood, routine, and conventional.
Furthermore, the detailed substantive analysis supporting these characterizations has been provided consistently and extensively throughout prosecution. The Response to Arguments sections of the Final Office Action addressed in specific detail why the rule-based traversal configuration is conventional, why the node-type endpoint designation does not constitute a specific technical architectural innovation analogous to Enfish, why the incremental pathway storage is conventional pre-computation and caching, and why the interactive visual workspace describes generic display and selection functionality rather than a specific technical improvement of the type found in Core Wireless or Data Engine. This analysis is part of the Office Action and constitutes the Examiner's substantive evaluation of those specific claim features the fact that it appears in the Response to Arguments section rather than being repeated verbatim in the rejection body does not render it legally insufficient or create a genuine inconsistency in the rejection. The Office Action must be read as a whole, and when read as a whole, the Final Office Action provides detailed substantive analysis of the specific claim limitations Applicant identifies and explains in specific terms why each limitation, both individually and in combination, does not overcome the 101 rejection.
With respect to the dependent claims, the Examiner maintains that the characterizations provided in the prior Office Actions accurately reflect the substantive nature of each dependent claim limitation and provide sufficient basis for the rejection. The following analysis addresses each dependent claim group to confirm the correctness of those characterizations at the level of specificity Applicant demands.
Claims 2, 10, and 19, which recite displaying an option to search for an entity from the database and adding a node representing the entity to the visual workspace, recite a conventional database keyword search and result display operation. Searching a database by keyword and adding a matching result to a display workspace is the standard behavior of any interactive database application and represents well-understood, routine, and conventional computer functionality that does not provide significantly more than the abstract idea of identifying relevant entities for compliance investigation. The characterization of this limitation as insignificant extra-solution activity is correct because it describes a preparatory data input function that precedes the core traversal and pathway identification process without adding any technical feature that improves computer technology.
Claims 3, 11, and 20, which recite displaying a graphic representation of a connection between a new node and existing nodes when a new node is added, recite a conventional graph visualization update operation. Automatically displaying edge connections between newly added and existing nodes is the standard behavior of interactive graph visualization systems, representing well-understood and conventional graph display functionality. This limitation describes the expected behavior of a conventional graph visualization workspace and does not constitute a specific technical improvement to display technology.
Claims 7, 16, and 25, which recite providing a display listing relevant pathways in ranked order, recite a conventional ranked list display operation. Presenting database query results in a ranked or ordered list is a well-understood and routine computer function implemented by information retrieval systems for decades. The ranking of pre-computed pathways by degree of relevance is a conventional data presentation technique that does not constitute a specific technical improvement to database or visualization technology, and the characterization of this limitation as insignificant extra-solution activity is correct because ranked display of results is a conventional post-processing step that does not improve the technical functioning of the underlying computer system.
Claims 8 and 17, which recite stopping traversal in response to determining another rule, recite an additional conventional traversal stopping condition. Applying multiple configurable stopping criteria to a graph traversal algorithm is a standard feature of rule-based graph search systems and represents a conventional graph traversal configuration parameter that does not constitute a specific technical innovation in traversal algorithm design. This is a straightforward extension of the conventional rule-based traversal stopping mechanism already recited in the independent claims.
Claims 12 and 21, which recite that the rules include a threshold number of node traversals from a starting node that stops traversal, recite a conventional maximum traversal depth parameter. Limiting graph search depth by a configurable maximum number of node traversals is a standard pruning technique in graph traversal algorithms that has been conventional in the field well before the priority date of this application. This limitation describes the well-known concept of depth-limited graph search, which is a textbook graph algorithm technique that does not constitute a specific technical innovation.
Claims 4, 13, and 22, which recite displaying information about a node including all of its associated surfaced pathways and allowing user selection of one or more pathways to the current workspace, recite a conventional one-to-many data retrieval and display operation. Displaying all associated records for a selected data element and allowing user selection of specific associated records for further display is the standard behavior of any interactive database application presenting relational data. The content of what is displayed a node's associated pathways is compliance-relevant data content that reflects the business purpose of the system, and the display and selection mechanism is a conventional user interface function that does not provide a technical improvement to database or visualization technology beyond the generic presentation of associated data records for user selection.
Claims 5, 14, and 23, which recite updating the automatic traversal of pathways in response to new nodes or edges being added to the graph database, recite a conventional database update and re-computation trigger. Initiating re-execution of a computation process in response to new data being added to a database is a well-understood and conventional database management function it is the standard behavior of any system that maintains pre-computed results and updates them when the underlying data changes. This is consistent with the conventional pre-computation and caching pattern addressed throughout prosecution and does not constitute a specific technical innovation in database update or maintenance technology.
Evaluating all dependent claims collectively, each recites an additional limitation that describes a conventional database, user interface, or graph visualization function applied to the compliance pathway data identified by the independent claims. The characterizations of these limitations as insignificant extra-solution activity or as directed to the content of the data rather than to technical improvements to computer functionality are substantively correct regardless of the specific terminology used to express them, because none of the dependent claim limitations recites a specific technical mechanism that would constitute an improvement to computer technology or provide significantly more than the abstract ideas identified in the independent claims. The dependent claims narrow the scope of the independent claims by specifying particular conventional functions, but they do not add any unconventional technical element that would overcome the 101 rejection. The substantive correctness of these characterizations is confirmed by the detailed analysis provided throughout prosecution, which has consistently demonstrated that each claim limitation, at whatever level of granularity it is examined, describes the application of conventional computer technology to the business problem of financial crime compliance investigation. Accordingly, the rejection is maintained.
The Applicant argues on pages 33-35 that “the MPEP requires more than a conclusory statement. The Examiner's approach does not satisfy the requirements of the MPEP. MPEP 2106.05 instructs that when evaluating whether a claim integrates a judicial exception into a practical application or provides significantly more, the examiner must evaluate "additional elements individually and in combination to determine whether the claim as a whole integrates the exception into a practical application." MPEP 2106.05(a) further instructs that examiners should be "careful to avoid oversimplifying the claims" by looking at them generally and "failing to account for the specific requirements of the claims." The Examiner's own citation to McRO Inc. v. Bandai Namco Games Am. Inc. supports this point the claim must be evaluated "as an ordered combination, without ignoring the requirements of the individual steps."
Here, the Examiner has done precisely what the MPEP cautions against. By collapsing the specific claim limitations into the generic categories of "store graph data, receive data input, traverse pathways, display a visual graphical element, display a list, and display a set of options," the Examiner has oversimplified the claims and failed to account for their specific requirements. As the USPTOs own guidance on subject matter eligibility illustrates, a proper additional elements analysis identifies each additional element with specificity and evaluates each one individually before considering the combination. The Examiner's analysis does not do this.
Moreover, simply asserting in the Response to Arguments that all claim language was considered, without revising the actual rejection to reflect that consideration, is insufficient. An applicant is entitled to a rejection that sets forth a clear and substantive explanation of why each relevant claim limitation does or does not satisfy the eligibility requirements. See NAPEP 2106.07 (discussing the requirements for a prima facie case of ineligibility). A bare assertion that the analysis was performed, contradicted by the unchanged substance of the rejection itself, does not meet this standard.
For these reasons, Applicant respectfully submits that the Examiner's assertion that "all claim language" was considered is conclusory and unsupported. The rejection under Step 2A Prong 2 and Step 2B has not been revised in any material respect from the August 4, 2025 Office Action to the December 4, 2025 Final Office Action the additional elements remain the same, the characterization remains the same, and the dependent claims analysis remains the same. The specific claim limitations that Applicant identified as having been overlooked including the graph traversal rules with designated node types as endpoints, the automatic preprocessing and storage of relevant pathways, and the interactive workspace for adding and visualizing pathways are still not individually addressed in the rejection. Applicant therefore requests that the Examiner withdraw the 101 rejection or, in the alternative, provide a revised rejection that substantively evaluates all of the claim limitations as required by the MPEP and governing case law.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that Applicant's argument that the Examiner's eligibility analysis fails to satisfy the requirements of MPEP 2106.05 because it oversimplifies the claims by collapsing specific limitations into generic functional categories, and that a bare assertion of consideration unsupported by revision to the rejection body is insufficient to establish a prima facie case of ineligibility, has been fully considered but is not persuasive. The Examiner respectfully disagrees and the rejection is maintained.
As a threshold matter, Applicant's argument is directed entirely at the procedural adequacy of the rejection's presentation rather than at the substantive merits of the eligibility analysis. Applicant does not identify any legal or factual error in the Examiner's substantive determination that the claimed elements represent conventional computer components and functions that do not integrate the identified abstract ideas into a practical application or provide significantly more. Instead, Applicant argues that the rejection body did not present the analysis at a sufficient level of granularity. This procedural argument does not overcome the substantive rejection, and the extensive detailed analysis provided across multiple Office Actions and the Advisory Action, read together as the complete prosecution record, more than satisfies the requirements of MPEP 2106.07 for a prima facie case of ineligibility.
The MPEP's requirement that examiners evaluate additional elements individually and in combination and avoid oversimplifying claims does not mandate that every individual claim phrase be separately enumerated and analyzed in the operative rejection body as a formal matter of presentation. What the MPEP requires is that the examiner provide a substantive explanation sufficient to establish a prima facie case one that identifies the judicial exception, identifies the additional elements, and explains why those elements do not provide the necessary integration or inventive concept. As the MPEP itself recognizes, examiners need not write lengthy rejections that address every possible argument Applicant might raise they must provide sufficient explanation to put Applicant on notice of the basis for the rejection and shift the burden to Applicant to respond. The prosecution record of this application demonstrates overwhelmingly that this standard has been satisfied. Across the August 4, 2025 Office Action, the December 4, 2025 Final Office Action, and the March 16, 2026 Advisory Action, the Examiner has provided detailed substantive analysis addressing the specific claim limitations Applicant identifies the traversal rules with node-type endpoint designation, the automatic traversal and incremental pathway storage, the interactive visual workspace, and the selective pathway navigation and has explained in specific terms why each of these limitations, both individually and in combination, represents conventional computer technology applied to a business problem rather than a technological improvement. This analysis, taken together across the prosecution record, constitutes a fully developed prima facie case of ineligibility that goes well beyond a bare conclusory assertion.
Applicant's argument that the Response to Arguments section cannot substitute for substantive analysis in the rejection body misapprehends how Office Actions function as a whole. An Office Action is a single unified document, and the Response to Arguments section is an integral part of that document that constitutes part of the Examiner's substantive position. The MPEP does not require that all substantive analysis be confined to the formal rejection paragraphs and excluded from the Response to Arguments section it requires that the Office Action as a whole provide sufficient explanation to establish the rejection and respond to Applicant's arguments. The Final Office Action of December 4, 2025, when read as a whole, provides extensive substantive analysis in the Response to Arguments section that directly addresses the specific claim limitations Applicant identified as having been overlooked, explains why each limitation under its broadest reasonable interpretation describes a conventional computer function, and explains in detail why the specific cases Applicant cites Enfish, McRO, Data Engine, Core Wireless, Amdocs, and DDR Holdings do not support the conclusion that the claims are patent eligible. This analysis is not a bare assertion it is a detailed, well-reasoned substantive evaluation of the specific claim language that more than satisfies the MPEP's requirements.
Furthermore, the Examiner has in the responses to Arguments 24, 25, and 26 provided a substantially more detailed additional elements analysis that expressly addresses each specific claim limitation at the granular level Applicant demands, identifies each limitation individually, explains why each represents a conventional computer function under its broadest reasonable interpretation, and evaluates the combination of all limitations as an ordered whole. This analysis is now part of the prosecution record and constitutes the Examiner's complete and detailed substantive position on the additional elements question. The analysis confirms that the substantive conclusion reached in the prior Office Actions that the additional elements represent conventional computer components and functions that do not integrate the abstract ideas into a practical application or provide significantly more is correct and fully supported at every level of claim specificity from the broadest functional summary to the most granular individual limitation.
With respect to Applicant's specific contention that the graph traversal rules with designated node types as endpoints, the automatic preprocessing and storage of relevant pathways, and the interactive workspace for adding and visualizing pathways have not been individually addressed in the rejection, the Examiner directs Applicant to the detailed analysis provided in the responses to the previous arguments, which address each of these specific limitations in detail. The graph traversal rules with designated node types as endpoints have been addressed in the context of the previous argument, where the Examiner explained why node-type-based traversal termination represents a conventional graph search stopping criterion rather than a specific technical architectural innovation analogous to the self-referential table in Enfish. The automatic preprocessing and storage of relevant pathways has been addressed in the context of the previous Argument, where the Examiner explained why incremental pathway computation and storage represents the conventional pre-computation and caching pattern rather than a non-conventional technical architectural decision. The interactive workspace for adding and visualizing pathways has been addressed in the context of the previous Arguments, where the Examiner explained why selective pathway navigation through the visual workspace represents conventional interactive graph visualization and user selection functionality rather than a specific technical improvement analogous to the improvements found patent eligible in Core Wireless and Data Engine. Each of these analyses has been provided in specific substantive detail and constitutes the Examiner's individual and combined evaluation of these specific limitations as required by MPEP 2106.05.
Applicant's request that the Examiner either withdraw the rejection or provide a revised rejection that substantively evaluates all claim limitations is respectfully declined. The Examiner has provided, across the complete prosecution record and specifically in the responses to the previous Arguments of this Office Action, a comprehensive and detailed substantive evaluation of all claim limitations that demonstrates the correctness of the rejection at every level of analytical specificity. The rejection is not based on a bare conclusory assertion it is based on a well-developed and extensively supported substantive analysis that has consistently demonstrated, through detailed engagement with the specific claim language, the applicable case law, and the MPEP guidance, that the claims are directed to abstract ideas without additional elements that integrate those ideas into a practical application or provide significantly more. The fact that this analysis consistently leads to the same conclusion reflects the nature of the claims rather than any deficiency in the analysis, and Applicant has not identified any specific legal or factual error in the substantive eligibility determination that would warrant withdrawal of the rejection. Accordingly, the is maintained.
The Applicant argues on pages 33-35 that “The Examiner's reliance on the Tufte book does not support the 101 rejection. Applicant respectfully traverses the Examiner's continued reliance on Edward R. Tufte's 1983 book, The Visual Display of Quantitative Information, in support of the 101 rejection of Application No. 18/750,562. As set forth below, the prosecution history demonstrates that the Examiner has changed his characterization of why the Tufte book is relevant and how it applies to the claimed invention on multiple occasions. Each time Applicant has addressed the Examiner's stated rationale, the Examiner has offered a new theory for the book's relevance rather than withdrawing it. Applicant respectfully submits that this pattern confirms the Tufte book is not relevant to the claimed invention and does not support the rejection.
The Examiner respectfully disagrees.
Applicant's argument regarding the Examiner's reliance on Edward R. Tufte's 1983 book, The Visual Display of Quantitative Information, and the alleged shifting characterizations of its relevance throughout prosecution, has been fully considered. The Examiner notes that the Tufte book is not relied upon in the current rejection and has not formed any part of the basis for the 101 rejection as it stands. The Examiner addresses this argument solely because Applicant has raised it, and not because the Tufte book has any bearing on the current rejection analysis.
As the current rejection stands on its own substantive grounds the detailed Alice/Mayo framework analysis addressing the abstract idea identification at Step 2A Prong 1, the additional elements evaluation at Step 2A Prong 2, and the significantly more analysis at Step 2B the Tufte book is not pertinent to the discussion and Applicant's arguments regarding its relevance or the consistency of its characterization across prior Office Actions do not advance the eligibility analysis in any direction. Whether the Tufte book accurately or inaccurately described the conventional nature of data visualization, and whether the Examiner's prior characterizations of its relevance were consistent or inconsistent, has no bearing on whether the current rejection is substantively correct under the applicable legal framework. The rejection rests on the well-developed and extensively supported analysis provided across the prosecution record including the detailed responses to the previous arguments and that analysis stands independently of any reference to Tufte. Accordingly, the rejection is maintained.
The Applicant argues on pages 35-36 that “the Examiner's first theory: the Tufte book purportedly evidences "Graph Theory" on Computers. Under the two-step Alice/Mayo framework, a 101 rejection requires the Examiner to demonstrate that the claims are directed to an abstract idea (Step 2A) and, if so, that they lack an inventive concept sufficient to transform the claim into patent-eligible subject matter (Step 2B). The Examiner's first theory for citing the Tufte book attempted to satisfy this framework by asserting that "graph theory" on computers was already well known, thereby negating any claimed technological improvement. Specifically, the Examiner stated: "[T]he idea of utilizing graph theory in the context of computers to display visual information has been around since the mid-20th century, with a specific example of Edward Tufte who wrote a book in 1983 'The Visual Display of Quantitative Information' which was later reprinted as second edition in 2001 that graph theory is utilized to reveal data with graphics (this is being identified not as prior art, but to provide context of what one of ordinary skill in the art would know)." The Examiner's stated purpose was to establish clarification for what one of ordinary skill in the art would know," and to conclude that because "graph theory" purportedly had a "long standing" history on computers, the present application "does not provide a technological improvement or improvement to the technical field
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July 7, 2025 Advisory Action, section 5.
The Examiner repeated this exact characterization multiple times throughout the August 4, 2025 Office Action, using it to rebut Applicant's arguments regarding Data Engine, Core Wireless, and the claimed invention's efficiency improvements. In each instance, the Examiner asserted that the Tufte book showed "graph theory is utilized to reveal data with graphics" and that, because a
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previous solution" existed "over 20 years ago," the present application could not represent a technological improvement. Applicant respectfully submits that this theory fails at the threshold under 101: as demonstrated below, the Tufte book does not discuss "graph theory" at all, and therefore it cannot serve as evidence that the claimed graph-database technology and traversal methods were conventional or well-understood to a person of ordinary skill in the art.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument regarding the Examiner's first theory for citing the Tufte book specifically the characterization that the book evidences the well-known nature of graph theory on computers and therefore negates any claimed technological improvement has been fully considered. The Examiner notes, as stated in the response to the previous Argument, that the Tufte book is not relied upon in the current rejection and forms no part of the basis for the 101 rejection as it presently stands.
The Examiner raises the Tufte book here solely because Applicant has presented this argument, not because the book has any continuing relevance to the current rejection analysis. Applicant's detailed critique of the Examiner's prior characterization of the Tufte book including the argument that the book does not discuss graph theory in the computer science sense and therefore cannot establish the conventional nature of graph database technology and traversal methods is therefore directed at a theory that is no longer part of the rejection. Whether the prior characterization of the Tufte book was precisely accurate or not has no bearing on the substantive correctness of the current rejection, which rests entirely on the detailed Alice/Mayo framework analysis developed throughout prosecution and addressed comprehensively in the responses to the previous arguments. That analysis stands independently on its own merits without any reliance on the Tufte book, and Applicant's arguments regarding the book's prior use do not identify any deficiency in the current rejection's substantive basis. Accordingly, the rejection is maintained.
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The Applicant argues on pages 36-37 that “Applicant's prior response: The Tufte Book does not discuss ''Graph Theory". Because the Examiner's 101 rejection relied on the Tufte book to establish what was purportedly conventional in the art, the factual accuracy of the Examiner's characterization is essential to the legal sufficiency of the rejection. In the Response to Final Office Action filed June 12, 2025, Applicant demonstrated that the Examiner's characterization was factually incorrect. Applicant stated: "[T]he Examiner identifies the book 'The Visual Display of Quantitative Information,' published in 1983 by Tufte and asserts that this book shows that graph theory is used to reveal data with graphics. Applicant reviewed an online copy of the book and found no mention of graph theory as purported by the Examiner. It makes mention of graphics and graphical design which are not the same as graph theory." Applicant further explained that the book "does not have to do with graph theory, graphical user interfaces, graph databases, graph data structures, interactive node graph interfaces, or structuring systems that enable rapid navigation of data to uncover relevant information." As Applicant explained, the Tufte book addresses graphic design principles for illustrating data in visual form a fundamentally different discipline from the computer science concepts of graph theory, graph databases, and graph traversal that are central to the claimed invention. Tufte's own introduction makes the book's scope unmistakable: "Data graphics visually display measured quantities by means of the combined use of points, lines, a coordinate system, numbers, symbols, words, shading, and color" (Introduction, PDF p. 7). He further states: "This is a book about the design of statistical graphics and, as such, it is concerned both with design and with statistics" (Introduction, PDF p. 9). The book's subject matter is the aesthetics and integrity of printed charts time-series, scatterplots, bar charts, and maps not computer science, graph databases, interactive software interfaces, or any form of computational data structure. Applicant respectfully submits that a reference with no connection to the claimed technology cannot establish that the technology was well-understood, routine, or conventional for purposes of Step 2B of the Alice/Mayo analysis, nor can it show that the claims are directed to an abstract idea under Step 2A.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the Tufte book does not discuss graph theory in the computer science sense and therefore cannot establish the conventional nature of graph database technology and traversal methods for purposes of the Alice/Mayo analysis has been fully considered. The Examiner notes, consistent with the responses to the previous Arguments, that the Tufte book is not relied upon in the current rejection and forms no part of the basis for the 101 rejection as it presently stands.
The Examiner addresses this argument solely because Applicant has raised it, and not because the Tufte book has any continuing relevance to the current rejection. Applicant's factual critique that the Tufte book addresses the aesthetics and design of printed statistical graphics rather than computer science concepts of graph theory, graph databases, or graph traversal is therefore directed at a reference that no longer appears in or supports the rejection. Whether the Tufte book accurately evidences the conventional nature of graph database technology is a question that has no bearing on the substantive correctness of the current rejection, which rests entirely on the detailed Alice/Mayo framework analysis developed throughout prosecution and set forth comprehensively in the responses to all the previous Arguments. That analysis establishes the conventional nature of the claimed elements through the well-documented state of graph database technology, rule-based graph traversal, pre-computation and caching, and interactive graph visualization in the computer science field as of the priority date, independent of any reference to Tufte. Accordingly, the rejection is maintained.
The Applicant argues on pages 37-38 that “the Examiner's second theory: the Tufte Book purportedly evidences "Data Visualization". In the December 4, 2025 Final Office Action at page 28, the Examiner conceded that the Tufte book does not, in fact, discuss "graph theory" as previously asserted. However, rather than withdrawing the reference, the Examiner offered a new rationale for its relevance a shift that Applicant respectfully submits undercuts the consistency and reliability of the rejection. The Examiner acknowledged: "Applicant is correct that Edward R. Tufte's 'The Visual Display of Quantitative Information' (1983) does not discuss 'graph theory' in the mathematical or computer science sense (i.e. the formal study of graphs as abstract structures consisting of nodes/vertices and edges)." The Examiner admitted he "should have more precisely stated that Tufte demonstrates principles of 'graphical display of data' or 'data visualization' rather than using the term 'graph theory.
Rather than withdrawing the Tufte reference upon conceding this error, however, the
Examiner simply pivoted to a new rationale. The Examiner now asserted that "[t]he Examiner's citation to Tufte was intended to establish that the visualization of relational data through graphical representations including the use of nodes, edges, and network diagrams to display relationships and enable users to understand data patterns has been a well-established practice in the field of data visualization and statistical graphics since well before the applicant's filing date." Jd2 Applicant respectfully submits that this is a materially different characterization from the original position that the book demonstrated the use of "graph theory" on computers. Under 101, this repositioning is significant: the Examiner is no longer claiming the book evidences the same thing it was originally cited for, yet the rejection remains unchanged. A 101 rejection must rest on a consistent and well-articulated rationale, and an evidentiary reference whose stated purpose shifts from one Office Action to the next does not provide the reasoned basis that the Alice/Mayo framework requires.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument regarding the Examiner's second theory for citing the Tufte book specifically the shift from characterizing it as evidencing graph theory to characterizing it as evidencing well-established data visualization practices and the assertion that this repositioning undermines the consistency and reliability of the rejection, has been fully considered. The Examiner notes, consistent with the responses to the previous arguments, that the Tufte book is not relied upon in the current rejection and forms no part of the basis for the 101 rejection as it presently stands.
Applicant's argument regarding the evolution of the Examiner's characterization of the Tufte book across prior Office Actions is therefore directed entirely at a reference that no longer appears in or supports the current rejection. The question of whether the Tufte book's relevance was consistently characterized in prior Office Actions has no bearing on the substantive correctness of the current rejection, which stands entirely on its own independent grounds as developed throughout the detailed Alice/Mayo framework analysis set forth in the responses to the previous arguments. That analysis does not depend on the Tufte book in any respect, and any prior inconsistency in its characterization is therefore immaterial to the current rejection. The rejection under 35 U.S.C. 101 is maintained on the substantive grounds previously articulated and is not affected by Applicant's arguments regarding the Tufte reference. Accordingly, the rejection is maintained.
The Applicant argues on pages 38-39 that “the Examiner's third theory: "substance over technology". The December 4, 2025 Office Action then adds a "clarification" to the data visualization position. Applicant respectfully submits that this is the Examiner's third theory and it marks the most significant departure from any recognized 101 analytical framework. Rather than using the Tufte book to establish what was conventional in the prior art, the only legitimate purpose for non-prior art evidentiary references in a 101 analysis, the Examiner invoked the book for an aesthetic philosophy about chart design as a basis for concluding the claims lack a technical improvement. In the December 4, 2025, Final Office Action, the Examiner introduced the theory for the book's relevance in a newly articulated three-part "clarification." The Examiner asserted that: (l) visual representation of relational data is conventional; (2) the claimed invention applies conventional techniques to a specific domain; and (3) "Tufte demonstrates that effective data visualization focuses on substance, not technology." This third point was entirely new. The Examiner cited specific pages of the Tufte book (pages 77 and 121) and quoted Tufte's discussion of "chartjunk" to argue that "graphical excellence depends on the substance and quality of the data and ideas being communicated, not on the technological means of display." Applicant respectfully submits, however, that a review of the Tufte book reveals the Examiner has misread Tufte's point. When Tufte writes that graphical displays should "induce the viewer to think about the substance rather than about methodology, graphic design, the technology of graphic production, or something else'
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(Ch. l, PDF p. 10), he is making an aesthetic argument about printed chart design specifically, that the decorative embellishments of a chart (what Tufte calls "chartjunk") should not distract the reader from the underlying data. Tufte defines "graphical excellence" as "the well-designed presentation of interesting data a matter of substance, of statistics, and of design" (Ch. l, PDF p. 48). The "technology" Tufte warns against is the technology of graphic production ruling pens, cross-hatching, moiré vibration, and computer-generated decorative effects not the underlying computer science or data architecture that organizes information. Indeed, Tufte's entire discussion of “chartjunk" concerns "the interior decoration of graphics" that "generates a lot of ink that does not tell the viewer anything new," whether "to make the graphic appear more scientific and precise, to enliven the display, to give the designer an opportunity to exercise artistic skills" (Ch. 5, PDF p. 102). This has no bearing whatsoever on whether an invention's claimed combination of graph database technology, traversal algorithms, and interactive node-based interfaces constitutes a technological improvement under 101. The Examiner then applied this principle to conclude that "the claims do not recite any technical improvement to how graph databases function or how user interfaces display information," but instead merely organize business data for compliance analysts. Applicant respectfully submits that this represents a third distinct theory for the Tufte book's purported relevance. The Examiner has moved from asserting the book demonstrated "graph theory" on computers, to asserting it demonstrated "data visualization" principles, to asserting it stands for the philosophical proposition that good graphics are about substance rather than technology and that therefore the claims must be directed to a business process rather than a technological improvement. This theory has no grounding in the Alice/Mayo framework. The question under Step 2A is whether the claims are directed to a judicial exception, and the question under Step 2B is whether the claims recite additional elements that amount to significantly more than that exception. A graphic design author's opinion about chart aesthetics is not a proper substitute for the technical analysis that 101 requires.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument regarding the Examiner's third theory for citing the Tufte book specifically the invocation of Tufte's aesthetic philosophy about chart design as a basis for concluding the claims lack a technical improvement and the assertion that this represents an improper and shifting analytical framework that has no grounding in the Alice/Mayo analysis, has been fully considered. The Examiner notes, consistent with the responses to the previous arguments, that the Tufte book is not relied upon in the current rejection and forms no part of the basis for the 101 rejection as it presently stands.
The Examiner addresses this argument solely because Applicant has raised it. Applicant's detailed critique of the third theory including the argument that Tufte's discussion of chartjunk and graphical excellence concerns the aesthetics of printed chart design rather than the technical merits of computer-implemented inventions, and that a graphic design author's aesthetic philosophy is not a proper substitute for the technical analysis required under the Alice/Mayo framework is directed entirely at a reference and a rationale that no longer appear in or support the current rejection. The substantive correctness of the current rejection does not depend on Tufte in any respect, and every point Applicant raises regarding the book's misapplication is therefore immaterial to whether the rejection should be maintained. The current rejection stands entirely on the detailed Alice/Mayo framework analysis set forth in the responses to all the previous Arguments, which establishes through well-supported legal and factual reasoning that the claims are directed to abstract ideas without additional elements that integrate those ideas into a practical application or provide significantly more, independent of any reference to Tufte or any aesthetic principle drawn from graphic design literature. Accordingly, the rejection under 101 is maintained.
The Applicant argues on pages 39-40 that “The Tufte book is not relevant to the 101 analysis under any theory. For the foregoing reasons, Applicant respectfully submits that the Tufte book does not, and cannot, support the 101 rejection. Under Alice/Mayo, the Examiner bears the burden of articulating a consistent, well-supported basis for concluding that the claims are directed to an abstract idea and lack an inventive concept. The Examiner's shifting reliance on the Tufte book fails to meet that burden. The Tufte book is, by its own express terms, a treatise on the visual design of statistical graphics how to make printed charts and diagrams more effective and aesthetically clear. Tufte himself states that the book is about "how to communicate information through the simultaneous presentation of words, numbers, and pictures" in printed form, with "the emphasis. On maximizing principles, empirical measures of graphical performance, and the sequential improvement of graphics through revision and editing" (Introduction, PDF p. 8). The book's chapters address "Graphical Excellence," "Graphical Integrity," "Data-Ink and Graphical Redesign," "Chartjunk: Vibrations, Grids, and Ducks," and "Data-Ink Maximization and Graphical Design" all topics directed to the aesthetics and integrity of printed statistical illustrations. A review of the book's comprehensive index confirms the complete absence of any discussion of "graph theory," "graph databases," "graph data structures," "nodes" or "edges" in the computer science sense, "traversal algorithms, Interactive interfaces," "user interfaces," or any related computational concepts. The book does not address graph databases, graph data structures, graph traversal algorithms, interactive node-based interfaces, or any of the computer science technologies recited in the claims. Applicant respectfully submits that the Examiner's change in rationale for citing the book on three occasions first invoking "graph theory," then retreating to "data visualization," and finally advancing a "substance over technology" aesthetic philosophy confirms that no coherent basis exists to connect the Tufte book to the claimed invention.
Moreover, the Examiner has expressly stated that the book "is being identified not as prior art, but to provide context of what one of ordinary skill in the art would know." Yet none of the Examiner's evolving theories actually establishes that one of ordinary skill in the art would understand the claimed combination of graph database technology, traversal algorithms, endpoint node types, and interactive visual workspaces to be conventional by reference to a 1983 book on statistical graphic design. As Tufte concludes in the book's epilogue: "What is to be sought in designs for the display of information is the clear portrayal of complexity. Not the complication of the simple; rather the task of the designer is to give visual access to the subtle and the difficult, that is, the revelation of the complex" (Epilogue, PDF p. 184). This is a statement about the craft of drawing informative charts not a statement about whether computer science innovations in data organization and retrieval are patent-eligible. Applicant respectfully submits that the Tufte book does not speak to the technology at issue and should not form any part of the basis for the 101 rejection. The Examiner's evolving rationale for citing the book across three separate theories spanning multiple Office Actions, further confirms that the rejection, insofar as it relies on the Tufte book, lacks the reasoned and consistent analytical foundation that the Alice/Mayo framework requires. Accordingly, Applicant respectfully requests that the Examiner withdraw reliance on the Tufte book in connection with the 101 rejection.”
The Examiner respectfully disagrees.
With respect to the argument the Examiner notes that the Applicant's argument that the Tufte book cannot support the 101 rejection under any theory, and that the Examiner's shifting characterizations of its relevance across multiple Office Actions confirm the absence of a coherent analytical basis connecting the book to the claimed invention, has been fully considered. The Examiner notes, consistent with the responses to the previous arguments, that the Tufte book is not relied upon in the current rejection and forms no part of the basis for the 101 rejection as it presently stands.
Applicant's request that the Examiner withdraw reliance on the Tufte book is granted to the extent that the book does not appear in and is not relied upon in the current rejection. There is therefore nothing to withdraw. The current rejection stands entirely on the detailed Alice/Mayo framework analysis developed throughout prosecution and set forth comprehensively in the responses to all the previous Arguments, which establishes through well-supported legal and factual reasoning that the claims are directed to abstract ideas without additional elements that integrate those ideas into a practical application or provide significantly more. That analysis is wholly independent of the Tufte book and is unaffected by any of Applicant's arguments regarding it. The extensive arguments Applicant has devoted to the Tufte book across multiple previous Arguments do not identify any deficiency in the substantive basis of the current rejection and therefore do not advance any basis for withdrawing it. Accordingly, the rejection under 35 U.S.C. 101 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 1-5, 7-14, 16-23, 25, and 26 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claimed invention is directed to an abstract idea without significantly more. The claims recite the abstract idea of navigating relational data about entities through defined rules to identify relevant pathways for investigating and evaluating financial crime or other business-related risks, which constitutes both a mental process and a method of organizing human activity related to commercial compliance. This judicial exception is not integrated into a practical application because the additional elements recited in the claims generic computer components performing generic computer functions of storing graph data, traversing pathways, storing results, and displaying information amount to mere instructions to apply the exception using conventional computer technology. The claims do not include additional elements sufficient to amount to significantly more than the judicial exception itself, as each additional element individually and the combination of all additional elements represents well-understood, routine, and conventional computer functionality that does not improve computer technology or any other technology or technical field.
STEP 1:
Regarding Step 1 of the Subject Matter Eligibility Test, claims 1-5 and 7-8 are directed to a computer-implemented system (machine), claims 9-14 and 16-17 are directed to a computer-implemented method (process), and claims 18-23, 25, and 26 are directed to a nonvolatile computer-readable medium (manufacture). Therefore, all pending claims fall within the statutory categories of invention and examination proceeds to Step 2A.
STEP 2A PRONG ONE:
The claims recite an abstract idea. The independent claims 1, 9, and 18 recite the following limitations that constitute the identified judicial exception:
Receiving and storing relational data: "receive data from various sources"; "store a database configured to store, in nonvolatile memory, a graph, pursuant to one or more data models, using the graph data structure"; "storing the received data in accordance with the one or more data models in the graph data structure in the database"
Defining rules to identify relevant pathways: "define a set of rules for controlling graph traversal that are configured to selectively identify for the user relevant pathways from the graph, wherein the set of rules are configured to: (i) select a starting node for graph traversal; (ii) designate a particular node type to end graph traversal of a pathway; and (iii) end the path traversal of the pathway using the particular node type"
Automatically traversing and identifying relevant pathways: "automatically, as operated by the rules, perform graph traversal from the starting node along a pathway and stop graph traversal of the pathway at any node that has the particular node type, wherein the pathway from the starting node to the end node is identified to be a relevant pathway for the starting node, in response, storing the relevant pathway for retrieval, and repeating the automatic graph traversal to identify additional relevant pathways"
Communicating and presenting pathway information: "provide a workspace comprising a visual workspace adapted to allow a user to interact with graphic representations of nodes and edges"; "in response to a user selecting a node, communicate that the selected node has one or more of the relevant pathways"; "interactively add one of the communicated one or more of the relevant pathways to the visual workspace"
Assisting user navigation: "whereby the computer is configured to assist the user to efficiently self-navigate the data through the relevant pathways in the visual workspace"
Abstract Idea Grouping Analysis
Option A Mental Process:
These limitations, under their broadest reasonable interpretation, cover performance of the limitations in the human mind, including observation, evaluation, judgment, and opinion. Specifically, the core concept recited by the independent claims navigating relational data about entities through defined rules to identify connections relevant to financial crime and sanctions compliance evaluation, and presenting those identified connections to a user for selective exploration constitutes a mental process because it covers the mental steps of observation, evaluation, and judgment that compliance analysts have performed long before computers existed.
The limitation of defining rules to select a starting node, designate a particular node type as a traversal endpoint, and end traversal when a node of that type is encountered describes the mental process of deciding where to begin an investigation, what type of entity constitutes a relevant finding, and stopping an investigation when such an entity is found. The limitation of automatically performing graph traversal and stopping at any node having the particular node type describes, under its broadest reasonable interpretation, the mental process of navigating from one conceptual entity to another and stopping when a particular type of entity is reached this is conceptually equivalent to a compliance analyst reviewing relationship records, following connections between entities, and stopping when a sanctioned entity is identified. The traversal of relationships between entities to identify connections to sanctioned actors is fundamentally a process of human reasoning and judgment about relationships, which compliance analysts performed long before computers existed. The word "automatically" does not preclude mental performance; a person can automatically, meaning without conscious deliberation, traverse conceptual relationships in their mind following predetermined logical criteria.
The limitation of providing a visual workspace that communicates relevant pathways to a user and allows the user to selectively add those pathways to the workspace describes the mental and manual process of reviewing a list of identified relationships and selecting which ones to examine further a process analogous to a compliance analyst maintaining a visual diagram of entity relationships and selectively adding connections as their investigation develops. The limitation describing user self-navigation through relevant pathways describes the mental process of an analyst exploring pre-identified relationship chains to understand compliance risks.
The mere nominal recitation of a generic processor or computer does not take these limitations out of the mental processes grouping. See MPEP 2106.04(a)(2), subsection III. The specification itself confirms the mental nature of the underlying concept by describing the invention as providing "a powerful and elegant solution to the needs of the institution with respect to financial crime and sanctions compliance" and enabling users to "quickly and cogently understand risk" characterizations directed to human cognitive outcomes rather than technical computer improvements.
Option B Certain Methods of Organizing Human Activity:
These limitations additionally fall within the "commercial or legal interactions" sub-grouping of certain methods of organizing human activity under MPEP 2106.04(a)(2), subsection II. The independent claims, read in their entirety including the preamble, are directed to organizing the human activity of commercial compliance investigation. The preamble of each independent claim expressly states the purpose of the claimed system to permit users to investigate and evaluate financial crime or other business-related risks and the claim body implements this purpose through limitations directed to navigating relationship data about entities to surface pathways of compliance interest and presenting those pathways to users for evaluation.
The specification repeatedly and consistently describes the invention in terms of financial crime compliance, sanctions compliance, regulatory compliance, and evaluating business risks, stating that the system allows "financial institutions, multinational corporations, legal professionals, and other stakeholders" to "evaluate their possible exposure to financial crime or sanctions-related risks." These are inherently commercial and legal interactions the paradigmatic example of the methods of organizing human activity grouping. Methods of organizing human activity can be performed on a computer without losing their character as methods of organizing human activity. See MPEP 2106.04(a)(2), subsection II. The use of graph database technology, traversal algorithms, and visual interfaces as tools to implement the commercial compliance investigation process does not remove the claims from this grouping. See MPEP 2106.04(a)(2)(II).
The claims recite an abstract idea in the form of both a mental process and a method of organizing human activity related to commercial compliance. The analysis proceeds to Step 2A Prong Two.
STEP 2A PRONG TWO:
The Examiner has evaluated all additional elements both individually and in combination, considering the claim as a whole as required by MPEP 2106.05, and has determined that the judicial exception is not integrated into a practical application.
Identification of Additional Elements
The claims recite the following additional elements beyond the identified abstract idea:
A computer / processor: "a computer configured to" perform the recited steps (Claims 1-8); a processor implementing the method steps (Claims 9-17, 18-26)
A graph database with nonvolatile memory storage: "store a database configured to store, in nonvolatile memory, a graph, pursuant to one or more data models, using the graph data structure comprising edges, nodes, and attributes"
Rule-based graph traversal configuration: the defined set of rules for controlling graph traversal, including starting node selection, endpoint node type designation, and traversal termination criteria
Automatic traversal and incremental pathway storage: automatic performance of graph traversal and storage of identified relevant pathways for retrieval
Visual workspace with interactive display: a visual workspace adapted to allow user interaction with graphic representations of nodes and edges, with selective addition of pathways and graphical display of connected pathway elements
Communication and selection mechanism: communication that a selected node has relevant pathways and interactive addition of selected pathways to the workspace
Analysis of Additional Elements
Improvement to Technology or Technical Field (MPEP 2106.05(a)):
The claim does not recite an improvement to the functioning of a computer or to any other technology or technical field. The specification describes the invention as providing a tool for compliance analysts to investigate financial crime relationships more efficiently this describes using conventional computer technology as a tool to perform the abstract business process of compliance investigation, not improving computer functionality itself.
The specification does not identify any specific technical limitation of existing graph database systems, graph traversal algorithms, or computer visualization technology that the claimed invention overcomes. The specification states that existing systems "have been found thus far to be inadequate in providing the institution with a cogent and quick representation of the risk as new situations arise" and that "understanding and assessing the information down to relevant parts has been difficult to achieve" these describe user-facing functional shortcomings in business terms, not specific technical deficiencies of the underlying computer technology. The specification does not explain how the claimed traversal approach differs technically from known graph search algorithms such as breadth-first or depth-first search with pruning, how the claimed data structure provides technical advantages over conventional graph databases, or how the claimed visual workspace technically improves upon conventional interactive graph visualization systems.
The specification's reference to saving "processing time and power consumption" describes the natural and expected consequence of performing a more limited computational search it reflects a business decision about what data is relevant for compliance purposes, not a technical innovation in computational methods. Any system that limits traversal scope will inherently reduce processing time and power consumption; this is a consequence of conventional optimization, not evidence of technological improvement. As noted in MPEP 2106.05(a), citing BSG Tech LLC v. Buyseasons, Inc., "an improvement to the information stored by a database is not equivalent to an improvement in the database's functionality." The claimed system improves what compliance information is surfaced and how it is presented to users it does not improve how the underlying graph database, traversal algorithms, or visualization systems technically function. See MPEP 2106.05(a).
Particular Machine (MPEP 2106.05(b)):
The claims do not recite use of a particular machine that imposes meaningful limits on the claimed abstract idea. The recited computer, processor, graph database, nonvolatile memory, and visual workspace are generic computing components that do not impose meaningful limits on the claim scope. The computer is recited at a high level of generality as a generic machine configured to perform the abstract compliance investigation process and does not constrain the claims to a particular technical implementation. See MPEP 2106.05(b).
Mere Instructions to Apply the Exception (MPEP 2106.05(f)):
The additional elements amount to no more than mere instructions to implement the identified abstract idea on a computer. The claims recite generic computer components a computer, a processor, a graph database with nonvolatile memory, a visual workspace performing generic computer functions of storing data, traversing data relationships, storing results, and displaying information to users. This is equivalent to adding the words "apply it" to the judicial exception, which the Supreme Court in Alice Corp. v. CLS Bank Int'l held is insufficient to transform an abstract idea into patent-eligible subject matter. Alice Corp. The claims describe functional results at a high level of generality "selectively identify for the user relevant pathways," "stop graph traversal," "assist the user to efficiently self-navigate" without reciting the specific technical mechanisms by which those results are achieved in a manner that would improve computer technology. Claims that recite only the idea of a solution or outcome without reciting details of how a solution to a problem is technically accomplished do not integrate a judicial exception into a practical application. See MPEP 2106.05(f); Electric Power Group, LLC v. Alstom S.A. See MPEP 2106.05(f).
Insignificant Extra-Solution Activity (MPEP 2106.05(g)):
Several of the additional elements constitute insignificant extra-solution activity. The step of receiving data from various sources is mere data gathering a conventional data collection step that precedes the core abstract process of compliance pathway identification and does not meaningfully limit the abstract idea. The step of providing a visual workspace and displaying the identified relevant pathways using graphical elements constitutes mere output of the results of the abstract idea a conventional data output step that presents the results of the compliance investigation process to users without adding any technical substance beyond what is inherent in outputting computational results. These data gathering and output steps are necessary incidental activities to the abstract compliance investigation process but do not independently provide integration into a practical application. See MPEP 2106.05(g).
Considering all additional elements individually and in combination as an ordered whole, the claim does not integrate the judicial exception into a practical application. The additional elements a generic computer, a conventional graph database with nonvolatile storage, conventional rule-based traversal configuration, conventional graph search and result caching, and conventional interactive graph visualization represent the application of conventional computer technology to implement the identified abstract ideas of compliance-relevant pathway navigation and compliance risk evaluation. The combination of these conventional elements produces the expected result of a conventional layered database application performing compliance pathway identification and presentation. None of the additional elements, individually or in combination, imposes a meaningful limit on practicing the abstract idea or reflects a specific technical improvement to computer technology or any other technology or technical field. Accordingly, the claims are directed to an abstract idea.
STEP 2B:
As discussed with respect to Step 2A Prong Two, the additional elements in the claims amount to no more than mere instructions to apply the exception using generic computer components. The same analysis applies in Step 2B mere instructions to apply an exception using a generic computer component cannot provide an inventive concept at Step 2B. See Alice Corp; MPEP 2106.05(f).
In order for a claim to recite significantly more than a judicial exception, the machine must play a significant part in permitting the claimed method to be performed, rather than function solely as an obvious mechanism for permitting a solution to be achieved more quickly. Here, the computer functions solely as an obvious mechanism for performing the compliance investigation process more quickly and at greater scale than could be achieved manually it does not play a technically significant role that improves how the computer itself functions. The claimed limitations of a generic computing device are not constraining the abstract idea to a particular technological environment and do not provide significantly more.
Well-Understood, Routine, Conventional Activity Analysis
The additional elements, considered individually and in combination, are well-understood, routine, and conventional activities in the relevant field as of the priority date of this application. The Examiner takes official notice, consistent with MPEP 2106.07(a)(III)(D), that the following elements were well-understood, routine, and conventional in the computer science and graph database fields as of the priority date of the original parent application:
Graph database with nonvolatile memory storage using nodes, edges, and attributes: Graph databases storing nodes, edges, and properties in nonvolatile memory are a well-established, widely deployed computer science technology. The courts have recognized that storing information in a database is well-understood, routine, and conventional activity. See MPEP 2106.05(d)(II), citing Versata Dev. Group, Inc. v. SAP Am., Inc. The specification itself confirms the conventional nature of graph database technology by describing graph databases as existing systems used to store nodes, edges, and properties without identifying any novel data structure or storage mechanism.
Rule-based graph traversal with configurable starting node selection, endpoint node type designation, and traversal termination: Configuring graph traversal with defined starting points, stopping criteria based on node properties, and traversal termination rules are standard, conventional parameters of graph search algorithms including well-known algorithms such as depth-first search and breadth-first search with configurable pruning criteria. The courts have recognized that applying filtering and selection rules to data is well-understood, routine, and conventional activity. See MPEP 2106.05(d)(II), citing Intellectual Ventures I LLC v. Capital One Fin. Corp.
Automatic graph traversal and incremental storage of traversal results: Automatically executing a data traversal or search algorithm and storing the results for later retrieval commonly known as pre-computation and caching is a well-understood, routine, and conventional computer science optimization technique. The courts have recognized that storing and retrieving information are well-understood, routine, conventional activities. See MPEP 2106.05(d)(II), citing Versata, 793 F.3d at 1334; OIP Techs., Inc. v. Amazon.com, Inc.
Interactive visual workspace displaying graphical representations of nodes and edges with selective user addition: Providing an interactive graphical user interface that displays relational data as nodes and edges and allows users to select and view associated data is conventional interactive graph visualization functionality. The courts have recognized that displaying results on a graphical user interface and receiving user input are well-understood, routine, and conventional activities. See MPEP 2106.05(d)(II), citing TLI Communications LLC v. AV Auto. LLC; Affinity Labs of Texas, LLC v. DirecTV, LLC.
Communicating pathway associations in response to user node selection and presenting selectable options: Retrieving and presenting associated records in response to user selection of a data element, and allowing user selection of associated items for further display, is the standard operation of any interactive database application presenting one-to-many data relationships. This is well-understood, routine, and conventional database application functionality. See MPEP 2106.05(d)(II), citing OIP Techs.
The combination of these individually conventional elements does not produce a non-conventional result. The combination implements a conventional layered database application architecture data ingestion and storage at the database layer, rule-governed query processing and result caching at the application layer, and interactive result display and user selection at the user interface layer applied to the business domain of financial crime compliance investigation. This is precisely the type of combination of conventional elements to achieve a predictable result that the Supreme Court in Alice identified as insufficient to confer patent eligibility. Alice Corp; see also BASCOM Global Internet Servs., Inc. v. AT&T Mobility LLC, (combination of known elements may provide inventive concept only where the specific combination reflects a non-conventional and non-generic arrangement). The present combination reflects the conventional architecture of database applications and does not constitute a non-conventional or non-generic arrangement.
Considering all additional elements individually and in combination, the claims do not include additional elements sufficient to amount to significantly more than the identified judicial exception. All additional elements represent well-understood, routine, and conventional computer components and functions, and their combination in a conventional layered database application architecture produces a conventionally expected result rather than a non-conventional technical advancement. The claims are not patent eligible.
Dependent Claims Analysis
The dependent claims do not add limitations that integrate the judicial exception into a practical application or provide an inventive concept. The following analysis addresses the dependent claims by functional group:
Claims 2, 10, and 19 (Search for entity from database and add node to visual workspace): These claims recite displaying an option to search for an entity from entities in the database and, in response, adding a node representing the entity to the visual workspace. Under its broadest reasonable interpretation, this limitation describes a conventional database keyword search and display operation searching a database by user-supplied criteria and adding a matching result to a display workspace is the standard behavior of any interactive database application and represents well-understood, routine, and conventional computer functionality. This limitation describes a conventional data input and display step that constitutes insignificant extra-solution activity it is a data gathering step that precedes the core abstract process of compliance pathway identification without adding any technical element that integrates the abstract idea into a practical application or provides significantly more.
Claims 3, 11, and 20 (Display graphic representation of connection between new and existing nodes): These claims recite displaying a graphic representation of a corresponding connection between a new node and one or more nodes in the visual workspace in response to the user adding a new node. This limitation describes a conventional graph visualization update operation automatically displaying edge connections between newly added and existing nodes is the standard and expected behavior of interactive graph visualization systems and represents well-understood, routine, and conventional display functionality. This is a conventional output step that presents the visual result of a standard graph data relationship and does not provide any specific technical improvement to graph visualization technology.
Claims 7, 16, and 25 (Display relevant pathways in ranked order): These claims recite providing a display that lists the relevant pathways associated with the corresponding starting node in ranked order. Presenting database query results in a ranked or ordered list based on a relevance metric is a well-understood, routine, and conventional computer function implemented in information retrieval and database systems for decades. The ranking of pre-computed pathways by degree of relevance is a conventional data presentation technique that reflects the business value of identifying the most compliance-significant connections, not a technical improvement to database or visualization technology. This limitation constitutes insignificant extra-solution activity a conventional output formatting step that does not provide significantly more than the abstract idea.
Claims 8 and 17 (Stop traversal in response to another rule): These claims recite stopping the traversal in response to determining another rule. This limitation recites an additional conventional traversal stopping condition applying multiple configurable stopping criteria to a graph traversal algorithm is a standard feature of rule-based graph search systems. Applying additional rules to terminate a search operation is a conventional and well-understood computer function that does not constitute a specific technical innovation in traversal algorithm design beyond what is already recited in the independent claims.
Claims 12 and 21 (Threshold number of node traversals stops traversal): These claims recite that the rules include a threshold number of node traversals from a starting node that stops traversal. Limiting graph search depth by a configurable maximum number of node traversals is a standard graph search pruning technique commonly known as depth-limited search that is a well-understood, routine, and conventional feature of graph traversal algorithms. This technique was conventional in computer science well before the priority date of this application and does not reflect any specific technical innovation in traversal algorithm design.
Claims 4, 13, and 22 (Display all surfaced pathways and allow selection): These claims recite displaying information about a node including a plurality of all of its associated surfaced pathways and allowing the user to select one or more of the associated surfaced pathways to the current workspace. This limitation describes a conventional one-to-many data retrieval and display operation displaying all associated records for a selected data element and allowing user selection of specific associated records for further display is the standard behavior of any interactive database application presenting relational data. The content of what is displayed a node's pre-identified compliance-relevant pathways reflects the business purpose of the system, while the display and selection mechanism is a conventional user interface function.
Claims 5, 14, and 23 (Update automatic traversal when new nodes or edges added): These claims recite updating the automatic traversal of pathways in response to new nodes or edges being added to the graph in the graph database. This limitation describes a conventional database update and re-computation trigger initiating re-execution of a computation process in response to new data being added to a database is a well-understood and conventional database management function. Triggering re-computation of cached results when underlying data changes is the standard behavior of any database system that maintains pre-computed results, consistent with the conventional pre-computation and caching pattern that underlies the incremental pathway storage described in the independent claims.
Claims 26 (Stop traversal in response to determining another rule CRM): Claim 26 depends from claim 18 and recites the same additional traversal stopping rule limitation as claims 8 and 17. The same analysis applies: applying an additional configurable stopping criterion to a graph traversal operation is a well-understood, routine, and conventional computer function that does not provide significantly more than the abstract idea.
None of the dependent claims adds a limitation that integrates the identified abstract idea into a practical application or amounts to significantly more than that abstract idea. Each dependent claim further specifies the data content, display format, traversal parameters, or system behavior of the claimed compliance investigation system in conventional functional terms without reciting any specific technical mechanism that constitutes an improvement to computer technology or any other technology or technical field. The dependent claims do not remedy the deficiencies of the independent claims. See MPEP 2106.07.
For the foregoing reasons, claims 1-5, 7-14, 16-23, 25, and 26 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. The claims recite abstract ideas in the form of a mental process and a method of organizing human activity related to commercial compliance, without additional elements that integrate those abstract ideas into a practical application or provide significantly more than the abstract ideas themselves. All additional elements represent well-understood, routine, and conventional computer components and functions applied to the business problem of financial crime compliance investigation, and their combination in a conventional database application architecture does not constitute a non-conventional technological improvement that would confer patent eligibility under 35 U.S.C. 101.
Conclusion
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/S.S.S/Examiner, Art Unit 3625
/BETH V BOSWELL/Supervisory Patent Examiner, Art Unit 3625
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