Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of Claims
This action is in response to remarks received 06/04/2026.
Claims 1, 11 & 18 being independent and claims 2-10, 12-17 & 19-20 dependent.
Claims 1, 3, 5, 11, 14 and 18 have been amended.
Applicant’s arguments, see pages 15-16, filed 06/04/2026, with respect to the rejections of claims 1-20 under 35 USC 102 have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground of rejection is made under 35 U.S.C. § 103 over Clemens (US 2024/0086409 A1), supported by the rationale articulated in KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (2007); see MPEP 2143(A) (combining prior art elements according to known methods to yield predictable results).
Claims 1-20 are currently pending and have been examined.
Response to Arguments
Applicant's arguments filed 06/04/2026 have been fully considered but they are not persuasive.
With respect to rejections under 35 USC § 101, Applicant made three arguments (Prong One mental-process, Prong Two practical application via improvement, and Step 2B/BASCOM).
With respect to the first argument, Applicant argues that the claims cannot be classified as a mental process because it is unclear how the human mind could practically perform the recited generating and performing steps, particularly as amended to recite restricting transmission of the data structure toward a second plurality of computing devices on a communication path.
The recitation of the network-based transmission-control steps does not remove the claims from the mental-process grouping under Step 2A Prong one. The claim as a whole continues to recite, at its core, the concept of evaluating data values against rules and determining whether a value is valid, i.e., collecting information, analyzing it against conditions, and reaching a determination, which is a mental process of observation, evaluation, and judgement, MPEP § 2106.04 (a)(2). That certain steps are recited as being performed by one or more processors and on a communication path does not negate the abstract character of the underlying evaluation; it merely invokes computers as tools and situates the abstract idea in a technological environment, MPEP § 2106.05 (f), (h). The determination of whether a value satisfies a validation rule is an evaluative judgment that can be performed mentally, and reciting that the result is used to gate a transmission does not change the nature of the judgement itself.
Accordingly, the claims recite an abstract idea under Prong One.
Applicant’s second argument, that, even if the claims recite an abstract idea, the amended claims integrate that idea into a practical application by reciting a system positioned in a communication path from a first computing device to a second plurality of computing devices that restricts transmission of an invalid data structure toward downstream devices, thereby improving the functioning of the network (conserving bandwidth, preventing propagation of invalid data structures), and Applicant analogizes BASCOM.
This argument has been considered but is not persuasive for the following reasons. The additional elements recited in amended claim 1; one or more processors, a policy administration system, a user interface, a network, a communication path, and a first/second plurality of computing devices; are recited at a high level of generality and are used to perform the abstract evaluation and to carry out generic data-transmission functions (receiving a data structure, transmitting or withholding it). Reciting that a generic validating node sits in a communication path and withholds onward transmission of data determined to be invalid amounts to applying the abstract idea using generic computer and network components performing their ordinary functions (routing/gating data), which is not a technical improvement to the network itself but rather the use of the network as a tool to carry out the result of the abstract determination, MPEP § 2106.05(f).
The asserted improvement; conserving bandwidth and avoiding propagation of invalid data; flows directly from the abstract determination that data is invalid, not from any improvement in the way computer or networks operate. Deciding not to transmit data that has been judged invalid is the expected consequence of judgement; it does not reflect an improved network architecture, an improved transmission protocol, or an improvement in the functioning of the computing device. This is distinguishable from BASCOM, where the inventive concept resided in a specific, non-conventional arrangement; the installation of a filtering tool at a specific location remote from the end-users with individually customizable filtering; that improved the technology of content filtering itself. Here, by contrast, the claim recites conventional placement of a validating node in a communication path and conventional gating of transmission; the arrangement is not shown to be non-conventional or to yield an improvement beyond the predictable result of not forwarding data that has been deemed invalid.
To the extent Applicant relies on the specification’s assertions of improved bandwidth conservation and prevention of invalid-data propagation (e.g., Spec. ¶¶ [34 & 72]), an improvement described only in the specification does not establish integration under Step 2A Prong Two where the claim itself recites only generic components (processors, a policy administration system, a network) performing conventional data-transmission functions. The asserted improvement must be reflected in the claim, not merely the specification. See MPEP § 2106.04(d)(1).
Accordingly, the additional elements do not integrate the abstract idea into a practical application, MPEP § 2106.04(d), and the claims remain directed to the abstract idea.
Applicant’s Third argument, that, the instant claims recited additional elements that amount to significantly more than the judicial exception, as the additional elements amount to an inventive concept; however, the Examiner respectfully disagrees. For substantially the reasons above, the additional elements, considered individually and as an ordered combination; do not amount to significantly more than the abstract idea. the processors, policy administration system, user interface, network, and communication path placement perform well-understood, routine, and conventional functions (receiving data, evaluating data against rules, transmitting or withholding data across a network). Situating a generic validating node in a communication path to gate downstream transmission is a conventional network arrangement, not the non-conventional and non-generic arrangement that supported eligibility in BASCOM. The ordered combination recites the abstract evaluation followed by the conventional expected act of not forwarding data judged invalid, which does not supply an inventive concept, (MPEP § 2106.05).
For the above reasoning, the 35 USC § 101 rejection of claims 1-20 is therefore maintained.
With respect to rejections under 35 USC § 102, the arguments have been considered, however, the Examiner respectfully disagrees. Applicant argues that Clemens fails to disclose each and every element of the amended claims and therefore cannot anticipate. In view of Applicant’s amendments, the anticipation rejection has been withdrawn and replaced with the 35 USC § 103 rejection set forth below. Applicant’s argument is therefore moot as to anticipation. To the extent Applicant’s argument is directed to the plurality of actions … selecting an action limitation, that limitation is expressly disclosed by Clemens ¶¶ [144 & 224-225], as set forth below. To the extent the argument is directed to the communication path … second plurality of computing devices limitation, that limitation is addressed under the KSR rationale set forth below.
Claim Rejections - 35 USC § 101
35 U.S.C. § 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (an abstract idea) without significantly more.
Under Step 1, claims 1-10 are directed to a method, claims 11-17 are directed to a system, and claims 18-20 are directed to a non-transitory computer-readable medium.
Accordingly, the claims fall within the statutory categories of process, machine, and manufacture under 35 USC 101.
Under Step 2A, Prong One, representative independent claim 1 recites steps including:
receiving a data structure comprising a plurality of fields and a corresponding plurality of values according to a data type of a plurality of data types for a policy;
selecting from a plurality of configurations corresponding to the plurality of data types, a configuration based on the data type of the data structure, the configuration identifying (i) at least one of the plurality of fields to be validated for transmission and (ii) a plurality of actions to be performed based on at least one of the plurality of fields determined as not valid;
identifying from the plurality of fields of the data structure, a field to be validated in accordance with the configuration;
determining that a value of the plurality of values corresponding to the field is not valid in accordance with the configuration;
generating an indication identifying the data structure defining the policy as restricted due to the value of the field,
responsive to determining that the value is not valid; and
selecting from the plurality of actions in accordance with the configuration an action, based on the indication to restrict transmission of the data structure; and
performing the action selected from the plurality of actions to restrict the transmission of the data structure.
These steps describe collecting information, analyzing information, and making a determination based on the analysis, followed by indicating a result. Such operations constitute mental processes that can be performed in the human mind or with pen and paper (e.g., reviewing policy data fields, determining whether values satisfy validation rules, and deciding whether transmission should be permitted).
Mental processes are identified by the 2019 Revised Patent Subject Matter Eligibility Guidance as a category of abstract ideas. Accordingly, claim 1 recites a judicial exception.
Independent claims 11 & 18 recite limitations substantially similar to those of claim 1, implemented in the form of a system and a computer-readable medium, respectively. These claims similarly recite collecting information, evaluating the information according to rules, and determining an outcome regarding whether transmission should occur.
Therefore, claims 11 and 18 also recite the abstract idea of mental processes.
Under Step 2A, Prong two, the additional elements recited in the claims include
one or more processors
memory
a policy administration system
a user interface
a network
data structures
These elements represent generic computer components performing conventional data processing functions, such as receiving data, processing data according to rules, and generating an output. The claims merely use a computer as a tool to perform an abstract idea of validating information and deciding whether transmission should occur.
The claims do not:
improve the functioning of the computer itself
improve another technology or technical field
apply the abstract idea using a particular machine in a meaningful way
effect a transformation of an article
Instead, the claims simply automate the evaluation of a policy data values and the determination of whether data should be transmitted. Thus, the abstract idea is not integrated into a practical application. Accordingly, the claims remain directed to the abstract idea.
Under Step 2B, the claims do not include additional elements that amount to significantly more than the abstract idea. The additional elements, including processors, memory, policy administration systems, user interfaces, and network; are described at a high level of generality and perform well-understood, routine, and conventional functions, such as:
receiving data
processing information
validating values
generating indications
transmitting data across network
These generic computer functions merely implement the abstract idea using conventional computing technology and therefore do not provide an inventive concept. Thus, the claims do not amount to significantly more than the judicial exception.
Dependent claims 2-10 depend directly or indirectly from claim 1 and add limitations relating to:
validating additional values (claim 2)
executing requests or transmitting data (claim 3)
selecting configurations based on request types (claim 4)
providing indication via a user interface (claim 5)
defining fields and values in the data structure (claim 6-9)
applying the validation to a vehicle policy (claim 10)
These additional limitations merely provide additional data evaluation rules, data field relationships, or contextual applications of the same abstract idea, and therefore do not integrate the abstract idea into a practical application or add significantly more. accordingly, claims 2-10 are rejected for the same reasons as claim 1.
Dependent claims 12-17 depend from independent claim 11 and recite limitations substantially similar to those in claims 2-9, including validating additional values, identifying request types, and evaluating relationships between fields and values. These limitations similarly involve additional instances of analyzing data and determining whether values are valid, which remain part of the same abstract idea. Thus, claims 12-17 are rejected for the same reasons as claim 11.
Dependent claims 19-20 depend from independent claim 18 and recite additional validation operations and configuration selection steps similar to those recited in claims 2 and 4. These limitations likewise represent additional data analysis steps within the same abstract idea. Therefore, claims 19-20 are rejected for the same reasons as claim 18.
For the above reasoning, claims 1-20 are directed to an abstract idea without significantly more and are rejected under 35 USC 101.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over David Clemens et al. (US 2024/0086409 A1, herein Clemens).
As per claim 1, Clemens teaches a method of validating data to be transmitted across networked environments, comprising:
receiving, by one or more processors of a policy administration system in a communication path from a first computing device to a second plurality of computing devices in a network, a data structure comprising a plurality of fields and a corresponding plurality of values according to a data type of a plurality of data types for a policy, the plurality of values having a subset of values generated via a user interface provided by the policy administration system (Clemens ¶¶ [108, 112-114, 119 & 244-245]);
selecting, by the one or more processors, from a plurality of configurations corresponding to the plurality of data types, a configuration based on the data type of the data structure, the configuration identifying (i) at least one of the plurality of fields to be validated for transmission to the network and (ii) a plurality of actions to be performed based on at least one of the plurality of fields determined as not valid (Clemens ¶¶ [109, 124-125, 133, 144 & 224-225]);
identifying, by the one or more processors, from the plurality of fields of the data structure, a field to be validated in accordance with the configuration (Clemens ¶¶ [124-125 & 134]);
determining, by the one or more processors, that a value of the plurality of values corresponding to the field is not valid in accordance with the configuration (Clemens ¶¶ [109, 118, 135-137 & 144]);
generating, by the one or more processors, an indication identifying the data structure defining the policy as restricted from transmission to the network due to the value of the field, responsive to determining that the value is not valid (Clemens ¶¶ [114, 118, 144 & 225]); and
selecting, by the one or more processors, from the plurality of actions in accordance with the configuration, an action, based on the indication to restrict transmission of the data structure to the network (Clemens ¶¶ [118, 133, 144-145 & 224-225]); and
performing, by the one or more processors, the action selected from the plurality of actions to restrict the transmission of the data structure toward the second plurality of computing devices on the communication path in the network (Clemens ¶¶ [117-118, 132, 144 & 244-245]).
To whatever extent Applicant contends that Clemens does not explicitly disclose that the policy administration system is positioned in a communication path from a first computing device to a second plurality of computing devices and restricts transmission of the data structure toward the second plurality of computing devices on the communication path in the network, it would have been obvious to one of ordinary skill in the art before the effective filing date to position Clemens’ validating system inline within such a communication path so as to restrict onward transmission of an invalid data structure toward downstream computing devices.
The rationale is as follows. Clemens already teaches (a) a policy administration system that receives a data structure, evaluates its field values against a configuration, and determines validity; (b) restricting/withholding the data structure and controlling whether data is transmitted onward based on that determination ¶¶ [118, 132 & 144]; and (c) operation within a networked environment connecting a source device and remote computing devices (¶¶ [117 & 244-245]). Clemens expressly recognizes the motivation for controlling such downstream transmission: restricting values that certain variables take on “is important … when such values have an impact on operational aspects of the data processing system”, and invalid values “may lead to unauthorized access”, “further errors”, and improper operation of downstream software and devices, (Clemens ¶¶ [71-73]). Positioning the validating system in the communication path between the source device and the downstream plurality of devices, so that a data structure determined to be invalid is not forwarded to those downstream devices; is no more than the predictable arrangement of these known elements (a validating node and known network connections) according to their established functions to achieve the result Clemens itself identifies as desirable, namely preventing invalid data structures from reaching and affecting downstream devices. Such placement is a known network arrangement (e.g., situating a policy-enforcing node inline in a communication path) that would have yielded predictable results, and one of ordinary skill would have had a reasonable expectation of success in so arranging Clemens’ system. See KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (2007); MPEP § 2143(A) (combining prior art elements according to known methods to yield predictable results)
Accordingly, claim 1 would have been obvious over Clemens.
As per claim 2, Clemens teaches the method of claim 1, further comprising: Clemens further teaches:
determining, by the one or more processors, that a second value of a second plurality of values corresponding to a second field of a second data structure defining a second policy is valid; generating, by the one or more processors, a second indication identifying the second data structure defining the second policy as permitted to be transmitted to the network, responsive to determining that the second value is valid; and performing, by the one or more processors, a second action, responsive to the second indication to permit transmission of the second data structure to the network (Clemens ¶¶ [118, 120-121 & 132]).
As per claim 3, Clemens teaches the method of claim 2, Clemens further teaches:
wherein performing the second action further comprises: executing a request associated with the policy, in accordance with the data structure defining the policy; and transmitting, to the first computing device, the second data structure defining the second policy (Clemens ¶¶ [100 & 117]).
As per claim 4, Clemens teaches the method of claim 1, Clemens further teaches:
wherein selecting the configuration further comprises selecting the configuration identifying a first request type for which the field of the plurality of fields is to be validated for transmission, and further comprising: determining, by the one or more processors, that a second request type associated with the data structure matches the first request type identified by the policy, and wherein identifying the field further comprises identifying the field, responsive to determining that the second request type matches the first request type (Clemens ¶¶ [109 & 125]).
As per claim 5, Clemens teaches the method of claim 1, Clemens further teaches:
wherein performing the action further comprises: providing, via the user interface, the indication identifying the field of the plurality of fields corresponding to the value as invalid; and restricting, from transmission to at least one computing device of the plurality of computing devices, transmission of the data structure defining the policy (Clemens ¶¶ [114 & 118]).
As per claim 6, Clemens teaches the method of claim 1, Clemens further teaches:
wherein receiving the data structure further comprises receiving the data structure comprising (i) the plurality of fields including (a) a first field and (b) a second field and (ii) the corresponding plurality of values including (a) a first value corresponding to the first field and (b) a second value corresponding to the second field, the first value inputted via the user interface, the second value generated using the first value in accordance with the second field (Clemens ¶¶ [108 & 114]).
As per claim 7, Clemens teaches the method of claim 1, Clemens further teaches:
wherein determining that the value is not valid further comprises: identifying, from the plurality of values of the data structure, a second value corresponding to second field of the plurality of fields in accordance with the configuration, the second value being part of the subset of values; and determining that the value is not valid based on consistency between the value and the second value (Clemens ¶¶ [77 & 127]).
As per claim 8, Clemens teaches the method of claim 1, Clemens further teaches:
wherein determining that the value is not valid further comprises determining that value of the plurality of values corresponds to a null value (Clemens ¶ [109]).
As per claim 9, Clemens teaches the method of claim 1, Clemens further teaches:
wherein identifying the field further comprise identifying, from the plurality of fields in accordance with the configuration, the field corresponding to at least one of a remaining subset of values of the plurality of values generated using one or more of the subset of values (Clemens ¶¶ [118 & 132]).
As per claim 10, Clemens teaches the method of claim 1, Clemens further teaches:
wherein receiving the data structure further comprises receiving the data structure comprising the plurality of fields and the corresponding plurality of values for the policy associated with a vehicle, the plurality of fields comprising at least one field identifying the vehicle (Clemens ¶ [69]).
As per claims 11 & 18, the claims recite analogous limitations as claim 1 above and rejected under the same premise, including the KSR rationale set forth above.
As per claim 12, the claim recites analogous limitations as claim 2 above and rejected under the same premise.
As per claim 13, the claim recites analogous limitations as claim 4 above and rejected under the same premise.
As per claim 14, the claim recites analogous limitations as claim 5 above and rejected under the same premise.
As per claim 15, the claim recites analogous limitations as claim 6 above and rejected under the same premise.
As per claim 16, the claim recites analogous limitations as claim 7 above and rejected under the same premise.
As per claim 17, the claim recites analogous limitations as claim 8 above and rejected under the same premise.
As per claim 19, Clemens teaches the non-transitory computer readable medium storing instructions of claim 18, Clemens further teaches:
wherein the operations further comprise: determining that a second value of a second plurality of values corresponding to a second field of a second data structure defining a second policy is valid; generating a second indication identifying the second data structure defining the second policy as permitted to be transmitted to the network, responsive to determining that the second value is valid; and performing a second action, responsive to the second indication to permit transmission of the second data structure to the network (Clemens ¶¶ [118, 120-121 & 132]).
As per claim 20, Clemens teaches the non-transitory computer readable medium storing instructions of claim 18, Clemens further teaches:
wherein the operations further comprise: selecting the configuration identifying a first request type for which the field of the plurality of fields is to be validated for transmission; determining that a second request type associated with the data structure matches the first request type identified by the policy, and identifying the field, responsive to determining that the second request type matches the first request type (Clemens ¶¶ [109 & 125]).
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
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/T.P.K./Examiner, Art Unit 3696
/MATTHEW S GART/Supervisory Patent Examiner, Art Unit 3696
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