DETAILED ACTION
This action is responsive to the Applicant’s response filed 7/06/26.
As indicated in Applicant’s response, claims 1, 5-6, 8-16, 19-20 have been amended, and claim 21 added. Claims 1-21 are submitted pending prosecution by the following office action.
Claim Rejections - 35 USC § 101
Claim 1 is rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Claim(s) 1 is/are directed to Abstract Idea. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because of the 2-steps analysis as follows.
Step I
This claim relates to a process/method category
Step 2A
Prong one:
The limitation "causing... orthonormal vector based principal component analysis (PCA) to be performed... comprising obtaining an inverted solution of a trained machine learning model" recites mathematical formulas, algorithms, and matrix/vector operations and acquiring of a solution. Mathematical calculations and execution of algorithms - even when performed by software or a machine learning model - are mathematical concepts – see Mathematical Concepts (MPEP 2106.04(a)) and acquiring a solution falls into a standard data gathering/acquisition of a mental process.
The steps of "identifying target film property data" and analyzing that data using PCA or an inverted ML model represent gathering, analyzing, and organizing data. These steps involve mental concepts or data manipulation steps that can be performed computationally or theoretically in the human mind. See Mental Processes / Data Processing (MPEP 2106.04(a))
In fact, a orthogonal vector based principal component analysis can be viewed as a well-defined mathematical algorithm used for dimensionality reduction and data transformation; which under the Mathematical Concepts per MPEP 2106.04(a)(I), mathematical relationships, algorithms and formulas are identified as Judicial Exceptions; whereas the steps of "identifying" and "causing" (orthogonal component analysis) and causing processing to meet the target" are acts that can be performed in a human mind or via use of pen and paper. MPEP 2106.04(a)(2)(III), as concepts that can be performed in mental realm even if with a computer - fall within this category.
Prong two:
As specified from the claim language, this specification does not demonstrate an improvement to the functioning of a computer or specific manufacturing hardware itself. Instead, the claim relies on general-purpose machine learning, generic PCA math, and generic computer processing.
The limitation recited as "causing, based on the output, performance of one or more corrective actions associated with substrate processing by manufacturing equipment..." is recited in purely functional terms ("causing performance of..."). It fails to recite how the manufacturing equipment is altered or controlled at a detailed physical level. Broadly linking an abstract mathematical output to a generic environment ("manufacturing equipment") or an outcome ("to cause the substrates to meet the target film property data") constitutes mere field-of-use restriction or extra-solution activity. See MPEP 2106.04(d)(ii))
The limitations about solution to a trained machine learning amounts to a desired result without clear depiction of transformation to the field in which the abstract idea operates; notwithstanding that orthonormal vector and machine learning expressed in broad terms are viewed as well-understood concepts in mathematical means or numerical techniques. The "processing of substrates" as recited in generic terms is considered extra-solution activity - MPEP 2106.04(d)(2) to the abstract steps of “identifying” and “causing … to perform”; here again, there is lack of technical improvement evidenced in this limitation not describing how the PCA improves the physical substrate processing or the functioning of a PCA computer itself; the claim simply states a desired result (to meet something) – see – MPEP 2106.05(f) – that is, a claim that simply recites a result without specific technical "how-to" fails to provide a practical application. MPEP 2106.05(a)(b)(c )(g)
Step 2B
The additional elements construed individually as "target film property data" amounting to generic data subjected to gathering/input; "PCA" / "trained machine learning model", construed as standard algorithmic tools and data processing steps; "Manufacturing equipment", expressed at a high level of generality as a conventional machine environment are all construed as following.
Performing a PCA is the Abstract Idea itself; i.e. using a mathematical representation or relationships.
Processing of substrates amounts to a generic manufacturing step, absent any detail on how substrate is modified or manipulated.
Manufacturing equipment recited generically is a well-known concept in industrial data/material formation.
The recitation of “obtaining of inverted solution” is construed as data acquisition step where the object thereof is a desirable result devoid of details showing how the solution is being realized (absent any detail on how specifically a “substrate” is being technically modified or in what ways an inverted solution is particularly implemented) – MPEP 2106.05(f)
In other words, none of these elements, individually, represent non-conventional activity; they are well-understood, routine, and conventional in the art of computer-implemented manufacturing control. MPEP 2106.05(d); whereas mention of a desired result fail to demonstrate a technical and concrete transformation that can be patentable.
Taking the steps in combination, the sequence merely describes: (1) getting target data, (2) applying standard data-inversion/PCA math, and (3) telling manufacturing equipment to fix substrate properties to match the target or meet a desired result. This reflects the basic process of using math to calculate a correction and applying it generally. The combination does not provide a specific, non-conventional technical solution to a technical problem.
Accordingly, the claim lacks an inventive concept and fails Step 2B as its limitations or features cannot add significantly more to the Judicial Exception from above. Claim 1 is non-statutory under 35 U.S.C. 101.
Claims 8 and 15 is/are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Claim(s) 8 and 15 is/are directed to Abstract Idea. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because of the 2-steps analysis as follows
A. Eligibility of claim 8
Step I: Claim 8 is a "medium" category subject matter
Step 2A
Prong one:
Here again, the same steps of identifying and causing analysis and causing the processing, obtaining a solution as recited can be viewed as mental activities by a human or activities made via pen and paper or via mathematical concepts. Claim 8 is directed to an Abstract Idea - MPEP 2106.04(a) (1) & (2), specifically that of a Mathematical Concept and a Mental process as set forth above with claim 1.
Prong two:
The limitation of “processing of substrates” recited in very generic term, lacks any technical improvement as the claim does not describe how the PCA improves the physical substrate processing or the functioning of a PCA computer itself; and in those terms the processing of substrates is considered extra-solution activity - MPEP 2106.04(d)(2) - or expression of a desired result such as “inverted solution”- MPEP 2106.05(f) - without showing of the "how-to" - MPEP 2106.04(a)
The limitations about solution to a trained machine learning amounts to a desired result without clear depiction of transformation to the field in which the abstract idea operates; notwithstanding that orthonormal vector and machine learning are viewed as well-understood concepts in mathematical means or numerical techniques. These elements as recited fail to demonstrate that a transformation is being present to particularly realize the target film processing
Claim 8 cannot integrate the Abstract Idea into a practical application
Step 2B
As the language about “performing a PCA” is being a generic/abstraction act - i.e. using a mathematical representation or relationships - within the Abstract Idea itself, and as “processing of substrates” amounts to a generic manufacturing step without presence of machine or HW, and as “obtaining of inverted solution” is construed as a desirable result devoid of details showing how the solution is being realized (absent any detail on how specifically a “substrate” is being technically modified or inverted solution being implemented), claim 8 merely depicts a standard scientific method of gathering data, performing statistical analysis, and adjusting a process based on a desired solution or results: this is a well-understood routine, as well as conventional activity in the fields of materials science. That is, the above-mentioned additional elements expressed in their recited order in claim 8 do not add significantly more to the Abstract Idea of step 2A. MPEP 2106.05 (a)(b)(c)(d) (g)
Claim 8 is deemed non-eligible under the 35 USC § 101 statute.
B. Eligibility of claim 15.
Claim 15 is a system/apparatus claim
For Step 2A, prong one: claim 15 recites the step of identifying, obtaining a solution, causing a mathematical analysis and a processing to meet a target, according to which, all are construed as activities that can be done by a human process or via use of pen/paper as set forth as falling into a Abstract Idea type of Judicial Exception in claim 1.
For step 2A, prong two: claim 15 recites no details on how a PCA can improve a substrate process; nor how a processing of substrate is implemented with an inventive technique, notably when “processing of substrates” expressed in generic terms is considered extra-solution activity - MPEP 2106.05(g) - without showing the "how-to" - MPEP 2106.05(f) – to the abstract steps of identifying or causing.
The limitations about solution to a trained machine learning amounts to a desired result without clear depiction of transformation to the field in which the abstract idea operates; notwithstanding that orthonormal vector and machine learning expressed in broad terms are viewed as well-understood concepts in mathematical means or numerical techniques. These elements as recited fail to demonstrate how a transformation is done to particularly realize the target film processing.
Claim 15 as far as merely depicting these concepts in generic terms and mere reciting functional operations and desired result cannot integrate the Abstract Idea into a practical Application.
Per step 2b,
As the language about “performing a PCA” is being a generic/abstraction act - i.e. using a mathematical representation or relationships - within the Abstract Idea itself, and as “processing of substrates” amounts to a generic manufacturing step without presence of machine or HW, and as “obtaining of inverted solution” is construed as a desirable result devoid of details showing how the solution is being realized (absent any detail on how specifically a “substrate” is being technically modified or inverted solution being implemented), claim 8 merely depicts a standard scientific method of gathering data, performing statistical analysis, and adjusting a process based on a desired solution or results: this is a well-understood routine, as well as conventional activity in the fields of materials science.
That is, the above-mentioned additional elements of claim 8 do not add significantly more to the Abstract Idea of step 2A.
Claim 15 is deemed non-eligible under35 USC § 101 statute.
Step 2B analysis of dependent claims.
Claims 2-3 recites a mathematical analysis using a numerical advanced technique of ML training, where input is based on historical data; there is no details on how the ML learning affects the PCA so to generate a improvement to the field of substrates processing. The ML training recited in generic terms with historical data cannot add significantly more to the Abstract Idea of claim 1.
Claims 4-5 recites selecting of data points for the orthogonal analytic directed at target film and generated updated parameters (to meet a target); but gathering of data and updating data are well-understood routines in the process of observation and analytic that cannot add significantly more to the Abstract Idea of the base claim.
Claims 6-7 recite cause modification of hardware (to meet a target) and to apply a PCA if a property does not meet a target; thus, the modification is construed as post-solution activity and applying a PCA is construed as generic step of analyzing via mathematical deduction or rationalizing, and these claims fail to add significantly more to the abstract Idea of claim 1.
Claims 9-10, 11-12, 13-14 can be additional elements bearing the same step IIB analysis of claims 2-3, 4-5, 6-7 from above.
Claims 16-17, 18-20 as "additional elements" will be referred to with the step IIB analysis of claims 2-3, 4-5, 6-7 from above.
Claim 21 recites receiving tested film property data based on corrective actions and updating the machine learning model based on the above, with result in improving subsequent actions to cause the substrates to more closely meet the target film property. The update and corrective actions are deemed post-activity to the Abstract Idea because they are based on the initial processing by PCA; further these extra-solution activities do not describe how the improvement is implemented but merely states a desired result such as improving data so to more closely meet some criteria. The extra-solution activities described solely in terms of their functional nomination and desirable state of achievement cannot represent a technical implementation that add significantly more to the Judicial Exception.
In all, claims 1-21 are all non-eligible under the 35 USC § 101 statute.
Response to Arguments
Applicant's arguments filed 7/06/26 have been fully considered but they are not persuasive. Following are the Examiner’s observations in regard thereto.
(A) In regard to the 35 USC § 101 rejection, Applicant’s assumption that the added limitations will make the subject matter eligible (Applicant's Remarks pg. 8 top) is deemed largely inconclusive, and so for the reasons set forth with the statutory rejection now presented with this Office Action.
(B) The Applicant has submitted that the cited references fail to teach or suggest PCA achieved on basis of obtaining a inverted solution of a trained ML (Applicant's Remarks pg. 8 bottom). The remark is deemed MOOT in view of absence of prior art rejection being presented herewith. The allowability state of the claims as amended cannot be ascertained due to un-resolved state of the 35 USC § 101 rejection.
In all, the claims stand prosecuted as set forth in the above presented Office Action.
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 extension fee pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Tuan A Vu whose telephone number is (571) 272-3735. The examiner can normally be reached on 8AM-4:30PM/Mon-Fri.
If attempts to reach the examiner by telephone are unsuccessful, the examiner's supervisor, Chat Do can be reached on (571)272-3721.
The fax phone number for the organization where this application or proceeding is assigned is (571) 273-3735 ( for non-official correspondence - please consult Examiner before using) or 571-273-8300 ( for official correspondence) or redirected to customer service at 571-272-3609.
Any inquiry of a general nature or relating to the status of this application should be directed to the TC 2100 Group receptionist: 571-272-2100.
/Tuan A Vu/
Primary Examiner, Art Unit 2193
August 28, 2026
