DETAILED ACTION
Status of the Claims
This office action is submitted in response to the amendment filed on 6/5/26.
Examiner notes that this application claims foreign priority to 2023-149759 (Japan), which was filed on 9/15/23.
Claims 1, 4, and 6 have been amended.
Claim 3 has been canceled.
Therefore, claims 1-2, and 4-6 are currently pending and have been examined.
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 .
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 1-2 and 4-6 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.
Step 1: Under Step 1, the claims are evaluated to determine whether they fall within one of the four statutory categories of 35 U.S.C. § 101: process, machine, manufacture, or composition of matter. See MPEP § 2106.03. Claim 1 recites a "workflow management device" comprising a storage and a processor, and thus falls within the "machine" category. Claim 6 recites a "workflow management method" comprising a series of steps, and thus falls within the "process" category. Claims 2, 4, and 5 depend from claim 1, and thus likewise fall within the "machine" category. Accordingly, the claims satisfy Step 1.
Step 2A, Prong One: Independent claims 1 and 6, in part, describe an invention comprising: updating workflow information to indicate a current status of each drafter and/or approver of a respective workflow, the workflow information including, for each workflow, a drafter and a plurality of approvers listed in order of approval; setting in advance whether an operation on a document is to be denied due to an interlock, including setting in advance whether an operation on a respective document in a respective workflow for a first approver of the plurality of approvers is allowed based on whether one or more second approvers of the plurality of approvers has approved the respective document in the respective workflow; determining whether a received operation on a document is to be denied due to an interlock by referencing the interlock information; allocating documents to an area separately designated for a particular organization and workflow; issuing to a user an identifier that uniquely identifies a combination of the organization and the workflow and restricts the user's access to that separately allocated area; maintaining progress information of the workflow, which includes a workflow identification (ID), a time, a user ID, process information indicating a current process of the document in the workflow, and an indication of whether an operation on the document by a user was denied by interlock, stored in association with each other; and, upon determining an operation is denied, changing the progress information corresponding to the time, user ID, and workflow ID to indicate the operation was denied by interlock and to indicate the specific operation that was denied. As such, the invention is directed to the abstract idea of managing document workflows, which, pursuant to MPEP § 2106.04(a), is aptly categorized as a method of organizing human activity (business management) and a mental/manual process (the rules that the interlock information defines, including the rule conditioning a first approver's permission to operate on a document on whether one or more second approvers has approved that document, are approval-sequencing rules of the same character long applied in paper-based approval chains, and further define the abstract workflow management scheme itself). Therefore, under Step 2A, Prong One, the claims recite a judicial exception.
Next, the aforementioned claims recite additional elements that are associated with the judicial exception, including: receiving workflow information and interlock information; receiving an operation on the document while the workflow is in progress; storing the workflow information, the interlock information, the progress information, and the document in a separately allocated area; and displaying the workflow information on a display, including displaying an indication that a particular drafter and/or approver is currently drafting or approving a document in a respective workflow. Dependent claim 5 further discloses displaying information to a user if the operation is denied. The Examiner understands these limitations to be insignificant extra-solution activity. See Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1344-45, 108 U.S.P.Q.2d 1173, 1179 (Fed. Cir. 2013) (citing Diamond v. Diehr, 450 U.S. 175, 191-192 (1981) ("[I]nsignificant post-solution activity will not transform an unpatentable principle into a patentable process.")).
The aforementioned claims also recite additional elements including a "storage" for storing data; a "processor" for executing the process; and a "display" for presenting the workflow information. These limitations are recited at a high level of generality and appear to be nothing more than generic computer components used to apply the abstract idea. Claims that amount to nothing more than an instruction to apply the abstract idea using a generic computer do not render an abstract idea eligible. Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 223, 110 USPQ2d 1976, 1983 (2014).
Step 2A, Prong Two: Looking at the elements individually and in combination, the claims as a whole do not integrate the judicial exception into a practical application because they fail to: improve the functioning of a computer or a technical field; apply the judicial exception in the treatment or prophylaxis of a disease; apply the judicial exception with a particular machine; effect a transformation or reduction of a particular article to a different state or thing; or apply the judicial exception beyond generally linking the use of the judicial exception to a particular technological environment. Rather, the claims merely use a computer as a tool to perform the abstract idea, and/or add insignificant extra-solution activity to the judicial exception, and/or generally link the use of the judicial exception to a particular technological environment (e.g., generic computers connected to a network). Accordingly, the claims do not integrate the judicial exception into a practical application, and the analysis proceeds to Step 2B.
Step 2B: The claims do not include additional elements sufficient to amount to significantly more than the judicial exception. The additional elements, when considered individually and as an ordered combination, do not amount to significantly more than the abstract idea itself. Furthermore, looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or any other technology, and their collective functions are merely facilitated by generic computer implementation.
Additionally, pursuant to the requirement under Berkheimer v. HP Inc., 881 F.3d 1360, 125 USPQ2d 1649 (Fed. Cir. 2018), the following citations are provided to demonstrate that the additional elements, identified as extra-solution activity, are well-understood, routine, and conventional. See MPEP § 2106.05(d).
Storing and retrieving information in memory, including storing structured records associating workflow identifiers, timestamps, user identifiers, status information, and denial flags. Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93.
Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362; OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network).
Outputting/Presenting data to a user. Mayo, 566 U.S. at 79, 101 USPQ2d at 1968; OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1092-93 (Fed. Cir. 2015); MPEP § 2106.05(g)(3).
Thus, taken alone and in combination, the additional elements do not amount to significantly more than the above-identified judicial exception, and claims 1, 2, and 4-6 are ineligible under 35 U.S.C. § 101.
Next, claims 2, 4, and 5 depend from claim 1 and include all limitations contained therein. These claims do not recite any additional technical elements sufficient to transform the abstract idea into patent-eligible subject matter. Specifically:
Claim 2 recites wherein the interlock information sets whether an operation is to be denied due to an interlock according to a type of operation and a user. This limitation merely specifies criteria, namely operation type and user identity, for determining when to deny an operation, which is further detail regarding how the abstract workflow management rules are configured. This limitation further defines the abstract idea and does not integrate it into a practical application or add significantly more.
Claim 4 recites wherein the interlock information sets viewing or revising of the document as an operation that is to be denied with an interlock. This limitation identifies specific types of operations, namely viewing and revising, that may be subject to denial. This limitation merely provides examples of the operations governed by the abstract workflow management rules, further defining the abstract idea without adding any technical improvement.
Claim 5 recites wherein, upon determining the operation is denied due to an interlock, the processor is configured to display information that the operation has been denied due to an interlock to a user who has requested the operation. This limitation adds a notification step that merely outputs the result of the abstract workflow management determination to the user. As noted above, this is insignificant extra-solution activity, and the Berkheimer citations provided above demonstrate that outputting/presenting data to a user is well-understood, routine, and conventional. See OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1092-93 (Fed. Cir. 2015); MPEP § 2106.05(g)(3).
Thus, the dependent claims merely provide additional non-structural details that fail to meaningfully limit the claims or the abstract idea. The dependent claims continue to be directed to the same abstract idea of managing document workflows, implemented using generic computer components.
Therefore, claims 1, 2, and 4-6 are not drawn to eligible subject matter, as they are directed to an abstract idea without significantly more.
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.
Claims 1-2 and 4-6 are rejected under 35 U.S.C. § 103 as being unpatentable over Dutta (7,035,910B1) in view of Sogge (8,151,208B2), and in further view of Lim (20080091682A1) and Lowry (20180293533A1).
Claims 1 and 6: Dutta discloses a workflow management device and method comprising:
"a storage" and "a processor configured to" (Figs. 1 and 3);
"receive workflow information and interlock information" and "the interlock information being information that sets in advance whether an operation on the document is to be denied due to an interlock" (Figs. 4-5 and 8; Col. 2, Lines 34-44; Col. 6, Lines 59-67; Col. 8, Lines 35-62; Col. 11, Lines 15-28. Dutta discloses a workflow management system that provides a workflow template defining the stages of a document from its creation through its approval, including a Create state, an In-Review state, an In-Approve state, and an Approved state. A publishing operation access control list (ACL) is defined and stored in advance for each document, specifying which roles or users may perform which operations on the document at each stage of the workflow. If a requesting user's roles match the ACL, the operation is permitted; if not, the operation is denied.);
"receive an operation on the document while the workflow is in progress based on the workflow information" (Figs. 7-8; Col. 2, Lines 23-33; Col. 10, Lines 49-60. A user makes a request to perform an operation on a document during the active workflow period.);
"determine whether the received operation is to be denied due to an interlock by referencing the interlock information" (Claim 7; Figs. 7-8; Col. 10, Line 49 – Col. 11, Line 14. Upon receipt of a request to perform an operation on a document, the system resolves the requesting user's roles and compares them against the publishing operation ACL. If the user's roles do not match the ACL, the system denies access to the operation.); and
"wherein the storage is configured to store therein the workflow information, the interlock information" (Claim 2; Fig. 3; Col. 6, Lines 9-14; Col. 12, Lines 29-32. Store area 118 operates as a repository for documents, workflow information, and publishing operation ACL data stored in relation to the documents.).
Dutta does not appear to explicitly describe "the workflow information being information of a plurality of workflows of documents from drafting to approval and includes, for each workflow, a drafter, which is a user among a plurality of users, and a plurality of approvers, which are users listed in order of approval"; "sets in advance whether an operation on a respective document in a respective workflow for a first approver of the plurality of approvers is allowed based on whether one or more second approvers of the plurality of approvers has approved the respective document in the respective workflow"; or "update the workflow information to indicate a current status of each drafter and/or approver of each workflow including displaying the workflow information on a display and displaying an indication that a particular drafter and/or approver is currently drafting or approving a document in a respective workflow."
Sogge, however, discloses "the workflow information being information of a plurality of workflows of documents from drafting to approval and includes, for each workflow, a drafter, which is a user among a plurality of users, and a plurality of approvers, which are users listed in order of approval" (Figs. 1-2; Tables 2-5. Sogge discloses a workflow approval system in which workflow tracking information includes an originator, the user who submitted the document for approval, corresponding to the drafter, and multiple sequential approval steps, each comprising one or more individually identified approvers. The steps are ordered such that each step defines next steps, establishing an explicit order of approval. For example, Fig. 1 illustrates a tracking tree for a document in which originator John Smith submitted the document, followed by an accounting step assigned to approver Mike Jones, which upon approval routes to a budgeting step assigned to approver James Lee and an accounts receivable step assigned to approver Ted Brown, in sequential order. Table 2 defines the Tracking Step data structure as comprising an Approval Status, an Approvers array containing individually identified Tracking Approvers, a Step Name, Time Tracking, and Next Steps, establishing a formally ordered list of approvers across sequential workflow steps.).
Sogge further discloses information that "sets in advance whether an operation on a respective document in a respective workflow for a first approver of the plurality of approvers is allowed based on whether one or more second approvers of the plurality of approvers has approved the respective document in the respective workflow" (Col. 4, Lines 26-34 and 61-63; Figs. 1-2; Tables 2 and 4. The workflow definition sets in advance that a second step is dependent upon a first step, such that the approval of the first step is needed before approval of the second step may be requested. With reference to Fig. 1, the approval system will seek approval based on the budgeting step of approver James Lee and the accounts receivable step of approver Ted Brown only after the accounting step of approver Mike Jones results in an approval; approver James Lee is thus a first approver whose approval activity on the document is permitted based on whether second approver Mike Jones has approved the document in the workflow. Each step of a workflow may further have a condition that must be satisfied before the approval of that step is needed, and the step approval statuses of Table 4, including "Waiting Response," "Not Assigned," and "Condition Not Met," reflect that a given approver is not permitted to act on the document until the predefined preceding approvals have occurred. This dependency structure is set in advance in the workflow definition via the Next Steps element of the Tracking Step data structure of Table 2.).
Sogge further discloses "update the workflow information to indicate a current status of each drafter and/or approver of each workflow including displaying the workflow information on a display and displaying an indication that a particular drafter and/or approver is currently drafting or approving a document in a respective workflow" (Figs. 1, 5-7; Tables 3-5. Sogge discloses that the approval system generates and displays a tree-like representation of the current state of a workflow, including the approval status of each individually identified approver. Fig. 1 illustrates icons displayed to the left of each approver's name indicating that approval is pending, granted, or rejected. Table 5 defines the Approver Approval Status enumeration, which includes "Waiting Response," indicating that a particular approver is currently responsible for acting on the document, i.e., currently approving. Figs. 5-6 disclose that the display workflow tracking information component iteratively displays the name and current approval status of each approver at each step, thereby displaying an indication of which drafter or approver is currently active in the workflow.).
Therefore, it would have been obvious to one of ordinary skill in the art prior to the filing date of the invention to combine these features of Sogge with those of Dutta. One would have been motivated to do this in order to provide users of a document workflow management system with real-time visibility into the current state of the approval process and to ensure that approval activity on a document is sought and permitted only in the predefined order of approval, thereby preventing premature action on a document before the requisite prior approvals have occurred and improving workflow transparency and efficiency.
Next, Dutta and Sogge do not appear to explicitly describe "the document in an area that has been separately allocated to the workflow and an organization to which a user is affiliated."
Lim, however, discloses "the document in an area that has been separately allocated to the workflow and an organization to which a user is affiliated" (Paragraphs 317-319. Lim discloses an information management system in which policies and documents are stored in a separately designated restricted folder, and access to that folder is limited to identified executives of a specific organization, with all other users explicitly denied access.);
Dutta and Sogge further fail to explicitly describe that "the processor is configured to" "issue, to the user, an identifier that only allows access to the area that has been separately allocated to the workflow and the organization to which the user is affiliated."
Lim, however, discloses that the processor is configured to "issue, to the user, an identifier that only allows access to the area that has been separately allocated to the workflow and the organization to which the user is affiliated" (Paragraphs 319-324. Lim discloses that the system associates specific user identifiers with executives of a defined organization, and those identifiers are the sole basis upon which access to the restricted folder containing the workflow documents is permitted, with access denied to all others.);
Therefore, it would have been obvious to one of ordinary skill in the art prior to the filing date of the invention to combine this feature of Lim with those of Dutta and Sogge. One would have been motivated to do this in order to protect and isolate workflow data and documents by restricting access exclusively to those users affiliated with the relevant organization and workflow, thereby preventing unauthorized access or interference during the document approval process.
Next, Dutta, Sogge, and Lim do not explicitly disclose "the identifier uniquely identifying a combination of the organization and the workflow."
Lowry, however, discloses "the identifier uniquely identifying a combination of the organization and the workflow" (Fig. 1; Paragraphs 138, 176-184. Lowry discloses that security is granted to each user via organization, project, and task, and that a user is allocated an organization ID under which security options are granted with access rights to that project and its associated tasks, thereby uniquely identifying a combination of the organization and the workflow for each user.).
Furthermore, Dutta, Sogge, and Lim do not explicitly disclose that the storage is configured to store "progress information of the workflow, which includes a workflow identification (ID), a time column indicating a time, a user ID, process information indicating a current process of the document in the workflow, and an interlock information indicating whether an operation on the document by a user was denied by interlock, stored in association with each other."
Lowry, however, discloses that the storage is configured to store "progress information of the workflow, which includes a workflow identification (ID), a time column indicating a time, a user ID, process information indicating a current process of the document in the workflow, and an interlock information indicating whether an operation on the document by a user was denied by interlock, stored in association with each other" (Figs. 1-2; Paragraphs 176-184, 195-201, and 207-212. Lowry discloses a workflow management system maintaining comprehensive task and workflow tracking information. The Task Item table (Fig. 1, element 11) stores a workflow identifier (Task Item ID, Project ID), time information (Created Date Time, Start Date Time, Due Date Time, Next Action Date Time), user identifier (Created By Usercode ID), and process information indicating the current state of the workflow task (Status, Current Task Data ID). Denial and failure information is tracked via the Error Status and Escalate Level fields, which record when operations are denied or have failed during the workflow. Paragraph 180 states that "each entry and action is recorded with time, date and personnel stamp along with a description of an action if it has taken place." All of this information is stored in association with each other as part of the workflow progress tracking.).
Finally, Dutta, Sogge, and Lim do not explicitly disclose "upon determining the operation is denied due to an interlock, change the progress information corresponding to the time, user ID and workflow ID to indicate the operation was denied by interlock and to indicate the specific operation that was denied."
Lowry, however, discloses "upon determining the operation is denied due to an interlock, change the progress information corresponding to the time, user ID and workflow ID to indicate the operation was denied by interlock and to indicate the specific operation that was denied" (Figs. 1-2; Paragraphs 180, 207, and 210-212. Lowry discloses that the system dynamically updates its workflow tracking records upon the occurrence of any entry or action. Paragraph 180 states that "each entry and action is recorded with time, date and personnel stamp along with a description of an action if it has taken place." The Task Response table (Fig. 1, element 13; Paragraphs 210-212) records, in association with the Task Item ID, Usercode ID, and Response Date Time, a Response Text and Audit Change Text documenting the specific action that was performed or attempted, including denied or failed operations. The Error Status and Escalate Level fields of the Task Item table (Paragraph 207) are further updated to reflect when a task operation has been denied or missed. Thus, when an operation is denied, Lowry updates the tracking information corresponding to the time, user ID, and workflow ID to indicate the denial and to indicate the specific operation that was denied.).
Therefore, it would have been obvious to one of ordinary skill in the art prior to the filing date of the invention to combine this feature of Lowry with those of Dutta, Sogge, and Lim. One would have been motivated to do this in order to readily identify users permitted to work on a particular document on behalf of an organization, and to maintain a comprehensive and auditable record of all workflow operations, including denied operations, for purposes of accountability, compliance, and workflow oversight.
Claim 2: The Dutta/Sogge/Lim/Lowry combination discloses those limitations cited above. Lim, however, further discloses a device "wherein the interlock information sets whether an operation is to be denied due to an interlock according to a type of operation and a user" (Paragraphs 18, 20, and 319-324. Lim discloses that the system's policies set rules specifying which identified users are permitted to perform which specific operation types on which specific documents, with all other users and operation types denied.).
The rationale for combining Dutta, Sogge, Lim, and Lowry is articulated above and reincorporated herein by reference.
Claim 4: The Dutta/Sogge/Lim/Lowry combination discloses those limitations cited above. Dutta, however, further discloses a device "wherein the interlock information sets viewing or revising of the document as an operation that is to be denied with an interlock" (Col. 3, Lines 36-43; Col. 7, Lines 1-13. Dutta discloses that the security controls define the specific types of actions users may take with respect to a document. Users other than the document owner are denied the ability to view the checked-out working copy during the Create state, and users assigned the reviewer or approver roles are denied the ability to perform check-out operations for revision during stages of the workflow in which those roles have not been granted such privileges.).
The rationale for combining Dutta, Sogge, Lim, and Lowry is articulated above and reincorporated herein by reference.
Claim 5: The Dutta/Sogge/Lim/Lowry combination discloses those limitations cited above. Lim, however, further discloses a device "wherein, upon determining when the operation is denied due to an interlock, the processor is configured to display information that the operation has been denied due to an interlock to a user who has requested the operation" (Paragraph 252. Lim discloses that if a document access request is denied, an error message is displayed on the Web browser of the user who requested the operation.).
The rationale for combining Dutta, Sogge, Lim, and Lowry is articulated above and reincorporated herein by reference.
Other Relevant Prior Art
Though not cited in the above rejections, the following references are likewise
deemed to be relevant to Applicant’s disclosures:
• Alabdrabalnabi et al. (20210406831), directed to a system for managing approval workflow processes in a network system.
• River et al. (20210264367), directed to a workflow processing method using
unique identifiers.
• Brunswick et al. (20160104092), directed to a method for managing business
award workflow.
• Sudo et al. (CN 119647926), directed to a workflow management apparatus and method.
• Iwakiri et al. (JP 2013200753), directed to a workflow management method.
Response to Arguments
Applicant's arguments filed June 5, 2026 have been fully considered.
Regarding the rejection of the claims under 35 U.S.C. § 101, Applicant argues that claims 1 and 6, when considered as a whole, set forth a technical improvement to workflow management of a document among multiple users by automatically employing and managing an interlock of the document, citing MPEP § 2106.05(a) II and Rapid Litigation Management v. CellzDirect, Inc., 827 F.3d 1042, 119 USPQ2d 1370 (Fed. Cir. 2016) for the proposition that improvements are relevant to eligibility regardless of the technology of the claimed invention. Applicant further argues that the newly added limitation, under which the interlock for a first approver is based on whether one or more second approvers have approved the document, is an automatic process that does not relate to a method of organizing human activity and cannot be practically performed in the human mind. Applicant also cites MPEP § 2106.04(d) and Finjan, Inc. v. Blue Coat Sys., Inc., 879 F.3d 1299, 125 USPQ2d 1282 (Fed. Cir. 2018) for the proposition that an improvement can be provided by the additional elements in combination with the recited judicial exception. On that basis, Applicant contends the claims must be analyzed as a whole. Applicant additionally points to the automatic updating and display of the current status of each drafter and approver as part of the asserted improvement. These arguments are not persuasive.
First, Applicant's asserted improvement remains an improvement to the document approval process itself, not to the functioning of a computer or to any other technology or technical field. The relevant inquiry under MPEP § 2106.05(a) is whether the claim improves the computer or another technology, and the specification frames the problem being solved in purely organizational terms: without an interlock mechanism, a person who is not expected to view or revise a document will be able to do so before a final decision is reached and, as a result, work may stagnate or an accident may occur. See Paragraphs 0003-0004 of the pre-grant publication. Preventing the wrong person from acting on a document at the wrong point in an approval chain is a longstanding concern of business management, and resolving it by rule does not improve the storage, the processor, the display, or any other technical component, each of which performs only its conventional function. CellzDirect does not compel a different conclusion; the claims there recited a concrete laboratory technique effecting a physical transformation of biological material, whereas the present claims automate an organizational gatekeeping practice on generic computer hardware.
Second, the newly added limitation does not remove the claims from the recited groupings of abstract ideas. The rule that a first approver's operation on a document is allowed based on whether one or more second approvers has approved that document is an approval-sequencing rule, precisely the kind of rule long applied in paper-based approval chains, in which a file is withheld from a subsequent approver until the requisite prior signature has been obtained. The limitation therefore further defines the abstract workflow management scheme rather than adding a technical element to it. See MPEP § 2106.04(a)(2)(II) (managing personal behavior or relationships or interactions between people, and business relations, as certain methods of organizing human activity). Moreover, whether the claimed process can be practically performed in the human mind is the test for the mental processes grouping, not for methods of organizing human activity; the claims remain directed to the latter grouping regardless, and automating a manual organizational process on a computer does not confer eligibility. See Bancorp Servs., L.L.C. v. Sun Life Assurance Co. of Canada, 687 F.3d 1266, 1278, 103 USPQ2d 1425, 1433 (Fed. Cir. 2012).
Third, analyzing the claims as a whole under MPEP § 2106.04(d), including the additional elements in combination with the recited judicial exception, does not yield a technical improvement. The additional elements are the receipt of the workflow and interlock information, the receipt of the operation, the storage of the information and the document, the display of the workflow information and denial notification, and the generic storage, processor, and display on which the scheme runs. In combination with the recited sequencing and recordkeeping rules, these elements do no more than implement the abstract workflow management scheme in a generic computing environment; the ordered combination adds nothing beyond the elements considered individually. Finjan is inapposite: the claims there were directed to a virus-scanning method that generated a new kind of file enabling a computer to do things it could not do before, an improvement in computer functionality itself. Here, no limitation causes the computer to function differently or more effectively; the computer is used as a tool to enforce approval-sequencing rules. See Alice Corp., 573 U.S. at 223.
Fourth, regarding the automatic updating and display of the current status of each drafter and approver, presenting the results of the abstract workflow management process on a display is paradigmatic extra-solution activity that does not integrate the abstract idea into a practical application, and the use of a visual indicator to denote a currently active drafter or approver is a display formatting choice. See OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1092-93 (Fed. Cir. 2015); MPEP § 2106.05(g).
Accordingly, Applicant's arguments have been fully considered but are not persuasive. The rejection of claims 1, 2, and 4-6 under 35 U.S.C. § 101 is therefore maintained.
Next, Applicant's arguments with respect to the rejections of claims 1-6 under 35 U.S.C. § 103 have been fully considered but are not persuasive.
Applicant argues that Lim does not disclose that the interlock for one approver (e.g., a first approver) for an operation on a document in a workflow is based on whether one or more other approvers (e.g., second approvers) have approved the document, as now recited in claims 1 and 6. Applicant is correct that Lim is not relied upon for this limitation, and Lim's paragraph 0373, which discloses a contextual time period during which a policy is in effect, is not applied to it. However, Sogge, of record and applied in the rejection above, discloses the newly added limitation. As set forth in the rejection of claims 1 and 6, Sogge discloses a workflow definition that sets in advance that a second step is dependent upon a first step, such that the approval of the first step is needed before approval of the second step may be requested, and the approval system will seek approval based on the budgeting step and the accounts receivable step only after the accounting step results in an approval. See Sogge, Col. 4, Lines 26-34 and 61-63; Figs. 1-2; Tables 2 and 4. A first approver at a dependent step is thus permitted to act on the document based on whether a second approver at the preceding step has approved the document, with the dependency set in advance via the NextSteps element of the TrackingStep data structure. Applicant's argument, which is directed to Lim alone, does not address the rejection as now articulated over the combination and is therefore not persuasive. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981) (one cannot show non-obviousness by attacking references individually where the rejections are based on combinations of references).
Regarding the dependent claims, Applicant relies solely on their dependency from the independent claims and identifies no separate distinguishing feature; these claims stand rejected for the reasons set forth above.
Accordingly, Applicant's arguments have been fully considered but are not persuasive. The rejection of claims 1, 2, and 4-6 under 35 U.S.C. § 103 is therefore maintained.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTOPHER BUSCH whose telephone number is (571)270-7953. The examiner can normally be reached M-F 10-7.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Waseem Ashraf can be reached at 571-270-3948. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/CHRISTOPHER C BUSCH/Examiner, Art Unit 3621
/WASEEM ASHRAF/Supervisory Patent Examiner, Art Unit 3621
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