DETAILED ACTION
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3/6/26 has been entered.
Status of the Claims
This office action is submitted in response to the RCE filed on 3/6/26.
Examiner notes that this application claims foreign priority to 2023-149759 (Japan), which was filed on 9/15/23.
Claims 1 and 6 have been amended.
Therefore, claims 1-6 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 1-6 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.
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 is directed to a machine. Claim 6 recites a "workflow management method" comprising a series of steps, and thus is directed to a process. As such, the claims are directed to statutory categories.
Next, independent claims 1 and 6, in part, describe an invention comprising: updating workflow information to indicate a status of each drafter and/or approver of a respective workflow; determining whether a received operation on a document is allowed or denied; 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; granting and/or denying access to documents based on the identifier and the interlock information; and upon determining an operation is denied, updating the progress information to record the denial along with the corresponding time, user ID, workflow ID, and 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. 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 and interlock information; receiving an operation on a document while the workflow is in progress; storing the workflow information, interlock information, progress information, and the document in a separately allocated area. Dependent claim 5 further discloses displaying information to a user if the operation is denied. 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 and executable instructions; and a "processor" for executing the process. These limitations are recited at a high level of generality, and appear to be nothing more than generic computer components. 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., 134 S. Ct. at 2358, 110 USPQ2d at 1983. See also 134 S. Ct. at 2389, 110 USPQ2d at 1984.
Furthermore, looking at the elements individually and in combination, under Step 2A, Prong Two, 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(s), 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).
Next, under Step 2B, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements, when considered both individually and as an ordered combination, do not amount to significantly more than the abstract idea. Furthermore, looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. Simply put, as noted above, 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, the following citations are provided to demonstrate that the additional elements, identified as extra-solution activity, amount to activities that 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 (the abstract idea), and are ineligible under 35 USC 101.
Claims 2-4 are dependent on the aforementioned independent claims, and include all the limitations contained therein. These dependent claims do not recite any additional technical elements, and simply disclose additional limitations that further limit the abstract idea with details regarding what the interlock information defines and describes.
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 — operation type and user identity — for determining when to deny access, which is further detail regarding how the abstract workflow management rules are configured. This does not integrate the abstract idea into a practical application or add significantly more, as it remains part of the same business practice of managing document access through configurable rules. Claim 3 recites "wherein the interlock information sets whether an operation is to be denied due to an interlock according to a time period." This limitation adds a temporal criterion to the access control rules, specifying that denials may be based on time periods. This is simply another parameter for implementing the abstract workflow management idea and does not transform the claim into patent-eligible subject matter. Time-based access controls are conventional in access management systems. 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 — viewing and revising — that may be subject to denial. This merely provides examples of the operations that may be controlled by the workflow management system and does not add any inventive concept or technical improvement. Claim 5 is dependent on claim 4 and recites "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." This limitation adds a notification step that informs a user when their requested operation has been denied. As noted above, this is insignificant post-solution activity that merely outputs the result of the abstract workflow management determination to the user. Displaying error messages or denial notifications to users is well-understood, routine, and conventional activity in computer systems. 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(s). The dependent claims continue to be directed to the same abstract idea of managing document workflows through configurable access control rules, implemented using generic computer components.
Therefore, claims 1-6 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 1-6 are rejected under 35 U.S.C. § 103 as being unpatentable over Dutta (7,035,910B1) in view of Sogge et al. (8,151,208B2), and in further view of Lim (20080091682A1), and in further view of 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, the workflow information being information on a workflow of a document from drafting to approval, 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" 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 TrackingStep data structure as comprising an ApprovalStatus, an Approvers array containing individually identified TrackingApprovers, a StepName, TimeTracking, and NextSteps, establishing a formally ordered list of approvers across sequential workflow steps.).
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 ApproverApprovalStatus 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 this feature 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, allowing participants to readily identify which drafter or approver is currently responsible for action on a document, thereby 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 interlock 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 interlock 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 3: 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 time period" (Paragraph 373. Lim discloses that a policy has a contextual component that includes a time period during which the policy goes into effect or is no longer active, such that whether a user is permitted to perform an operation may be determined based on the applicable time period.).
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 regarding the sufficiency of the claims under 35 USC 101 are unpersuasive. Applicant argues that claims 1 and 6 are directed to a technical improvement to workflow management by "automatically employing and managing an interlock of the document," and that this constitutes integration of the abstract idea into a practical application under Step 2A, Prong Two. Applicant further argues that the claims recite computer-implemented technical processes that cannot be implemented by a human mind, and that the amended display limitation — showing the current status of each drafter and approver — represents a feedback element that goes beyond mere organization of human activity. These arguments are not persuasive for the following reasons.
First, Applicant's characterization of the claims as directed to a "technical improvement" conflates an improvement to a business process with an improvement to computer technology. The relevant inquiry under MPEP § 2106.05(a) is whether the claims improve the functioning of the computer itself or improve another technology or technical field — not whether they improve the efficiency of a human administrative process. The interlock mechanism, the ordered approval workflow, the denial logging, and the display of current approver status are all improvements to the document approval process, which is an organizational and managerial activity. None of these limitations improve the operation of the computer, the storage architecture, the processor, or any other technical component. The storage and processor recited in the claims perform only their conventional functions. See Alice Corp., 573 U.S. at 223; see also Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1370, 115 USPQ2d 1636, 1641 (Fed. Cir. 2015) (finding claims directed to tailoring information based on user characteristics ineligible where the claims did not improve computer functionality).
Second, Applicant's argument that the claims "cannot be implemented by a human mind" is not the applicable test at Step 2A, Prong Two. The question is not whether a human could practically perform the claimed steps, but whether the claims integrate the judicial exception into a practical application by, for example, improving a computer or technical field, effecting a transformation of a physical article, or applying the exception with a particular machine in a way that imposes a meaningful limit on the claim scope. See MPEP §§ 2106.05(a)-(g). Speed and automation achieved by implementing an abstract idea on a computer do not constitute integration into a practical application. 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, regarding the amended display limitation — displaying an indication that a particular drafter or approver is currently drafting or approving a document — this is generic computer output presenting the results of the abstract workflow management process to a user. Presenting results of an abstract process on a display is paradigmatic extra-solution activity that does not integrate the abstract idea into a practical application. 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). The use of a visual indicator such as a thick-line border to denote a currently active approver is a display formatting choice that does not transform the underlying abstract workflow management process into patent-eligible subject matter.
Fourth, Applicant cites Rapid Litigation Management v. CellzDirect for the proposition that technical improvements are eligible regardless of the technology. However, CellzDirect involved a concrete, non-obvious improvement to a laboratory technique for preserving hepatocytes — a physical transformation of biological material. The present claims involve no analogous physical or technical transformation. Managing document access, logging denial events, and displaying approval status on a screen are implementations of conventional human organizational and managerial activity on generic computer hardware.
Fifth, Applicant argues that this is not a case like Alice where the computer is "merely used as a tool." The examiner respectfully disagrees. Every limitation of claims 1 and 6 either recites a step in the abstract workflow management process itself, or recites a generic computer component performing its routine function: storing data, processing rules, issuing identifiers, updating records, and displaying output. No limitation specifies a particular technical implementation that improves upon conventional computer architecture or operation. The claims are precisely the type that Alice identifies as using a computer as a tool to implement an abstract idea. Alice Corp., 573 U.S. at 222-23.
Accordingly, the §101 rejection of claims 1-6 is maintained.
Next, Applicant's arguments regarding the sufficiency of the claims under 103 have been considered but are unpersuasive.
Regarding "plurality of approvers listed in order of approval" and "displaying an indication that a particular drafter and/or approver is currently drafting or approving": Applicant argues that neither Dutta nor Lowry discloses workflow information comprising a drafter and a plurality of approvers listed in order of approval, and that Dutta does not disclose displaying an indication of which drafter or approver is currently active on a document. These arguments are not persuasive because the rejection has been supplemented with Sogge et al, which explicitly and directly discloses both limitations.
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 claimed drafter — and multiple sequential approval steps, each step comprising one or more individually identified approvers in a defined order of approval. Fig. 1 of Sogge illustrates a tracking tree showing originator John Smith, followed by an ordered sequence of named approvers (Mike Jones, James Lee, Ted Brown) at successive steps. Table 2 of Sogge defines the TrackingStep data structure as comprising an ApprovalStatus, an Approvers array, a StepName, and NextSteps, establishing a formally ordered list of approvers across sequential workflow steps. Sogge further discloses that the system generates and displays a tree-like representation of the current state of the workflow, with icons displayed beside each approver's name indicating their current approval status — including a "Waiting Response" status (Table 5) indicating that a particular approver is currently responsible for acting on the document, i.e., currently approving. Applicant's argument that the prior art does not teach these limitations is therefore not persuasive in view of the Sogge reference now of record.
Regarding "change the progress information... to indicate the operation was denied by interlock and to indicate the specific operation that was denied": Applicant argues that Lowry does not disclose 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. This argument is not persuasive.
Notably, Applicant has amended the final limitation of claim 1 to recite "change the interlock progress information" and amended claim 6 to recite "change the progress information" — replacing the prior claim language that referred solely to "interlock information." This amendment actually strengthens, rather than overcomes, the Lowry mapping. Lowry's system is explicitly a progress tracking system: the Task Item table (Fig. 1, element 11) and Task Response table (Fig. 1, element 13) are the core progress records of Lowry's workflow, storing workflow IDs, timestamps, user IDs, current process status, error status, and response text documenting the specific action performed or attempted. Paragraph 180 of Lowry 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" — directly mapping to the requirement to update the progress information with the time, user ID, workflow ID, and specific operation that was denied. The Task Response table's Response Text and Audit Change Text fields (Paragraphs 210-212) record the specific action performed, and the Error Status and Escalate Level fields (Paragraph 207) record denial and failure events. Applicant's amendment to substitute "progress information" for "interlock information" does not distinguish over Lowry; it more directly reads on what Lowry already teaches.
Furthermore, Applicant's quotation of Lowry paragraphs 210-212 in support of their argument actually confirms Lowry's relevance — those paragraphs describe the Task Response table recording task-specific response data including the specific action taken, associated with a Task Item ID, Usercode ID, and Response Date Time. This is precisely the association of workflow ID, user ID, time, and specific operation that the amended claim requires.
Accordingly, the §103 rejection of claims 1-6 is maintained as to the Dutta/Sogge/Lim/Lowry combination.
Conclusion
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.
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/CHRISTOPHER C BUSCH/Examiner, Art Unit 3621
/WASEEM ASHRAF/Supervisory Patent Examiner, Art Unit 3621
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