DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of the Application
This is a Final-Action in response to the claims submitted on 03/02/2026.
Claims 1-2, 4, and 12-18 are examined herein.
Claim Objections
Claims 1 and 18 are objected to because of the following informalities: the claims read “inserting corresponding data of the information inputs into the document based on aa plurality of variables in the template” wherein it should read “inserting corresponding data of the information inputs into the document based on a plurality of variables in the template”. Appropriate correction is required.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-2, 4, and 12-18 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
Claims 1, 2 and 18 disclose the limitation “wherein the display representations relate to gathering information inputs from the user an estate plan for the estate”. The claim appears to have a typographical error making the scope of the claim unclear. It is unclear if the limitation should read “wherein the display representations relate to gathering information inputs from the user and an estate plan for the estate”, “wherein the display representations relate to gathering information inputs from the user related to an estate plan for the estate”, “wherein the display representations relate to gathering information inputs from the user or an estate plan for the estate” among other options. For examination purposes the claim is interpreted as “wherein the display representations relate to gathering information inputs from the user related to an estate plan for the estate”.
Claims 1, 2 and 18 disclose “repeatedly inserting the corresponding data into the document based on at least one of the variables includes a repeatable variable being a repeatable variable”. The claim appears to have a typographical error making the scope of the claim unclear. For examination purposes the claim is interpreted as “repeatedly inserting the corresponding data into the document based on at least one of the variables including a repeatable variable”
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, 4, and 12-18 are rejected under 35 U.S.C. 101 because the claims are directed to an abstract idea without significantly more.
With respect to Step 1 of the eligibility inquiry (as explained in MPEP 2106), it is first noted that the claims are directed to at least one potentially eligible category of subject matter (i.e., process and machine, respectively). Thus, Step 1 of the Subject Matter Eligibility test for claims 1-20 is satisfied.
With respect to Step 2A Prong One, it is next noted that the claims recite an abstract idea that falls under the “Certain Methods Of Organizing Human Activity” group within the enumerated groupings of abstract ideas set forth in the MPEP 2106 since the claims set forth steps that recite commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations).
Claims 1, 2 and 18 recites the abstract idea of soliciting and obtaining contributions for philanthropic organizations [See Background of the invention] and generate an estate planning document. Taking claim 18 as a representative claim, the abstract idea is described as:
(a ) receiving data for philanthropic information related to one or more philanthropic entities, the philanthropic information based on Judeo-Christian beliefs or values including directives for stewardship of the Bible for data storage and data retrieval;
(b) providing corresponding instances of the service of a plurality of users for making contribution to at least one of the philanthropic entities through an estate of the user, wherein electronic access to the instances originates from the at least one philanthropic entity;
(c) iteratively determining and processing a next selection of a plurality of sequential display representations and a display for iteratively displaying the next selection, wherein the iteratively determining the next selection is responsive to one or more concurrent interactions of each user of the users with each corresponding instance of the instances through each corresponding device of the corresponding devices, wherein the display representations relate to gathering information inputs from the user an estate plan for the estate, wherein the iteratively determining and processing comprises determining a pending one of the display representations to be selected as the next selection and determining a second pending one of the display representations to not be selected as the next selection, based on the information inputs as a concurrent interaction of the concurrent interactions for a current display representation of the display representations that includes an indication of a progress in the iteratively displaying the next selection resulting in a sequentially displaying of the display representations, and wherein the iteratively determining and processing further comprises performing each of the following
validating fields for the gathering of the information inputs;
detecting an interruption of the progress and storing the information inputs for availability to continue the progress at a next session of the access;
grouping at least two of the information inputs as a grouped information inputs and storing the grouped information inputs in a first data structure;
grouping at least two other of the information inputs as other grouped information inputs and storing the other grouped information inputs in the first data structure;
referring each grouped information inputs in the first data structure by a corresponding reference in a second data structure;
recalling the grouped information input stored in the first data structure at a different iteration of the iteratively determining and processing from a current iteration of the iteratively determining and processing through the corresponding reference in the second data structure; and
searching the first data structure for a related information input to a partial user input for at least one of the information inputs when the user stops inputting the partial user input after a time delay; and
(d) generating an estate planning document based on a pre- determined document generation template, wherein the generating comprises inserting corresponding data of the information inputs into the document based on aa plurality of variables in the template, wherein the generating further comprises modifying a formatting of at least one of the corresponding data based on at least one formatting keyword in the template, wherein the generating further comprises repeatedly inserting the corresponding data into the document based on at least one of the variables includes a repeatable variable being a repeatable variable, wherein the repeatedly inserting includes inserting the corresponding data differently for a first time, one or more middle times, and a last time differently in the document, wherein the repeatedly inserting includes inserting the corresponding data in the document multiple times with a delimiter in between, and wherein the generating further comprises inserting a gender specific one of the corresponding data in the document based on at least one of the variable being a gender based variable.
This idea falls within the certain methods of organizing human activity grouping of abstract ideas because it is directed towards commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations). The noted abstract idea is also directed to managing interactions between people such as that required during communications when soliciting and obtaining contributions for philanthropic organizations conforms to the requirements of more than one party.
Claims 1 and 18 disclose similar limitations describing the same abstract idea.
Because the above-noted limitations recite steps falling within the Certain Methods Of Organizing Human Activity abstract idea groupings of the MPEP 2106, they have been determined to recite at least one abstract idea when evaluated under Step 2A Prong One of the eligibility inquiry.
Therefore, because the limitations above set forth activities falling within the Certain Methods Of Organizing Human Activity abstract idea groupings described in the MPEP 2106, the additional elements recited in the claims are further evaluated, individually and in combination, under Step 2A Prong Two and Step 2B below.
With respect to Step 2A Prong Two, the judicial exception is not integrated into a practical application. The additional elements that fail to integrate the abstract idea into a practical application are:
an electronic communication network;
a communication network;
a network receiver;
a network transmitter;
a processor;
a platform;
a device of a user;
a memory of the device;
a document generator;
sequentially displaying representations on the device of a user;
However, using a computer environment such as an electronic communication network, a user device and other recited computer elements amounts to no more than generally linking the use of the abstract idea to a particular technological environment. Soliciting and obtaining contributions for philanthropic organizations and generate an estate planning document can reasonably be performed by pencil and paper until limited to a computerized environment by requiring an electronic communication network and a user device to perform the steps.
These additional elements have been evaluated, but fail to integrate the abstract idea into a practical application because they amount to using generic computing elements or computer-executable instructions (software) to perform the abstract idea, similar to adding the words “apply it” (or an equivalent), and alternatively serve to link the use of the judicial exception to a particular technological environment. See MPEP 2106.05(f) and 2106.05(h).
In addition, these limitations fail to provide an improvement to the functioning of a computer or to any other technology or technical field, fail to apply the exception with a particular machine, fail to apply the judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, fail to effect a transformation of a particular article to a different state or thing, and fail to apply/use the abstract idea in a meaningful way beyond generally linking the use of the judicial exception to a particular technological environment.
Accordingly, because the Step 2A Prong One and Prong Two analysis resulted in the conclusion that the claims are directed to an abstract idea, additional analysis under Step 2B of the eligibility inquiry must be conducted in order to determine whether any claim element or combination of elements amount to significantly more than the judicial exception.
With respect to Step 2B of the eligibility inquiry, it has been determined that the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
As noted above, the claims as a whole merely describes a method, computer system, and computer program product that generally “apply” the concepts discussed in prong 1 above. (See MPEP 2106.05 f (II)) In particular applicant has recited the computing components at a high-level of generality such that it amounts to no more than mere instructions to apply the exception using generic computer components. As the court stated in TLI Communications v. LLC v. AV Automotive LLC, 823 F.3d 607, 613 (Fed. Cir. 2016) merely invoking generic computing components or machinery that perform their functions in their ordinary capacity to facilitate the abstract idea are mere instructions to implement the abstract idea within a computing environment and does not add significantly more to the abstract idea. Accordingly, these additional computer components do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Therefore, even when viewed as a whole, nothing in the claim adds significantly more (i.e. an inventive concept) to the abstract idea and as a result the claim is not patent eligible.
In addition, when taken as an ordered combination, the ordered combination adds nothing that is not already present as when the elements are taken individually. There is no indication that the combination of elements integrates the abstract idea into a practical application. Their collective functions merely provide generic computer implementation. Therefore, when viewed as a whole, these additional claim elements do not provide meaningful limitations to transform the abstract idea into a practical application of the abstract idea or that, as an ordered combination, amount to significantly more than the abstract idea itself.
For the reasons identified with respect to Step 2A, prong 2, claims 1, 2 and 18 fail to recite additional elements that amount to an inventive concept. For example, use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general-purpose computer or computer components after the fact to an abstract idea (e.g., a commercial or legal interaction or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more (see MPEP 2106.05(g)). In addition, limitations that amount to merely indicating a field of use or technological environment in which to apply a judicial exception do not amount to significantly more than the exception itself, and cannot integrate a judicial exception into a practical application (see MPEP 2106.05(h)).
Dependent claims 4, and 12-17 recite the same abstract idea as recited in the independent claims, and when evaluated under Step 2A Prong One are found to merely recite details that serve to narrow the same abstract idea recited in the independent claims accompanied by the same generic computing elements or software as those addressed above in the discussion of the independent claims, which is not sufficient to amount to a practical application or add significantly more, or other additional elements that fail to amount to a practical application or add significantly more, as noted above.
Dependent claim 4 further limits the abstract idea by linking the judicial exception to a particular field of use by introducing a limitation related to displaying data based on a user selection. Further embellishing that the invention is capable of displaying information in a generic computing environment does not integrate the abstract idea into a practical application or adds significantly more to the abstract idea. Therefore the claims are also non-statutory subject matter.
Dependent claims 12-14 further limits the abstract idea by introducing the limitation wherein the template includes a plurality of variables for inserting corresponding data of the information inputs into the document, wherein the template includes at least one formatting keyword for modifying a formatting of at least one of the corresponding data, wherein at least one of the variables includes a repeatable variable for repeatedly inserting the corresponding data into the document. The examiner views these additional elements as results-oriented steps given that there is no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result are currently present such that this is viewed as equivalent to “apply it” for merely implementing the abstract idea using generic computing components (See Id.). Therefore the claims are also non-statutory subject matter.
Dependent claims 15-17 further limits the abstract idea by linking the judicial exception to a particular field of use by introducing the limitation wherein the repeatedly inserting includes inserting the corresponding data differently for a first time, one or more middle times, and a last time differently in the document, wherein the repeatedly inserting includes inserting the corresponding data in the document multiple times with a delimiter in between, wherein at least one of the variable includes a gender based variable for inserting a gender specific one of the corresponding data in the document. Inserting data in a document is a process that could be performed manually until limited by a computer environment. Further embellishing that the invention is capable of processing information in a generic computing environment does not integrate the abstract idea into a practical application or adds significantly more to the abstract idea. Therefore the claims are also non-statutory subject matter. Furthermore, the examiner views these additional elements as results-oriented steps given that there is no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result are currently present such that this is viewed as equivalent to “apply it” for merely implementing the abstract idea using generic computing components (See Id.). Therefore the claims are also non-statutory subject matter.
The ordered combination of elements in the dependent claims (including the limitations inherited from the parent claim(s)) add nothing that is not already present as when the elements are taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology, and the collective functions merely provide high level of generality computer implementation. Therefore, whether taken individually or as an order combination, the claims are nonetheless rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
For more information see MPEP 2106.
Response to Arguments
Applicant's arguments filed 03/02/2026 have been fully considered.
With regards to the previously presented 35 USC 101, Applicant argues:
“Indeed, while some cited portions of the claim appear to relate to an abstract idea, e.g., "philanthropic information related to one or more philanthropic entities, the philanthropic information based on Judeo-Christian beliefs or values including directives for stewardship of the Bible", other cited portions do not related to nor support a finding for an abstract idea, e.g., "an indication of a progress grouping, referring, and recalling "grouped information inputs", and generating document "based on pre-determined document generation template" that includes "modifying a formatting", "repeatedly inserting" various data depending on their attributes, etc. These limitations do not "describe" nor relate to any abstract idea, let alone the abstract idea of "soliciting and obtaining contributions for philanthropic organizations" with respect to Step 2A.” Examiner respectfully disagrees. As presented in the current 35 USC 101 rejection above, these limitations are considered as abstract processes that could potentially be performed manually until limited by a computer environment when requiring the use of a network and other computer elements, wherein such computer elements are mere instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea - see MPEP 2106.05(f).
“For example, the limitations of step (c) provide an iterative step to select to display (and to not select to display) based on the inputs of the user, with an updated indication progress shown to the user based on the selected displays. Step (c) further provides user input validation and progress interruption detection and restoration. These features are improvements to the graphical user interface (GUI) that are recognized improvements to the function of a computer under MPEP § 2106.05(a).” Examiner respectfully disagrees. The current limitations are not directed to any of the examples that the courts have indicated may show an improvement in computer-functionality, on the contrary the claimed limitations are directed to mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential) and Providing historical usage information to users while they are inputting data, in order to improve the quality and organization of information added to a database, because "an improvement to the information stored by a database is not equivalent to an improvement in the database’s functionality," BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287-88, 127 USPQ2d 1688, 1693-94 (Fed. Cir. 2018).
Applicant further argues that the claimed limitations provide improvement on the technology , however failed to provide an articulated reasoning or indicates where in the specification, it is shown that the argued limitations provide an improvement to the technology. Examiner asserts that the claimed invention is merely using the technology as a tool to automate a manual process in order to provide the users the benefits that generic automation of a process provides, thereby providing business solutions rather than technological improvements.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Baker, US 2008/0033855, Method and apparatus for facilitating charitable donations. A method for placing an automated donation station, comprising the steps of receiving a request for an automated donation station at a particular location.
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 MARIA C SANTOS-DIAZ whose telephone number is (571)272-6532. The examiner can normally be reached Monday-Friday 8:00AM-5:00PM.
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, Sarah Monfeldt can be reached at 571-270-1833. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/MARIA C SANTOS-DIAZ/Primary Examiner, Art Unit 3629
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