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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 4/20/2026 has been entered.
In response to Final Communications received 1/20/2026, Applicant, on 4/20/2026, amended Claims 1-2, 5-6, 10-12, 14-15, and 19-20, and cancelled Claims 3 and 21. Claims 1-2, 4-8, 10-17, 19-20, and 22 are considered in this application, and have been rejected below.
Response to Arguments
Arguments regarding 35 USC §112(a) – The rejection is hereby removed in light of Applicant’s amendments to the Claims.
Arguments regarding 35 USC §101 Alice – Applicant asserts that the claims are not directed at a judicial exception by stating the amended limitations of the claims, and stating the steps involve manipulating a specific computer data structure by adding nodes, interacting with specific GUI input controls, and creating a workflow which require a GUI. Examiner disagrees as the claims recite limitations which describe abstract processes of both a “Mental Process” and a “Certain Method of Organizing Human Activity”, as the claims recite limitations for the purposes of workflow creation, which is Managing Human Activity. There is no improvement to a technology or any technological process, as any inventive concept as well as the amendments would be contained wholly within the abstraction, nor is there any improvement to the any additional element, as per Applicant’s Specification shown in the rejection below, nor is there any controlling of another system such as the text processing, or any improvement to any other additional element within the claim alone or in combination. This is “Applying It”, similar to Alice, on a generic computing system.
Applicant asserts that the claims are integrated into a practical application by stating there is a specific improvement to workflow development technology, there is a transformation and configuration of a processing entity, and there is a specific technical implementation which when taken as a whole are similar to that of Enfish and Core Wireless. Examiner disagrees as the cases of Enfish and Core Wireless have different fact patterns that the current case. There claims aren’t integrated as the Claims merely utilize current technologies such as a computer, medium, etc., to perform the abstract limitations of the Claims, with two identified abstract ideas, as per the rejection below. The claims recite limitations which describe abstract processes of both a “Mental Process” and a “Certain Method of Organizing Human Activity”, as the claims recite limitations for the purposes of workflow creation, which is Managing Human Activity. Again, there is no improvement to a technology or any technological process, as any inventive concept as well as the amendments would be contained wholly within the abstraction, nor is there any improvement to the any additional element, as per Applicant’s Specification shown in the rejection below, nor is there any controlling of another system such as the text processing, or any improvement to any other additional element within the claim alone or in combination. This is “Applying It”, similar to Alice, on a generic computing system.
Applicant recites Berkheimer and states that the Office Action has cited no evidence that the specific ordered combination of claim elements, such as the newly incorporated feature of presenting candidate types in a first input control and determine a processing type based on a user selection, is routine and convention. Examiner disagrees as the Action has not stated that anything is well-understood, routine, and conventional, but even if the Action had, Applicant’s own specification was used as evidence as in the rejection below, and Applicant has stated what evidence in the specification would prove this. So the Action has stated the Specification, and Applicant generally asserts that because the claims are allowable over the prior art, they must be non-conventional, a mere allegation of eligibility under 101. Again, there is no improvement to a technology or any technological process, as any inventive concept as well as the amendments would be contained wholly within the abstraction, nor is there any improvement to the any additional element, as per Applicant’s Specification shown in the rejection below, nor is there any controlling of another system such as the text processing, or any improvement to any other additional element within the claim alone or in combination. This is “Applying It”, similar to Alice, on a generic computing system. There is no inventive concept.
Therefore, the arguments are non-persuasive, the Claims are ineligible as there is no inventive concept, and the rejection of the Claims and their dependents are maintained under 35 USC 101.
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.
Alice – Claims 1-2, 4-8, 10-17, 19-20, and 22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claims 1, 10, and 19 directed to the limitations for, in response to a received editing operation, adding a first node corresponding to a text processing node to a node connection graph (Collecting and Analyzing Information, an observation and evaluation, a Mental Process; Managing Human Beings, i.e. Managing a Workflow; a Certain Method of Organizing Human Activity), obtaining configuration information for the first node via a set of input controls associated with the first node, the configuration information indicating a text processing process corresponding to the first node, wherein obtaining the configuration information comprises: presenting, in a first input control of the set of input controls, a set of candidate types, and determining, based on a selection of a type in the set of candidate types, a processing type of the text processing process corresponding to the first nod (Receiving and Analyzing Information, an observation and evaluation, a Mental Process; Managing Human Beings, i.e. Managing a Workflow; a Certain Method of Organizing Human Activity), creating a workflow based on the node connection graph, wherein in response to the workflow being applied to a processing entity, the processing entity is configured to process an input request according to a processing flow indicated by the workflow (Analyzing and Receiving Information, an observation and evaluation, a Mental Process; Managing Human Beings, i.e. Managing a Workflow; a Certain Method of Organizing Human Activity), and connecting, in the node connection graph, an output of the first node to an input of a third node to indicate that an output result of the text processing process of the first node is provided as an input of the third node (Analyzing and Transmitting the Information, an evaluation and judgment, a Mental Process; Managing Human Beings, i.e. Managing a Workflow; a Certain Method of Organizing Human Activity), which under their broadest reasonable interpretation, covers performance of the limitation in the mind for the purposes of creating a workflow, a Certain Method of Organizing Human Activity, but for the recitation of generic computer components. That is, other than reciting an electronic device, processing unit, memory, and computer-readable medium, nothing in the claim element precludes the step from practically being performed or read into the mind for the purposes of Creating a Workflow. For example, creating a target workflow encompasses a manager or supervisor who looks at what needs to be done and creates an efficient manner to perform the tasks to achieve the goal of accomplishing what needs to be done, an observation, evaluation, and judgment. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas, an observation, evaluation, and judgment. Further, as described above, the claims recite limitations for Managing Human Behavior, a “Certain Method of Organizing Human Activity”. Accordingly, the claim recites an abstract idea.
This judicial exception is not integrated into a practical application. In particular, the claim recites the above stated additional elements to perform the abstract limitations as above. The electronic device, processing unit, memory, and computer-readable medium are recited at a high-level of generality (i.e., as a generic software/module performing a generic computer function of storing, retrieving, sending, and processing data) such that they amount to no more than mere instructions to apply the exception using generic computer components. Even if taken as an additional element, the receiving and transmission steps above are insignificant extra-solution activity as these are receiving, storing, and transmitting data as per the MPEP 2106.05(d). Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception, when considered both individually and as an ordered combination. As discussed above with respect to integration of the abstract idea into a practical application, the additional element being used to perform the abstract limitations stated above amount to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept. The claim is not patent eligible. Applicant’s Specification states:
“[0026]In some embodiments, the electronic device 110 communicates with a server 130 to enable the provision of services to the application 120. The electronic device 110 may be any suitable type of electronic device including, e.g., a mobile terminal, fixed terminal, or portable terminal, including a mobile phone, a desktop computer, a laptop computer, a notebook computer, a netbook computer, a tablet computer, a media computer, a multimedia tablet, a palmtop computer, a portable game terminal, a VR/AR device, and a Personal Communication System, a PCS) device, a personal navigation device, a personal digital assistant (PDA), an audio/video player, a digital camera/camcorder, a positioning device, a television receiver, a radio broadcast receiver, an electronic book device, game device, or any combination of the foregoing,”
Which states that any type of computer can be used, which has a processor and memory, such as any personal computer, laptop, mobile phone, tablet, etc., to perform the abstract limitations, and from this interpretation, one would reasonably deduce the aforementioned steps are all functions that can be done on generic components, and thus application of an abstract idea on a generic computer, as per the Alice decision and not requiring further analysis under Berkheimer, but for edification the Applicant’s specification has been used as above satisfying any such requirement. This is “Applying It” by utilizing current technologies. For the receiving and transmitting steps that were considered extra-solution activity in Step 2A above, if they were to be considered additional elements, they have been re-evaluated in Step 2B and determined to be well-understood, routine, conventional, activity in the field. The background does not provide any indication that the additional elements, such as the device, processor, medium, etc., nor the receiving and transmitting steps as above, are anything other than a generic, and the MPEP Section 2106.05(d) indicates that mere collection or receipt, storing, or transmission of data is a well‐understood, routine, and conventional function when it is claimed in a merely generic manner (as it is here). For these reasons, there is no inventive concept. The claim is not patent eligible.
Claims 2-8, 11-17, and 20 contain the identified abstract ideas, further narrowing them, with the additional elements of a target interface element which is highly generic when considered as part of a practical application or under prong 2 of the Alice Analysis of the MPEP, thus not integrated into a practical application, nor are they significantly more for the same reasons and rationale as above.
New Claims 21-22 contain the identified abstract ideas, further narrowing them such as by presenting a set of candidate types and determining a processing type, with no additional elements to be considered as part of a practical application or under prong 2 of the Alice Analysis of the MPEP, thus not integrated into a practical application, nor are they significantly more for the same reasons and rationale as above.
After considering all claim elements, both individually and in combination, Examiner has determined that the claims are directed to the above abstract ideas and do not amount to significantly more. Therefore, the claims and dependent claims are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. See Alice Corporation Pty. Ltd. v. CLS Bank International, No. 13–298.
Allowable Subject Matter
Claims 1-2, 4-8, 10-17, 19-20, and 22 have overcome the prior art and would be allowable if amended to overcome the 35 USC 101 rejections.
The closest prior art of record are Freire (U.S. Publication No. 2012/009,5801), Hull (U.S. Publication No. 2008/006,5448), and Chow (U.S. Publication No. 2011/000,4614}. Freire, a system and method for analogy-based workflow identification, teaches in response to a received editing operation, obtaining configuration information for the first node via a set of input controls associated with the first node, the configuration information indicating a text processing process corresponding to the first node, wherein adding the first node to the node connection graph in response to the received editing operation comprises: presenting a plurality of interface elements corresponding to a plurality of node types; and in response to a selection of a target interface element of the plurality of interface elements, adding the first node to the node connection graph, the target interface element corresponding to the text processing node, presenting, in a first input control of the set of input controls, a set of candidate types; and determining, based on a selection of a target type in the set of candidate types, a processing type of the text processing process corresponding to the first node, obtaining an input parameter of the text processing process via a second input control in the set of input controls, a first input parameter, the first input parameter being configured through referencing a target data object in a second node associated with the first node, and/or a second input parameter, the second input parameter being defined via the second input control, obtaining at least one operator associated with the text processing process via a third input control in the set of input controls, wherein the third input control corresponds to a processing type of the text processing process, obtaining an expression corresponding to the text processing process via a fourth input control in the set of input controls, and creating a desired update to a workflow by using the process of node connections with a graph as above, it does not explicitly state a target graph, nor does it teach connecting of an downstream node. Hull, a method and apparatus for identifying workflow graphs using an iterative analysis of empirical data, teaches a goal or target workflow graph that creates a dependency between constraints and nodes and teaches automated text analysis of documents and files for nodes, but does not teach in response to the target workflow object being applied to a processing entity, the processing entity is configured to process an input request according to a processing flow indicated by the target workflow object, and connecting, in the node connection graph, an output of the first node to an input of a downstream node associated with the first node, to indicate that, in the processing process of the target workflow object, an output result of the text processing process corresponding to the first node is provided as an input of the downstream node. Chow, a system and method for auto-retrieving to avoid data binding, teaches workflow downstream activities which are used to connect nodes in the workflow, but no the specificity of the processing entity being configured to process an input request according to a processing flow indicated by the target workflow object, and connecting, in the node connection graph, an output of the first node to an input of a downstream node associated with the first node, to indicate that, in the processing process of the target workflow object, an output result of the text processing process corresponding to the first node is provided as an input of the downstream node. None of the prior art explicitly teaches this in response to the target workflow object being applied to a processing entity, the processing entity is configured to process an input request according to a processing flow indicated by the target workflow object, and connecting, in the node connection graph, an output of the first node to an input of a downstream node associated with the first node, to indicate that, in the processing process of the target workflow object, an output result of the text processing process corresponding to the first node is provided as an input of the downstream node., along with the other limitations of the claims, and these are the reasons which adequately reflect the Examiner's opinion as to why Claims 1, 10, and 19 are allowable over the prior art of record, and are objected to as provided above.
Conclusion
The prior art made of record is considered pertinent to applicant's disclosure.
US 20120095801 A1
Freire; Juliana et al.
ANALOGY BASED WORKFLOW IDENTIFICATION
US 20110004614 A1
Chow; Weihsiung William et al.
Auto-Retrieving To Avoid Data Binding
US 20080065448 A1
Hull; David A. et al.
Methods and apparatus for identifying workflow graphs using an iterative analysis of empirical data
US 20250284488 A1
Massie-Keller; Hart et al.
System and Methods for Generating Models and Digital Threads using Graphs
US 20250117727 A1
Osborne; d'Artagnan Leif
INTELLIGENT MACHINE-DRIVEN WORKFLOW WITH DECISION DELEGATION
US 20180096509 A1
GOLDBERG; EVAN et al.
MULTI-GRANULAR RIGS FOR DISTRIBUTED NODE-BASED INTERACTIVE WORKFLOWS
US 20100185973 A1
Ali; Alnur et al.
Visual Creation Of Computer-Based Workflows
US 20070055558 A1
Shanahan; James G. et al.
Method and apparatus for probabilistic workflow mining
US 12400164 B2
Osborne; d'Artagnan Leif
Intelligent machine-driven workflow with decision delegation
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOSEPH M WAESCO whose telephone number is (571)272-9913. The examiner can normally be reached on 8 AM - 5 PM M-F.
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, BETH BOSWELL can be reached on (571) 272-6737. The fax phone number for the organization where this application or proceeding is assigned is 571-273-1348.
Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/JOSEPH M WAESCO/Primary Examiner, Art Unit 3625B 5/26/2026
Prosecution Insights