DETAILED ACTION
The following is a Final Office action. In response to Non-Final communications received 12/18/2025, Applicant, on 3/5/2026, amended Claims 1, 2, 5, 12, 14-15, and 17-19. Claims 1-20 are pending in this action, have been considered in full, and are rejected below.
Response to Arguments
Arguments regarding 35 USC §101 Alice – Applicant asserts that the claims are not directed at an abstract idea, by stating the amended limitations of the claims and stating that they describe specific, event-driven analytical workflow implemented by a content management system, stating that they are not directed towards organizing human activity, and that they are integrated into a practical application as they improve the operation of the content management system by enabling automated, event-driven workspace determination and configuration, also alleging this is significantly more. Examiner disagrees as the claims recite clear abstractions of both mental processes and certain methods of organizing human activity as per the rejection below. This is stated clearly by the office action, and managing projects is clearly organizing human activity. Further, this is a mere assertion that the claims are eligible under 101. Applicant does not state how or why these would not be considered abstract under Prong 1, nor why they would be integrated with the limitations to overcome 101 under Prong 2 of the Alice Analysis of the MPEP, or even what technologies have been improved. The claims are not practically integrated as the additional elements of a content management system is recited at a high-level of generality (i.e., as a generic processor 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. Again, this is utilization of current technologies, “Applying It”, similar to that of Alice, and does not make these limitations eligible under 101, as there is no improvement to the content management system, or any additional element, alone or in combination. Further, there is no improvement to a technology or any technological process and performing these actions on a computer system would be utilization of current technologies to perform the abstract limitations of the Claims, and any inventive concept would be contained wholly within the abstraction.
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.
Arguments regarding 35 USC §103 – Applicant asserts that the combination of Lee and Ayzenshtat does not teach the amended limitations of the claims. Examiner disagrees as Lee teaches determining/identifying from a plurality of projects associated with a user, a project associated with a calendar event and a user account as in Fig 7 a calendar event, such as something occurring on a particular date or time is shown for a project and user on the system and the projects are view with linked data and documents as in [0176] which are content items, adding a collaborative content item associated with the calendar event to the project, content management as in [0147], content in view of projects as in [0086], use of a document workspace as in [0141-142], and use of an identifier as in [0124]. Ayzenshtat teaches generating a project view for the project, the project view comprising a representation of the collaborative content item, using similarity for identifying items in a collection, content, on multiple attributes as in [0029], and use of calendar entry information as in [0030]. Brashear teaches creating a workspace for a project as in [0051] and in [0061] changing and updating the project workspace based on/in response to new project information such as the attributes of [0057].
This teaches the amended limitations of the Claims.
Therefore, the arguments are non-persuasive, the combination of Lee, Ayzenshtat, and Brashear teaches the amended limitations of the Claims, and the rejection of the Claims and their dependents are maintained under 35 USC 103.
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claims 1, 14, and 18 recite limitations for analyzing calendar-event data associated with a calendar event to generate similarity metrics for a plurality of project identifiers based on measured similarities between one or more attributes of the calendar-event data and stored project data associated with the plurality of project identifiers (Collecting/Analyzing Information, an Observation and Evaluation, a Mental Process; Managing Human Behavior, i.e. managing projects; a Certain Method of Organizing Human Activity), determining/identifying, based on the similarity metrics for the plurality of project identifiers, from a plurality of projects associated with a user, a project workspace associated with the calendar event and a user account (Collecting/Analyzing Information, an Observation and Evaluation, a Mental Process; Managing Human Behavior, i.e. managing projects; a Certain Method of Organizing Human Activity), adding, in response to determining the project workspace, a collaborative content item associated with the calendar event to the project workspace (Analyzing the Information, an Evaluation, a Mental Process; Managing Human Behavior, i.e. managing projects; a Certain Method of Organizing Human Activity), generating a project view for the project, the project view comprising a representation of the collaborative content item (Transmitting the Analyzed Information, an Evaluation and Judgment, a Mental Process; Managing Human Behavior, i.e. managing projects; a Certain Method of Organizing Human Activity), and presenting/populating the project view/workspace on a client device. (Transmitting the Analyzed Information, an Evaluation and Judgment, a Mental Process; Managing Human Behavior, i.e. managing projects; 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 Managing Human Behavior, i.e. managing projects, but for the recitation of generic computer components. That is, other than reciting content management system, client device, system, processor, memory, and medium, nothing in the claim element precludes the step from practically being performed or read into the mind for the purposes of a Managing Human Behavior. For example, to generate a project view for the project, the project view comprising a representation of the collaborative content item encompasses a supervisor or project manager looking at a project, creating a snapshot of it and put a symbol for it, such as SubGroup A, and then copying this and sending this portion to supervisors or lower tier managers, which is 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 content management system, client device, system, memory, processor, and 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 transmitting 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:
“[00187]Devices implementing methods according to these disclosures can comprise hardware, firmware and/or software, and can take any of a variety of form factors. Typical examples of such form factors include laptops, smart phones, small form factor personal computers, personal digital assistants, and so on. Functionality described herein also can be embodied in peripherals or add-in cards. Such functionality can also be implemented on a circuit board among different chips or different processes executing in a single device, by way of further example. ”
Which shows that any generic computer can be used to perform the abstract limitations, such as a laptop, phone, desktop, etc., 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 systems, processor, memory, 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 2-13, 15-17, and 19-20 contain the identified abstract ideas, further narrowing them, with the additional element of a native application which is 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.
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.
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 of this title, 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.
The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-4, 6-10, 12, 14-15, and 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over Lee (U.S. Publication No. 2013/004,7068) in view of Ayzenshtat (U.S. Publication No. 2014/030,4249) in further view of (U.S. Publication No. 2013/021,1882).
Regarding Claims 1, 14, and 18, Lee, a system and method for local editing of shared multiple user documents, teaches a computer-implemented method comprising:
determining/identifying from a plurality of projects associated with a user, a project associated with a calendar event and a user account (Fig 7 a calendar event, such as something occurring on a particular date or time is shown for a project and user on the system and the projects are view with linked data and documents as in [0176] which are content items)
adding, by the content management system, a collaborative content item associated with the calendar event to the project ([0176] content items such as a text document and digital data are added to the project)
presenting/populating, by the content management system, the project view/workspace on a client device (Fig. 7 and [0141-142] the project workspace/view is shown on a client device such as in [0189])
Although Lee teaches content management as in [0147], content in view of projects as in [0086], use of a document workspace as in [0141-142], and use of an identifier as in [0124], it does not explicitly state a calendar event system or a project associated with one.
Ayzenshtat, a system and method for expert discovery via search in shared content, teaches
generating, by the content management system, a project view for the project, the project view comprising a representation of the collaborative content item ([0044] views of content items are created in a content management system).
Using similarity for identifying items in a collection, content, on multiple attributes as in [0029],
Teaches use of calendar entry information as in [0030].
It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the project views and project information of Lee with the content management system and content views of Ayzenshtat as they are both analogous art along with the claimed invention which teach solutions to managing information of projects, and the combination would lead to an improved system which would allow users to efficiently search content and documents of projects as taught in [0003] of Ayzenshtat.
Neither Lee nor Ayzenshtat teaches project information being used.
Brashear, a system and method for project documentation and proposals, teaches creating a workspace for a project as in [0051] and in [0061] changing and updating the project workspace based on/in response to new project information such as the attributes of [0057].
It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the content management system with project views and project information of the combination of Lee and Ayzenshtat with the content management system and content views of Ayzenshtat as they are all analogous art along with the claimed invention which teach solutions to managing information of projects, and the combination would lead to an improved system which would projects to be estimated and viewed more efficiently as taught in [0003-4] of Brashear.
Examiner notes Lee teaches a system, one or more processor ([0193] system and processor), memory [0187] and computer readable medium ([0024] storage medium).
Regarding Claim 2, Lee teaches wherein generating the project view further includes creating a workspace for the project ([0086-87] workspaces are created for projects)
Regarding Claim 3, Lee teaches wherein the collaborative content item is displayed through a native application ([0088] the system uses an API or native application for specific systems such as [0199] applications software or applications interface software)
Regarding Claims 4, 15, and 19, the combination of Lee and Ayzenshtat teach the collaborative content item, the calendared event as in Fig. 7, and project views as in Claim 1 above.
Lee also teaches similar elements using similar numbers, a type of similarity as in [0084], but it does not explicitly teach a score for relevance.
Ayzenshtat teaches
determining a relevance score for the collaborative content item based at least in part on a similarity between the collaborative content item as in [0043]; and
including the collaborative content item in the project view based on the relevance score ([0043] and [0046] relevancy scores are used to determine attachments to parts).
It would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the similarity of elements of Lee with the similarity and relevancy scores of Ayzenshtat as they are both analogous art along with the claimed invention which teach solutions to managing information of projects, and the combination would lead to an improved system which would allow users to efficiently search content and documents of projects as taught in [0003] of Ayzenshtat.
Regarding Claim 6, Lee teaches further comprising: sending, to a client device, data to display the project view and the collaborative content item (Fig. 7 shows a client device with data of the project view and content items).
Regarding Claims 7, 16, and 20, the combination of Lee and Ayzenshtat teach sharing a collaborative content as in Claim 1 above.
teaches further comprising: sharing the collaborative content item with a second user account associated with the calendar event ([0025] multiple users can annotate documents as in [0037]).
Regarding Claim 8, Lee teaches further comprising:
Receiving edits to the collaborative content item ([0025] multiple users can annotate or edit content items) and
implementing the edits to the collaborative content item ([0025] an annotation is an edit).
Regarding Claim 9, Lee teaches further comprising:
synchronizing the edits to the collaborative content item with at least one second user account associated with the calendar event ([0038] multiple users can see the annotations, based on access levels as in [0034]).
Regarding Claim 10, Lee teaches further comprising:
identifying a set of permissions associated with the collaborative content item; and restricting access to the collaborative content item based on the set of permission ([0034] access is restricted based on permissions])
Regarding Claim 12, Lee teaches wherein the calendar event includes a project identifier (Fig. 7 shows a project with an identifier), and further comprising:
based on the project identifier, determining that the project associated with the project identifier exists (Fig. 7 the project exists as it is shown in the system exemplary)
Allowable Subject Matter
Claims 5, 11, 13, and 16 are objected to as being dependent upon a rejected base claim, but would be over the prior art of record and allowable if the independent claims were amended in such a way as to overcome the 35 USC 101 rejection and any other rejections.
Conclusion
The prior art made of record is considered pertinent to applicant's disclosure.
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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 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.
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/JOSEPH M WAESCO/Primary Examiner, Art Unit 3625B 6/24/2026
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