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 .
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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claims 1, 8, and 15 recite receiving user information and contact profile information, determining, using a machine learning model and based on the user information and contact profile information, confidence scores corresponding to contacts (the confidence scores indicating a likelihood of a future contribution to the user), generating, based on the confidence scores, a contact list including a set of prioritized contacts, and providing the contact list.
The limitation of receiving information and determining confidence scores, as drafted, is, under its broadest reasonable interpretation, a process of collecting and analyzing information to produce a prediction or ranking. Such activities—collecting data, analyzing or predicting outcomes, and organizing or ranking information—fall within the judicially recognized categories of abstract ideas (e.g., fundamental economic practices, methods of organizing human activity, and mathematical concepts) as described in Alice Corp. v. CLS Bank Int’l, 573 U.S. 208 (2014), and Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016). The claim’s recitation of a “machine learning model” to produce confidence scores describes an informational analysis/prediction step rather than a concrete technological improvement. The use of an algorithmic or statistical technique to analyze information, standing alone, is an abstract concept. The limitation of generating a prioritized contact list and providing that contact list, as drafted, is likewise an information-organization and presentation step that, under its broadest reasonable interpretation, can be performed mentally or by humans using pen and paper, absent meaningful limiting technical detail. For example, a human could review user and contact information, estimate likelihoods of future contribution, rank contacts, and produce a prioritized list. Thus, these claim elements fall within the “Mental Processes” or “Organizing Human Activity” groupings of abstract ideas.
This judicial exception is not integrated into a practical application. In particular, the claim’s additional elements are limited to generic computer components—“one or more memories” and “one or more processors”—and their use to perform the abstract steps (receive, determine using a model, generate, provide). The processors and memories are recited at a high level of generality and carry out conventional computing functions. There is no recitation of a specific, unconventional machine learning architecture, specialized data structure, novel data representation, particular training/inference pipeline, distributed or edge-computing arrangement that materially alters how the computing is performed, or any other technical detail that would impose meaningful limits on application of the abstract idea.
Under the Alice framework, merely implementing an abstract idea on generic computer components does not integrate the abstract idea into a practical application or supply an “inventive concept.” See Alice, 573 U.S. at 221–23; Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66 (2012). Reciting the use of a “machine learning model” without further technical detail is analogous to reciting a generic algorithmic step; such recitation alone does not render the claim patent-eligible (see Elec. Power, 830 F.3d at 1354). The claim does not recite any additional element or combination of elements that transforms the abstract idea into a patent-eligible application.
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above, the generic processor and memory elements amount to no more than instructions to implement the abstract idea on a generic computer. Mere invocation of a machine learning model or generic computing elements to perform predictive scoring and ranking does not supply the required inventive concept. Therefore, claims 1, 8, and 15 are directed to an abstract idea and do not recite additional limitations that transform the abstract idea into patent-eligible subject matter.
The dependent claims 2-7, 9-14, and 16-20 contain steps that are considered part of the abstract idea.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 1-20 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Spinner et al. (U.S. Patent Publication 2015/0134556), hereinafter Spinner.
Regarding claim 1 (and similarly claims 8 and 15), Spinner discloses
A system, comprising: (Fig. 4; [0134]; [0049])
one or more memories; and (Fig. 4, 401/403)
one or more processors, communicatively coupled to the one or more memories, configured to: (Fig. 4, 402) (Fig. 4; [0134-0135])
receive user information (i.e. keywords) associated with a user; ([0050]; [0052-0055])
receive contact profile information (i.e. user network information and third party information) associated with a set of contacts, ([0051]; i.e. contacts associated with the user) ([0058-0060]; [0063-0064])
determine, using a machine learning model and based on the user information and the contact profile information, confidence scores (i.e. rankings) corresponding to contacts included in the set of contacts, wherein the confidence scores indicate a likelihood of a future contribution to the user by contacts included in the set of contacts; ([0069]; [0077]; [0088])
generate, based on the confidence scores, a contact list including a set of prioritized contacts; and ([0069]; [0088-0089])
provide the contact list. ([0086]; Fig. 9; [0048])
Regarding claim 2 (and similarly claims 9 and 16), Spinner discloses
The system of claim 1, wherein the set of prioritized contacts includes at least one contact (i.e. Jane Doe who has contributed in the last two years) who previously contributed to the user and at least one contact (i.e. Tom Doe who has no positive contributions in the last two years) who has not previously contributed to the user. (Fig. 9; [0146])
Regarding claim 3 (and similarly claims 10 and 17), Spinner discloses
The system of claim 1, wherein the one or more processors are further configured to: modify the contact list based on at least one of a geographic location, (i.e. parameter such as geographic proximity to a future event) a maximum donation level, or a minimum donation level related to a future user event. ([0028]; [0079]; i.e. parameters are adjusted to modify the contact list)
Regarding claim 4 (and similarly claims 11 and 18), Spinner discloses
The system of claim 1, wherein the one or more processors are further configured to: receive a request to contact at least one prioritized contact included in the set of prioritized contacts; (Fig. 9; [0116]; [0088-0089]; i.e. a user may select to invite the prospect/a user may select a subset to send email invitations to an event) and automatically contact, based on the request, the at least one prioritized contact. ([0044]; [0089])
Regarding claim 5 (and similarly claims 12 and 19), Spinner discloses
The system of claim 4, wherein the request to contact is a request to contact via at least one of: an electronic mail transmission, a short message service transmission, or a telecommunication. ([0044]; [0025])
Regarding claim 6 (and similarly claims 13 and 20), Spinner discloses
The system of claim 1, wherein the contact list includes obfuscated contact information (i.e. address and phone numbers) for the set of prioritized contacts. ([0048])
Regarding claim 7 (and similarly claim 14), Spinner discloses
The system of claim 1, wherein the contact profile information includes at least one of: name information, demographic information, contribution history information, philanthropic activity information, business information, professional information, personal information, or political information. ([0032])
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Henze (U.S. Patent Publication 2005/0065809) shows identifying a top plurality of prospective donors.
Olds et al. (U.S. Patent Publication 2023/0035505) shows using a machine learned donor prediction model to predict donors to a campaign.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to CAROLINE H JAHNIGE whose telephone number is (571)272-8450. The examiner can normally be reached 7:30 AM - 4:00 PM.
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, Christopher Parry can be reached at (571) 272-8328. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/CAROLINE H JAHNIGE/Primary Examiner, Art Unit 2451