DETAILED ACTION
This FINAL office action is in response to Applicant’s amendment filed September 18, 2026. Applicant’s September 18th amendment amended claims 1, 5 and 7. Claims 1, 5 and 6 are the independent claims. Claims 1-18 are pending.
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 .
Response to Amendment
The Objection to the Title in the previous office action is maintained.
The 35 U.S.C. 101 rejection of claims 1-18 in the previous office action is maintained
The 35 U.S.C. 103 rejections of claims 1-18 in the previous office action over Podgurny et al., Amit and Xu et al., are withdrawn in response to Applicant's amendments to the claims.
Response to Arguments
Applicant’s arguments, see Pages 10, 11, filed September 18, 2026, with respect to Podgurny et al., Amit and Xu et al. have been fully considered and are persuasive. The 35 U.S.C. 103 rejections of claims 1-18 has been withdrawn.
Applicant's arguments filed September 18, 2026 have been fully considered but they are not persuasive. Specifically, Applicant argues that the claims are patent eligible under 35 U.S.C. 101 as the claims recite significantly more than an abstract idea (e.g. claims recite a plurality of specific technical operations that go well beyond any abstract idea, ear information and multi-generational accumulation of corrected task data in a unified table constitutes an inventive concept; Remarks: Last Paragraph, Page 7; Paragraph 3, Page 9); the claims cannot be performed mentally (Remarks: Last Paragraph, Page 7); the claims are similar to Enfish (e.g. claims recite an improvement to computer-implemented task management system - e.g. automatically infers missing year data, enables streamlined multi-generational work hand overs, improves functioning of a task management system itself; Specification: Paragraph 72; Remarks: Paragraph 2, Page 8; Paragraph 2, Page 9); the claims are similar to Subject Matter Eligibility example 42, Claim 1 (e.g. acquires task information from a plurality of persons in charges, enables seamless sharing across multiple participants Remarks: Last Two Paragraphs, Page 8; Paragraphs 1-2, Page 9); and the claims integrate abstract idea into a practical application (e.g. defined data-standardization and accumulation pipeline - solving fragmented non-uniform records maintained by separate users; Remarks: Paragraph 1, Page 9).
In response to applicant's argument that certain features of the invention make he claims patent eligible under 35 U.S.C. 101, it is noted that the features upon which applicant relies (i.e., iterative cross-referencing across potentially large datasets spanning multiple generations of persons - Bullet B, Last Paragraph, Page 7; manage data across multiple generates of persons in charge creates a unified/correct knowledge base - Bullet C, Last Paragraph, Page 7; incomplete and/or non-standardized date entries - Last Paragraph, Page 8; fragmented non-uniform records maintained by separate users - Paragraph 1, Page 9; seamless sharing across multiple participants - Paragraph 1, Page 9; multi-generational accumulation of corrected task data - Paragraph 3, Page 9) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
In response to Applicant’s argument that the claims are patent eligible under 35 U.S.C. 101 as the claims are not directed to an abstract/cannot be performed mentally, the examiner respectfully disagrees.
the claims are directed to well-known economic practice of human task management, specifically the claims are directed to accumulating revised task information (missing year data) for a plurality of persons in charge in a task management able (i.e. storing/saving/recording data – including person in charge, responsibility period, start date, end date, etc. in a table).
While the claims may represent an improvement to the fundamental economic process of human task management (e.g. recording persons in charge of tasks over multiple generations of persons in charge), the claims in no way either claimed or disclosed represent a practical application, the claims do not provide a technical solution to a technical problem; the claims do not improve any of the underlying technology (processor, computer, recording medium, device); nor do the claims improve another technical field.
Additionally, the claims are directed to a mental process practically capable of being performed in the human mind via observation, evaluation, judgement and opinion. Representative claim 1: The step of acquiring task information may be performed in the human mind using observation of data. The step of revising incomplete data information may be performed in the human mind by evaluation and judgement. The step of accumulating the revised task information…in a table may be performed in the human mind via observation or via pen and paper (e.g. writing down revised task information in the form a table, matrix or spreadsheet).
The recitation of a device (comprising a processor), computer or recording medium storing computer executable instructions – each used for their conventional, routine, well-known purposes, does not negate the mental nature of these claim limitations as the claims merely use the generic computer as a tool to perform an otherwise mental process. The device (comprising a processor), computer or recording medium storing computer executable instructions are recited at a high level of generality and amount to no more than mere instructions to apply the abstract idea using a generic computer.
Other than the recitation of a device, processor, computer, and recording medium nothing in the claimed steps precludes the step from practically being performed in the mind. The claims do not recite additional elements that are sufficient to amount to significantly more than the abstract idea. The limitations directed to a hardware device including a device, processor, computer, and recording medium are each recited at a high level of generality and amount to no more than mere instructions to apply the exception using a generic computer, generic sensors, and/or generic control devices. See MPEP 2106.05(f). Further the mere nominal recitation of a generic computer (i.e., device, processor, computer, and recording medium) (each used for their well-understood, conventional and routine purpose) does not take the claim limitation out of the mental processes grouping.
Nothing in Applicant’s disclosures suggests that the Applicant intended to accomplish any of the steps recited in the claims through anything other than well understood technology used in a routine and conventional manner. Therefore, the claims lack an inventive concept.
Reevaluating the steps of acquiring and accumulating steps which are considered insignificant extra solution activity, these limitations are mere data gathering and storage/recording recited at a high level of generality and amount to nothing more than gathering and storing data which are both well-understood, routine and conventional activities. The limitations remain insignificant extra solution activity even upon reconsideration. Even when considered in combination the additional elements represent mere instructions to apply an exception and insignificant extra solution activity which cannot provide an inventive concept.
Accordingly, the claims are not patent eligible under 35 U.S.C. 101.
In response to Applicant’s argument that the claims are patent eligible under 35 U.S.C. 101 as the claims recite significantly more than an abstract idea, the examiner respectfully disagrees.
As discussed above, the claims are directed to well-known economic practice of human task management, or more specifically, accumulating task information for a plurality of persons in charge in a task management able (i.e. storing/saving/recording data – including person in charge, responsibility period, start date, end date, etc.) as well as a mental process capable of being performed in the human mind of via pen and paper.
As for the claim limitations directed to a device, processor, recording medium and computer at best recite generic, well-known computer hardware or other machinery each performing conventional and ordinary computer or machinery functions. The recited generic computer hardware simply performs generic computer function of acquiring, processing and accumulating data. Generic computers performing generic, well known computer functions, alone, do not amount to significantly more than the abstract idea. Further the recited processor and recording medium are part of every conventional general-purpose computer.
Applicant has not demonstrated that a special purpose machine/computer is required to carry out the claimed invention. A special purpose machine is now evaluated as part of the significantly more analysis established by the Alice decision and current 35 U.S.C. 101 guidelines. It involves/requires more than a machine only broadly applying the abstract idea and/or performing conventional functions.
Applicant’s specification discloses that the claimed elements directed to computer, processor, device, and recording medium merely comprise generic computer hardware or other machinery which is commercially available.
Applicant’s claimed features directed to a system and components do not represent custom or specific computer hardware circuits, instead the term system merely refers to commercially available software and/or hardware.
As discussed above and as described in MPEP § 2106.05(f), the recited computer and other machinery must “play a significant part in permitting the claimed method to be performed, rather than function solely as an obvious mechanism for permitting a solution to be achieved more quickly” in order to add significantly more than the abstract idea. The claims merely invoke computers or other machinery merely as a tool to perform an existing process and use of a computer or other machinery in its ordinary capacity for economic or other tasks and as such do not recite significantly more than an abstract idea.
As discussed above the additional elements in the claims amount to no more than a mere instruction to apply the abstract idea using generic computing components or other machinery, wherein mere instructions to apply an judicial exception using generic computer components or other machinery do not provide an inventive concept.
The claims use “conventional or generic technology in a nascent but well-known environment” to implement the abstract idea of “computer-implemented task management”. In re TLI Commc’ns LLC Pat. Litig., 823 F.3d 607, 612 (Fed. Cir. 2016). The recited technology (processor, recording medium, etc.), are used as a “conduit for the abstract idea,” not to provide a technological solution to a specific technological problem. Id.; see also id. at 611–13 (holding claims reciting the use of a cellular telephone and a network server to classify an image and store the image based on its classification to be abstract because the patent did “not describe a new telephone, a new server, or a new physical combination of the two” and did not address “how to combine a camera with a cellular telephone, how to transmit images via a cellular network, or even how to append classification information to that data”).
Nothing in Applicant’s disclosures suggests that the Applicant intended to accomplish any of the steps recited in the claims through anything other than well understood technology used in a routine and conventional manner. Therefore, the claims lack an inventive concept. See also, e.g., Elec. Power Grp., 830 F.3d at 1355 (holding claims lacked inventive concept where “[n]othing in the claims, understood in light of the specification, requires anything other than off-the-shelf, conventional computer, network, and display technology for gathering, sending, and presenting the desired information”); Content Extraction, 776 F.3d at 1348 (holding claims lacked an inventive concept where the claims recited the use of “existing scanning and processing technology”).
Accordingly, the claims are not patent eligible under 35 U.S.C. 101.
In response to Applicant’s arguments that the claims are patent eligible under 35 U.S.C. 101 because the claims are similar to the Enfish decision since the claims recite an improvement to computer-implemented task management system, the examiner respectfully disagrees.
On May 12, 2016, the U.S. Court of Appeals for the Federal Circuit (Federal Circuit) in Enfish, LLC v. Microsoft Corp. held that the claimed database software designed as a "self-referential" table is patent eligible under 35 U.S.C. § 101 because it is not directed to an abstract idea.
The claims of the patents at issue in this case describe the steps of configuring a computer memory in accordance with a self-referential table, in both method claims and system claims that invoke 35 U.S.C. § 112(t). The court asked whether the focus of the claims is on the specific asserted improvement in computer capabilities (i.e., the self-referential table for a computer database), or instead on a process that qualifies as an "abstract idea" for which computers are invoked merely as a tool. To make the determination of whether these claims are directed to an improvement in existing computer technology, the court looked to the teachings of the specification. Specifically, the court identified the specification's teachings that the claimed invention achieves other benefits over conventional databases, such as increased flexibility, faster search times, and smaller memory requirements.
The instant application, specifically the newly recited limitations directed to accumulating revise task information in a task management table at best recites using a generic computer (device comprising a processor) to accumulate (store, save, record, log, etc.) data in the form of a table (matrix, spreadsheet, etc.) which merely recites a generic computer performing generic computer functions (accumulating/storing data). The purpose of a table is to store/save accumulated revised task information (i.e. data), which may or may not be later used to by the device or the plurality of persons in charge of the various tasks. Utilizing a table for its express purpose does not constitute improving the computer (device with a processor). As discussed below, the claims are similar to ideas found to be abstract, wherein upon examination of the claims as a whole and in terms of each claim’s limitations reveals that the claims are not directed to improving computer performance and do not recite any such benefit. The claims are directed to accumulating revised task information (mere data) and merely use a device (comprising a processor – i.e. a generic computer) to at best improve the business process of storing/recording task information related to persons in charge across ‘multi-generations’ of persons in charge (i.e. tracking what human is in charge of a task over time). The claims, at best, recite a wished-for improvement in the abstract idea of human task management (an improvement in the abstract idea itself).
Nowhere in Applicant’s specification does Applicant discuss or imply that the thrust of the invention, much alone a side-effect, is directed to improving the performance of the computer or device or computer readable medium in sharp contrast to the recent court findings in the Enfish decision.
Accordingly, the claims are nothing like Enfish and are not patent eligible under 35 U.S.C 101.
In response to Applicant’s arguments that the claims are patent eligible under 35 U.S.C. 101 because the claims are similar to Subject Matter Eligibility Example 42, the examiner respectfully disagrees.
Subject Matter Eligibility Example 42 is directed to a method for transmitting notifications when medical records are updated via a network based patient management system that collects, converts and consolidates patient information from various local healthcare systems/providers via a graphical user interface into a standardized format, stores the standardized data on network based storage devices and generates/transmits messages containing the updated patient information in a standardized format to all the physicians/healthcare providers that have access to the patients information so that all users can be quickly notified of any changes without manually having to go lookup or consolidate all of the providers information (i.e. providing an improvement to prior systems by allowing remote users to share information in real-time in a standardized format regardless of the format in which the information was inputted by the user).
In sharp contrast the instant application does not recite a network of any kind, does not consolidate data from multiple data sources, does not provide remote access over a network to users, does not standardize/normalize data of any kind, and does not s share information in real-time in a standardized format regardless of the format in which the information was inputted by the user.
Accordingly, the claims are not similar to those found patentable in Subject Matter Eligibility Example 42 and are therefore not patent eligible under 35 U.S.C. 101.
In response to Applicant’s argument that the claims are patent eligible under 35 U.S.C. 101 as the claims integrate the abstract idea into a practical application, the examiner respectfully disagrees.
The claims are directed to a well-known business practice – human task management – in this case accumulating, in a table, revised task information for a plurality of persons in charge (person in charge, start date, end date, etc. – merely data collection/storage). While the claims may represent an improvement to the business process of human task management by accumulating task information (e.g. responsibility periods, persons in charge) over ‘multiple generations’ of persons in charge they in no way either claimed or disclosed represent a practical application.
Under the see MPEP § 2106.05, the claims are evaluated to determine if additional elements that integrate the judicial exception into a practical application (see Manual of Patent Examining Procedure ("MPEP") §§ 2106.05(a)-(c), (e)- (h)). A claim that integrates a judicial exception into a practical application applies, relies on, or uses the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception.
For example, limitations that are indicative of "integration into a practical application" include:
Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP § 2106.05(a);
Applying the judicial exception with, or by use of, a particular machine - see MPEP § 2106.05(b);
Effecting a transformation or reduction of a particular article to a different state or thing - see MPEP § 2106.05(c); and
Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception - see MPEP § 2106.05(e).
In contrast, limitations that are not indicative of "integration into a practical application" include:
Adding the words "apply it" (or an equivalent) with the judicial exception, or merely include instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea - see MPEP § 2106.05(±);
Adding insignificant extra-solution activity to the judicial exception- see MPEP § 2106.05(g); and
Generally linking the use of the judicial exception to a particular technological environment or field of use - see MPEP 2106.05(h).
In view of the MPEP § 2106.05, one must consider whether there are additional elements set forth in the claims that integrate the judicial exception into a practical application. The identified additional non-abstract elements recited in the independent claims are the generic device, computer, processor and recording medium storing instructions. This generic computer hardware merely performs generic computer functions of acquiring, processing and accumulating (storing, saving, recording) data and represent a purely conventional implementation of applicant’s accumulation of task information (data) in the general field of human task management and do not represent significantly more than the abstract idea. See at least MPEP § 2106.05(a) ("Improvements to the Functioning of a Computer or to Any Other Technology or Technical Field").
These recited additional elements are merely generic computer components. The claims do present any other issues as set forth in the MPEP § 2106.05 regarding a determination of whether the additional generic elements integrate the judicial exception into a practical application. Rather, the claims merely use instructions to implement an abstract idea on a computer, or merely use a computer as a tool to perform an abstract idea.
The claims do not recite improvements to the functioning of a computer or any other technology field (MPEP 2106.05(a)), the claims do not apply or use the abstract idea to effect a particular treatment or prophylaxis for a disease or medical condition, the claims to do apply the abstract idea with a particular machine (MPEP 2106.05(b)), the claims do not effect a transformation or reduction of a particular article to a different state or thing (e.g. data remains data even after processing; MPEP 2106.05(c)), the claims no not apply or use the abstract idea in some other meaningful way beyond generally linking the user of the abstract idea to a particular technological environment (i.e. a generic computer) such that the claim as a whole is more than a drafting effort designed to monopolize the abstract idea (MPEP 2106.05(e)). The recited generic computing elements are no more than mere instructions to apply the exception using a generic computer component. Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
Thus, under Step 2A, Prong Two (MPEP §§ 2106.05(a)-(c) and (e)- (h)), the claims do not integrate the judicial exception into a practical application.
There is a fundamental difference between computer functionality improvements, on the one hand, and uses of existing computers as tools to perform a particular task, on the other — a distinction that the Federal Circuit applied in Enfish, in rejecting a § 101 challenge at the first stage of the Mayo/Alice framework because the claims at issue focused on a specific type of data structure, i.e., a self-referential table, designed to improve the way a computer stores and retrieves data in memory, and not merely on asserted advances in uses to which existing computer capabilities could be put. See Enfish, 822 F.3d at 1335-36. Here the claims simply use a computer as a tool and nothing more.
For the reasons outlined above, that the claims recite a method of organizing human activity, i.e., an abstract idea, and that the additional element recited in the claim beyond the abstract idea (i.e., device, computer, processor, recording medium storing computer executable instructions) is no more than a generic computer component used as a tool to perform the recited abstract idea. As such, it does not integrate the abstract idea into a practical application. See Alice Corp., 573 U.S. at 223-24 (“[Wholly generic computer implementation is not generally the sort of ‘additional featur[e]’ that provides any ‘practical assurance that the process is more than a drafting effort designed to monopolize the [abstract idea] itself.’” (quoting Mayo, 566 U.S. at 77)).
Accordingly, the claims are directed to an abstract idea.
Step Two of the Mayo/Alice Framework (Step 2B)
Having determined under step one of the Mayo/Alice framework that the claims are directed to an abstract idea, we next consider under Step 2B of the Guidance, the second step of the Mayo/Alice framework, whether the claims include additional elements or a combination of elements that provides an “inventive concept,” i.e., whether an additional element or combination of elements adds specific limitations beyond the judicial exception that are not “well-understood, routine, conventional activity” in the field (which is indicative that an inventive concept is present) or simply appends well-understood, routine, conventional activities previously known to the industry to the judicial exception. See MPEP § 2106.05.
Under step two of the Mayo/Alice framework, the elements of each claim are considered both individually and “as an ordered combination” to determine whether the additional elements, i.e., the elements other than the abstract idea itself, “transform the nature of the claim” into a patent-eligible application. Alice Corp., 573 U.S. at 217 (citation omitted); see Mayo, 566 U.S. at 72-73 (requiring that “a process that focuses upon the use of a natural law also contain other elements or a combination of elements, sometimes referred to as an ‘inventive concept,’ sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the natural law itself’ (emphasis added) (citation omitted)).
Here the only additional element recited in the claims beyond the abstract idea is a device, computer, processor, recording medium storing computer executable instructions” i.e., generic computer component. See Alice, 573 U.S. at 223 (“[T]he mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention.”). Applicant has not identified any additional elements recited in the claim that, individually or in combination, provides significantly more than the abstract idea.
Similar to the discussion in Uniloc USA, Inc. v. LG Electronics USA, Appeal No. 19-1835 (Fed. Cir. Apr. 30, 2020), where the Federal Circuit reaffirmed that software inventions are patentable in the U.S. with a bright-line statement: “Our precedent is clear that software can make patent-eligible improvements to computer technology, and related claims are eligible as long as they are directed to non-abstract improvements to the functionality of a computer or network platform itself.” The instant application merely applies the abstract idea using a generic computer as a conduit/tool for the abstract idea and does not improve the functioning of a computer or computer networks, does not improve another technical field and does not provide a technical solution to a technical problem.
With regards to Applicant’s argument that the claimed invention improves the functioning of computer implemented task management systems by inferring missing year data, enables streamlined multi-generational work and the like, the examiner respectfully disagrees. Accumulating data in a table, including determining a year for data information for task information lacking a year, is a routine, conventional, and well-known use of tables and computers. The functioning of the device, computer, processor or recording medium are not improved by acquiring task information, revising incomplete task information/data and accumulating (storing, saving, recording, etc..) data. Computers as well as humans using pen and paper commonly acquire, review and accumulate data.
As for Applicant’s argument that the invention resolves a technical problem, the examiner respectfully disagrees. At best the argued ‘improvements’ are business improvements in the business problem of acquiring, revising (correcting) and accumulating task information related to persons in charge of tasks and in no way represent an improvement in the functioning of a computer or computer network, do not represent an technical solution to a technical problem inherent in computers or another technical field.
With regards to argued Specification Paragraph 72, this paragraph discloses that the management device can estimate and revise the timing of task information of which the input is omitted and can manage task information for mlutple persons in charge in time series thereby enabling a smooth hand over between persons in charge – this is at best a wished for business benefit – smooth task transitions/hand overs between people/humans – i.e. at best an improvement in the abstract idea itself. This paragraph makes clear that the focus of the invention is to improve the conventional, routine and well-known business practice/process of human task management, specifically accumulating revised task information over multiple generations of persons in charge. This paragraph, like the remainder of Applicant’s disclosure, does not disclose an improvement in the underlying technology (e.g. process, device, recording medium, etc.); does not disclose an improvement in another technical field; and does not disclose providing a technical solution to a technical problem.
Accordingly, the claims are not patent eligible under 35 U.S.C. 101.
Specification
The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed.
The following title is suggested: Task Management System for Tracking Person in Charge, Responsibility Time Periods and Task Take Overs or the like.
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 1-18 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.
Regarding independent Claims 1, 5, and 6, the claims are directed to the abstract idea of human task assignment management/recording. This is a process (i.e. a series of steps) which (Statutory Category – Yes –process).
The claims recite a judicial exception, a method for organizing human activity, task assignment (task management, human task assignment) (Judicial Exception – Yes – organizing human activity). Specifically, the claims are directed to accumulating, in a table, revised incomplete task date information, wherein task assignment is a fundamental economic practice that falls into the abstract idea subcategories of managing personal behavior or interactions between people. See 2106.04(a). Further all of the steps of “acquiring”, “revising” and “accumulating” recite functions of the task assignment/management are also directed to an abstract idea that falls into the abstract idea subcategories of managing personal behavior or interactions between people. The intended purpose of independent claims 1, 5 and 6 appears to be to accumulating revised incomplete task date information (lacking year) in a table for the purpose of managing the task information across multiple generations of persons in charge (wished for benefit, intended use).
Accordingly, the claims recite an abstract idea – fundamental economic practice, specifically in the abstract idea subcategories of managing personal behavior or interactions between people. The exceptions are the person in charge (who is a person) and additional limitations of generic computer elements: device, processor, computer readable recording medium storing instructions. See 2106.04(a).
Accordingly, the claims recite an abstract idea under Step 2A, Prong One, we proceed to Step 2A, Prong Two. Considering whether the additional elements set forth in the claim integrate the abstract idea into a practical application (See 2106.04(a)), the previously identified non-abstract elements directed to generic computing components include: device, processor, computer readable recording medium storing instructions. These generic computing components are merely used to receive/access, process or display data as described extensively in Applicant’s specification (Specification: Figure 4). Generic computers performing generic computer functions, alone, do not amount to significantly more than the abstract idea. Moreover, when viewed as a whole with such additional elements considered as an ordered combination, the claim modified by adding a generic computer would be nothing more than a purely conventional computerized implementation of applicant's task assignment/management in the general field of business management and would not provide significantly more than the judicial exception itself. Note McRo, Inc. v. Bandai Namco Games America Inc. (837 F.3d 1299 (Fed. Cir. 2016)), guides: "[t]he abstract idea exception prevents patenting a result where 'it matters not by what process or machinery the result is accomplished."' 837 F.3d at 1312 (quoting O'Reilly v. Morse, 56 U.S. 62, 113 (1854)) (emphasis added). The claims are not directed to a particular machine nor do they recite a particular transformation (MPEP § 2106.05(b)).
Additionally, the claims do not recite any specific claim limitations that would provide a meaningful limitation beyond generally linking the use of the judicial exception to a particular technological environment. Nor do the claims present any other issues as set forth in the MPEP 2106.04(a) regarding a determination of whether the additional generic elements integrate the judicial exception into a practical application. Rather, the claims merely use instructions to implement an abstract idea on a computer, or merely use a computer as a tool to perform an abstract idea. Thus, under Step 2A, Prong Two (MPEP §§ 2106.05(a)-(c) and (e)- (h)), Claims 1-18 do not integrate the judicial exception into a practical application.
Regarding the use of the generic (known, conventional) recited device, processor, computer readable recording medium storing instructions," the Supreme Court has held "the mere recitation of a generic computer cannot transform a patent-ineligible abstract idea into a patent-eligible invention." Alice, 573 U.S. 208, 223. Generic computers performing generic computer functions, alone, do not amount to significantly more than the abstract idea. The claims as a whole do not recite more than what was well-known, routine and conventional in the field (see MPEP § 2106.05(d)). In light of the foregoing and under the MPEP 2106.04(a), that each of the claims, considered as a whole, is directed to a patent-ineligible abstract idea that is not integrated into a practical application and does not include an inventive concept.
Accordingly, the claims are not patent eligible under 35 U.S.C. 101.
Additionally, the claims recite a judicial exception, a mental processes, which can be performed in the human mind or via pen and paper (Judicial Exception – Yes – mental process).
The claimed steps of revising incomplete date information in each piece of the task information using data information describes the abstract idea. These limitations as drafted are directed to a process that under its reasonable interpretation covers performance of the steps in the mind but for the recitation of the generic computer components. Other than the recitation of a device, processor, computer readable recording medium storing instructions nothing in the claimed steps precludes the step from practically being performed in the mind. The claims do not recite additional elements that are sufficient to amount to significantly more than the abstract idea because the steps acquiring task information is directed to insignificant pre-solution activity (i.e. data gathering). The step of accumulating the revised task information…in a table is directed to insignificant post-solution activity (i.e. data storage/recording). The mere nominal recitation of a generic processor/computer does not take the claim limitation out of the mental processes grouping. Thus, the claim recites a mental process. (Judicial Exception recited – Yes – mental process).
The claims do not integrate the abstract idea into a practical application. The generic device, processor, computer readable recording medium storing instructions are each recited at a high level of generality merely performs generic computer functions of retrieving, processing or displaying data. The generic processor/computer merely applies the abstract idea using generic computer components. The 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 claims do not recite improvements to the functioning of a computer or any other technology field (MPEP 2106.05(a)), the claims do not apply or use the abstract idea to effect a particular treatment or prophylaxis for a disease or medical condition, the claims to do apply the abstract idea with a particular machine (MPEP 2106.05(b)), the claims do not effect a transformation or reduction of a particular article to a different state or thing (e.g. data remains data even after processing; MPEP 2106.05(c)), the claims no not apply or use the abstract idea in some other meaningful way beyond generally linking the user of the abstract idea to a particular technological environment (i.e. a generic computer) such that the claim as a whole is more than a drafting effort designed to monopolize the abstract idea (MPEP 2106.05(e)). The recited generic computing elements are no more than mere instructions to apply the exception using a generic computer component.
Accordingly, this additional element does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. (Integrated into a Practical Application – No).
As discussed above the additional elements in the claims amount to no more than a mere instruction to apply the abstract idea using generic computing components, wherein mere instructions to apply an judicial exception using generic computer components cannot integrate a judicial exception into a practical application or provide an inventive concept. For the acquiring step that was considered extra-solution activity, this has been re-evaluated and determined to be well-understood, routine, conventional activity in the field. Applicant’s specification does not provide any indication that the computer/processor is anything other than a generic, off-the-shelf computer component, and the Symantec, TLI, and OIP Techs. court decisions (MPEP 2106.05(d)(II)) indicate that mere collection or receipt 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 ineligible (Provide Inventive Concept – No).
The claims are ineligible under 35 U.S.C. 101 as being directed to an abstract idea without significantly more.
Regarding dependent claims 2-4 and 7-18, the claims are directed to the abstract idea of task assignment and merely further limit the abstract idea claimed in independent Claims 1, 5, and 6.
Claims 2, 9 and 14 further limit the abstract idea by estimating a task execution frequency (a more detailed abstract idea remains an abstract idea). Claims 3, 10 and 15 further limit the abstract idea by retrieving task information from the revised task information (a more detailed abstract idea remains an abstract idea). Claims 4, 11 and 16 further limit the abstract idea by extracting unfinished tasks of a previous person in charge (a more detailed abstract idea remains an abstract idea). Claims 7, 12 and 17 further limits the abstract idea by generating textual data describing the task for transferring (a more detailed abstract idea remains an abstract idea). Claims 8, 13 and 18 further limit the abstract idea by inserting predetermined value for incomplete task date information (a more detailed abstract idea remains an abstract idea).
None of the limitations considered as an ordered combination provide eligibility because taken as a whole the claims simply instruct the practitioner to apply the abstract idea to a generic computer.
Further regarding Claims 1-18, Applicant’s specification discloses that the claimed elements directed to a device, processor, computer readable recording medium storing instructions at best merely comprise generic computer hardware which is commercially available (Specification: Figure 4). More specifically Applicant’s claimed features directed to a system do not represent custom or specific computer hardware circuits, instead the terms merely refers to commercially available software and/or hardware. Thus, as to the system recited, "the system claims are no different from the method claims in substance. The method claims recite the abstract idea implemented on a generic computer; the system claims recite a handful of generic computer components configured to implement the same idea." See Alice Corp. Pry. Ltd., 134 S.Ct. at 2360.
Accordingly, the claims merely recite manipulating data utilizing generic computer hardware (e.g. device, processor, etc.). Generic computers performing generic computer functions, alone, do not amount to significantly more than the abstract idea. Further the lack of detail of the claimed embodiment in Applicant’s disclosure is an indication that the claims are directed to an abstract idea and not a specific improvement to a machine.
Accordingly given the broadest reasonable interpretation and in light of the specification the claims are interpreted to include the process steps being performed by a human mind or via pen and paper. The claim limitations which recite a computer implemented method is at best recite generic, well-known hardware. However, the recited generic hardware simply performs generic computer function of processing data. Generic computers performing generic, well known computer functions, alone, do not amount to significantly more than the abstract idea. Further the recited memories are part of every conventional general-purpose computer.
Applicant has not demonstrated that a special purpose machine/computer is required to carry out the claimed invention. A special purpose machine is now evaluated as part of the significantly more analysis established by the Alice decision and current 35 U.S.C. 101 guidelines. It involves/requires more than a machine only broadly applying the abstract idea and/or performing conventional functions.
Applicant’s specification discloses that the claimed elements directed to a device, processor, computer readable recording medium storing instructions merely comprise generic computer hardware which is commercially available (Specification: Figure 4). More specifically Applicant’s claimed features directed to a system and components do not represent custom or specific computer hardware circuits, instead the term system merely refers to commercially available software and/or hardware. Thus, as to the system recited, "the system claims are no different from the method claims in substance. The method claims recite the abstract idea implemented on a generic computer; the system claims recite a handful of generic computer components configured to implement the same idea." See Alice Corp. Pry. Ltd., 134 S.Ct. at 2360.
Accordingly, the claims are not patent eligible under 35 U.S.C. 101.
Allowable Subject Matter
The prior art of record, in particular Podgurny et al., Amit and Xu et al., fail to disclose a computer implemented task management system comprising accumulating revised task information for the plurality of persons in charge in a task management table to manage the task information across multiple generations of persons in charge wherein revised task information comprising determining a year for date information that is in a format lacking a year so that a start date and a deadline date in each piece of the task information correspond to the responsibility period of the respective person in charge based on acquired task information representing work related operation as a task of a person in charge work-related operations for each of a plurality of persons in charge, the task information representing tasks of each person in charge and a responsibility period of [[the]] each person in charge of the work-related operations, the responsibility period being defined by a start date and an end date of a tenure of the person in charge as claimed in Claims 1, 5 and 6.
Claims remain patent ineligible under 35 U.S.C. 101, see discussion above.
Conclusion
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.
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SCOTT L. JARRETT
Primary Examiner
Art Unit 3625
/SCOTT L JARRETT/Primary Examiner, Art Unit 3625
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