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 .
Applicant’s submission of a Response
Applicant’s submission of a response was received on 08/07/2026. Presently, claims 1-20 are pending.
Response to Arguments
Applicant's arguments filed 08/07/2026 have been fully considered but they are not persuasive. Claims have overcome each and every objection and 112(b) rejection previously set forth in the Office Action mailed 05/07/2026. Applicant’s representative asserts that the amended claims limitations are not met. However, in light of the amendments to the claims, new rejection(s) under 35 U.S.C. 103 have been presented, as discussed in detail below.
In regards to rejections under 35 U.S.C. §101, applicant asserts the following: “For example, as described at paragraph [0035] of the Specification, casino management systems (CMSs) are proprietary systems that do not communicate with different proprietary CMSs, and therefore, are incompatible with each other. As described further at paragraph [0051], this creates a technical problem for tracking player activity that retrieves player activity from and distributes player activity to multiple venue systems, as the venue systems may do not share compatible player tracking systems or use different data formats. Claim 1 solves this technical problem by receiving data from different venue systems, which may utilize different data formats, associating the received data with a particular user based on based on a linking between the stored value account associated with the first user and a plurality of loyalty accounts associated with the first user, and updating global activity records stored in a standardized table associated with the user based on the received data. The global activity records may track the user's activity across all venue systems and be used, for example, to enforce responsible gaming limits based on this activity, even in cases in which the venues themselves are not capable of communicating directly with one another.” (Page 10 of Remarks)
Regarding point (1), the examiner respectfully disagrees.
In response to the arguments above, the application does mention receiving data from different venue systems, which may utilize different data formats. However, the specification does not mention “updating global activity records stored in a standardized table associated with the user based on the received data”. (See 101 rejection below).
In regards to rejections under 35 U.S.C. §102, applicant asserts the following: “Anbazhagan is silent with respect to receiving user activity data from different venue systems that utilize different data formats for generating user activity data. For this reason, the system described in Anbazhagan does not provide the benefit of enabling user activity to be tracked across different systems that are incompatible and/or incapable of communicating with one another.” (Page 12 of Remarks).
Regarding point (2), the examiner notes that Anbazhagan alone is not relied upon to teach these limitations.
In response to the arguments above, the office relies on newly found prior art of Benton et al. (US 20220300636 A1) to teach that user activity data has different formats. (See 103 Rejection below)
Regarding claim 12, since it recites similar features to claim 1, the rejection is maintained as present below.
Applicant’s representative argues that since the prior art does not disclose or suggest the suggested features of claim 1 or 12 and so, dependent claims are patentable. However, in light of the remarks and standing rejection below, the examiner asserts the prior art of record teaches all the elements as claimed and these elements satisfy all structural, functional, operational, and spatial limitations currently in the claims. Therefore, the standing rejections are proper and maintained.
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 a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. The claims are directed to at least one of abstract idea groupings, according to the 2019 Revised Patent Subject Matter Guidelines (Mathematical Concepts, Mental Processes and/or Certain Methods of Organizing Human Activity). Further, the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception as discussed below.
Step 1 of the 2019 Revised Patent Subject Matter Eligibility Guidance
More specifically, regarding Step 1 of the 2019 Revised Patent Subject Matter Eligibility Guidance, the claims are directed to a system and/or process, which is are statutory categories of invention.
Step 2A-1 of the 2019 Revised Patent Subject Matter Eligibility Guidance
Next, the claims are analyzed to determine whether it is directed to a judicial exception.
Independent claim 1 recites the following, with the abstract ideas highlighted in bold, including an indication as to the abstract idea grouping(s) to which the indicated limitations belong to, according to the 2019 Revised Patent Subject Matter Guidelines. Independent claims 12 and 20, having substantially similar features, were also analyzed and to which the following conclusion is also applicable:
A computer system comprising: at least one memory device configured to store a global customer database, the global customer database including global user activity records, each of the global user activity records associated with (i) a user, (ii) a stored value account associated with the user and stored within a master leger ledger, and (iii) responsible gaming (RG) limits associated with the user; at least one processor in communication with the at least one memory device and a plurality of venue systems each including at least one gaming device, each of the plurality of venue systems configured to generate user activity data having a respective data format of a plurality of data formats, wherein the at least one processor is configured to execute instructions which, when executed by the at least one processor, cause the at least one processor to: receive the user activity data from the plurality of venue systems associated with a plurality of different venues, the user activity data including data having at least a first data format and a second data format of the plurality of data formats, the first data format different from the second data format, the user activity data relating to user activity at gaming devices at the plurality of different venues; store the user activity data in the global customer database in a standardized table; identify the user activity as relating to a first user based on a linking between the stored value account associated with the first user and a plurality of loyalty accounts associated with the first user and with a corresponding one of the plurality of venue systems; update the global user activity records stored in the standardized table associated with the first user based on the received user activity data; determine that the first user is establishing a session at a first venue of the plurality of different venues based on a linking between the stored value account associated with the first user and a first loyalty account associated with the first user and the first venue; and transmit the global user activity records associated with the first user to a first venue system of the plurality of venue systems that is associated with the first venue, the transmitted global user activity records configured to be compared to the RG limits.
The limitations in claim 1 (as well as claim(s) 12 and 20) recites an abstract idea included in the groupings of Mental Process, connected to technology only through application thereof using generic computing elements (e.g., computer with computing elements of a processor, memory, and databases, etc.) and/or insignificant extra-solution activity. According to the 2019 Revised Patent Subject Matter Guidelines:
Mental Processes include concepts performed in the human mind (including an observation, evaluation, judgement, opinion);
Specifically, the instant claims include functions/limitations, as highlighted in the independent claim above, that constitute at least:
D. Concepts performed in the human mind (e.g., “receiving user activity data, identify user activity, update global user activity records, determine that a first user is establishing a session, comparing global user activity records with RG limits”), which is an abstract idea included in the grouping of Mental Processes. These limitations are interpreted as at least Mental Processes insomuch as the claim limitations are directed to steps/concepts which are capable of being performed in the human mind, while only generically connected to interaction with a computer utilizing non-special purpose generic computing elements and/or insignificant extra-solution activity as set forth in the claims.
Regarding dependent claims 2-11 and 13-19:
Each claim is dependent either directly or indirectly from the independent claim identified above and includes all the limitations of said independent claim. Therefore, each dependent claim recites the same abstract idea as identified above. Each of the dependent claim further describes additional aspects of the abstract idea, i.e., additional aspects to the Mental Processes. For example, some dependent claims merely provide additional Mental Processes to be performed and/or additional insignificant extra-solution activity, without anything more significant to establish eligibility under 35 U.S.C. 101.
Step 2A-2 of the 2019 Revised Patent Subject Matter Eligibility Guidance
The second prong of step 2a is the consideration if the claim limitations are directed to a practical application.
Limitations that are indicative of integration into a practical application:
-Improvements to the functioning of a computer, or to any other technology or technical field - see MPEP 2106.05(a)
-Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition – see Vanda Memo
-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)
-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) and Vanda Memo
Limitations that are not indicative of integration into a practical application:
-Adding the words “apply it” (or an equivalent) with the judicial exception, or mere 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(f)
-Adding insignificant extra-solution activity to the judicial exception - see MPEP 2106.05(g)
-Generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.05(h)
Claims 1-20 clearly do not improve the functioning of a computer, as they only incorporate generic computing elements, do not affect a particular treatment, and do not transform or reduce a particular article to a different state or thing. Similarly, there is no improvement to a technical field. In addition the claims do not apply the judicial exception with, or by use of a particular machine. The claims do not apply or use the judicial exception in a meaningful way. The claimed invention does not suggest improvements to the functioning of a computer or to any other technology or technical field (see MPEP 2106.05 (a)).
This judicial exception is not integrated into a practical application because the claimed invention merely applies the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform the abstract idea (MPEP 2106.05 (f)) and/or generally links the use of the judicial exception to a particular technology or field of use (MPEP 2106.05 (h)). The claimed computer components are recited at a level of generality and are merely invoked as tool to perform the abstract idea. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea.
For the reasons as discussed above, the claim limitations are not integrated to a practical application.
Step 2b of the 2019 Revised Patent Subject Matter Eligibility Guidance
Next, the claims as a whole are analyzed to determine whether any element, or combination of elements, is sufficient to ensure that the claim amounts to significantly more than the exception.
The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because no element or combination of elements is sufficient to ensure any claim of the present application as a whole amounts to significantly more than one or more judicial exceptions, as described above. For example, the recitations of utilization of “computer with computing elements of a processor, memory, and databases”, etc. used to apply the abstract idea merely implements the abstract idea at a low level of generality and fail to impose meaningful limitations to impart patent-eligibility. These elements and the mere processing of data using these elements do not set forth significantly more than the abstract idea itself applied on general purpose computing devices. The recited generic elements are a mere means to implement the abstract idea. Thus, they cannot provide the “inventive concept” necessary for patent-eligibility. “[I]f a patent’s recitation of a computer amounts to a mere instruction to ‘implement]’ an abstract idea ‘on ... a computer,’... that addition cannot impart patent eligibility.” Alice, 134 S. Ct. at 2358 (quoting Mayo, 132 S. Ct. at 1301). As such, the significantly more required to overcome the 35 U.S.C. 101 hurdle and transform the claimed subject matter into a patent-eligible abstract idea is lacking. Accordingly, the claims are not patent-eligible.
In addition to the abstract ideas indicated above, the claims include additional elements, such as:
“a stored value account associated with the user and stored within a master leger”
As claimed, these additional elements are viewed as mere Data Gathering, which is a form of insignificant extra-solution activity and thus does not integrate the judicial exception into a practical application (See MPEP 2106.05(g)).
Further, in order to be eligible the claims would require structure that is beyond generic. See Alice Corp. v. CLS Bank International, 134 S. Ct. at 2358-59. The elements of computer with computing elements of a processor, memory, and databases are well known conventional devices used to electronically implement managing data as evidenced by LEAHY et al. (US 20150309696 A1; hereinafter Leahy). Leahy discloses that a conventional computer is used to store, read, and modify data (¶25). See Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018). Furthermore, in regards to storing data in different formats, this process is well-known as evidenced by Fong et al. (US 20100049732 A1; hereinafter Fong), because it shows that a conventional database system receives and stores data in various formats (¶4).
The dependent claims do not add “significantly more” for at least the same reasons as directed to their respective independent claims, at least based on the position, as discussed above, that each of the dependent claims merely provide additional limitations to further expand the abstract idea of the independent claims, without adding anything which would establish eligibility under 35 U.S.C. 101.
Consequently, consideration of each and every element of each and every claim, both individually and as an ordered combination, leads to the conclusion that the claims are not patent-eligible under 35 USC §101.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1-20 rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention.
Claims 1 and 12 recite the following limitation: “store the user activity data in the global customer database in a standardized table” and “update the global user activity records stored in the standardized table” This limitation is not adequately described in the specification as originally filed and forms the basis of the rejection. As such, the limitations are reasonably rejected under a theory of new matter. Therefore, claims 1 and 12 is rejected under 35 U.S.C. § 112(a), as failing to comply with the written description requirement.
Claims 2-11 and 13-20 are rejected for dependent upon a rejected base claim.
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, 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.
Claims 1-8 and 10-20 are rejected under 35 U.S.C. 103 as being unpatentable over ANBAZHAGAN et al. (US 20230137728 A1; hereinafter Anbazhagan) in view of Benton et al. (US 20220300636 A1; hereinafter Benton).
Regarding claims 1, 12, and 20, Anbazhagan discloses a computer system (using computers in this system; ¶34) comprising: at least one memory device configured to store a global customer database (universal database 142; ¶12 and ¶74), the global customer database including global user activity records (user habit information is related to user activity; ¶35), each of the global user activity records associated with (i) a user (databases and data stores 140,142 may include user account; ¶35), (ii) a stored value account associated with the user (user account; ¶35) and stored within a master leger (user's account value stored on a ledger; ¶70), and (iii) responsible gaming (RG) limits associated with the user (user habit information; ¶35); at least one processor in communication with the at least one memory device (inherent to a computer) and a plurality of venue systems each including at least one gaming device (gaming systems across multiple jurisdictions indicates plurality of venues in different locations; abstract), wherein the at least one processor is configured to execute instructions (inherent to a computer) which, when executed by the at least one processor, cause the at least one processor to: receive user activity data from the plurality of venue systems associated with a plurality of different venues (player's gaming activity from multiple jurisdictions, which belong to different venues, is received on a single account; ¶71), the user activity data relating to user activity at gaming devices at the plurality of different venues (player's gaming activity; ¶71); identify the user activity as relating to a first user (user activity such as number of wins, money spent, etc. is identified on a leaderboard; ¶43) based on a linking between the stored value account associated with the first user and a plurality of loyalty accounts associated with the first user (user account and loyalty system are both linked by the databases; ¶35) and with a corresponding one of the plurality of venue systems (loyalty system implemented across jurisdictions indicates plurality of venues in different locations; ¶43); update the global user activity records associated with the first user based on the received user activity data (account activity will be updated and synchronized with the principal account; ¶69); determine that the first user is establishing a session at a first venue of the plurality of different venues (login session means the user started a session; ¶43) based on a linking between the stored value account associated with the first user and a first loyalty account associated with the first user and the first venue (user account and loyalty system are both linked by the databases; ¶35); and transmit global user activity records associated with the first user to a first venue system of the plurality of venue systems that is associated with the first venue (user can connect to different jurisdictions and any account activity is regularly synchronized across all the data centers to allow the user access to the same single account regardless of the geographic location; ¶68-69), the transmitted global user activity records configured to be compared to the RG limits (comparison of activity records happens because RG limits, such as spending limits, session time limits, or wagering limits are checked in order to see if the user has reached their limit; ¶112). In regards to additional limitations of claim 20, Anbazhagan discloses at least one non-transitory computer-readable storage media having instructions embodied thereon (inherent to a computer).
Anbazhagan does not explicitly disclose user activity data having a respective data format of a plurality of data formats, the user activity data including data having at least a first data format and a second data format of the plurality of data formats, the first data format different from the second data format; storing the user activity data in the global customer database in a standardized table; update the global user activity records stored in the standardized table.
However, Benton teaches user activity data having a respective data format of a plurality of data formats (data collection from a variety of formats; ¶27), the user activity data including data having at least a first data format and a second data format of the plurality of data formats, the first data format different from the second data format (user activity data included in ¶5 and data can be collected in different formats); storing the user activity data in the global customer database in a standardized table (normalizing and standardizing data into a universal format; ¶24); update the global user activity records stored in the standardized table (updating cloud database; ¶23).
Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Anbazhagan to implement the teachings of Benton because when data comes from multiple sources it will have different data formats and the system that stores the data needs to be able to store data in different formats or convert it to a standard format.
Regarding claims 2 and 13, Anbazhagan discloses wherein the instructions further cause the at least one processor to: receive an update to the RG limits associated with the first user (account activity will be updated and synchronized with the principal account; ¶69) from a mobile device associated with the first user (user has access to the system via mobile devices 122; ¶34); and update the RG limits stored in the global customer database (any account activity is regularly synchronized across all the data centers to allow the user access to the same single account regardless of the geographic location; ¶69).
Regarding claims 3, and 14, Anbazhagan discloses wherein the instructions further cause the at least one processor to, in response to updating the RG limits (account activity will be regularly updated and synchronized with the principal account; ¶69), transmit the updated RG limits to the plurality of venue systems (player's gaming activity from multiple jurisdictions, which belong to different venues, is accessed and it reflects the player's gaming activity; ¶71).
Regarding claims 4 and 15, Anbazhagan discloses wherein the venue systems are configured to, when receiving a transaction request associated with the first user (system allows for transactions; ¶78), determine to execute the transaction request based on a comparison between global user activity records associated with the first user and the RG limits associated with the first user (system determines to execute a transaction based on responsible gaming limits because once the user has reached a limit, the system would prevent the user from making further deposits; ¶112).
Regarding claims 5 and 16, Anbazhagan discloses wherein the transaction request is received from a gaming device of the first venue system (the system 100 allows for gaming and gambling in ¶33 and the system used for transactions in ¶104).
Regarding claims 6 and 17, Anbazhagan discloses wherein the transaction request is received from a mobile device associated with the first user (the system available to be used with mobile devices; ¶34).
Regarding claims 7 and 18, Anbazhagan discloses wherein the transaction request identifies a transaction amount (transactions such as deposits and withdrawals are communication with the user's account; ¶82) to transfer to a gaming device of the first venue system from a stored value account associated with the first user (a single user account used with a single wallet or other means such as a ledger in ¶81) and defined in a central ledger (user's account stores value on a ledger; ¶81).
Regarding claims 8 and 19, Anbazhagan discloses wherein the plurality of venue systems are further configured to end an active session associated with the first user in response to a determination that the RG limits associated with the first user are exceeded based on global user activity records associated with the first user (user has session time limits regardless of location if user has reached the limit imposed, it will prevent the user from staying in the session; ¶112).
Regarding claim 10, Anbazhagan discloses wherein the global user activity records are each further associated with a jurisdiction of a plurality of jurisdictions (the system itself, which includes the activity of the user is implemented across multiple jurisdictions; abstract), and wherein the RG limits are configured to be applied based on activity within the associated jurisdiction (user's access to different jurisdictions will be setup for compliance with laws and regulations of that jurisdiction which means that even their RG limits will be set to be compliant; ¶68).
Regarding claim 11, Anbazhagan discloses wherein the at least one processor is further configured to: receive, from a second venue system, a request to link (user account and loyalty system are both linked by the databases in ¶35 and because they are linked in a database, there is a backend request for this data to be linked) the stored value account associated with the first user to a second loyalty account associated with a second venue associated with the second venue system (loyalty program is not only applied to one location but also to a different location; ¶84), the request including identification information associated with the first user (all this data is also linked in the database with identification information, such as user information; ¶35); identify the stored value account associated with the first user based on the identification information associated with the first user (all this information is identified by the database linking all this data including user information; ¶35); and in response to identifying the stored value account associated with the first user, record a linking between the stored value account and the second loyalty account (databases inherently records links between data using the relationship between them; ¶35).
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, 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.
Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Anbazhagan in view of Stephen Capps (US 20150199873 A1; hereinafter Capps).
Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Anbazhagan in view of Benton as applied to claim 1 above, and further in view of Stephen Capps (US 20150199873 A1; hereinafter Capps).
Regarding claim 9, Anbazhagan discloses wherein the plurality of venue systems are further configured to cause a determination that the RG limits associated with the first user are exceeded based on global user activity records associated with the first user (user has session time limits, amount spent limits, or wagering limits ¶112 and this is based on global activity record because any account activity will be regularly updated in synchronized in ¶69).
Anbazhagan does not explicitly disclose the at least one gaming device to display a notification in response to a determination that the RG limits associated with the first user are exceeded. However, Capps teaches the at least one gaming device to display a notification in response to a determination that the RG limits associated with the first user are exceeded based (service provider may transmit a notification that the spending limit has been exceeded; ¶46).
Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Anbazhagan to implement the teachings of Capps because it would provide the user with a way to know that their RG limits are being reached or have been reached.
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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOSE ANGELES whose telephone number is (703)756-5338. The examiner can normally be reached Mon-Thu 8am-5pm.
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, Dmitry Suhol can be reached at (571) 272-4430. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/JOSE ANGELES/Examiner, Art Unit 3715
/Jay Trent Liddle/Primary Examiner, Art Unit 3715