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 .
Information Disclosure Statement
The information disclosure statement filed 10/29/2024 fails to comply with 37 CFR 1.98(a)(2), which requires a legible copy of each cited foreign patent document; each non-patent literature publication or that portion which caused it to be listed; and all other information or that portion which caused it to be listed. It has been placed in the application file, but the information referred to therein has not been considered. More specifically, copies were not provided for foreign documents 101031915 and 10548851 and NPL with respect to Huang et al and Zhang et al.
Drawings
The drawings filed on: 09/26/2024 are accepted.
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 1-28 rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claim 1 Analysis:
101 Analysis Step 2A, Prong One
Claim 1 recites the following limitations (of which bolded limitations constitute a ‘mental process’ that covers performance of the limitations in the human mind).
A computer-implemented method comprising: processing a textual document to identify a plurality of identified factual citations based on a machine-learning model; normalizing each identified factual citation of the plurality of identified factual citations, resulting in a plurality of normalized identified factual citations; detecting at least one citation pattern in the plurality of normalized identified factual citations; generating at least one citation format rule based on the at least one citation pattern; and determining a plurality of factual citations from the textual document based on the at least one citation format rule.
As a note, steps fall within the mental process groupings of abstract ideas because they
cover concepts performed in the human mind, including observation, evaluation,
judgement and opinion (See MPEP 2106.04(a)(2), subsection III).
With respect to the particular limitations that were bolded above, these steps can be practically performed in the human mind using observation, evaluation, judgment and/or opinion. For example, the particular limitations encompass: 1) evaluating a textual document to identify a plurality of identified factual citation based on information about a machine learning model, and making a judgement on a plurality of normalized identified factual citations, 2) evaluating the plurality of normalized identified factual citations and making a judgement on identifying a citation pattern, 3) evaluating the citation pattern and making a judgement on a citation format rule, 4) evaluating the at least one citation format rule and making a judgement of a plurality of factual citations based on the evaluation.
101 Analysis Step 2A, Prong Two
With regards to the following additional elements of:
“A computer implemented method …”, “.. processing …”, “generating…”– these additional elements are considered merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea,. More specifically, these elements apply a judicial exception to a generic computer that employs generic computer functions (execution of steps and producing output based on the execution). The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
101 Analysis Step 2B
The claim does not amount to significantly more than the recited exception:
With regards to the following additional elements of:
“A computer implemented method …”, “.. processing …”, “generating…”– these additional elements are considered merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea,. More specifically, these elements apply a judicial exception to a generic computer that employs generic computer functions (execution of steps and producing output based on the execution). The courts have identified these types of limitations as insufficient to qualify as ‘significantly more’ when recited in a claim with a judicial exception.
101 Analysis for claims 2-14:
Claims 2-14 do not recite any further limitations that cause the claim to be patent
eligible. Rather, the limitations of dependent claims are directed toward additional
aspects of the judicial exception that do not integrate the judicial exception into a
practical application nor amount to significantly more than the judicial exception. For example aside from common additional elements mentioned in claim 1, these claims recite additional elements including :
“… machine learning model …”, this additional element is considered merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea,. More specifically, this element applies a judicial exception to a generic computer. The courts have identified these types of limitations as insufficient to qualify as ‘significantly more’ when recited in a claim with a judicial exception.
“… receive/receiving …”, these additional elements are considered adding insignificant extra-solution activity to the judicial exception. More specifically it is considered ‘mere data gathering’ that courts have found to be insignificant extra solution activity (see Obtaining information about transactions using the Internet to verify credit card transactions, CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 99 USPQ2d 1690, 1694 (Fed. Cir. 2011)). The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
“displaying …”, this additional element is considered adding insignificant extra-solution activity to the judicial exception. More specifically selecting a data source to be manipulated (such as manipulated to be displayed on a display) is an insufficient extra solution activity. The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
“updating …”/”storing”/”replacing”, these additional elements are considered adding insignificant extra-solution activity to the judicial exception. More specifically it is considered ‘mere data gathering’ that courts have found to be insignificant extra solution activity (see Consulting and updating an activity log, Ultramercial, 772 F.3d at 715, 112 USPQ2d at 1754). The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
Thus the additional elements of these dependent claims are directed to ‘apply it’ or insignificant extra solution activity, and thus these claims are insufficient to integrate the judicial exception into a practical application and insufficient to amount to significantly more than the judicial exception.
101 Analysis for claim 16:
Claim 16 is rejected under similar rationale as claim 1 above. The examiner notes that it additionally recites additional elements of system and processor. These additional elements are considered applying a generic computer to perform the judicial exception. As explained above, these additional elements are insufficient to integrate the judicial exception into a practical application and insufficient to amount to significantly more than the judicial exception.
101 Analysis for claims 17-27:
Claims 17-27 do not recite any further limitations that cause the claim to be patent
eligible. Rather, the limitations of dependent claims are directed toward additional
aspects of the judicial exception that do not integrate the judicial exception into a
practical application nor amount to significantly more than the judicial exception. For example aside from common additional elements mentioned in claim 16, these claims recite additional elements including :
“… machine learning model …”, this additional element is considered merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea,. More specifically, this element applies a judicial exception to a generic computer. The courts have identified these types of limitations as insufficient to qualify as ‘significantly more’ when recited in a claim with a judicial exception.
“… receive/receiving …”, these additional elements are considered adding insignificant extra-solution activity to the judicial exception. More specifically it is considered ‘mere data gathering’ that courts have found to be insignificant extra solution activity (see Obtaining information about transactions using the Internet to verify credit card transactions, CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375, 99 USPQ2d 1690, 1694 (Fed. Cir. 2011)). The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
“displaying …”, this additional element is considered adding insignificant extra-solution activity to the judicial exception. More specifically selecting a data source to be manipulated (such as manipulated to be displayed on a display) is an insufficient extra solution activity. The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
“updating …”/”storing”/”replacing”, these additional elements are considered adding insignificant extra-solution activity to the judicial exception. More specifically it is considered ‘mere data gathering’ that courts have found to be insignificant extra solution activity (see Consulting and updating an activity log, Ultramercial, 772 F.3d at 715, 112 USPQ2d at 1754). The courts have identified these types of limitations as insufficient to integrate a judicial exception into a practical application.
Thus the additional elements of these dependent claims are directed to ‘apply it’ or insignificant extra solution activity, and thus these claims are insufficient to integrate the judicial exception into a practical application and insufficient to amount to significantly more than the judicial exception.
101 Analysis for claim 28:
Claim 28 is rejected under similar rationale as claim 1 above. The examiner notes that it additionally recites additional elements of system and processor. These additional elements are considered applying a generic computer to perform the judicial exception. As explained above, these additional elements are insufficient to integrate the judicial exception into a practical application and insufficient to amount to significantly more than the judicial exception.
Double Patenting
A rejection based on double patenting of the “same invention” type finds its support in the language of 35 U.S.C. 101 which states that “whoever invents or discovers any new and useful process... may obtain a patent therefor...” (Emphasis added). Thus, the term “same invention,” in this context, means an invention drawn to identical subject matter. See Miller v. Eagle Mfg. Co., 151 U.S. 186 (1894); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Ockert, 245 F.2d 467, 114 USPQ 330 (CCPA 1957).
A statutory type (35 U.S.C. 101) double patenting rejection can be overcome by canceling or amending the claims that are directed to the same invention so they are no longer coextensive in scope. The filing of a terminal disclaimer cannot overcome a double patenting rejection based upon 35 U.S.C. 101.
Claims 1-28 is/are rejected under 35 U.S.C. 101 as claiming the same invention as that of claims 1-28 of prior U.S. Patent No. 11501072. This is a statutory double patenting rejection.
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(s) 1, 4, 5, 16, 19, 20, 28 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018).
With regards to claim 1, Councill teaches a computer-implemented method comprising:
processing a textual document to identify a plurality of identified factual citations based on a … model (page 661 right column, page 662, left column: a document is processed for citations/’reference strings’ using an associated CRF model, where the CRF model applies a sliding window upon token data to tag a citation/reference sequence);
normalizing each identified factual citation of the plurality of identified factual citations, resulting in a plurality of normalized identified factual citations (page 662: right column page 663, left column , the reference strings are tagged and then normalized (such as name normalization and page number normalization));
detecting at least one citation pattern in the plurality of normalized identified factual citations (page 663, left column: at least one citation pattern is detected post normalization);
generating at least one citation format rule based on the at least one citation pattern (page 663, left column: at least one citation pattern is generated as a regular expression); and
determining a plurality of factual citations from the textual document based on the at least one citation format rule (page 663, left column: the regular expression is used to analyze the body text).
However although Councill teaches a model is applied to identify/tag a target information (reference/citation data), Council does not expressly say this model is a machine learning model.
Yet Bergeron et al teaches the model is a machine learning model (Abstract, Fig. 5, paragraphs 0012-0013, 0015, 0033, 0048: identification of target information (citation) is located with a computer implemented process (having at least a processor and medium) by invoking a model (such as classification model) that applies a sliding window to score and identify tokens of text that contain the target information (addresses) ).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill’s ability to apply a model to identify target information (citations/references) in token text, such that the type of model used to identify the target information is a machine learning model, as taught by Bergeron et al. The combination would have allowed Councill’s ability to automatically located desired information in a cost effective and efficient manner (Bergeron et al, paragraph 0015).
With regards to claim 4. The computer-implemented method of claim 1, Councill and Bergeron et al wherein the machine-learning model comprises a classification model configured to receive a text fragment as input and output a classification, as similarly explained in the rejection of claim 1 (the combination was explained to teach that text fragments are tagged/identified using a classifier model), and is rejected under similar rationale.
With regards to claim 5. The computer-implemented method of claim 1, the combination of Councill and Bergeron et al teaches further comprising: processing the plurality of normalized identified factual citations, as similarly explained in the rejection of claim 1, and is rejected under similar rationale.
However Councill and Bergeron et al does not expressly teach … based on at least one rule-based algorithm to eliminate at least one normalized identified factual citation of the plurality of normalized identified factual citations before generating the at least one citation format rule.
Yet Bergeron et al teaches … based on at least one rule-based algorithm to eliminate at least one … identified [target entity] of the plurality of … identified [target entities] before generating [the best selection]/rule (paragraph 0049: potential identified target entities are identified within sliding text windows, and each of the potential target entities are scored to select a best target entity).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill and Bergeron et al’s ability to identify a format rule based upon identification of a target entity (factual citation), such that the target entity would have undergone a scoring of potential target entities found in the windows, and selected a single target entity as the target entity, as taught by Bergeron et al. The combination would have automatically located desired information in a cost effective and efficient manner (Bergeron et al, paragraph 0015).
With regards to claim 16, Council and Bergeron teaches a system comprising at least one processor programmed or configured to: process a textual document to identify a plurality of identified factual citations based on a machine-learning model; normalize each identified factual citation of the plurality of identified factual citations, resulting in a plurality of normalized identified factual citations; detect at least one citation pattern in the plurality of normalized identified factual citation; generate at least one citation format rule based on the at least one citation pattern; and determine a plurality of factual citations from the textual document based on the at least one citation format rule, as similarly explained in the rejection of claim 1, and is rejected under similar rationale.
With regards to claim 19. The system of claim 16, Council and Bergeron teaches wherein the machine-learning model comprises a classification model configured to receive a text fragment as input and output a classification, as similarly explained in the rejection of claim 4, and is rejected under similar rationale.
With regards to claim 20. The system of claim 16, Council and Bergeron teaches wherein the at least one processor is further configured to: process the plurality of normalized identified factual citations based on at least one rule-based algorithm to eliminate at least one normalized identified factual citation of the plurality of normalized identified factual citations before generating the at least one citation format rule, as similarly explained in the rejection of claim 5, and is rejected under similar rationale.
With regards to claim 28, Council and Bergeron teaches a computer program product comprising at least one non-transitory computer-readable medium including program instructions that, when executed by at least one processor, cause the at least one processor to: process a textual document to identify a plurality of identified factual citations based on a machine-learning model; normalize each identified factual citation of the plurality of identified factual citations, resulting in a plurality of normalized identified factual citations; detect at least one citation pattern in the plurality of normalized identified factual citation; generate at least one citation format rule based on the at least one citation pattern; and determine a plurality of factual citations from the textual document based on the at least one citation format rule, as similarly explained in the rejection of claim 1, and is rejected under similar rationale.
Claim(s) 2, 3, 17 and 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of Leeman-Munk et al (US Patent: 11074412, issued: Jul. 27, 2021, filed: Mar. 16, 2021).
With regards to claim 2. The computer-implemented method of claim 1, Councill and Bergeron et al teaches further comprising: tokens corresponding to strings in the textual document ….. the machine learning model, as similarly explained in the rejection of claim 1, and is rejected under similar rationale.
However although Councill and Bergeron et al teaches processing tokens of strings with the machine learning model, Councell and Bergeron et al does not expressly teach tokenizing the textual document into a plurality of tokens corresponding to strings in the textual document before processing the textual document with the machine-learning model.
Yet Leeman-Munk et al teaches tokenizing the textual document into a plurality of tokens corresponding to strings in the textual document before processing the textual document with the machine-learning model (column 1, lines 15-65, Fig. 2A: a tokenizer is executed prior to using a classifier network model and finite window size (window of a number of adjacent tokens having a potential target token) is gradually stepped down based upon desired accuracy).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill and Bergeron et al’s ability to use a machine learning model with tokens of a source document to identify target content (factual citations), such that the source document’s strings are tokenized in any configurable window size, prior to processing using the machine learning model to identify the target content, as taught by Leeman-Munk et al. The combination would have allowed use of a tokenizer that can implementing an optimal window size based on target performance criteria.
With regards to claim 3. The computer-implemented method of claim 2, the combination of Councill, Bergeron et al and Leeman-Munk et al teaches wherein the machine-learning model is configured to receive, as input, a group of tokens of the plurality of tokens and output a prediction, the group of tokens comprising a target token, between 1 and 20 adjacent tokens preceding the target token, and between 1 and 20 adjacent tokens succeeding the target token, and wherein the plurality of identified factual citations is based on predictions for each token of the plurality of tokens, as similarly explained in the rejection of claim 2 (the combination of Councill and Bergeron et al’s processing of tokenized text that is provided into a machine learning model was modified such that a window of tokenized text can be numerically configurable in any size that would achieve a desired accuracy, and thus encompasses a range such as any window size such as a window size in the 40’s or less (i.e. 41 token size for 20 before and 20 after , or configurable to be less)), and is rejected under similar rationale.
With regards to claim 17. The system of claim 16, the combination of Councill, Bergeron et al and Leeman-Munk et al teaches wherein the at least one processor is further configured to: tokenize the textual document into a plurality of tokens corresponding to strings in the textual document before processing the textual document with the machine-learning model, as similarly explained in the rejection of claim 2, and is rejected under similar rationale.
With regards to claim 18. The system of claim 17, the combination of Councill, Bergeron et al and Leeman-Munk et al teaches wherein the machine-learning model is configured to receive, as input, a group of tokens of the plurality of tokens and output a prediction, the group of tokens comprising a target token, between 1 and 20 adjacent tokens preceding the target token, and between 1 and 20 adjacent tokens succeeding the target token, and wherein the plurality of identified factual citations is based on predictions for each token of the plurality of tokens, as similarly explained in the rejection of claim 3, and is rejected under similar rationale.
Claim(s) 6-9, 12 and 21-24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of Armstrong (US Application: US 20060287971, published: Dec. 21, 2006, filed: Jun. 15, 2005).
With regards to claim 6. The computer-implemented method of claim 1, the combination of Councill and Bergeron et al teaches further comprising: … each factual citation of the plurality of factual citations, as similarly explained in the rejection of claim 1, and is rejected under similar rationale.
However the combination does not expressly teach … linking at least one source document from a plurality of source documents to each factual citation of the plurality of factual citations.
Yet Armstrong teaches … linking at least one source document from a plurality of source documents to each factual citation of the plurality of factual citations (Abstract, paragraphs 0021, 0028, 0029, 0032-0036: a user can select/identify quotation(s) on a page and hyperlink(s) can be established/inserted into each of the quotation(s) to corresponding source document(s) location/page automatically searched/obtained).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill and Bergeron et al’s ability to identify citations in a document, such that the citations identified could have been available to the user for interaction/linking to view other documents, as taught by Armstrong et al. The combination would have allowed Councill and Bergeron et al to have allowed easy identification of all sources that have quoted a document.
With regards to claim 7. The computer-implemented method of claim 6, the combination of Councill, Bergeron et al and Armstrong et al teaches wherein linking the at least one source document to each factual citation of the plurality of factual citations comprises: inserting a hyperlinked citation into each factual citation which, when selected by a user, displays at least one corresponding source document, as similarly explained in the rejection of claim 6 (Armstrong et al, Abstract, paragraphs 0021, 0028, 0029: a user can select/identify quotation(s) on a page and hyperlink(s) can be established/inserted into each of the quotation(s) to corresponding source document(s) location/page), and is rejected under similar rationale.
With regards to claim 8. The computer-implemented method of claim 6, the combination of Councill, Bergeron et al and Armstrong et al teaches further comprising: prompting a user for input prior to linking the at least one source document, as similarly explained in the rejection of claim 6 (Armstrong et al, Abstract, paragraphs 0021, 0028, 0029: a user can select/identify quotation(s) on a page and hyperlink(s) can be established/inserted into each of the quotation(s) to corresponding source document(s) location/page), and is rejected under similar rationale..
With regards to claim 9. The computer-implemented method of claim 6, the combination of Councill, Bergeron et al and Armstrong et al teaches further comprising: displaying the at least one source document; and receiving a selection from a user of a page from the at least one source document, wherein linking the at least one source document to each factual citation of the plurality of factual citations is based on the page selected, as similarly explained in the rejection of claim 6 (Armstrong et al, Abstract, paragraphs 0021, 0028, 0029: a user can select/identify quotation(s) on a page and hyperlink(s) can be established/inserted into each of the quotation(s) to corresponding source document(s) location/page), and is rejected under similar rationale.
With regards to claim 12. The computer-implemented method of claim 6, the combination of Councill, Bergeron et al and Armstrong et al teaches further comprising: receiving the plurality of source documents from a user, wherein linking the at least one source document from the plurality of source documents is performed automatically without user intervention, as similarly explained in the rejection of claim 6 (Abstract, paragraphs 0021, 0028, 0029, 0032-0036: a user can select/identify quotation(s) on a page and hyperlink(s) can be established/inserted into each of the quotation(s) to corresponding source document(s) location/page automatically searched/obtained), and is rejected under similar rationale.
With regards to claim 21. The system of claim 16, wherein the at least one processor is further configured to: link at least one source document from a plurality of source documents to each factual citation of the plurality of factual citations, as similarly explained in the rejection of claim 6, and is rejected under similar rationale.
With regards to claim 22. The system of claim 21, wherein linking the at least one source document to each factual citation of the plurality of factual citations comprises: inserting a hyperlinked citation into each factual citation which, when selected by a user, displays at least one corresponding source document, as similarly explained in the rejection of claim 7, and is rejected under similar rationale.
With regards to claim 23. The system of claim 21, wherein the at least one processor is further configured to: prompt a user for input prior to linking the at least one source document, as similarly explained in the rejection of claim 8, and is rejected under similar rationale.
With regards to claim 24. The system of claim 21, wherein the at least one processor is further configured to: display the at least one source document; and receive a selection from a user of a page from the at least one source document, wherein linking the at least one source document to each factual citation of the plurality of factual citations is based on the page selected, as similarly explained in the rejection of claim 9, and is rejected under similar rationale.
Claim(s) 10 and 25 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of Armstrong (US Application: US 20060287971, published: Dec. 21, 2006, filed: Jun. 15, 2005) in view of Rogynskyy et al (US Application: US 2020/0372075, published: Nov. 26, 2020, filed: May 21, 2020).
With regards to claim 10. The computer-implemented method of claim 8, the combination of Councill, Bergeron et al and Armstrong teaches … the machine learning model … and … the input , as similarly explained in the rejection of claim 8, and is rejected under similar rationale.
However the combination does not expressly teach … further comprising updating the machine-learning model based on the input.
Yet Rogynskyy et al teaches updating the machine-learning model based on the input (paragraph 0217: a machine learning model is updated when the user input identifies a location of an electronic activity document (target entity) to a source record)).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill, Bergeron et al, Armstrong et al’s ability to use a model to correlate a citation / target entity to a document (using a model and user input), such that the model gets updated (along with its rules) when a user updates the correlation/assignment of the target entity to the source, as taught by Rogynskyy et al. The combination would have allowed a citation linking application that is adapts and reacts to user input histor(ies).
With regards to claim 25. The system of claim 23, Councill, Bergeron et al, Armstrong et al and Rogynskyy et al teaches wherein the at least one processor is further configured to update the machine-learning model based on the input, as similarly explained in the rejection of claim 10, and is rejected under similar rationale.
Claim(s) 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of Armstrong (US Application: US 20060287971, published: Dec. 21, 2006, filed: Jun. 15, 2005) in view of Rosenoff et al (US Patent: 7003719, issued: Feb. 21, 2006, filed: Jan. 25, 1999).
With regards to claim 11. The computer-implemented method of claim 8, the combination of Councill, Bergeron et al and Armstrong teaches …wherein the input … a source document for at least one factual citation, as similarly explained in the rejection of claim 8, and is rejected under similar rationale.
However the combination does not teach …. comprises uploading or identifying a location of a source document for at least one factual citation, the method further comprising: determining a page corresponding to the at least one factual citation based on comparing text to pages in the source document.
Yet Rosenoff et al teaches comprises uploading or identifying a location of a source document for at least one factual citation, the method further comprising: determining a page corresponding to the at least one factual citation based on comparing text to pages in the source document (column 2, lines 58-67, claim 1 and claim 3 , Fig. 3: of Rosenoff et al: a hyperlink associated with citation can reference a specific portion of a page of a content. The citation links to a portion of content/documents by searching through the source document by comparing text retained by hyperlink to the page ).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Council, Bergeron et al and Armstrong’s ability to modify a citation by including a link to a source document, such that the citation having the link would have further referenced a page number (offset) , as taught by Rosenoff et al. The combination would have allowed implementation of robust hyperlinks even if documents being referenced be moved to a different location.
Claim(s) 13 and 26 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of Armstrong (US Application: US 20060287971, published: Dec. 21, 2006, filed: Jun. 15, 2005) in view of Rosenoff et al (US Patent: 7003719, issued: Feb. 21, 2006, filed: Jan. 25, 1999).
With regards to claim 13. The computer-implemented method of claim 6, the combination of Councill, Bergeron et al and Armstrong teaches … the page corresponding to the at least one factual citation , as similarly explained in the rejection of claim 6, and is rejected under similar rationale.
However the combination does not expressly teach … further comprising: determining a page offset value based on the page corresponding to the at least one factual citation and a structure of the at least one source document; and modifying the at least one factual citation based on the page offset value.
Yet Rosenoff et al teaches … further comprising: determining a page offset value based on the page corresponding to the at least one factual citation and a structure of the at least one source document; and modifying the at least one factual citation based on the page offset value (column 2, lines 58-67, claim 1 and claim 3 , Fig. 3: of Rosenoff et al: a hyperlink associated with citation can reference a specific portion of a page of a content ).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill, Bergeron et al and Armstrong’s ability to modify a citation by including a link to a source document, such that the citation having the link would have further referenced a page number (offset) , as taught by Rosenoff et al. The combination would have allowed implementation of robust hyperlinks even if documents being referenced be moved to a different location.
With regards to claim 26. The system of claim 21, Councill, Bergeron et al, Armstrong and Rosenoff et al teaches wherein the at least one processor is further configured to: determine a page offset value based on the page corresponding to the at least one factual citation and a structure of the at least one source document; and modify the at least one factual citation based on the page offset value, as similarly explained in the rejection of claim 13, and is rejected under similar rationale.
Claim(s) 14 and 27 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of DeLuca et al (US Application: US 2018/0067912, issued: Mar. 8, 2018, filed: Sep. 7, 2016).
With regards to claim 14. The computer-implemented method of claim 1, further comprising: storing the at least one citation format rule, as similarly explained in the rejection of claim 1, and is rejected under similar rationale.
However the combination does not expressly … in association with at least one of the following: a user, an entity, a source document, or any combination thereof; and processing a subsequent textual document based on the at least one citation format rule.
Yet DeLuca et al teaches … at least … format rule, in association with at least one of the following: a user, an entity, a source document, or any combination thereof; and processing a subsequent textual document based on the at least one … format rule (Abstract, Fig. 4, paragraphs 0019, 0068, 0071: profile data include style and phrasing patterns , which is used to apply to subsequent text data (document) that is entered) .
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill and Bergeron et al’s ability to obtain/store a citation format rule, such that the format rule could have been associated with the user for subsequent document processing, as taught by DeLuca et al. The combination would have allowed Councill and Bergeron et al to have helped preserved prior tendencies/preferences specific to the user.
With regards to claim 27. The system of claim 16, the combination of Councill, Bergeron et al and DeLuca et al teaches wherein the at least one processor is further configured to: store the at least one citation format rule in association with at least one of the following: a user, an entity, a source document, or any combination thereof; and process a subsequent textual document based on the at least one format citation rule, as similarly explained in the rejection of claim 14, and is rejected under similar rationale.
Claim(s) 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Councill (“ParsCit: An open-source CRF reference string parsing package”, published: 2008, pages 661-667) in view of Bergeron et al (US Application: US 2020/0210442, published: Jul. 2, 2020, filed: Dec. 27, 2018) in view of Leeman-Munk et al (US Patent: 11074412, issued: Jul. 27, 2021, filed: Mar. 16, 2021) in view of Matzkel et al (US Patent: 9338139, issued: May 10, 2016, filed: Dec. 30, 2010).
With regards to claim 15. The computer-implemented method of claim 2, the combination of Councill, Bergeron et al and Leeman-Munk et al teaches wherein tokenizing the textual document into the plurality of tokens, as similarly explained in the rejection of claim 2, and is rejected under similar rationale.
However the combination does not expressly teach tokenizing … comprises at least one of the following: replacing lower case words in the textual document with a token comprising a lowercase indicator; replacing upper case words in the textual document with a token comprising an uppercase indicator; and replacing title case words in the textual document with a token comprising a titlecase indicator.
Yet Matzkel et al teaches tokenizing … comprises at least one of the following: replacing lower case words in the textual document with a token comprising a lowercase indicator; replacing upper case words in the textual document with a token comprising an uppercase indicator; and replacing title case words in the textual document with a token comprising a titlecase indicator (Fig. 6, column 10, lines 43-50: uppercase words are replaced with lower case versions and the lower case versions include control tokens that comprise an uppercase indicator).
It would have been obvious to one of ordinary skill in the art before the effective filing of the invention to have modified Councill, Bergeron et al and Leeman-Munk et al’s ability to perform tokenizing, such that the tokenizing would have included usage of a case indicator /token to signal the upper case was in the original word/text, as taught by Matzkel et al. The combination would have allowed the ability to retain information for how case was originally used in a word.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Burns et al (US application: US 2007/0239704): This reference teaches aggregating citation information from disparate documents.
Calapodescu et al (US Application: US 20170300565): This reference teaches entity extraction from text documents.
Rolle (US Application: US 2009/0187567): This reference teaches determine valid citation patterns in electronic documents.
Zholudev et al (US Application: US 2016/0342591): This reference teaches linking documents using citations.
Schafer et al (US Patent: 11194963): This reference teaches citation analysis, generating a suggested list of references, as well as confirming proper format of citations.
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/WILSON W TSUI/Primary Examiner, Art Unit 2172
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