DETAILED ACTION
Status of the Claims
The following is a Final Office Action in response to remarks filed 09 January 2026.
Claim 102 has been amended.
Claims 87-106 are pending and have been examined.
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Terminal Disclaimer
The terminal disclaimer filed on 09 January 2026 disclaiming the terminal portion of any patent granted on this application which would extend beyond the expiration date of 16/749,604 (now US Patent 12,141,754) has been reviewed and is accepted. The terminal disclaimer has been recorded.
Response to Arguments
Applicants argue that the 35 U.S.C. 101 rejection under the Alice Corp. vs. CLS Bank Int’l be withdrawn; however the Examiner respectfully disagrees. As an initial note, the arguments are not compliant under 37 CFR 1.111(b) as they amount to a mere allegation of patent eligibility, simply stating that prima facie rejection under §101. Contrary to Applicant’s assertion that prima facie case was not established by the Examiner, the Examiner respectfully disagrees and notes that the previous rejection did in fact note that the rejection of claim 87 indicated that there was no positive recitation of structure whatsoever and thus cannot integrate the claims nor amount to significantly more. As such, this argument is not persuasive, and the rejection not overcome. The Examiner suggests amending the claims to more positively recite the structure of the invention.
Applicant next argues that the claims are an improvement; however the Examiner respectfully disagrees. This argument appears to be whether or not the use of computer or computing components for increased speed and efficiency makes the claims eligible; however the Examiner respectfully disagrees. Nor, in addressing the second step of Alice, does claiming the improved speed or efficiency inherent with applying the abstract idea on a computer provide a sufficient inventive concept. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted)). This argument also appears to be that the claims are patent eligible due to the arguments regarding the §103 rejections; however, the Examiner asserts that subject matter eligibility and novelty/non-obviousness are two separate inquires, neither being a benchmark for the other. See Amdocs Ltd. v. Openet Telecom, Inc., 841 F.3d 1288, 1311 (Fed. Cir. 2016) (“Novelty is the question of whether the claimed invention is new. Inventiveness is the question of whether the claimed matter is invention at all, new or otherwise. The inventiveness inquiry of § 101 should therefore not be confused with the separate novelty inquiry of § 102 or the obviousness inquiry of § 103.”). As such, this argument is not persuasive, and the rejection not overcome.
In response to arguments in reference to any depending claims that have not been individually addressed, all rejections made towards these dependent claims are maintained due to a lack of reply by the Applicants in regards to distinctly and specifically pointing out the supposed errors in the Examiner's prior office action (37 CFR 1.111). The Examiner asserts that the Applicants only argue that the dependent claims should be allowable because the independent claims are unobvious and patentable over the prior art.
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 102-106 rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims are directed to a process (an act, or series of acts or steps), a machine (a concrete thing, consisting of parts, or of certain devices and combination of devices), and a manufacture (an article produced from raw or prepared materials by giving these materials new forms, qualities, properties, or combinations, whether by hand labor or by machinery). Thus, each of the claims falls within one of the four statutory categories (Step 1). The claims recite a method (process) and system (with an apparatus), however, the claim(s) recite(s) workflow management (i.e. ordering/organizing of tasks based upon workflow states, actors, hierarchies, and attributes) which is an abstract idea of a mental process.
Claim 87 recites: “A method for managing workflows for data objects persisted in at least one database of a data processing system, the data processing system comprising:(i) the at least one database storing: a plurality of data objects and values of their attributes, the plurality of data objects including a first data object having a first attribute; and (ii) a workflow management system comprising: a workflow execution engine for managing execution of finite state machines (FSMs) including: a first FSM associated with the first data object and for managing a first workflow for the first data object, and a second FSM for managing a second workflow for changing a value of the first attribute of the first data object; the method comprising: when a current workflow state of the first FSM is a first workflow state, using the workflow management system to perform: receiving, from a first actor authorized to perform a first workflow task corresponding to the first transition between the first and second workflow states, the input indicating that the first workflow task is to be performed; performing the first workflow task for the first data object; and updating the first FSM to indicate that the current workflow state of the first workflow for the first data object is the second workflow state; and concurrently with using the first FSM to manage a first workflow for the first data object, using the second FSM to manage the second workflow for the first attribute of the first data object.”
Claim 102 recites “A method for managing workflows for data objects persisted in at least one database of a data processing system, the data processing system comprising:(i) the at least one database storing: a plurality of data objects and values of their attributes, the plurality of data objects including a first data object having a first attribute; and(ii) a workflow management system comprising: a workflow execution engine for managing execution of finite state machines (FSMs) including: a first FSM associated with the first data object and for managing a first workflow for the first data object, and a second FSM for managing a second workflow for changing a value of the first attribute of the first data object; the method comprising: when a current workflow state of the first FSM is a first workflow state, using the workflow management system to perform: receiving, from a first actor authorized to perform a first workflow task corresponding to the first transition between the first and second workflow states, the input indicating that the first workflow task is to be performed; performing the first workflow task for the first data object; and updating the first FSM to indicate that the current workflow state of the first workflow for the first data object is the second workflow state; and concurrently with using the first FSM to manage the first workflow for the first data object, using the second FSM to manage the second workflow for changing the value of the first attribute of the first data object”
... as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process—concepts performed in the human mind (including an observation, evaluation, judgment, opinion) but for the recitation of “a database,” “database processing system,” “workflow management system comprising: a work flow execution engine” “finite state machines (FSMs),” and “graphical user interface (GUI)” which are not a positive recitation of structure whatsoever (i.e. entirely software based and not particularly tied to a physical structure or device(s)) and thus can only be directed towards an abstract idea. Further, but for the “a database,” “database processing system,” and “workflow management system comprising: a work flow execution engine” language, the context of the claim(s) encompasses the user manually ordering/organizing of tasks based upon workflow states, actors, hierarchies, and attributes which is a mental process of decision making based upon judgement or evaluation. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind, but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claim(s) recite(s) an abstract idea (Step 2A, Prong One: YES).
Regarding claims 87 and 102, this judicial exception is not integrated into a practical application (Step 2A Prong Two) because there are no additional elements to consider. As noted above, “a database,” “database processing system,” “workflow management system comprising: a work flow execution engine” “finite state machines (FSMs),” and “graphical user interface (GUI)” which are not a positive recitation of structure whatsoever (i.e. entirely software based and not particularly tied to a physical structure or device(s)) and thus can only be directed towards an abstract idea. Furthermore, the claims recitation of the “a database,” “database processing system,” “workflow management system comprising: a work flow execution engine” “finite state machines (FSMs),” and “graphical user interface (GUI)” which are not a positive recitation of structure whatsoever (i.e. entirely software based and not particularly tied to a physical structure or device(s)) and thus can only be directed towards an abstract idea are only generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.04(d)(I) discussing MPEP 2106.05(h). Accordingly, the combination of these additional elements does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea, even when considered as a whole (Step 2A Prong Two: NO).
Regarding claims 87 and 102, the claims do not include a combination of additional elements that are sufficient to amount to significantly more than the judicial exception (Step 2B). As discussed above with respect to integration of the abstract idea into a practical application (Step 2A Prong 2), there are no additional elements to consider and elements that are only generally linking the use of the judicial exception to a particular technological environment or field of use do not provide an inventive concept, even when considered as a whole. Therefore, when considering the additional elements alone, and in combination, there is no inventive concept in the claim. As such, the claim(s) is/are not patent eligible, even when considered as a whole (Step 2B: NO).
Claim 95 recites “A system for managing workflows for data objects persisted in at least one database of a data processing system, the data processing system comprising:(i) the at least one database storing: a plurality of data objects and values of their attributes, the plurality of data objects including a first data object, the first data object having a plurality of attributes including a first attribute that can have any one of a plurality of values including a first hierarchy attribute; and metadata specifying relationships among at least some of the plurality of data objects by specifying one or more hierarchies of data objects including a first hierarchy; and(ii) a workflow management system comprising: a workflow execution engine for managing execution of finite state machines (FSMs) including a first FSM associated with the first data object and for managing a first workflow for the first data object, the first FSM comprising a plurality of workflow states and a plurality of transitions corresponding to respective tasks of the first workflow... when a current workflow state of the first FSM is a first workflow state, using the workflow management system and the first FSM associated with the first data object to manage the first workflow for the first data object at least in part by: determining a current value of the first attribute of the first data object by accessing the current value of the first attribute in the at least one data store; identifying, using the current value of the first attribute and the first hierarchy, a first actor authorized to perform a first workflow task for the first data object, the identifying comprising: using the current value of the first hierarchy attribute to determine that the first data object belongs to the first hierarchy of data objects specified by the metadata; and identifying the first actor as authorized to perform the first workflow task for a second data object hierarchically related to the first data object in the first hierarchy; generating a graphical user interface (GUI) through which the first actor can provide input indicating that the first workflow task is to be performed; and in response to receiving, from the first actor and through the GUI, the input indicating that the first workflow task is to be performed: performing the first workflow task for the first data object; and updating the current workflow state of the first FSM from a first workflow state to a second workflow state” as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process—but for the recitation of generic computer components (Step 2A Prong 1). That is, other than reciting “the system comprising: at least one computer hardware processor; and at least one non-transitory computer-readable storage medium storing processor executable instructions that, when executed by the at least one computer hardware processor, cause the at least one computer hardware processor to perform a method comprising:,” nothing in the claim element precludes the step from practically being performed in the mind. For example, but for the “cause the at least one computer hardware processor to perform a method comprising” language, the context of the claim(s) encompasses the user manually ordering/organizing of tasks based upon workflow states, actors, hierarchies, and attributes which is a mental process of decision making based upon judgement or evaluation. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind, but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claim(s) recite(s) an abstract idea (Step 2A, Prong One: YES).
Regarding claim 95, this judicial exception is not integrated into a practical application (Step 2A Prong Two). In particular, the claim only recites one additional element – using at least one hardware processor to perform the steps. The at least one hardware processor in the steps is recited at a high-level of generality such that it amounts no more than mere instructions to apply the exception using a generic computer component. Specifically the claims amount to nothing more than an instruction to apply the abstract idea using a generic computer or invoking computers as tools by 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 2106.04(d)(I) discussing MPEP 2106.05(f). Furthermore, the claims recitation of the “a database,” “database processing system,” “workflow management system comprising: a work flow execution engine” “finite state machines (FSMs),” and “graphical user interface (GUI)” which are not a positive recitation of structure whatsoever (i.e. entirely software based and not particularly tied to a physical structure or device(s)) and thus can only be directed towards an abstract idea are only generally linking the use of the judicial exception to a particular technological environment or field of use – see MPEP 2106.04(d)(I) discussing MPEP 2106.05(h). Accordingly, the combination of these additional elements does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea, even when considered as a whole (Step 2A Prong Two: NO).
Regarding claim 95, the claim does not include a combination of additional elements that are sufficient to amount to significantly more than the judicial exception (Step 2B). As discussed above with respect to integration of the abstract idea into a practical application (Step 2A Prong 2), the combination of additional elements of using at least one hardware processor to perform the steps amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Similarly to above, the recitation of “a database,” “database processing system,” “workflow management system comprising: a work flow execution engine” “finite state machines (FSMs),” and “graphical user interface (GUI)”is/are only generally linking the use of the judicial exception to a particular technological environment or field of use do not provide an inventive concept, even when considered as a whole. Therefore, when considering the additional elements alone, and in combination, there is no inventive concept in the claim. As such, the claim(s) is/are not patent eligible, even when considered as a whole (Step 2B: NO).
Dependent claims 87-94, 96-101, and 103-106 recite(s) the additional limitation(s) further limiting the data and how the workflow is managed, which is still directed towards the abstract idea previously identified and is not an inventive concept that meaningfully limits the abstract idea. Again, as discussed with respect to claims 87, 95, and 102, the claims are simply limitations which are no more than mere instructions to apply the exception using a computer or with computing components. Accordingly, the additional element(s) does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Even when considered as a whole, the claims do not integrate the judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B.
Claims 102-106 are therefore not eligible subject matter, even when considered as a whole.
Conclusion
THIS ACTION IS MADE FINAL. 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 extension fee 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 ANDREW B WHITAKER whose telephone number is (571)270-7563. The examiner can normally be reached on M-F, 8am-5pm, EST.
If attempts to reach the examiner by telephone are unsuccessful, the Examiner’s supervisor, Lynda Jasmin can be reached on (571) 272-6782. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ANDREW B WHITAKER/Primary Examiner, Art Unit 3629