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 .
Status of Claims
This action is in response to the reply filed December 04, 2025.
Claims 1, 3, 8, 10, 15, and 17 have been amended.
Claims 2, 4-5, 7, 9, 11-12, 14, 16, 18-19, and 21 have been cancelled.
Claims 22-24 have been newly submitted.
Claims 1, 3, 6, 8, 10, 13, 15, 17, 20, and 22-24 are currently pending and have been examined.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on December 05, 2025 is being considered by the examiner.
Response to Arguments
Applicant’s arguments filed December 04, 2025 have been fully considered but they are not persuasive.
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
2. Step 2A - Prong 1: The present claims are not directed to an abstract idea
As described above, the problem addressed by the claimed invention is necessarily rooted in technology, and the solution recited by the claims provides a technical solution to this technical problem, thus improving the technology of automated baggage handling. As explained in the BACKGROUND section of the specification, "data entry errors can occur which can be very costly coupled with the additional cost of baggage handling." Specification at 9. That is, information across secure online baggage-handling databases may become inconsistent for various reasons, necessitating reversion to manual processing due to missing links and data entry errors. The claims (e.g., independent claims 1, 8, and 15) are directed to methods and systems that address this issue by detecting broken (missing) links and applying a particular method for automatically recovering the link, thus resolving the inconsistency that would have, with previous systems, required re-processing of previously screened luggage items, which can result in "long lines that cause passengers to miss their connective flight or other travel journey arrangements to get through the Customs authority." Id. at 368.
For example, claim 1 (and, similarly, claims 8 and 15) recites "accessing, by at least one of the at least one processor, a baggage data database associated with the baggage handling system to find one or more baggage identifier linked pairs (BILPs), wherein each of the one or more BILPs comprises a linked pair of a first and a second unique baggage identifier; matching, by at least one of the at least one processor, the first unique baggage identifier of the respective checked-in luggage item with a corresponding first unique baggage identifier in a BILP of the one or more BILPs to recover the missing link; and updating, by the at least one of the at least one processor, the secure database with the recovered missing link."
Examiner respectfully disagrees. Examiner maintains that the claims, as a whole, are directed to the abstract idea of identifying incomplete baggage records, extrapolating the missing data using available records, and updating the baggage records to include the missing data, which is a method of organizing human activity. In other words, the claims are using a backup identifier and explain the steps for relying on the backup identifier. Improper or incomplete data entry and its consequences, as explained in the current application, is a business problem rather than a technological problem.
The claimed computer components have not been improved by the automation of the manual process. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential), has been found by the courts not to be sufficient to show an improvement in a computer-functionality.
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
2. Step 2A - Prong 1: The present claims are not directed to an abstract idea
New independent claims 23-25, while varying in scope from independent claim 1, contain similar recitations and are therefore not directed to an abstract idea for analogous reasoning as presented above with respect to independent claim 1. For example, new independent claim 23 (and, similarly, new independent claims 22 and 24) recite "matching the picture of the respective checked-in luggage item in the security luggage item manifest with the picture linked to the second unique baggage identifier of the respective checked-in luggage item to find the first unique baggage identifier of the respective checked-in luggage item to recover the missing link," and "updating the secure database with the recovered missing link."
Thus, these claims-as a whole-are directed to automatic detection and correction of inconsistencies across baggage-handling databases. While the claims recite accessing databases and transmitting data through a communication network, they are not directed to abstract ideas such as mere communication or methods of organizing human activity. Instead, the claims are directed to technical solutions for addressing a technical problem that has previously limited the ability to take full advantage of automated baggage handling.
Examiner respectfully disagrees. Improper or incomplete data entry and its consequences, as explained in the current application, is a business problem rather than a technological problem. The claims do not appear to solve the underlying problem of glitches and instead explain an abstract workaround to the problem. In other words, neither the source of a glitch nor its prevention is addressed by the instant claims or specification. The problem in the instant claim is missing data, which is a business problem, and the solution is the current claims is to use a backup identifier, which is a business solution to the business problem of incomplete records.
The claimed computer components have not been improved by the automation of the manual process. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential), has been found by the courts not to be sufficient to show an improvement in a computer-functionality.
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
3. Step 2A - Prong 2: The present claims integrate any alleged abstract idea into a practical application
The claims link the use of any judicial exception to the technical environment of automated baggage handling, such that the claims - as a whole - provide an improvement to the field of automated baggage handling. In particular, and as discussed above, claims 1 (and, similarly, claims 8 and 15) recites: "accessing, by at least one of the at least one processor, a baggage data database associated with the baggage handling system to find one or more baggage identifier linked pairs (BILPs), wherein each of the one or more BILPs comprises a linked pair of a first and a second unique baggage identifier; matching, by at least one of the at least one processor, the first unique baggage identifier of the respective checked-in luggage item with a corresponding first unique baggage identifier in a BILP of the one or more BILPs to recover the missing link; and updating, by the at least one of the at least one processor, the secure database with the recovered missing link." These recitations provide detailed, specific steps for one approach to addressing the technical problem with a concrete technical solution that is highly practical. New independent claims 23-25, while varying in scope from independent claim 1, contain similar recitations and therefore integrate any alleged abstract idea into a practical application for analogous reasoning as presented above with respect to independent claim 1. For example, new independent claim 23 (and, similarly, new independent claims 22 and 24) recite "matching the picture of the respective checked-in luggage item in the security luggage item manifest with the picture linked to the second unique baggage identifier of the respective checked-in luggage item to find the first unique baggage identifier of the respective checked-in luggage item to recover the missing link," and "updating the secure database with the recovered missing link." These recitations provide detailed, specific steps for another approach to addressing the technical problem with a concrete technical solution that is highly practical.
These sets of limitations are directed to assuring that the baggage handling process continues smoothly, even in the face of errors such as database inconsistency. And the recited steps are far from well-understood, routine, or conventional. Previous systems resorted to manual processes when database inconsistencies arose.
Thus, independent claims 1, 8, 15, and 22-24 are directed to improving automated baggage-handling technology in a way that is designed to avoid the consequences of database "glitches." Accordingly, claims 1, 8, 15, and 22-24 integrate any judicial exception into a practical application.
Examiner respectfully disagrees. Limiting the claims to the field of use of automated baggage handling does not amount to more than generally linking the use of the abstract idea to a particular technological environment or field of use. See Affinity Labs of Tex., LLC v. DIRECTV, LLC, 838 F.3d 1253, 1259 (Fed. Cir. 2016) (merely limiting the field of use of the abstract idea to a particular … environment does not render the claims any less abstract).
The court in TLI Communications stated the use of a computer is not significantly more when, “[the claims] are directed to the use of conventional or generic technology in a nascent but well-known environment, without any claim that the invention reflects an inventive solution to any problem presented by combining the two.” TLI Communications LLC v. AV Automotive, LLC., 823 F.3d 607, 612 (Fed. Cir. 2016). Therefore, since the claims are reciting a conventional or generic technology in a nascent but well-known environment, the additional steps do not amount to significantly more than the abstract idea. The claims do not recite a new database but instead merely recites the type of data stored in the database. In re TLI Communications LLC Patent Litigation, 823 F.3d 607, 612 (Fed. Cir. 2016) (The specification does not describe a new telephone, a new server, or a new physical combination of the two. The specification fails to provide any technical details for the tangible components, but instead predominately describes the system and methods in purely functional terms.) Recitation of particular types of data and what do with that data has been found to be routine when, as here, the manipulation of this data amounts to basic logical determinations. See Return Mail, Inc. v. USPS, 868 F.3d 1350, 1369 (Fed. Cir. 2017). See MPEP 2106.05(g)
Regarding the particularity of the claims, merely reciting claims that are a narrow application of the identified idea is not sufficient to recite patent eligible subject matter. See Electronic Communication v. Shopperschoice.com, LLC, 958 F.3d 1178, 1183 (Fed. Cir. 2020) (“patent eligibility turns on the content of the claims, not merely on the number of words recited in the claims”); BSG Tech LLC v. BuySeasons, Inc., 899 F.3d 1281, 1287 (Fed. Cir. 2018) (“a claim is not patent eligible merely because it applies an abstract idea in a narrow way”).
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
4. Step 2B: The present claims - as a whole - recite additional elements that amount to more than any judicial exception
As discussed above, Independent claims 1, 8, 15, and 22-24 recite limitations related to automatically ameliorating baggage-handling database "glitches" in real time, i.e., during baggage handling. Independent claims 1, 8, 15, and 22-24 also recite "converting the extrapolated first unique baggage identifier and the retrieved SSI into SSI file sharing data configured to be used by a second security authority to perform a security screening process on the checked-in luggage item, wherein the second security authority is different from the first security authority." These additional steps are also designed to further streamline baggage processing, allowing the baggage to remain in trusted custody across different security authorities, where the potential consequences for having an inconsistent baggage-handling database are significant.
Additionally, the Office rejected dependent claims 4-5, 11-12, and 18-19 on the basis that the subject matter encompassed within these claims "do not amount to significantly more than the judicial exception." Office action at 6-7. Applicant notes that the subject matter of previously presented dependent claim 4 was included in independent claim 1 and that the claim language, as a whole, includes additional elements that amount to more than any judicial exception because it enables "a second security authority to perform a security screening process on the checked-in luggage item using the security screening tool." Furthermore, this significant result is made possible due to the steps of "matching ... the first unique baggage identifier of the respective checked-in luggage item with a corresponding first unique baggage identifier in a BILP of the one or more BILPs to recover the missing link; and updating ...the secure database with the recovered missing link." See also FIGS. 36A-36D and 934-943 of the corresponding published application. Accordingly, the combination of additional elements emphasized above sufficiently limits the claim scope to a practical application of any alleged judicial exception.
Independent claims 1, 8, 15, and 22-24 are directed to an inventive concept related to automating and streamlining baggage handling, including automatically detecting and correcting database errors that would have otherwise limited an ability to take full advantage of such systems. Thus, the claims, as a whole, recite additional elements that amount to significantly more than any judicial exception.
Examiner respectfully disagrees. Improper or incomplete data entry and its consequences, as explained in the current application, is a business problem rather than a technological problem. The claims do not appear to solve the underlying problem of “glitches” and instead explain an abstract workaround to the problem. In other words, neither the source of a glitch nor its prevention is addressed by the instant claims or specification. The problem in the instant claim is missing data, which is a business problem, and the solution to that problem is for the current claims to use a backup identifier, which is a business solution to the business problem of incomplete records.
The claimed computer components have not been improved by the automation of the manual process. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) or speeding up a loan-application process by enabling borrowers to avoid physically going to or calling each lender and filling out a loan application, LendingTree, LLC v. Zillow, Inc., 656 Fed. App'x 991, 996-97 (Fed. Cir. 2016) (non-precedential), has been found by the courts not to be sufficient to show an improvement in a computer-functionality.
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
5. The present claims are similar to USPTO examples of patent-eligible claims.
This type of analysis similarly applies to the claims of the present application and should produce the same result. That is, the combination of additional elements related to detecting and recovering broken (missing) database links during baggage handling, results in a specific improvement over prior art systems by allowing automated baggage handling to proceed without manual intervention and therefore solving the attendant delays and disruptions that may occur without such improvements. Thus, these claims are not directed to any recited judicial exception and should also be eligible.
Examiner respectfully disagrees. Missing identifier data is not the same as the computer viruses, worms, and other malicious code discussed in Subject Matter Eligibility Example 1. Keeping baggage records is not inextricably tied to computer technology in the same way computer viruses, worms, and other malicious code. As discussed above, the claimed computer components have not been improved by the automation of the manual process.
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, 3, 6, 8, 10, 13, 15, 17, 20, and 22-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Alice/Mayo Framework Step 1:
Claims 1, 3, 6, and 22 recite a series of steps and therefore recite a process.
Claims 8, 10, 13, and 23 recite a combination of devices and therefore recite a machine.
Claims 15, 17, 20, and 24 recite a tangible article given properties through artificial means and therefore recite a manufacture.
Alice/Mayo Framework Step 2A – Prong 1:
Claims 1, 8, 15, and 22-24, as a whole, are directed to the abstract idea of identifying incomplete baggage records, extrapolating the missing data using available records, and updating the baggage records to include the missing data, which is a method of organizing human activity. The claims recite a method of organizing human activity because the identified idea is a fundamental economic principles or practices (including hedging, insurance, mitigating risk) by reciting record keeping by using available baggage identifiers to extrapolate missing records and update a manifest to include the missing identifiers and provide a complete baggage manifest. See MPEP 2106.04(a)(2)(II)(A). The method of organizing human activity of “identifying incomplete baggage records, extrapolating the missing data using available records, and updating the baggage records to include the missing data,” is recited by claiming the following limitations: generating a security luggage item manifest, determining whether the manifest is missing identifier links, extrapolating an identifier, accessing baggage data to find linked pairs, matching identifiers to recover a missing link, updating the recovered missing link, retrieving an image, converting data formats, transmitting the converted data, and matching a manifest picture of the luggage with an identifier picture. The mere nominal recitation of a processor, a memory, a non-transitory computer readable medium, a secure database, a baggage data database, a baggage handling system, a non-transitory memory device, a security screening imaging machine, a security screening tool, a network interface, and a communication network does not take the claim of the method of organizing human activity grouping. Thus, the claim recites an abstract idea.
Alice/Mayo Framework Step 2A – Prong 2:
Claims 1, 8, 15, and 22-24 recite the additional elements: a processor, a memory, a non-transitory computer readable medium, a secure database, a baggage data database, a baggage handling system, a non-transitory memory device, a security screening imaging machine, a security screening tool, a network interface, and a communication network. These processor, memory, non-transitory computer readable medium, secure database, a baggage data database, baggage handling system, non-transitory memory device, network interface, and communication network limitations are no more than mere instructions to apply the exception using a generic computer component. The security screening imaging machine and security screening tool steps are recited at a high level of generality (i.e., as a general means of gathering luggage data), and amounts to mere data gathering, which is a form of insignificant extra-solution activity.
Regarding Claims 3, 10, and 17 the updating the secure database is recited at a high level of generality, i.e., as a generic database performing a generic updating function. Taken individually these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Considering the limitations containing the judicial exception as well as the additional elements in the claim besides the judicial exception does not amount to a practical application of the abstract idea. The claim as a whole does not improve the functioning of a computer or improve other technology or improve a technical field. The claim as a whole is not implemented with a particular machine. The claim as a whole does not effect a transformation of a particular article to a different state. The claim as a whole is not applied in any 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. The claim as a whole merely describes how to generally “apply” the concept of maintaining a manifest in a computer environment. The claimed computer components are recited at a high level of generality and are merely invoked as tools to perform an existing exception handling process. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea. The claim is directed to the abstract idea.
Alice/Mayo Framework Step 2B:
Claims 1, 8, 15, and 22-24 do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claims recite a generic computer performing generic computer function by reciting a processor, a memory, a non-transitory computer readable medium, a secure database, a baggage data database, a baggage handling system, a non-transitory memory device, a security screening imaging machine, a security screening tool, a network interface, and a communication network. See Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1341 (describing a “processor” as a generic computer component); Mortg. Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d 1314, 1324–25 (Fed. Cir. 2016) (claims reciting an “interface,” “network,” and a “database” are nevertheless directed to an abstract idea); Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343, 1347–48 (discussing the same with respect to “data” and “memory”). The claims recite the following computer functions recognized by the courts as generic computer functions by reciting transmitting information (See MPEP 2106.05(d)(II) receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec; TLI Communications LLC; OIP Techs.; buySAFE, Inc.), processing information (See MPEP 2106.05(d)(II) performing repetitive calculations, Flook; Bancorp Services), retrieving information (See MPEP 2106.05(d)(II) storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc.; OIP Technologies), and updating information (See MPEP 2106.05(d)(II) electronic recordkeeping, Alice Corp.; Ultramercial). The specification demonstrates the well-understood, routine, conventional nature of the following additional elements because they are described in a manner that indicates the elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. 112(a): a processor (Specification [0001047]-[0001048]), a memory (Specification [0001042]), a non-transitory computer readable medium (Specification [0001042]), a secure database (Specification [000935]), a baggage data database (Specification [000944], [000946]), a baggage handling system (Specification [000336], [000358], [000830]), a non-transitory memory device (Specification [0001042]), a security screening imaging machine (Specification [000720]), a security screening tool (Specification [000877]-[000878]), a network interface (Specification [000334], [000821], [0001045]), and a communication network (Specification [000335]). See MPEP 2106.05(d)(I)(2). The claims add the words “apply it” or words equivalent to “apply the abstract idea” such as instructions to implement the abstract idea on a computer by reciting a processor, a memory, a non-transitory computer readable medium, a secure database, a baggage data database, a baggage handling system, a non-transitory memory device, a network interface, and a communication network. See MPEP 2106.05(f). The claims recite insignificant extrasolution activity (i.e. mere data gathering, selecting a particular data source or type of data to be manipulated, or an insignificant application) by reciting a security screening imaging machine, a security screening tool, and updating the secure database. See MPEP 2106.05(g). The claims limit the field of use by reciting handling airport luggage. See MPEP 2106.05(h). Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. See MPEP 2106.05(a). Their collective functions merely provide conventional computer implementation. See MPEP 2106.05(b). Therefore, the claims do not include additional elements alone, and in combination, that are sufficient to amount to significantly more than the recited judicial exception.
With regards to Claims 3, 10, and 17, the additional elements do not amount to significantly more than the judicial exception. Claims 3, 10, and 17 recite a generic computer performing generic computer functions by reciting updating the secure database. (See MPEP 2106.05(d)(II) electronic recordkeeping, Alice Corp.; Ultramercial). Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. See MPEP 2106.05(a). Their collective functions merely provide conventional computer implementation. See MPEP 2106.05(b). Therefore, the claims do not include additional elements that are sufficient to amount to significantly more than the recited judicial exception.
Remaining Claims:
With regards to Claims 6, 13, and 20, these claims merely add a degree of particularity to the limitations discussed above rather than adding additional elements capable of transforming the nature of the claimed subject matter. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. Therefore, the claims as a whole do not amount to significantly more than the abstract idea itself.
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 SCOTT M TUNGATE whose telephone number is (571)431-0763. The examiner can normally be reached Monday - Friday, 9:00 - 4:30 EST.
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/SCOTT M TUNGATE/Primary Examiner, Art Unit 3628