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 .
DETAILED ACTION
This responds to Applicant’s Arguments/Remarks filed 08/26/2026. Claims 1, 4-5, 11, 14-15 have been amended. Claim 21 has been added. Claims 1-21 are now pending in this Application.
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 8/26/2026 has been entered.
Claim Rejections - 35 USC § 101
Claim 1 has been amended to recite “generating a database view by executing view creation”, “executing new write database”, “wherein the method is performed by a database server”. However, the amendment does not overcome the rejection.
The amended limitation merely recites “using computer to perform the method of claim 1”, which is part of the abstract idea. The limitation does not improve the functioning of a computer or another technology. Therefore, the examiner respectfully maintained the rejection.
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter because of the following reasons:
Claims 1, 11 appear to be directed to an abstract idea without reciting additional limitations that tie it to a practical application or without reciting additional limitations that amount to significantly more than the abstract idea. The additional limitations are receiving data. These limitations are mere data gathering which are insignificant extra solution activities under step 2A prong II and well understood routine and conventional under step 2B (For Berkhiemer See MPEP 2106.05(d)(II) Versata.)
Step 2A, Prong One:
Independent claims 1, 9, and 17 are directed to update views to column values
Generating a database view based on a first database statement that specifies a value expression for a restricted column in a base table;
Executing a second database statement including: evaluating the value expression to generate a new value for the restricted column of a row in the base table, and storing the new value into the restricted column of the row. These are basic data manipulation operation. As such this step can be performed mentally.
Step 2A Prong Two and Step 2B
Use of updating rows, evaluating expressions, string value implement on conventional computer are idea discussed above.
The step of receiving data associated with a building constitutes an insignificant extra-solution activity in the form of mere data gather, see MPEP 2106.05(g)
i. Performing clinical tests on individuals to obtain input for an equation, In re Grams, 888 F.2d 835, 839-40; 12 USPQ2d 1824, 1827-28 (Fed. Cir. 1989);
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.
Claims 2-10, 12-21 further define database and base table. It does not disclose a specific technical improvement or unconventional database technique.
Accordingly claims 1-20 are found to be directed to a patent ineligible abstract idea.
Response to Arguments
Applicant’s arguments filed 8/26/2026 have been fully considered but they are not persuasive.
Applicant argues that Kaufman does not disclose a database server per claim 1.
In response to Applicant’s argument, the examiner submits that “a database server” is a computer or software system that stores, manage and processes data in a database. Kaufman discloses “a software system (abstract)” “managing complex data relationships and interaction” (Par [0012]).
Therefore, Kaufman discloses “a database server”.
Applicant’s arguments with respect to claim(s) 1-21 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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) 1-5, 7-15, 17-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kaufman et al (U.S. Pub No. 2004/0073565 A1), and in view of Ghazal et al (U.S. Pub No. 2024/0202576 A1).
As per claim 1, Kaufman discloses a method comprising:
generating a database view by executing view creation a database statement that specifies a value expression for a restricted column in a base table (Par [0113, 0121-0126]); and
executing a database statement including: evaluating the value expression to generate a new value for the restricted column of a row in the base table (par [0121-0126, 0147-0156, 0185]), and
storing the new value into the restricted column of the row (Par [0179, 0183]);
wherein the method is performed by a database server (Par [0068]).
Kaufman discloses executing a view creation, executing a database statement. Kaufman does not explicitly disclose executing a view write database statement. However, Ghazal discloses executing a view write database statement (Par [0059-0061]).
It would have been obvious to one of ordinary skill in the art before the effective filling date of the effective filling date of the claimed invention was made to incorporate the feature as disclosed in Ghazal into the teaching of Kaufman in order to provide more accuracy (Par [0049]).
As per claim 2, Kaufman discloses the method of Claim 1 wherein said executing does not cause executing a database trigger (par [0052]).
As per claim 3, Kaufman discloses the method of Claim 1 wherein the restricted column in the base table is referential (par [0052]).
As per claim 4, Ghazal discloses the method of Claim 1 wherein the view write database statement does not contain an identifier of the restricted column in the base table (par [0059-0061]).
As per claim 5, Kaufman discloses the method of Claim 1 wherein: the database view is unmaterialized and (Par [0121-0122]);
the view creation database statement contains an identifier of a foreign key (par [0101, 0105]).
Kaufman does not explicitly disclose allows writes. However, Ghazal discloses allows writes (Par [0060-0061]).
As per claim 7, Kaufman discloses the method of Claim 1 further comprising: detecting that a third database statement contains an identifier of the restricted column in the base table; rejecting the third database statement in response to said detecting (par [0121-0126, 0147, 0185]).
As per claim 8, Kaufman discloses the method of Claim 1 further comprising to the new value, applying a database constraint of the restricted column in the base table (Par [0120-0125]).
As per claim 9, Kaufman discloses the method of Claim 8 wherein the database constraint is referential, non-nullity, or uniqueness (par [0064-0065]).
As per claim 10, Kaufman discloses the method of Claim 1 wherein said storing is one selected from a group comprising overwriting or writing without overwriting (Par [0184]).
As per claim 11, Kaufman discloses one or more non-transitory computer-readable media storing instructions that, when executed by one or more processors, cause:
generating a database view based on a first database statement that specifies a value expression for a restricted column of a base table (Par [0113, 0121-0126]); and
executing a second database statement including: evaluating the value expression to generate a new value for the restricted column of a row in the base table (par [0121-0126, 0147, 0185]), and
storing the new value into the restricted column of the row (Par [0179, 0183]).
Kaufman discloses executing a database statement. Kaufman does not explicitly disclose executing a view write database statement. However, Ghazal discloses executing a view write database statement (Par [0059-0061]).
It would have been obvious to one of ordinary skill in the art before the effective filling date of the effective filling date of the claimed invention was made to incorporate the feature as disclosed in Ghazal into the teaching of Kaufman in order to provide more accuracy (Par [0049]).
As per claim 12, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein said executing does not cause executing a database trigger (par [0055]).
As per claim 13, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein the restricted column in the base table is referential (Par [0052]).
As per claim 14, Ghazal discloses the one or more non-transitory computer-readable media of Claim 11 wherein the second database statement does not contain an identifier of the restricted column in the base table (par [0059-0061]).
As per claim 15, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein: the database view is unmaterialized and (Par [0121-0122]);
the view creation database statement contains an identifier of a foreign key (par [0101, 0105]).
Kaufman does not explicitly disclose allows writes. However, Ghazal discloses allows writes (Par [0060-0061]).
As per claim 17, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein the instructions further cause: detecting that a third database statement contains an identifier of the restricted column in the base table;
rejecting the third database statement in response to said detecting.
As per claim 18, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein the instructions further cause to the new value (par [0121-0126, 0147, 0185]),
applying a database constraint of the restricted column in the base table (Par [0120-0125]).
As per claim 19, Kaufman discloses the one or more non-transitory computer-readable media of Claim 18 wherein the database constraint is referential, non-nullity, or uniqueness (Par [0064-0065]).
As per claim 20, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein said storing is one selected from a group comprising overwriting or writing without overwriting (Par [0184]).
As per claim 21, Kaufman discloses the method of claim 1 wherein said generating comprises in a database schema or database dictionary, generating a definition of the database view (Par [0182, 0228, 0232]).
Claim(s) 6 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kaufman et al (U.S. Pub No. 2004/0073565 A1), and Ghazal et al (U.S. Pub No. 2024/0202576 A1), and further in view of Millard et al (U.S. Pub No. (2011/0119244 A1).
As per claim 6, Kaufman discloses the method of Claim 1 further comprising without reading the restricted column in the base table, including returning a projection that is based on the database view (par [0121-0126, 0147, 0185]).
Kaufman and Ghazal do not explicitly disclose executing a third database statement that contains a wildcard that represents multiple columns of the database view.
However, Millard discloses executing a third database statement that contains a wildcard that represents multiple columns of the database view (Par [0008]).
It would have been obvious to one of ordinary skill in the art before the effective filling date of the effective filling date of the claimed invention was made to incorporate the feature as disclose in Millard into the teaching of Kaufman as modified by Ghazal in order to improve the system (Par [0009]).
As per claim 16, Kaufman discloses the one or more non-transitory computer-readable media of Claim 11 wherein the instructions further cause without reading the restricted column in the base table, including returning a projection that is based on the database view (par [0121-0126, 0147, 0185]).
Kaufman and Ghazal do not explicitly disclose executing a third database statement that contains a wildcard that represents multiple columns of the database view.
However, Millard discloses executing a third database statement that contains a wildcard that represents multiple columns of the database view (Par [0008]).
It would have been obvious to one of ordinary skill in the art before the effective filling date of the effective filling date of the claimed invention was made to incorporate the feature as disclose in Millard into the teaching of Kaufman as modified by Ghazal in order to improve the system (Par [0009]).
Conclusion
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September 28, 2026
/THU N NGUYEN/Examiner, Art Unit 2154