DETAILED ACTION
Status of the Claims
This office action is submitted in response to the amendment filed on 4/30/26.
Examiner notes that this application is a national stage entry of PCT/JP2022/038196.
Examiner further notes Applicant’s priority date of 10/13/22, which stems from the aforementioned PCT.
Claim 2 has been cancelled.
Claims 1, 3, and 5-10 have been amended.
Therefore, claims 1 and 3-10 are currently pending and have been examined.
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 .
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 and 3-10 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 1: Claims 1 and 3-10 are directed to one of the statutory categories. Claim 1 recites a negotiation apparatus, comprising at least one processor, and thus falls within the "machine" category. Claim 9 recites a negotiation method, and thus falls within the "process" category. Claim 10 recites a non-transitory recording medium having recorded thereon a program, and thus falls within the "article of manufacture" category. Claims 3–8 depend from claim 1 and thus likewise fall within the "machine" category. Accordingly, the claims satisfy Step 1. See MPEP 2106.03.
Step 2A, Prong One: Independent claims 1, 9, and 10, in part, describe an invention comprising: (1) adding, in a first negotiation with a first negotiation party, a reason for provision to an agreement candidate proposal, the reason for provision being based on a status of a second negotiation that is conducted with a different second negotiation party in association with the first negotiation; (2) referring to information indicating an association between the first negotiation and the second negotiation, and information indicating the status of the second negotiation — including content of the agreement candidate proposal in the second negotiation or a result of the second negotiation — to generate the reason for provision; and (3) adding the generated reason for provision to the agreement candidate proposal. As such, the invention is directed to the abstract idea of formulating and providing justifications or explanations for offers in commercial negotiations based on the status of other associated negotiations, which, pursuant to MPEP § 2106.04(a), is aptly categorized as a method of organizing human activity (commercial negotiations, contractual relationships, and multi-party bargaining strategies), as well as a mental process (determining what reason to provide based on the status of another negotiation, deciding what information from one negotiation should inform another negotiation, and formulating explanations or justifications for negotiation proposals). Therefore, under Step 2A, Prong One, the claims recite a judicial exception.
Next, the aforementioned claims recite additional elements that are associated with the judicial exception, including: providing the first negotiation party with the agreement candidate proposal which has the reason for provision added thereto. The Examiner understands these limitations to be insignificant extra-solution activity. See Accenture Global Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 108 U.S.P.Q.2d 1173 (Fed. Cir. 2013), citing Cf. Diamond v. Diehr, 450 U.S. 175, 191–192 (1981) ("[I]nsignificant post-solution activity will not transform an unpatentable principle into a patentable process.").
The aforementioned claims also recite additional elements including: at least one processor for carrying out the provision reason adding process and the agreement candidate proposal providing process (claim 1); at least one processor for performing the adding and the providing (claim 9); and a non-transitory recording medium having recorded thereon a program for causing a computer to carry out the recited processes (claim 10). These limitations are recited at a high level of generality and appear to be nothing more than generic computer components used to apply the abstract idea. Claims that amount to nothing more than an instruction to apply the abstract idea using a generic computer do not render an abstract idea eligible. Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 223 (2014), 110 USPQ2d 1977, 1983 (2014).
Step 2A, Prong Two: Looking at the elements individually and in combination, the claims as a whole do not integrate the judicial exception into a practical application because they fail to: improve the functioning of a computer or a technical field; apply the judicial exception in the treatment or prophylaxis of a disease; apply the judicial exception with a particular machine; effect a transformation or reduction of a particular article to a different state or thing; or apply the judicial exception beyond generally linking the use of the judicial exception to a particular technological environment. Rather, the claims merely use generic computer components as a tool to perform the abstract idea of formulating and providing negotiation justifications, and/or add insignificant extra-solution activity to the judicial exception (e.g., transmitting the agreement candidate proposal to a negotiation party and presenting the generated reason for provision), and/or generally link the use of the judicial exception to a particular technological environment (e.g., a generic processor-based system operating in a multi-party negotiation context). Accordingly, the claims do not integrate the judicial exception into a practical application, and the analysis proceeds to Step 2B.
Step 2B: The claims do not include additional elements sufficient to amount to significantly more than the judicial exception. The additional elements, when considered individually and as an ordered combination, do not amount to significantly more than the abstract idea itself. 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 any other technology, and their collective functions are merely facilitated by generic computer implementation.
Additionally, pursuant to the requirement under Berkheimer v. HP Inc., 881 F.3d 1360, 125 USPQ2d 1649 (Fed. Cir. 2018), the following citation is provided to demonstrate that the additional elements, identified above, are well-understood, routine, and conventional. See MPEP § 2106.05(d).
Receiving or transmitting data over a network, including transmitting a proposal to a negotiation party. buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014); MPEP § 2106.05(d)(II).
Thus, taken alone and in combination, the additional elements do not amount to significantly more than the above-identified judicial exception, and claims 1–10 are ineligible under 35 U.S.C. § 101.
Next, claims 3–8 depend from claim 1 and include all limitations contained therein. These claims do not recite any additional elements sufficient to transform the abstract idea into patent-eligible subject matter. Specifically:
Claim 3 further recites that the at least one processor further adds, to the agreement candidate proposal, guarantee information for guaranteeing validity of the reason for provision. This limitation adds further detail to the abstract idea by specifying that additional validating information accompanies the formulated reason; it amounts to a non-structural elaboration of the justification being provided and does not recite any improvement to computer functionality or any other technical advance beyond the abstract idea itself.
Claim 4 further recites that the at least one processor adds, to the agreement candidate proposal, the reason for provision which is inputted via input equipment. The recited input equipment is a generic computer component for receiving data input, recited at a high level of generality, and the balance of the limitation merely specifies the source of the reason for provision; it amounts to insignificant data-gathering and a non-structural detail that does not meaningfully limit the abstract idea. See MPEP § 2106.05(g).
Claim 5 further recites that the at least one processor refers to content of an agreement candidate proposal in the second negotiation or information which indicates a result of the second negotiation, as the information which indicates the status of the second negotiation. This limitation further defines the particular information collected and analyzed to formulate the reason for provision and amounts to an additional non-structural detail of the abstract data analysis without adding significantly more than the abstract idea.
Claims 6–8 further recite the particular type of association referred to in generating the reason for provision — namely, an association of conducting one of the first negotiation and the second negotiation for formation of agreement in the other (claim 6); an association of conducting the first negotiation and the second negotiation in parallel for selective formation of agreement only in either the first negotiation or the second negotiation (claim 7); and an association of conducting the first negotiation and the second negotiation in parallel for formation of agreement in both the first negotiation and the second negotiation (claim 8). These limitations describe variations on the manner in which concurrent negotiations are related to one another and merely add further detail to the abstract idea of multi-party negotiation strategy — i.e., additional methods of organizing human activity and managing commercial interactions — without reciting any technical improvement that would transform the abstract idea into patent-eligible subject matter.
Therefore, claims 1–10 are not drawn to eligible subject matter, as they are directed to an abstract idea without significantly more.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1 and 3–10 are rejected under 35 U.S.C. § 103 as being unpatentable over Ephrati (US 7,296,001 B1) in view of Sierra et al. ("A Framework for Argumentation-Based Negotiation," Intelligent Agents IV: Agent Theories, Architectures, and Languages (ATAL '97), LNAI 1365, Springer, 1998, pp. 177–192).
Claims 1, 9, and 10: Ephrati discloses a negotiation apparatus, negotiation method, and non-transitory recording medium comprising:
a negotiation apparatus, comprising at least one processor, the at least one processor carrying out (col. 12, ll. 5–25; FIG. 13, element 1251. Ephrati discloses a negotiation facilitator system 110 implemented on a computer system having a processor 1251 that executes the program instructions carrying out the operations recited below; claim 9's adding, by at least one processor and claim 10's non-transitory recording medium having recorded thereon a program for causing a computer to carry out the recited processes are likewise disclosed, Ephrati describing implementation as a computer program product including program instructions embodied on a computer readable storage medium.);
in a first negotiation with a first negotiation party … an agreement candidate proposal which is to be provided to the first negotiation party (col. 6, ll. 30–67; FIG. 3; FIG. 7B, element 410A. Ephrati discloses an active negotiation conducted between the facilitator system and a negotiating party, e.g., the active negotiation 410A with Seller A, in which offers and counter offers are exchanged using the negotiation offer object 300, which is an agreement candidate proposal to be provided to a negotiating party.);
the second negotiation is a negotiation with a second negotiation party conducted in association with the first negotiation, the second negotiation party being different from the first negotiation party (col. 4, ll. 60–67; FIG. 7B, elements 410A, 410B, 410C; FIG. 1. Ephrati discloses that the negotiation facilitator system 110 manages, in association with one another, multiple active negotiations conducted by the same buyer with different sellers—e.g., active negotiations 410A, 410B, and 410C with Seller A, Seller B, and Seller C respectively—such that the negotiation with one seller and the negotiation with a different seller are negotiations with different negotiation parties conducted in association by the common buyer through the facilitator system.);
the reason for provision is a reason for provision based on a status of a second negotiation, which is different from the first negotiation, as to the recited status of a second negotiation (col. 8, l. 55 – col. 9, l. 10; FIG. 5. Ephrati discloses that, in a switchable bilateral negotiation, competing offers submitted by inactive sellers in their respective negotiations are recorded by the facilitator system and disclosed to the buyer and, in whole or in part, to the active seller, such that the status of one seller's negotiation—the competing offer—is made available within the associated negotiation.);
the information which indicates the status of the second negotiation including content of the agreement candidate proposal in the second negotiation or information which indicates a result of the second negotiation (col. 8, l. 55 – col. 9, l. 10; FIG. 9, step 906. Ephrati discloses that the information made available across the associated negotiations is the content of a competing offer—i.e., the content of an agreement candidate proposal in that other negotiation—and that the facilitator system selectively discloses aspects of an accepted offer, which is information indicating the content or a result of that other negotiation.); and
an agreement candidate proposal providing process of providing the first negotiation party with the agreement candidate proposal (col. 7, ll. 1–10; FIG. 8, step 810; FIG. 9, step 906. Ephrati discloses that, upon validating an offer, the facilitator system sends a message to the offeror that the offer is valid and discloses the offer to the offeree, thereby providing a negotiation party with the agreement candidate proposal.).
Ephrati does not appear to explicitly disclose a provision reason adding process of adding, in a first negotiation with a first negotiation party, a reason for provision to an agreement candidate proposal; referring to information which indicates an association between the first negotiation and the second negotiation and information which indicates the status of the second negotiation to generate the reason for provision; or adding to the agreement candidate proposal, the generated reason for provision in a manner that enables the first negotiation party to recognize the reason for provision.
Sierra, however, discloses a provision reason adding process of adding, in a first negotiation with a first negotiation party, a reason for provision to an agreement candidate proposal which is to be provided to the first negotiation party (p. 177, Abstract; p. 178, §1. Sierra discloses a framework in which negotiating agents exchange proposals and counter-proposals backed by arguments that summarize the reasons why the proposal should be accepted, sending an argument along with a proposal indicating why it should be accepted, such that a reason supporting a proposal is added to the proposal provided to the counterparty.).
Sierra further discloses referring to information which indicates an association between the first negotiation and the second negotiation and information which indicates the status of the second negotiation to generate the reason for provision (p. 184, Example 1; pp. 186–188, §3.4. Sierra discloses that an agent generates a supporting argument, via the illocution-generation function G, whose content is drawn from the status of a different, associated negotiation; in Example 1, the VCᵢ agent, negotiating with the CSD agent over the vetting of company A, generates an appeal whose reason is that meeting the proposed deadline would require delaying an already-agreed vetting for a different customer, company B, i.e., the reason is generated by reference to the status of an associated second negotiation.).
Sierra further discloses adding to the agreement candidate proposal, the generated reason for provision in a manner that enables the first negotiation party to recognize the reason for provision (pp. 182–185, §§3.1, 3.3; pp. 186–188, §3.4. Sierra discloses that the generated argument is communicated to the counterparty as an appeal illocution appeal (a, b, ξ, [not]ϕ, t), in which ϕ is the argument communicated by agent a to agent b in support of formula ξ, and that the receiving agent interprets the illocution via the interpretation function I, such that the generated reason is added to and conveyed with the proposal in a manner that enables the receiving party to recognize the reason.).
Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the invention to combine Sierra with Ephrati. One would have been motivated to do this in order to improve the likelihood that a candidate proposal is accepted, as Sierra teaches that backing a proposal with an argument summarising the reasons it should be accepted can alter the recipient's beliefs and preferences so as to bring about acceptance.
Claim 3: The combination of Ephrati and Sierra discloses those limitations cited above. Ephrati further discloses wherein in the provision reason adding process, the at least one processor further adds, to the agreement candidate proposal, guarantee information for guaranteeing validity of the reason for provision (col. 6, ll. 40–55; FIG. 3. Ephrati discloses that the offer disclosed to the counterparty includes offeror identification information identifying the party making the offer, which guarantees the validity of the offer.).
The rationale for combining Sierra with Ephrati is articulated above and reincorporated herein by reference.
Claim 4: The combination of Ephrati and Sierra discloses those limitations cited above. Ephrati further discloses wherein in the provision reason adding process, the at least one processor adds, to the agreement candidate proposal, the reason for provision which is inputted via input equipment (col. 6, ll. 40–55; FIG. 13, element 1209. Ephrati discloses a keyboard as input equipment and a free text box in the negotiation offer object by which a negotiating party inputs text accompanying the offer—e.g., "Serious offers only"—which the system adds to the offer object and discloses to the other party, thereby adding to the agreement candidate proposal a reason for provision that is inputted via input equipment.).
The rationale for combining Sierra with Ephrati is articulated above and reincorporated herein by reference.
Claim 5: The combination of Ephrati and Sierra discloses those limitations cited above. Ephrati further discloses wherein in the provision reason adding process, the at least one processor refers to content of an agreement candidate proposal in the second negotiation or information which indicates a result of the second negotiation, as the information which indicates the status of the second negotiation (col. 8, l. 55 – col. 9, l. 10; FIG. 5. Ephrati discloses that the facilitator system refers to the content of a competing offer submitted in one seller's negotiation—and/or the recorded details or outcome of that offer—when disclosing information within the associated negotiation, thereby referring to the content of an agreement candidate proposal in, or a result of, the second negotiation.).
The rationale for combining Sierra with Ephrati is articulated above and reincorporated herein by reference.
Claim 6: The combination of Ephrati and Sierra discloses those limitations cited above. Ephrati further discloses wherein in the provision reason adding process, the at least one processor refers to information which indicates an association of conducting one of the first negotiation and the second negotiation for formation of agreement in the other, as the information which indicates an association (col. 8, l. 55 – col. 9, l. 25; FIG. 5. Ephrati discloses that the facilitator system records competing offers submitted in one negotiation and refers to that information—including under rules requiring a competing offer to improve upon the active negotiation's most recent counter offer—in conducting the associated negotiation toward formation of a deal, such that information indicating an association in which one negotiation is conducted bearing on formation of agreement in the other is referred to by the processor.).
The rationale for combining Sierra with Ephrati is articulated above and reincorporated herein by reference.
Claim 7: The combination of Ephrati and Sierra discloses those limitations cited above. Ephrati further discloses wherein in the provision reason adding process, the at least one processor refers to information which indicates an association of conducting the first negotiation and the second negotiation in parallel for selective formation of agreement only in either the first negotiation or the second negotiation, as the information which indicates an association (col. 9, ll. 40–60; FIG. 5; FIG. 7B. Ephrati discloses a concurrent bilateral negotiation conducted in parallel with multiple sellers in which, upon the buyer's acceptance of one seller's counter offer, a break off message is sent to all other sellers and a deal is made with that one seller, i.e., the parallel associated negotiations are conducted for selective formation of agreement in only one of them.).
The rationale for combining Sierra with Ephrati is articulated above and reincorporated herein by reference.
Claim 8: The combination of Ephrati and Sierra discloses those limitations cited above. Ephrati further discloses wherein in the provision reason adding process, the at least one processor refers to information which indicates an association of conducting the first negotiation and the second negotiation in parallel for formation of agreement in both the first negotiation and the second negotiation, as the information which indicates an association (col. 9, ll. 25–40; col. 10, l. 30 – col. 11, l. 5; FIG. 6, element 160. Ephrati discloses a concurrent bilateral negotiation having more than one active negotiation link conducted in parallel, and a many-to-many multilateral negotiation comprising such parallel individual negotiations, each capable of proceeding to its own deal, i.e., formation of agreement in more than one of the associated negotiations.).
The rationale for combining Sierra with Ephrati is articulated above and reincorporated herein by reference.
Other Relevant Prior Art
Though not cited in the aforementioned rejections, the following references are nevertheless deemed to be relevant to Applicant’s disclosures:
Batachia et al. (7103580), directed to a method for negotiation using intelligent agents.
Noh et al. (20140019368), directed to a method for automated negotiation.
Vasiliu et al. (20100332376), directed to a system and method for auction negotiation.
Rairick et al. (WO2014003917), directed to a method of online price negotiation.
Zhou et al. (CN115345486), directed to a method for exciting contract negotiation under dynamic multi-cycle project joint development.
Response to Arguments
Applicant’s arguments regarding the sufficiency of the arguments under 35 USC 101 are unpersuasive.
Regarding Step 2A, Prong One, Applicant argues, citing the memorandum issued August 4, 2025, that the mental process grouping is not without limit and that the claims recite "specific information processing" rather than a mental process or a method of organizing human activity. Examiner disagrees. As that memorandum states, it "is not intended to announce any new USPTO practice or procedure and is meant to be consistent with existing USPTO guidance," and it reminds examiners that a claim falls outside the mental process grouping only where the limitation cannot practically be performed in the human mind, illustrating that boundary with limitations encompassing artificial intelligence or specific mathematical operations that name the operations performed (see the July 2024 Subject Matter Eligibility Examples, Example 47) or a specific hardware-based data structure. The present claims recite no such limitation—they recite no artificial intelligence, no specific mathematical operation, and no hardware-based data structure—but instead recite referring to information indicating an association and a status and generating a reason therefrom, which are observations, evaluations, and judgments that can practically be performed in the human mind, and which therefore fall squarely within the mental process grouping. See MPEP § 2106.04(a)(2). The same limitations further describe formulating and providing a justification for an offer in a commercial negotiation based on the state of associated negotiations, which is a commercial interaction and the managing of relationships between people, and thus also recites a method of organizing human activity. See MPEP § 2106.04(a)(2). Reciting the abstract idea as "information processing," or with greater specificity, does not remove it from the enumerated groupings, as the recited information processing is itself the abstract idea. Accordingly, the claims recite a judicial exception under Step 2A, Prong One.
Regarding Step 2A, Prong Two, Applicant argues that the recited reason for provision is not merely appended after the fact but is generated based on the association and status information and presented as part of the agreement candidate proposal in a manner that enables recognition, and that this constitutes a practical application and a technical solution to a technical problem. Examiner disagrees. The improvement identified by Applicant is, by Applicant's own characterization, an improvement in "increasing the level of acceptance of a modification proposal"—that is, an improvement in the outcome of the negotiation itself, which is the abstract idea, and not an improvement in the functioning of a computer or in any other technology or technical field. See MPEP § 2106.05(a). The specification confirms this: paragraphs 0015, 0024, and 0052–0054 describe generating the reason for provision by referencing the association and status information and presenting it to the counterparty so as to increase acceptance of a proposal—a description of the abstract idea and its business objective, not of any technical improvement to the computer or to negotiation technology. Applicant's reliance on DDR Holdings is misplaced, as the claims are not necessarily rooted in computer technology to overcome a problem specifically arising in the realm of computer networks; the problem addressed—persuading a counterparty to accept a proposal by providing a supporting reason—is a longstanding problem of commercial negotiation that exists independent of any computer network. The additional elements—the generic processor, the non-transitory recording medium, and the input equipment—apply the abstract idea using generic computer components, and the providing/presenting of the proposal and reason to the negotiation party is insignificant extra-solution activity, none of which integrates the judicial exception into a practical application. See MPEP §§ 2106.05(a), (f), and (g).
Regarding Step 2B, Applicant argues, citing BASCOM, that the claims recite a non-conventional and inventive combination of known elements amounting to significantly more than the abstract idea. This argument is not persuasive. Unlike the claims in BASCOM, which recited a specific, non-conventional arrangement of technical components (the installation of a filtering tool at a specific location on a network, giving it a particular technical benefit), the present claims recite no analogous non-conventional technical arrangement; they recite the generic processor, recording medium, and input equipment performing their ordinary functions to carry out the abstract idea, together with the transmitting/providing of data over a network, which is well-understood, routine, and conventional. See MPEP § 2106.05(d). Considered individually and as an ordered combination, the additional elements do not amount to significantly more than the judicial exception. The ordered combination adds nothing beyond what is present in the elements taken individually, as the generic components merely perform the abstract idea in their expected manner.
Accordingly, the rejection of claims 1–10 under 35 U.S.C. § 101 is maintained.
Finally, Applicant's arguments regarding the previous rejections under 35 U.S.C. § 103 have been fully considered, but are rendered moot in light of the modified grounds of rejection, which were necessitated by the amendments.
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 CHRISTOPHER BUSCH whose telephone number is (571)270-7953. The examiner can normally be reached M-F 10-7.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Waseem Ashraf can be reached at 571-270-3948. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/CHRISTOPHER C BUSCH/Examiner, Art Unit 3621
/WASEEM ASHRAF/Supervisory Patent Examiner, Art Unit 3621
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