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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 December 19, 2025 has been entered.
Status of the Claims
Claims 1-9, 11-17, and 19-22 were previously pending. Claims 1 and 14 were amended in the reply filed September 26, 2025. Claims 1-9, 11-17, and 19-22 are currently pending.
Response to Arguments
Applicant's amendment overcome the objection to the Specification and it is withdrawn.
Applicant's arguments filed with respect to the rejection made under § 101 have been fully considered but they are not persuasive.
"The present technology addresses a technical problem in distributed computing systems used in airline operations. Specifically, the Specification explains that 'there is a need for a system and a method for uniquely identifying flight legs, where the unique identifier is globally unique, does not prohibit usage of other identifiers for flight legs, matches across different domains in the context of aircraft operations, cannot be modified, and that is used identification purposes.' Specification, paragraph [0009]. This problem arises because 'for a flight route comprising a plurality of flight legs, a given flight leg may change during operation of the aircraft due to an event (e.g., change of destination or emergency landing).' Specification, paragraph [0118]. Remarks, 11. This does not describe a technical problem specifically arising in the realm of computers or any other technology, and instead describes problems with organizing human activities (i.e., managing and communicating information about flight operations of an airline enterprise). The same difficulties would be encountered and solved by Applicant's invention if, e.g., two people were speaking about an airline flight leg and using two different identifiers for it. "In sum, 'software can make non-abstract improvements to computer technology just as hardware improvements can.' Enfish, 822 F.3d at 1335. But to be directed to a patent-eligible improvement to computer functionality, the claims must be directed to an improvement to the functionality of the computer or network platform itself." Customedia Techs., LLC v. Dish Network Corp., 951 F.3d 1359, 1365 (Fed. Cir. 2020) (emphasis added). The same reasoning applies to the problems described in the Remarks, 12-13.
"The Specification explains that 'the FLUID may be of a fixed length of 28 characters' including '11 characters for an encoded timestamp (first portion), 1 character as a separator, 3 characters for an encoded source system code (second portion), 1 character as a separator, and 12 characters for an encoded random value (third portion).' Specification, paragraph [0147]. This structured identifier architecture provides a globally unique, machine-readable identifier. Critically, the 12-character random portion overcomes GUFI's technical limitation of ID repetition by providing sufficient character length to ensure global uniqueness over extended time periods." Remarks, 13-14. This does not appear to be a technical improvement for the same reasons as above. See also Secured Mail Solutions LLC v. Universal Wilde, Inc., 873 F.3d 905 (Fed. Cir. 2017) (generation of unique machine-readable identifiers for communicating information held to be ineligible—"Secured Mail argues that the claims are specifically directed to a sender-generated unique identifier, which improved on the existing process both by reliably identifying the sender of the mail object and by permitting the sender to create a bi-directional communication channel between the sender and recipient of the mail object. The fact that an identifier can be used to make a process more efficient, however, does not necessarily render an abstract idea less abstract.").
"This combination of steps—maintaining a database of flight routes with FLUIDs, generating structured unique identifiers with sufficient character length, storing associations, and propagating the complete updated route to multiple systems-provides a specific technical mechanism for automating synchronization across distributed systems that overcomes the limitations of both Business Key and GUFI approaches." Remarks, 15. This describes an improved record-keeping technique that uses a generic computer's abilities to store and transmit data as tools to propagate the information to other parties involved in flight management. "Even though the information being distributed is of a particular variety — here, digital imaging processing based on a distribution rule that determines when a condition is met — distribution of information is an abstract idea." Sanderling Management Ltd. v. Snap Inc., 65 F.4th 698 (Fed. Cir. 2023) (slip op. at 7).
"Amended claim 1 recites steps that cannot practically be performed in the human mind. Specifically, 'generating the third portion of the FLUID based on a random number' requires computational generation of random values. The Specification explains that '[t]he indication of the random number may be received from a random number generator' and that '[t]he random number generator may be one or more of: a true random number generator (TRNG), a pseudo random number generator (PRNG) and cryptographically secure pseudo random number generator (CSPRNGs).' Specification, paragraphs [0142]- [0143]." Remarks, 16. Applicant does not explain why a human cannot mentally conceive of a random number. Moreover, the random number generators in the Specification are merely used as tools to assist in creating abstract data used to identify flight legs. See Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367 (Fed. Cir. 2015) ("claiming the improved speed or efficiency inherent with applying the abstract idea on a computer [does not] provide a sufficient inventive concept"); Bancorp Servs., L.L.C. v. Sun Life Assur. Co. of Can. (U.S.), 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.").
"Here, the Office Action characterizes the claims as merely 'collecting, analyzing, and outputting information' and using computers 'as a tool.' This characterization fails to account for the specific requirements of amended claim 1, including the structured three-portion FLUID generation based on timestamp, source system identification, and random number; the database storage of flight routes with corresponding FLUIDs and the propagation of the complete updated route to ensure consistency across systems. These specific technical steps are not generic data collection but rather a particular mechanism for maintaining data synchronization." Remarks, 17. The creation of an abstract identifier for a flight leg is not an additional element but part of the abstract idea. A process that starts with data, applies an algorithm to the data, and then ends with a new form of data is abstract. Recognicorp, LLC v. Nintendo Co, Ltd., 855 F.3d 1322 (Fed. Cir. 2017). Distributing this abstract information to other parties (via generic computers) is also not a technological improvement as above.
"Here, the Office Action evaluates individual elements—such as the processor, database, and transmission steps—as generic components without considering how these elements interact as an integrated system." Remarks, 17. This was performed at ¶ 19-21 of the Final Office Action (mailed 10/9/2025) and again below.
"Amended claim 1 does not merely claim the abstract idea of 'unique identification.' Rather, it recites a particular way to achieve unique identification through a specific three-portion structure (timestamp, source system, random number) with sufficient character length to avoid the repetition problem that plagued GUFI, storage in a database associating FLUIDs with flight legs, and transmission of the complete flight route with all FLUIDs such that the flight services system and a third-party system each independently refer to a same flight leg using a corresponding same FLUID to ensure consistency. "A claim is not patent eligible merely because it applies an abstract idea in a narrow way." BSG Tech LLC v. BuySeasons, Inc., 899 F.3d 1281, 1287 (Fed. Cir. 2018). Even the characterization here describes certain methods of organizing human activities using generic computer abilities to store and transmit data.
"This automated propagation of data across multiple computer systems cannot be performed mentally." Remarks, 19. Applicant has not rebutted the finding that transmission of data between computers over a nonspecific network is both a generic ability and well-understood, routine, and conventional.
"The claims do not merely recite generic computer components performing generic functions. Rather, they recite a specific mechanism for generating structured identifiers, storing associations in a database, and propagating complete route information to ensure data consistency across multiple systems. This provides a meaningful limitation that transforms any alleged abstract idea into a patent-eligible application." Remarks, 20. As above, storage and transmission of data is not an improvement to computers. Moreover, using generic computers as a tool to more efficiently create abstract identifiers for flight legs is also not an improvement to computers or any other technology.
Although Applicant compares the claimed invention to the one in Desjardins (Remarks, 20-23), they are in no way comparable. In Desjardins, the claimed invention improved machine learning itself rather than using it as a tool to perform otherwise abstract functions. "Here, the invention confronts the persistent issue in distributed computer systems used for airline operations: maintaining robust, automated synchronization of flight leg data across multiple, heterogeneous computer systems when flight legs are modified due to operational events. This is not a mere automation of human activity, but a computer-centric challenge rooted in the limitations of conventional systems, which struggle to maintain consistent references and data integrity when flight leg parameters are updated." Remarks, 21. Even under Applicant's own characterizations, it is not clear what similarities this has with Desjardins. As above, this describes improving communications about flight legs (an abstract idea) using generic computers as tools. It does not improve machine learning techniques or any other capability particular to computers. Accordingly, the rejection is maintained.
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 1-9, 11-17, and 19-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter (abstract idea without significantly more). Claims are eligible for patent protection under § 101 if they are in one of the four statutory categories and not directed to a judicial exception to patentability. Alice Corp. v. CLS Bank Int'l, 573 U.S. 208 (2014). Claims 1-9, 11-17, and 19-22, each considered as a whole and as an ordered combination, are directed to a judicial exception (i.e., an abstract idea) without significantly more.
MPEP 2106 Step 2A – Prong 1:
The claims recite an abstract idea reflected in the representative functions of the independent claims—including:
providing a flight route comprising a plurality of flight legs, each flight leg comprising a corresponding flight leg unique identifier (FLUID);
receiving a request for a new flight leg based on a given flight leg of the flight route, with at least one field of the new flight leg recorded;
generating a new flight leg unique identifier (FLUID), the new FLUID comprising a first portion, a second portion and a third portion, said generating the new FLUID comprising:
generating the first portion of the new FLUID based on a timestamp associated with the new flight leg;
generating the second portion of the new FLUID based on an identification of the source system of the request; and
generating the third portion of the new FLUID based on a random number;
storing the new FLUID associated with the new flight leg;
transmitting the new FLUID with the at least one field of the new flight leg, wherein the flight leg unique identifier comprises an identifier; and
transmitting the flight route comprising the plurality of corresponding FLUIDs and the new FLUID to the flight services, the flight route comprising a plurality of flight legs and the new flight leg, each flight leg comprising a corresponding flight leg unique identifier (FLUID), the new flight leg comprising the new FLUID, the flight services and a third-party each independently referring to a same flight leg using a corresponding same FLUID to ensure consistency in communications;
wherein the plurality of corresponding FLUIDs and the new FLUID comprises identifiers.
These limitations taken together qualify as a certain method of organizing human activities because they recite collecting, analyzing, and outputting information for managing and communicating information about flight operations of an airline enterprise (i.e., in the terminology of the 2019 Revised Guidance, fundamental economic practices (i.e., flight record keeping); commercial interactions (including business relations); managing personal behavior or relationships or interactions between people (including social activities). Additionally, it recites purely mental processes (e.g., an airline employee observing and evaluating new flight leg data, and arriving at a judgment on a flight leg unique identifier).
It shares similarities with other abstract ideas held to be non-statutory by the courts (see Secured Mail Solutions v. Universal Wilde, 873 F.3d 905 (Fed. Cir. 2017)—communicating information about a mail object using a personalized marking, similar because at another level of abstraction the claims could be characterized as communicating information about a flight leg using a unique identifier; University of Florida Research Foundation v. GE Company, 916 F.3d 1363 (Fed. Cir. 2019)—collecting, analyzing, manipulating (including converting into a different format), and displaying data, which also characterizes the invention). See also Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1340 (Fed. Cir. 2017) (discussing abstract idea precedent related to the collection, recognition, manipulation, and storage of data).
These cases describe significantly similar aspects of the claimed invention, albeit at another level of abstraction. See Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1240-41 (Fed. Cir. 2016) ("An abstract idea can generally be described at different levels of abstraction. As the Board has done, the claimed abstract idea could be described as generating menus on a computer, or generating a second menu from a first menu and sending the second menu to another location. It could be described in other ways, including, as indicated in the specification, taking orders from restaurant customers on a computer.").
MPEP 2106 Step 2A – Prong 2:
This judicial exception is not integrated into a practical application because there are no meaningful limitations that transform the exception into a patent eligible application. The elements merely serve to provide a general link to a technological environment (e.g., computers and the Internet) in which to carry out the judicial exception (database; processor connected to a source system comprising one selected from the group of a schedule management system and flight services system, computer-readable identifier readable by at least one of a plurality of computer systems, non-transitory storage medium storing computer-readable instructions thereon; and at least one processor operatively connected to the non-transitory storage medium—all recited at a high level of generality).
Although they have and execute instructions to perform the abstract idea itself (e.g., modules, program code, etc. to automate the abstract idea), this also does not serve to integrate the abstract idea into a practical application as it merely amounts to instructions to "apply it." Aside from such instructions to implement the abstract idea, they are solely used for generic computer operations (e.g., receiving, storing, retrieving, transmitting data), employing the computer as a tool. See FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1096 (Fed. Cir. 2016) ("[T]he use of generic computer elements like a microprocessor or user interface do not alone transform an otherwise abstract idea into patent-eligible subject matter.") (citing DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245,1256 (Fed. Cir. 2014)) (emphasis added).
The claims only manipulate abstract data elements into another form. They do not set forth improvements to another technological field or the functioning of the computer itself and instead use computer elements as tools to improve the functioning of the abstract idea identified above. Looking at the additional limitations and abstract idea as an ordered combination and as a whole 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. Rather than any meaningful limits, their collective functions merely provide generic computer implementation of the abstract idea identified in Prong One. None of the additional elements recited "offers a meaningful limitation beyond generally linking 'the use of the [method] to a particular technological environment,' that is, implementation via computers." Alice Corp., slip op. at 16 (citing Bilski v. Kappos, 561 U.S. 610, 611 (U.S. 2010)).
At the levels of abstraction described above, the claims do not readily lend themselves to a finding that they are directed to a nonabstract idea. Therefore, the analysis proceeds to step 2B. See BASCOM Global Internet v. AT&T Mobility LLC, 827 F.3d 1341, 1349 (Fed. Cir. 2016) ("The Enfish claims, understood in light of their specific limitations, were unambiguously directed to an improvement in computer capabilities. Here, in contrast, the claims and their specific limitations do not readily lend themselves to a step-one finding that they are directed to a nonabstract idea. We therefore defer our consideration of the specific claim limitations’ narrowing effect for step two.") (citations omitted).
MPEP 2106 Step 2B:
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception for the same reasons as presented in Step 2A Prong 2 (i.e., they amount to nothing more than a general link to a particular technological environment and instructions to apply it there). Moreover, the additional elements recited are known and conventional computing elements (database; processor connected to a source system comprising one selected from the group of a schedule management system and flight services system, computer-readable identifier readable by at least one of a plurality of computer systems, non-transitory storage medium storing computer-readable instructions thereon; and at least one processor operatively connected to the non-transitory storage medium—see Specification ¶¶ 0040-42, 59, 66-67, 75, 90, 103, 136 describing these at a high level of generality and in a manner that indicates that the additional elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy the statutory disclosure requirements).
The Federal Circuit has recognized that "an invocation of already-available computers that are not themselves plausibly asserted to be an advance, for use in carrying out improved mathematical calculations, amounts to a recitation of what is 'well-understood, routine, [and] conventional.'" SAP Am., Inc. v. InvestPic, LLC, 890 F.3d 1016, 1023 (Fed. Cir. 2018) (alteration in original) (citing Mayo v. Prometheus, 566 U.S. 66, 73 (2012)). Apart from the instructions to implement the abstract idea, they only serve to perform well-understood functions (e.g., receiving, storing, retrieving, transmitting data—see Specification above as well as Alice Corp.; Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307 (Fed. Cir. 2016); and Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015) covering the well-known nature of these basic computer functions).
"The use and arrangement of conventional and generic computer components recited in the claims—such as a database, user terminal, and server— do not transform the claim, as a whole, into 'significantly more' than a claim to the abstract idea itself. We have repeatedly held that such invocations of computers and networks that are not even arguably inventive are insufficient to pass the test of an inventive concept in the application of an abstract idea." Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1056 (Fed. Cir. 2017) (citations and quotation marks omitted). 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.
Dependent Claims Step 2A:
The limitations of the dependent claims but for those addressed below merely set forth further refinements of the abstract idea without changing the analysis already presented (i.e., they merely narrow the abstract idea without adding any new additional elements beyond it). Additionally, for the same reasons as above, the limitations fail to integrate the abstract idea into a practical application because they use the same general technological environment and instructions to implement the abstract idea as the independent claims (i.e., a generic computer processor and source system comprising one selected from the group of a schedule management system and flight operation control system). Claims 13 and 20-22 recite various generic "systems" only characterized by their abstract functions (e.g., flight planning, crew operations, etc.). Claims 12 and 19 introduce a generic database. All of these merely serve to further limit the general link to a particular technological environment in which to execute the abstract idea.
Dependent Claims Step 2B:
The dependent claims merely use the same general technological environment and instructions to implement the abstract idea. Although they add the elements identified in 2A above (generic "systems" and database), these do not amount to significantly more for the same reasons they fail to integrate the abstract idea into a practical application. Moreover, the Specification also indicates this is the routine use of known components for the same reasons presented with respect to the elements in the independent claims above (see ¶¶ 0042, 90-93, 103, 121 describing these at a high level of generality and without appreciable technical specifics). Accordingly, they are not directed to significantly more than the exception itself, and are not eligible subject matter under § 101.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to DANIEL VETTER whose telephone number is (571)270-1366. The examiner can normally be reached M-F 9:00-6:00.
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/DANIEL VETTER/
Primary Examiner, Art Unit 3628