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 Final Office Action is in response to Applicant’s Amendment/Request for Reconsideration filed 07/01/2026.
Claims 1 – 27 are pending.
All claims have a priority date of 09/23/2025 per the discussion within the previous Office Action.
Response to Amendment
Applicant's arguments and remarks of 07/01/2026 have been entered.
Applicant’s amendments to the claims have rendered the previous objections as moot; therefore, the objections to claims 2, 10, and 21, are withdrawn.
Applicant’s amendments to claim 9 have rendered the previous rejection under 35 U.S.C. § 112(b) as moot; therefore, this rejection for claim 9 is withdrawn.
Applicant’s amendments to claim 22 have rendered the previous rejections under 35 U.S.C. § 112(d) for claims 22 – 25 as moot; therefore, this rejection for these claims is withdrawn.
The examiner will address applicant's remarks at the end of this office action.
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 – 27 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
At Step 1 of eligibility analysis, the instant claims are directed towards a method and a system; thus, all claims fall within one of the four statutory categories and are considered eligible subject matter.
At Step 2A, Prong One, of analysis, the amended claims set forth a method for proposing task improvement plans within a manufacturing environment. This method is described by detecting operational inefficiencies of a task, evaluating whether regulatory compliance is required, updating documentation and workflows, and propagating the plan throughout the environment. This description aptly describes a mental process of continuous improvement used throughout most industries. The Examiner notes that claims recite a mental process when they contain limitations that can practically be performed in the human mind, including; observations, (detecting operational inefficiencies); evaluations, (evaluating regulatory compliance); judgments, and opinions, (determining approval is not required). The aforementioned mental process is a grouping of abstract idea.
Claim 1, which is illustrative of claims 12 and 21, contains those elements that define this abstract ideas (and are highlighted below):
A method of regulatory-compliant autonomous improvement in a robotic manufacturing environment, comprising:
(a) configuring a plurality of robotic agents to perform one or more tasks in said manufacturing environment;
(b) configuring an idea registry to store, track, and update improvement proposals and associated metadata and validation history;
(c) enabling at least one of said plurality of robotic agents, upon detecting, based on operational data, a deviation or inefficiency in execution of a task conducted in said environment, to generate a corresponding improvement proposal associated with execution of said task and, where available, further based on validation history stored in said idea registry, and to submit said improvement proposal to said idea registry;
(d) evaluating, via a decision module, the improvement proposal based on one or more regulatory compliance protocols to determine whether regulatory approval is required for said improvement proposal; and
(e) upon determining that regulatory approval is not required, or that said improvement approval has been received;
(i) integrating said improvement proposal into one or more of: design documentation, production protocols, and training workflows for said manufacturing environment;
(ii) propagating said improvement proposal to one or more robotic agents and production systems, including updating control instructions or system configurations; and
(iii) causing said one or more robotic agents to execute the updated control instructions during subsequent performance of said task.
At Step 2A, Prong Two, of analysis, the Examiner has determined that the identified abstract idea (judicial exception) is not integrated into a practical application because the additional elements are merely instructions to apply the abstract idea to a computer, as described in MPEP 2106.05(f). Further, in MPEP 2106.05(f) it is noted that "[use] of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general-purpose computer or computer components after the fact to an abstract idea does not integrate a judicial exception into a practical application or provide significantly more.” Therefore, according to the MPEP, this is not solely limited to computers but includes other technology that, recited in an equivalent to “apply it,” is a mere instruction to perform the abstract idea on that technology.
Claims 1, 12, and 21, recite only the following additional elements:
a plurality of autonomous robotic agents;
an idea registry;
a decision module;
an integration module;
non-transitory computer-readable medium storing instructions.
These elements merely invoke computers or other machinery as a tool to perform an existing process. See MPEP 2106.05(f). Foremost, use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data – “an idea registry”), does not integrate a judicial exception into a practical application. Applicant has only broadly referred to, perhaps through incorporation, of “a system and method utilizing computer-integrated manufacturing (CIM), a manufacturing approach of using computers to control the entire production process”. Further, the modules are not specifically defined with structure to perform certain tasks, but rather, merely describe: “…the use of such generative AI systems - including but not limited to large language models (LLMs), multimodal foundation models, and other neural or hybrid architectures…”. Lastly, the use of a plurality of robotic agents is generally linking the use of a judicial exception to a particular technological environment – an industrial robotic manufacturing environment, or “robotic swarm”. “In one illustrative embodiment multiple robots - homogeneous or heterogeneous - are interconnected, forming a swarm of robots”. [0047]. See also [0093]; “Assembly techniques 214 refers to a library of standardized assembly routines or scripts that employ various base automated operations 203 to be performed by one or multiple robots, alone or in swarms. In one preferred embodiment, such assembly techniques 214 are software- based instructions; and in another optional embodiment, these instructions are burned directly onto specialized ROM-based chips used by one or more robots”. These claims suitably describe a field of use or technological environment in which to apply a judicial exception as well as instructions to apply the abstract idea. And cannot integrate a judicial exception into a practical application. See MPEP 2106.05(f) and (h).
At Step 2B of eligibility analysis, the Examiner has determined that the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because they do not amount to more than simply instructing one to practice the abstract idea by using broadly and generically recited devices to perform the steps that define the abstract idea. As discussed above, the additional elements of: (an idea registry; a decision module; an integration module; non-transitory computer-readable medium storing instructions), are recited at a high level of generality and are instructions to apply the exception on a computer. See MPEP § 2106.05(f).
Further, certain limitations amount to merely indicating a field of use or technological environment in which to apply a judicial exception and do not amount to significantly more than the exception itself - a plurality of autonomous robotic agents. This elements are disclosed within the instant application as: “[o]ne or more autonomous, semi-autonomous, and/or human-directed robots, acting independently and in robot swarms, are used as hereinafter…”. [0084]. Limitations that amount to merely indicating a field of use or technological environment in which to apply a judicial exception do not recite significantly more than the abstract idea. See MPEP 2106.05(h).
Dependent claims 2 and 3 contain further embellishments to the same abstract idea found in claim 1. Recitations to tasks and improvements are further definitions that are directed to the method of proposing task improvement plans within a manufacturing environment.; thus, directed to the abstract idea. Further, these claims are applied with the computer or environment of claim 1, which does not provide for integration into a practical application. See MPEP 2106.04(d).
Dependent claims 4, 15, and 27, contain further embellishments to the same abstract idea found in claims 1, 12, and 21. Recitations to an idea registry, it’s data, and propagating the approved improvement using instructions, are linking the performance of the abstract idea identified to a computer, per MPEP 2106.05(f), where it is noted that use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) does not integrate a judicial exception into a practical application.
Dependent claims 5 and 13 contain further embellishments to the same abstract idea found in claims 1 and 12. Recitations to robotic agents or coordinated robotic swarm are linking the performance of the abstract idea to a particular technological environment – a plurality of autonomous robotic agents. Limitations that amount to merely indicating a field of use or technological environment in which to apply a judicial exception do not integrate a judicial exception into a practical application. See MPEP 2106.05(h).
Dependent claims 6, 14, and 20, contain further embellishments to the same abstract idea found in claims 1 and 12. Recitations to AI or models is defined as mere use of this technology without defining any improvement to this technical field. Because this field is broadly and generically defined - “…including but not limited to large language models (LLMs), multimodal foundation models, and other neural or hybrid architectures…”, it recites other technology that, recited in an equivalent to “apply it,” – (“…uses AI…”), is a mere instruction to perform the abstract idea on that technology, per MPEP 2106.05(f), and does not integrate a judicial exception into a practical application.
Dependent claims 7, 9, and 18, contain further embellishments to the same abstract idea found in claims 1 and 12. Recitations to certain manufacturing environments, and testing in that environment, are further descriptions of the concept of proposing task improvement plans within a manufacturing environment. Continuous improvement for processes and workflows is a concept long performed in industry. An improvement to an abstract idea cannot provide an inventive concept. Further, these claims are applied with the computer or environment of claims 1 and 12, thus, not providing for integration into a practical application. See MPEP 2106.04(d).
Dependent claims 8, 16, and 22 – 26, contain further embellishments to the same abstract idea found in claims 1, 12, and 21. Recitations to FAA, EASA, FDA, and EMA, as well as those groups requirements for documentations and approvals, are elements directed to the method for proposing task improvement plans within a manufacturing environment. Therefore, they are directed to the abstract idea identified. Further, these claims are applied with the computer or environment of claims 1, 12, and 21; and thus, do not provide for integration into a practical application. See MPEP 2106.04(d).
Dependent claims 10, 11, 17, and 19, contain further embellishments to the same abstract idea found in claim 1 and 12. Recitations to approvals, polling, compiling data, evaluations, and updating, are expected subsequent steps that follow when an improvement is proposed within any manufacturing environment. Polling of other robotic agents is included here because this requires the evaluation and judgment steps to be performed within a robotic environment. According to the MPEP, this is not solely limited to computers but includes other technology that, recited in an equivalent to “apply it,” is a mere instruction to perform the abstract idea on that technology. See MPEP 2106.05(f).
Therefore, for the reasons cited above, claims 1 – 27, are directed to an abstract idea without integration into a practical application and without reciting significantly more.
Claims Distinguished Over Prior Art
Regarding claims 1, 12, and 21, the prior art does not teach nor suggest a system or method as currently claimed. The most relevant prior art is (Keravala, US 11,738,461), who discloses squads of industrial robots autonomously communicating and working together, perhaps in a manufacturing environment. However, these robots do not identify improvements to tasks nor submit improvement proposals. (Jiao, US 11,698628), teaches methods for optimizing a manufacturing process; but does not suggest robotic agents. The most recent cited prior art, (Nakano), discusses deviations between production plans and actual production results, without teaching robotic agents generating improvement plans. Therefore, the Examiner reads the current claims as reciting elements not disclosed by the prior art. Specifically not disclosed, either alone, or in combination, are the following claimed elements, within claims 1, 12, and 21:
enabling at least one of said plurality of robotic agents, upon detecting, based on operational data, a deviation or inefficiency in execution of a task conducted in said environment, to generate a corresponding improvement proposal associated with execution of said task and, where available, further based on validation history stored in said idea registry; propagating said improvement proposal to one or more robotic agents and production systems, including updating control instructions or system configurations; and causing said one or more robotic agents to execute the updated control instructions during subsequent performance of said task.
Regarding claims 2 – 11, 13 – 20, and 22 – 27, based on their dependency to independent claims 1, 12, and 21, they inherit the distinguished claim limitations and are therefore, also not disclosed by the prior art.
Noting that patentability of any claimed invention under 35 U.S.C. §§ 102 and 103 with respect to the prior art is neither required for, nor a guarantee of, patent eligibility under 35 U.S.C. 101, the Examiner points to other rejections within this Office Action.
Response to Arguments
Applicant's arguments, filed 07/01/2026, have been fully considered but they are not persuasive. Applicant’s remarks are directed to rejection of all prior claims under 35 U.S.C. § 101. See page 12. Applicant traverses this rejection. Based on the reasoning that follows, the Examiner respectfully disagrees with Applicant’s arguments.
Applicant first argues that at Step 2A, Prong One, the claims do not recite a mental process. Applicant adds that the amended claims “recite a specific robotic manufacturing architecture that cannot practically be performed in the human mind.” See page 12. Applicant’s remarks seem to bolster the Examiner’s conclusion that the amend claims do recite a mental process. As noted above, the Examiner concluded that the claims set forth a method for proposing task improvement plans within a manufacturing environment. Applicant’s remarks include “…detecting a deviation or inefficiency in execution of a task based on operational data,…generate an improvement proposal,…and submit the proposal”. Applicant further adds “…evaluating the proposal based on one or more regulatory compliance protocols,…” These claims precisely recite method steps that manufacturing environments perform while performing continuous improvements to warehouse tasks. Known to one skilled in the art Six Sigma techniques or Kaizen methods for eliminating wastes, reducing defects and optimizing workflows. These methods rely heavily on measuring current performance, analyzing data, developing improvements and monitoring and controlling the ongoing process. As noted above, certain relied on arguments; “detecting”, ”generate an improvement”, “submit the proposal”, “evaluating the proposal”, are method steps explicitly defined within the MPEP as reciting a mental process. Examples of mental processes include observations, evaluations, judgments, and opinions. Note that an observation is recited as “detecting”, an evaluation is recited by “evaluating the proposal”, and judgments and opinions are recited by ”generate an improvement” and submit the proposal”. See MPEP 2106.04(a)(2)(III). Applicant’s reliance on MPEP 2106.04(a)(2)(III)(A) is misplaced because the human mind is equipped to perform the above limitations identified as the mental process. Further, the amended claims set forth a method similar to a claim of "collecting information, analyzing it, and displaying certain results of the collection and analysis," where the data analysis steps are recited at a high level of generality such that they could practically be performed in the human mind, Electric Power Group v. Alstom, S.A., 830 F.3d 1350, 1353-54, 119 USPQ2d 1739, 1741-42 (Fed. Cir. 2016). This too is set forth in the instant claims by “detecting operational data”, evaluating the proposal, and “propagating…updating instructions”.
Because claims 12 and claim 21 recite corresponding amended claims, the Examiner remarks also similar lines to claim 1, above. The Examiner has also detailed above where claim 1 is illustrative of claims 12 and 21 in reciting a mental process.
Similar remarks apply to Applicant’s citing of SRI. See page 13. Notable to SRI was the conclusion that the claim recited using a plurality of network monitors to analyze specific network traffic data and integrate generated reports from the monitors to identify hackers and intruders on the network. (Emphasis added). While monitoring network traffic data analyzing network packets cannot practically be performed in the human mind, the above elements of store, track, and update improvement proposals; detecting, based on operational data, a deviation or inefficiency in execution of a task; generate a corresponding improvement proposal associated with execution of said task and, to submit said improvement proposal; evaluating the improvement proposal based on one or more regulatory compliance protocols to determine whether regulatory approval is required for said improvement proposal; and upon determining that regulatory approval is not required, or that said improvement approval has been received; integrating said improvement proposal into one or more of: design documentation, production protocols, and training workflows for said manufacturing environment; propagating said improvement proposal, are all method steps that can (and have historically) been performed practically in the human mind, and recite a mental process. Even the use of a physical aid (i.e., the pen and paper) to help perform a mental step does not negate the mental nature of this limitation. The Examiner again points to Six Sigma techniques or Kaizen methods, which are in fact, graph based; i.e., can be performed with pencil and paper. Applicant’s arguments are not persuasive.
Further to Applicant’s remarks regarding SRI is a discussion of integration into a practical application. Applicant discusses this aspect and the Examiner’s remarks follows.
Applicant argues that the amended claims “recite a specific technical architecture for governing AI-generated behavior in safety-critical robotic manufacturing”. See page 13. The Examiner finds these arguments not persuasive. First, the Applicant adds, at Specification [0059]; that, “[t]his solution not only mitigates the risks associated with hallucinated or unverifiable AI-generated outputs, but also ensures that beneficial process improvements are captured, evaluated, and implemented in a way that maintains both product integrity and regulatory compliance. (Emphasis added). This would regard Applicant’s solution to be directed toward continuous improvements in a manufacturing environment. Continuous improvement is an abstract idea, described by proposing ideas and evaluating ideas. Determining if regulatory compliance is needed is also an abstract concept. It is a facet of the evaluating process and can practically be performed, (and was historically accomplished) by humans observing and documenting workflows and tasks. Thus, Applicant is directing the method steps to provide continuous improvement strategies. Continuous improvement is not a technical environment and Applicant’s use of ordinary devices to perform this task is not enough to provide for integration into a practical application.
Analysis at Step 2A, Prong Two, requires evaluation of whether the claim as a whole integrates the exception into a practical application of that exception. If the additional elements in the claim integrate the recited exception into a practical application of the exception, then the claim is not directed to the judicial exception. See MPEP 2106.04. Relevant considerations for evaluating whether additional elements integrate a judicial exception into a practical application are delineated at MPEP 2106.04(d), and further discussed at MPEP 2106.05, and include an improvement in the functioning of a computer, or an improvement to other technology or technical field. Applicant’s amended claims do not contain such additional elements that might provide for improving a computer or technology. As noted above, the amended claims contain only the following additional elements: a plurality of autonomous robotic agents; an idea registry; a decision module; an integration module; and, non-transitory computer-readable medium storing instructions.
These elements merely invoke computers or other machinery as a tool to perform an existing process. See MPEP 2106.05(f). Foremost, use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data – “an idea registry”), does not integrate a judicial exception into a practical application. Applicant has only broadly referred to, perhaps through incorporation, of “a system and method utilizing computer-integrated manufacturing (CIM), a manufacturing approach of using computers to control the entire production process”. Further, the modules are not specifically defined with structure to perform certain tasks, but rather, merely describe: “…the use of such generative AI systems - including but not limited to large language models (LLMs), multimodal foundation models, and other neural or hybrid architectures…”. Lastly, the use of a plurality of robotic agents is generally linking the use of a judicial exception to a particular technological environment – an industrial robotic manufacturing environment, or “robotic swarm”. “In one illustrative embodiment multiple robots - homogeneous or heterogeneous - are interconnected, forming a swarm of robots”. [0047]. See also [0093]; “Assembly techniques 214 refers to a library of standardized assembly routines or scripts that employ various base automated operations 203 to be performed by one or multiple robots, alone or in swarms. In one preferred embodiment, such assembly techniques 214 are software- based instructions; and in another optional embodiment, these instructions are burned directly onto specialized ROM-based chips used by one or more robots”. These claims suitably describe a field of use or technological environment in which to apply a judicial exception as well as instructions to apply the abstract idea. And cannot integrate a judicial exception into a practical application. See MPEP 2106.05(f) and (h).
As Applicant notes, “the robotic agents…are the entities performing the claimed environment.” See page 14. Thus, describing “apply it” with a robot. The robotic swarm broadly and generically described as noted above. Again, pointing to SRI, those claims recited using a plurality of network monitors to analyze specific network traffic data and integrate generated reports from the monitors to identify hackers and intruders on the network that constituted an improvement in computer network technology. (Emphasis added). Applicant cannot point to improvements in any technology or technical field as recited within the claims; these instant claims merely set forth a method for proposing task improvement plans within a manufacturing environment. Applicant’s arguments are not persuasive.
Applicant’s final argument remarks that the instant claims “are distinguishable from the cases cited”. See page 14. This argument is misplaced and not persuasive. The Examiner’s citing of SAP bolsters the conclusion that an improvement to an abstract idea is not a guarantee of patent eligibility under 35 U.S.C. 101. As detailed earlier, claims 1 – 27 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Nakano discloses product production management using process plan information.
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/SARAH M MONFELDT/Supervisory Patent Examiner, Art Unit 3629
DONALD J. EDMONDS
Examiner
Art Unit 3629
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