LinkedIn Corporation

Patent Trials and Appeals Board

Jan 26, 2022

2021002848 (P.T.A.B. Jan. 26, 2022)

UNITED STATES PATENT AND TRADEMARK OFFICE UNITED STATES DEPARTMENT OF COMMERCE United States Patent and Trademark Office Address: COMMISSIONER FOR PATENTS P.O. Box 1450 Alexandria, Virginia 22313-1450 www.uspto.gov APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO. 14/555,327 11/26/2014 Eduardo Vivas 3080.B88US1 8920 45839 7590 01/26/2022 SCHWEGMAN LUNDBERG & WOESSNER / LINKEDLN/MICROSFT PO BOX 2938 MINNEAPOLIS, MN 55402 EXAMINER FISHER, PAUL R ART UNIT PAPER NUMBER 3689 NOTIFICATION DATE DELIVERY MODE 01/26/2022 ELECTRONIC Please find below and/or attached an Office communication concerning this application or proceeding. The time period for reply, if any, is set in the attached communication. Notice of the Office communication was sent electronically on above-indicated "Notification Date" to the following e-mail address(es): USPTO@slwip.com slw@blackhillsip.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________________ Ex parte EDUARDO VIVAS, ANTHONY DUANE DUERR, AARON TYLER RUCKER, NIKKO DAVID BAUTISTA, IAIN MACNAUGHTON, RAFAEL E. CRESPO, KYLE SOSNOWSKI, CHRISTOPHE BOUDET, and NITIN PERUMBETI __________________ Appeal 2021-002848 Application 14/555,327 Technology Center 3600 ____________________ Before HUBERT C. LORIN, ANTON W. FETTING, and JAMES P. CALVE, Administrative Patent Judges. CALVE, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE1 Pursuant to 35 U.S.C. § 134(a), Appellant appeals from the decision of the Examiner to reject claims 1, 2, 4-6, and 8-12, which are all of the pending claims.2 See Appeal Br. 1. We have jurisdiction under 35 U.S.C. § 6(b). We AFFIRM. 1 “Appellant” refers to “applicant” as defined in 37 C.F.R. § 1.42. Appellant identifies Microsoft Technology Licensing LLC as the real party in interest. See Appeal Br. 2. 2 Claims 3, 7, and 13-22 are cancelled. See Final Act. 2. Appeal 2021-002848 Application 14/555,327 2 CLAIMED SUBJECT MATTER Claim 1, the sole independent claim, recites a method as follows: 1. A computer-implemented method for ingesting job listings from a plurality of company websites, wherein the ingested job listings are added to a job listings database searchable by end users of a job hosting service, the job listings database including both ingested job listings and paid job listings from various companies, the method comprising: for each company of a plurality of companies having a company website with an associated company uniform resource locator (URL), accessing and analyzing, via a job ingestion software module, the company website associated with the company unifom1 resource locator (URL) to determine a job listing URL of the company website having a plurality of job listings for the respective company; for each company of the plurality of companies, accessing, via the job ingestion software module, one or more of the job listings for the respective company to obtain job attributes for the one or more job listings of the respective company; for each of the one or more job listings, using an idempotent function, generating an identifier for the respective job listing; for each of the one or more job listings, comparing the identifier of the respective job listing with a list of identifiers associated with job listings stored in the job listings database accessible to the job hosting service; when, as a result of the comparison of the respective identifiers, a determination is made that a job listing has an identifier that is not associated with an identifier of an existing job listing stored in the job listings database accessible to the job hosting service, generating, from the obtained job attributes of the job listing, a new job listing for inclusion in the job listings database accessible to the job hosting service, and storing, in the job listings database accessible to the job hosting service the new job listing; and Appeal 2021-002848 Application 14/555,327 3 responsive to a job search invoked by a user of the job hosting service, presenting in a user interface a set of search results satisfying the job search, the set of search results including i) one or more ingested job listings stored in the job listings database, and ii) one or more paid job listings posted to the job hosting service directly via a user interface of the job hosting service. Appeal Br. 46 (Claims App.). REJECTIONS Claims 1, 2, 4-6, and 8-12 are rejected under 35 U.S.C. § 101 as directed to a judicial exception without significantly more. Claims 1, 8, 9, and 12 are rejected under 35 U.S.C. § 103 as unpatentable over Berg,3 Farooque,4 and Dixon.5 Claim 2 is rejected under 35 U.S.C. § 103 as unpatentable over Berg, Farooque, Dixon, and Jurney.6 Claims 4 and 5 are rejected under 35 U.S.C. § 103 as unpatentable over Berg, Farooque, Dixon, Jurney, and Luo.7 Claim 6 is rejected under 35 U.S.C. § 103 as unpatentable over Berg, Farooque, Dixon, Jurney, and Rahman.8 Claims 10 and 11 are rejected under 35 U.S.C. § 103 as unpatentable over Berg, Farooque, Dixon, and Ananian.9 3 US 2009/0063468 A1, published March 5, 2009. 4 US 2013/0239026 A1, published September 12, 2013. 5 US 2009/0063273 A1, published March 5, 2009. 6 US 2012/0226623 A1, published September 6, 2012. 7 US 2008/0065633 A1, published March 13, 2008. 8 US 2011/0208664 A1, published August 25, 2011. 9 US 2012/0150761 A1, published June 14, 2012. Appeal 2021-002848 Application 14/555,327 4 ANALYSIS Eligibility of Claims 1, 2, 4-6, and 8-12 The Examiner determines the claims relate to collecting and posting data related to job listings by accessing URL information, determining a URL with job postings, obtaining job attributes, generating a hash value, comparing the hash value, and storing the listings in a database, and such activities are both fundamental economic or business practices, which are a method of organizing human activity, and mental processes. Final Act. 3. The Examiner determines similar acts of collecting and comparing data have been held to be abstract ideas. Id. The Examiner determines that collecting and posting jobs data for users is a fundamental business practice known in the employment field, and such activities manage relationships between employers and prospective employees. Id.; see Ans. 14-16. The Examiner determines that the claims do not recite a practical application because obtaining, storing, and presenting data are insignificant extra solution activity of data gathering and presenting, and the comparison and inclusion steps can be performed in the human mind. Final Act. 4-6. The Examiner also determines that the specific manner of generating a hash value for comparison in the dependent claims is not disclosed as a specific application but instead is a general concept that can generate hashes using any technique. Id. at 5-6. The Examiner further determines that the claimed elements, taken individually and in combination, do not improve computers, another technology, or a technical field but merely link the abstract idea to a particular environment. Id. at 6. The Examiner determines that the claims only require generic computer components and functions that do not provide significantly more than the abstract idea. Id. at 6-7. Appeal 2021-002848 Application 14/555,327 5 Principles of Law 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. 35 U.S.C. § 101. Laws of nature, natural phenomena, and abstract ideas are not patentable. See Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014). To distinguish patents that claim laws of nature, natural phenomena, and abstract ideas from those that claim patent-eligible applications, we first determine whether the claims are directed to a patent-ineligible concept. Id. at 217. If they are, we consider the claim elements, individually and as an ordered combination, to determine if any additional elements provide an inventive concept sufficient to ensure that the claims in practice amount to significantly more than a patent on the ineligible concept. Id. at 217-18. The USPTO has issued guidance about this framework. 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Revised Guidance”). To determine if a claim is “directed to” an abstract idea, we evaluate whether the claim recites: (1) any judicial exceptions, including certain groupings of abstract ideas listed in the Revised Guidance (i.e., mathematical concepts, certain methods of organizing human activities such as a fundamental economic practice, or mental processes); and (2) additional elements that integrate the judicial exception into a practical application.10 Id. at 52-55. 10 “A claim that integrates a judicial exception into a practical application will apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception.” Revised Guidance, 84 Fed. Reg. at 54. Appeal 2021-002848 Application 14/555,327 6 If a claim (1) recites a judicial exception and (2) does not integrate that exception into a practical application, we consider whether the claim (3) provides an inventive concept such as by adding a limitation beyond a judicial exception that is not “well-understood, routine, conventional” in the field or (4) appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. Revised Guidance, 84 Fed. Reg. at 56. Step 1 We agree with the Examiner that claim 1 recites a method, which falls within a statutory category of invention of a process. See 35 U.S.C. § 101; Non-Final Act. 3. Alice Step One Revised Guidance Step 2A, Prong One: Do the Claims Recite a Judicial Exception? We agree with the Examiner that the claims recite certain methods of organizing human activity by accessing uniform resource locators (URLs) of companies, determining a URL with job postings, obtaining job attributes, generating a hash value, comparing the hash value, storing the listings in a database, and presenting job listings. These steps manage interactions and business relations of employers and prospective employees. Final Act. 3-4; Ans. 14-16; Revised Guidance, 84 Fed. Reg. at 52. Collecting and posting job listings also involves mental processes. Final Act. 3; Ans. 18-19. The claims focus on data processing systems for hosting job postings and techniques for automatically ingesting basic job postings into a social network. Spec. ¶¶ 1, 16-20. The application title, AUTOMATED JOB INGESTION, reflects this focus as does the preamble of claim 1. Appeal 2021-002848 Application 14/555,327 7 Appellant argues that the Office Action does not identify what claim language relates to collecting and posting job listings data. Appeal Br. 11- 12. Appellant asserts that the claims are not “accessing URL information, determining a URL with job postings, obtaining job attributes, generating a hash value, comparing the hash value and storing the listings in a database” as the Examiner has indicated. Id. at 12. We are not persuaded. The Examiner’s determinations notified Appellant of the limitations that recite the identified abstract idea. See Final Act. 3-4; Ans. 14-16. Appellant’s arguments largely track the limitations, which do not have to be recited verbatim. See Appeal Br. 11-12; see also In re Jung, 637 F.3d 1356, 1362-63 (Fed. Cir. 2011) (office actions placed applicant on notice of the rejection as manifested by applicant’s responses). Claim 1 recites steps of collecting and posting job listings by using a job ingestion software module for “accessing and analyzing . . . the company website associated with the company [URL] to determine a job listing URL of the company website,” “accessing, via the job ingestion module, one or more of the job listings . . . to obtain job attributes for the one or more job listings,” “generating an identifier for the respective job listing,” “comparing the identifier of the respective job listing with a list of identifiers associated with job listings stored in the job listings database,” “generating . . . a new job listing for inclusion in the job listings database” if comparison indicates the job identifier is not already in the job listings database, and “presenting” job listings stored in the database in response to a job search. Appeal Br. 46 (Claims App.). Claim 2 recites “posting the generated new job listing” and claim 8 recites “generating a hash.” Appeal Br. 47-48 (Claims App.); see also Ans. 15 (discussing limitations in dependent claims 2 and 8). Appeal 2021-002848 Application 14/555,327 8 These steps and features organize the activities and relationships of employers seeking employees for jobs and prospective employees seeking employment by collecting job listings data from company websites and analyzing that data with identifiers/hash values to generate new job listings to include in a job listings database, and presenting job listings responsive to a job search. See Ans. 16; Appeal Br. 46 (Claims App.). The Specification indicates that job hosting services post job listings so users of the service can search and apply for jobs. Spec. ¶ 2. The job ingestion module 206 automates the retrieval of job listings that are posted on company websites outside of the social network system. Id. ¶ 33. Job ingestion module 206 can retrieve, access, and/or crawl for jobs on company websites. Id. ¶ 46. Job ingestion module 206 collects field attributes from a job URL and generates job listings from the extracted data. Id. ¶¶ 67, 77. Recited at this level of generality, such data collection and analysis is an abstract idea. See Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016) (“[S]electing information, by content or source, for collection, analysis, and display does nothing significant to differentiate a process from ordinary mental processes, whose implicit exclusion from § 101 undergirds the information-based category of abstract ideas.”); see also In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607, 613 (Fed. Cir. 2016) (classifying and storing digital images in an organized manner based on attached classification data is a method of organizing human activity); Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343, 1347 (Fed. Cir. 2014) (steps of collecting data, recognizing and extracting data in the collection, and storing the recognized data are functions humans always have performed to organize and store data). Appeal 2021-002848 Application 14/555,327 9 Here, the claims access company websites and job listings on those websites to obtain job attributes that are extracted and classified with an identifier that is compared to identifiers of other job listings in a database to determine whether the job listing should be included as a new listing in the database. Such activities recite mental processes. See PersonalWeb Techs. LLC v. Google LLC, 8 F.4th 1310, 1317 (Fed. Cir. 2021) (“[T]he step of comparing the content-based identifier against other values. That is all abstract.”); Classen Immunotherapies, Inc. v. Biogen IDEC, 659 F.3d 1057, 1067 (Fed. Cir. 2011) (simply collecting and comparing known data recite mental steps); CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1373 (Fed. Cir. 2011) (collecting and comparing lists of credit card numbers to Internet transactions to determine if different transactions use different credit cards of different user names and billing addresses from the same IP address can be performed entirely in the human mind including the logical reasoning); see also Final Act. 3 (citing Classen and Electric Power). Appellant asserts that the Revised Guidance does not recognize a sub- grouping of fundamental economic or business practices and a fundamental business practice is not a recognized sub-groupings of the certain methods of organizing human activity category of abstract ideas. Appeal Br. 13. We are not persuaded. 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. . . . The Board’s slight revision of its abstract idea analysis does not impact the patentability analysis.”). The certain methods of organizing human activity category of abstract ideas includes commercial or legal interactions, business relations, and managing personal relationships and interactions between people. See Revised Guidance, 84 Fed. Reg. at 52. Appeal 2021-002848 Application 14/555,327 10 Here, the Examiner correctly determined that the claims recite steps that organize the human activity of job searches by collecting and storing job listings of employers so prospective employees can conduct a job search by using a job hosting service that stores such job listings in a database that can be searched by the user. See Final Act. 3-4; Ans. 13-16. Organizing such job searching activities of companies and prospective employees falls within the certain methods of organizing human activity category whether labelled as a fundamental economic/business practice, business relation, or managing personal behavior, relationships, and interactions between people. Revised Guidance, 84 Fed. Reg. at 52. As indicated by the decisions cited above, our reviewing court held similar steps of collecting, analyzing, and classifying data to recite methods of organizing human activity and mental processes, which are within the enumerated categories of abstract ideas. See id.; see also In re Ferguson, 558 F.3d 1359, 1364 (Fed. Cir. 2009) (a method of organizing business or legal relationships in the structuring of a sales force or marketing company is not patent eligible) (cited in id. n.13). “Merely claiming ‘those functions in general terms, without limiting them to technical means for performing the functions that are arguably an advance,’ does not make a claim eligible at step one.” Ericsson Inc. v. TCL Commc’n Tech. Holdings Ltd., 955 F.3d 1317, 1328 (Fed. Cir. 2020); SAP Am., Inc. v. InvestPic, LLC, 898 F.3d 1161, 1167-68 (Fed. Cir. 2018) (to avoid ineligibility, a claim must have the specificity that transforms it from one claiming only a result to one claiming a way of achieving the result); Elec. Power, 830 F.3d at 1356 (noting that the essentially result-focused, functional character of the claim language at issue is a frequent feature of claims that are held to be ineligible under § 101); cf. Appeal Br. 15-16. Appeal 2021-002848 Application 14/555,327 11 Here, the claims recite a method of ingesting job listings without any technical implementation details or any recital of a particular technique for ingesting job listings from third-party websites for inclusion in a searchable database of a job hosting service as Appellant contends. See Appeal Br. 15. As claimed, the job ingestion can be accomplished by any and all technical means. The hash function uses a “hash-checking algorithm” to determine if a new job listing differs from an existing job listing with the same identifier. Appeal Br. 48-50 (Claims App.). The Specification describes such hashing generically without any technical details or improvements to the function. Spec. ¶¶ 86, 92, 93; see SAP, 898 F.3d at 1167 (“The focus of the claims, as reflected in what is quoted above, is on selecting certain information, analyzing it using mathematical techniques, and reporting or displaying the results of the analysis. That is all abstract.”). The Examiner determines that the hashing and comparison can be performed as mental processes. Ans. 17. Appellant argues that ingesting online job listings is a concept entirely grounded in computer technology and cannot be performed as a mental process. Appeal Br. 16. Appellant argues that the human mind cannot ingest data from a website or access data on a website or store such data in a database. Id. at 17. Appellant argues that the human mind cannot access a company website using a URL as claimed. Id. at 18. Appellant asserts that the specification describes the process as performed by servers for millions of job listings that cannot be performed in the human mind. Id. at 19. “That purely mental processes can be unpatentable, even when performed by a computer, was precisely the holding of the Supreme Court in Gottschalk v. Benson.” CyberSource, 654 F.3d at 1375 (citing Gottschalk v. Benson, 409 U.S. 63, 65-67, 71 (1972)). Appeal 2021-002848 Application 14/555,327 12 CyberSource also held that obtaining information about credit card transactions on the Internet can be performed by a human who simply reads records of Internet credit card transactions from a preexisting database. Id. at 1372. “[E]ven if some physical steps are required to obtain information from the database (e.g., entering a query via a keyboard, clicking a mouse), such data-gathering steps cannot along confer patentability.” Id. A person also can construct a map of credit card numbers by writing down a list of credit card transactions made from a particular IP address. Id. Performing an abstract idea on an Internet computer network or a generic computer is still an abstract idea. See BASCOM Global Internet Servs., Inc. v. AT&T Mobility LLC, 827 F.3d 1341, 1348 (Fed. Cir. 2016); see also Secured Mail Solutions LLC v. Universal Wilde, Inc., 873 F.3d 905, 911 (Fed. Cir. 2017) (personalized URL patents that affixed a personalized network address to a mail object that a recipient could activate as a request over the network using the personalized network address to display data on the screen simply communicated information about a mail object as an abstract idea); Intellectual Ventures I LLC v. Erie Indemnity Co., 850 F.3d 1315, 1330 (Fed. Cir. 2017) (“Remotely accessing and retrieving user- specified information is an age-old practice that existed well before the advent of computers and the Internet. . . . Yet the claimed invention does not recite any particular unique delivery of information through this mobile interface. Rather, it merely recites retrieving the information through the mobile interface.”). In Erie, pointers provided links to access user specific resources and information. Erie, 850 F.3d at 1330. Here, job ingestion is done by steps that a user can perform by visiting a company’s website at a URL and accessing job listings at the website to obtain job attributes. Appeal 2021-002848 Application 14/555,327 13 The Specification indicates that job ingestion module 206 can mine employer seed URLs (company URLs) using a search engine optimization tool, user input of seed URL, crawling of directories, or crawling of search result pages to discover company URLs in order to ingest job listings. Spec. ¶ 57. Job ingestion module 206 can identify job URLs with job listings and extract raw HTML from a job URL and extract fields from the raw HTML. Id. ¶¶ 58-62. Few technical details are described, and none are claimed to distinguish the job ingestion process from mental processes that job seekers use to find job listings at company websites and extract job attributes from the listings to store on a computer or in a spreadsheet or database. See Ans. 17-18; Spec. ¶ 33 (job ingestion module automates retrieval of job listings). Moreover, “the inability for the human mind to perform each claim step does not alone confer patentability.” FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1098 (Fed. Cir. 2016) (“As we have explained, ‘the 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.’”) (quoting Bancorp Servs., L.L.C. v. Sun Life Assurance Co. of Can. (U.S.), 687 F.3d 1266, 1278 (Fed. Cir. 2012)). In FairWarning, the claimed method detected fraud and/or misuse in a computer environment by analyzing computer audit log files and user identifier data of human activity to detect suspicious behavior. Id. at 1093. Collecting information about the accesses made to a patient’s personal health information and analyzing that information using rules related to accesses in excess of a specific volume, accesses during a pre-determined time interval, and accesses by a specific user to identify improper access merely collected and analyzed information by steps that people can go through in their minds as mental processes. Id. Appeal 2021-002848 Application 14/555,327 14 Decisions discussed above such as CyberSource, FairWarning, TLI, Electric Power Group, and Content Extraction indicate that job ingestion of job listings and job attributes from company websites at a URL to include generating and comparing identifiers for respective job listings to generate new job listings for inclusion in a job listings database can be performed as mental processes when recited at this level of generality. See Berkheimer v. HP Inc., 881 F.3d 1360, 1367 (Fed. Cir. 2018) (using a parser to determine and extract components of a document and reassemble the components into a composite output file recites the abstract ideas of storing and editing data where the parsing and comparing steps are similar to the collecting and recognizing of Content Extraction and the classifying in an organized manner of TLI); Internet Patents Corp. v. Active Network, Inc., 790 F.3d 1343, 1349 (Fed. Cir. 2015) (dynamically generating online application forms in response to activation of a hyperlink represents generic data collection steps). The hash function uses a hash-checking algorithm without technical details. See Spec. ¶¶ 92, 93. As claimed, it can be performed as a mental process. See Elec. Power, 830 F.3d at 1354 (“[W]e have treated analyzing information by steps people go through in their minds, or by mathematical algorithms, without more, as essentially mental processes within the abstract idea category.”); Bancorp, 687 F.3d at 1277-78 (definitions of computers illustrate the interchangeability of certain mental processes and basic digital computation, and help explain why the use of a computer in an otherwise patent-ineligible process for no more than its most basic function of making calculations and computations fails to circumvent the prohibition against patenting abstract ideas and mental processes); Ans. 18-19. Appeal 2021-002848 Application 14/555,327 15 Even if the Specification described technical improvements for the job ingestion and hashing as Appellant alleges (Appeal Br. 17-20), no details are claimed. See Ericsson, 955 F.3d at 1325 (“While the specification may be ‘helpful in illuminating what a claim is directed to . . . the specification must always yield to the claim language’ when identifying the ‘true focus of a claim.’”); Accenture Glob. Servs., GmbH v. Guidewire Software, Inc., 728 F.3d 1336, 1345 (Fed. Cir. 2013) (“[T]he complexity of the implementing software or the level of detail in the specification does not transform a claim reciting only an abstract concept into a patent-eligible system or method.”). Nor do the claims recite techniques for processing millions of job listings. Accordingly, we determine that the claims recite the abstract idea identified above. Alice Step One Revised Guidance Step 2A, Prong Two: Is There an Integration into a Practical Application? We next consider whether the claims recite additional elements that integrate the abstract idea into a practical application. Revised Guidance, 84 Fed. Reg. at 54. We agree with the Examiner that the claims lack any additional elements to integrate the abstract idea into a practical application. The claims recite steps that amount to data processing functions of accessing and obtaining job listing attributes from company URLs and generating a job identifier to compare to identifiers of jobs stored in a job listings data base. These limitations recite aspects of the abstract idea or extra-solution activity such as presenting a set of search results. See Elec. Power, 830 F.3d at 1354 (merely presenting results of abstract processes of collecting and analyzing information, without more, such as identifying a particular tool for the presentation, is abstract as an ancillary part of the collection and analysis). Appeal 2021-002848 Application 14/555,327 16 As such, the claims lack additional elements that improve computers or other technology, that provide a particular machine that is integral to the claim, that transform or reduce a particular article to a different state or thing, or that effect a treatment or prophylaxis for a disease or medical condition. See Final Act. 4-5; Revised Guidance, 84 Fed. Reg. at 55. The “job listings database” is a generic database that performs generic functions of containing job listings. Spec. ¶¶ 19, 21. It may be implemented as a general-purpose computer modified by software to be a special-purpose computer to perform one or more of the functions described for it. Id. ¶ 25. A “database” is “a data storage resource and may store data structured as a text file, a table, a spreadsheet, a relational database . . ., a triple store, a hierarchical data store, or any suitable combination thereof.” Id. Appellant argues that generating an identifier for ingested job listings and comparing a generated identifier with identifiers of existing job listings in a job listings database prevents adding duplicate job listings when an job listing already existing in the database has the same identifier thereby to improve technology. Appeal Br. 21, 23. Appellant also argues that users can expect search results to include job listings ingested from company websites and paid job listings posted to the job hosting service directly, which is an improvement over using fee-based job boards or separately browsing job listings on individual company websites. Id. at 22. Appellant’s arguments are not persuasive for several reasons. First, the features relied upon by Appellant for integration and eligibility are features of the abstract idea identified under Prong One. As such, they are not additional elements that can integrate that abstract idea into a practical application. Appeal 2021-002848 Application 14/555,327 17 “Additional elements” refer to claim features, limitations, and/or steps that are recited in a claim beyond the identified judicial exception. Revised Guidance, 84 Fed. Reg. at 55 n.24); see also Alice, 573 U.S. at 221 (a claim that recites an abstract idea must include additional features to ensure it does not monopolize the abstract idea). Even if we consider these features as additional elements, they do not represent improvements to computers or other technology. “Software can make non-abstract improvements to computer technology just as hardware improvements can, and . . . the improvements can be accomplished through either route.” Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335 (Fed. Cir. 2016). However, “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) (citing Enfish, 822 F.3d at 1336-39). We find no such improvements in the claimed method as implemented in a generic computer environment. See Spec. ¶¶ 21-26, Fig. 1. The unique identification can be generated using an unidentified “idempotent function.” Id. ¶ 84. It can be associated with a job code. Id. “If the global ID does not exist in the database 115, then the job listing can be created.” Id. ¶ 85. If the global ID of the new job listing already exists for a current job listing in the job listing database, the management node 301 can generate a hash of the current job and the new job. Id. ¶ 86. If hashes of the new and existing job listings are different, then management node 301 can update the existing job listing in the job listing database by using a publish-subscribe messaging service. Id. No technical implementation details are described or claimed. Appeal 2021-002848 Application 14/555,327 18 Interpreted in light of this description, the generation and comparing of job listing identifiers does not improve computers, software, or other technologies for organizing and storing job listing data. “Ultimately, ‘the focus of the claims is not on . . . an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools.’” PersonalWeb, 8 F.4th at 1318. In PersonalWeb, the claims used content- based identifiers to purge duplicate content and discard duplicates identified by their content. Id. at 1316. The use of content-based identifiers, including the use of algorithm-generated content-based identifiers, to perform data- management functions of controlling access to data items, retrieving and delivering copies of data items, and marking copies of data items for deletion recited mental processes that can be performed in the human mind. Id. (“Generating such identifiers via a known algorithm is no less abstract.”). Steps of comparing a content-based identifier against other values also was abstract. Id. at 1317. Marking items for deletion to prevent duplication was an abstract mental process. Id. at 1318 (“The claims as a whole, then, are directed to a medley of mental processes that, taken together, amount only to a multistep mental process. . . . [T]he asserted efficiency improvements are not different in kind from those that would accrue in the library analogue-- for example, using content-based identifiers to purge duplicate books.”); see also Data Scape Ltd. v. Western Digital Corp., 816 F. App’x 461, 462-64 (Fed. Cir. 2020) (the selective transfer of files from a first storage medium to a second storage medium by automatically checking to ensure a particular file is not already stored on the second storage medium before transferring the file to avoid unnecessary duplication relates to the well-known concept of data collection, recognition, and storage). Appeal 2021-002848 Application 14/555,327 19 Simply collecting job listings from different company websites to add to a searchable database of ingested job listings and paid job listings from various companies does not improve computers or other technology. No technical details are claimed to indicate that this method improves databases. See Univ. of Fla. Research Foundation, Inc. v. General Elec. Co., 916 F.3d 1363, 1367-68 (Fed. Cir. 2019) (replacing pen and paper methodologies used to collect data from various bedside machines by using data synthesis technology and device drivers written for the various machines to present data from the various bedside machines in a configurable fashion in a single interface is a quintessential “do it on a computer” patent that described the drivers in purely functional language without any technical details). Claim 2 recites generic steps of establishing a company profile on a social networking service and posting a generated new job listing on the company profile page. See Appeal Br. 47 (Claims App.). Appellant asserts that this step automates the addition of a job listing to a company profile page without the need to enter the information manually. Appeal Br. 24-25. Mere automation of a manual process does not improve computers. See Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1055 (Fed. Cir. 2017) (automation of manual processes using generic computers to supplant and enhance an abstract manual process is not ineligible for patenting); NetSoc, LLC v. Match Grp., LLC, 838 F. App’x 544, 548 (Fed. Cir. 2020) (automatic establishment of a conventional social network to allow humans to exchange information and form relationships is an abstract method of organizing human activity); see also Alice, 573 U.S. at 225 (“Using a computer to create and maintain ‘shadow’ accounts amounts to electronic recordkeeping-one of the most basic functions of a computer.”). Appeal 2021-002848 Application 14/555,327 20 Generating hashes of new job listings and comparing the hashes to hashes of existing job listings is claimed without any technical details to take the steps out of the abstract realm of mental processes and mathematical concepts identified under Prong One. See PersonalWeb, 8 F.4th at 1316-18 (generating content-based identifiers via known algorithms and comparing those identifiers against other values are mental processes in a claim that recites a medley of mental processes as a multistep mental process claim). The time saved by database administrators not having to enter, update, and/or delete ingested job listings manually in a database is the result of a generic computer implementation rather than a patent-eligible improvement to computers as Appellant asserts. Appeal Br. 26-27. Such generic speed and efficiency improvements from a generic computer implementation are insufficient. See PersonalWeb, 8 F.4th at 1319 (“[O]ur precedent is clear that merely adding computer functionality to increase the speed or efficiency of the process does not confer patent eligibility on an otherwise abstract idea.”); Customedia, 951 F.3d at 1365 (“The only improvements identified in the specification are generic speed and efficiency improvements inherent in applying the use of a computer to an task. . . . This is not an improvement in the functioning of the computer itself.”); Credit Acceptance, 859 F.3d at 1055 (“[M]ere automation of manual processes using generic computers” is not sufficient to make an abstract idea patent eligible.); see also Smart Sys. Innovations, LLC v. Chicago Transit Auth., 873 F.3d 1364, 1374 n.9 (Fed. Cir. 2017) (explaining that a hash identifier is a generic, routine concept that does not transform claims to a patent eligible application of an abstract idea). Accordingly, we determine that the claims lack additional elements that are sufficient to integrate the abstract idea into a practical application. Appeal 2021-002848 Application 14/555,327 21 Alice, Step Two and Revised Guidance Step 2B: Do the Claims Include an Inventive Concept? We next consider whether the claims recite any additional elements, individually or as an ordered combination, to provide an inventive concept. Alice, 573 U.S. at 217-18. This step is satisfied when limitations involve more than well-understood, routine, and conventional activities known in the industry. See Berkheimer, 881 F.3d at 1367. Individually, the database is used to perform conventional functions known in the industry. It stores job listings. No unconventional functions are claimed. As an ordered combination, the limitations recite not more than when they are considered individually. “If a claim’s only ‘inventive concept’ is the application of an abstract idea using conventional and well-understood techniques, the claim has not been transformed into a patent-eligible application of an abstract idea.” BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290-91 (Fed. Cir. 2018); see Bozeman Fin. LLC v. Fed. Reserve Bank of Atl., 955 F.3d 971, 980-81 (Fed. Cir. 2020) (using known computer components to collect and analyze data, present data, and send notifications is a logical sequence with no inventive concept); SAP, 898 F.3d at 1169-70 (claims to available databases and processors that perform basic functions such as generic parallel processing components that are not asserted to be inventive to carry out improved mathematical calculations merely recite what is well-understood, routine, and conventional); Elec. Power, 830 F.3d at 1355 (using off-the-shelf, conventional computer, network, and display technology to gather, send, and present desired information is not inventive); see also PersonalWeb, 8 F.4th at 1318 (using cryptographic hashes in lieu of conventional names is not “significantly more,” it restates the abstract idea). Appeal 2021-002848 Application 14/555,327 22 Even if the techniques are groundbreaking, innovative, or brilliant, that is not enough for eligibility. SAP, 898 F.3d at 1163 (“No matter how much of an advance in the finance field the claims recite, the advance lies entirely in the realm of abstract ideas, with no plausibly alleged innovation in the non-abstract application realm. An advance of that nature is ineligible for patenting.”). Combining one abstract idea (organizing activity) with another abstract idea (mental processes) is not an inventive concept. See RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327 (Fed. Cir. 2017) (“Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract.”); see also Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“[A] claim for a new abstract idea is still an abstract idea.”); Bancorp, 687 F.3d at 1279 (“Using a computer to accelerate an ineligible mental process does not make that process patent-eligible.”). Accordingly, we sustain the rejection of claims 1, 2, 4-6, 8-12 as directed to an abstract idea without significantly more. Claims 1, 8, 9, and 12 Rejected Over Berg, Farooque, and Dixon Regarding claim 1, the Examiner cites Berg to teach a method of ingesting job listings from plural company websites and adding the job listings to a database searchable by users of a job hosting service with job listings from other companies by comparing identifiers of job listings (e.g., titles, keywords) with a list of identifiers of job listings stored in a job listings database. Final Act. 7-9. The Examiner cites Farooque to teach the generation of content based hash values that are compared to hashes of existing content to determine if content is new or not. Id. at 10; Ans. 33. Appeal 2021-002848 Application 14/555,327 23 Appellant argues that Berg does not compare identifiers for ingested job listings to identifiers of job listings stored in a job listings database to determine if the job listing is a new job listing or a duplicate of an existing job listing in the database. See Appeal Br. 32-33. Appellant argues that Berg lists jobs in a category page so they remain indexed on a search engine even as the jobs change over time to optimize search engines, not to identify or remove duplicate listings. Id. at 33-34 (discussing Berg ¶ 47, claim 13). Claim 1 recites a method that compares identifiers of new job listings to a list of identifiers of jobs stored in the database to determine whether a new job listing is a duplicate of a job listing already stored in the database. If a job identifier for a newly-ingested job listing “is not associated with an identifier of an existing job listing stored in the job listings database,” the new job listing is added to the database. Appeal Br. 46 (Claims App.). Berg does not compare identifiers of job listings to identifiers of job listings already stored in a job listings database to determine if the ingested job listing should be added to the database as a new job listing. Berg selects keywords and identifiers for job listings to optimize job listings so they are recognized by search engines. Berg ¶¶ 54, 55, 61-66. Job identifiers are not compared to identifiers of jobs already in a database to determine whether to add a job listing to a database, as claimed. Instead, Berg uses category pages to display jobs for a category using job title, location, skill, and salary. Id. ¶ 47; Final Act. 9 (citing id.). These “identifiers” are not used to identify and remove duplicate job listings. To the contrary, the category pages allow job listings to remain indexed on the internet for search engine optimization for months or years. Berg ¶ 47. We find no teaching or suggestion to use job identifiers to identify duplicate job listings in Berg. See Appeal Br. 33-34. Appeal 2021-002848 Application 14/555,327 24 Farooque uses hashes to indicate when content is updated, but hashes are not used with a content identifier as claimed. See Farooque ¶ 31; Ans. 33; Final Act. 10. Nor is it apparent that a skilled artisan would have been motivated to use Farooque’s hashes with the job listing identifiers in Berg to update job listings when Bert places job listings on a category page so that they remain indexed on the internet and within search engines for months or years to help a company’s job listing website achieve higher search engine position over time, i.e., to optimize placement of a company’s job listings on the internet by using a category page. See Berg ¶ 47; see also Appeal Br. 34 (Berg uses category pages so job listings remain indexed on a search engine even as jobs change over time to optimize search engines). As a result, even though Farooque’s hash values may be a known technique to prevent data duplication as the Examiner determines (Final Act. 11), it is not clear that the technique would improve Berg’s category pages by removing duplicates because Berg creates category pages so that the job listings remain indexed in a search engine for months or years. See Berg ¶ 47. If companies list jobs on a job site or a job board with job listings of other companies as claimed, they submit a site map of active job listings and active web pages to assist search engines with indexing their site’s content. Berg ¶ 62. “The site map may be submitted to major search engines on a regular basis, for example, every day.” Id. (emphasis added). Company job feeds or files may be created and delivered to search systems or job sites so these sites can index the job descriptions. Id. Because the job sites receive job listings from companies (rather than ingest jobs from company sites as claimed), the job sites rely on companies to provide only active job listings. Appeal 2021-002848 Application 14/555,327 25 Stated another way, the job sites do not need to check the active job listings that they receive daily or otherwise from companies for duplicates of jobs already stored in their databases. They rely on companies to provide the current list of active jobs. Absent hindsight, it is not clear that a skilled artisan would have been motivated to modify Berg to use hash values of Farooque to identify duplicate data (see Final Act. 11-12) when the job sites in Berg simply rely on companies to provide a daily listing of active job that they desire to have posted on the job site. See Berg ¶ 62. Accordingly, we do not sustain the rejection of claims 1, or its dependent claims 8, 9, and 12. Dependent Claims 2, 4-6, 10, and 11 Rejected Over Berg, Farooque, Dixon, and Jurney/Luo/Rahman The Examiner’s reliance on Jurney, Luo, and/or Rahman to teach or suggest features recited in dependent claims 2, 4-6, 10, and 11 does not remedy the deficiencies of Berg, Farooque, and Dixon as to claim 1 from which these claims all depend. See Final Act. 15-31. Thus, we do not sustain the rejections of these claims. DECISION In summary: Claim(s) Rejected 35 U.S.C. § References/Basis Affirmed Reversed 1, 2, 4-6, 8- 12 101 Eligibility 1, 2, 4-6, 8- 12 1, 8, 9, 12 103 Berg, Farooque, Dixon 1, 8, 9, 12 2 103 Berg, Farooque, Dixon, Jurney 2 4, 5 103 Berg, Farooque, Dixon, Jurney, Luo 4, 5 Appeal 2021-002848 Application 14/555,327 26 Claim(s) Rejected 35 U.S.C. § References/Basis Affirmed Reversed 6 103 Berg, Farooque, Dixon, Jurney, Rahman 6 10, 11 103 Berg, Farooque, Dixon, Ananian 10, 11 Overall Outcome 1, 2, 4-6, 8- 12 TIME PERIOD FOR RESPONSE No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a). See 37 C.F.R. § 1.136(a)(1)(iv). AFFIRMED