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 .
Status of Claims
This final office action is responsive to Applicant’s submission filed 08/19/2025. Currently, claims 1-20 and 24-37 are pending. Claims 1, 12, 18 and 20 have been amended. Claims 21-23 have been cancelled. Claims 30-35 are newly added.
Allowable Subject Matter
The following is a statement of reasons for the indication of allowable subject matter:
None of the cited and/or relevant prior art, single or in combination, teaches:
“collecting, by computer systems at a plurality of different sites, a plurality of vehicle images and metadata for the vehicle images… wherein the vehicle images include (1) a plurality of vehicle images produced by gate cameras at the sites and (2) a plurality of vehicle images produced by cameras of mobile devices… wherein the gate camera images and the mobile device camera images include images of a plurality of rental vehicles showing their condition when they were picked up from a first rental site and a plurality of images of those rental vehicles showing their condition when they were dropped off at a second rental site that is different than the first rental site, and wherein the searchable multi-site database provides tracking of vehicle condition as rental vehicles travel between different rental sites without needing to separately search the computer systems at the different sites”,
as recited in claim 1.
Claims 18 and 20 recite similar limitations as set forth in claim 1, and therefore are patentable over prior art.
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 1-20 and 24-37 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e. abstract idea) without significantly more.
The claims recite methods for tracking damages to vehicles.
Exemplary claim 20, recites in part,
collecting…at a plurality of different rental sites, a plurality of rental vehicle images and metadata for the rental vehicle images…,
accessing data… representative of a plurality of condition reports…,
processing the accessed condition report data and the metadata;
determining which of the rental vehicle images and which of the accessed condition reports correspond to the same rental transactions based on the processed condition report data and the processed metadata;
in response to a determination that a rental vehicle image corresponds to a condition report, creating an association in a memory between that rental vehicle image and that condition report; and
creating a searchable multi-site database of the vehicle images based on the associations… and wherein the searchable multi-site database provides tracking of vehicle condition as rental vehicles travel between different rental sites.
The above limitations, under their broadest reasonable interpretation, describes the steps of collecting, processing (classifying and indexing) and storing data. The steps of collecting, processing and storing data encompass "Mental Processes”, enumerated in MPEP 2106.04(a)(2)(III). If a claim limitation, under its broadest reasonable interpretation, covers “claim that encompasses a human performing the step(s) mentally with or without a physical aid recites a mental process”, or “claim that requires a computer may still recite a mental process”, then it falls within the “Mental Processes” grouping of abstract ideas.
In addition, the claim recites in part,
“providing one or more first graphical user interfaces (GUIs) that permits a user to search the database for rental vehicle images and condition report data of interest based on user input for one or more fields that correspond to the metadata;
receiving the user input via the one or more first GUIs that defines a search of the database;
searching the database based on the received user input to identify a plurality of rental vehicle images, condition report data, and metadata that are responsive to the search; and
providing one or more second GUIs that provides the identified rental vehicle images, condition report data, and metadata for display to the user”,
The above limitations, under their broadest reasonable interpretation, describes the steps of, 1) receiving user input (inputting user query), 2) processing the query (searching database), and 3) outputting the results (displaying search results). The limitations describe a database search. The process of searching a database encompasses "Mental Processes”, enumerated in MPEP 2106.04(a)(2)(III). If a claim limitation, under its broadest reasonable interpretation, covers “claim that encompasses a human performing the step(s) mentally with or without a physical aid recites a mental process”, or “claim that requires a computer may still recite a mental process”, then it falls within the “Mental Processes” grouping of abstract ideas.
Accordingly, the claim limitations, under their broadest reasonable interpretation, covers “claim that encompasses a human performing the step(s) mentally with or without a physical aid recites a mental process”, or “claim that requires a computer may still recite a mental process”, that falls within the “Mental Processes” grouping of abstract ideas. See MPEP 2106.04(a)(2)(III).
The judicial exception is not integrated into a practical application. In particular, the claim recites additional elements in the form of one or more computing devices (processor, memory, database, gate cameras, mobile devices, graphical user interface). The recited computing devices represent using a computer as a tool to perform the judicial exception as in MPEP 2106.05(f).
In addition, the content of the rental vehicle images, metadata and condition report(s) simply describes the type of data collected, processed and stored, which amounts to insignificant extra-solution activity that does not impose meaning limitation on the abstract idea. The limitation “wherein the searchable multi-site database, the one or more first GUIs, and the one or more second GUIs provide users with an ability to track tracking vehicle condition after rental vehicles travel between different rental sites without needing to separately search the computer systems at the different rental sites” simply describes the expected outcome to be achieved, which amounts to insignificant extra-solution activity that does not impose meaning limitation on the abstract idea. See MPEP 2106.05(g).
When considered both individually and as a whole, the additional elements do not integrate the abstract idea into a practical application.
The recitation of additional elements is acknowledged, as identified above. The discussion with respect to the practical application is equally applicable to consideration of whether the claims amount to significantly more. The rental vehicle images, metadata, and condition report, while amounting to extra-solution activity, also amounts to limiting the abstract idea to a field of use (MPEP 2106.05(h)). The recited computing devices represent using a computer as a tool to perform the judicial exception as in MPEP 2106.05(f). The limitation “wherein the searchable multi-site database, the one or more first GUIs, and the one or more second GUIs provide users with an ability to track tracking vehicle condition after rental vehicles travel between different rental sites” simply describes the expected outcome to be achieved, which amounts to insignificant extra-solution activity that does not impose meaning limitation on the abstract idea. See MPEP 2106.05(g).
There are no meaningful recitations, considered in combination, that transform the judicial exception into a patent eligible application such that the claim amounts to significantly more than the judicial exception itself.
Accordingly, claim 20 is directed to a judicial exception (i.e., abstract idea) without significantly more.
Claims 1 and 18 recites similar limitations, and therefore are rejected based on similar rationale.
Dependent claims 2-17, 19 and 24-37 recite limitations directed to the abstract idea, and does not integrate the abstract idea into a practical application nor provide an inventive concept.
Response to Arguments
Applicant's arguments filed 01/10/2025 with respect to the rejection of claims 1-20 and 24-29 under 35 U.S.C. §101 have been fully considered but they are not persuasive.
In response to Applicant’s arguments, Examiner respectfully disagrees.
As discussed above under section 101, the claimed invention(s) is/are directed to a judicial exception (i.e., abstract idea) without significantly more.
In Ex Parte Alexander, Appeal 2018-001741, US Application 13/547,420 [Patent Trial and Appeal Board (PTAB), 2019], the claims were directed to a sensor data collection system for collecting data from a plurality of endpoint devices. A central data collection point receives data generated at each of the endpoint device. Each of the endpoint devices, (i) computes predicted power usage values, (ii) compares a discrepancy between predicted power usage values and corresponding sensor data, and (iii) sends exception data and sufficiently accurate data to the central data collection point. The PTAB held that the additional elements recited in the claim integrated the identified mental process into a practical application. In particular, the “computing” step is performed by the “plurality of endpoints” and the “superseding” step is performed by the “central data collection point.” The PTAB explained that this distribution of functionality “allows the central system to maintain accurate predictions for future power use, while significantly reducing the necessary communication bandwidth across the network” compared to conventional systems.
In the present claims, the plurality of different sites simply collects data (vehicle images, metadata of vehicles images) using gate cameras and mobile device cameras. The collected data is transmitted to a central database, where the collected data is indexed with associated rental transaction data. One or more first and second GUIs are provided to users to search the central database to track vehicle conditions after rental vehicles travel between different rental sites. In contrast to Ex Parte Alexander, the plurality of “endpoints” (mobile device camaras and gate cameras) simply collect and send vehicle images and associated metadata to the central system, while the first and second GUIs receive user data and display results. The additional elements do not integrate the abstract idea into a practical application, as the recited “endpoints” fail to distribute functionalities performed by a central system and do not reduce necessary communication bandwidth across a network.
In Ex Parte Burcham, PTAB held that “[w]e understand Appellant’s invention as being directed to an improved graphical user interface for a mobile communication device, and not to advertising per se. The PTAB cites to Core Wireless, where the court concluded that the claims are directed to an improved user interface for mobile communication device which utilizes a specific manner of displaying a limited set of information to the user. The PTAB added that “[a]s described in the Specification at ¶19, “The promotional media content has metadata associated with it that defines methods to be invoked for different services, hence when the user drags the promotional media content thumbnail over a service, the service method invocation definition in the metadata that matches the service is invoked.”
In the present application, the recited GUIs provides for receiving user search input and displaying the search results in a generic manner. There is no improvement to graphical user interface technology of a computing device.
In Ex Parte Klimetschek, the PTAB explained that the claimed method improves the systems used to create, modify, and evaluate website content. The claimed “systems and methods provide these features in a unified authoring UI so that content authors are not required to leave the authoring UI in order to modify, target, preview, add, and remove components.” The PTAB again cites to Core Wireless, where the invention concerned “improved display interfaces, particularly for electronic devices with small screens like mobile telephones.” The PTAB held that claim 1 requires using a single user interface (UI) for modifying, targeting, and evaluating website components; i.e., a particular manner of carrying out these processes. Claim 1 also requires synchronizing the provision of modified content to both a live platform and a test-and-target service for simulating a campaign and visitor interactions. This requires that the website component in a particular (i.e., modified) state is provided at the same time to two different devices carrying out different functions with that same website component. The claims are not directed to the abstract idea of “modifying, targeting and testing advertisement components for display”, but rather to a specific improvement in the technical process of modifying and evaluating components for use in a website.
In the present application, the recited GUIs provides for receiving user search input and displaying the search results in a generic manner. There is no improvement to graphical user interface technology of a computing device. In addition, the central computer system simply receives data from a plurality sites, stores the received data and provides search results in response to a received search request.
In Ex Parte Mears, the PTAB explained that the data associated with the importance ranking/width limitation is used to automatically affect the user interface in a particular way by presenting “the cluster center and corresponding width of each one of the groups of clustered segments on the electronic display based on the importance ranking.” The PTAB again cites to Core Wireless, and held that the claim recites more than the generic display of data because it requires the data be summarized and presented in a particular way, i.e., as cluster centers corresponding to the mean of the groups of clustered segments along with a width indicative of their importance ranking.
In the present application, the recited GUIs provides for receiving user search input and displaying the search results in a generic manner. There is no improvement to graphical user interface technology of a computing device.
Paragraph 0004 of Applicant’s filed specification teaches that “[w]hile systems are known in the art for using cameras to capture images of rental vehicles before and after each rental transaction at different rental facilities to remove the subjectivity of the paper forms… For example, with such systems, it is believed that rental vehicle images are simply filed away in computer storage with minimal indexing, typically only at local rental facilities. Such local storage with minimal indexing presents a significant technical challenge to a rental car company that wishes to effectively track vehicle damage in a standardized and centralized manner. This challenge can be further magnified if the rental car company provides one-way rental services (i.e., rental transactions where the pickup location is different than the drop-off location) to customers.”
From the above paragraph, the steps of collecting, storing and “indexing” data (vehicle images and associated information) are well known computer functions in the art. In Intellectual Ventures I LLC v. Erie Indem. Co., the court explained that the claims lacked an inventive concept because they recite “generic functions, even if performed by a computer,” that are not inventive because “[s]electing files based on identifiers and matching different files/identifiers is just what computers do.” Similarly, the present claims are directed to gathering data (vehicle images and associated information) from a plurality of locations (rental sites) and creating “a searchable database of vehicle images indexed by the received metadata” (where the metadata comprises “an identifier for each vehicle depicts in the vehicle images and a temporal identifier indicative of when each vehicle image was created”). As such, indexing database files using identifiers are well-known generic computer functions in the art.
In addition, the steps of “providing one or more graphical user first graphical user interfaces (GUIs)”, “inputting user search query”, “retrieving the search results”, and “displaying the results on one or more second (GUIs)” simply describes database searching. The process of searching a database falls within the “Mental Processes” grouping of abstract ideas as discussed above.
Applicant’s specification teaches that “…these inventive embodiments provide significant improvements to the functioning of any computer systems that implement the solutions described herein in a number of different ways. For example, with respect to inventive embodiments disclosed herein where a searchable multi-site database of vehicle images is created, and where this database indexes the vehicles images by vehicle image metadata, the need to separately search a number of different computer systems for potentially relevant vehicle images is avoided. This means that any searching for relevant vehicle images can be performed faster and more efficiently than conventional computer solutions where rental vehicle images are stored locally at a number of different rental sites.”
The claimed invention gathers vehicle images and associated information. The collected information is indexed and stored in a database. A user is able to perform a search query, retrieve and display the search results. The claimed invention is implemented using generic computer elements that perform generic computer functions. The claimed invention uses generic computer elements to provide a business solution of tracking vehicles based on gathered information from different sites. The claimed invention does not improve the functioning of the computer (or computer elements) nor computer technology nor technical field.
In Core Wireless Licensing S.A.R.L. v. LG Electronics, Inc., 880 F.3d 1356, 125 U.S.P.Q.2d 1436 (hereinafter, Core Wireless), the court held that “[ajlthough the generic idea of summarizing information certainly existed prior to the invention, these claims are directed to a particular manner of summarizing and presenting information in electronic devices.” Specifically, the court explained that the claim further requires the application summary window list a limited set of data, “each of the data in the list being selectable to launch the respective application and enable the selected data to be seen within the respective application.” This claim limitation restrains the type of data that can be displayed in the summary window. Further, the court explained that the claim recites that the summary window “is displayed while the one or more applications are in an un-launched state,” a requirement that the device applications exist in a particular state. These limitations disclose a specific manner of displaying a limited set of information to the user, rather than using conventional user interface methods to display a generic index on a computer.
The court explained that,
“The disclosed invention improves the efficiency of using the electronic device accessed stored data,” which can be accessed directly from the mam menu…The speed of a user’s navigation through various views and windows can be improved because it “saves the user from navigating to the required application, opening it up, and then navigating within that application to enable the data of interest to be seen or a function of interest to be activated”.
However, in the present application, the claims simply display the search results in a generic manner with an associated selectable link (generic index). The claim recites “providing one or more first graphical user interfaces (GUIs) that permits a user to search the database for rental vehicle images of interest based on user input…” and “providing one or more second GUIs that provides the identified rental vehicle images and metadata for display to the user”. The recited GUIs of the claimed invention simply receiving user search requests and displays search results (including summary) in a generic manner. The selectable link or result summary is not linked with activating one or more applications that includes additional information associated with the selectable link (or display summary). There is no improvement to graphical user interface technology of a computing device. The claimed invention uses generic computer elements to perform generic computer functions of collecting/gathering data (vehicle images and associated information), indexing and storing the collected data, receiving a search query, processing the search query (retrieving search results), and displaying the results.
Accordingly, the claim(s) is/are directed to a judicial exception (i.e., abstract idea) without significantly more.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
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/OLUSEGUN GOYEA/Primary Examiner, Art Unit 3627