DETAILED ACTION
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on December 19, 2025 has been entered. Claims 1, 7, 9, and 13 have been amended. Claims 1-20 are presented for examination.
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 .
Response to Arguments
Applicant's arguments filed December 19, 2025 have been fully considered but they are not persuasive.
Regarding the rejection under 35 U.S.C. § 101, Applicant argues:
Thus, the limitations of claim 1 integrates any alleged abstract idea into a practical application by providing improvements to computer capabilities and/or a technical field (e.g., rental-vehicle-computing systems). For example, the claimed features of claim 1 provide for improved computing efficiency and accuracy at least by generating a vehicle-fleet-platform database that indicates an aggregated dataset of information from a plurality of data sources in response to issuing a set of API calls and automatically dispatching a mobile service vehicle corresponding to a vehicle match based on data in the aggregated database, among other limitations that provide for technical improvements to rental-vehicle-computing systems and computer capabilities.
Indeed, the Specification also recites that "the fleet management system generates and presents vehicle-data summaries in a single fleet management interface (or a unified series of graphical user interfaces) by drawing from vehicle data and/or service data aggregated into an integrated vehicle-fleet-platform database. The fleet management system thus provides previously isolated vehicle data in a single, efficiently navigable graphical user interface or series of graphical user interfaces" and "accordingly, the fleet management system reduces or eliminates both excessive computer processing and excessive computing device interaction experienced by conventional rental-vehicle-computing systems to locate and present vehicle data from a variety of integrated subsystems to surface in a fleet management interface." Id. at [0032]. Thus, Applicant respectfully submits that such improvements to a technical field provided by the claimed features are patent eligible under 35 U.S.C. 101. (Pages 22-23 of Applicant’s response)
The Examiner respectfully disagrees. The APIs are an example of software and they are simply integrated into the claims at a high level of generality. The claims do not improve upon the underlying operations of how the APIs work from a technical perspective and the claims also do not present a particularly unusual arrangement of APIs.
Additionally, a human user can aggregate data into a dataset. Using the recited hardware and software to generally aggregate the data is another example of only generally applying the additional elements at a high level to integrate the abstract ideas.
On pages 23-24 of Applicant’s response, Applicant submits that Applicant’s claims are akin to the eligible claim in Example 42. There is no conversion of data from a non-standardized format to a standardized format in Applicant’s claims (like in eligible claim 1 of Example 42); therefore, the Examiner finds no analogy between claim 1 of Example 42 and Applicant’s claims.
Applicant argues that the claims present a feedback loop for dispatching vehicles in a rental match, thereby presenting technological improvements (pages 25-26 of Applicant’s response). The Examiner points out that any recited feedback loop is not actively controlled by a fully-automated, mechanically-controlled feedback loop (like the scenario in Diamond v. Diehr in which a rubber mold was automatically opened and closed in response to the feedback). The analysis performed in the claims to facilitate the rental match presents details of the abstract ideas (as set forth in the rejection). Additionally, there are no specific technical details presented as to how vehicles are dispatched. As claimed, a human user may send instructions to or be instructed to dispatch a mobile service vehicle, albeit via computer executable instructions from one or more computing devices of the system; therefore, this is another example of organizing human activity with a general application of additional elements and a general link to technology. The processing components presented in the claims simply utilize the capabilities of a general-purpose computer and are, thus, merely tools to implement the abstract idea(s). As seen in MPEP § 2106.05(a)(I) and § 2106.05(f)(2), the court found that accelerating a process when the increased speed solely comes from the capabilities of a general-purpose computer is not sufficient to show an improvement in computer-functionality and it amounts to a mere invocation of computers or machinery as a tool to perform an existing process (see FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016)).
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 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claimed invention is directed to “receiv[ing] and integrat[ing] vehicle data for a fleet of different types of rental vehicles -- and/or service data from vehicle service centers associated with such rental vehicles” (Spec: ¶ 5) without significantly more.
Step
Analysis
1: Statutory Category?
Yes – The claims fall within at least one of the four categories of patent eligible subject matter. Apparatus (claims 1-8), Article of Manufacture (claims 9-12), Process (claims 13-20)
Independent claims:
Step
Analysis
2A – Prong 1: Judicial Exception Recited?
Yes – Aside from the additional elements identified in Step 2A – Prong 2 below, the claims recite:
[Claim 1] receive vehicle data based on data inputs associated with a set of provider-rental vehicles designated for use in part by transporting providers for fulfilling transportation requests according to a provider-use rental;
receive vehicle data based on data inputs associated with a set of personal-rental vehicles designated for operation by renters for self-transportation according to a personal-use rental;
identify service data for one or more vehicle service centers associated with the set of provider-rental vehicles and the set of personal-rental vehicles;
aggregate, into an aggregated dataset, the vehicle data for the set of provider-rental vehicles comprising data indicating a designation for the provider-use rental, the vehicle data for the set of personal-rental vehicles comprising data indicating a designation for the personal-use rental, and the service data for the one or more vehicle service centers;
provide, based on the aggregated dataset, a display comprising vehicle-data summaries for the set of provider-rental vehicles indicating the designation for provider-use rental and the set of personal-rental vehicles indicating the designation for personal-use rental;
receive a rental request comprising an indication of intent for use in part by transportation providers for fulfilling transportation requests according to a provider-use rental;
generate a rental match for the rental request utilizing the vehicle data for the set of provider-rental vehicles comprising data indicating a designation for the provider-use rental, the vehicle data for the set of personal-rental vehicles comprising data indicating a designation for the personal-use rental, and the service data for the one or more vehicle service centers comprising a service status of the vehicle indicated by the rental match;
continuously update a vehicle-data summary corresponding to the rental match based on transportation data received;
identify a set of mobile service vehicles in a geographical region;
determine services available at the set of mobile service vehicles;
generate, based on the vehicle-data summary corresponding to the rental match and vehicle supplies corresponding to the set of mobile service vehicles, a mobile service vehicle match; and
automatically dispatch, in response to generating the mobile service vehicle match, a mobile service vehicle corresponding to the mobile service vehicle match to the vehicle indicated by the rental match.
[Claim 9] receive vehicle data based on data inputs associated with a set of provider-rental vehicles designated for use in part by transportation providers for fulfilling transportation requests according to a provider-use rental;
receive vehicle data based on data inputs associated with a set of personal-rental vehicles designated for operation by renters for self-transportation according to a personal-use rental;
identify service data for one or more vehicle service centers associated with the set of provider-rental vehicles and the set of personal-rental vehicles;
aggregate, into an aggregated dataset, the vehicle data for the set of provider-rental vehicles comprising data indicating a designation for the provider-use rental, the vehicle data for the set of personal-rental vehicles comprising data indicating a designation for the personal-use rental, and the service data for the one or more vehicle service centers;
based on the aggregated vehicle data and service data, generate, for display:
vehicle-data summaries for the set of provider-rental vehicles comprising the designation for the provider-use rental and corresponding service information from the service data; and
vehicle-data summaries for the set of personal-rental vehicles comprising the designation for personal-use rental and corresponding service information from the service data;
receive a rental request comprising an indication of intent for use in part by transportation providers for fulfilling transportation requests according to a provider-use rental;
generate a rental match for the rental request utilizing the vehicle data for the set of provider-rental vehicles comprising data indicating a designation for the provider-use rental, the vehicle data for the set of personal-rental vehicles comprising data indicating a designation for the personal-use rental, and the service data for the one or more vehicle service centers comprising a service status of the vehicle indicated by the rental match;
continuously update a vehicle-data summary corresponding to the rental match based on transportation data received;
identify a set of mobile service vehicles in a geographical region;
determine services available at the set of mobile service vehicles;
generate, based on the vehicle-data summary corresponding to the rental match and vehicle supplies corresponding to the set of mobile service vehicles, a mobile service vehicle match; and
automatically dispatch, in response to generating the mobile service vehicle match, a mobile service vehicle corresponding to the mobile service vehicle match to the vehicle indicated by the rental match.
[Claim 13] A method comprising:
receiving vehicle data based on data inputs associated with a set of provider-rental vehicles designated for use in part by transportation providers for fulfilling transportation requests according to a provider-use rental;
receiving vehicle data based on data inputs associated with a set of personal-rental vehicles designated for operation by renters for self-transportation according to a personal-use rental;
identifying service data for one or more vehicle service centers associated with the set of provider-rental vehicles and the set of personal-rental vehicles;
aggregating, into an aggregated dataset, the vehicle data for the set of provider-rental vehicles comprising data indicating a designation for the provider-use rental and the vehicle data for the set of personal-rental vehicles comprising data indicating a designation for the personal-use rental;
generating, for display, vehicle-data summaries for the set of provider-rental vehicles and for the set of personal-rental vehicles based on the aggregated vehicle data; and
providing the display comprising vehicle-data summaries for the set of provider-rental vehicles indicating the designation for provider-use rental and the set of personal-rental vehicles indicating the designation for personal-use rental;
receive a rental request comprising an indication of intent for use in part by transportation providers for fulfilling transportation requests according to a provider-use rental;
generate a rental match for the rental request utilizing the vehicle data for the set of provider-rental vehicles comprising data indicating a designation for the provider-use rental, the vehicle data for the set of personal-rental vehicles comprising data indicating a designation for the personal-use rental, and the service data for the one or more vehicle service centers comprising a service status of the vehicle indicated by the rental match;
continuously update a vehicle-data summary corresponding to the rental match based on transportation data received;
identifying a set of mobile service vehicles in a geographical region;
determining services available at the set of mobile service vehicles;
generating, based on the vehicle-data summary corresponding to the rental match and vehicle supplies corresponding to the set of mobile service vehicles, a mobile service vehicle match; and
in response to generating the mobile service vehicle match, dispatching a mobile service vehicle corresponding to the mobile service vehicle match to the vehicle indicated by the rental match.
It is noted that “automatically” may simply mean “in direct response to.”
Aside from the additional elements, the aforementioned claim details exemplify the abstract idea(s) of a mental process (since the details include concepts performed in the human mind, including an observation, evaluation, judgment, and/or opinion). As explained in MPEP § 2106.04(a)(1)(III), “[t]he courts consider a mental process (thinking) that ‘can be performed in the human mind, or by a human using a pen and paper’ to be an abstract idea. CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372, 99 USPQ2d 1690, 1695 (Fed. Cir. 2011).” The limitations reproduced above, as drafted, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind but for the recitation of generic computer components. That is, other than reciting the additional elements identified in Step 2A – Prong 2 below, nothing in the claim elements precludes the steps from practically being performed in the mind and/or by a human using a pen and paper. For example, but for the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the respectively recited steps/functions of the claims, as drafted and set forth above, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind and/or with the use of pen and paper. A human user can aggregate the various types of data recited, perform the recited analysis, and present information, for example. A human can also identify, i.e., generate, a rental match and continuously update vehicle summaries related to matches. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with pen and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Aside from the additional elements, the aforementioned claim details exemplify a method of organizing human activity (since the details include examples of commercial or legal interactions, including advertising, marketing or sales activities or behaviors, and/or business relations and managing personal behavior or relationships or interactions between people, including social activities, teaching, and following rules or instructions). More specifically, the evaluated process is related to “receiv[ing] and integrat[ing] vehicle data for a fleet of different types of rental vehicles -- and/or service data from vehicle service centers associated with such rental vehicles” (Spec: ¶ 5), which (under its broadest reasonable interpretation) is an example of commercial interactions and sales activities (i.e., organizing human activity); therefore, aside from the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the limitations identified in the more detailed claim listing above encompass the abstract idea of organizing human activity.
As claimed, a human user may send instructions to or be instructed to dispatch a mobile service vehicle, albeit via computer executable instructions from one or more computing devices of the system; therefore, this is another example of a mental process and/or organizing human activity with a general application of additional elements and a general link to technology.
2A – Prong 2: Integrated into a Practical Application?
No – The judicial exception(s) is/are not integrated into a practical application.
Claim 1 includes a system comprising: at least one processor; and
a non-transitory computer-readable medium comprising instructions that, when executed by the at least one processor, cause the system to perform the recited operations as well as a vehicle-fleet-platform database to aggregate data. Claim 1 provides an integrated fleet management interface comprising vehicle-data summaries. Claim 1 receives data from requestor devices via a transportation matching system.
Claim 1 generates a set of application programming interface (API) calls, each API call corresponding to a respective data source of a plurality of data sources; issues the set of API calls to the plurality of data sources; performs various receiving operations based on issuing the set of API calls; generates a vehicle-fleet-platform database that indicates the aggregated dataset that includes information from the plurality of data sources in response to issuing the set of API calls; provides, based on retrieving information from the vehicle-fleet-platform database that indicates the aggregated dataset, an interface comprising vehicle-data summaries; and automatically dispatches a mobile service vehicle via computer executable instructions from one or more computing devices of the system.
Claim 9 includes a non-transitory computer-readable medium comprising instructions that, when executed by at least one processor, cause a computing device to perform the recited operations. Claim 9 recites that data is aggregated into a vehicle-fleet-platform database and summaries are generated for display within a fleet management interface. Claim 9 provides an integrated fleet management interface comprising vehicle-data summaries. Claim 9 receives data from requestor devices via a transportation matching system.
Claim 9 generates a set of application programming interface (API) calls, each API call corresponding to a respective data source of a plurality of data sources; issues the set of API calls to the plurality of data sources; performs various receiving operations based on issuing the set of API calls; generates a vehicle-fleet-platform database that indicates the aggregated dataset that includes information from the plurality of data sources in response to issuing the set of API calls; based on the vehicle-fleet-platform database, generates, for display within a fleet management interface vehicle-data summaries; and automatically dispatches a mobile service vehicle via computer executable instructions from one or more computing devices of the system.
Claim 13 aggregates the vehicle data into a vehicle-fleet-platform database and generates summaries for display within an integrated fleet management interface and claim 13 provides an integrated fleet management interface comprising vehicle-data summaries. Claim 13 receives data from requestor devices via a transportation matching system.
Claim 13 generates a set of application programming interface (API) calls, each API call corresponding to a respective data source of a plurality of data sources; issues the set of API calls to the plurality of data sources; performs various receiving operations based on issuing the set of API calls; generates a vehicle-fleet-platform database that indicates the aggregated dataset that includes information from the plurality of data sources in response to issuing the set of API calls; generates, based on retrieving information from the vehicle-fleet-platform database that indicates the aggregated dataset the vehicle-data summaries; and automatically dispatches, via computer executable instructions from one or more computing devices of the system in response to generating the mobile service vehicle match, a mobile service vehicle corresponding to the mobile service vehicle match to the vehicle indicated by the rental match.
The use of APIs is an example of integrating software instructions; however, the claims use the APIs at a high level of generality and simply as software-based instructions. The ability to automatically dispatch a mobile service vehicle via computer executable instructions from one or more computing devices of the system may simply allow a human user to electronically send instructions to dispatch a vehicle; however, this communication is also facilitated by generic processing elements at a high level of generality. As claimed, a human user may send instructions to or be instructed to dispatch a mobile service vehicle, albeit via computer executable instructions from one or more computing devices of the system; therefore, this is another example of a mental process and/or organizing human activity with a general application of additional elements and a general link to technology.
The claims as a whole merely describe how to generally “apply” the abstract idea(s) in a computer environment. The claimed processing elements are recited at a high level of generality and are merely invoked as a tool to perform the abstract idea(s). Simply implementing the abstract idea(s) on a general-purpose processor is not a practical application of the abstract idea(s); Applicant’s specification discloses that the invention may be implemented using general-purpose processing elements and other generic components (Spec: ¶¶ 239-269).
The use of a processor/processing elements (e.g., as recited in all of the claims) facilitates generic processor operations. The use of a memory or machine-readable media with executable instructions (e.g., as recited in the apparatus and article of manufacture claims) facilitates generic processor operations.
The additional elements are recited at a high-level of generality (i.e., as generic processing elements performing generic computer functions) such that the incorporation of the additional processing elements amounts to no more than mere instructions to apply the judicial exception(s) using generic computer components. There is no indication in the Specification that the steps/functions of the claims require any inventive programming or necessitate any specialized or other inventive computer components (i.e., the steps/functions of the claims may be implemented using capabilities of general-purpose computer components). Accordingly, the additional elements do not integrate the abstract ideas into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims are directed to an abstract idea(s).
The processing components presented in the claims simply utilize the capabilities of a general-purpose computer and are, thus, merely tools to implement the abstract idea(s). As seen in MPEP § 2106.05(a)(I) and § 2106.05(f)(2), the court found that accelerating a process when the increased speed solely comes from the capabilities of a general-purpose computer is not sufficient to show an improvement in computer-functionality and it amounts to a mere invocation of computers or machinery as a tool to perform an existing process (see FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016)).
There is no transformation or reduction of a particular article to a different state or thing recited in the claims.
Additionally, even when considering the operations of the additional elements as an ordered combination, the ordered combination does not amount to significantly more than what is present in the claims when each operation is considered separately.
2B: Claim(s) Provide(s) an Inventive Concept?
No – The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception(s). As discussed above with respect to integration of the abstract idea(s) into a practical application, the use of the additional elements to perform the steps identified in Step 2A – Prong 1 above amounts to no more than mere instructions to apply the exceptions using a generic computer component(s). Mere instructions to apply an exception using a generic computer component(s) cannot provide an inventive concept. The claims are not patent eligible.
Dependent claims:
Step
Analysis
2A – Prong 1: Judicial Exception Recited?
Yes – Aside from the additional elements identified in Step 2A – Prong 2 below, the claims recite:
[Claim 2] receive vehicle data for third-party-rental vehicles;
assign one or more of the third-party-rental vehicles to the set of personal-rental vehicles; and
aggregate the vehicle data for the third-party-rental vehicles as assigned to the set of personal-rental vehicles.
[Claim 3] receive updated vehicle data for a personal-rental vehicle;
based on the updated vehicle data, determine a status change for the personal-rental vehicle within the vehicle-fleet-platform database from a particular personal-use rental to a particular provider-use rental;
based on determining the status change to the particular provider-use rental, update a vehicle-data summary for the personal-rental vehicle to become a provider-rental vehicle for display; and
generate an additional rental match for an additional provider-use rental request utilizing the vehicle-data summary for the personal-rental vehicle.
[Claim 4] provide, for display, a vehicle-data summary for a provider-rental vehicle or a personal-rental vehicle, the vehicle-data summary comprising a renter indicator for a particular renter;
receive an indication of a user selection of the renter indicator; and
based on the user selection of the renter indicator, provide, for display, a renter-activity summary of tracked activities from a rental account for the particular renter.
[Claim 5] wherein the set of provider-rental vehicles comprises a subset of flexible-provider-rental vehicles used in part by a subset of providers for transporting requestors under a first mileage scheme that dictates personal mileage based on miles driven by a corresponding provider account in providing transportation services and a subset of express-provider-rental vehicles used in part by an additional subset of providers for transporting requestors under a second mileage scheme that dictates personal mileage based on user selection.
[Claim 6] receive a vehicle-damage tag indicating damage to a first rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles;
dispatch the first rental vehicle to a first vehicle service center from the one or more vehicle service centers based on the vehicle-damage tag;
receive a vehicle-maintenance tag indicating a vehicle part requiring maintenance from a second rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles; and
dispatch the second rental vehicle to a second vehicle service center from the one or more vehicle service centers based on the vehicle-maintenance tag.
[Claim 7] automatically dispatch an autonomous vehicle for the rental match.
[Claim 8] receive a rental request, from a rental requestor, corresponding to a rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles;
based on the rental request, generate a radio frequency identification code for the rental requestor to send; and
provide the radio frequency identification code to the rental requestor to access and start the rental vehicle based on the rental request.
[Claim 10] aggregate the vehicle data by aggregating vehicle manufacturers or vehicle models for the set of provider-rental vehicles and the set of personal-rental vehicles;
receive an indication of a user selection of a sorting option corresponding to the vehicle manufacturers or the vehicle models; and
provide, for display, the vehicle-data summaries ordered according to the vehicle manufacturers or the vehicle models.
[Claim 11] before displaying the fleet management data:
identify a subset of vehicle service centers and a subset of third-party-vehicle centers in a geographical region;
determine services available at the subset of vehicle service centers and services available at the subset of third-party-vehicle centers; and
provide, for display, identifiers for the subset of vehicle service centers and the subset of third-party-vehicle centers and the services available at the subset of vehicle service centers and the subset of third-party-vehicle centers.
[Claim 12] receive a vehicle-damage tag indicating damage to a first rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles;
receive a vehicle-maintenance tag indicating a vehicle part requiring maintenance from a second rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles; and
provide, for display, a first vehicle-data summary comprising the vehicle-damage tag for the first rental vehicle and a second vehicle-data summary comprising the vehicle-maintenance tag for the second rental vehicle.
[Claim 14] aggregating the vehicle data by aggregating service statuses indicating one of an active status, a maintenance status, a service status, or a damaged status;
receiving an indication of a user selection of a sorting option corresponding to the service statuses;
providing, for display, the vehicle-data summaries ordered according to the service statuses of the active status, the maintenance status, the service status, or the damaged status; and
providing, within the vehicle-data summaries, vehicle rental statuses.
[Claim 15] aggregating the vehicle data by aggregating vehicle manufacturers or vehicle models for the set of provider-rental vehicles and the set of personal-rental vehicles;
receiving an indication of a user selection of a sorting option corresponding to the vehicle manufacturers or the vehicle models; and
providing, for display, the vehicle-data summaries ordered according to the vehicle manufacturers or the vehicle models.
[Claim 16] before displaying the fleet management data:
identifying fleet-vehicle centers and third-party-vehicle centers in a geographical region;
determining services available at the fleet-vehicle centers and services available at the third-party-vehicle centers; and
providing, for display, identifiers for the fleet-vehicle centers and the third-party-vehicle centers and the services available at the fleet-vehicle centers and the third-party-vehicle centers.
[Claim 17] receiving the vehicle data from a renter and aggregating the vehicle data into the vehicle-data summary.
[Claim 18] receiving a vehicle-damage tag indicating damage to a first rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles;
receiving a vehicle-maintenance tag indicating a vehicle part requiring maintenance from a second rental vehicle from the set of provider-rental vehicles or the set of personal-rental vehicles; and
providing, for display, a first vehicle-data summary comprising the vehicle-damage tag for the first rental vehicle and a second vehicle-data summary comprising the vehicle-maintenance tag for the second rental vehicle.
[Claim 19] receiving updated vehicle data for a personal-rental vehicle indicating a change from a particular personal-use rental to a particular provider-use rental;
based on the updated vehicle data, modifying a status for the personal-rental vehicle from the particular personal-use rental to the particular provider-use rental; and
based on the modification to the particular provider-use rental, updating a vehicle-data summary for the personal-rental vehicle to become a provider-rental vehicle for display.
[Claim 20] providing, for display, a renter indicator for a particular renter associated with a vehicle-data summary from the vehicle-data summaries;
receiving an indication of a user selection of the renter indicator; and
based on the user selection of the renter indicator, providing a renter-activity summary of tracked activities from a rental account for the particular renter.
The dependent claims further present details of the abstract ideas identified in regard to the independent claims above.
It is noted that “automatically” may simply mean “in direct response to.”
Aside from the additional elements, the aforementioned claim details exemplify the abstract idea(s) of a mental process (since the details include concepts performed in the human mind, including an observation, evaluation, judgment, and/or opinion). As explained in MPEP § 2106.04(a)(1)(III), “[t]he courts consider a mental process (thinking) that ‘can be performed in the human mind, or by a human using a pen and paper’ to be an abstract idea. CyberSource Corp. v. Retail Decisions, Inc., 654 F.3d 1366, 1372, 99 USPQ2d 1690, 1695 (Fed. Cir. 2011).” The limitations reproduced above, as drafted, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind but for the recitation of generic computer components. That is, other than reciting the additional elements identified in Step 2A – Prong 2 below, nothing in the claim elements precludes the steps from practically being performed in the mind and/or by a human using a pen and paper. For example, but for the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the respectively recited steps/functions of the claims, as drafted and set forth above, are a process that, under its broadest reasonable interpretation, covers performance of the limitations in the mind and/or with the use of pen and paper. A human user can aggregate the various types of data recited, perform the recited analysis, and present information, for example. A human can also identify, i.e., generate, a rental match and continuously update vehicle summaries related to matches. It is also noted that, regarding claim 8, a radio frequency identification code is just data and a human user can generate data conveying a radio frequency identification code for the rental requestor to send and provide the radio frequency identification code. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind (and/or with pen and paper) but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Aside from the additional elements, the aforementioned claim details exemplify a method of organizing human activity (since the details include examples of commercial or legal interactions, including advertising, marketing or sales activities or behaviors, and/or business relations and managing personal behavior or relationships or interactions between people, including social activities, teaching, and following rules or instructions). More specifically, the evaluated process is related to “receiv[ing] and integrat[ing] vehicle data for a fleet of different types of rental vehicles -- and/or service data from vehicle service centers associated with such rental vehicles” (Spec: ¶ 5), which (under its broadest reasonable interpretation) is an example of commercial interactions and sales activities (i.e., organizing human activity); therefore, aside from the recitations of generic computer and other processing components (identified in Step 2A – Prong 2 below), the limitations identified in the more detailed claim listing above encompass the abstract idea of organizing human activity.
As claimed, a human user may send instructions to or be instructed to dispatch a mobile service vehicle, albeit via computer executable instructions from one or more computing devices of the system; therefore, this is another example of a mental process and/or organizing human activity with a general application of additional elements and a general link to technology.
Additionally, it is noted that sorting operations (e.g., as recited in claims 10, 14, and 15) are examples of filtering content. MPEP § 2106.04(a)(2)(II)(C) cites the following as an example of managing personal behavior, i.e., organizing human activity: “filtering content, BASCOM Global Internet v. AT&T Mobility, LLC, 827 F.3d 1341, 1345-46, 119 USPQ2d 1236, 1239 (Fed. Cir. 2016) (finding that filtering content was an abstract idea under step 2A, but reversing an invalidity judgment of ineligibility due to an inadequate step 2B analysis).” MPEP § 2106.04(a)(2)(III)(D) cites the following as an example of a mental process: “An application program interface for extracting and processing information from a diversity of types of hard copy documents – Content Extraction, 776 F.3d at 1345, 113 USPQ2d at 1356.”
2A – Prong 2: Integrated into a Practical Application?
No – The judicial exception(s) is/are not integrated into a practical application.
The dependent claims incorporate the additional elements of the independent claims from which they depend.
Claim 1 includes a system comprising: at least one processor; and
a non-transitory computer-readable medium comprising instructions that, when executed by the at least one processor, cause the system to perform the recited operations as well as a vehicle-fleet-platform database to aggregate data. Claim 1 provides an integrated fleet management interface comprising vehicle-data summaries. Claim 1 receives data from requestor devices via a transportation matching system.
Claim 1 generates a set of application programming interface (API) calls, each API call corresponding to a respective data source of a plurality of data sources; issues the set of API calls to the plurality of data sources; performs various receiving operations based on issuing the set of API calls; generates a vehicle-fleet-platform database that indicates the aggregated dataset that includes information from the plurality of data sources in response to issuing the set of API calls; provides, based on retrieving information from the vehicle-fleet-platform database that indicates the aggregated dataset; and automatically dispatches a mobile service vehicle via computer executable instructions from one or more computing devices of the system.
Claim 2 includes a vehicle-fleet-platform database to aggregate data. Claim 3 receives data from a computing device and a vehicle summary is updated for display within a fleet management interface. Claim 4 provides summaries for display on a computing device. Various types of data are received from a vehicle-service-computing device and data are detected by a telematics device of a second rental vehicle in claim 6. A rental request is received from a rental requestor device in claim 8. Claim 8 further performs the following operations: generate a virtual code for the rental requestor device to send to an in-vehicle-computing device connected by an on-board-diagnostics port to the rental vehicle; and provide the virtual code to the rental requestor device to access and start the rental vehicle based on the rental request.
Claim 7 recites automatically dispatching an autonomous vehicle for the rental match by transmitting, to the autonomous vehicle, computer executable instructions from the one or more computing devices of the system
Claim 9 includes a non-transitory computer-readable medium comprising instructions that, when executed by at least one processor, cause a computing device to perform the recited operations. Claim 9 recites that data is aggregated into a vehicle-fleet-platform database and summaries are generated for display within a fleet management interface. Claim 9 provides an integrated fleet management interface comprising vehicle-data summaries. Claim 9 receives data from requestor devices via a transportation matching system.
Claim 9 generates a set of application programming interface (API) calls, each API call corresponding to a respective data source of a plurality of data sources; issues the set of API calls to the plurality of data sources; performs various receiving operations based on issuing the set of API calls; generates a vehicle-fleet-platform database that indicates the aggregated dataset that includes information from the plurality of data sources in response to issuing the set of API calls; based on the vehicle-fleet-platform database, generates, for display within a fleet management interface; and automatically dispatches a mobile service vehicle via computer executable instructions from one or more computing devices of the system.
An indication of a user selection is received from a computing device and summaries are provided for display within the fleet management interface in claim 10. Claim 11 recites providing identifiers for display within a fleet-location-management interface before displaying the fleet management interface. In claim 12, various types of data are received from a vehicle-service-computing device and summaries are provided for display within the fleet management interface. Claim 12 further recites that the received tag is detected by a telematics device.
Claim 13 aggregates the vehicle data into a vehicle-fleet-platform database and generates summaries for display within an integrated fleet management interface and claim 13 provides an integrated fleet management interface comprising vehicle-data summaries. Claim 13 receives data from requestor devices via a transportation matching system.
Claim 13 generates a set of application programming interface (API) calls, each API call corresponding to a respective data source of a plurality of data sources; issues the set of API calls to the plurality of data sources; performs various receiving operations based on issuing the set of API calls; generates a vehicle-fleet-platform database that indicates the aggregated dataset that includes information from the plurality of data sources in response to issuing the set of API calls; generates, based on retrieving information from the vehicle-fleet-platform database that indicates the aggregated dataset the vehicle-data summaries; and automatically dispatches, via computer executable instructions from one or more computing devices of the system in response to generating the mobile service vehicle match, a mobile service vehicle corresponding to the mobile service vehicle match to the vehicle indicated by the rental match.
Claim 14 receives an indication from a computing device and provides summaries and other information for display within the fleet management interface. Claim 15 receives an indication from a computing device and provides summaries for display within the fleet management interface. Claim 16 recites providing identifiers for display within a fleet-location-management interface before displaying the fleet management interface. Claim 17 recites receiving the vehicle data from renter computing devices, telematic computing devices, in-vehicle-computing devices, rental-location-computing devices, or vehicle-service-computing devices. Data are received from a vehicle-service-computing device in claim 18. Claim 18 further recites that the received tag is detected by a telematics device and that summaries are provided for display within the fleet management interface. Claim 19 receives data from a computing device, modifies a status of data within the vehicle-fleet-platform database, and updates a summary for display within the fleet management interface. Claim 20 provides an indicator for display within the fleet management interface.
Claims 14-15 and 18-20 further provide, display, and/or update data on the integrated fleet management interface.
The use of APIs is an example of integrating software instructions; however, the claims use the APIs at a high level of generality and simply as software-based instructions. The ability to automatically dispatch a mobile service vehicle via computer executable instructions from one or more computing devices of the system may simply allow a human user to electronically send instructions to dispatch a vehicle; however, this communication is also facilitated by generic processing elements at a high level of generality. As claimed, a human user may send instructions to or be instructed to dispatch a mobile service vehicle, albeit via computer executable instructions from one or more computing devices of the system; therefore, this is another example of a mental process and/or organizing human activity with a general application of additional elements and a general link to technology.
The claims as a whole merely describe how to generally “apply” the abstract idea(s) in a computer environment. The claimed processing elements are recited at a high level of generality and are merely invoked as a tool to perform the abstract idea(s). Simply implementing the abstract idea(s) on a general-purpose processor is not a practical application of the abstract idea(s); Applicant’s specification discloses that the invention may be implemented using general-purpose processing elements and other generic components (Spec: ¶¶ 239-269).
The use of a processor/processing elements (e.g., as recited in all of the claims) facilitates generic processor operations. The use of a memory or machine-readable media with executable instructions (e.g., as recited in the apparatus and article of manufacture claims) facilitates generic processor operations.
The additional elements are recited at a high-level of generality (i.e., as generic processing elements performing generic computer functions) such that the incorporation of the additional processing elements amounts to no more than mere instructions to apply the judicial exception(s) using generic computer components. There is no indication in the Specification that the steps/functions of the claims require any inventive programming or necessitate any specialized or other inventive computer components (i.e., the steps/functions of the claims may be implemented using capabilities of general-purpose computer components). Accordingly, the additional elements do not integrate the abstract ideas into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims are directed to an abstract idea(s).
The processing components presented in the claims simply utilize the capabilities of a general-purpose computer and are, thus, merely tools to implement the abstract idea(s). As seen in MPEP § 2106.05(a)(I) and § 2106.05(f)(2), the court found that accelerating a process when the increased speed solely comes from the capabilities of a general-purpose computer is not sufficient to show an improvement in computer-functionality and it amounts to a mere invocation of computers or machinery as a tool to perform an existing process (see FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016)).
There is no transformation or reduction of a particular article to a different state or thing recited in the claims.
Additionally, even when considering the operations of the additional elements as an ordered combination, the ordered combination does not amount to significantly more than what is present in the claims when each operation is considered separately.
2B: Claim(s) Provide(s) an Inventive Concept?
No – The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception(s). As discussed above with respect to integration of the abstract idea(s) into a practical application, the use of the additional elements to perform the steps identified in Step 2A – Prong 1 above amounts to no more than mere instructions to apply the exceptions using a generic computer component(s). Mere instructions to apply an exception using a generic computer component(s) cannot provide an inventive concept. The claims are not patent eligible.
Allowable Subject Matter
Claims 1-20 are allowed over the prior art. (The claims remain rejected under 35 U.S.C. § 101.)
The following is a statement of reasons for the indication of allowable subject matter:
Independent claims 1, 9, and 13 are most closely addressed by Turato et al. (US 2019/0025856) in view of HyreCar (as disclosed in “How HyreCar Works.” Retrieved from [URL: https://web.archive.org/web/20200713184448/https://www.hyrecar.com/howitworks] on November 20, 2024, Archived on July 13, 2020) in view of Puente et al. (US 2015/0206206) in view of Brady (US 2020/0258018) in view of Hirose et al. (US 2017/0316535), for the reasons presented in the prior art rejections of the non-final Office action dated March 27, 2025.
Turato, HyreCar, Puente, Brady, and Hirose do not explicitly disclose the following set of operations:
identifying a set of mobile service vehicles in a geographical region;
determining services available at the set of mobile service vehicles;
generating, based on the vehicle-data summary corresponding to the rental match and vehicle supplies corresponding to the set of mobile service vehicles, a mobile service vehicle match; and
in response to generating the mobile service vehicle match, dispatching a mobile service vehicle corresponding to the mobile service vehicle match to the vehicle indicated by the rental match.
The following references generally discuss dispatching a mobile technician to perform service on or related to a vehicle:
"Introducing: Mobile Service from Lyft." Retrieved from [URL: https://www.lyft.com/hub/posts/introducing-mobile-service] on 9/30/2025, Published on April 17, 2019 – See entire article.
Sumino et al. (WO-2004001643-A1) – See the English translation (e.g., “Reporting to the police, reporting to the fire department (ambulance), requesting the dispatch of a tow truck, arranging for a repair shop, dispatching a person in charge of damage investigation to the site, arranging a substitute rental car,” Page 7).
Zanghi et al. (US 10,423,934) – See col. 25: 21-29; claim 1.
However, even considering all of these references individually and in combination, the Examiner finds that one of ordinary skill in the art (prior to Applicant’s invention) would not have found it obvious to perform all of the operations recited as specifically integrated in each of independent claims 1, 9, and 13. Therefore, claims 1-20 are deemed to be allowable over the prior art of record.
Conclusion
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/SUSANNA M. DIAZ/
Primary Examiner
Art Unit 3625A