DETAILED ACTION
This Office Action is in response to the amendment filed in the Request for Continued Examination on November 26, 2025. Claims 16 - 28 are presented for examination. Claims 16 - 20, 22, and 24 - 28 are rejected.
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on November 25, 2025 has been entered.
Response to Amendment
The amendment filed in the Request for Continued Examination on November 25, 2025 has been entered and considered by the examiner. Based on the amendments to the claims and reconsideration of the prior art of record, the rejections under 35 U.S.C. 103 have been withdrawn.
Response to Arguments
Applicant's arguments filed in the Request for Continued Examination on November 25, 2025 have been fully considered but they are not persuasive.
With regards to claim 16 and the rejections under 35 U.S.C. 101, the applicant argues that the claimed invention provides a user who may not be experienced to carry out complex simulations because the interface screen is specifically adapted for the simulation process.
The examiner respectfully disagrees. The amendment to the claim to add a user interface for the simulation program screen on a terminal device does not add significantly more than an abstract idea. The claimed user interface, in the amended language, is used to receive inputs for a simulation condition. Receiving inputs, as pointed out in the previous Office Action, is a step of step of receiving data, in the form of data gathering. Recitation of a user interface for the simulation program to receive data is still a step of data gathering in the form of receiving data.
In addition, the applicant argues that the recited limitations, when considered as a whole, improve the operations and management of power storage devices by making it possible to conduct specific simulation calculations where the user operates a terminal device with an interface screen for the simulation program, making it easier to use, and calculating a short-circuit current and determining the simulation result at the information processing device to make it possible to determine the simulation result, which otherwise would not have been possible due to the processing requirements.
The examiner respectfully disagrees. The amendments to the claims are not directed to providing an improvement in the technology or the functioning of a computer, as the amendment merely provides description of the element of the terminal device to receive inputs.
As a whole, the amendments provide additional limitations that still amounts to performing an evaluation to obtain short-circuit current for a thermal phenomenon simulation, without significantly more.
Paragraph [0004] of the specification recites:
“In an event related to safety of the power storage device, a plurality of physical phenomena such as chemical reaction, heat transfer, current, electrochemistry, and fluid dynamics are related to each other, and a mechanism and a physical property value are often unknown. For this reason, it is difficult for a technician who is not familiar with batteries to simulate the safety of the power storage device.”
Based on the language in the specification, providing an interface for a user for the terminal device to provide inputs does not prevent the simulation of the safety of the power storage device to be easier. Instead, the issue of the previous methods is introduced, regarding the physical phenomena along with the mechanism and physical property value being unknown, which makes it difficult for a technician unfamiliar with batteries to simulate the safety of the power storage device. Paragraphs [0100] - [0102] appears to provide subject matter, in which the invention perform the steps of providing a relationship between temperature and calorific values, which are obtained using a differential thermal analysis, then is converted to a relationship of time-calorific value, and fitted. This step appears to provide an improvement over the recitation in paragraph [0004], so that a technician who does not know much or anything about batteries, would have a less difficult task for simulating the safety of the power storage device.
In addition, the applicant argues that claims 17 - 21 provide even more practical applications, because they recite specific simulations/calculations.
The examiner respectfully disagrees. As recited in the previous Office Action, the recitation merely recites additional mental processes performed, but for the recitation of computer components. Specific simulations/calculations performed, without the addition of significantly more than the abstract idea, are merely simulations/calculations performed and directed to additional abstract ideas.
In addition, the applicant argues that claim 18 provide a practical application, because the recitation of “the power storage device includes a wound electrode assembly, the processor further configured to calculate the short-circuit current in a state where the wound electrode is virtually developed.”
The examiner respectfully disagrees. In addition to the additional mental process performed in terms of the calculations, the claimed limitation provides a description of an element of the power storage device in the form of a wound electrode assembly, without adding significantly more than the abstract idea.
In addition, the applicant argues that the recitation of claim 19 to allow simulating a thermal phenomenon accompanying an external short circuit is further evidence of the claimed subject matter providing a practical application.
The examiner respectfully disagrees. As stated in the previous Office Action, claim 19 recites additional mental processes performed. The claim does not provide significantly more than the abstract idea, as performing a simulation does not provide significantly more than the judicial exception recited individually or as a whole in conjunction with claim 16.
Examiner’s Note
Claims 21 and 23 recite the relationship regarding the calorific value and temperature, and the use of the relational expression to perform heat generation rate calculations.
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 16 - 20, 22, and 24 - 28 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
With respect to claim 16, applying step 1, the preamble of claim 16 claims a method so this claim falls within the statutory category of a process.
In order to apply step 2A, a recitation of claim 16 is copied below. The limitations of the claim that describe an abstract idea are bolded.
The claim recites:
An information processing device comprising:
a non-transitory computer-readable medium that stores a simulation program; and
a processor configured to execute the simulation program and cause the information processing device to receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device;
after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device;
receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the power storage device;
calculate a short-circuit current based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a simulation result for a thermal phenomenon from the power storage device to outside; and
transmit the simulation result of the power storage device, estimated at the information processing device, to the terminal device, located apart from the information process.
Under Step 2A, prong one, the limitation of “calculate a short-circuit current based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a simulation result for a thermal phenomenon from the power storage device to outside” is an abstract idea because it is directed to a mental process. The limitation, as drafted and under a broadest reasonable interpretation “can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer. MPEP 2106.04(a)(2)(III). For example, a person could mentally provide an evaluation in calculating a short-circuit current using the data received and the simulation model for the intended use simulate a thermal phenomenon.
Under Step 2A, prong two, this judicial exception is not integrated into a practical application because the additional claim limitations outside the abstract idea presents insignificant extra-solution activity in the form of “receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device”, “after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device”, “receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the power storage device”, and “transmit the simulation result of the power storage device, estimated at the information processing device, to the terminal device located apart from the information processing device”.
These additional limitations must be considered individually and with the claim as a whole to determine if it integrates the judicial exception into a practical application.
These additional limitations amount to insignificant extra-solution activity because it is an insignificant application of data gathering. See MPEP 2106.04(d) referencing MPEP 2106.05(g). Simply receiving data and transmitting data does not meaningfully limit the claim. Under a broadest reasonable interpretation, receiving data for the simulation condition is merely receiving data, receiving a request is merely receiving data, transmitting information and transmitting the result of the simulation are forms of receiving and sending data, in the form of data gathering. See MPEP 2016.05(g)(3). There are no additional steps making these features meaningful limitations on the claim.
The claim as a whole, is linked to performing an evaluation to obtain short-circuit current for a thermal phenomenon simulation, but there are no particular physical elements or steps in the claim that add a meaningful limitation to transform the abstract idea into a physical process. Thus, the claim as a whole is directed to a general field of use. See MPEP 2106.04(d) referencing MPEP 2106.05(h).
Moving on to step 2B of the analysis, Examiner must consider whether each claim limitation individually or as an ordered combination amounts to significantly more than the abstract idea. This analysis includes determining whether an inventive concept is furnished by an element or a combination of elements that are beyond the judicial exception. For limitations that were categorized as “apply it” or generally linking the use of the abstract idea to a particular technological environment or field of use, the analysis is the same. The limitations that were determined extra-solution activity will require further analysis.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitations are considered to be mere data gathering, in a high level of generality that the limitations in the claims that recite data gathering as a well understood, routine, and conventional activity, similar to receiving or transmitting data over a network MPEP2106.05(d)(II)(i). Receiving data and transmitting data is merely data gathering, without additional steps making this feature a meaningful limitation on the claim. The prior art of Recoskie et al (WO 2018/132911 A1) discloses the ability to transmit and receive signals with regards to simulation of a short-circuit of a battery. See MPEP 2016.05(g)(3).
Looking at the claim limitations as an ordered combination, claim 16 does not amount to significantly more.
For the foregoing reasons, claim 16 is directed to an abstract idea without significantly more, and is rejected as not patent eligible under 35 U.S.C. 101.
With respect to claim 22, applying step 1, the preamble of claim 22 claims a method so this claim falls within the statutory category of a process.
In order to apply step 2A, a recitation of claim 22 is copied below. The limitations of the claim that describe an abstract idea are bolded.
The claim recites:
An information processing device comprising:
a non-transitory computer-readable medium that stores a simulation program; and
a processor configured to execute the simulation program and cause the information processing device to receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device;
after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device;
receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the power storage device, the simulation condition including a heating location when the power storage device is heated from outside; and
simulate a thermal phenomenon from the power storage device accompanying heating of the power storage device based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a simulation result; and
transmit the simulation result estimated at the information processing device, to the terminal device, located apart from the information processing device.
Under Step 2A, prong one, the limitation of “simulate a thermal phenomenon from the power storage device accompanying heating of the power storage device based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a simulation result” is an abstract idea because it is directed to a mental process. The limitation, as drafted and under a broadest reasonable interpretation “can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer. MPEP 2106.04(a)(2)(III). For example, a person could perform an evaluation of a thermal phenomenon simulation using a generic computer using received simulation condition data.
Under Step 2A, prong two, this judicial exception is not integrated into a practical application because the additional claim limitations outside the abstract idea presents insignificant extra-solution activity in the form of “receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device”, “after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device”, “receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the power storage device”, and “transmit the simulation result, estimated at the information processing device, to the terminal device located apart from the information processing device”.
These additional limitations must be considered individually and with the claim as a whole to determine if it integrates the judicial exception into a practical application.
These additional limitations amount to insignificant extra-solution activity because it is an insignificant application of data gathering. See MPEP 2106.04(d) referencing MPEP 2106.05(g). Simply receiving data and transmitting data does not meaningfully limit the claim. Under a broadest reasonable interpretation, receiving data for a simulation condition is merely receiving data, receiving a request is merely receiving data, transmitting information and transmitting the result of the simulation are forms of receiving and sending data, in the form of data gathering. See MPEP 2016.05(g)(3). There are no additional steps making these features meaningful limitations on the claim.
The claim as a whole, is linked to performing an evaluation to obtain short-circuit current for a thermal phenomenon simulation, but there are no particular physical elements or steps in the claim that add a meaningful limitation to transform the abstract idea into a physical process. Thus, the claim as a whole is directed to a general field of use. See MPEP 2106.04(d) referencing MPEP 2106.05(h).
Moving on to step 2B of the analysis, Examiner must consider whether each claim limitation individually or as an ordered combination amounts to significantly more than the abstract idea. This analysis includes determining whether an inventive concept is furnished by an element or a combination of elements that are beyond the judicial exception. For limitations that were categorized as “apply it” or generally linking the use of the abstract idea to a particular technological environment or field of use, the analysis is the same. The limitations that were determined extra-solution activity will require further analysis.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitations are considered to be mere data gathering, in a high level of generality that the limitations in the claims that recite data gathering as a well understood, routine, and conventional activity, similar to receiving or transmitting data over a network MPEP2106.05(d)(II)(i). Receiving data and transmitting data is merely data gathering, without additional steps making this feature a meaningful limitation on the claim. The prior art of Recoskie et al (WO 2018/132911 A1) discloses the ability to transmit and receive signals with regards to simulation of a short-circuit of a battery. See MPEP 2016.05(g)(3).
Looking at the claim limitations as an ordered combination, claim 22 does not amount to significantly more.
For the foregoing reasons, claim 22 is directed to an abstract idea without significantly more, and is rejected as not patent eligible under 35 U.S.C. 101.
With respect to claim 24, applying step 1, the preamble of claim 24 claims a method so this claim falls within the statutory category of a process.
In order to apply step 2A, a recitation of claim 24 is copied below. The limitations of the claim that describe an abstract idea are bolded.
The claim recites:
An information processing device comprising:
a non-transitory computer-readable medium that stores a simulation program; and
a processor configured to execute the simulation program and cause the information processing device to receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device;
after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device;
receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the power storage device; and
simulate generation of gas accompanying a material decomposition reaction of the power storage device based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a simulation result; and
transmit the simulation result, estimated at the information processing device, to the terminal device located apart from the information processing device.
Under Step 2A, prong one, the limitation of “simulate generation of gas accompanying a material decomposition reaction of the power storage device based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a simulation result” is an abstract idea because it is directed to a mental process. The limitation, as drafted and under a broadest reasonable interpretation “can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer. MPEP 2106.04(a)(2)(III). For example, a person could perform an evaluation of gas generation using a generic computer using received simulation condition data.
Under Step 2A, prong two, this judicial exception is not integrated into a practical application because the additional claim limitations outside the abstract idea presents insignificant extra-solution activity in the form of “receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device”, “after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device”, “receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the power storage device”, and “transmit the simulation result, estimated at the information processing device, to the terminal device located apart from the information processing device”.
These additional limitations must be considered individually and with the claim as a whole to determine if it integrates the judicial exception into a practical application.
These additional limitations amount to insignificant extra-solution activity because it is an insignificant application of data gathering. See MPEP 2106.04(d) referencing MPEP 2106.05(g). Simply receiving data and transmitting data does not meaningfully limit the claim. Under a broadest reasonable interpretation, receiving data in the form of a simulation condition is merely receiving data, receiving a request is merely receiving data, transmitting information and transmitting the result of the simulation are forms of receiving and sending data, in the form of data gathering. See MPEP 2016.05(g)(3). There are no additional steps making these features meaningful limitations on the claim.
The claim as a whole, is linked to performing an evaluation to obtain short-circuit current for a thermal phenomenon simulation, but there are no particular physical elements or steps in the claim that add a meaningful limitation to transform the abstract idea into a physical process. Thus, the claim as a whole is directed to a general field of use. See MPEP 2106.04(d) referencing MPEP 2106.05(h).
Moving on to step 2B of the analysis, Examiner must consider whether each claim limitation individually or as an ordered combination amounts to significantly more than the abstract idea. This analysis includes determining whether an inventive concept is furnished by an element or a combination of elements that are beyond the judicial exception. For limitations that were categorized as “apply it” or generally linking the use of the abstract idea to a particular technological environment or field of use, the analysis is the same. The limitations that were determined extra-solution activity will require further analysis.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitations are considered to be mere data gathering, in a high level of generality that the limitations in the claims that recite data gathering as a well understood, routine, and conventional activity, similar to receiving or transmitting data over a network MPEP2106.05(d)(II)(i). Receiving data and transmitting data is merely data gathering, without additional steps making this feature a meaningful limitation on the claim. The prior art of Recoskie et al (WO 2018/132911 A1) discloses the ability to transmit and receive signals with regards to simulation of a short-circuit of a battery. See MPEP 2016.05(g)(3).
Looking at the claim limitations as an ordered combination, claim 24 does not amount to significantly more.
Looking at the claim limitations as an ordered combination, claim 24 does not amount to significantly more.
For the foregoing reasons, claim 24 is directed to an abstract idea without significantly more, and is rejected as not patent eligible under 35 U.S.C. 101.
With respect to claim 27, applying step 1, the preamble of claim 27 claims a method so this claim falls within the statutory category of a process.
In order to apply step 2A, a recitation of claim 27 is copied below. The limitations of the claim that describe an abstract idea are bolded.
The claim recites:
An information processing device comprising:
a non-transitory computer-readable medium that stores a simulation program; and
a processor configured to execute the simulation program and cause the information processing device to receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device
after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a first power storage device;
receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the first power storage device; and
calculate a short-circuit current based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a first simulation result for a first thermal phenomenon of the first power storage device; and
simulate a second thermal phenomenon from a second power storage device accompanying heating of the second power storage device due to the first thermal phenomenon from the first power storage device to determine a second simulation result; and
transmit the first and second simulation results, estimated at the information processing device, to the terminal device located apart from the information processing device.
Under Step 2A, prong one, the limitation of “calculate a short-circuit current based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program to determine a first simulation result for a first thermal phenomenon of the first power storage device”; and “simulate a second thermal phenomenon from a second power storage device accompanying heating of the second power storage device due to the first thermal phenomenon from the first power storage device to determine a second simulation result” are abstract ideas because they are directed to a mental process. The limitation, as drafted and under a broadest reasonable interpretation “can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer. MPEP 2106.04(a)(2)(III). For example, a person could mentally provide an evaluation in calculating a short-circuit current using the data received for the intended use for a thermal phenomenon simulation, and perform an evaluation of a thermal phenomenon simulation using a generic computer using received simulation condition data.
Under Step 2A, prong two, this judicial exception is not integrated into a practical application because the additional claim limitations outside the abstract idea presents insignificant extra-solution activity in the form of “receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device”, “after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device”, “receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to the first power storage device”, and “transmit the first and second simulation results, estimated at the information processing device, to the terminal device located apart from the information processing device”.
These additional limitations must be considered individually and with the claim as a whole to determine if it integrates the judicial exception into a practical application.
These additional limitations amount to insignificant extra-solution activity because it is an insignificant application of data gathering. See MPEP 2106.04(d) referencing MPEP 2106.05(g). Simply receiving data and transmitting data does not meaningfully limit the claim. Under a broadest reasonable interpretation, receiving data in the form of a simulation condition is merely receiving data, receiving a request is merely receiving data, transmitting information and transmitting the result of the simulation are forms of receiving and sending data, in the form of data gathering. See MPEP 2016.05(g)(3). There are no additional steps making these features meaningful limitations on the claim.
The claim as a whole, is linked to performing an evaluation to obtain short-circuit current for a thermal phenomenon simulation, but there are no particular physical elements or steps in the claim that add a meaningful limitation to transform the abstract idea into a physical process. Thus, the claim as a whole is directed to a general field of use. See MPEP 2106.04(d) referencing MPEP 2106.05(h).
Moving on to step 2B of the analysis, Examiner must consider whether each claim limitation individually or as an ordered combination amounts to significantly more than the abstract idea. This analysis includes determining whether an inventive concept is furnished by an element or a combination of elements that are beyond the judicial exception. For limitations that were categorized as “apply it” or generally linking the use of the abstract idea to a particular technological environment or field of use, the analysis is the same. The limitations that were determined extra-solution activity will require further analysis.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitations are considered to be mere data gathering, in a high level of generality that the limitations in the claims that recite data gathering as a well understood, routine, and conventional activity, similar to receiving or transmitting data over a network MPEP2106.05(d)(II)(i) Receiving data and transmitting data is merely data gathering, without additional steps making this feature a meaningful limitation on the claim. The prior art of Recoskie et al (WO 2018/132911 A1) discloses the ability to transmit and receive signals with regards to simulation of a short-circuit of a battery. See MPEP 2016.05(g)(3).
Looking at the claim limitations as an ordered combination, claim 27 does not amount to significantly more.
For the foregoing reasons, claim 27 is directed to an abstract idea without significantly more, and is rejected as not patent eligible under 35 U.S.C. 101.
With respect to claim 28, applying step 1, the preamble of claim 28 claims a method so this claim falls within the statutory category of a process.
In order to apply step 2A, a recitation of claim 28 is copied below. The limitations of the claim that describe an abstract idea are bolded.
The claim recites:
An information processing device comprising:
a non-transitory computer-readable medium that stores a simulation program; and
a processor configured to execute the simulation program and cause the information processing device to receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device
after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device;
receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to a first power storage device, the simulation condition including a heating location when the first power storage device is heated from outside;
simulate a first thermal phenomenon of the first power storage device accompanying heating of the first power storage device based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program; and
simulate a second thermal phenomenon from a second power storage device accompanying heating of the second power storage device due to the first thermal phenomenon of the first power storage device to determine a second simulation result; and
transmit the first and second simulation results, estimated at the information processing device to the terminal device located apart from the information processing device.
Under Step 2A, prong one, the limitation of “simulate a first thermal phenomenon of the first power storage device accompanying heating of the first power storage device based on the received simulation condition using a simulation model set up in advance and stored as part of the simulation program”; and “simulate a second thermal phenomenon from a second power storage device accompanying heating of the second power storage device due to the first thermal phenomenon of the first power storage device to determine a second simulation result” are abstract ideas because they are directed to a mental process. The limitation, as drafted and under a broadest reasonable interpretation “can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer. MPEP 2106.04(a)(2)(III). For example, a person could mentally provide an evaluation of thermal phenomenon simulations using a generic computer using received simulation condition data and data received from a simulation of thermal phenomenon performed.
Under Step 2A, prong two, this judicial exception is not integrated into a practical application because the additional claim limitations outside the abstract idea presents insignificant extra-solution activity in the form of “receive a request from a terminal device operated by a user, located apart from an information processing device, communicably connected to the information processing device”, “after receiving the request, transmit information for an interface screen to the terminal device, the interface screen being configured to receive inputs for a simulation condition related to a power storage device”, “receive the inputs entered by the user at the terminal device by way of an interface screen for the simulation program for the simulation condition related to a first power storage device, the simulation condition including a heating location when the first power storage device is heated from outside”, and “transmit the first and second simulation results, estimated at the information processing device to the terminal device located apart from the information processing device”.
These additional limitations must be considered individually and with the claim as a whole to determine if it integrates the judicial exception into a practical application.
These additional limitations amount to insignificant extra-solution activity because it is an insignificant application of data gathering. See MPEP 2106.04(d) referencing MPEP 2106.05(g). Simply receiving data and transmitting data does not meaningfully limit the claim. Under a broadest reasonable interpretation, receiving data in the form of a simulation condition is merely receiving data, receiving a request is merely receiving data, transmitting information and transmitting the result of the simulation are forms of receiving and sending data, in the form of data gathering. See MPEP 2016.05(g)(3). There are no additional steps making these features meaningful limitations on the claim.
The claim as a whole, is linked to performing an evaluation to obtain short-circuit current for a thermal phenomenon simulation, but there are no particular physical elements or steps in the claim that add a meaningful limitation to transform the abstract idea into a physical process. Thus, the claim as a whole is directed to a general field of use. See MPEP 2106.04(d) referencing MPEP 2106.05(h).
Moving on to step 2B of the analysis, Examiner must consider whether each claim limitation individually or as an ordered combination amounts to significantly more than the abstract idea. This analysis includes determining whether an inventive concept is furnished by an element or a combination of elements that are beyond the judicial exception. For limitations that were categorized as “apply it” or generally linking the use of the abstract idea to a particular technological environment or field of use, the analysis is the same. The limitations that were determined extra-solution activity will require further analysis.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitations are considered to be mere data gathering, in a high level of generality that the limitations in the claims that recite data gathering as a well understood, routine, and conventional activity, similar to receiving or transmitting data over a network MPEP2106.05(d)(II)(i) Receiving data and transmitting data is merely data gathering, without additional steps making this feature a meaningful limitation on the claim. The prior art of Recoskie et al (WO 2018/132911 A1) discloses the ability to transmit and receive signals with regards to simulation of a short-circuit of a battery. See MPEP 2016.05(g)(3).
Looking at the claim limitations as an ordered combination, claim 28 does not amount to significantly more.
For the foregoing reasons, claim 28 is directed to an abstract idea without significantly more, and is rejected as not patent eligible under 35 U.S.C. 101.
With respect to claim 17, the limitations recited, as an ordered combination with claim 16, falls under the abstract idea as being directed to a mental process, due to its dependence on claim 16, recited as being directed to a mental process above, and does not integrate the judicial exception into a practical application.
Individually, claim 17 recites additional mental processes that can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer, along with details of the simulation condition received in the data gathering step performed, without providing any elements that are sufficient to amount to significantly more than the judicial exception.
With respect to claim 18, the limitations recited, as an ordered combination with claim 16, falls under the abstract idea as being directed to a mental process, due to its dependence on claim 16, recited as being directed to a mental process above, and does not integrate the judicial exception into a practical application.
Individually, claim 18 recites additional mental processes that can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer, without providing any elements that are sufficient to amount to significantly more than the judicial exception.
With respect to claim 19, the limitations recited, as an ordered combination with claim 16, falls under the abstract idea as being directed to a mental process, due to its dependence on claim 16, recited as being directed to a mental process above, and does not integrate the judicial exception into a practical application.
Individually, claim 19 recites additional mental processes that can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer, along with additional details that describe the simulation condition received in the data gathering step performed, without providing any elements that are sufficient to amount to significantly more than the judicial exception.
With respect to claim 20, the limitations recited, as an ordered combination with claim 16, falls under the abstract idea as being directed to a mental process, due to its dependence on claim 16, recited as being directed to a mental process above, and does not integrate the judicial exception into a practical application.
Individually, claim 20 recites additional mental processes that can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer, along with additional details of the simulation condition received in the data gathering step performed, without providing any elements that are sufficient to amount to significantly more than the judicial exception.
With respect to claim 25, the limitation recited, as an ordered combination with claim 24, falls under the abstract idea as being directed to a mental process, due to its dependence on claim 24, recited as being directed to a mental process above, and does not integrate the judicial exception into a practical application.
Individually, claim 25 recites an additional mental process that can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer with regards to calculations performed, without providing any elements that are sufficient to amount to significantly more than the judicial exception.
With respect to claim 26, the limitations recited, as an ordered combination with claim 25, falls under the abstract idea as being directed to a mental process, due to its dependence on claim 25, recited as being directed to a mental process above, and does not integrate the judicial exception into a practical application.
Individually, claim 26 recites additional mental processes that can be performed in the human mind, or by a human using a pen and paper”, including an observation, evaluation, judgement or opinion, but for the recitation of computer components or a generic computer with regards to calculations performed, without providing any elements that are sufficient to amount to significantly more than the judicial exception.
Allowable Subject Matter
The following is a statement of reasons for the indication of allowable subject matter:
Claim 16: The prior art of Recoskie et al (WO 2018/132911 A1) discloses a simulation of conditions experienced by a battery performed, including a short-circuit event Chiu et al. (“ An Electrochemical Modeling of Lithium-Ion Battery Nail Penetration”) discloses exothermic reaction due to short circuit of a battery, Zavalis et al. (“Investigation of Short-Circuit Scenarios in a Lithium-Ion Battery Cell”) discloses thermal runaway due to short circuit of a battery, Lee et al. (“Failure Analysis of Short-Circuited Lithium-Ion Battery with Nickel-Manganese-Cobalt/Graphite Electrode”) discloses gas produced due to a short circuit of a battery, McCoy et al (U.S. PG Pub 20120182021 A1) discloses thermal runaway due to a parallel connection between two batteries, and monitoring differential current to prevent it, and Haimovich et al. (“A Simulator for System-Level Analysis of Heat Transfer and Phase Change in Thermal Batteries”) discloses GUI and desktop machine to simulate thermal batteries with validation of the model before simulation is performed, and Iizuka et al (JP 2006010648 A) discloses total calorific value and heat generation rate.
However, none of the references cited, including the prior art of Recoskie, Chiu, Zavalis, Lee, McCoy, Haimovich, and Iizuka, taken either alone or in combination with the prior art of record discloses for claim 16: An information processing device, including the step obtaining a condition of a simulation and using the condition, along with a simulation model associated with a simulation program to compute a current of a short-circuit, and using the short-circuit current to perform a simulation of a thermal phenomenon of a power storage device, in combination with the remaining elements and features of the claimed invention. It is for these reasons that the applicants’ invention defines over the prior art of record.
Dependent claims 17 - 21 are allowable under 35 U.S.C. 103 for depending from claim 16, an allowable base claim under 35 U.S.C. 103.
Claim 22: The prior art of Recoskie et al (WO 2018/132911 A1) discloses a simulation of conditions experienced by a battery performed, including a short-circuit event Chiu et al. (“ An Electrochemical Modeling of Lithium-Ion Battery Nail Penetration”) discloses exothermic reaction due to short circuit of a battery, Zavalis et al. (“Investigation of Short-Circuit Scenarios in a Lithium-Ion Battery Cell”) discloses thermal runaway due to short circuit of a battery, Lee et al. (“Failure Analysis of Short-Circuited Lithium-Ion Battery with Nickel-Manganese-Cobalt/Graphite Electrode”) discloses gas produced due to a short circuit of a battery, McCoy et al (U.S. PG Pub 20120182021 A1) discloses thermal runaway due to a parallel connection between two batteries, and monitoring differential current to prevent it, and Haimovich et al. (“A Simulator for System-Level Analysis of Heat Transfer and Phase Change in Thermal Batteries”) discloses GUI and desktop machine to simulate thermal batteries with validation of the model before simulation is performed, and Iizuka et al (JP 2006010648 A) discloses total calorific value and heat generation rate.
However, none of the references cited, including the prior art of Recoskie, Chiu, Zavalis, Lee, McCoy, Haimovich, and Iizuka, taken either alone or in combination with the prior art of record discloses claim 22: An information processing device, including the step obtaining a condition of a simulation for a power storage device, based on the power storage device with a heating location located on the outside, and using the condition, and heating location, along with a simulation model associated with a simulation program to perform a simulation of a thermal phenomenon of the power storage device, in combination with the remaining elements and features of the claimed invention. It is for these reasons that the applicants’ invention defines over the prior art of record.
Dependent claim 23 is allowable under 35 U.S.C. 103 for depending from claim 22, an allowable base claim under 35 U.S.C. 103.
Claim 24: The prior art of Recoskie et al (WO 2018/132911 A1) discloses a simulation of conditions experienced by a battery performed, including a short-circuit event Chiu et al. (“ An Electrochemical Modeling of Lithium-Ion Battery Nail Penetration”) discloses exothermic reaction due to short circuit of a battery, Zavalis et al. (“Investigation of Short-Circuit Scenarios in a Lithium-Ion Battery Cell”) discloses thermal runaway due to short circuit of a battery, Lee et al. (“Failure Analysis of Short-Circuited Lithium-Ion Battery with Nickel-Manganese-Cobalt/Graphite Electrode”) discloses gas produced due to a short circuit of a battery, McCoy et al (U.S. PG Pub 20120182021 A1) discloses thermal runaway due to a parallel connection between two batteries, and monitoring differential current to prevent it, and Haimovich et al. (“A Simulator for System-Level Analysis of Heat Transfer and Phase Change in Thermal Batteries”) discloses GUI and desktop machine to simulate thermal batteries with validation of the model before simulation is performed, and Iizuka et al (JP 2006010648 A) discloses total calorific value and heat generation rate.
However, none of the references cited, including the prior art of Recoskie, Chiu, Zavalis, Lee, McCoy, Haimovich, and Iizuka, taken either alone or in combination with the prior art of record discloses for claim 24: An information processing device, including the step obtaining a condition of a simulation and using the condition, along with a simulation model associated with a simulation program to compute a material decomposition reaction that generates gas regarding the power storage device, in combination with the remaining elements and features of the claimed invention. It is for these reasons that the applicants’ invention defines over the prior art of record.
Dependent claims 25 and 26 are allowable under 35 U.S.C. 103 for depending from claim 24, an allowable base claim under 35 U.S.C. 103.
Claims 27 and 28: The prior art of Recoskie et al (WO 2018/132911 A1) discloses a simulation of conditions experienced by a battery performed, including a short-circuit event Chiu et al. (“ An Electrochemical Modeling of Lithium-Ion Battery Nail Penetration”) discloses exothermic reaction due to short circuit of a battery, Zavalis et al. (“Investigation of Short-Circuit Scenarios in a Lithium-Ion Battery Cell”) discloses thermal runaway due to short circuit of a battery, Lee et al. (“Failure Analysis of Short-Circuited Lithium-Ion Battery with Nickel-Manganese-Cobalt/Graphite Electrode”) discloses gas produced due to a short circuit of a battery, McCoy et al (U.S. PG Pub 20120182021 A1) discloses thermal runaway due to a parallel connection between two batteries, and monitoring differential current to prevent it, and Haimovich et al. (“A Simulator for System-Level Analysis of Heat Transfer and Phase Change in Thermal Batteries”) discloses GUI and desktop machine to simulate thermal batteries with validation of the model before simulation is performed, and Iizuka et al (JP 2006010648 A) discloses total calorific value and heat generation rate.
However, none of the references cited, including the prior art of Recoskie, Chiu, Zavalis, Lee, McCoy, Haimovich, and Iizuka, taken either alone or in combination with the prior art of record discloses for claim 27: An information processing device, including the step obtaining a condition of a simulation and using the condition, along with a simulation model associated with a simulation program to compute a current of a short-circuit, and using the short-circuit current to perform a simulation of a thermal phenomenon of a power storage device, and performing an additional simulation, in which a different power storage device is affected by the thermal phenomenon of the previous power storage device, to obtain a result of a thermal phenomenon regarding the different power storage device, in combination with the remaining elements and features of the claimed invention. It is for these reasons that the applicants’ invention defines over the prior art of record.
Conclusion
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/Cedric Johnson/ Primary Examiner, Art Unit 2186
December 19, 2025