DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 February 05, 2026 has been entered.
Status of Claims
This action is in response to the reply filed February 05, 2026.
Claims 1 and 11 have been amended.
Claims 2 and 12 have been cancelled.
Claims 1, 3-11, and 13-20 are currently pending and have been examined.
Response to Arguments
As explained in the Non-Obvious Subject Matter section below, the previous rejection under 35 USC 103 has been withdrawn in response to the submitted amendments.
Applicant’s remarks filed February 05, 2026 have been fully considered but they are not persuasive.
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
Claims 1 and 11 integrate the alleged abstract idea into a practical application by reciting a specific improvement to the operation of a computerized reservation system. The claims are not directed merely to the concept of reserving a facility or charging for its use. Instead, they define a particular server-implemented mechanism for managing reservation capacity over time in a manner that improves system operation, availability, and efficiency.
Examiner respectfully disagrees. Regarding the particularity of the claims, merely reciting claims that are a narrow application of the identified idea is not sufficient to recite patent eligible subject matter. See Electronic Communication v. Shopperschoice.com, LLC, 958 F.3d 1178, 1183 (Fed. Cir. 2020) (“patent eligibility turns on the content of the claims, not merely on the number of words recited in the claims”); BSG Tech LLC v. BuySeasons, Inc., 899 F.3d 1281, 1287 (Fed. Cir. 2018) (“a claim is not patent eligible merely because it applies an abstract idea in a narrow way”).
The identified improvements of managing reservation capacity over time argued by Applicant are really, at best, improvements to the performance of the abstract idea itself (e.g. improvements made in the underlying business method) and not in the operations of any additional elements or technology. For example, in Trading Tech, the court determined that the claim simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology. Trading Technologies Int’l v. IBG LLC, 921 F.3d 1084, 1093-94 (Fed. Cir. 2019). See In re Board of Trustees of Leland Stanford Junior University, 991 F.3d 1245, 1251 (Fed. Cir. 2021) (“[T]he improvement in computational accuracy alleged here does not qualify as an improvement to a technological process; rather, it is merely an enhancement to the abstract mathematical calculation … itself.”).
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
As amended, claims 1 and 11 require the management server to maintain a reservation upper limit time for a user during a predetermined period, to decrement that stored limit when a reservation is made, and to automatically restore previously consumed reservation capacity when a reservation lapses. Importantly, the claims now expressly require that the management server monitor stored reservation date and time information to detect lapse of the reservation date and time independently of any user request. Upon detection of such lapse, the server automatically generates an updated reservation upper limit time by adding back the previously consumed usage time, without requiring receipt of any additional reservations, purchases, or user input.
This functionality constitutes a technological improvement to the reservation system itself. The claimed server does not simply execute a business rule faster. Rather, it maintains and updates a persistent system state that dynamically changes in response to temporal events detected by the server. The automatic restoration of reservation capacity upon lapse alters how the system manages limited resources, enabling reuse of reservation capacity within the predetermined period while preventing over-allocation. This improves system availability and utilization and reduces reservation congestion, which are technical problems identified in the specification.
Examiner respectfully disagrees. Monitoring stored reservation date and time information to detect lapse of the reservation date and time independently of any user request is a part of the previously identified abstract idea. The instant claims recital of server is merely the use of a computer as a tool for automating the detection of temporal events, updating reservation states, and adjusting reservation limits. Improving the performance of the abstract idea by using a computer as a tool does not materially alter the patent eligibility of the claimed subject matter. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted)).
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
The Office Action's characterization of the claims as merely improving the performance of an abstract idea or automating a manual process is not supported by the claim language. The claimed behavior cannot be practically performed by a human, particularly in a networked system handling multiple users, facilities, and overlapping reservations. Detecting reservation lapse events, reconciling consumed reservation capacity, and restoring availability without user action require continuous server-side monitoring and state updates that are inherently computer- implemented. The claims therefore do not simply computerize a known manual practice, but instead introduces a new operational model enabled by server-based event detection and automated state management.
Examiner respectfully disagrees. Claims can recite a mental process even if they are claimed as being performed on a computer. The Supreme Court recognized this in Benson, determining that a mathematical algorithm for converting binary coded decimal to pure binary within a computer’s shift register was an abstract idea. The Court concluded that the algorithm could be performed purely mentally even though the claimed procedures "can be carried out in existing computers long in use, no new machinery being necessary." 409 U.S at 67, 175 USPQ at 675. See also Mortgage Grader, 811 F.3d at 1324, 117 USPQ2d at 1699 (concluding that concept of "anonymous loan shopping" recited in a computer system claim is an abstract idea because it could be "performed by humans without a computer"). See also MPEP 2106.04(a)(2)(III)(C).
As detailed in the rejection below, all of the identified additional elements, including the server, are generic computer components performing generic computer functions. In re TLI Communications LLC Patent Litigation, 823 F.3d 607, 612 (Fed. Cir. 2016) (The specification does not describe a new telephone, a new server, or a new physical combination of the two. The specification fails to provide any technical details for the tangible components, but instead predominately describes the system and methods in purely functional terms.) Any novelty in the “new operational model” cannot provide the inventive concept necessary for patent eligibility. See Genetic Techs. Ltd. v. Merial L.L.C., 818 F.3d 1369, 1376 (Fed. Cir. 2016) ("[U]nder the Mayo/Alice framework, a claim directed to a newly discovered law of nature (or natural phenomenon or abstract idea) cannot rely on the novelty of that discovery for the inventive concept necessary for patent eligibility.")
Regarding the previous rejection under 35 USC 101, Applicant presented the following arguments:
Moreover, the processing elements are not used as generic tools. Claims 1 and 11 require specific interactions between stored reservation information, time-based monitoring, and automatic generation of updated reservation limits that change system behavior in real time. These limitations define a particular way of managing temporal resource constraints in an on- demand reservation system, and they meaningfully limit the claims to a specific technological solution.
Examiner respectfully disagrees. The improvements identified by Applicant are really, at best, improvements to the performance of the abstract idea itself (e.g. improvements made in the underlying business method) and not in the operations of any additional elements or technology. For example, in Trading Tech, the court determined that the claim simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology. Trading Technologies Int’l v. IBG LLC, 921 F.3d 1084, 1093-94 (Fed. Cir. 2019). See In re Board of Trustees of Leland Stanford Junior University, 991 F.3d 1245, 1251 (Fed. Cir. 2021) (“[T]he improvement in computational accuracy alleged here does not qualify as an improvement to a technological process; rather, it is merely an enhancement to the abstract mathematical calculation … itself.”).
As detailed in the rejection below, all of the identified additional elements, including the server, are generic computer components performing generic computer functions. In re TLI Communications LLC Patent Litigation, 823 F.3d 607, 612 (Fed. Cir. 2016) (The specification does not describe a new telephone, a new server, or a new physical combination of the two. The specification fails to provide any technical details for the tangible components, but instead predominately describes the system and methods in purely functional terms.)
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, 3-11, and 13-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Alice/Mayo Framework Step 1:
Claims 1 and 3-10 recite a combination of devices and therefore recite a machine.
Claims 11 and 13-20 recite a series of steps and therefore recite a process.
Alice/Mayo Framework Step 2A – Prong 1:
Claims 1 and 11, as a whole, are directed to the abstract idea of managing reservations by tracking usage time and comparing usage time to time limits, which is a mathematical concept, a method of organizing human activity, and a mental process. The claims recite a mathematical concept because the identified idea is a mathematical calculation by reciting adding and subtracting usage time in order to compare to a time limit. See MPEP 2106.04(a)(2)(I)(C). The claims recite a method of organizing human activity because the identified idea is a fundamental economic principles or practices (including hedging, insurance, mitigating risk) by reciting managing shared resource using time limits. See MPEP 2106.04(a)(2)(II)(A). The claims recite a method of organizing human activity because the identified idea is managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions) by reciting rejecting and allowing reservations by the tracking the usage time of individual users and comparing that to time limits. See MPEP 2106.04(a)(2)(II)(C). The claims recite a mental processes because the identified idea contains limitations that can practically be performed in the human mind (including an observation, evaluation, judgement, or opinion) by reciting observing a users usage time and evaluating whether a reservation usage time by a user would exceed the time limit. See MPEP 2106.04(a)(2)(III). The mathematical concept, method of organizing human activity, and mental process of “managing reservations by tracking usage time and comparing usage time to time limits,” is recited by claiming the following limitations: obtaining user information, setting a reservation upper limit time, receiving a reservation, determining if the usage time exceeds the limit time, if the usage does not exceed the limit then manage the reservation and update the limit time, determining a reservation has lapsed, monitoring reservation information to detect a reservation lapse, and generating an updated upper limit time. The mere nominal recitation of a management server, a terminal device, a communication network, a processor, and a memory does not take the claim of the mathematical concept, method of organizing human activity, or mental process groupings. Thus, the claim recites an abstract idea.
With regards to Claims 6, 8, 13-16, and 18, the claims further recite the above-identified judicial exception (the abstract idea) by reciting the following limitations: determining a reservation has been deleted, receiving a second reservation, determining if the second usage time exceeds updated limit time, processing a reservation as unacceptable, receiving a third reservation, determining if the third usage time exceeds the updated limit time, if the third usage does not exceed the updated limit then manage the reservation and update the limit time, charging a rental fee, and determining whether a reservation date and time exceed a time period.
Alice/Mayo Framework Step 2A – Prong 2:
Claims 1 and 11 recite the additional elements: a management server, a terminal device, a communication network, a processor, and a memory. These a management server, a terminal device, a communication network, a processor, and a memory limitations are no more than mere instructions to apply the exception using a generic computer component. Taken individually these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Considering the limitations containing the judicial exception as well as the additional elements in the claim besides the judicial exception does not amount to a practical application of the abstract idea. The claim as a whole does not improve the functioning of a computer or improve other technology or improve a technical field. The claim as a whole is not implemented with a particular machine. The claim as a whole does not effect a transformation of a particular article to a different state. The claim as a whole is not applied in any meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception. The claim as a whole merely describes how to generally “apply” the concept of time limits in a computer environment. The claimed computer components are recited at a high level of generality and are merely invoked as tools to perform an existing resource sharing process. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea. The claim is directed to the abstract idea.
Alice/Mayo Framework Step 2B:
Claims 1 and 11 do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claims recite a generic computer performing generic computer function by reciting a management server, a terminal device, a communication network, a processor, and a memory. See Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1341 (describing a “processor” as a generic computer component); Mortg. Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d 1314, 1324–25 (Fed. Cir. 2016) (claims reciting an “interface,” “network,” and a “database” are nevertheless directed to an abstract idea); Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343, 1347–48 (discussing the same with respect to “data” and “memory”). The claims recite generic computer functions by reciting receiving information (See MPEP 2106.05(d)(II) receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec; TLI Communications LLC; OIP Techs.; buySAFE, Inc.), processing information (See MPEP 2106.05(d)(II) performing repetitive calculations, Flook; Bancorp Services), retrieving information (See MPEP 2106.05(d)(II) storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc.; OIP Technologies), and updating information (See MPEP 2106.05(d)(II) electronic recordkeeping, Alice Corp.; Ultramercial). The specification demonstrates the well-understood, routine, conventional nature of the following additional elements because they are described in a manner that indicates the elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. 112(a): a management server (Specification [0023]), a terminal device (Specification [0020]), a communication network (Specification [0020]), a processor (Specification [0023]), and a memory (Specification [0023]). See MPEP 2106.05(d)(I)(2). The claims add the words “apply it” or words equivalent to “apply the abstract idea” such as instructions to implement the abstract idea on a computer by reciting a management server, a terminal device, a communication network, a processor, and a memory. See MPEP 2106.05(f). Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. See MPEP 2106.05(a). Their collective functions merely provide conventional computer implementation. See MPEP 2106.05(b). Therefore, the claims do not include additional elements that are sufficient to amount to significantly more than the recited judicial exception.
Remaining Claims:
With regards to Claims 7, 9-10, 17, and 19-20, these claims merely add a degree of particularity to the limitations discussed above rather than adding additional elements capable of transforming the nature of the claimed subject matter. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. Therefore, the claims as a whole do not amount to significantly more than the abstract idea itself.
Non-Obvious Subject Matter
The following is a statement of reasons for the indication of non-obvious subject matter:
The closest prior art of record is Reddy et al. (U.S. P.G. Pub. 2003/0182150 A1); Cromer et al. (U.S. P.G. Pub. 2008/0147555 A1); Mosko et al. (U.S. P.G. Pub. 2010/0142551 A1); Smullin et al. (U.S. P.G. Pub. 2014/0089016 A1).
Applicant’s discussion of Reddy and Cromer regarding the purchase of more time for the adjustment of the limit times on the Remarks filed February 05, 2026 on p. 9 are found persuasive.
Mosko discloses using a maximum number of reservable time slots in a communication network, however the slots are distinct from the usage time values and their relationship to limit times as claimed (Mosko [0041], [0043], [0053]).
Smullin discloses placing limits on the total number of reservations at a charging capable parking space, however the total length of those reservations is not limited (Smullin [0056], [0077], [0088]).
The closest prior art of record does not utilize the combination of limitations that perform calculations for a total reservable amount of time (i.e. a reservation upper limit), wherein that total reservable amount of time is reduced after each reservation booking (i.e. a first updated reservation upper limit) and replenished after the completion of each usage (i.e. a second updated reservation upper time limit). In other words, the closest prior art either uses purchasable amounts of time or a maximum number of reservations but it not use a limit set by a rolling bank of reservable time as claimed.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Mosko et al. (U.S. P.G. Pub. 2010/0142551 A1); Smullin et al. (U.S. P.G. Pub. 2014/0089016 A1).
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/SCOTT M TUNGATE/Primary Examiner, Art Unit 3628