DETAILED ACTION
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 Nov. 21st, 2025 has been entered.
This action is in response to the amendments filed on Nov. 21st, 2025. A summary of this action:
Claims 1, 3-7, 10-23 have been presented for examination.
Claims 2, 8-9 were cancelled
Claims 1, 11, and 18 are objected to because informalities:
Claim 1, 3-7, 10-23 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement
Claims 1, 3-7, 10-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea of both a mathematical concept and mental process without significantly more.
The claims are not rejected under § 102/103
The closest art of reference is the newly cited Lankarani, H. M., G. Olivares, and H. Nagarajan. "A Virtual Multibody and Finite Element Analysis Environment in the Field of Aerospace Crashworthiness." Virtual Nonlinear Multibody Systems. Dordrecht: Springer Netherlands, 2003. 187-212. See § 3 ¶ 1, then see §§ 5-5.2, as taken in view of newly cited Soltis, Stephen J. "Overview of usage of crash dynamic analytical methods in civil aircraft research and certification programs." Proceedings of the International Aircraft Fire and Cabin Safety Research Conference. 2007., section “Head Impact Protection Design Guidelines”, including see the section fig. 13 “Row-to-row” and “Examples of Head Strike Surfaces” and fig. 15 for “MADYMO Model Response”; as taken in further view of Vadlamudi, “A multi-body systems approach to simulate helicopter occupant protection systems”, 2011, as was previously cited, including its teaching on page 213, col. 1, ¶ 1 for “In order to accelerate the modelling process and simulation times, the three occupants were simulated in isolation, as there were no interactions between them, before integration into the full model shown in Figure 6.”, as taken in further view either of newly cited Cheng et al., “Experiences in reverse-engineering of a "Finite element automobile crash model”, 2001, § 2, third bullet point for the translating limitation, or in view of newly cited Egan et al., “Techniques for Real-Time Rigid Body Simulation”, 2003 § 2.4.2 (note the limitations are in the alternative) however these combinations of prior art, even when the order of the references is changed (e.g. Vadlamudi as previously cited taken as the primary reference), do not fairly teach the express ordered combination of all features now claimed as it “would require a substantial reconstruction and redesign of the elements shown in [the primary reference] as well as a change in the basic principle under which the [primary reference] construction was designed to operate” (MPEP § 2143.01(VI)), and without impermissible hindsight to arrive at what is expressly claimed
This action is non-final
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/Amendments
Regarding the claim objections
Withdrawn in part, maintained in part.
Regarding the § 112 Rejection
Withdrawn in view of amendment, new grounds as necessitated by amendment.
Regarding the § 101 Rejection
Maintained, substantially updated as necessitated by substantial amendment.
With respect to the prong 1 remarks, incl.: “Importantly, the halting
condition is triggered by a physics grounded event in which an overlap occurs between the
modeled components, which signals that the partial simulations should be combined”, see below for how the rejection treats this subject matter.
To summarize, this is simply the abstract idea of a simple application of Newton’s laws of motion, along with some elementary physics. The alleged important feature is merely an aspect of Newton’s first and third laws, i.e. its merely that until the collision, both objects in motion have no forces but their own initially applied forces/accelerations (see instant specification) to them, but when they collide one must apply conservation of momentum/energy.
Or to put it in the analogy of the apple that fell and hit Newton’s head, in the time before it collided with his head, but after it started falling, there was only one force acting on it, which was gravity. F=ma=mg, g = -9.8m/s.
From that force, and from Newton’s laws of motion and Newton’s discovery of calculus, one is readily able to calculate the trajectory (velocity and position as function of time) of the apple (or in this case, each individual seat) for the applied acceleration of gravity.
To do such a calculation, one only needs a single time point, i.e. the time when the apple hits Newton’s head, for at that time one must halt the integrals, because there is another force acting on the apple: the equal and opposite force imposed by the collision with Newton’s head.
At this point, for the moment around the collision with the head, a person must then also apply the math of conversation of energy/momentum, for at the point of collision a second force is applied to the apple. In other words, the math calculations for the velocity and position of the apple during and after the collision require factoring in the forces/energy/momentum of the collision, but only in that time frame, for prior to the collision only gravity acted on the apple.
That is the abstract idea this claim is directed to, but to do it for seats in a seating arrangement, with an applied “force” on each seat (as claimed, ¶ 72 and elsewhere in the specification: “acceleration”, i.e. F=ma). In other words, apply the same math as the apple falling, one can readily mentally evaluate the position and velocity as a function of time of each seat individually before the collision. From this, one can readily determine when and where they will collide (when they reach the same position), akin to determining when and where (at what height) the apple will hit Newton’s head.
But then, much like the apple, when the two seats (and virtual body on the second seat) collide, one must calculate using the math principles of conservation of momentum/energy for the time of the collision, i.e. one has to combine the forces, and similar such variables, at the point of collision, per Newton’s third law and conservations of energy/momentum, but one only needs to do this at the time period of the collision, because before this the seats have no interaction with each other.
With respect to alleging “elements” and “nodes” and the like, this implies that the claim requires the use of finite element analysis. But such is not claimed (¶ 24), and even if it were its not directed at a particular technological implementation in finite element analysis, but rather merely conveys using generic, conventional (¶ 2; WURC evidence of record as well) FEM to obtain the data as claimed.
Nor is there any data structures particularly recited in the claim, and furthermore:
MPEP § 2106.05(a)(I): “Examples that the courts have indicated may not be sufficient to show an improvement in computer-functionality… vii. Providing historical usage information to users while they are inputting data, in order to improve the quality and organization of information added to a database, because "an improvement to the information stored by a database is not equivalent to an improvement in the database’s functionality," BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1287-88, 127 USPQ2d 1688, 1693-94 (Fed. Cir. 2018); and”
Furthermore, several of these remarks allege improvements to technology, but the specification does not provide support for the particular improvements alleged. See MPEP § 2106.05(a), for the specification must provide sufficient details for POSITA to recognize the alleged improvement.
See the rejection below for more clarification
With respect to the prong 2 remarks, see the rejection below. Furthermore, as noted above, several of these remarks allege improvements to technology, but the specification does not provide support for the particular improvements alleged. See MPEP § 2106.05(a), for the specification must provide sufficient details for POSITA to recognize the alleged improvement.
With respect to the 2B remarks, the remarks don’t address the WURC evidence of record. Thus, these don’t address the rationale of record, i.e. the alleged technology of this claim is nothing more then what is routine and conventional in the field of use.
To clarify, as shown by the WURC evidence of record and unrebutted, the coupling of such simulations is a common practice, routinely performed. The claims present no new novel technological implementation of how two separate computer simulations are combined together (e.g. by some novel particular data structure that links their shared data in a manner that provides an improvement to technology, e.g. by other improvements in the technology of how information is exchanged between them, etc.), but rather merely claim generically combining their results.
With respect to the new claims, see below for how they are rejected.
Claim Interpretation
Claims 1 and 11 only differ by claim 1 requiring the use of a computer. In the preamble.
Thus, claim 11 is a mental process, because it does not expressly recite the computer (MPEP § 2111 for In re Prater) and is differentiated from claim 1 by its express lack of a computer.
Should a computer be added into claim 11, then this would be duplicate claims.
Therefore, in that event, the Examiner provides the following warning:
Applicant is advised that should claim 1 (and dependents thereof) be found allowable, claim 11 (and parallel dependents thereof) will be objected to under 37 CFR 1.75 as being a substantial duplicate thereof. When two claims in an application are duplicates or else are so close in content that they both cover the same thing, despite a slight difference in wording, it is proper after allowing one claim to object to the other as being a substantial duplicate of the allowed claim. See MPEP § 608.01(m).
The Examiner suggests deleting claim 11.
Claim Objections
Claims 1, 11, and 18 are objected to because of the following informalities:
The independent claims, using claim 1 as representative recites the term “common” (e.g. instant disclosure, ¶ 46). At issue is that this term may be considered a subjective term as to what “common” is intended to convey, rendering the claim ambiguous. In view of the instant disclosure, the Examiner interprets this term, in view of ¶ 46, to mean have a single time interval and a single reference frame for both the first and second numerical simulations (akin to claim 1). The Examiner suggests amending to more clearly reflect this interpretation and to delete the word “common” to avoid any potential ambiguity issues.
Appropriate correction is required.
Claim Rejections - 35 USC § 112(a)
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claim 1, 3-7, 10-23 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The dependent claims inherit the deficiencies of the claims they depend upon.
See MPEP 2163(II)(A): "For example, in Hyatt v. Dudas, 492 F.3d 1365, 1371, 83 USPQ2d 1373, 1376-1377 (Fed. Cir. 2007), the examiner made a prima facie case by clearly and specifically explaining why applicant’s specification did not support the particular claimed combination of elements, even though applicant’s specification listed each and every element in the claimed combination. The court found the "examiner was explicit that while each element may be individually described in the specification, the deficiency was lack of adequate description of their combination" and, thus, "[t]he burden was then properly shifted to [inventor] to cite to the examiner where adequate written description could be found or to make an amendment to address the deficiency.""
Also, see MPEP 2163(I) for Lockwood v. Amer. Airlines, Inc., 107 F.3d 1565, 1572, 41 USPQ2d 1961, 1966 (Fed. Cir. 1997).
Representative independent claim 1:
executing a first numerical simulation that simulates a first force on a first seat in a passenger seating arrangement-by simulating first interactions between first physical elements of the first seat caused by the first force for a first non-zero period of time, wherein the first numerical simulation includes a first partial numerical simulation which includes first state data that defines a location, initial velocity, deformation, and stresses associated with the first seat;
executing a second numerical simulation that simulates a second force on a second seat supporting a virtual body and positioned aft of the first seat in the passenger seating arrangement, by simulating second interactions between second physical elements of the second seat and/or the virtual body caused by the second force for a second non- zero period of time, wherein the second numerical simulation includes a second partial numerical simulation which includes second state data that defines a location, initial velocity, deformation, and stresses associated with the second seat;
…
executing a combined numerical simulation based at least in part on the first partial numerical simulation and the second partial numerical simulation, wherein the combined numerical simulation models:
i) the first seat in accordance with the first state data, ii) the second seat and the virtual body in accordance with the second state data;
and iii) a collision of the first seat with the second seat and/or the virtual body by simulating collisions without simulating movements, stresses, and/or deformations of the first seat, the second seat, and/or the virtual body prior to the collision;
This particular combination is not supported (emphasis for features in bold).
See ¶ 38: “Although this approach results in some additional time before impact, compared to other methods, the approach still obviates the need to reprocess most of the movements, stresses, and deformation leading up to impact” – and ¶ 35: “the combined numerical simulation 300a has the technical advantage of being able to simulate the period of time during which the entire seating arrangement must be modeled simultaneously (i.e., impact), but without incurring the processing costs of simultaneously simulating the movements, stresses, and deformation of model elements that are not mechanically linked prior to impact”. See ¶ 34 as well, as detailed on below.
At issue is the breadth of the exclusion, for the exclusionary limitation is “without simulating movements, stresses, and/or deformations of the first seat, the second seat, and/or the virtual body prior to the collision” – however, the specification does not convey such a wide exclusion, but rather merely that the first and second simulations are run until shortly before impact, the state data then obtained for them, and then the combined simulation is run from the time right before impact through the impact, i.e. to simulate the collisions it still requires simulating the “movements, stresses, and/or deformations of the first seat, the second seat, and/or the virtual body prior to the collision” – only this was done in the first and second simulation separately, not in the combined simulation.
To clarify, the specification conveys a simple concept:
Run a first simulation of a first chair in the seating arrangement.
Run a second simulation of a second chair with a virtual body in the seating arrangement.
Halt the simulation when “overlap”, i.e. when they intersect/crash, between the second seat/virtual body and the first seat (e.g. run the two simulations until there is a collision, e.g. the virtual body’s head impacts the seat in front of it [note the “aft”])
Correcting the overlap, by one of two ways:
i) “A common reference frame” (see ¶ 46) = a common coordinate system, e.g. suppose all of the geometry is in the Cartesian Coordinate system (x, y, z). The “translating” is simply moving elements in the simulation (e.g. the head; or per fig. 5 ‘202 ¶ 37, the first seating assembly) to a new position 240’ as compared to 240 (fig. 5). In other words, as visually depicted in figure 5, simply move the seat back a little bit so there is not yet a collision.
ii) “Correcting clipping” = ¶ 46: “If a conflict is identified (act 914), the system may detect whether the partial numerical simulations have been modeled based on a common reference frame, and translate one or both numerical models to compensate If the conflict is identified but the partial numerical simulations have already been assigned correct positions (i.e., non-overlapping positions of any fixed elements,) the system can correct dipping by, e.g., adjusting the common time interval used to capture state data (act 916) and recapture the partial numerical simulation state data based on the adjusted time interval. This process can be performed iteratively” = both simulations were simulated in the same time period (e.g. from 0-5 seconds) so simply adjust this to right prior to the collision (e.g. adjust to 0-4.5 seconds).
Then, do the combined simulation, see ¶ 50: “This combined numerical simulation can be run from an initial condition based on the instantaneous state data to a final condition in which elements in the combined numerical simulation originating from the first numerical simulation have collided with elements of the second numerical simulation. (act 1014)” – i.e. simply start the second simulation at the positioning (and other state data from the first two simulations) from (i) or (ii) as discussed above (the clipping/translating)
Thus, the combined simulation, to simulate the collisions, still requires that the “movements, stresses, and/or deformations of the first seat, the second seat, and/or the virtual body prior to the collision;” were simulated in order to simulate the collision.
Merely, suppose in the event of (ii) with the common time interval example of being adjusted to 0-4.5 seconds from 0-5 seconds, the combined simulation is only running combined from 4.5 seconds to 5 seconds (the impact/collision); wherein the combined simulates starts with the pre-simulated data gathered in the first and second simulations for 0-4.5 seconds.
Or similar for the translating.
Hence: “wherein the combined numerical simulation models: i) the first seat in accordance with the first state data, ii) the second seat and the virtual body in accordance with the second state data;” because its using the results of the prior simulations
At issue, as stated above, is the breadth of this exclusion excludes, in the simulation of the collisions, any simulations of the “movements, stresses, and/or deformations of the first seat, the second seat, and/or the virtual body prior to the collision”, i.e. it’s excluding the first and second simulations that were run to generate this data.
The Examiner suggests amending the claim to use a much more narrowly drafted exclusionary clause, for claims are given their broadest reasonable interpretation, including any exclusionary clause is read as broadly as reasonably permitted for what it expressly recites, with any terms in the clause construed in a manner consistent with specification.E.g. ¶¶ 34-35: “The state data captured from each of the partially complete numerical simulations 200b, 300b, can be combined to generate an initial state of a combined numerical simulation 400a, as shown in FIG. 4A. In one embodiment, the combined numerical simulation 400a can include, e.g., a first seating assembly 202 and a second seating assembly 204 with a seated virtual ATD 206, where each structure has adopted location, initial velocity, deformation, and stresses associated with the simulated acceleration that was applied to each of the first and second numerical simulations 200b, 300b… The combined numerical simulation 400a differs from, e.g., a complete numerical simulation of a total seating arrangement like l 00a (FIG. l) in that the initial configuration of the combined numerical assembly is configured in such a way that running the combined numerical simulation would result in an imminent impact.”
In addition,
Claim 1 recites:
adjusting a time interval of the first state data and the second state data and recapturing the first state data or the second state data based on the time interval that was adjusted;
Claim 11 recites (representative of claim 20):
adjusting a time interval of the first state data or the second state data and recapturing the first state data or the second state data based on the time interval that was adjusted;
This is not sufficiently described. See ¶ 46: “adjusting the common time interval used to capture state data (act 916) and recapture the partial numerical simulation state data based on the adjusted time interval. This process can be performed iteratively.” And ¶ 44: “The system can then extract instantaneous state data from each of the first numerical simulation and second numerical simulation at a common time interval. (act 904)” and ¶ 51: “extract instantaneous state data from each of the first numerical simulation and second numerical simulation at a common time interval”
This does not support the “or” in the above. To clarify, and as detailed on above, POSITA would have readily recognized that the use of “common” in conjunction with the “and” usage in the specification conveyed that both first and second simulations were being run on one common (i.e. the same) time interview), e.g. run both simulations from 0-5 seconds.
The “recapture” and other such recitations in the disclosure convey that the state data is obtained from both simulations, not one “or” the other.
I.e. run both of the simulations from 0-5 seconds, readjust the simulations to be from 0-4.5 seconds (e.g. because the crash was at 5 seconds, or in the time period from 4.5-5), obtain the data from those two first simulations for the second adjusted time period (0-4.5 seconds), then use this as the initial state for the combined simulation so the combined simulation only simulates the time “imminent” (¶ 35) to the impact time.
To clarify, see the above explanation for other grounds of § 112(a).
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, 3-7, 10-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea of both a mathematical concept and mental process without significantly more.
Step 1
Claims 1 and 11 are directed towards the statutory category of a process.
Claim 18 is directed towards the statutory category of an apparatus.
Claims 11 and 18, and the dependents thereof, are rejected under a similar rationale as representative claim 1, and the dependents thereof.
Step 2A – Prong 1
The claims recite an abstract idea of both a mental process and mathematical concept.
See MPEP § 2106.04: “...In other claims, multiple abstract ideas, which may fall in the same or different groupings, or multiple laws of nature may be recited. In these cases, examiners should not parse the claim. For example, in a claim that includes a series of steps that recite mental steps as well as a mathematical calculation, an examiner should identify the claim as reciting both a mental process and a mathematical concept for Step 2A Prong One to make the analysis clear on the record.”
To clarify, see the USPTO 101 training examples, available at https://www.uspto.gov/patents/laws/examination-policy/subject-matter-eligibility.
The abstract idea recited in claim 1 is:
The term “simulating…” is merely a textual placeholder for calculating.
¶ 42: “Any suitable number of permutations of distance between the seating assemblies 202, 204, relative orientations of the seating assemblies, or orientations of the entire seating arrangement ( e.g., tilting, pitch, yaw, roll) can be modeled based on the partial numerical simulations (200b, 300b) or variations thereof without recalculating the partial numerical simulations,”
Thus, the executing of the numerical simulation steps is considered a math concept in textual form.
And these math calculations are simple enough they are readily mentally evaluated such as by pen, paper, and/or a computer.
The limitations taken together are also a mental process, given the simplicity of the math involved. See below for details:
To clarify, but for the recitations of doing this in a generic computer environment, the claimed invention is directed to the abstract idea of simply applying Newton’s Law’s of motion, along with other basic principles of elementary physics commonly taught in introductory physics, to a particular data environment.
To clarify, note that first and second simulations are to calculate a “velocity” and “location”. See ¶ 24: “imparting force or acceleration”, ¶ 25: “after the application of acceleration to the seating assemblies 102, 104”, ¶ 27: “FIG. 2B shows an example of a first partially completed computer numerical simulation 200b resulting from the initial numerical simulation 200a having undergone simulated force or acceleration for a nonzero pe1iod of time.”
Newton’s First Law of Motion: At object at rest remains at rest, and an object in motion remains in constant velocity, unless acted upon by another force.
Newton’s Second Law of Motion: Force = change in momentum per change in time, with momentum equal to the mass times velocity, etc., leading to the scientific truism in mathematical form of F=ma, i.e. force = mass *(change in velocity)/(change in time) = mass * acceleration.
Newton’s Third Law of Motion: For every action (applied force), there is an equation and opposite reaction (equal and opposite force).
So thus, the first two limitations (the first two numerical simulations), when read in view of the specification, require nothing more then the mathematical concept of applying Newton’s Law’s of motion to a particular object of a “seat”/”virtual body” (MPEP § 2106.05(h): “iii. Limiting the use of the formula C = 2 (pi) r to determining the circumference of a wheel as opposed to other circular objects, because this limitation represents a mere token acquiescence to limiting the reach of the claim, Flook, 437 U.S. at 595, 198 USPQ at 199;… vi. Limiting the abstract idea of collecting information, analyzing it, and displaying certain results of the collection and analysis to data related to the electric power grid, because limiting application of the abstract idea to power-grid monitoring is simply an attempt to limit the use of the abstract idea to a particular technological environment, Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354, 119 USPQ2d 1739, 1742 (Fed. Cir. 2016)”), i.e. apply a force/acceleration to an object, and calculate the velocity and position of the object after some period of time after the force was applied.
To clarify, the math required for this is trivial and known to all engineers and scientists, for collegiate level introductory calculus and physics courses routinely teach this concept and have long taught it, e.g. integrate acceleration over time to get velocity, etc.
In other words, the math is simple enough to achieve the desired results with the desired inputs for the math to be mentally evaluated.
The third limitation of the “halting…” is merely the principle itself of Newton’s first and third law, i.e. when the two objects (seats) have their positions in such a manner that they “overlap” [i.e. collide/intersect each other], i.e. at this time instant the two objects have new forces acting on them by the collision, and thus one must determine when the new applied forces are on both objects to determine what happens after the collision.
The fourth limitation is a trivial part of the mental math, i.e. one can easily calculate out the velocities and positions (both over time) of the objects with applied forces, and from that determine when and where they will collide, and know that at the time period of the collision once must account for the transfer of momentum/energy (via the laws of conservation of momentum/conservation of energy). To clarify, ¶ 35: “a complete numerical simulation of a total seating arrangement like l 00a (FIG. l) in that the initial configuration of the combined numerical assembly is configured in such a way that running the combined numerical simulation would result in an imminent impact.”
Thus, once someone determines by mental evaluation of the simple math calculations when and where the collision will be, one can also know at what time was the collision “imminent” but has not yet occurs. Limitation (ii) in this step (¶ 46), i.e. before one starts the process of working out how energy/momentum transferred in the collision, one first mentally evaluates the math calculations to obtain the forces/velocities/accelerations/momentums and the like in the moment right before the collision, and to do so one simple adjusts the time period of the first two calculations so as to be right before the collision.
Or another option – simply do the “translating”, i.e. once you know when and where the collision is, one can simply move (e.g. mentally, or with a drawing – see ¶ 37 and fig. 5 for # 240 and # 240’) the objects slightly so they are not colliding yet, but they are about to be.
The fifth limitation of the combined numerical simulation is nothing more then the continuation of the above, i.e. this is where one calculates the transfers of momentum/energy during the collision.
One can readily do this mentally using simple geometry, e.g. a free body diagram, or for more complex geometry simply use a computer as a tool to automate it to do it quickly.
Furthermore, such a mental process is one long done by students in such collegiate introductory physics and calculus classes, e.g. calculating the variables noted about for collisions between cars, between billiard balls, between two trains, etc.
To clarify on this analogy, an oft-quoted adage found in Phillips v. AWH Corp., 415 F.3d 1303, 75 U.S.P.Q.2d 1321 (Fed. Cir. 2005) (MPEP § 2111.01(I and III)) is helpful: “Eloquent words can mask much mischief. The court's opinion today is akin to [*1335] rearranging the deck
chairs on the Titanic — the orchestra is playing as if nothing is amiss, but the ship is still heading for Davey Jones' locker”
This claim merely recites terms such as “numerical simulation”, “state data”, etc. to invoke the idea of doing a simple application of Newtonian physics for kinematics in a computerized environment, but this claim recites no particular manner in how to actually perform the simulations in a technological manner (i.e. how a computer is to get the desired results in a particular manner), but for it being “computer-implemented”.
As to further specifying that stresses and deformations are to be determined, this is merely adding two more variables to have their values calculated, with no particular instructions on how to do this recited in the claim, i.e. part of the mental process. There is no technological means recited on how the stresses or deformations are to be calculated.
Should a reminder of what Newton’s Law’s of Motion are, see:
NASA’s Glenn Research Center, “Newton’s Law’s of Motion” Article: www(dot)grc(dot)nasa(dot)gov/beginners-guide-to-aeronautics/newtons-laws-of-motion/, accessed 2026.
To further clarify, such subject matter is readily found in introductory physics courses taught to all engineers and many others, akin to the idea of hedging in Bilski. See:
Brown, Robert. Introductory Physics I, Elementary Mechanics. 2013. URL: webhome(dot)phy(dot)duke(dot)edu/~rgb/Class/intro_physics_1/intro_physics_1(dot)pdf - see section 4.5 on “Collisions”, and its subsections.
See fig. 54, then see the equations that follow
PNG
media_image1.png
519
969
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Greyscale
PNG
media_image2.png
330
870
media_image2.png
Greyscale
Followed by the accompanying description of the above (§ 4.6), including: “The big question now is: Assuming we know m1,m2, v1i and v2i, can we find v1f and v2f , even though we have not specified any of the details of the interaction between the two masses during the collision?... In one dimension, however, we have two independent equations and two unknowns, and it turns out that these two conditions alone suffice to determine the final velocities. To get this solution, we must solve the two conservation equations above simultaneously. There are three ways to proceed....”
See § 4.6.1, includes its simple algebraic equations readily evaluated mentally or with physical aids such as pen, paper, and/or a calculator.
See §§ 4.6.2 as well for two other simple methods to do this in 1D.
See § 4.7 for such collisions in 2D to 3D
See Homework Problem # 8 (page 269)
Schnick, Jeffrey. Calculus-Based Physics I. 2008. URL: web(dot)cocc(dot)edu/bemerson/pageresources/GlobalResources/CCTextCalculus/SA/StAPhysics1st(dot)pdf
See Example 4-1 (page 23), note the “Before” is before the collision and is the mass, velocity, and positions of the two objects prior to a collision, and the “After”, with the set of simple equations to get the “final velocity of each of the objects”
Then, go to page 57, last paragraph: “Next, let’s consider a 2-D Collision Type II problem. Solving a typical 2-D Collision Type II problem involves finding the trajectory of one of the particles, finding when the other particle crosses that trajectory, and establishing where the first particle is when the second particle crosses that trajectory. If the first particle is at the point on its own trajectory where the second particle crosses that trajectory then there is a collision. In the case of objects rather than particles, one often has to do some further reasoning to solve a 2-D Collision Type II problem. Such reasoning is illustrated in the following example involving a rocket.” – so see Example 10-2.
See page 184, last paragraph: “As you should recall from Chapter 4, the concept is referred to as conservation of momentum for the special case in which there is no net transfer of momentum to the system from the surroundings, and you apply it in the case of some physical process such as a collision, by picking a before instant and an after instant, drawing a sketch of the situation at each instant, and writing the fact that, the momentum in the before picture has to be equal to the momentum in the after picture, in equation form: p = …”
To give another example of this abstract idea:
Mazur, “Principles & Practice of Physics”, Chapter 5: “Energy” and Chapter 8: “Force”, Lecture Notes for Physics 105 at University of Alabama, Fall 2015. URL: pleclair(dot)ua(dot)edu/ph105/Slides/Fall15/ - see chapter 5, example 5.2 for an example of “Carts olliding” including slide 5-31 and 5-33, also example 5.3 starting incl. 5-44-5-50; and see the summary of section 5.5-5.6 on slides 5-73 to 5-86, then see section 8.7, in particular its discussion of Newton’s Laws of Motion on 8-116 to 8-124, then see section 8.12 in particular slides 8-166 and 8-172.
To clarify, what is claimed is merely the application of introductory physics of collision by following Newton’s laws of motion and other basic principles of physics, i.e. a many interacting object system (note the seats and virtual body have “physical elements”, i.e. several objects), wherein an initial series of calculations are performed to determine the velocity and location of each physical element due to acceleration (Newton’s Law’s of motion) before they are interacting (colliding/overlapping) separately (see Newton’s first law of motion), followed by a combined calculation for when they start interacting to account for the transfers of energy/momentum (conservation of energy/momentum), so as to find the final velocities/accelerations/positions (and the like) during and after the collision.
And to further clarify, the thrust of this claimed advance lies at the “halting…” limitation, in combination with the following limitation to change the time interval/move (translate) the results in a coordinate system (reference frame)). This is nothing more then a result of the principles of Newton’s laws, i.e. apply a force (e.g. in the form of an acceleration, F= ma), and for the time before the two objects interact both objects can have their resulting velocities, positions, etc. calculated independently because they are non-interacting (i.e. the forces acting upon each object are in isolation from each other, i.e. Newton’s first law), but then, at the time period of the collision itself they forces then interact (Newton’s third law), so thus the calculations must be combined for this time period of the collision (as they are now interacting).
In other words, the apple that fell on Newton’s head only had the force of gravity acting on it as it fell, and thus in that time period the position and velocity could be calculated in isolation with F=-mg (g = 9.8 m/s or so). But when it hit his head, one had to halt such an isolated calculation, because his head interacted with the apple and imposed a new equal and opposite force on the apple as reaction to the collision, so thus one conserves momentum/energy at this point for the interacting combined calculations.
Note that physical aids such as pen and paper (e.g. to draw free body diagrams) would be useful in this mental process, as would a calculator.
Under the broadest reasonable interpretation, the claim recites a mathematical concept – the above limitations are steps in a mathematical concept such as mathematical relationships, mathematical formulas or equations, and mathematical calculations. If a claim, under its broadest reasonable interpretation, is directed towards a mathematical concept, then it falls within the Mathematical Concepts grouping of abstract ideas. In addition, as per MPEP § 2106.04(a)(2): “It is important to note that a mathematical concept need not be expressed in mathematical symbols, because "[w]ords used in a claim operating on data to solve a problem can serve the same purpose as a formula." In re Grams, 888 F.2d 835, 837 and n.1, 12 USPQ2d 1824, 1826 and n.1 (Fed. Cir. 1989). See, e.g., SAP America, Inc. v. InvestPic, LLC, 898 F.3d 1161, 1163, 127 USPQ2d 1597, 1599 (Fed. Cir. 2018)”
See MPEP § 2106.04(a)(2).
To clarify, see the USPTO 101 training examples, available at https://www.uspto.gov/patents/laws/examination-policy/subject-matter-eligibility.
Under the broadest reasonable interpretation, these limitations are process steps that cover mental processes including an observation, evaluation, judgment or opinion that could be performed in the human mind or with the aid of physical aids but for the recitation of a generic computer component. If a claim, under its broadest reasonable interpretation, covers a mental process but for the recitation of generic computer components, then it falls within the "Mental Process" grouping of abstract ideas. A person would readily be able to perform this process either mentally or with the assistance of physical aids. See MPEP § 2106.04(a)(2).
To clarify, see the USPTO 101 training examples, available at https://www.uspto.gov/patents/laws/examination-policy/subject-matter-eligibility. In particular, with respect to the physical aids, see example # 45, analysis of claim 1 under step 2A prong 1, including: “Note that even if most humans would use a physical aid (e.g., pen and paper, a slide rule, or a calculator) to help them complete the recited calculation, the use of such physical aid does not negate the mental nature of this limitation.”; also see example # 49, analysis of claim 1, under step 2A prong 1: “Moreover, the recited mathematical calculation is simple enough that it can be practically performed in the human mind. Even if most humans would use a physical aid, like a pen and paper or a calculator, to make such calculations, the use of a physical aid would not negate the mental nature of this limitation.”
As such, the claims recite an abstract idea of both a mental process and mathematical concept.
Step 2A, prong 2
The claimed invention does not recite any additional elements that integrate the judicial exception into a practical application. Refer to MPEP §2106.04(d).
The following limitations are merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f), including the “Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more”:
Preamble of claims 1 and 18 recite a generic computer and generic computer components used as tools to automate the abstract idea. See ¶ 6 to clarify on this being generic, along with ¶ 43
Claim 11 does not require a computer. See MPEP § 2111 for In re Prater, and see claim 1, i.e. claim 11 is a claim to the mental process itself, without any instructions to automate it with a computer.
The following limitations are generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h):
Should the data environment of the seating arrangements not be considered abstract, then these would merely be considered as generally linking to a particular field of use (MPEP § 2106.05(h) for EPG and Parker v. Flook). To clarify, this abstract idea is readily applicable to other fields of use, e.g. the game of billiards.
Should the recitations of “numerical simulation” be considered as not part of the abstract idea, then the Examiner notes that these would simply be mere instructions to do it on a computer as well as an insignificant computer implementation (MPEP § 2106.05(g)), i.e. to perform modeling such as of Newton’s Laws of Motion as applied to the field of use, but use a computer with generic commonplace software to do it (¶ 2: “For that reason, extensive preliminary testing is performed in a virtual space using computer numerical simulation (e.g., finite-element analysis or the like”; ¶ 24: “Computer numerical simulations of this type (e.g., finite-element models, or the like) can be used to model the behavior of a variety of structures and materials”) – in particular, note the generic nature of how such simulations are described, i.e. this claim is not directed to the technology of how the simulations are performed on a computer, but rather simply to a simple application of Newtonian physics with Newton’s laws of motion and the like.
The recitations of capturing and recapturing state data are considered as both part of the mere data gathering and the mere instructions to do it on the computer, as well as an insignificant computer implementation. Should it be found that the stresses and deformations are not part of the abstract idea, then the Examiner submits that these would be merely part of the mere data gathering by selecting what data is to be gathered.
The feature of the correcting clipping, should it not be found to be abstract, would be merely data gathering and activities involved in the mere data gathering.
Should it be found that the “translating…” feature and the “conflict…” determination is not part of the abstract idea, then this would be considered as insignificant extra-solution activities that are nominal/tangential to the primary process of the claimed invention.
A claim that integrates a judicial exception into a practical application will apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception. See MPEP § 2106.04(d).
MPEP 2106.04(II)(A)(2) “…Instead, under Prong Two, a claim that recites a judicial exception is not directed to that judicial exception, if the claim as a whole integrates the recited judicial exception into a practical application of that exception. Prong Two thus distinguishes claims that are "directed to" the recited judicial exception from claims that are not "directed to" the recited judicial exception…Because a judicial exception is not eligible subject matter, Bilski, 561 U.S. at 601, 95 USPQ2d at 1005-06 (quoting Chakrabarty, 447 U.S. at 309, 206 USPQ at 197 (1980)), if there are no additional claim elements besides the judicial exception, or if the additional claim elements merely recite another judicial exception, that is insufficient to integrate the judicial exception into a practical application. See, e.g., RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. Ltd. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself."). For a claim reciting a judicial exception to be eligible, the additional elements (if any) in the claim must "transform the nature of the claim" into a patent-eligible application of the judicial exception, Alice Corp., 573 U.S. at 217, 110 USPQ2d at 1981, either at Prong Two or in Step 2B” and MPEP § 2106(I): “Mayo, 566 U.S. at 80, 84, 101 USPQ2dat 1969, 1971 (noting that the Court in Diamond v. Diehr found “the overall process patent eligible because of the way the additional steps of the process integrated the equation into the process as a whole,”” – and see MPEP § 2106.05(e).
To further clarify, MPEP § 2106.04(II)(A)(1): “Alice Corp., 573 U.S. at 216, 110 USPQ2d at 1980 (citing Mayo, 566 US at 71, 101 USPQ2d at 1965). Yet, the Court has explained that ‘‘[a]t some level, all inventions embody, use, reflect, rest upon, or apply laws of nature, natural phenomena, or abstract ideas,’’ and has cautioned ‘‘to tread carefully in construing this exclusionary principle lest it swallow all of patent law” See also Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 1335, 118 USPQ2d 1684, 1688 (Fed. Cir. 2016) ("The ‘directed to’ inquiry, therefore, cannot simply ask whether the claims involve a patent-ineligible concept, because essentially every routinely patent-eligible claim involving physical products and actions involves a law of nature and/or natural phenomenon").”
As a point of clarity, RecogniCorp, LLC v. Nintendo Co., 855 F.3d 1322, 1327, 122 USPQ2d 1377 (Fed. Cir. 2017) ("Adding one abstract idea (math) to another abstract idea (encoding and decoding) does not render the claim non-abstract"); Genetic Techs. Ltd. v. Merial LLC, 818 F.3d 1369, 1376, 118 USPQ2d 1541, 1546 (Fed. Cir. 2016) (eligibility "cannot be furnished by the unpatentable law of nature (or natural phenomenon or abstract idea) itself." discussed in MPEP § 2106.04(II)(A)(2) as well as MPEP § 2106.04(I): “Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151, 120 USPQ2d 1473, 1483 (Fed. Cir. 2016) ("a new abstract idea is still an abstract idea") (emphasis in original).
The claimed invention does not recite any additional elements that integrate the judicial exception into a practical application. Refer to MPEP §2106.04(d).
Step 2B
The claimed invention does not recite any additional elements/limitations that amount to significantly more.
The following limitations are merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f), including the “Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more”:
Preamble of claims 1 and 18 recite a generic computer and generic computer components used as tools to automate the abstract idea. See ¶ 6 to clarify on this being generic, along with ¶ 43
Claim 11 does not require a computer. See MPEP § 2111 for In re Prater, and see claim 1, i.e. claim 11 is a claim to the mental process itself, without any instructions to automate it with a computer.
The following limitations are generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h):
Should the data environment of the seating arrangements not be considered abstract, then these would merely be considered as generally linking to a particular field of use (MPEP § 2106.05(h) for EPG and Parker v. Flook). To clarify, this abstract idea is readily applicable to other fields of use, e.g. the game of billiards.
Should the recitations of “numerical simulation” be considered as not part of the abstract idea, then the Examiner notes that these would simply be mere instructions to do it on a computer as well as an insignificant computer implementation (MPEP § 2106.05(g)), i.e. to perform modeling such as of Newton’s Laws of Motion as applied to the field of use, but use a computer with generic commonplace software to do it (¶ 2: “For that reason, extensive preliminary testing is performed in a virtual space using computer numerical simulation (e.g., finite-element analysis or the like”; ¶ 24: “Computer numerical simulations of this type (e.g., finite-element models, or the like) can be used to model the behavior of a variety of structures and materials”) – in particular, note the generic nature of how such simulations are described, i.e. this claim is not directed to the technology of how the simulations are performed on a computer, but rather simply to a simple application of Newtonian physics with Newton’s laws of motion and the like.
The recitations of capturing and recapturing state data are considered as both part of the mere data gathering and the mere instructions to do it on the computer, as well as an insignificant computer implementation. Should it be found that the stresses and deformations are not part of the abstract idea, then the Examiner submits that these would be merely part of the mere data gathering by selecting what data is to be gathered. Also WURC in view of MPEP § 2106.05(d)(II) as well as the below evidence.
The feature of the correcting clipping, should it not be found to be abstract, would be merely data gathering and activities involved in the mere data gathering.
Should it be found that the “translating…” feature and the “conflict…” determination is not part of the abstract idea, then this would be considered as insignificant extra-solution activities that are nominal/tangential to the primary process of the claimed invention.
In addition, the additional elements in ordered combination (including with the use of the abstract idea of combining two simulations) are considered WURC in view of the below.
Costa Cadilha, Maria Inês. Numerical Simulation of Aircraft Ditching of a Generic Transport Aircraft: Contribution to Accuracy and Effciency. Diss. Instituto Superior Técnico, 2014. Pages 40-41 (starting at the last paragraph on page 40): “Distributed memory processing becomes even more useful when looking into the multi-domain approach. This multi-domain approach is commonly known as Multi Model Coupling (MMC). The basic idea behind this concept is that the simulation domain can be divided into sub-domains based on a difference in maximum stable time steps of the sub-models. In the context of ditching simulations the division could be between, for example, the water and the aircraft model…. The objective of MMC is that each sub-domain is allowed to advance at its own (different) time step, and synchronization points establish the communication (i.e. contact) between both [the claimed recitation of independently running the simulations for periods of time]. With this, fi local meshes can be defined without significantly increasing the calculation time for the whole model. A scheme is presented in Figure 4.20.” – then see page 41, last paragraph, in its description of using this option in “VPS solver”: “When the Multi Model Coupling option is used, it is necessary for the output parameters, time step control and code version to be defined for each one of the sub-models… It is important to refer that for the Multi Model Coupling file structure, the sub-models are completely independent from each other. This means any of the sub-models can be opened and used separately if the user wishes so.” – to clarify, VPS solver is a commercially available simulation software - § 1.2 ¶ 1: “Within this research, the hybrid FE-SPH module of the VPS explicit solver (formerly known as PAM-CRASH), from ESI-Group, was extended by various features for improvement of water modeling and reproduction of FSI phenomena”
ESI Group, Article: “Multi-Model Coupling for PAM-CRASH: a New Way for Crash Simulation”, PAM Talk 2006, Issue 31, Spring 2006, URL: www(dot)esi-group(dot)com/sites/default/files/resource/other/1687/pam_talk_31_spring(dot)pdf – see pages 4-5, including ¶¶ 1-5: “Multi-Model Coupling is a new way for crash simulation, considered very promising for extensions toward multi-program and multi-physics applications. The implementation of the concept was the result of a fruitful partnership between ESI Group and Volkswagen Group research teams. The main idea of the Multi-Model Coupling is to have two distinct standard PAM-CRASH models which will interact in order to compute a solution for the total structure consisting of the union of the two models. The multiple benefits from this coupling process are the following: The user can define a first model with a relatively coarse mesh, often called the “global” model, which corresponds to the bulk of the structure. A second model can be made with a fine or very fine mesh called the “local” model which represents only the small, significant part(s) of the initial total structure for which a detailed, deep analysis will be done (e.g. fracture prediction). These two different models can “collaborate”, i.e. interact to give an accurate result with an efficient usage of computation resources. The end result is a combination of two distinct simulations functioning together. Each model has its own time step. Time step is a crucial parameter of the simulation time, and therefore significantly influences the overall performance. An integrated algorithm allows the use of a different time step for each model. Thus the “global” model, consisting of many coarse elements, can use a larger time step, while the “local” model uses a smaller time step to ensure its stability. This scheme, called “sub-cycling”, allows the simulation to run more efficiently as the “global” model is computed with the larger time step, avoiding the use of the smallest common time step as would be imposed if the whole model were computed in a unique PAM-CRASH run. This optimization dramatically reduces total clock elapsed time” ; also see col. 2 on page 5; and page 6, incl.: “From the practical point of view the user runs the coupled application using n1 processes for the first model and n2 for the second model. After an initialization phase the solution procedure runs, and necessary data exchanges for code coupling are performed [the capturing limitations such as in claim 1]…” – also, see pages 13-15, including the visual depiction of the virtual “Dummy model library” [example of the virtual body] for use in such crash simulations, as discussed in ESI: “…ESI Group offers a library of dummy models that covers the current safety standards as well as the most important up to date research tools. These models are built by using state-of- the-art Finite Element or Multi-Body modeling techniques…”
Janssen et al., “FE Coupling Workshop”, 2007, 6th European Madymo Users Meeting, Berlin, URL: ftp(dot)lstc(dot)com/anonymous/outgoing/support/PRESENTATIONS/Madymo_Coupling_Presentation(dot)pdf
Janssen is an overview of “coupling between MADYMO and FE Codes” (slide 4) – wherein MADYMO is a commonly used software for crash test dummies in seats in vehicles (slides 5-8) wherein “FE crash codes are typically used for structural design” and “MADYMO is specialized in restraint design & optimization” and “TASS aims to offer its customers the best of both worlds by harmonizing MADYMO with FE crash codes through a plug & play coupling solution” wherein TASS has coupling functionality between MADYMO and multiple other types of simulation (slide 12).
For more technical details on what is required on how to couple such simulations, see TASS, “Madymo”, “Coupling Manual”, Version 7.4.1, 2012, § 1, including §§ 1.1.1 – 1.1.3. Also, see § 5 which discusses coupling with “LS-DYNA”. Include seeing § 1.1.1: “A coupling to another software product provides the opportunity for the user to combine, in a single simulation, the features from both products”; § 1.1.2: “The coupling between two software products is done through a coupling interface. The information to be send from one software product to the other is first gathered internally. This information is then send to the PARTNER through the coupling interface routines. The PARTNER distributes the data, performs calculations and subsequently gathers data and sends is back through the interface. This process is illustrated in Fig. 1.1… The coupling between two software products is done through the coupling library MADCL. The information to be send from one software product to the other is not gathered and distributed but instead all MPP processes on MADYMO side can communicate directly to all MPP processes on the PARTNER side… The Direct coupling and the MPP coupling differ in what type of data is communicated between MADYMO and the PARTNER… MB object data is communicated; at each time integration point, displacements are sent from MADYMO to the PARTNER code, which in turn sends forces acting upon these objects back to MADYMO. This is called Basic Coupling. In basic coupling, the PARTNER program builds a copy of the MB object natively in MADYMO. This copy allows the PARTNER program to put forces acting on the MB object, and to display it in its kinematic output file… FE data is communicated; at each time integration point, nodal displacements are sent from the PARTNER program to MADYMO, which in turn sends forces acting on these nodes back to the PARTNER program. This is called the Extended Coupling. In extended coupling, MADYMO builds a copy of (part of) the FE model it receives from the PARTNER program. Now MADYMO can put forces on the nodes, and display the FE model in the kinematic output file (KIN3 file)…All coupling types synchronize their time step, so the minimum of the PARTNER and MADYMO time step is taken…” – and see fig. 1.1-1.2
For another example, see Schauer, Dale, et al. Preliminary Vehicle Impact Simulation Technology Advancement (Pre-VISTA). No. FHWA-RD-96-059. United States. Department of Transportation. Federal Highway Administration, 1997. See section 1 starting on page 5, include seeing page 6, # 1-3 which discuss various WURC coupling techniques for simulations of a vehicle (fig. 1, top) and a seat with a passenger or crash test dummy (fig. 2, bottom). See pages 8-24 for additional details. Also see pages 39-40.
Greve, Lars, and Stefanos Vlachoutsis. "Multi-scale and multi-model methods for efficient crash simulation." International journal of crashworthiness 12.4 (2007): 437-448. See page 438, including: “The subcycling technique is used in this paper to overcome the mesh refinement limitations mentioned above. The technique is based on the idea that the whole FE model is divided into two different partitions of different time steps, subsequently called the global and the local model. The local model uses a refined FE mesh size with a small time step, whereas the global model uses a standard mesh size and an integer multiple of the local model's time step. The principle of subcycling was first demonstrated by Belytschko and Mullen [2] in 1976, using a combined explicit-implicit time integration method. Explicit-explicit methods were introduced in 1979 by Belytschko, Yen and Mullen [3], and more sophisticated approaches have been developed in which non-integer time step ratios can be utilized, for example [4].” In col. 1, then see col. 2: Following the classical subcycling technique the finite elements were put into different groups according to the element time steps. The stability of the subcycling technique has been frequently demonstrated for rather simple structures subjected to transient loading, [4-7], and the classical method also found its way into commercial crash codes such as PAM-CRASH and LS-DYNA [8, 9]. In those days (2000), the commercial crash code structures were based on Shared Memory Processing (SMP). During the next phase of crash code evolution the code infrastructure was redesigned for the DMP standard, using Message Passing Interfacing (MPI) for more (cost-) efficient parallel computation. However, additional MPI traffic caused by the classical subcycling technique was believed to reduce the efficiency of the DMP computation mode. Hence, the classical subcycling option has been removed in newer versions of PAM-CRASH. In this paper the idea of subcycling is revived…” – and see page 439, including the last paragraph in col. 1.
Also, see Slaats, Paul MA, et al. "Tools for occupant protection analysis." SAE transactions (2001): 263-267. Introduction: “In the crash safety community of the automotive industry, it is common practice to combine structural vehicle models with occupant models that are based on multi- body techniques. Mathematical occupant models have been developed for frontal, side, and rear impact, based on the Finite Element (F.E.) method as well as multi- body techniques [1]. In particular, the multi-body based occupant models (some may also be partly F.E.) are available in well-validated dummy databases for most occupant types, like the 5th female, 50th, and 95th male percentile Hybrid III dummy types as well as various child types, like three year old and six year old models…”
With respect to having a single simulation for both the seat and the virtual body, and then simulating using a second simulation the remainder of the vehicle interior including other seats, see:
Di Napoli, F., et al. "Mixed FE–MB methodology for the evaluation of passive safety performances of aeronautical seats." International journal of crashworthiness 24.3 (2019): 314-325. Page 315, col. 1-2, incl: “Whilst in the MB approach the dummy is modelled by rigid bodies, defined by both mass and moments of inertia (connected by suitable characteristics joints), in the rE approach the dummy is modelled by means of FEs containing more details than the former, which lead to several difficulties in terms of model management and computational costs. As well as the dummy, the seat can be modelled either by choosing the MB approach (simplified model), or the FE one (detailed model) (11]. The restraint modelling systems are of comparable complexity for the two approaches, as in both cases the belts can be modelled by means of one- or two-dimensional element types…In fact, this type of modelling is widely used for preliminary Simulations…Commercial solvers based on the MB methodology, such as the TNO-Madymo one, actually provide the possibility of adopting a hybrid modelling approach, MB- FE [13], allowing improving the modelling where needed as well as lowering the computational time…To also overcome this last approximation of the hybrid approach, a more accurate model, based on the use of 'coupling' technique, can be adopted. 'Coupled' simulations are those where the two solvers (FE and MB) work simultaneously by exchanging information each other [ 1 Sl, within an iterative process…The coupling simulations are more versatile than the full-FE ones and leave the user the possibility to choose which structure or subcomponent has to be analysed in detail.”
Lankarani, H. M., G. Olivares, and H. Nagarajan. "A Virtual Multibody and Finite Element Analysis Environment in the Field of Aerospace Crashworthiness." Virtual Nonlinear Multibody Systems. Dordrecht: Springer Netherlands, 2003. 187-212 – see § 3 and then see §§ 5-5.2.
Should further clarification be sought on the WURC nature of performing crash simulations for aircraft, a brief history is readily available at:
Jackson, “A History of Full-Scale Aircraft and Rotorcraft Crash Testing and Simulation at NASA Langley Research Center”, 2004, section “CRASH MODELING AND SIMULATION” starting on page 17
Should further evidence be required for the WURC consideration, also see: Vadlamudi, S., M. Blundell, and Y. Zhang. "A multi-body systems approach to simulate helicopter occupant protection systems." International journal of crashworthiness 16.2 (2011): 207-218. See § 1, including page 209, ¶ 1, then see page 212 col. 1 including ¶¶ 1-3 and §§ 3-5 wherein this is using the commercial software “Madymo” configured in a certain manner.
Additional WURC evidence includes:
Ambrósio, Jorge. "Crash analysis and dynamical behaviour of light road and rail vehicles." Vehicle System Dynamics 43.6-7 (2005): 385-411. Abstract: “Through applications to the crashworthiness of road and of rail vehicles, selected problems are discussed and the need for coupled models of vehicle structures, suspension subsystems and occupants is emphasized.” And § 1 including: “Though the most common numerical tools used to address both areas of vehicle dynamics are based on multibody methodologies, traditionally these two aspects of vehicle design have been addressed separately or with little interaction…Furthermore, in applications for which the structural patterns of deformation are not known beforehand or for which subcomponent finite element models are available, the multibody dynamics methods enable the effective coupling between the lumped parameter models and the finite element description of the structural deformations.”
Carvalho, M., J. Ambrosio, and J. Milho. "Implications of the inline seating layout on the protection of occupants of railway coach interiors." International Journal of Crashworthiness 16.5 (2011): 557-568. Abstract and § 1 incl.: “The numerical model of this layout is developed using MADYMO[42], which includes a multibody description for the dummies and a finite element approach for the seats and structural features of the vehicle interior”
Hoffmann, Rainer, et al. "Finite element analysis of occupant restraint system interaction with PAM-CRASH." SAE transactions (1990): 1901-1912. Abstract: “A new approach in numerical occupant simulation using the dynamic coupling of the nonlinear explicit finite element code PAM-CRASH and the crash victim simulation program MADYMO has been validated and is presented. The new technique combines the advantages of the finite element method for the solution of dynamic problems with large structural deformations with the merits of validated occupant models. It uses the full capabilities of both industrial programs PAM-CRASH and MADYMO, and is therefore well suited for an industrial environment. A description of the coupling method will be given in this paper…” and see pages 1901-1903; then in particular see fig. 4 and pages 1904-1905 incl.: “…The coupling of both programs is realized using the PAM-CRASH contact algorithms. These algorithms permit to detect and evaluate the contact of any MADYMO ellipsoids or hyper-ellipsoids with any PAM-CRASH finite element structure…”
Prabhune, Prajakta, Anindya Deb, and G. Balasubramani. "Simulation Methodology for Occupant Safety Assessment of Indian Railway Passenger Coach." ASME/IEEE Joint Rail Conference. Vol. 50978. American Society of Mechanical Engineers, 2018. Abstract, then see page 4
Prasad, Priya, and Clifford C. Chou. "A review of mathematical occupant simulation models." Accidental Injury: Biomechanics and Prevention (1993): 121-186. Page 121, including ¶ 1 and the last paragraph for its discussion of coupling, incl.: “Recent developments in finite element analysis and coupling of finite element analysis codes with rigid body dynamics codes have open a new era in occupant dynamics simulation.” - then see its description of MADYMO 1999 edition on page 127, col. 2: “Capabilities for coupling with external programs such as Matlab and Radioss” – and see page 135, col. 1, # 1 for “Coupling with FEM packages: An interface has been developed coupling the MADYM03D and the PISCES (Physics International Scientific Codes and Engineering Services) finite element structures/gas flow program. The combined program is useful for simulating interactions between a 3D MADYMO rigid body dummy and an FE airbag. Details of this development are discussed below. The MADYM03D has also been coupled with PAM-Crash, Dyna3D, Radioss, and MSClDytran (MSC (MacNeal-Schwendler Corp) now call MSCsoftware) finite element codes.” – also, section the section “Coupling with CVS” starting on page 150, including ¶ 1 and fig. 7.35 on page 153. Also see pages 159-160
Shukla, Neeraj. "Analysis of the Articulated Total Body (ATB) and Mathematical Dynamics Model (MADYMO) Software Suites for Modeling Anthropomorphic Test Devices (ATDs) in Blast Environments." Army Research Laboratory ARLTR-6458 (2013). § 2 incl.: “MADYMO is a software suite developed and managed by TNO Automotive Safety Solutions (TASS), which is headquartered in the Netherlands. MADYMO comes with full software support and training by TASS in North America, who continues to produce new updates with enhanced features for ATD and human models. MADYMO is used by most major automobile manufacturers, accident reconstruction organizations, and defense organizations and contractors including the U.S. Army Tank Automotive Research, Development and Engineering Center (TARDEC), U.S. Navy Naval Air Systems Command (NAVAIR), General Dynamics Land Systems (GDLS), the Norwegian Defense Research Establishment (FFI), the Council for Scientific and Industrial Research (CSIR), and ARL.” Then § 3 incl.: “ATB models are composed of only rigid-body components while MADYMO models can include rigid-body components as well as FE analysis… This feature appears to be poorly supported and was not exercised in this evaluation. MADYMO, on the other hand, is very capable of interacting with other models including complete step-by-step coupling with LS-DYNA for FE analysis, decoupled interaction with an external model via prescribed structural motion of a FE mesh, coupling with MATLAB for complex switching and control logic, as well as the capability of outputting D3PLOT files for use in external applications such as LS-PrePost” and § 3.1 incl.: “The MADYMO software suite includes …Coupling Assistant, used to couple the MADYMO model with FE codes such as a coupling a MADYMO H3 model to a LS-DYNA FE code” – then see § 8 for more details.
Tyan, Tau, et al. "Modeling of an advanced steering wheel and column assembly for frontal and side impact simulations." SAE International Journal of Materials and Manufacturing 7.2 (2014): 366-401. Abstract ¶ 2 and page 372, col. 2, ¶ 1
Slaats, Paul MA, et al. "Tools for occupant protection analysis." SAE transactions (2001): 263-267. Introduction ¶ 1 – then see the section “Coupling Model” on page 264.
Vadlamudi, S., M. Blundell, and Y. Zhang. "A multi-body systems approach to simulate helicopter occupant protection systems." International journal of crashworthiness 16.2 (2011): 207-218. § 1 ¶ 2 then see §§ 3-4
Musale et al., US 2007/0143087 - ¶¶ 28-32
With respect to the limitations for the conflict determination, and substeps (i or ii), these are WURC steps of conflict detection and resolution. See:
To clarify, with respect to the correction of clipping during such overlap, see:
Frisken-Gibson, Sarah F. "Using linked volumes to model object collisions, deformation, cutting, carving, and joining." IEEE transactions on visualization and computer graphics 5.4 (1999): 333-348. § 3.3, ¶ 2: “When the goal is to prevent object interpenetration, a standard back-tracking algorithm is used to find the point of collision. In back-tracking, objects are moved in relatively large steps toward a desired position. Step sizes are relatively large to ensure interactivity in the simulation, but small enough to prevent objects from appearing to leap through each other. If object penetration is detected for a proposed new object position, the object is not moved to that position. Instead, the step size of the moving object is reduced. If a penetration is detected using this new step size, the step size is again reduced. Otherwise, the step size is increased slightly and the new position is investigated. This process is repeated until the maximum allowable step toward the desired position is determined”
Egan, Kevin. "Techniques for real-time rigid body simulation." Department of Computer Science, Brown University (2003). § 2.4.3 on page 6.
Hahn, James K. "Realistic animation of rigid bodies." ACM Siggraph computer graphics 22.4 (1988): 299-308. § 5.3 ¶ 2
Bridson, Robert, Ronald Fedkiw, and John Anderson. "Robust treatment of collisions, contact and friction. § 7.4 ¶ 2.
Bouma, William J. and Vanĕček, George, "Collision Detection and Analysis in a Physically Based Simulation" (1991). Department of Computer Science Technical Reports. Paper 895. Page 2, ¶¶ 2-3
Chang, Jian, Jian J. Zhang, and Rehan Zia. "Modelling deformations in car crash animation." The Visual Computer 25.12 (2009): 1063-1072. Page 1067, last paragraph, # 4.
Fukuzawa, Yukio. "Particle Simulation in 3D." (2013). Page 2, ¶¶ 2-4
Laerhoven, Tom Van, Chris Raymaekers, and Frank Van Reeth. "Generalized object interactions in a component based simulation environment." WSCG. 2003. Page 5, col. 1, ¶ 4 for the “rewinding”
Tang, Bing, et al. "Interactive generation of falling motions." Computer Animation and Virtual Worlds 17.3‐4 (2006): 271-279. Page 273, col. 1 ¶ 2, discussion of Zordan; also see the “Simulated Trajectory Prediction” section.
Zordan, Victor Brian, et al. "Dynamic response for motion capture animation." ACM Transactions on Graphics (TOG) 24.3 (2005): 697-701. Page 700, col. 1, ¶ 2, discussion of the “automatic rewind” feature.
With respect to the translating feature:
Cheng, Z. Q., et al. "Experiences in reverse-engineering of a finite element automobile crash model." Finite elements in analysis and design 37.11 (2001): 843-860. § 2 bullet point 3: “Initial penetrations: An initial penetration is an overlap between two parts at the start of the simulation. Small initial penetrations are normal due to the fact that the mesh is only an approximation to the actual structure. In most cases, LS-DYNA [4] can automatically adjust nodes [i.e. moving/translating the nodes] during its initialization process so that such penetrations are eliminated…No matter which direction LS-DYNA tries to move [clarification on what the adjustment is] the nodes in question, a penetration will remain…”
Anggono, Agus Dwi, Joko Sedyono, and Bana Handaga. "Geometric modeling and assembly analysis of 90 degree steering system." AIP Conference Proceedings. Vol. 1977. No. 1. AIP Publishing LLC, 2018. Abstract for “Clash detection among the components was carried out in assembly workbench of CATIA” then see page 4, ¶¶ 1-2, including: “After all components and sub-assembly become one product, the clash analysis was then performed to analyze the collision among the parts in the assembly. If there was collision in the assembly, the solid design must be modified to fix the dimension of the components. Clash detection was reconducted until there was no clash detected in the assembly product.” – see pages 6-7 to clarify.
David Hornsby, “Clashing Geometry in BIM Datasets”, Nov. 2018, Blog post, URL: blog(dot)spatial(dot)com/building-information-modeling-bim/clashing-geometry-in-bim-datasets – see ¶¶ 1-2 including: “A major benefit of constructing a building virtually is the cost savings gained by identifying errors in the design before they are found on site. One of the more common errors that can be avoided is when two objects overlap in space or clash…The traditional approach to resolving these issues is with 2D drawings and tracing paper —a manual, slow and error-prone process. In complex situations the clash may well be missed and likely a more expensive situation to resolve on site too. Fortunately in modern BIM systems, the 3D representation of the building in software lends itself to automating clash with many CAD products or even with available clash analysis applications.” – see the figures to clarify.
Hawk Ridge Systems, “Exploring Interference Detection with Multi-Body Parts in SOLIDWORKS”, Oct. 27th, 2018, Blog Post, URL: hawkridgesys(dot)com/blog/solidworks-2019-interference-detection-multi-body-parts. ¶ 1: “Interference Detection is an essential tool that allows you to find where individual parts in an assembly interfere [i.e. overlap] with each other. This helps to check that all of your components fit together before being manufactured….” – e.g. see the figures
Packer, “SOLIDWORKS Simulation Volumetric Interference”, July 29th, 2018, Blog, URL: www(dot)goengineer(dot)com/blog/solidworks-simulation-volumetric-interference – see the figures and their accompanying description, including: “Below is an example of a volumetric interference of a ball sitting on a tabletop… It is always best to find all the volumetric interferences in a model and make the necessary changes to the model before running a simulation on an assembly. If you ever run into this error message, or even if you don’t, but your model still will not mesh. The first thing you should check is if there are any volumetric interferences in your assembly by using the interference detection tool and make the necessary changes to the assembly to “clean it up” in order to remove all of these interferences.”
Feng, Y. T., and D. R. J. Owen. "An augmented spatial digital tree algorithm for contact detection in computational mechanics." International Journal for Numerical Methods in Engineering 55.2 (2002): 159-176. § 1 ¶¶ 1-3
Zhu, Jihong, Weihong Zhang, and Pierre Beckers. "Integrated layout design of multi‐component system." International journal for numerical methods in engineering 78.6 (2009): 631-651. § 1.2.1, ¶¶ 1-2, then page 6 last paragraph, then page 7 ¶¶ 1-2; also see § 2.1 starting on page 16 including ¶¶ 1-2, then page 18 second to last paragraph.
With respect to a common reference frame, Fasanella, Edwin L. Best practices for crash modeling and simulation. National Aeronautics and Space Administration, Langley Research Center, 2002. Page 3, ¶ 1: “One of the first steps in developing a model of an aircraft or airframe component is the development of the geometry. However, even before constructing the geometric model, one must decide on a coordinate system and a system of units. Quite often, left-handed coordinate systems are used. For example, in aircraft drawings, body station (BS), water line (WL), and butt line (BL) dimensions are typically defined using a left-handed system. Finite element programs do not generally accept a left-handed coordinate system since the equations of vector algebra are defined in a coordinate system that obeys the "right-hand" rule. Thus, it is important to choose the origin at an appropriate location and to use a [note the singular] consistent system of the fundamental physical units of length, time, and mass in defining the model.”
The claimed invention is directed towards an abstract idea of both a mathematical concept and a mental process without significantly more.
Regarding the dependent claims
To summarize the dependent claims, several of these dependent claims merely state a variety of what is to be simulated, with no recitations on how the simulations are to be performed.
Claim 3 is merely further limiting the abstract idea, and should it be found that it is not part of the abstract idea then it is generally linking to a field of use/technological environment, i.e. this is merely specifying how long to run the simulations, which is generally linking to a particular field of use
To clarify, its merely clarifying in claim 3 that the time period is the period of time before the two objects actually collide with each other. See above for how this is abstract.
Claim 4 is rejected under a similar rationale as claim 3
Claim 5 is further limiting the mental process, e.g. a person mentally drawing (as part of a mental process of observations, evaluations, and judgements in designing seats) two seats on paper, such as by simple free body diagrams or more complex drawings, and then mentally judging to assigning identifiers to each part of each seat, e.g. part numbers or the like, and merely specifying that identifiers do not overlap. E.g. instant fig. 1A. To clarify, the Examiner notes PersonalWeb in the July 2024 Fed. Register notice, given that these are merely any “identifier”. If construed as particular identifiers, e.g. XML tags, see MPEP § 2106.05(h) for how they would be treated: “Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29, 121 USPQ2d 1928, 1939 (Fed. Cir. 2017) (limiting use of abstract idea to use with XML tags).”
Claim 6 is merely adding another step in the mental process of claim 5, e.g. in drawing the person makes a mistake and causes one of the identifiers to overlap with a second one, so they mentally judge how to fix the mistake and then modify the drawing (e.g. using a pencil and its eraser, or white-out with a pen) to remedy the mistake
Claim 7 is considered as further limiting the abstract idea (i.e. F=ma as discussed above, i.e. apply an initial acceleration), or should it be found not to be abstract then this is generally linking to a particular field of use/technological environment
Claim 10 is merely further limiting the mere data gathering steps in claim 1 by stating what data is to be gathered (MPEP § 2106.05(g and h), wherein this is WURC in view of the evidence above for claim 1; also see MPEP § 2106.05(d)(II): “iii. Electronic recordkeeping, Alice Corp. Pty. Ltd. v. CLS Bank Int'l, 573 U.S. 208, 225, 110 USPQ2d 1984 (2014) (creating and maintaining "shadow accounts"); Ultramercial, 772 F.3d at 716, 112 USPQ2d at 1755 (updating an activity log); iv. Storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93;”
Claim 12 is merely further limiting the abstract idea by specifying what is to be simulated/calculated/mentally evaluated by simple calculations, and should it be found that this is not part of the abstract idea then it would be both mere instructions to “apply it” given the results-oriented nature of this limitation with no recitation of how it is to be performed, as well as a token post-solution activity recited in a high degree of generality that is WURC in view of the above discussed evidence in claim 1
Claim 13 is merely further limiting the abstract idea, and should it be found that it’s not then it’s merely further limiting the mere data gathering and is WURC in view of the above evidence
Claim 14 is merely further limiting the abstract idea, and should it be found that it’s not part of the abstract idea then it is generally linking to a particular field of use/technological environment
Claim 15 is rejected under a similar rationale as claims 13-14
Claim 16 is adding another mental process akin to the ones found it the independent claims as discussed above, wherein this includes a simple mental process of re-positioning seats in the seating arrangement, e.g. re-arranging the deck chairs on the Titanic as it sinks
Claim 17 is rejected under a similar rationale as the similar recitations found in the independent claims above, and in claim 12
Claim 19 is rejected under a similar rationale as the similar limitations found in other dependent claims above, e.g. claim 12
Claim 20 is rejected under a similar rationale as claim 5 above
Claim 21 is merely a mental process of the adjusting, i.e. simply observing the results of the prior abstract idea, and then mentally judging to move/adjust some parts of the geometry of seats, and then re-run the combined simulation (rejected under a similar rationale as above for the first combined simulation).
Claim 22 – the first two limitations are merely specifying the geometry of the problem (i.e. part of the abstract idea itself; and if not generally linking to a particular field of use for similar reasons as above on this being for seating arrangements), and the “without rerunning” is merely the result of the abstract idea itself as discussed above (and should it be found it is not, then its merely the result of applying the abstract idea on the computer and part of the insignificant computer implementation, i.e. its simply stating the result of Newton’s laws of motions in that when two objects are moving in isolation they impart no forces on each other, but when they collide apply Newton’s third law, therefore when doing coupled simulations with a computer, or doing hand calculations as discussed above, one can readily calculate the movement of the two (or more) objects in isolation, determine when they will collide, and only perform the calculations of the combined collision time period for that time period, using the initial positions and velocities, and the like, from the prior independent calculations without needing to re-run them because the two objects did not exert any forces on each other by Newton’s third law of motion, or as stated in the first law, in many ways: an object in motion remains in motion, so long as no external force acts on it).
Claim 23 – first, see ¶¶ 36 and 48, i.e. this merely conveys that later combined simulations (calculations simple enough for mental performance, as discussed above) can be done without repeating the first two partial calculations for the first and second seats (the first two limitations of claim 1). To clarify, see the discussion above for the independents. This claim merely adds on that once a person has obtained the velocity and positions of the two objects (the two seats) prior to the collision in isolation, then for the period of time in the collision they simply keep re-using their old result, while able to adjust the positioning of the seats before re-running the combined calculations. A faster abstract idea is still an abstract idea, i.e. the “less processing power” is merely provided by a faster abstract idea/new abstract idea when automated in a computer environment, which does not amount to an improvement to technology, for “Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151, 120 USPQ2d 1473, 1483 (Fed. Cir. 2016) ("a new abstract idea is still an abstract idea")” (MPEP § 2106.04(I))
The claimed invention is directed towards an abstract idea of both a mathematical concept and a mental process without significantly more.
Conclusion
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/David A Hopkins/Primary Examiner, Art Unit 2188