DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of the Claims
Claims 1-2, 4-6, 9-13, and 15-28 were previously pending. Claims 1-2, 9-11, 13, 16-18, 20, and 22 were amended, and claims 6, 12, 19, 21, and 23 were canceled in the reply filed April 28, 2026. Claims 1-2, 4-5, 9-11, 13, 15-18, 20, 22, and 24-28 are currently pending.
Response to Arguments
Applicant's amendments partially overcome the objection made to the Specification. Claim 27 still recites the terms "purchased" and "expenses" which have no antecedent basis in the descriptive portion of the Specification.
Applicant's amendments overcome the rejection made under § 112(a) and it is withdrawn.
Applicant's arguments filed with respect to the rejection made under § 101 have been fully considered but they are not persuasive. Applicant's arguments that the claims do not recite an abstract idea are unpersuasive for reasons already of record (Non-Final Rejection mailed 1/28/2026, ¶ 6).
Applicant also argues that the claims integrate the abstract idea into a practical application. Remarks, 21-22. These are also unpersuasive for reasons already of record (Non-Final Rejection mailed 1/28/2026, ¶ 7). Applicant does not explain how delivering baggage from an airport to a person at hotel using a generic printer is similar to, e.g., controlling a feed dispenser with an effective amount of minerals for livestock. As all of the comparisons are conclusory, the rejection is maintained.
Specification
The specification is objected to as failing to provide proper antecedent basis for the claimed subject matter. See 37 CFR 1.75(d)(1) and MPEP § 608.01(o). Correction of the following is required: the detailed description lacks antecedent basis for the claim terms "expenses" and "purchased."
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 1-2, 4-5, 9-11, 13, 15-18, 20, 22, and 24-28 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter (abstract idea without significantly more). Claims are eligible for patent protection under § 101 if they are in one of the four statutory categories and not directed to a judicial exception to patentability. Alice Corp. v. CLS Bank Int'l, 573 U.S. 208 (2014). Claims 1-2, 4-5, 9-11, 13, 15-18, 20, 22, and 24-28, each considered as a whole and as an ordered combination, are directed to a judicial exception (i.e., an abstract idea) without significantly more.
MPEP 2106 Step 2A – Prong 1:
The claims recite an abstract idea reflected in the representative functions of the independent claims including:
With respect to claims 1, 9, and 10:
to obtain, at an airport, hotel information about a reservation at a hotel for a customer based on a customer information, which is information about the customer who uses the airport and obtained from the customer at the airport;
to control an output, at the airport, of an instruction to perform a procedure for delivering baggage of the customer from the airport to the hotel based on the hotel information;
to give, at the hotel, a completion information indicating that a delivery of the baggage is completed, when the delivery of the baggage to the hotel is completed;
to change a delivery flag associated with accommodation information stored based on the completion information, wherein the delivery flag indicates a status of the delivery of the baggage;
to output the status of the delivery of the baggage based on the delivery flag;
to display the destination at the hotel for the baggage in response to reading the destination information from the slip; and
to display, in response to the delivery slip on the baggage is read at the hotel, a guest name and a room number corresponding to the customer, so that a staff of the hotel hands over the baggage to the customer based on the displayed guest name and room number;
to control an output, at the hotel, of a total cost of a first cost of the delivery and a second cost incurred at a time of check-out of the customer from the hotel which is after the delivery of the baggage is completed,
wherein the hotel is physically separated from the airport,
to identify the customer by face authentication and obtain the hotel information based on the customer information about the identified customer.
With respect to claims 11, 16, and 17:
to identify a customer based on an authentication information obtained from the customer who uses an airport and obtained from the customer at the airport, and to obtain, at the airport and in response to identifying the customer, hotel information about a hotel reserved for the customer registered in advance;
to give an instruction to deliver baggage of the customer from the airport to the hotel based on the hotel information;
to notify the customer that a delivery of the baggage is completed, when the delivery of the baggage is completed;
to change a delivery flag associated with accommodation information stored based on the completion information, wherein the delivery flag indicates a status of the delivery of the baggage;
to output the status of the delivery of the baggage based on the delivery flag;
to display the destination at the hotel for the baggage in response to reading the destination information from the slip; and
displaying, in response to the delivery slip on the baggage is read at the hotel, a guest name and a room number corresponding to the customer, so that a staff of the hotel hands over the baggage to the customer based on the displayed guest name and room number;
to control an output, at the hotel, of a total cost of a first cost of the delivery and a second cost incurred at a time of check-out of the customer from the hotel which is after the delivery of the baggage is completed,
wherein the hotel is physically separated from the airport,
to identify the customer by face authentication.
With respect to claims 18, 20, and 22:
to identify a customer based on an authentication information obtained from the customer who uses an airport and obtained from the customer at the airport, and to obtain hotel information about a reservation at a hotel for the customer registered in advance in response to the identified customer;
to output, at the airport, a delivery slip instructing a delivery of baggage of the customer from the airport to the hotel based on the hotel information;
to notify the customer that the delivery of the baggage is completed, when the delivery of the baggage is completed;
to change a delivery flag associated with accommodation information stored based on the completion information, wherein the delivery flag indicates a status of the delivery of the baggage;
to output the status of the delivery of the baggage based on the delivery flag;
to display the destination at the hotel for the baggage in response to reading the destination information from the slip by a scanner; and
displaying, in response to the delivery slip on the baggage is read at the hotel, a guest name and a room number corresponding to the customer, so that a staff of the hotel hands over the baggage to the customer based on the displayed guest name and room number;
to control an output, at the hotel, of a total cost of a first cost of the delivery and a second cost incurred at a time of check-out of the customer from the hotel which is after the delivery of the baggage is completed,
wherein the hotel is physically separated from the airport,
to identify the customer by face authentication.
These limitations taken together qualify as a method of organizing human activities because they recite collecting, analyzing, and outputting information for coordinating and tracking the delivery of baggage to traveling people via a service provider and determining a cost (i.e., in the terminology of the 2019 Revised Guidance, fundamental economic practices; commercial interactions (including marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, following rules or instructions).
It shares similarities with other abstract ideas held to be non-statutory by the courts (see Electronic Comm. v. Shopperschoice.com, LLC, 958 F.3d 1178, 1181 (Fed. Cir. 2020)—business practices designed to advise customers of the status of delivery of their goods, similar because at another level of abstraction the claims could be characterized as business practices designed to advise customers of the status of delivery of their baggage; Electric Power Grp., LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016)—process of gathering and analyzing information of a specified content, then displaying the results, similar because at another level of abstraction the claims could be characterized as process of gathering and analyzing information of a baggage delivery, then displaying the results; Secured Mail Solutions v. Universal Wilde, 873 F.3d 905 (Fed. Cir. 2017)—communicating information about a mail object using a personalized marking, similar because at another level of abstraction the claims could be characterized as communicating information about a delivery object using accommodations and customer information; Smart Sys. Innovations v. Chicago Transit Authority, 873 F.3d 1364 (Fed. Cir. 2017)—formation of financial transactions in a particular field (i.e., mass transit) and data collection related to such transactions, similar because at another level of abstraction the claims could be characterized as formation of financial transactions in a particular field (i.e., hotel baggage delivery) and data collection related to such transactions).
These cases describe significantly similar aspects of the claimed invention, albeit at another level of abstraction. See Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1240-41 (Fed. Cir. 2016) ("An abstract idea can generally be described at different levels of abstraction. As the Board has done, the claimed abstract idea could be described as generating menus on a computer, or generating a second menu from a first menu and sending the second menu to another location. It could be described in other ways, including, as indicated in the specification, taking orders from restaurant customers on a computer.").
MPEP 2106 Step 2A – Prong 2:
This judicial exception is not integrated into a practical application because there are no meaningful limitations that transform the exception into a patent eligible application. The elements merely serve to provide a general link to a technological environment (e.g., computers and the Internet) in which to carry out the judicial exception (system, memory configured to store instructions, server, processor configured to execute the instructions, input apparatus, output apparatus, sending a signal via a data bus to control a printer to print a slip, database, outputting a signal to a display, face authentication—all recited at a high level of generality).
In addition to being a generic computer function, sending a signal via a data bus to control a printer to print a slip can also be viewed as insignificant extra-solution activity, similar to the printing of menus after they have been generated in Apple v. Ameranth (842 F.3d at 1241-42). See also MPEP 2106.05(g). This includes the limitation of the contents of the printed slip "comprising destination information at the hotel, wherein the destination information indicates a destination at the hotel for the baggage," which is purely abstract data similar to the menus in Amaranth. Even if the recited "face authentication" (recited absent any means to accomplish it) is treated as an additional element, it is merely used at a high level of generality to gather (biometric) data in order to perform an abstract function (confirming a customer's identity in order to receive their goods). The face authentication is thus tangential to the rest of the invention because the customer could also be identified by any other means (e.g., government-issued identification card, password, matching ticket stub, digital token, another biometric such as fingerprint, etc.) and achieve the same result (in the published Specification ¶ 0030 face authentication is explicitly identified as optional and that customer identification can be achieved by other means and not affect the remainder of the invention, which supports that this limitation is nominally related and cannot serve to integrate the abstract idea into a practical application).
Although the claims have and execute instructions to perform the abstract idea itself (e.g., modules, program code, etc. to automate the abstract idea), this also does not serve to integrate the abstract idea into a practical application as it merely amounts to instructions to "apply it." Aside from such instructions to implement the abstract idea, they are solely used for generic computer operations (e.g., receiving, storing, retrieving, transmitting data), employing the computer as a tool. See FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 1096 (Fed. Cir. 2016) ("[T]he use of generic computer elements like a microprocessor or user interface do not alone transform an otherwise abstract idea into patent-eligible subject matter.") (citing DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d 1245,1256 (Fed. Cir. 2014)) (emphasis added). Additionally, although the claims take place at a hotel and airport, this merely sets forth a field-of-use for the invention.
The claims do not set forth improvements to another technological field or the functioning of the computer itself and instead use computer elements as tools to improve the functioning of the abstract idea identified above. Looking at the additional limitations and abstract idea as an ordered combination and as a whole 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. Rather than any meaningful limits, their collective functions merely provide generic computer implementation of the abstract idea identified in Prong One. None of the additional elements recited "offers a meaningful limitation beyond generally linking 'the use of the [method] to a particular technological environment,' that is, implementation via computers." Alice Corp., slip op. at 16 (citing Bilski v. Kappos, 561 U.S. 610, 611 (U.S. 2010)).
At the levels of abstraction described above, the claims do not readily lend themselves to a finding that they are directed to a nonabstract idea. Therefore, the analysis proceeds to step 2B. See BASCOM Global Internet v. AT&T Mobility LLC, 827 F.3d 1341, 1349 (Fed. Cir. 2016) ("The Enfish claims, understood in light of their specific limitations, were unambiguously directed to an improvement in computer capabilities. Here, in contrast, the claims and their specific limitations do not readily lend themselves to a step-one finding that they are directed to a nonabstract idea. We therefore defer our consideration of the specific claim limitations’ narrowing effect for step two.") (citations omitted).
MPEP 2106 Step 2B:
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception for the same reasons as presented in Step 2A Prong 2 (i.e., they amount to nothing more than a general link to a particular technological environment and instructions to apply it there). Moreover, the additional elements recited are known and conventional computing elements (system, memory configured to store instructions, server, processor configured to execute the instructions, input apparatus, output apparatus, sending a signal via a data bus to control a printer to print a slip, database, outputting a signal to a display—see published Specification ¶¶ 0025, 31, 37, 39-40, 44-46 (as amended), 49 describing these at a high level of generality and in a manner that indicates that the additional elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy the statutory disclosure requirements; see also ¶ 0030 even if face authentication (recited without any means to accomplish it) is considered an additional element). Additionally, although the claims take place at a hotel and airport, this merely sets forth a field-of-use for the invention.
The Federal Circuit has recognized that "an invocation of already-available computers that are not themselves plausibly asserted to be an advance, for use in carrying out improved mathematical calculations, amounts to a recitation of what is 'well-understood, routine, [and] conventional.'" SAP Am., Inc. v. InvestPic, LLC, 890 F.3d 1016, 1023 (Fed. Cir. 2018) (alteration in original) (citing Mayo v. Prometheus, 566 U.S. 66, 73 (2012)). Apart from the instructions to implement the abstract idea, they only serve to perform well-understood functions (e.g., receiving, storing, retrieving, transmitting data—see Specification above as well as Alice Corp.; Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307 (Fed. Cir. 2016); and Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015) covering the well-known nature of these basic computer functions
"The use and arrangement of conventional and generic computer components recited in the claims—such as a database, user terminal, and server— do not transform the claim, as a whole, into 'significantly more' than a claim to the abstract idea itself. We have repeatedly held that such invocations of computers and networks that are not even arguably inventive are insufficient to pass the test of an inventive concept in the application of an abstract idea." Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1056 (Fed. Cir. 2017) (citations and quotation marks omitted). 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.
Dependent Claims Step 2A:
The limitations of the dependent claims but for those addressed below merely set forth further refinements of the abstract idea without changing the analysis already presented (i.e., they merely narrow the abstract idea without adding any new additional elements beyond it). Additionally, for the same reasons as above, the limitations fail to integrate the abstract idea into a practical application because they use the same generic technological environment and instructions to implement the abstract idea as the independent claims. Claim 24 adds a generic "baggage delivery management system" absent any technical details, which is not sufficient for the same reasons.
Dependent Claims Step 2B:
The dependent claims merely use the same generic technological environment and instructions to implement the abstract idea. Claim 24 adds a generic "baggage delivery management system" absent any technical details, which is not sufficient for the same reasons as in Step 2A (i.e., it merely provides a general link to a particular technological environment with which to perform the abstract idea). Accordingly, they are not directed to significantly more than the exception itself, and are not eligible subject matter under § 101.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to DANIEL VETTER whose telephone number is (571)270-1366. The examiner can normally be reached M-F 9:00-6:00.
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/DANIEL VETTER/Primary Examiner, Art Unit 3628
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