Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Response to Arguments
Applicant’s amendments and arguments with respect to the objection to the specification, the objection to the drawings and the claim objection have been fully considered and are persuasive. The objection to the specification, the objection to the drawings and the claim objection has been withdrawn.
Applicant's amendment and arguments with respect to the rejection of claim 1 (and claims 2-7 based on their dependency) under 35 USC 112(b) have been fully considered and are persuasive. The rejection under 35 USC 112(b) has been withdrawn.
Applicant's amendment and arguments with respect to the rejection of claims 1-20 under 35 USC 103) have been fully considered and are persuasive. The rejection under 35 USC 103 has been withdrawn.
Applicant’s amendment and arguments with respect to the rejection of claim 8 under 35 USC 101 have been fully considered but they are not persuasive. Applicant has amended claim 8 to include “cause, based on the actual steering angle being different from the target steering angle, the front frame to be steered towards the target steering angle based on the second calculated steering angle.” Based on the specification, particularly ¶[0031], the articulated machine is controlled by an operator who inputs the steering controls to an input device (joystick, steering wheel, etc.). The input device then sends the signal to the controller which then transmits the signals to the actuators. As such, under a broadest reasonable interpretation of the claim limitation, the “cause… the front frame to be steered” can be interpreted as a person controlling the articulated machine. The fact that the claim requires a generic controller to transmit the signals does not integrate into practical application, but is instead is just generally applying an exception using generic computer components. As such, the rejection to claim 8 under 35 USC 101 has been maintained herein. Further, while the non-final office action of 20 May 2025 only included a rejection to claim 8 under 35 USC 101, upon further consideration, claims 1-7 and 9-20 have been rejected under 35 USC 101 herein as explained in more detail below.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Claim 1 Analysis:
STEP 1: Does claim 1 fall within one of the statutory categories? Yes. The claim is directed toward a method which falls within one of the statutory categories.
STEP 2A (PRONG 1): Is the claim directed to a law of nature, a natural phenomenon or an abstract idea? Yes, the claim is directed to an abstract idea.
Claim 1. A method for steering alignment calibration of an articulated machine having a rear frame and a front frame pivotally connected by an articulation joint to steer the articulated machine, the method for steering alignment calibration comprising:
displaying a steering alignment calibration screen to an operator of the articulated machine, wherein the steering alignment calibration screen includes a target steering angle between the rear frame and the front frame about the articulation joint and a calculated steering angle, and wherein the calculated steering angle is determined based on a sensed steering angle and a calibration steering angle;
steering the articulated machine until the calculated steering angle displayed on the steering alignment calibration screen is equal to the target steering angle;
determining, based on inspecting the articulated machine, an actual steering angle of the articulated machine, wherein the actual steering angle is different from the sensed steering angle;
comparing the actual steering angle to the target steering angle; and
steering the front frame toward the target steering angle in response to determining that the actual steering angle is not equal to the target steering angle.
The method in claim 1 is a mental process that can be practicably performed in the human mind and, therefore, an abstract idea. The limitations of claim 1 highlighted above merely consist of a person looking at an articulated machine and determining that the actual angle of the machine (angle between the front and rear frames) does not match the target steering angle. These observations can easily be done mentally in the human mind. Thus, the claim recites a mental process.
Further, the following limitations:
steering the articulated machine until the calculated steering angle displayed on the steering alignment calibration screen is equal to the target steering angle;
determining, based on inspecting the articulated machine, an actual steering angle of the articulated machine, wherein the actual steering angle is different from the sensed steering angle;
comparing the actual steering angle to the target steering angle; and
steering the front frame toward the target steering angle in response to determining that the actual steering angle is not equal to the target steering angle
recite a method of organizing human activity and is therefore an abstract idea. The limitations of claim 1 highlighted above merely consist of a person steering an articulated machine until an angle between a front frame and rear frame of the articulated machine matches a desired angle as shown on a display, getting off the machine to visually observe that the angle between the front and rear frames is not as the desired position, getting back on the machine and continuing to steer the machine until the desired angle is reaches. These limitations are a process that is performed by a human when they are driving the articulated machine, and as such are limitations drawn to the managing of personal behavior and recite a method of organizing human activity.
STEP 2A (PRONG 2): Does the claim recite additional elements that integrate the judicial exception into a practical application? No, the claim does not recite additional elements that integrate the judicial exception into a practical application.
Claim 1. A method for steering alignment calibration of an articulated machine having a rear frame and a front frame pivotally connected by an articulation joint to steer the articulated machine, the method for steering alignment calibration comprising:
displaying a steering alignment calibration screen to an operator of the articulated machine, wherein the steering alignment calibration screen includes a target steering angle between the rear frame and the front frame about the articulation joint and a calculated steering angle, and wherein the calculated steering angle is determined based on a sensed steering angle and a calibration steering angle;
steering the articulated machine until the calculated steering angle displayed on the steering alignment calibration screen is equal to the target steering angle;
determining, based on inspecting the articulated machine, an actual steering angle of the articulated machine, wherein the actual steering angle is different from the sensed steering angle;
comparing the actual steering angle to the target steering angle; and
steering the front frame toward the target steering angle in response to determining that the actual steering angle is not equal to the target steering angle.
Claim 1 does not recite any of the exemplary considerations that are indicative of an abstract idea having been integrated into a practical application. The additional elements underlined above do not integrate the abstract idea into practical application. The displaying step recited above is merely the display of a sensor reading (outputting a sensor reading) and is claimed generically such that it is mere pre-solution activity which is a form of insignificant extra solution activity. Further, the steering steps (which would be additional elements under the mental processes grouping), under a broadest reasonable interpretation, are merely a person manipulating the articulated machine into a desired position, and as such are mere extra solution activity.
STEP 2B: Does the claim recite additional elements that amount to significantly more than the judicial exception? No, the claim does not recite additional elements that amount to significantly more than the judicial exception.
Independent claim 1 does not include additional elements (considered both individually and as an ordered combination) that are sufficient to amount to significantly more than the judicial exception for the same reasons to those discussed above with respect to determining that the claim does not integrate the abstract idea into a practical application. A conclusion that an additional element is insignificant extra-solution activity in Step 2A should be re-evaluated in Step 2B to determine if they are more than what is well-understood, routine, conventional activity in the field. The additional limitations of the displaying step is nothing more than applying the exception using a generic computer or generic computer components, as the output or display of a sensor reading is well understood, routine and conventional activity as described in applicant’s originally filed specification ¶[0003]. Further still, a person manipulating/steering an articulated machine to a desired position or a desired angle between the front and rear frame of the machine is well understood routine and conventional activity, as admitted by applicant in the originally filed specification ¶[0004]. Generally applying an exception using generic computer components cannot provide an inventive concept.
Dependent claims 2-7 do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claims are directed toward additional aspects of the judicial exception and/or well-understood, routine and conventional additional elements that do not integrate the judicial exception into a practical application. Particularly, dependent claims 2-5 and 7 are limitations that would be classified as part of the mental process (determining steps) and/or organizing human activity using a similar rationale as applied to claim 1 above. Dependent claim 6 recites an additional element under Prong 2 as turning of the machine before making a mental observation is mere insignificant extra solution activity using a similar analysis as applied to claim 1 above.
Claim 8 Analysis:
STEP 1: Does claim 8 fall within one of the statutory categories? Yes. The claim is directed toward an articulated machine (apparatus) which falls within one of the statutory categories.
STEP 2A (PRONG 1): Is the claim directed to a law of nature, a natural phenomenon or an abstract idea? Yes, the claim is directed to an abstract idea.
Claim 8. An articulated machine, comprising:
a rear frame;
a front frame;
an articulation joint pivotally connecting the front frame to the rear frame, wherein a steering angle is a relative position of the front frame relative to the rear frame about the articulation joint;
a steering system operatively connected between the rear frame and the front frame and operable to rotate the front frame about the articulation joint to adjust the steering angle;
a steering position sensor outputting operable to steering position sensor signals indicating a sensed steering angle of the articulated machine;
an output device;
a memory; and
a machine controller operatively connected to the steering position sensor, the output device and the memory, the machine controller being programmed to:
determine a first calculated steering angle based on a first sensed steering angle from first steering position sensor signals and a first calibration steering angle stored at the memory and representing a difference between an actual steering angle of the articulated machine and the first sensed steering angle, wherein the actual steering angle is based on an inspection of the articulated machine and is different from the sensed steering angle,
display the first calculated steering angle and a target steering angle at the output device,
determine a second calculated steering angle based on a second sensed steering angle from second steering position sensor signals and the first calibration steering angle,
display the second calculated steering angle at the output device in place of the first calculated steering angle as the steering system changes the steering angle, and
cause, based on the actual steering angle being different from the target steering angle, the front frame to be steered towards the target steering angle based on the second calculated steering angle.
The limitations of claim 8 highlighted above are a mental process that can be practicably performed in the human mind and, therefore, an abstract idea. The limitations of claim 8 highlighted above merely consist of a person looking at an articulated machine and determining that the actual angle of the machine (angle between the front and rear frames) does not match the target steering angle. These observations can easily be done mentally in the human mind. Thus, the claim recites a mental process.
STEP 2A (PRONG 2): Does the claim recite additional elements that integrate the judicial exception into a practical application? No, the claim does not recite additional elements that integrate the judicial exception into a practical application.
Claim 8. An articulated machine, comprising:
a rear frame;
a front frame;
an articulation joint pivotally connecting the front frame to the rear frame, wherein a steering angle is a relative position of the front frame relative to the rear frame about the articulation joint;
a steering system operatively connected between the rear frame and the front frame and operable to rotate the front frame about the articulation joint to adjust the steering angle;
a steering position sensor outputting operable to steering position sensor signals indicating a sensed steering angle of the articulated machine;
an output device;
a memory; and
a machine controller operatively connected to the steering position sensor, the output device and the memory, the machine controller being programmed to:
determine a first calculated steering angle based on a first sensed steering angle from first steering position sensor signals and a first calibration steering angle stored at the memory and representing a difference between an actual steering angle of the articulated machine and the first sensed steering angle, wherein the actual steering angle is based on an inspection of the articulated machine and is different from the sensed steering angle,
display the first calculated steering angle and a target steering angle at the output device,
determine a second calculated steering angle based on a second sensed steering angle from second steering position sensor signals and the first calibration steering angle,
display the second calculated steering angle at the output device in place of the first calculated steering angle as the steering system changes the steering angle, and
cause, based on the actual steering angle being different from the target steering angle, the front frame to be steered towards the target steering angle based on the second calculated steering angle.
Claim 8 does not recite any of the exemplary considerations that are indicative of an abstract idea having been integrated into a practical application. The additional elements underlined above do not integrate the abstract idea into practical application. The displaying steps recited above is merely the display of a sensor reading (outputting a sensor reading) and is claimed generically and amount to mere post solution activity. Further, the steering steps (causing…the front frame to be steered…)under a broadest reasonable interpretation, are merely a person manipulating the articulated machine into a desired position, and as such are mere extra solution activity (post solution actions). The memory and machine controller recited are mere instructions to implement the abstract idea on a computer, or merely use a computer as a tool to perform the abstract idea which is indicative that the judicial exception has not been integrated into practical application. Further still, the front frame, the rear frame, the articulation joint, the steering system, the steering position sensor and the output device are recited at a high level of generality and is at best the equivalent of adding the words “apply it” to the claim. Thus, it is clear that the abstract idea is merely using components in their ordinary capacity and implemented on a computer, which is indicative of the abstract idea having not been integrated into a practical application.
STEP 2B: Does the claim recite additional elements that amount to significantly more than the judicial exception? No, the claim does not recite additional elements that amount to significantly more than the judicial exception.
Independent claim 8 does not include additional elements (considered both individually and as an ordered combination) that are sufficient to amount to significantly more than the judicial exception for the same reasons to those discussed above with respect to determining that the claim does not integrate the abstract idea into a practical application. A conclusion that an additional element is insignificant extra-solution activity in Step 2A should be re-evaluated in Step 2B to determine if they are more than what is well-understood, routine, conventional activity in the field. The additional limitations of the displaying step is nothing more than applying the exception using a generic computer or generic computer components, as the output or display of a sensor reading is well understood, routine and conventional activity as described in applicant’s originally filed specification ¶[0003]. Further still, a person manipulating/steering an articulated machine to a desired position or a desired angle between the front and rear frame of the machine is well understood routine and conventional activity, as admitted by applicant in the originally filed specification ¶[0004]. Generally applying an exception using generic computer components and/or components recited generically and acting in their ordinary capacity cannot provide an inventive concept.
Dependent claims 9-14 do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claims are directed toward additional aspects of the judicial exception and/or well-understood, routine and conventional additional elements that do not integrate the judicial exception into a practical application. Particularly, dependent claims 9-10 are limitations that would be classified as part of the mental process (determining steps) and/or extra solution activity using a similar rationale as applied to claim 8 above. Dependent claims 11-14 recited an additional elements under Prong 2 that merely further describe the articulated machine and are the equivalent of adding the words “apply it” using a similar analysis as applied to claim 8 above.
Claim 15 Analysis:
STEP 1: Does claim 15 fall within one of the statutory categories? Yes. The claim is directed toward a method which falls within one of the statutory categories.
STEP 2A (PRONG 1): Is the claim directed to a law of nature, a natural phenomenon or an abstract idea? Yes, the claim is directed to an abstract idea.
Claim 15. A method for steering alignment of an articulated machine for locking a steering frame lock between a rear frame and a front frame of the articulated machine that are pivotally connected by an articulation joint to steer the articulated machine, wherein the steering frame lock includes a lock link having a first lock link end that is movably connected to the rear frame and a second lock link end that detachably connects to the front frame when the articulated machine is steered to a frame lock steering angle, the method for steering alignment comprising:
displaying a steering frame lock screen to an operator on a display device of the articulated machine, wherein the steering frame lock screen displays the frame lock steering angle and a calculated steering angle, wherein the calculated steering angle is determined by a machine controller of the articulated machine based on a sensed steering angle and a calibration steering angle, and wherein the sensed steering angle and the calculated steering angle are updated as the front frame rotates relative to the rear frame about the articulation joint;
steering the articulated machine until the calculated steering angle displayed on the steering frame lock screen is equal to the frame lock steering angle;
determining, based on inspecting the articulated machine, whether an actual steering angle of the articulated machine is equal to the frame lock steering angle for connection of the second lock link end, wherein the actual steering angle is different from the sensed steering angle; and
steering toward the frame lock steering angle in response to determining that the actual steering angle is not equal to the frame lock steering angle.
The method in claim 15 is a mental process that can be practicably performed in the human mind and, therefore, an abstract idea. The limitations of claim 15 highlighted above merely consist of a person looking at an articulated machine and determining that the actual angle of the machine (angle between the front and rear frames) does not match the target steering angle. These observations can easily be done mentally in the human mind. Thus, the claim recites a mental process.
Further, the following limitations:
steering the articulated machine until the calculated steering angle displayed on the steering frame lock screen is equal to the frame lock steering angle;
determining, based on inspecting the articulated machine, whether an actual steering angle of the articulated machine is equal to the frame lock steering angle for connection of the second lock link end, wherein the actual steering angle is different from the sensed steering angle; and
steering toward the frame lock steering angle in response to determining that the actual steering angle is not equal to the frame lock steering angle
recite a method of organizing human activity and is therefore an abstract idea. The limitations of claim 15 highlighted above merely consist of a person steering an articulated machine until an angle between a front frame and rear frame of the articulated machine matches a desired angle as shown on a display, getting off the machine to visually observe that the angle between the front and rear frames is not as the desired position, getting back on the machine and continuing to steer the machine until the desired angle is reaches. These limitations are a process that is performed by a human when they are driving the articulated machine, and as such are limitations drawn to the managing of personal behavior and recite a method of organizing human activity.
STEP 2A (PRONG 2): Does the claim recite additional elements that integrate the judicial exception into a practical application? No, the claim does not recite additional elements that integrate the judicial exception into a practical application.
Claim 15. A method for steering alignment of an articulated machine for locking a steering frame lock between a rear frame and a front frame of the articulated machine that are pivotally connected by an articulation joint to steer the articulated machine, wherein the steering frame lock includes a lock link having a first lock link end that is movably connected to the rear frame and a second lock link end that detachably connects to the front frame when the articulated machine is steered to a frame lock steering angle, the method for steering alignment comprising:
displaying a steering frame lock screen to an operator on a display device of the articulated machine, wherein the steering frame lock screen displays the frame lock steering angle and a calculated steering angle, wherein the calculated steering angle is determined by a machine controller of the articulated machine based on a sensed steering angle and a calibration steering angle, and wherein the sensed steering angle and the calculated steering angle are updated as the front frame rotates relative to the rear frame about the articulation joint;
steering the articulated machine until the calculated steering angle displayed on the steering frame lock screen is equal to the frame lock steering angle;
determining, based on inspecting the articulated machine, whether an actual steering angle of the articulated machine is equal to the frame lock steering angle for connection of the second lock link end, wherein the actual steering angle is different from the sensed steering angle; and
steering toward the frame lock steering angle in response to determining that the actual steering angle is not equal to the frame lock steering angle.
Claim 15 does not recite any of the exemplary considerations that are indicative of an abstract idea having been integrated into a practical application. The additional elements underlined above do not integrate the abstract idea into practical application. The displaying step recited above is merely the display of a sensor reading (outputting a sensor reading) and is claimed generically such that it is mere pre-solution activity which is a form of insignificant extra solution activity. Further, the steering steps (which would be additional elements under the mental processes grouping), under a broadest reasonable interpretation, are merely a person manipulating the articulated machine into a desired position, and as such are mere extra solution activity.
STEP 2B: Does the claim recite additional elements that amount to significantly more than the judicial exception? No, the claim does not recite additional elements that amount to significantly more than the judicial exception.
Independent claim 15 does not include additional elements (considered both individually and as an ordered combination) that are sufficient to amount to significantly more than the judicial exception for the same reasons to those discussed above with respect to determining that the claim does not integrate the abstract idea into a practical application. A conclusion that an additional element is insignificant extra-solution activity in Step 2A should be re-evaluated in Step 2B to determine if they are more than what is well-understood, routine, conventional activity in the field. The additional limitations of the displaying step is nothing more than applying the exception using a generic computer or generic computer components, as the output or display of a sensor reading is well understood, routine and conventional activity as described in applicant’s originally filed specification ¶[0003]. Further still, a person manipulating/steering an articulated machine to a desired position or a desired angle between the front and rear frame of the machine is well understood routine and conventional activity, as admitted by applicant in the originally filed specification ¶[0004]. Generally applying an exception using generic computer components cannot provide an inventive concept.
Dependent claims 16-20 do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claims are directed toward additional aspects of the judicial exception and/or well-understood, routine and conventional additional elements that do not integrate the judicial exception into a practical application. Particularly, dependent claims 16-19 are limitations that would be classified as part of the mental process (determining steps) and/or organizing human activity using a similar rationale and/or insignificant extra solution activity as applied to claim 15 above. Dependent claim 20 recites an additional element under Prong 2 as turning of the machine before making a mental observation is mere insignificant extra solution activity using a similar analysis as applied to claim 15 above.
Therefore, claims 1-20 are ineligible under 35 USC §101.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANNE MARIE ANTONUCCI whose telephone number is (313)446-6519. The examiner can normally be reached Monday to Friday 8:30 to 5:00.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, JAMES TRAMMELL can be reached at 571-272-6712. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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ANNE MARIE ANTONUCCI
Supervisory Patent Examiner
Art Unit 3666A
/ANNE MARIE ANTONUCCI/Supervisory Patent Examiner, Art Unit 3666