DETAILED ACTION
This action is in response to the submission filed on 2/18/2026. Claims 1-7 are presented for examination.
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 - 35 USC § 112
Applicant's arguments filed 2/18/2026 have been fully considered. The rejections have been withdrawn. However the submitted amendments have created new issues. See below.
Response to Arguments - 35 USC § 101
Applicant's arguments filed 2/18/2026 have been fully considered but they are not persuasive.
The claims are directed towards acquiring data and performing the mental process of determining. The second recited limitation of claim 1 is written such that it is unclear what is taking place and there appears to be no verb recited for the method step. For the purposes of examination ‘to simulate stress relaxation’ is interpreted as a mental process.
The rejection has been updated to reflect the amended claim language.
Response to Arguments - 35 USC § 103
Applicant’s arguments have been considered but are moot in view of the new grounds of rejection. The rejection has been updated to reflect the amended claim language.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-7 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
Claim 1, lines 8-12 have been amended to recite “for at least a part of bent portions in the press formed part immediately after the springback, a reduced value of the residual stress to simulate stress relaxation of the press formed part over time”. The phrase is confusing and unclear. Claim 1 is a method claim, therefore the limitation should begin with a verb for the method step. It is unknown if the reduced value is simulating the stress relaxion, or if the reduced value of the residual stress is being determined in order to simulate stress relaxation, or something else. It is unknown how a reduced value of the residual stress could ‘simulate’ anything. Any application of prior art is the Examiner’s best interpretation of the claimed subject matter.
Claims 2-7 are rejected by virtue of their dependency.
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 1-7 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. To determine if a claim is directed to patent ineligible subject matter, the Court has guided the Office to apply the Alice/Mayo test, which requires:
1. Determining if the claim falls within a statutory category;
2A. Determining if the claim is directed to a patent ineligible judicial exception consisting of a law of
nature, a natural phenomenon, or abstract idea; and
2B. If the claim is directed to a judicial exception, determining if the claim recites limitations or elements
that amount to significantly more than the judicial exception.(See MPEP 2106).
Step 1: With respect to claims 1-7, applying step 1, the preamble of independent claim 1 claims a method. As such these claims fall within the statutory category of process.
Step 2A, prong one: In order to apply step 2A, a recitation of claim 1 is copied below. The limitations of the claim that describe an abstract idea are bolded.
A shape change prediction method for a press formed part for predicting a shape change of the press formed part over time the shape change occurring after springback upon release from a press-forming die (mental process – observation, evaluation, judgement, opinion), the shape change prediction method comprising:
acquiring a shape and a residual stress of the press formed part immediately after the springback by performing a springback analysis of the press formed part;
for at least a part of bent portions in the press formed part immediately after the springback, a reduced value of the residual stress to simulate stress relaxation of the press formed part over time (mental process – observation, evaluation, judgement, opinion); and
determining, based on the reduced value of the residual stress set in the bent portions, a shape of the press formed part after a lapse of a predetermined time in which moments of force are balanced (mental process – observation, evaluation, judgement, opinion).
The limitations as analyzed include concepts directed to the "mental process" groupings
of abstract ideas performed in the human mind (including an observation, evaluation,
judgment, opinion) (see MPEP § 2106.04(a)(2), subsection III). The claim involves acquiring data and determining. The second recited limitation of claim 1 is written such that it is unclear what is taking place and there appears to be no verb recited for the method step. For the purposes of examination ‘to simulate stress relaxation’ is interpreted as a mental process. The steps are simple enough/broadly claimed that they could be performed mentally or with pen and paper. Thus, limitations noted above also fall into the "mental process" groupings of abstract ideas.
Step 2A, prong two: Under step 2A prong two, this judicial exception is not integrated
into a practical application because the additional claim limitations outside the abstract idea
only present insignificant extra-solution activity. In particular, the claim recites the additional limitations: “acquiring a shape and a residual stress of the press formed part immediately after the springback by performing a springback analysis of the press formed part” (insignificant extra-solution activity - mere data gathering/output MPEP 2106.05(g))
Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Step 2B: Moving on to step 2B of the analysis, the Examiner must consider whether each claim limitation individually or as an ordered combination amounts to significantly more than the abstract idea. This analysis includes determining whether an inventive concept is furnished by an element or a combination of elements that are beyond the judicial exception. For limitations that were categorized as "apply it" or generally linking the use of the abstract idea to a particular technological environment or field of use, the analysis is the same. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitations is considered directed towards data gathering. See MPEP 2106.04(d) referencing MPEP 2106.05(h). Furthermore, as Berkheimer evidence that the claim elements “acquiring a shape and a residual stress of the press formed part immediately after the springback by performing a springback analysis of the press formed part” are Well-Understood, Routine, and Conventional, MPEP § 2106.05(d) (II) provides support that mere data collecting is well understood, routine, and conventional: "The courts have recognized the following computer functions as well- understood, routine, and conventional functions when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra- solution activity:
• Receiving or transmitting data over a network, e.g., using the Internet to gather
data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary
computer to forward information); TLI Communications LLC v. AV Auto. LLC, 823 F.3d
607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016) (using a telephone for image
transmission); OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d
1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google,
Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives
and sends information over a network); but see DDR Holdings, LLC v. Hotels.com, L.P.,
773 F.3d 1245, 1258, 113 USPQ2d 1097, 1106 (Fed. Cir. 2014)
• 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
• Presenting offers and gathering statistics, OIP Techs., 788 F.3d at 1362-63, 115
USPQ2d at 1092-93
For the foregoing reasons, claim 1 is directed to an abstract idea without significantly more, and is rejected as not patent eligible under 35 U.S.C. 101. The same conclusion is reached for the dependent claims 2-7.
Claims 2-7 are further directed towards concepts directed to the "mental process" groupings of abstract ideas performed in the human mind (including an observation, evaluation, judgment, opinion) (see MPEP § 2106.04(a)(2), subsection III). The steps are simple enough/broadly claimed that they could be performed mentally or with pen and paper. Thus, limitations noted above also fall into the "mental process" groupings of abstract ideas. This judicial exception is not integrated into a practical application because the additional claim limitations outside the abstract idea only present generic computing components merely carrying out the abstract idea (see MPEP § 2106.05(f) and (b)). In particular, the claim recites the additional limitations: “wherein the springback analysis is performed by finite element simulation”. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional limitation is considered directed towards generic computing components for carrying out the abstract idea.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1 and 7 are rejected under 35 U.S.C. 103 as being unpatentable over US 20150039247 A1 (“Minote”) in view of US 20110246150 A1 (“Miyagi”).
Regarding claim 1, Minote teaches:
A shape change prediction method for a press formed part for predicting a shape change of the press formed part over time the shape change occurring after springback upon release from a press-forming die (Minote: Abstract), the shape change prediction method comprising:
acquiring a shape and a residual stress of the press formed part immediately after the springback by performing a springback analysis of the press formed part (Minote: para [0054], “The springback analyzing unit 15 acquires shape information, a temperature distribution, a stress distribution, a strain distribution, and the like of the press-formed product after springback by performing a springback analysis of the press-forming metallic sheet based on the information acquired by the press forming analyzing unit 13”; para [0056], “The cooling stress analyzing unit 17 can then acquire the residual stress thus accumulated as a stress distribution”);
for at least a part of bent portions in the press formed part immediately after the springback, a reduced value of the residual stress to simulate stress relaxation of the press formed part over time (Minote: para [0016], “a springback analysis is conducted by releasing a stress in a specific one of the regions thus divided sequentially”; para [0122], “we were able to confirm that the defective formation was reduced based on the simulation”; para [0071], “Specifically, when a springback analysis is performed considering the contact heat transfer between the mold and the press-forming metallic sheet, the springback analyzing unit 15 simulates mold release by restraining one or more nodes in the press-forming metallic sheet so as not to move, and then moving the mold”; para [0073], “so that the press-forming metallic sheet does not move, and releasing a stress at the bottom dead point. At this time, the springback analyzing unit 15 assumes that the time for which the stress is released is a constant time.); and
determining, based on the reduced value of the residual stress set in the bent portions, a shape of the press formed part after a lapse of a predetermined time (Minote: para [0017], “A press-forming analysis method that can predict the shape after the cooling process simply and appropriately and that can identify the cause of a defective formation in the warm press forming is provided”; para [0070], “Therefore, the residual stress distribution that is acquired at the step of analyzing cooling stress (S5), which will be explained later, can be acquired more precisely”; para [0078] It is preferable for the cooling stress analyzing unit 17 to conduct the cooling stress analysis after ensuring a sufficient cooling time until the temperature distribution falls within .+-.5 degrees Celsius, or preferably within .+-.1 degrees Celsius”; the cooling process takes ‘a predetermined time’).
Minote does not teach but Miyagi does teach:
determining a shape of the press formed part in which moments of force are balanced (Miyagi: para [0103], “The shifting of the fixed points may allow a viewer to determine whether the product seems to be warped because of its designated shape or because it is actually warped.”; para [0107], “The springback amount was 3.75 degrees with the moment force component of, for example, the area 1101 being set to zero”).
Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Minote (directed to shape change prediction) and Miyagi (directed to balancing moments of force) and arrived at shape change prediction with balancing moments of force. One of ordinary skill in the art would have been motivated to make such a combination for “analyzing a cause of springback in a formed product that is press-formed from a steel plate or other metal plates into parts of automobiles or household appliances” (Miyagi: para [0001]).
Regarding claim 7, Minote, Miyagi and Yoshida teach:
The shape change prediction method for a press formed part according to claim 1, wherein the springback analysis is performed by a finite element method simulation (Minote: para [0003], “Such springback is known to be caused by a residual stress residing in the press-formed product before the mold release, and a numerical analysis such as finite element method has been conventionally used to predict the shape after springback and to analyze the cause of the springback”; para[0009], “To investigate defective formation of a warm press-formed high strength steel sheet, we used a finite element method to conduct a springback analysis on a product after the mold release”).
Claims 2-6 are rejected under 35 U.S.C. 103 as being unpatentable over US 20150039247 A1 (“Minote”) in view of US 20110246150 A1 (“Miyagi”) further in view of US 20100005845 A1 (“Yoshida”).
Regarding claim 2, Minote and Miyagi do not teach but Yoshida does teach:
The shape change prediction method for a press formed part according to claim 1, wherein the press formed part includes a top portion and side wall portions and the bent portions include punch shoulders configured to connect the top portion and the side wall portions (Yoshida: para [0151], “Here, if calculating the maximum curvature of each element and displaying blank elements with a curvature of over a certain threshold value, it becomes possible to judge and separate locations other than the punch shoulder R or die shoulder R (web, vertical walls, flanges) as unconnected separate regions”; paras [0150], [0153], [0156], [0266]).
Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Minote and Miyagi (directed to shape change prediction) and Yoshida (directed to punch shoulders) and arrived at shape change prediction including punch shoulders. One of ordinary skill in the art would have been motivated to make such a combination “using numerical analysis to identify a location becoming a cause of occurrence of springback of a press formed product and numerically analyzing a property of that identified location so as to efficiently and economically shorten the time for studying a method of forming a formed member” (Yoshida: para [0012]).
Regarding claim 3, Minote and Miyagi do not teach but Yoshida does teach:
The shape change prediction method for a press formed part according to claim 1, wherein the press formed part includes a top portion, side wall portions and flange portions, and the bent portions include punch shoulders configured to connect the top portion and the side wall portions and/or die shoulders configured to connect the side wall portions and the flange portions (Yoshida: para [0151], “Here, if calculating the maximum curvature of each element and displaying blank elements with a curvature of over a certain threshold value, it becomes possible to judge and separate locations other than the punch shoulder R or die shoulder R (web, vertical walls, flanges) as unconnected separate regions”; paras [0150], [0153], [0156], [0266]).
Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Minote and Miyagi (directed to shape change prediction) and Yoshida (directed to punch shoulders) and arrived at shape change prediction including punch shoulders. One of ordinary skill in the art would have been motivated to make such a combination “using numerical analysis to identify a location becoming a cause of occurrence of springback of a press formed product and numerically analyzing a property of that identified location so as to efficiently and economically shorten the time for studying a method of forming a formed member” (Yoshida: para [0012]).
Regarding claim 4, Minote and Miyagi do not teach but Yoshida does teach:
The shape change prediction method for a press formed part according to claim 1, wherein a blank used for the press forming of the press formed part is a metal sheet having a tensile strength of 150 MPa or higher and 2000 MPa or lower (Yoshida: para [0268], “The forming conditions used were data of high strength steel sheet having, as properties of the metal plate, a sheet thickness of 1.6 mm and a tensile strength of the 780 MPa class.”).
Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Minote and Miyagi (directed to shape change prediction) and Yoshida (directed to tensile strength between 150-2000 MPa) and arrived at shape change prediction including tensile strength between 150-2000 MPa. One of ordinary skill in the art would have been motivated to make such a combination “using numerical analysis to identify a location becoming a cause of occurrence of springback of a press formed product and numerically analyzing a property of that identified location so as to efficiently and economically shorten the time for studying a method of forming a formed member” (Yoshida: para [0012]).
Regarding claim 5, Minote and Miyagi do not teach but Yoshida does teach:
The shape change prediction method for a press formed part according to claim 2, wherein a blank used for the press forming of the press formed part is a metal sheet having a tensile strength of 150 MPa or higher and 2000 MPa or lower (Yoshida: para [0268], “The forming conditions used were data of high strength steel sheet having, as properties of the metal plate, a sheet thickness of 1.6 mm and a tensile strength of the 780 MPa class.”).
Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Minote and Miyagi (directed to shape change prediction) and Yoshida (directed to tensile strength between 150-2000 MPa) and arrived at shape change prediction including tensile strength between 150-2000 MPa. One of ordinary skill in the art would have been motivated to make such a combination “using numerical analysis to identify a location becoming a cause of occurrence of springback of a press formed product and numerically analyzing a property of that identified location so as to efficiently and economically shorten the time for studying a method of forming a formed member” (Yoshida: para [0012]).
Regarding claim 6, Minote and Miyagi do not teach but Yoshida does teach:
The shape change prediction method for a press formed part according to claim 3, wherein a blank used for the press forming of the press formed part is a metal sheet having a tensile strength of 150 MPa or higher and 2000 MPa or lower (Yoshida: para [0268], “The forming conditions used were data of high strength steel sheet having, as properties of the metal plate, a sheet thickness of 1.6 mm and a tensile strength of the 780 MPa class.”).
Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Minote and Miyagi (directed to shape change prediction) and Yoshida (directed to tensile strength between 150-2000 MPa) and arrived at shape change prediction including tensile strength between 150-2000 MPa. One of ordinary skill in the art would have been motivated to make such a combination “using numerical analysis to identify a location becoming a cause of occurrence of springback of a press formed product and numerically analyzing a property of that identified location so as to efficiently and economically shorten the time for studying a method of forming a formed member” (Yoshida: para [0012]).
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 NITHYA J. MOLL whose telephone number is (571)270-1003. The examiner can normally be reached Monday-Friday 10am-6pm EST.
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/NITHYA J. MOLL/Primary Examiner, Art Unit 2189
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