DETAILED ACTION
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 8/17/2026 has been entered.
Claims 1-6, and 8 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 § 101
Applicant's arguments filed 7/14/2026 have been fully considered but they are not persuasive.
The claims have been amended to recite “performing a springback analysis of the press formed part by a finite element method simulation” and “setting…a reduced value of the residual stress … thereby simulating stress relaxation”. Finite element simulation is a general numerical method for solving partial differential equations in two- or three-space variables (i.e., some boundary value problems), which is mathematical modeling. Thus this limitation falls into the "Mathematical Concepts" groupings of abstract ideas. The claim also recites “determining, shape of the press formed part”. The determining step is simple enough/broadly claimed that it could be performed mentally or with pen and paper and drawing the shape of the press formed part. Thus, this limitation falls into the "mental process" groupings of abstract ideas
The rejection has been modified to reflect the amended claim language.
Response to Arguments- 35 USC § 103
Applicant's arguments filed 7/14/2026 have been fully considered but they are not persuasive.
Applicant argues on page 10 that “None of the passages of Minote cited in the Office Action teaches setting a reduced value of the residual stress from the acquired residual stress to simulate stress relaxation over time, or determining a shape of the press formed part after a lapse of a predetermined time based on such a reduced value.”
Minote teaches “setting a reduced value of the residual stress from the acquired residual stress to simulate stress relaxation over time” in paragraph [0094]: “The springback analyzing unit 15 then performs a springback analysis by setting the residual stress in the region b to zero and releasing the residual stress in the other regions, and by setting the residual stress in the region c to zero and releasing the residual stress in the other regions, in the same manner as described above, and calculates the respective deformation values”. Releasing and setting the residual stress to zero is reducing the residual stress from the acquired residual stress.
Minote teaches “determining a shape of the press formed part after a lapse of a predetermined time based on such a reduced value” in paragraph [0098]: “The residual
stress in a specific one of the regions thus divided is then set to zero, and the residual stress in the other regions is released. A springback analysis is then performed by comparing the shape of each of the regions after the springback from which the residual stress is released. This can clarify the residual stress in which region largely contributes to defective formation”. The shapes are compared based on the reduced residual value, which means the shapes are determined.
The rejection has been modified to reflect the amended claim language.
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 1-6 and 8 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 1-6 and 8, applying step 1, the preamble of independent claims 1 and 8 claim 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, 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 by a finite element method simulation (Mathematical concepts - Mathematical Calculation - MPEP
2106.04{a}{2}{1}{C} (i-vi);
setting, for at least a part of bent portions in the press formed part immediately after the springback, a reduced value of the residual stress from the acquired residual stress, thereby simulating stress relaxation of the press formed part over time (Mathematical concepts - Mathematical Calculation – MPEP 2106.04{a}{2}{1}{C} (i-vi)); 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 (mental process/drawing with pen and paper –observation, evaluation, judgement, opinion).
The limitation 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 determining. The determining step is simple enough/broadly claimed that it could be performed mentally or with pen and paper and drawing the shape of the press formed part. Thus, limitation noted above falls into the "mental process" groupings of abstract ideas.
The limitations as analyzed include concepts directed to the "Mathematical Concepts"
grouping of abstract ideas (including mathematical relationships, mathematical formulas or
equations, mathematical calculations) (see MPEP § 2106.04(a)(2), subsection I). A mathematical calculation is a mathematical operation (such as multiplication) or an act of calculating using mathematical methods to determine a variable or number, e.g., performing an arithmetic operation such as exponentiation (see MPEP 2106.04(a)(2)(1)(C). Finite element simulation is a general numerical method for solving partial differential equations in two- or three-space variables (i.e., some boundary value problems), which is mathematical modeling. Thus, limitations noted above also fall into the "Mathematical Concepts" 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: “acquiring a shape and a residual stress of the press formed part immediately after the springback” (insignificant extra-solution activity - mere data gathering 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 and output. 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” are Well-Understood, Routine, and Conventional, MPEP § 2106.05(d) (II) provides support that mere data collecting and data outputting 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. Independent claim 8 is directed to substantially the same subject matter as independent claim 1 and is rejected under similar rationale and further failure to add significantly more. The same conclusion is reached for the dependent claims 2-6.
Regarding claims 2-6, under step 2A prong two the judicial exceptions are not integrated into a practical application because the additional claim limitations outside the abstract idea only present general field of use. In particular, the claims recite the specific form of the press formed part undergoing simulation analysis. 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 limitations are considered directed towards general field of use.
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 8 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 by a finite element method simulation (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 [0070], “because the springback analyzing unit 15 can consider the temperature change caused by mold release more precisely, the temperature distribution in the press-forming metallic sheet after springback can be acquired more precisely. 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 [0081] “the press-forming analyzing apparatus 1 can acquire a thermal stress caused by a temperature distribution in a heated press-forming metallic sheet after springback as a residual stress distribution”; para [0009], “we used a finite element method to conduct a springback analysis on a product after the mold release.”);
setting, for at least a part of bent portions in the press formed part immediately after the springback, a reduced value of the residual stress from the acquired residual stress, thereby simulating stress relaxation of the press formed part over time (Minote: [0094] “The springback analyzing unit 15 then performs a springback analysis by setting the residual stress in the region b to zero and releasing the residual stress in the other regions, and by setting the residual stress in the region c to zero and releasing the residual stress in the other regions, in the same manner as described above, and calculates the respective deformation values”; para [0122], “we were able to confirm that the defective formation was reduced based on the simulation”; para [0009], “we used a finite element method to conduct a springback analysis on a product after the mold release”); 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: [0098], “The residual stress in a specific one of the regions thus divided is then set to zero, and the residual stress in the other regions is released. A springback analysis is then performed by comparing the shape of each of the regions after the springback from which the residual stress is released. This can clarify the residual stress in which region largely contributes to defective formation”).
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 8, 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, by a finite element method simulation, 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 [0070], “because the springback analyzing unit 15 can consider the temperature change caused by mold release more precisely, the temperature distribution in the press-forming metallic sheet after springback can be acquired more precisely. 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 [0081] “the press-forming analyzing apparatus 1 can acquire a thermal stress caused by a temperature distribution in a heated press-forming metallic sheet after springback as a residual stress distribution”; para [0009], “we used a finite element method to conduct a springback analysis on a product after the mold release”);
setting, for at least a part of bent portions in the press formed part immediately after
the springback, a reduced value of the residual stress, the reduced value being reduced from
the residual stress acquired by the springback analysis, and the setting of the reduced value
simulating stress relaxation of the press formed part over time (Minote: [0094] “The springback analyzing unit 15 then performs a springback analysis by setting the residual stress in the region b to zero and releasing the residual stress in the other regions, and by setting the residual stress in the region c to zero and releasing the residual stress in the other regions, in the same manner as described above, and calculates the respective deformation values”; para [0122], “we were able to confirm that the defective formation was reduced based on the simulation”; para [0009], “we used a finite element method to conduct a springback analysis on a product after the mold release”); and
determining, by the finite element method simulation and based on the reduced value
of the residual stress set in the bent portions, a shape of the press formed part, the determined shape being a shape of the press formed part after a lapse of a predetermined time (Minote: [0098], “The residual stress in a specific one of the regions thus divided is then set to zero, and the residual stress in the other regions is released. A springback analysis is then performed by comparing the shape of each of the regions after the springback from which the residual stress is released. This can clarify the residual stress in which region largely contributes to defective formation”).
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]).
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
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/NITHYA J. MOLL/Primary Examiner, Art Unit 2189
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