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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 7 April 2026 has been entered.
Introductory Remarks
In response to communications filed on 7 April 2026, claims 1 and 13 are amended per Applicant's request. Claims 2-8 and 11-12 are cancelled. No claims were withdrawn. No new claims were added. Therefore, claims 1, 9-10, and 13 are presently pending in the application, of which claims 1 and 13 are presented in independent form.
The previously raised 101 rejection of the pending claims is maintained.
The previously raised 103 rejection of the pending claims is withdrawn in view of the amendments to the claims.
Response to Arguments
Applicant’s arguments filed 7 April 2026 with respect to the rejection of the claims under 35 U.S.C. 101 (see Remarks, p. 6-7) have been fully considered but are not persuasive.
Applicant argues in Remarks, p. 6-7 that the claims are not directed to mental processes, as Claim 1 recites outputting certain information, that the claims cannot be classified under any of the three categories for a possible “abstract idea”. However, this is unpersuasive, as the claims merely recite associating certain information together (which is a basic learning concept that can certainly be performed mentally), and “outputting” images conveying that same associated information, which can be drawn out by a person, e.g., as a diagram.
The most that the claims recite is the use of a computer to automatically perform these functions of associating information together, and outputting the information, as well as “enabling” or “prohibiting” updating of stored information. However, these are some of the most basic functions of computers, e.g., electronic recordkeeping (e.g., associating information together); storing and retrieving data from memory (e.g., to be used in generating the images); and performing updating of the information in memory (both electronic recordkeeping and storing and retrieving data from memory).
Therefore, Applicant’s argument that the claims, in combination, are directed to a “practical application”, is unpersuasive. The test for whether claims are directed to a practical application rests on whether there is significantly more to the claims. However, these steps of performing storing, (retrieving and) outputting, and updating data steps, are insignificant extra-solution activities which are well-understood, routine, and conventional activities (i.e., the most basic functions of a computer), as argued above.
Because the claims only recite the abstract idea (e.g., associating information together, drawing out the claimed images, and updating the corresponding information) and add the words “apply it” with a computer, such steps do not integrate a judicial exception into a practical application.
See, e.g., MEPP § 2106.04(d) (I) (“The courts have also identified limitations that did not integrate a judicial exception into a practical application: Merely reciting the words ‘apply it’ (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea…”).
Attempting to narrow these steps to the use of a graphical user interface and touch panel, do nothing more than attempt to limit the claims to a particular technological field (i.e., implementation via computers), and thus are nothing more than an insignificant field-of-use limitation, describing the context rather than a particular manner of achieving the result.
See, e.g., Intellectual Ventures I LLC v. Erie Indemnity Co., 850 F.3d 1315, 121 USPQ2d 1928 (Fed. Cir. 2017) at p. 24 (“Remotely accessing and retrieving user-specified information is an age-old practice that existed well before the advent of computers and the Internet…. the claimed invention does not recite any particular unique delivery of information through this mobile interface. Rather, it merely recites retrieving the information through the mobile interface. Nor do the claims describe how the mobile interface communicates with other devices or any attributes of the mobile interface, aside from its broadly recited function. Thus, the mobile interface here does little more than provide a generic technological environment to allow users to access information. And as we have previously observed, ‘[a]n abstract idea does not become nonabstract by limiting the invention to a particular field of use or technological environment, such as the Internet…”).
Thus, for at least the aforementioned reasons and those set forth in the 101 rejection below, the 101 rejection has been maintained.
Applicant’s arguments filed 7 April 2026 with respect to the rejection of the claims under 35 U.S.C. 103 (see Remarks, p. 8-10) have been fully considered and are persuasive. None of the prior art appeared to teach, suggest, or otherwise render obvious the combination of independent claims’ limitations, and the prior art rejections have been accordingly withdrawn.
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, 9-10, and 13 are rejected under 35 U.S.C. 101 because the claims are directed to a judicial exception (i.e., an abstract idea) without significantly more.
Step 1
Claim 1 recites “A data management device” comprising a storage device and a processor. Claim 13 recites “A data management method”. Each claim is directed to a statutory category.
Step 2A, Prong One
Independent claims 1 and 13 recite a set of data defined as a data group, one being defined as a reference data group, the data group managed in association being defined as an association data group, and one is defined as a derivative data group. These involve associating data, and thus encompass an evaluation, observation, and/or judgment, which falls under the “Mental Processes” grouping of abstract ideas (e.g., one can mentally observe or evaluate by grouping data into subsets based on their mutual dependencies and relationships).
The independent claims further recite determining whether the derivative data group is associated with each of the reference data groups. This encompasses an evaluation, observation, and/or judgment, which falls under the “Mental Processes” grouping of abstract ideas.
The independent claims further recite outputting images comprising various sorts of information, e.g., the first image including identification information identifying a specific reference data group, which is the reference data group with which the derivative data group is associated, the first image being a substrate image of the specific reference data group schematically indicating a state in which multiple components are mounted on the substrate and including character information identifying the specific reference data group; the second image including identification information identifying a normal reference data group, which is the reference data group with which the derivative data group is not associated, based on a determination result, the second image being a substrate image of the normal reference data group schematically indicating a state in which the multiple components are mounted on the substrate and including character information identifying the normal reference data group, with the first image being distinguishable from the second image. This is equivalent to a person drawing out such information with such labels / information, e.g., with aid of pen and paper, and thus falls under the “Mental Processes” grouping of abstract ideas.
Lastly, the independent claims recite determining enabling update processing using the difference data of the derivative data group, and prohibiting updating the data for a difference in the data caused by an individual difference of the component or an individual difference of a device used in the mounting process in accordance with certain detected conditions (i.e., the user’s behavioral interactions with the display). These encompass an evaluation, observation, and/or judgment, which falls under the “Mental Processes” grouping of abstract ideas.
Dependent claim 9 recites changing a display method according to at least one of a difference in display color, presence or absence of a marker, and a difference in an icon. Similarly, dependent claim 10 recites changing a display method in accordance with a difference in the data caused by an individual difference of the component or an individual difference of a device used in the mounting process, and a difference in the data caused by a factor other than the individual difference. These encompass an evaluation, observation, and/or judgment, which falls under the “Mental Processes” grouping of abstract ideas (e.g., drawing a different type of diagram, using different types of colors, etc., for presenting the image).
Because the claims cover performance of the limitation in the mind but for the recitation of generic computer components, the claims fall within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea.
Step 2A, Prong Two
The judicial exception is not integrated into a practical application of the idea.
The claims recite various computing hardware components (storage device, processor, substrate, display device, touch panel / input device1), which are recited at a high level of generality and recited so generically that they represent no more than mere instructions to apply the judicial exception on a computer (see MPEP 2106.05(f)). These limitations can also be viewed as nothing more than an attempt to generally link the use of the judicial exception to the technological environment of a computer (see MPEP 2106.05(h)).
Similarly, the use of an update button and return button in claims 1 and 13 are so generically recited that they do no more than attempt to limit the claims to the realm of graphical user interfaces, i.e., an attempt to generally link the use of the judicial exception to a particular technological environment.
Thus, the steps of a storage device including memory configured to store the information; and displaying/outputting the information stored in memory using a display device including a touch panel configured to serve as an input device, are insignificant extra-solution activities that also do no more than attempt to limit the claims to a particular technological environment (i.e., a computer).
Additionally, the independent claims recite that the difference data is correspondence data corresponding to the data of the reference data group that differs from the data of the reference data group; that the data group being component-related data including information about image processing of image data obtained by imaging the component, information about handling the component, and information about an imaging condition when imaging the component; and that the condition for determining whether to enable updating is predicated on the difference data of the derivative data group being selected using the touch panel of the display device and by selecting an update button on the display device; and prohibiting updating is predicated on not selecting the difference data or by selecting a return button on the display device, are nothing more than insignificant field-of-use limitations, describing the context rather than a particular manner of achieving the result.
As such, the additional elements do not integrate the abstract idea into a practical application of that idea.
Step 2B
With respect to the well-understood, routine, and conventional elements, as stated previously above, the claims do not include any additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to the integration of the abstract idea into a practical application, the additional elements reciting the use of various computing hardware components amount to no more than mere instructions to apply the judicial exception using generic components. Mere instructions to apply an exception using generic computer components cannot provide an inventive concept.
Additionally, with regards to the claims’ recitation of storing information and displaying/outputting data, are well-understood, routine, and conventional activities within the computing realm. See MPEP 2106.05(d)(II) (“Receiving or transmitting data over a network, e.g., using the Internet to gather data” and “Presenting offers and gathering statistics” with respect to the displaying/outputting steps; “Storing and retrieving data in memory” with respect to the “storing” data step; and “Electronic recordkeeping” with respect to the “storing” data step).
Ordered Combination
Even as an ordered combination, the claims as a whole do not contain any additional elements that amount to significantly more. The claims as a whole do nothing more than define various types of data groups, determine a relationship between the data groups (i.e., determine whether the derivative data group is associated with each of the multiple types of the reference data groups), and display the results of the determination as two images that are distinguishable from each other, while enabling/prohibiting updating.
As seen, a vast majority of these limitations correspond to mental processes. The other recited steps, e.g., of outputting images, changing display methods, etc., can be practically performed by a person in the mind, e.g., drawing out the image in the claimed manner. The rest of the claimed steps do nothing more than attempt to state the abstract idea while adding the words “apply it” with a computer, e.g., the use of graphical user interfaces and displays, touch panels, etc. However, these are insignificant field-of-use limitations, describing the context rather than a particular manner of achieving the result, and/or attempt to limit the claims to a particular technological field—namely, implementation via computers.
At this level of generality, the claims do no more than describe a desired function or outcome, without providing any limiting detail that confines the claims to a particular technical/computing solution to an identified problem. The purely functional nature of the claim confirms that it is directed to an abstract idea, not to a concrete embodiment of that idea (see Affinity Labs of Texas LLC v. Amazon.com Inc., 838 F.3d 1253 (Fed. Cir. 2016) at p. 7-8, citing Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350 (Fed. Cir. 2016), slip op. 12 (“[T]he essentially result-focused, functional character of claim language has been a frequent feature of claims held ineligible under § 101”)). As a whole, the claims do not go beyond stating the relevant functions in general terms, without limiting them to a technical means for performing the functions that are arguably an advance over conventional computing technologies.
Therefore, for at least the aforementioned reasons, the claims are rejected under 35 U.S.C. 101 for being directed to a judicial exception (i.e., an abstract idea) without significantly more.
Prior Art
The claims would be allowable over the prior art of record if the 35 U.S.C. 101 rejection was overcome. No prior art rejection is hereby presented, as no prior art was found to teach, suggest, or otherwise render obvious the combination of the independent claim limitations.
Relevant prior arts of record identified were:
Maenishi (US 2009/0204251 A1): disclosed determining a mounting condition by obtaining the mounting condition associated with the manufacturing operation from the specific apparatus and setting the mounting condition obtained in the obtaining for an apparatus other than the specific apparatus (Maenishi, [Abstract]). Each of the apparatuses belonged to one of the groups classified based on attributes of the apparatuses (see, e.g., Maenishi, [0033-0036]), e.g., similar to the claimed data groups. There may be cases where a certain component mounting apparatus obtains mounting conditions from a specific apparatus which is the same model as the apparatus itself, though the component mounting apparatus does not always perform the same operation as the one performed by the specific apparatus due to the individual differences between these apparatuses, or the differences in the positions of the structural elements arranged in the respective apparatuses (Maenishi, [0171]). In cases where the names of the items which can be set as mounting conditions are different, these apparatuses can absorb the difference in names used by the respectively different manufacturers, as long as one of these apparatuses has information about the conversion between different names (See, e.g., Maenishi, [0311-0319]).
Kuribayashi et al. (“Kuribayashi”) (US 6,002,650 A): disclosed forming mounting data, including reading component text data corresponding to to-be-mounted components of individual mounting positions stored in a component electronic catalog, according to mounting-position data including mounting angles relating to the mounting positions formed on the to-be-mounted components, by using the component electronic catalog that has stored image data concerning various types of components including the to-be-mounted components as well as component text data necessary for component mounting including configurations and dimensions of the components (see, e.g., Kuribayashi, [Abstract]). Thus, Kuribayashi is similar to the claimed data group and reference data group.
Kuribayashi et al. (“Kuribayashi-II”) (US 6,480,751 B1): disclosed component arrangement data group (e.g., similar to the claimed association data group) comprising a plurality of component names including master component names (e.g., similar to the claimed reference data group) and substitute component names acceptable to be mounted in respective component supply positions (e.g., similar to the claimed derivative data group). However, Kuribayashi-II does not appear to at least disclose, suggest, or otherwise render obvious the outputting of the first and second images comprising the variously claimed information.
Ueda et al. (“Ueda”) (US 2010/0189340 A1): disclosed updating in-equipment component specific data which is input to a component library control unit 52, generated by a user operating an input unit, e.g., keyboard (Ueda, [0086]). The inspection information having a higher match rate is selected (see, e.g., Ueda, [0091]); thus, Ueda appears to be tangentially related to the claimed updating step.
However, as seen, none of the prior art appeared to teach, suggest, or otherwise render obvious the combination of the independent claims’ limitations. The dependent claims would be allowable over the prior art for at least by virtue of their dependency on independent claim 1.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to IRENE BAKER whose telephone number is (408)918-7601. The examiner can normally be reached M-F 8-5PM PT.
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/IRENE BAKER/Primary Examiner, Art Unit 2154
18 July 2026
1 Note that attempting to narrow the “input device” to a “touch panel” is an insignificant field-of-use limitation, describing the context rather than a particular manner of achieving the result.
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