DETAILED ACTION
This action is responsive to the RCE filed on 12/26/2025.
In the instant application, Claim 1 is an amended independent claim; Claims 1-13 have been examined and are pending. This action is made non-final.
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first invent or 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 12/26/2025 has been entered.
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 1-13 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Claims 1-13 recite a display unit, which is within the statutory class of a machine.
Claims are eligible for patent protection under § 101 if they are in one of the four statutory categories and not directed to a judicial exception to patentability. Alice Corp. v. CLS Bank Int'l, 573 U.S. 208 (2014).
Claims 1-13, each considered as a whole and as an ordered combination, are directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 2A – Prong 1
Claim 1 recites:
A display unit possessed by a management system that manages energy, wherein plural pieces of information in the management system including power load information, received power information, generated power information, heat load information, and heat output information are displayed on a single screen.
The limitations of “wherein plural pieces of information in the management system including power load information, received power information, generated power information, heat load information, and heat output information are displayed on a single screen” as presently drafted, under the broadest reasonable interpretation, The concept described in claim 1 is not meaningfully different than those ‘idea itself’ concepts found by the courts to be abstract ideas, such as in Electric Power Group (collecting information, analyzing it, and displaying certain results is an abstract idea, even when limited to specific content), Int. Ventures v. Cap One Financial (collecting, displaying, and manipulating data. As such, the description in claim 1 of “collecting, analyzing and displaying activity information” is an abstract idea, particularly as the nature of the information being displayed is not relevant to the determination of eligibility (all information is intangible).
The claimed user interface elements (various representations of data) do not describe an improved user interface for interacting with the device, merely a user interface for displaying the information. As such, the limitations of claim 1 is abstract idea.
Step 2A – Prong 2
This judicial exception is not integrated into a practical application because there are no meaningful limitations that transform the exception into a patent eligible application. The additional elements (management system that manage energy) merely amount to instructions to apply the exception using generic computer components (a “management system”— which is recited at a high level of generality). This also does not serve to integrate the abstract idea into a practical application as it merely amounts to displaying information or "apply it." (See MPEP 2106.04(d)(2) indicating mere instructions to apply an abstract idea does not amount to integrating the abstract idea into a practical application). Accordingly, the additional elements do not integrate the abstract idea into a practical application because they do not impose meaningful limits on practicing the abstract idea. Therefore, the claim is directed to an abstract idea.
The claims only manipulate abstract data elements into another form. They do not set forth improvements to another technological field or the functioning of the computer itself and instead use computer elements as tools in a conventional way to improve the functioning of the abstract idea identified above. Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. None of the additional elements recited "offers a meaningful limitation beyond generally linking 'the use of the [method] to a particular technological environment,' that is, implementation via computers." Alice Corp., slip op. at 16 (citing Bilski v. Kappos, 561 U.S. 610, 611 (U.S. 2010)).
MPEP 2106 Step 2B:
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception for the same reasons as presented in Step 2A Prong 2. Moreover, the additional elements recited are known and conventional generic computing elements (“management system”, “display unit”, describing the various components as general purpose, common, standard, known to one of ordinary skill, and at a high level of generality, and in a manner that indicates that the additional elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy the statutory disclosure requirements). Therefore, these additional elements amount to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept that amounts to significantly more. See MPEP 2106.05(f).
The Federal Circuit has recognized that "an invocation of already-available computers that are not themselves plausibly asserted to be an advance, for use in carrying out improved mathematical calculations, amounts to a recitation of what is 'well-understood, routine, [and] conventional.'" SAP Am., Inc. v. InvestPic, LLC, 890 F.3d 1016, 1023 (Fed. Cir. 2018) (alteration in original) (citing Mayo v. Prometheus, 566 U.S. 66, 73 (2012)). Apart from the instructions to implement the abstract idea, they only serve to perform well-understood functions (e.g., receiving, translating, and displaying data—see Specification above as well as Alice Corp.; Intellectual Ventures I LLC v. Symantec Corp., 838 F.3d 1307 (Fed. Cir. 2016); and Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015) covering the well-known nature of these computer functions).
Regarding dependent claims 2-13 are dependent on claim 1. Therefore, claims 2-13 recite the same abstract idea of processing information. The claims recite additional elements including:
Information being displayed in separate areas (claim 2).
Information being displayed from different collected periods (3).
Displaying numerical information and graph information 4).
Displaying today’s information and the previous day’s information (5).
Displaying a bar graph including the today’s information and the previous day’s information (6).
Displaying various collected information (7-13).
These limitations describe the abstract concept which correspond to concepts identified as abstract ideas by the courts, such as in Electric Power Group (collecting information, analyzing it, and displaying certain results is an abstract idea, even when limited to specific content);
Claims 2-13 are therefore not drawn to eligible subject matter as they are directed to an abstract idea without significantly more.
Claims 1-13 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claims do not fall within at least one of the four categories of patent eligible subject matter.
With respect to claims 1-13, a “display unit possessed by a management system that manages energy” is being recited. All that included in the unit is the management system that does not includes any hardware component for it to be limited to hardware. As such, the display unit is reasonably interpreted as functional descriptive material, per se. The functional descriptive material are nonstatutory when claimed as descriptive material per se, 33 F.3d at 1360, 31 USPQ2d at 1759.
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 of this title, 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned at the time any inventions covered therein were effectively filed absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned at the time a later invention was effectively filed in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claims 1-5 and 9 are rejected under 35 U.S.C. 103 as being unpatentable over Chen et al. (“Chen,” US 2016/0313716), published on October 27, 2016 in view of YOSHIMOTO et al. (“Yoshimoto,” US 2019/0148946), published on May 16, 2019.
Regarding claim 1, Chen teaches a display unit possessed by a management system that manages energy (Chen: ¶0041 and Fig. 3; user interface layout 300 for monitoring status and controlling operation of the MGMS 120 “microgrid management system”), wherein plural pieces of information in the management system including power load information (Chen: ¶0047 and Fig. 3; a load details window 314 can include a graphical display depicting the relative amount of energy various loads within the microgrid are consuming as well as the relative amount being contributed to the external macrogrid), [received power information], generated power information (Chen: ¶0048 and Fig. 3; a generation details window 316 can include a graphic display depicting the relative amount of energy various resources within the microgrid and contributing as well as the relative contribution of the external macrogrid), [heat load information and heat output information] are displayed on a single screen (Chen: ¶0041 and Fig. 3; user interface layout 300 for monitoring status and controlling operation of the MGMS 120. Note: information related to microgrid are displayed on the microgrid dashboard. ¶0040 and Fig. 3; numerous additional or alternative windows can be provided to allow monitoring and control of various parameters of the MGMS 120. The example windows depicted in Fig. 3 and the sample data displayed therein are merely illustrative of some the type information and controls that can provided).
Chen does not explicitly teach wherein plural pieces of information in the management system including received power information, heat load information and heat output information instruction.
However Yoshimoto teaches an energy management system; wherein plural pieces of information in the management system including received power information, heat load information and heat output information instruction (Yoshimoto: ¶0048 and Fig. 3; the display part 600 has a function that displays electric power generation data 601 and heat storage data 602 and a received electric power display part 603).
Both references are directed to energy/power management systems and are in the same field of endeavor of the claimed invention. Even though both Chen and Yoshimoto do not teach all the pieces of information claimed in claim 1, the pieces of information are associated with non-functional descriptive material which do not carry any patentable weight since the displaying of non-functional descriptive material does not change the displaying function of Chen and/or Yoshimoto (see MPEP 2111.05(I)(B) “no new feature of physical structure and no new relation of printed matter to physical structure”). Furthermore, Chen teaches that other information may be displayed in the microgrid dashboard (Chen: ¶0041 and Fig. 3; user interface layout 300 for monitoring status and controlling operation of the MGMS 120. Note: information related to microgrid are displayed on the microgrid dashboard. ¶0040 and Fig. 3; numerous additional or alternative windows can be provided to allow monitoring and control of various parameters of the MGMS 120. The example windows depicted in Fig. 3 and the sample data displayed therein are merely illustrative of some the type information and controls that can provided).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Yoshimoto and Chen in front of them to include the energy management system as disclosed by Yoshimoto with the microgrid management system of Chen to effectively uses a solar power generation system and a solar heat collection system and that can hence maximize a cross merit of a user (Yoshimoto: ¶0008).
Regarding claim 2, Chen and Yoshimoto teach the display unit of claim 1,
Chen and Yoshimoto further teach: wherein the plural pieces of the information related to the power and the heat are displayed in respectively separate areas on the single screen (Chen: ¶0041 and Fig. 3; user interface layout 300 includes separate areas for displaying information).
Regarding claim 3, Chen and Yoshimoto teach the display unit of claim 2,
Chen and Yoshimoto further teach: wherein at least one of the plural areas displays plural types of information with different collection periods (Yoshimoto: ¶0048 and Fig. 3; electric power generation data 601 and heat storage data 602 and a received electric power display part 603 are displayed in separate areas. They all have different collection periods).
Regarding claim 4, Chen and Yoshimoto teach the display unit of claim 2,
Chen and Yoshimoto further teach: wherein an area of the areas displays numerical information and graph information (Chen: ¶0041 and Fig. 3; information are displayed in numerical information and graph information).
Regarding claim 5, Chen and Yoshimoto teach the display unit of claim 3,
Chen and Yoshimoto further teach: wherein the plural types of the information include today's information and previous day's information (Yoshimoto: ¶0048 and Fig. 3; electric power generation data 601 and heat storage data 602 are displayed with data from Today and Yesterday).
Regarding claim 9, Chen and Yoshimoto teach the display unit of claim 2,
Chen and Yoshimoto also teach: wherein at least one of the plural areas is capable of displaying a graph, which shows a breakdown of an energy source, in a manner to be switched with other information (Chen: ¶0047 and Fig. 3; a load details window 314 can include a graphical display depicting the relative amount of energy various loads within the microgrid are consuming as well as the relative amount being contributed to the external macrogrid. ¶0048 and Fig. 3; a generation details window 316 can include a graphic display depicting the relative amount of energy various resources within the microgrid and contributing as well as the relative contribution of the external macrogrid).
Claims 6 and 10-13 are rejected under 35 U.S.C. 103 as being unpatentable over Chen and Yoshimoto as applied to claim 1 above and further in view of Shah et al. (“Shah,” US 2017/0212668), published on July 27, 2017.
Regarding claim 6, Chen and Yoshimoto teach the display unit of claim 5,
Chen and Yoshimoto do not appear to teach: wherein an area of the areas displays a bar graph including the today's information and the previous day's information.
However Shah teaches a building energy management system; wherein an area of the areas displays a bar graph including the today's information and the previous day's information (Shah: ¶0250 and Fig. 19; the total energy use of the facility may be summed over a variety of different intervals by selecting time intervals of one week, one month, three months , six months, one year, or a custom time interval as shown in Fig. 21. ¶0264 and Fig. 29; a bar chart 2902 indicates energy consumption between two consecutive days).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Shah, Chen and Yoshimoto in front of them to include the feature of selecting time interval for displaying collected data disclosed by Shah with the microgrid management system of Chen to provide improved and easy-to use interfaces allowing users to view energy consumption data at any level of granularity and that the user can transition between different time intervals (Shah: ¶0264).
Regarding claim 10, Chen and Yoshimoto teach the display unit of claim 2,
Chen and Yoshimoto do not explicitly teach: wherein the plural pieces of the information related to the power and the heat further include used fuel volume information showing used fuel volume in the management system.
However Shah teaches a building energy management system; wherein the plural pieces of the information related to the power and the heat further include used fuel volume information showing used fuel volume in the management system (Shah: ¶0255-0256 and Figs. 22-23; gas consumption may be indicated in both units of energy and units of volume. Energy consumption tracker displays energy consumption data such as electricity, gas, steam, BTU, Propane, Fuel, Diesel).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Shah, Chen and Yoshimoto in front of them to include the feature of selecting time interval for displaying collected data disclosed by Shah with the microgrid management system of Chen to provide improved and easy-to use interfaces allowing users to view energy consumption data at any level of granularity and that the user can transition between different time intervals (Shah: ¶0264).
Regarding claim 11, Chen, Yoshimoto and Shah teach the display unit of claim 10,
Chen, Yoshimoto and Shah further teach: wherein an area of the areas displaying the used fuel volume information is displayable in a manner to switch information for each type of the fuel (Shah: ¶0255 and Fig. 22; selecting over a bar 1942, 1944, 1946, or 1948 for a particular commodity in chart 1938 may display a pop-up 2200 that indicates the amount of the commodity consumed by the corresponding facility during the user-selected time interval).
Regarding claim 12, Chen and Yoshimoto teach the display unit of claim 1,
Chen and Yoshimoto do not appear to teach: wherein the plural pieces of the information related to the power and the heat further include at least one of energy consumption information showing energy consumption in the management system, and carbon dioxide emission volume information showing carbon dioxide emission volume in the management system.
However Shah teaches a building energy management system; wherein the plural pieces of the information related to the power and the heat further include at least one of energy consumption information showing energy consumption in the management system, and carbon dioxide emission volume information showing carbon dioxide emission volume in the management system (Shah: ¶0258 and Fig. 26; when building 2602 is selected, EUI chart 1918 and energy consumption tracker 1922 may display energy consumption data for the selected building 2602 and CO2 Emission).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Shah, Chen and Yoshimoto in front of them to include the feature of selecting time intervals for displaying collected data disclosed by Shah with the microgrid management system of Chen to provide improved and easy-to use interfaces allowing users to view energy consumption data at any level of granularity and that the user can transition between different time intervals (Shah: ¶0264).
Regarding claim 13, Chen and Yoshimoto teach the display unit of claim 2,
Chen and Yoshimoto do not explicitly teach: wherein the single screen further includes a control state display area showing a control state of the management system.
However Shah teaches a building energy management system; wherein the single screen further includes a control state display area showing a control state of the management system (Shah: ¶0258 and Fig. 26; selecting a particular facility 1914 or 1916 via portfolio tab 1910 may cause overview dashboard 1900 to display energy related data for the selected facility 1914 or 1916).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Shah, Chen and Yoshimoto in front of them to include the feature of selecting time intervals for displaying collected data disclosed by Shah with the microgrid management system of Chen to provide improved and easy-to use interfaces allowing users to view energy consumption data at any level of granularity and that the user can transition between different time intervals (Shah: ¶0264).
. Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over Chen, Yoshimoto and Shah as applied to claim 6 above and further in view of Golden et al. (“Golden,” US 2008/0167756), published on July 10,2008.
Regarding claim 7, Chen, Yoshimoto and Shah teach the display unit of claim 6,
Chen, Yoshimoto and Shah seem to teach: wherein a bar portion, which shows the today's information, shows a cumulative value from today's start time to current time (Shah: ¶0250 and Fig. 19; the total energy use of the facility may be summed over a variety of different intervals by selecting time intervals of one week, one month, three months , six months, one year, or a custom time interval).
However if Chen, Yoshimoto and Shah do not teach this limitation, Golden is relied to teach: wherein a bar portion, which shows the today's information, shows a cumulative value from today's start time to current time (Golden: ¶0051 and Fig. 5; dispatchable power sources and curtailable loads are managed by creating events. The type of event may be selected, as well as a start and end date, a start time and end time, and a duration of the event).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Golden, Chen, Yoshimoto and Shah in front of them to include the method for managing consumption and storage in a power grid as disclosed by Golden with the microgrid management system of Chen to permit electric utilities and others to effectively monitor and control distributed energy resources (Golden: ¶0006).
Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over Chen, Yoshimoto and Shah as applied to claim 6 above and further in view of Meruva et al. (“Meruva” US 2018/0293038), published on October 11, 2018.
Regarding claim 8, Chen, Yoshimoto and Shah teach the display unit of claim 6,
Chen, Yoshimoto and Shah do not appear to teach: wherein a bar portion, which shows the previous day's information, includes: a first bar portion which shows a cumulative value of previous one day, and a second bar portion which is distinguishably displayed overlapping the first bar portion, and which shows a cumulative value from previous day's start time to the previous day's current time which is the same as the today's current time.
However Meruva teaches a method for displaying energy consumption on a dashboard; wherein a bar portion, which shows the previous day's information, includes: a first bar portion which shows a cumulative value of previous one day, and a second bar portion which is distinguishably displayed overlapping the first bar portion, and which shows a cumulative value from previous day's start time to the previous day's current time which is the same as the today's current time (Meruva: ¶0064 and Fig. 7; energy consumption widget 706-14 can display a comparison of energy comfort across a plurality of zones between two different time periods).
Accordingly, it would have been obvious to one of ordinary skill in the art , before the effective filing date of the claimed invention, having the teachings of Meruva, Chen, Yoshimoto and Shah in front of them to include the feature of selecting time interval for displaying collected data disclosed by Shah with the microgrid management system of Chen to track energy and temperature information across hours, days, month, and/or years to provide different, meaningful, and easy-to-digest trends, patterns, and areas of interest. Users may readily understand which parts of a facility may need attention, maintenance, and/or reduction thereof. As a result, cost savings may be realized while the provision of comfort across the facility improved (Meruva: ¶0018).
Conclusion
The prior art made of record on form PTO-892 and not relied upon is considered pertinent to applicant's disclosure. Applicant is required under 37 C.F.R. § 1.111(c) to consider these references fully when responding to this action.
It is noted that any citation to specific, pages, columns, lines, or figures in the prior art references and any interpretation of the references should not be considered to be limiting in any way. A reference is relevant for all it contains and may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art. In re Heck, 699 F.2d 1331, 1332-33,216 USPQ 1038, 1039 (Fed. Cir. 1983) (quoting In re Lemelson, 397 F.2d 1006,1009, 158 USPQ 275,277 (CCPA 1968)).
Inquiry
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Tam T. Tran whose telephone number is (571) 270-5029. The examiner can normally be reached M-F: 7:30 AM - 5:00 PM.
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/TAM T TRAN/Primary Examiner, Art Unit 2174