DETAILED ACTION
This FINAL action is to the response filed 2/19/2026.
In the response Claims 16-18, 20 and 22-29 remain pending. Claims 1-15, 19 and 21 remain canceled. Claims 16 and 27-29 are the independent claims.
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Withdrawn Rejections
The 35 U.S.C. 103 rejection of claims 16-18, 20 and 22-29 with cited references of Vukovic (U.S. 2021/0245758) in view of Ahmad (U.S. Pub 2021/0394792) has been withdrawn in light of the persuasive arguments. Specifically, Vukovic discloses that messages are triggered by a vehicle’s intention to change lanes. Further disclosing in paragraph 47 a condition referenced in a NACK response regarding “already occupying the space” and describing unequipped and non-communicative vehicles which further underscores that Vukovic does not contemplate that vehicle transmits any such status message of real-time physical entry into or departure from a road resource area. Ahmad is pre-maneuver/intent-based and defines road resources as regions with spatial and temporal boundaries in paragraphs 26-29. Nowhere does Ahmad describe a vehicle monitoring whether it has physically crossed into or out of such a region including transmission of any status message triggered by the event.
Claim Rejections - 35 USC § 101
5. 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.
6. Claim 16-18, 20 and 22-29 remain rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e. abstract idea) without significantly more.
The determination of whether a claim recites patent ineligible subject matter is a 2-step inquiry.
STEP 1: the claim does not fall within one of the four statutory categories of invention (process, machine, manufacture or composition of matter), see MPEP 2106.03, or
STEP 2: the claim recites a judicial exception, e.g. an abstract idea, without reciting additional elements that amount to significantly more than the judicial exception, as determined using the following analysis: see MPEP 2106.04
STEP 2A (PRONG 1): Does the claim recite an abstract idea, law of nature, or natural phenomenon? see MPEP 2106.04(II)(A)(1)
STEP 2A (PRONG 2): Does the claim recite additional elements that integrate the judicial exception into a practical application? see MPEP 2106.04(II)(A)(2) and 2106.05(a) thru (d) for explanations.
STEP 2B: Does the claim recite additional elements that amount to significantly more than the judicial exception? see MPEP 2106.05
101 Analysis – Step 1
Claim 16 is directed to “A method …” (i.e., process). Claim 27 is directed to “An apparatus…” (i.e., machine). Claim 28 is directed to “A computer program comprising a non-transitory…” (i.e., composition of matter). Claim 29 is directed to “A computer readable signal (i.e., process). Therefore, the claims are within at least one of the four statutory categories.
101 Analysis – Step 2A, Prong I
Regarding Prong I of the Step 2A analysis, the claims are to be analyzed to determine whether they recite subject matter that falls within one of the follow groups of abstract ideas: a) mathematical concepts, b) certain methods of organizing human activity, and/or c) mental processes. see MPEP 2106(A)(II)(1) and MPEP 2106.04(a)-(c)
Independent claim 16 includes limitations that recite an abstract idea (emphasized below [with the category of abstract idea in brackets]). Furthermore, Independent claims 27-29 recites similar subject matter and are rejected under the same rationale.
Claim 16, A method of coordinating a maneuver among vehicles, the method comprising:
Negotiating, with a computing device of a first vehicle a maneuver among at least a first vehicle and a second vehicle, wherein the maneuver is specified at least in terms of one or more target road resources attributed to the first vehicle and one or more target road resources attributed to the second vehicle [mental process],
a target road resource comprising at least one area information and at least one time information [mathematical concepts],
wherein negotiating comprises one or more iterations of: Transmitting, from the first vehicle, a request message to the second vehicle, the request message comprising a specific proposal for the second vehicle to execute one or more actions [MPEP 2106.05(f) Mere Instructions to Apply an Exception]; and
Receiving, at the first vehicle, a response to the request message from the second vehicle [MPEP 2106.05(g) Insignificant Extra-Solution Activity, data gathering];
Determining, with the computing device of the first vehicle, that the first vehicle has entered an area associated with one of the target road resources attributed to the first vehicle and/or determining that the first vehicle has left an area associated with one of the target road resources attributed to the first vehicle [mental process];
in response to determining that the first vehicle has entered the area associated with the target road resource attributed to the first vehicle and/or in response to determining that the first vehicle has left the area associated with the target road resource attributed to the first vehicle, transmitting, with the computing device of the first vehicle a status message from the first vehicle to the second vehicle, wherein the status message comprises an identifier of the respective road resources and information indicating whether the respective area that is associated with the target road resource has been entered or left [MPEP 2106.05(g) Insignificant Extra-Solution Activity, post-solution activity].
The Examiner submits that the foregoing bolded limitation(s) above: constitute mathematical concepts and a “mental process” because under its broadest reasonable interpretation, the claim covers performance of
the limitation in the human mind.
The step of negotiating a maneuver falls under a mental process. For example, humans can negotiate maneuvers via hand signals, eye contact at intersections etc. Using a computing device to automate the “negotiation” does not transform the abstract concept.
In addition, determining if a vehicle has entered or left an area falls under a mental process to which a driver can perform observation and evaluation, for example the user has entered an area where potential merge event will occur or has left and area thus avoiding any merge conflict. It involves reasoning to determine a position of a vehicle relative to certain areas which is a decision-making process that could be done mentally.
Defining spatiotemporal parameters such as target road resource comprising area information and time information is a mathematical concept has it involves coordinates and time stamps.
Accordingly, the claim recites at least one abstract idea.
101 Analysis – Step 2A, Prong II
Regarding Prong II of the Step 2A analysis, the claims are to be analyzed to determine whether the claim, as a whole, integrates the abstract into a practical application. see MPEP 2106.04(II)(A)(2) and MPEP 2106.04(d)(2). It must be determined whether any additional elements in the claim beyond the abstract idea integrate the exception into a practical application in a manner that imposes a meaningful limit on the judicial exception. The courts have indicated that additional elements merely using a computer to implement an abstract idea, adding insignificant extra solution activity, or generally linking use of a judicial exception to a particular technological environment or field of use do not integrate a judicial exception into a “practical application.”
In the present case, the additional limitations beyond the above-noted abstract idea are as follows (where the underlined portions are the “additional limitations”, while the bolded portions continue to represent the “abstract idea”.):
For the following reason(s), the examiner submits that the above identified additional limitations do not integrate the above-noted abstract idea into a practical application. Regarding the additional limitations of “Receiving, at the first vehicle” & “transmitting…a status message”, The Examiner submits that these limitations are insignificant extra-solution activities that merely use a computing device to transmit and receive message data. The transmission of the status message between vehicles that comprises an identifier and availability of a road resource fall under post-solution activity because the proposal is not actually used by the second vehicle to modify its operational characteristics or constrain its behavior, for example canceling or actually executing an action of the maneuver.
Thus, taken alone, the additional elements do not integrate the abstract idea into a practical application. Further, looking at the additional limitation(s) as an ordered combination or as a whole, the limitation(s) add nothing that is not already present when looking at the elements taken individually. For instance, there is no indication that the additional elements, when considered as a whole, reflect an improvement in the functioning of a computer or an improvement to another technology or technical field, apply or use the above-noted judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, implement/use the above-noted judicial exception with a particular machine or manufacture that is integral to the claim, effect a transformation or reduction of a particular article to a different state or thing, or apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is not more than a drafting effort designed to monopolize the exception (MPEP § 2106.05). Accordingly, the additional limitation(s) do/does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
101 Analysis – Step 2B
Regarding Step 2B of the Revised Guidance, representative independent claims does not include additional elements (considered both individually and as an ordered combination) that are sufficient to amount to significantly more than the judicial exception for the same reasons to those discussed above with respect to determining that the claim does not integrate the abstract idea into a practical application. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of “iterations of: Transmitting”, amounts to nothing more than mere instructions to apply the exception using a generic computer component. For example, using a computer to perform the activity of iterative data transmission between vehicles is mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. And as discussed above the examiner submits that these limitations are insignificant extra-solution activities. See MPEP 2106.05(d)(II), and the cases cited therein, including Intellectual Ventures I, LLC v. Symantec Corp., 838 F.3d 1307, 1321 (Fed. Cir. 2016), TLI Communications LLC v. AV Auto. LLC, 823 F.3d 607, 610 (Fed. Cir. 2016), and OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015) in addition to -Collecting information, analyzing it, and displaying certain results of the collection and analysis (Electric Power Group), Collecting data, recognizing certain data within the collected data set and storing the recognized data in memory (Content Extraction).
Dependent claims 17-18 and 22-26, -do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claim are directed toward additional aspects of the judicial exception and do not integrate the judicial exception into a practical application. The claims describe information conveyed in the message which are insignificant extra-solution activities that merely transmit and collect signal data using vehicles. Therefore, the claims are not patent eligible under the same rationale as provided for in the rejection of the Independent claims. Therefore, the claims are ineligible under 35 USC §101.
Dependent claim 20, -do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claim are directed toward additional aspects of the judicial exception and do not integrate the judicial exception into a practical application. The claims describe information conveyed in the message which are insignificant extra-solution activities, particularly post-solution activity that sends a message without any modification to the operational state of the vehicle. Therefore, the claims are not patent eligible under the same rationale as provided for in the rejection of the Independent claims. Therefore, the claims are ineligible under 35 USC §101.
Response to Arguments
7. Applicant’s arguments filed 2/19/2026 have been considered but are moot in view of the withdrawn 35 U.S.C. 103 rejection. However, some, arguments towards the 35 U.S.C. 101 abstract idea rejection have been addressed below.
Applicant Argues: “…disagrees with the assertion that under the broadest reasonable interpretation, the negotiating step and the determining step covers performance of the limitation in the human mind. The claim element specifically recites that a computing device of the first vehicle performs these elements and the negotiating element includes transmission of information between a first vehicle and a second vehicle. Accordingly, the Examiner’s analysis that these elements cover performance of limitations in the human mind is not consistent with the actual language of the claim” (see pg. 9)
“Here, the negotiation of a maneuver among two vehicles through iterations of transmitting a request message with a specific proposal for the other vehicle to perform an receiving a response to the request, and sending status message regarding a position of one of the vehicles are integral to the claimed process rather than incidental to it.” (see pg. 9)
“The invention currently recited in claim 16 provides for two vehicles negotiating a maneuver between the two vehicles and providing an update regarding a vehicle location.” (see pg. 10)
The Examiner Respectfully Disagrees: The claim is directed to an abstract idea that recites the exchange and processing of information for coordinating a maneuver between vehicles that includes transmitting proposals, receiving responses, determining whether a vehicle has entered or left an area and transmitting status updates regarding the vehicle’s location. While the claim references vehicle location and road resources, these limitations merely involve collecting, analyzing and communicating information to facilitate negotiation between parties, which can be performed as a mental process. The additional recitation of generic computing devices and message transmission does not integrate the abstract idea into a practical technological improvement, but instead implements the coordination process using conventional computer and communication components.
The transmission of the status message between vehicles that comprises an identifier and availability of a road resource fall under post-solution activity because the proposal is not actually used by the second vehicle to modify any operational characteristics or constrain its behavior, for example canceling an active maneuver or actually executing an action of the maneuver when the road resource is available.
Conclusion
THIS ACTION IS MADE FINAL. 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 MANGLESH M PATEL whose telephone number is (571)272-5937. The examiner can normally be reached on M-F from 10:30 am to 7:30 pm.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Erin D. Bishop, can be reached at telephone number 571-270-3713. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/Manglesh M Patel/
Primary Examiner, Art Unit 3665
5/22/2026
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