DETAILED ACTION
Notice of 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 .
Status of the Application
Claims 1-10 were rejected in the previous office action. Claims 1-3 and 6 were amended. Claims 1-10 remain pending and are examined in this office action.
This is a non-final office action, based upon further analysis under § 101.
Response to Arguments
35 USC § 103:
Applicant’s arguments regarding the previous § 103 rejections of claims 1-10 (pgs. 6-12, remarks filed 1/14/2026) have fully considered and are persuasive. Claims 1-10 as currently recited have overcome the previous § 103 rejections, as discussed below in the reasons for “Novelty/Non-Obviousness.”
Claim Objections
Claims 1, 3-4, 6, and 8-9 are objected to because of the following informalities:
Claims 1 recites “causing the mobile device to share the mobile device GPS location information” – but should recite “causing the mobile device to share the mobile device GPS location information” is referring back to a previous limitation.
Claims 3 and 8 recite “the GPS location” but should recite “the shared mobile device GPS location information” to improve clarity.
Claims 4 and 9 recite “the rental computer system” but it appears they should recite “the rental management computer system.”
Claim 6 recites “GPS information” but then later recites “share the mobile device GPS location information…” – it appears that the first instance of “GPS information” should instead recite “mobile device GPS location information” to provide antecedent basis for the later limitation.
Appropriate correction is required.
Claim Interpretation
The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are:
“an input component of a website operative to receive information” – See specification at ¶ 0055-0056 showing website hosted on rental management computer system, and including input/output devices; also see ¶ 0007, ¶ 0058 showing website input section, and Fig. 12 and ¶ 0062, Fig. 15 and ¶ 0063, Figs. 19-20 and ¶ 0065 showing input of location and image information via web page elements.
Note that “of a website” does not modify the generic placeholder “an input component” with sufficient structure that one of ordinary skill would understand to be the element for performing the claimed function.
Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
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 1-10 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e. an abstract idea) without significantly more.
Step 1:
Claims 1-5 recite “A computer-implement method…” (i.e. a process); and claims 6-10 recite “A rental management computer system…” (i.e. a machine). These claims fall under one of the four categories of statutory subject matter and as a result, pass Step 1 of the subject matter eligibility test. However, “Determining that a claim falls within one of the four enumerated categories of patentable subject matter recited in 35 U.S.C. 101 (i.e., process, machine, manufacture, or composition of matter) in Step 1 does not end the eligibility analysis, because claims directed to nothing more than abstract ideas (such as a mathematical formula or equation), natural phenomena, and laws of nature are not eligible for patent protection.” See MPEP 2106.04. Accordingly, the examiner continues the subject matter eligibility analysis below.
Step 2A Prong One:
Independent claims 1 and 6 (using claim 1 as representative) recite limitations for the mobile rental of vehicles, comprising:
storing…rental transaction information associated with a customer for reservation of a rental vehicle for a rental time period,
wherein the stored rental transaction information includes a reserved rental return location selected from a plurality of rental return locations,
and wherein the reserved rental return location is received…before the reservation of the rental vehicle is activated;
before the customer agrees to the rental of the vehicle, advising the customer that a mobile device will be required to pick up the rental vehicle,
after the reservation of the rental vehicle has been activated and the customer has picked up the vehicle (…):
…begin a process for returning the rental vehicle;
…share…location information…;
using the shared…location information to…confirm if the customer is at the reserved rental return location; and
if the customer is not at the reserved rental return location…display a notice that returning the vehicle to a different location than the reserved rental return location may result in an additional fee
Independent claim 6 recites an additional limitation to:
receive information…including image information and GPS information
The limitations of independent claims 1 and 6 above are determined to recite an abstract idea (i.e. managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information) for the reasons discussed in the following continued Step 2A Prong One analysis. Note that “An abstract idea can generally be described at different levels of abstraction.” Apple, Inc. v. Ameranth, Inc., 842 F.3d 1229, 1240-41 (Fed. Cir. 2016).
As per MPEP 2106.04(a)(2)(II), claim limitations which recite commercial or legal interactions (including agreements in the form of contracts, legal obligations, advertising, marketing or sales activities or behaviors, and business relations) or managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions) fall into the “certain methods of organizing human activity” category of judicial exceptions. Therefore, since the processes described by the limitations above clearly recite a commercial interaction and managing interactions between people (i.e. managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information - which relates to contracts, sales activities or behaviors, and business relations, and also describes managing/coordinating customer interactions between a customer and a vehicle rental system/commercial entity), the claims fall into the “certain methods of organizing human activity” grouping of abstract ideas.
As described in MPEP 2106.04(a)(2)(III), “[T]he "mental processes" abstract idea grouping is defined as concepts performed in the human mind, and examples of mental processes include observations, evaluations, judgments, and opinions.” and “If a claim recites a limitation that can practically be performed in the human mind, with or without the use of a physical aid such as pen and paper, the limitation falls within the mental processes grouping, and the claim recites an abstract idea.” The limitations recited by the representative independent claims 1 and 6 above, under the broadest reasonable interpretation and but for the use of generic computer components, cover concepts (e.g. observation, evaluation, judgment, and opinion) that can reasonably be performed in the human mind or by the human mind with the aid of simple tools such as pen and paper. For example, the “reserved rental return location is received…” step amounts to an observation, while the steps to “begin a process for picking up the rental vehicle,” “share…location information,” and use the location information “confirm that the customer is at the reserved rental return location” would be considered evaluations, judgments, and opinions that could be performed either in the human mind or with the aid or simple tools such as pen and paper. Limitations for “storing,” “advising the customer,” and “displaying” are also analogous to functions that could otherwise be performed by a human with the aid of pen and paper (e.g. storing data in a paper ledger, or drawing/writing to display information on paper). As per MPEP 2106(a)(2)(III), “The courts do not distinguish between mental processes that are performed entirely in the human mind and mental processes that require a human to use a physical aid (e.g., pen and paper or a slide rule) to perform the claim limitation… Nor do the courts distinguish between claims that recite mental processes performed by humans and claims that recite mental processes performed on a computer.” Therefore, as the processes above described by the representative independent claims 1 and 6 can be characterized as mental processes, but for the recitation of generic computer components in the claims, the claims fall under the “mental processes” category of judicial exceptions (i.e. abstract ideas).
As claims 1 and 6 are identified by the examiner as reciting concepts that fall under more than one abstract idea grouping (i.e. “certain methods of organizing human activity” and “mental processes”), the examiner considers the limitations together as a single abstract idea for the purposes of the Step 2A Prong Two and Step 2B analysis, in accordance with MPEP 2106.04(II)(B).
Step 2A Prong Two:
Claims 1 and 6 recite the following additional elements:
“a non-transitory computer database…accessible by a rental management computer system” of claim 1
“by the rental management computer system” and “with the rental management computer system” of claims 1 and 6
“automatically…causing a mobile device to display a user interface element...” of claim 1 and similar claim 6
“in response to the selection of the user interface element on the mobile device, causing the mobile device to share the mobile device GPS location information with the rental management computer system, wherein at the time of the selection of the user interface element, the rental vehicle need not be parked at any of the plurality of rental return locations” of claim 1 and similar claim 6
the location data being “mobile device GPS” location data and used to “automatically” confirm the customer is at the rental return location of claims 1 and 6; and “GPS information” of claim 6
“causing the mobile device to display…” of claim 1 and similar claim 6
“a rental management computer system…” comprising “a database operative to store…,” “an input component of a website operative to receive information from a mobile device…,” and “a processor operative to…” of claim 6
The judicial exception (i.e. abstract idea) recited in claims 1 and 6 is not integrated into a practical application because the claims recite mere instructions to apply the abstract idea (i.e. managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information) using generic computers/computer components (i.e. “a non-transitory computer database…accessible by a rental management computer system,” “a rental management computer system,” “a mobile device,” “a user interface element” of claim 1; and “a rental management computer system,” “a database,” “an input component of a website,” “a processor,” “a mobile device,” “a user interface element,” and “an input component of a website” of claim 6).
Any limitations recited as being performed “automatically” merely claims the improved speed inherent with applying the abstract idea on computers. “[C]laiming the improved speed or efficiency inherent with applying the abstract idea on a computer” does not integrate a judicial exception into a practical application or provide an inventive concept. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367, 115 USPQ2d 1636, 1639 (Fed. Cir. 2015). The limitations for storing data using a database or non-transitory computer database, receiving or transmitting data (with the rental management computer system and the mobile device), displaying information on the mobile device, all describe generic computer implementation and the use of computers in their ordinary capacity. Similarly, displaying a user interface element, receiving selection of a user interface element on a mobile device and subsequently sharing mobile device GPS location information reads simply describes receiving input to turn on location sharing, which describes the use of a mobile device including a GPS in its ordinary capacity (e.g. any off-the-shelf mobile device includes capabilities for input/output via a user interface and GPS location tracking – recited these elements together does not change the generic nature of the functions). This describes generic use of a user interface and location tracking capabilities at a high level of generality, and does not provide an inventive concept that improves the functioning of computers themselves (e.g. how a device stores data, communicates data, an improvement to the functioning of user interfaces) or an improvement to any other technology (e.g. improvement to GPS functionality). The same analysis applies to the “input component of a website” used to receive information – this describes basic functionality of a website user interface being used in its ordinary capacity. Applicant’s specification at ¶ 0055 (filed 10/31/2022) clearly describes the mobile device in a highly generic manner as any one of a plurality of potential mobile devices that does not suggest that the mobile device or its associated functions represent a indicate a technological improvement. Instead, the claims simply recite the use of generic computer functionality to automate and apply the abstract idea (managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information) within a computer-based/mobile device environment.
See MPEP 2106.05(f), showing “[C]laims that amount to nothing more than an instruction to apply the abstract idea using a generic computer do not render an abstract idea eligible. Alice Corp.” and “Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more” – but instead indicates that the claims recite mere instructions apply the abstract idea using a generic computer or computer components.
Furthermore, that the location data used to confirm the customer is located at the rental return location is mobile device GPS location information/GPS location data, and the limitations specifying that “at the time of the selection of the user interface element, the rental vehicle need not be parked at any of the plurality of rental return locations” at most generally links the performance of the abstract idea to a particular field of use of technological environment (e.g. managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information, within a computer environment using mobile devices with GPS tracking). As above, the tracking/sharing of mobile device GPS data is no more than generic computer implement using a mobile device in its ordinary capacity.
Therefore, because the claims, considered as a whole, do not recite anything that integrates the abstract idea into a practical application, the claims are directed to an abstract idea.
Step 2B:
Claims 1 and 6 do not include additional elements, whether considered alone or as an ordered combination, that are sufficient to amount to significantly more than the judicial exception (i.e. abstract idea) because as mentioned above, the claims recite mere instructions to apply the abstract idea (i.e. managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information) using generic computers/computer components (i.e. “a non-transitory computer database…accessible by a rental management computer system,” “a rental management computer system,” “a mobile device,” “a user interface element” of claim 1; and “a rental management computer system,” “a database,” “an input component of a website,” “a mobile device,” and “a user interface element” of claim 6).
As above, limitations recited as being performed “automatically” merely amounts to “[C]laiming the improved speed or efficiency inherent with applying the abstract idea on a computer,” which does not integrate a judicial exception into a practical application or provide an inventive concept. Intellectual Ventures I LLC v. Capital One Bank (USA), 792 F.3d 1363, 1367, 115 USPQ2d 1636, 1639 (Fed. Cir. 2015). The limitations for storing data using a database or non-transitory computer database, receiving or transmitting data (with the rental management computer system and the mobile device), and displaying information on the mobile device all describe generic computer implementation and the use of computers in their ordinary capacity. Similarly, displaying a user interface element, receiving selection of a user interface element on a mobile device and subsequently sharing mobile device GPS location information reads simply describes receiving input to turn on location sharing, which describes the use of a mobile device including a GPS in its ordinary capacity (e.g. any off-the-shelf mobile device includes capabilities for input/output via a user interface and GPS location tracking). This describes generic use of a user interface and location tracking capabilities at a high level of generality, and does not provide an inventive concept that improves the functioning of computers themselves (e.g. how a device stores data, communicates data, an improvement to the functioning of user interfaces) or an improvement to any other technology (e.g. improvement to GPS functionality). The same analysis applies to the “input component of a website” used to receive information – this describes basic functionality of a website user interface being used in its ordinary capacity. Applicant’s specification at ¶ 0055 (filed 10/31/2022) clearly describes the mobile device in a highly generic manner as any one of a plurality of potential mobile devices that does not suggest that the mobile device or its associated functions represent a indicate a technological improvement. Instead, the claims simply recite the use of generic computer functionality to automate and apply the abstract idea (managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information) within a computer-based/mobile device environment.
See MPEP 2106.05(f), showing “[C]laims that amount to nothing more than an instruction to apply the abstract idea using a generic computer do not render an abstract idea eligible. Alice Corp.” and “Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., a fundamental economic practice or mathematical equation) does not integrate a judicial exception into a practical application or provide significantly more” – but instead indicates that the claims recite mere instructions apply the abstract idea using a generic computer or computer components.
Furthermore, that the location data used to confirm the customer is located at the rental return location is mobile device GPS location information/GPS location data, and the limitations specifying that “at the time of the selection of the user interface element, the rental vehicle need not be parked at any of the plurality of rental return locations” at most generally links the performance of the abstract idea to a particular field of use of technological environment (e.g. managing a vehicle rental reservation and facilitating a vehicle rental return process using shared location information, within a computer environment using mobile devices with GPS tracking). As above, the tracking/sharing of mobile device GPS data is no more than generic computer implement using a mobile device in its ordinary capacity.
Considering the additional elements above as an ordered combination does not add significantly more, as it does not add anything more than generic computer implementation used to carry out the abstract idea, or automate the abstract idea on computers.
Dependent Claims 2-5 and 7-10:
Dependent claims 2-5 and 7-10 are directed to the same abstract idea as independent claims 1 and 6 above as they do not recite anything that integrates the abstract idea into a practical application or amounts to significantly more than the abstract idea.
Claims 2-3 and 7-8 recite the following limitations, which do not introduce any additional elements beyond those already addressed above (e.g. sharing GPS location information and “the processor”) but merely further describes the abstract idea above, for: confirming that the customer is at the reserved rental return location if the mobile device location is within a pre-defined minimum distance from the reserved rental return location (claims 2 and 7); and automatically comparing the shared mobile device GPS location information with the reserved rental return location and calculating the distance between the GPS location and the reserved rental return location to determine whether to instruct the customer to move the vehicle (claims 3 and 8).
Claims 4 and 9 recite the rental management computer system prompting the customer to capture and provide image information for confirming a mileage and fuel level for the rental vehicle being returned, and sending the information to the rental computer system – however, these limitations merely further describe the abstract idea (prompting the customer to capture and report fuel and mileage levels when returning the vehicle) using generic computer components being used in their ordinary capacity (capturing images using the mobile device, and sending/transmitting the information to the rental management computer; and “the processor is operative to” of claim 9).
Claims 5 and 10 also recite limitations that further describe the abstract idea (“after the reservation of the rental vehicle has been activated… prompting the customer to…send…information regarding damage to the rental vehicle incurred during the rental time period” of claim 5; and “prompt the customer to…send…information regarding any damage to the rental vehicle incurred during the rental time period”) using generic computer implementation/generic computer components (“with the rental management computer system,” “use the mobile computer device to,” “to the rental management computer system” of claim 5; and “wherein the processor is operative to automatically…,” “use the mobile device to” and “to the rental management computer system” of claim 10).
Therefore, claims 1-10 are ineligible under § 101.
Novelty/Non-Obviousness
Claims 1-10 are novel and nonobvious over the prior art.
The closest prior art is as follows:
US 20140278599 A1 to Reh et al. (Reh) teaches a computer implemented method and system for mobile rental of vehicles (Reh: ¶ 0003-0007), including storing vehicle rental transaction information for the customer for a rental time period in a computer database (Reh: ¶ 0055, ¶ 0057, ¶ 0077/Fig. 8b), wherein the computer database is accessible by a rental management computer (Reh: ¶ 0139) and the rental transaction information including a reserved return location selected from a plurality of return locations (Reh: ¶ 0139 reservation information includes return location; also see ¶ 0121-0122, Fig. 32 and ¶ 0144); receiving the reserved rental return location via customer input on a rental reservation GUI, before activation of the vehicle rental reservation (Reh: ¶ 0139); receiving a customer selection of a user interface element to complete the reservation and cause the rental request to be transmitted to the rental management computer system (Reh: ¶ 0119-0120, ¶ 0123); and at a time after activation of the vehicle rental reservation (Reh: ¶ 0100-0105) and pickup of the rental vehicle, displaying a user interface element to begin a rental return process (Reh: ¶ 0119-0120, ¶ 0123, ¶ 0144); and after the reservation and while starting the return of the rental vehicle, prompting the customer to input information regarding damage to the rental vehicle incurred during the rental period (Reh: ¶ 0125 “The GUI screen also be configured to solicit input from the driver to indicate whether the rental vehicle has experienced any noticeable damage during the rental”)
US 20150348179 A1 to Kamisawa teaches transmitting a rental vehicle return notice that includes a current position of a customer mobile terminal (Kamisawa: ¶ 0302), wherein the received current position of the customer mobile terminal is used to automatically confirm that the customer is at a rental return location (Kamisawa: ¶ 0302-0304) to a previously specified (in reservation information) return location (Kamisawa: at least ¶ 0015, ¶ 0017, ¶ 0161-0162, ¶ 0178, ¶ 0180, ¶ 0182 ¶ 0471, ¶ 0473 showing the return location was specified in the reservation information in advance); and comparing the mobile device GPS location information with a rental return location and calculating the distance between the GPS location and the rental return location to determine whether to instruct the customer to move the vehicle (Kamisawa: ¶ 0242-0251 showing after customer enters desired return time and area, a distance between a current position and store for returning the vehicle within the reachable distance is calculated and provided to the customer; see ¶ 0070 current position is determined using GPS of mobile device; also ¶ 0077, ¶ 0245 also showing distance from the previously indicated rental return site).
US 9807547 B1 to Oesterling et al. (Oesterling) teaches that a user making user interface selections by entering a trip completion command into a CarShare App while the vehicle is at a location other than an authorized system parking location, i.e. authorized return location (Oesterling: Col. 13: 39-44), and transmitting a notification to provide a warning to the user that additional charged may be incurred for violating the registration agreement terms, i.e. returning the vehicle to an unauthorized parking location (Oesterling: Col. 13: 39-47).
US 20160080390 A1 to Kalb et al. (Kalb) teaches presenting a device requirement indicating that a ticket to gain entry to an event is linked to user’s mobile device that must be present (Kalb: ¶ 0101).
US 9681359 B2 to Ramalingam et al. (Ramalingam) teaches confirming a customer has arrived/is at a particular location based on the customer device location being within a threshold distance from the particular location (Ramalingam: Col. 9: 56-61 teaching “it is determined if the device is located at the merchant. In some instances, this determination may include determining if the device is within the merchant, while in other instances this may include determining if the device is within a predetermined distance of the merchant”).
US 11039284 B1 to Gravelle et al. (Gravelle) teaches capturing vehicle odometer and associated timestamp data by prompting a customer to capture a photo of a vehicle odometer reading with an associated date and timestamp (Gravelle: Col. 11: 55-59 showing “The user is prompted to take a photo of the vehicle odometer reading, and the application records the fact that the photo was taken proximate to the secure beacon and a specific date and time”).
However, no combination of the prior art teaches, in context of the limitations of the claims as a whole, the limitations for: “before the customer agrees to the rental of the vehicle, advising the customer that a mobile device will be required to pick up the rental vehicle with the rental management computer system.” While “Reh” provides instructions to the customer for launching an app to access the vehicle using their mobile device in a text message (Reh: Fig. 25, ¶ 0113-0114), this step occurs after activation/confirmation of the terms of the vehicle rental reservation and also does not explicitly advise the customer that the mobile device is required for pickup. No other closer prior art known to the examiner teaches this limitation.
Therefore, claims 1 and 6 (and the respective dependent claims 2-5 and 7-10) are novel and nonobvious over the prior art.
Conclusion
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/HUNTER MOLNAR/Examiner, Art Unit 3628