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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 March 27, 2026 has been entered.
Hence, this Office Action responds to the amendment and argument filed by applicant on March 27, 2026 in response to the Office Action mailed on January 02, 2026.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on March 27, 2026 was filed after the mailing date of the Notice of Allowance on January 02, 2026. The submission is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
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 1–20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more.
Claims 1–20 are directed to patent-ineligible subject matter because the claims recite an abstract idea and do not include additional elements sufficient to amount to significantly more than the judicial exception. The analysis below follows the Alice/Mayo framework as incorporated into the 2019 Revised Patent Subject Matter Eligibility Guidance (84 Fed. Reg. 50) and the October 2024 USPTO Subject Matter Eligibility Update.
STEP 1
Claims 1–20 are directed to statutory categories because the claims recite systems and methods. Accordingly, the analysis proceeds to Step 2A.
STEP 2A, PRONG ONE
Under Step 2A, Prong One, claims 1–20 recite an abstract idea.
Independent claims 1, 16, and 20 recite limitations including: receiving purchase orders and SKU identifiers; determining whether SKUs correspond to warehouse zones; determining whether pallet tags exist; allocating products between manual zones and AGV zones; maximizing utilization of warehouse zones; determining capacities, inventory levels, replenishment rates, and demand characteristics; and directing products to different warehouse areas.
Under their broadest reasonable interpretation, these limitations recite managing inventory allocation and fulfillment operations within a warehouse environment.
These claims therefore recite certain methods of organizing human activity, including commercial interactions, logistics operations, inventory management, warehousing, fulfillment planning, and resource allocation.
For example, the steps of: assigning products to manual or automated warehouse areas; selecting destinations for inventory; deciding whether products should be processed by human operators or AGVs; determining turnover and replenishment characteristics; and maximizing zone utilization, constitute commercial and logistical management activities that are routinely performed in warehouses.
Further, these claims recite mental processes because the determinations and evaluations can practically be performed mentally or with pen and paper, including: evaluating SKU characteristics, deciding allocation destinations, comparing capacities, determining turnover rates, comparing dates, and selecting warehouse destinations.
These claims additionally recite mathematical concepts because they include calculations such as: calculating first and second allocations; maximizing utilization; calculating AGV capacities; determining replenishment rates; and comparing inventory values.
Accordingly, claims 1–20 recite abstract ideas in the form of certain methods of organizing human activity, mental processes, and mathematical concepts.
STEP 2A, PRONG TWO
These claims do not integrate the judicial exception into a practical application.
The additional elements beyond the abstract idea include: memory; processors; user devices;
mobile receptacles; AGVs; warehouse zones; and SKU identifiers.
These elements merely implement the abstract idea using generic computing and warehouse components performing their ordinary functions.
These claims do not recite: any improvement to AGV technology; any improvement to robotics; any improvement to warehouse automation hardware; any improvement to sensors or navigation systems; any particular AGV control architecture; any new robotic movement technique; any technological improvement to warehouse operation itself.
These claims merely use generic AGVs and warehouse equipment as tools to carry out allocation decisions.
The recited AGV merely receives instructions to move products between zones. The claims do not alter AGV operation, navigation, routing, control systems, battery management, robotics hardware, or autonomous behavior.
Likewise, the “mobile receptacle,” “user device,” “processor,” and “memory” merely perform conventional activities including receiving information, executing instructions, and transporting inventory.
The claimed “maximizing utilization” limitation merely optimizes a business result and does not improve technology.
These claims therefore merely automate warehouse decision-making using generic computer and logistics components.
Mere automation of longstanding commercial and logistical activities using generic computing technology does not integrate the abstract idea into a practical application. See Alice Corp. v. CLS Bank, 573 U.S. 208 (2014); Electric Power Group v. Alstom, 830 F.3d 1350 (Fed. Cir. 2016). Accordingly, these claims do not integrate the judicial exception into a practical application.
STEP 2B
These claims do not include an inventive concept sufficient to amount to significantly more than the abstract idea.
When viewed individually and as an ordered combination, the additional elements amount to no more than: generic processors executing instructions; receiving inventory information; performing allocation calculations; issuing transport instructions; generic AGV utilization; conventional warehouse inventory processing; storing data in memory.
These claims merely automate allocation decisions previously performed by warehouse operators.
The specification describes the processors, memory, user devices, AGVs, and warehouse components at a high level of generality and as performing ordinary and conventional activities.
The claimed ordering of steps likewise merely reflects conventional warehouse workflows:
receive order → identify SKU → determine destination → allocate inventory → transport products.
Such workflow automation does not provide significantly more than the abstract idea itself.
These claims do not recite: specialized warehouse hardware, unconventional robotics, non-conventional data structures, specific AGV improvements, improved robotic navigation,
or any technical solution to a technical problem.
The Federal Circuit has repeatedly held claims directed to collecting information, analyzing information, and displaying or acting on results to be patent ineligible. See: Alice Corp. v. CLS Bank, 573 U.S. 208 (2014); Electric Power Group v. Alstom, 830 F.3d 1350 (Fed. Cir. 2016); SAP America v. InvestPic, 898 F.3d 1161 (Fed. Cir. 2018); In re Board of Trustees of Leland Stanford, 991 F.3d 1245 (Fed. Cir. 2021).
Similarly here, the claims merely collect warehouse information, analyze inventory attributes, and issue allocation instructions.
Accordingly, the claims do not amount to significantly more than the abstract idea. Thus, claims 1–20 are rejected under 35 U.S.C. §101 because the claims are directed to the abstract idea of warehouse inventory allocation and logistics planning, including inventory routing, resource allocation, fulfillment management, and optimization, and the claims do not recite additional elements sufficient to amount to significantly more than the judicial exception.
Allowable Subject Matter
Claims 1-20 are allowable over prior art of records. As allowable subject matter has been indicated, applicant's reply must either comply with all formal requirements or specifically traverse each requirement not complied with. See 37 CFR 1.111(b) and MPEP § 707.07(a).
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROKIB MASUD whose telephone number is (571)270-5390. The examiner can normally be reached Mon-Fri 8:00-5:00.
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/ROKIB MASUD/Primary Examiner, Art Unit 3627
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