Prosecution Insights
Last updated: April 19, 2026
Application No. 18/209,076

PROVIDING IRRIGATION CONTROL VIA GEOFENCING

Non-Final OA §103
Filed
Jun 13, 2023
Examiner
CONNOLLY, MARK A
Art Unit
2115
Tech Center
2100 — Computer Architecture & Software
Assignee
Textron Innovations Inc.
OA Round
2 (Non-Final)
82%
Grant Probability
Favorable
2-3
OA Rounds
2y 9m
To Grant
91%
With Interview

Examiner Intelligence

Grants 82% — above average
82%
Career Allow Rate
680 granted / 829 resolved
+27.0% vs TC avg
Moderate +9% lift
Without
With
+8.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
29 currently pending
Career history
858
Total Applications
across all art units

Statute-Specific Performance

§101
5.9%
-34.1% vs TC avg
§103
44.7%
+4.7% vs TC avg
§102
20.8%
-19.2% vs TC avg
§112
18.9%
-21.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 829 resolved cases

Office Action

§103
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 . Claims 1-20 have been presented for examination. The indicated allowability of claims 8 and 17 is withdrawn in view of the newly discovered reference(s) to Mikkiya et al US Pat No 11190901. Rejections based on the newly cited reference(s) follow. 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, 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. Claim(s) 1-4, 9-15 and 18-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Goodman et al [Goodman] US Pat No 9829871 in view of Bolto et al [Bolto] WO 2018/227235. Referring to claim 1, Goodman teaches the method of controlling a set of irrigation heads, the method comprising: initiating an irrigation task that directs the set of irrigation heads to irrigate at least a portion of a geographic area defined by a virtual boundary [col. 19 lines 22-23]. electronically detecting presence of a device within the geographic area [col. 17 lines 20-24, col. 19 lines 26-29]. suspending the irrigation task in response to electronically detecting the presence of the device within the geographic area [col. 19 lines 26-29]. In summary, Goodman teaches a method of operating an irrigation system wherein users of a property are tracked by their mobile devices and in the event that the property or a portion(s) of the property is being irrigated, suspend irrigation if any of the users are identified as occupying the irrigated portion(s) of the property. While Goodman teaches the irrigation method as described above, it is not explicitly taught how Goodman determines when it is determined that a user occupies a particular portion of the property. In other words, how does Goodman determine when a user occupies a portion of the property? At most, Goodman teaches that the users are tracked by their mobile devices via GPS [col. 17, lines 26-28]. Bolto teaches geofencing which allows CCMT devices (i.e. control circuit management technology) to be controlled based on if a GPS tracked device enters and exits a virtual geographic boundary [pg. 40 lines 21-34. Emphasis on lines 30-34]. It is further taught that irrigation is CCMT controllable as well [pg. 40 lines 35-36]. It would have been obvious to one of ordinary skill in the art before the effective filing to try incorporating the teachings of Bolto into Goodman because Bolto teaches a necessary mechanism to determine when and how to control the ON/OFF of devices based on a user’s proximity. Including a geofencing boundary into Goodman would provide a boundary with which occupancy could be determined as required in Goodman. This would allow Goodman to turn ON/OFF and suspend sprinkler operation based on if the user(s) are within the geofence or not. Referring to claims 2-4, Goodman teaches that irrigation is originally started and scheduled to run for 2 hours; suspended when a user(s) enters the portion of the property being irrigated; and resumed once the user(s) leave the portion of the property and runs till the end of the scheduled 2 hours [col. 19 lines 21-33]. Referring to claim 9, Goodman teaches being able to track multiple users and only resumes irrigation once all users leave the particular portion of the property being irrigated [col. 17 lines 20-24, col. 19 lines 29-33]. In other words, if any users still occupy the particular portion of the property, irrigation remains suspended. Referring to claims 10-11, Bolto teaches that irrigation is controlled by opening and closing the irrigation valves [pg. 40 lines 35-36]. Referring to claims 12-15 and 18-20, these are rejected on the same basis as set forth hereinabove. Goodman and Bolto teaches the method and therefore teaches the system and program performing the same. Claim(s) 5-6 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Goodman and Bolto as applied to claims 1-4, 9-15 and 18-20 above, and further in view of Evelyn-Veere [Evelyn] PGPUB 2005/0082382. Referring to claim 5, while the Goodman-Bolto combination teaches controlling irrigation for a property based on detecting occupancy, it is not explicitly taught that the property is a golf course. Rather, Goodman suggests that the property is a residential property wherein the property is divided into a front yard, back yard, etc… [col. 11 lines 22-27, col. 15 lines 33-45]. Evelyn teaches the desire to control irrigation on a golf course by preventing irrigation to avoid interfering with golfers [0079]. It would have been obvious to try including the teachings of Goodman and Bolto for a golf course because it provides an alternative way to control irrigation to prevent running a zone while people are present in the zone and a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. Referring to claim 6, Goodman teaches communicating with the irrigation system, the GPS coordinates of the user’s mobile device, in order for the system to know the position of the user and control the irrigation system accordingly [col. 17 lines 20-41]. Referring to claim 16, this is rejected on the same basis as set forth hereinabove. Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Goodman, Bolto and Evelyn as applied to claims 1-6, 9-16 and 18-20 above, and further in view of Rathod1. Referring to claim 7, while the Goodman-Bolto-Evelyn combination teaches the invention substantially as claimed above, it is not explicitly taught to use Bluetooth as a beacon to detect that the device has entered the yard/golf course. Instead, Goodman teaches using GPS to determine location as indicated above. Rathod teaches that an alternative to GPS is using Bluetooth as a beacon (i.e. iBeacon) to determine geolocation [0085]. It would have been obvious to one of ordinary skill in the art before the effective filing date to modify the Goodman-Bolto-Evelyn combination to try using a Bluetooth beacon to geolocate the user and their device instead of GPS because Rathod teaches the two are alternatives of each other and a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. Claim(s) 8 and 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Goodman and Bolto as applied to claims 1-4, 9-15 and 18-20 above, and further in view of Makkiya et al [Makkiya] US Pat No 11190901 Referring to claim 8, while Goodman and Bolto teach the invention including activating and suspending irrigation operation based on a result of a detection of a user device within a geofence, it is not explicitly taught that suspending operation is a result of electronically detecting the user device in an area outside of the geofences virtual boundary. Instead, we are not sure if the Goodman-Bolto combination controls irrigation based on if the user device is simply detected/not detected within the virtual boundary or if detection outside the virtual boundary occurs. Makkiya teaches that geofencing tracks an object to determine whether or not the object is detected within or outside of the geofence [col. 1 lines 6-23]. It would have been obvious to one of ordinary skill in the art before the effective filing date to include the teachings of Makkiya into the Goodman-Bolto combination because doing so would provide the details for how to control the irrigation using geofencing. Because Goodman teaches resuming irrigation once the users leave [col. 19 lines 29-33] it is interpreted that in the Goodman-Bolto-Mikkiya combination, once all the user devices are detected to enter an area outside the geofence, irrigation would resume. Referring to claim 17, this is rejected on the same basis as set forth hereinabove. Response to Arguments Applicant’s arguments with respect to claim(s) 1-20 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MARK A CONNOLLY whose telephone number is (571)272-3666. The examiner can normally be reached Monday-Friday 9am-5pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Kamini Shah can be reached at 571-272-2279. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /MARK A CONNOLLY/Primary Examiner, Art Unit 2115 1/31/26 1 Cited in the prior office action
Read full office action

Prosecution Timeline

Jun 13, 2023
Application Filed
Aug 01, 2025
Non-Final Rejection — §103
Oct 30, 2025
Response Filed
Jan 31, 2026
Non-Final Rejection — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

2-3
Expected OA Rounds
82%
Grant Probability
91%
With Interview (+8.9%)
2y 9m
Median Time to Grant
Moderate
PTA Risk
Based on 829 resolved cases by this examiner. Grant probability derived from career allow rate.

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