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 .
Applicant's request for reconsideration of the finality of the rejection of the last Office action is persuasive and, therefore, the finality of that action is withdrawn.
Status of Claims
This non-final office action is responsive to Applicant's submission filed 05/12/2026. Currently, claims 1-20 are pending. Claims 1-20 have been amended. No claims have been newly added and/or cancelled.
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 (i.e., abstract idea) without significantly more.
The claims recite method, system and computer program product for managing energy storage device charging process.
Exemplary claim 8 recites in part,
“determining an expected duration of an energy related event at a location that includes an energy storage device;
determining a duration of the energy related event and a recommended amount of charge for the energy storage device based on the duration;
controlling charging of the energy storage device prior to the energy related event through a battery management system based on the recommended amount of charge;
detecting occurrence of the energy related event;
determining a difference between a current charge amount of the energy storage device and the recommended amount of charge; and
controlling delivery of energy to the location based on the difference.”
The above limitations recite the steps of:
1) collecting and analyzing energy related event data,
2) determining energy related event duration and recommended amount of charge (based on energy related event data),
3) transmitting instructions charging energy storage device based on recommendation,
4) detecting occurrence of the energy related event (determined from collecting energy related event data)
5) comparing current and recommended charge amount,
6) transmitting instructions charging energy storage device based on comparison.
The above steps describe the process of managing energy storage device charging process. The above limitations, under their broadest reasonable interpretation, encompass "Certain Methods of Organizing Human Activity" (managing personal behavior or relationship or interaction between people) enumerated in MPEP 2106.04(a)(2)(II)(C). If a claim limitation, under its broadest reasonable interpretation, covers managing personal behavior or relationship or interaction between people, then it falls within the "Certain Methods of Organizing Human Activity" grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
The judicial exception is not integrated into a practical application. The claim recites the additional element of one or more computer-related devices. The additional computer-related elements merely invoke these additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
When considered individually or in combination, the recited additional elements do not integrate the abstract idea into a practical application.
The recitation of additional elements is acknowledged as identified above. The discussion with respect to the practical application is equally applicable to consideration of whether the claims amount to significantly more. The additional computer-related elements merely invoke these additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
Therefore, there are no meaningful recitations, considered in combination, that transform the judicial exception into a patent eligible application such that the claim amounts to significantly more than the judicial exception itself.
Accordingly, claim 1 is directed to a judicial exception (i.e., abstract idea) without significantly more.
Claims 1 and 15 recite similar limitations as set forth in claim 8, and therefore are rejected based on the same rationale.
Dependent claims 2-7, 9-14 and 16-20 recite limitations directed to the abstract idea, and do not integrate the abstract idea into a practical application nor amount to significantly more.
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.
The factual inquiries 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.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Appl. Pub. No. 2013/0046413 (Ellis), and further in view of U.S. Patent Appl. Pub. No. 2022/0102998 (Xu et al. – hereinafter Xu).
Referring to claim 1, Ellis discloses a method, comprising:
determining an expected duration of an energy related event at a location that includes an energy storage device; [See paragraphs 0095, 0096, 0098-100, 0105-0107 – The application server determines the given time period for a power disruption or loss.]
determining a duration of the energy related event and a recommended amount of charge for the energy storage device based on the duration; [See paragraphs 0096, 0098-0101, 0105-0107]
controlling charging of the energy storage device prior to the energy related event through a battery management system based on the recommended amount of charge; and [See paragraphs 0096, 0100, 0101, 0105-0107]
detecting occurrence of the energy related event. [See paragraphs 0102, 0105-0107]
Ellis does not explicitly disclose the limitations:
determining a difference between a current charge amount of the energy storage device and the recommended amount of charge; and
controlling delivery of energy to the location based on the difference.
Xu teaches a method with the limitations:
determining a difference between a current charge amount of the energy storage device and the recommended amount of charge; and [See paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
controlling delivery of energy to the location based on the difference. [See paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
It would have been obvious to one of ordinary skill in the art at the time of the effective filing date of the claimed invention to have modified the system executing the method of Ellis to have incorporated a power g threshold feature as in Xu with the motivation of efficiently managing charging of energy storage devices. [See Xu paragraphs 0017-0019; Ellis paragraphs 0098-0100]
Referring to claim 2, the combination of Ellis and Xu discloses the method of claim 1, further comprising: sending a notification of the recommended amount of charge to the location. [See Ellis paragraphs 0099-0102, 0105, 0106]
Referring to claim 3, the combination of Ellis and Xu discloses the method of claim 1, comprising: responsive to the energy storage device being charged above a threshold of the recommended amount, providing an amount of energy to the energy storage device for operating the location at full power. [See Xu paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
Referring to claim 4, the combination of Ellis and Xu discloses the method of claim 1, comprising: responsive to the energy storage device not being charged within a threshold of the recommended amount, providing an amount of energy to the energy storage device for operating the location at full power. [See Xu paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
Referring to claim 5, the combination of Ellis and Xu discloses the method of claim 1, comprising: withholding an amount of energy to the location based upon the difference. [See Xu paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
Referring to claim 6, the combination of Ellis and Xu discloses the method of claim 1, comprising: estimating a maximum rate of consumption for the energy storage device during the energy related event; and providing additional energy to the energy storage device during the energy related event. [See Xu paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
Referring to claim 7, the combination of Ellis and Xu discloses the method of claim 1, comprising recommending a greater amount of charge be delivered when the duration is greater than a threshold. [See Xu paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
Referring to claims 8-14, they recite similar limitations as set forth in claims 1-7, and therefore are rejected based on the same rationale.
Referring to claims 15-20, they recite similar limitations as set forth in claims 1-6, and therefore are rejected based on the same rationale.
Response to Arguments
101 Rejection
Applicant's arguments filed 05/12/2026 with respect to the rejection of claims 1-20 under 35 U.S.C. §101 have been fully considered but they are not persuasive.
In response to Applicant’s arguments, Examiner respectfully disagrees.
The claims recite the steps of: 1) collecting and analyzing energy related event data, 2) determining energy related event duration and recommended amount of charge (based on energy related event data), 3) transmitting instructions charging energy storage device based on recommendation (see filed spec. paragraph 0054), 4) detecting occurrence of the energy related event (determined from collected energy related event data), 5) comparing current and recommended charge amount, 6) transmitting instructions charging energy storage device based on comparison (see filed spec. paragraph 0054). The claims describe the process of managing energy storage device charging process, which covers managing personal behavior or relationship or interaction between people, and falls within the "Certain Methods of Organizing Human Activity" grouping of abstract ideas.
The recited computer-related elements (processor and memory) merely invoke these additional elements as a tool to perform the abstract idea and generally link the use of the abstract idea to a particular technological environment or field of use. See MPEP 2106.05(f) and MPEP 2106.05(h).
The steps of “controlling charging of the energy storage device prior to the energy related event through a battery management system based on the recommended amount of charge” and “controlling delivery or energy to the location based on the difference” simply transmits instructions to initiate a charging process to charge the energy storage device based on the recommended charge amount and difference between current and recommended charge amount comparison. When considered individually or in combination, the recited additional elements do not integrate the abstract idea into a practical application.
The claim recites managing charging and energy delivery in response to analyzing energy related event data and recommending a charge amount. In addition, the claim recites comparing current and recommended charge amounts to determine a difference. The battery management system transmits instructions to initiate a charging process to charge the energy storage device based on the recommended charge amount and difference between current and recommended charge amount comparison.
When considered as a whole, there are no meaningful recitations that transform the judicial exception into a patent eligible application such that the claim amounts to significantly more than the judicial exception itself.
Accordingly, the claimed invention is directed to a judicial exception (i.e., abstract idea) without significantly more.
103 Rejection
Applicant’s arguments, see pages 4 & 5, filed 05/12/2026, with respect to the rejection(s) of claim(s) 1-20 under 35 U.S.C. §103 have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of Ellis and Xu.
Conclusion
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/OLUSEGUN GOYEA/Primary Examiner, Art Unit 3627
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