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 .
Status of Claims
This final office action is responsive to Applicant’s submission filed 02/26/2026. 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,
“determine an expected duration of an energy related event at a location…;
determine a duration of the energy related event and a recommended amount of charge…prior to the event based on the duration;
detect occurrence of the energy related event;
determine a difference between a current charge amount of the energy storage device and the recommended amount of charge”.
The above limitations describe the steps of, 1) analyzing energy-related event data to determine energy-related event duration, 2) analyzing energy-related event data to provide a recommendation (amount of energy charge level), 3) monitoring energy-related event, and 4) analyzing current and recommended charge amount.
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 cited claim recites additional elements in the form of a computing device (processor and memory) for performing the limitations encompassing the identified abstract idea. The computing device represents using a generic computer as a tool to perform the judicial exception as in MPEP 2106.05(f). In addition, the additional limitations 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 of energy to the location based on the difference” simply describe a result-oriented solution and lacks details as to how the “charging of the energy storage device” or “delivery of energy to a location” are being controlled, which is equivalent to the words “apply it”. In other words, the additional limitations amount to mere instructions to apply an exception because they recite no more than an idea of a solution or outcome. See MPEP 2106.05(f).
When considered both individually and as a whole, the 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 practical application is equally applicable to consideration of whether the additional elements amount to significantly more. The recited computing elements represent using a computer as a tool to perform the judicial exception as in MPEP 2106.05(f). In addition, the “controlling” steps amount to post-solution activities based on determining recommendation charge amount and charge amount difference. See MPEP 2106.05(g).
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 8 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 similar rationale.
Dependent claims 2-7, 9-14 and 16-20 recite additional limitations directed to the identified 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, 2, 5, 8, 9, 12, 15, 16 and 19 are rejected under 35 U.S.C. 103 as being obvious over U.S. Patent Appl. Pub. No. 2024/0239226 (Lu et al. – hereinafter Lu), and further in view of U.S. Patent Appl. Pub. No. 2023/0286406 (Lu et al. – hereinafter Lu II).
The applied reference has a common applicant, assignee and/or inventor with the instant application. Based upon the earlier effectively filed date of the reference, it constitutes prior art under 35 U.S.C. 102(a)(2).
This rejection under 35 U.S.C. 103 might be overcome by: (1) a showing under 37 CFR 1.130(a) that the subject matter disclosed in the reference was obtained directly or indirectly from the inventor or a joint inventor of this application and is thus not prior art in accordance with 35 U.S.C.102(b)(2)(A); (2) a showing under 37 CFR 1.130(b) of a prior public disclosure under 35 U.S.C. 102(b)(2)(B); or (3) a statement pursuant to 35 U.S.C. 102(b)(2)(C) establishing that, not later than the effective filing date of the claimed invention, the subject matter disclosed and the claimed invention were either owned by the same person or subject to an obligation of assignment to the same person or subject to a joint research agreement. See generally MPEP § 717.02.
Referring to claim 1, Lu discloses a method, comprising:
determining an expected duration of an energy related event at a location that includes an energy storage device; [See paragraphs 0053, 0056, 0058-0060, 0067]
determining a duration of the energy related event and a recommended amount of charge for the energy storage device based on the duration; and [See paragraphs 0058, 0059, 0073-0075]
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. [See paragraphs 0058, 0059, 0073-0075]
Lu does not explicitly disclose the limitations:
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
responsive to the energy storage device being charged within a threshold of the recommended amount at the event, providing a first amount controlling delivery of energy to the location based on the difference.
Lu II teaches a method with the limitations:
detecting occurrence of the energy related event; [See paragraphs 0053, 0059, 0088]
determining a difference between a current charge amount of the energy storage device and the recommended amount of charge; and [See paragraphs 0053, 0059, 0088]
responsive to the energy storage device being charged within a threshold of the recommended amount at the event, providing a first amount controlling delivery of energy to the location based on the difference. [See paragraphs 0053, 0059, 0088]
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 Lu to have incorporated an energy management feature as in Lu II with the motivation of managing available energy at a location associated with an event. [See Lu II paragraph 0046; Lu paragraphs 0050, 0052]
Referring to claim 2, the combination of Lu and Lu II discloses the method of claim 1, further comprising: sending a notification of the recommended amount of charge to the location. [See Lu paragraphs 0058, 0059, 0073-0075]
Referring to claim 5, Lu and Lu II discloses the method of claim 1, comprising: withholding an amount of energy to the location based upon difference. [See Lu II paragraphs 0053, 0059, 0088]
Referring to claims 8, 9 and 12, they recite similar limitations as set forth in claims 1, 2 and 5, and therefore are rejected based on the same rationale.
Referring to claims 15, 16 and 19, they recite similar limitations as set forth in claims 1, 2 and 5, and therefore are rejected based on the same rationale.
Claims 3, 4, 6, 7, 10, 11, 13, 14, 17, 18 and 20 are rejected under 35 U.S.C. 103 as being obvious over Lu and Lu II, as applied to claims 1, 8 and 15, and further in view of U.S. Patent Appl. Pub. No. 2022/0102998 (Xu et al. – hereinafter Xu).
Referring to claim 3, Lu and Lu II discloses the method of claim 1 above. The combination does not explicitly disclose the limitation: 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 of operating the location at full power.
Xu teaches a method with the limitation: 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 of operating the location at full power. [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 combined teachings of Lu and Lu II to have incorporated a power charging threshold feature as in Xu with the motivation of efficiently managing charging of energy storage devices. [See Xu paragraphs 0017-0019; Lu paragraph 0046]
Referring to claim 4, the combination of Lu, Lu II 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 less than full power. [See Xu paragraphs 0029, 0030, 0037, 0038, 0089, 0090]
Referring to claim 6, the combination of Lu, Lu II 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 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 Lu, Lu II 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 10, 11, 13 and 14, they recite similar limitations as set forth in claims 3, 4, 6 and 7, and therefore are rejected based on the same rationale.
Referring to claims 17, 18 and 20, they recite similar limitations as set forth in claims 3, 4 and 6, and therefore are rejected based on the same rationale.
Response to Arguments
101 Rejection
Applicant's arguments filed 02/26/2026 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. Examiner notes that these arguments are directed to newly added claims, and have been addressed in the current rejection.
As discussed above under section 101, the claimed invention(s) is/are directed to a judicial exception (i.e., abstract idea) without significantly more.
The steps of determining an expected duration and recommended charge describe collecting and analyzing energy related event data to generate an expected duration and recommended charge. In addition, charge amount and recommended amount data is used to determine a charge difference. The limitations, covers managing personal behavior or relationship or interaction between people, which falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas.
The additional limitations 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 of energy to the location based on the difference” simply describe a result-oriented solution and lacks details as to how the “charging of the energy storage device” or “delivery of energy to a location” are being controlled, which is equivalent to the words “apply it”. In other words, the additional limitations amount to mere instructions to apply an exception because they recite no more than an idea of a solution or outcome. See MPEP 2106.05(f).
When considered both individually and as a whole, the additional elements do not integrate the abstract idea into a practical application.
The steps of “controlling charging an energy storage device” and “controlling grid energy delivery” steps amount to post-solution activities based on determining recommendation charge amount and charge amount difference. See MPEP 2106.05(g).
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, the claimed invention(s) is/are directed to a judicial exception (i.e., abstract idea) without significantly more.
102/103 Rejection(s)
Applicant’s arguments with respect to claims 1-20 have been considered but are moot because the new grounds of rejection do not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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.
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/OLUSEGUN GOYEA/Primary Examiner, Art Unit 3627