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
Claims 1 – 7 were previously pending and subject to a final office action mailed 02/07/2025. Claims 1 & 4 – 5 were amended in a reply filed 02/06/2026. Claims 1 – 7 are currently pending and subject to the non-final office action below.
Continued Examination Under 37 CFR 1.114
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 after final rejection on 02/06/2026 has been entered.
Response to Arguments
Applicant’s arguments filed 02/06/2026 with respect to the previous rejection under 35 USC 101 of the claims have been considered but are not persuasive.
Applicant initially argues that “integrates any alleged abstract idea into a practical application and satisfies Step 2A Prong Two” because “The generation of restoration task contents is a new technical output of the system, derived directly from image-based state comparison logic, that configures how the system responds to detected physical-state changes in the rental space. Through this integrated sequence, the claimed system improves the technical functioning of rental space management systems by enabling unattended operation with reliable, machine- determined restoration decisions that are temporally aligned with reservations and tied to concrete image data. The claim addresses a technical problem identified in the specification- namely, the inability of conventional systems to determine restoration needs without on-site human inspection-by introducing a specific technical solution involving coordinated image capture, comparison, and task generation.”
Examiner respectfully disagrees that the recited judicial exception is integrated into a practical application, because the functionality of determining restoration needs based on a comparison of before-and after-sates, as well as task generation, does not amount to an improvement to the functioning of a computing device or any other technology because these steps are a part of the recited judicial exception. Additionally, the additional elements of: “cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time” and “captured by the camera” amount to insignificant extra-solution activity (e.g., pre/post-solution activity), such as mere data gathering (See MPEP 2106.05(g)). Adding an initial step of collecting image data to a process that only recites alerting an administrator when it is determined that restoration is needed (a commercial interaction) does not add a meaningful limitation to the process of rental space management.
Also, the Federal Circuit has also indicated that mere automation of manual processes or increasing the speed of a process where these purported improvements come solely from the capabilities of a general-purpose computer are not sufficient to show an improvement in computer-functionality. FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016); Credit Acceptance Corp. v. Westlake Services, 859 F.3d 1044, 1055, 123USPQ2d 1100, 1108-09 (Fed. Cir. 2017). (See MPEP § 2106.04(a)(I)). Applicant’s instant claims do not present a technological process that improves the functions of a computer or any other technology: they merely automate steps that humans could perform manually i.e., comparing information and generating a maintenance request.
Examiner further notes that “TLI Communications provides an example of a claim invoking computers and other machinery merely as a tool to perform an existing process. The court stated that the claims describe steps of recording, administration and archiving of digital images {emphasis added}, and found them to be directed to the abstract idea of classifying and storing digital images in an organized manner. 823 F.3d at 612, 118 USPQ2d at 1747. The court then turned to the additional elements of performing these functions using a telephone unit and a server and noted that these elements were being used in their ordinary capacity (i.e., the telephone unit is used to make calls and operate as a digital camera {emphasis added} including compressing images and transmitting those images, and the server simply receives data, extracts classification information from the received data, and stores the digital images based on the extracted information). 823 F.3d at 612-13, 118 USPQ2d at 1747-48. In other words, the claims invoked the telephone unit and server merely as tools to execute the abstract idea.” (See MPEP § 2106.04(f)(2)). Therefore, the recited judicial exception is not integrated into a practical application because the “camera capture and image-based analysis of start and end states” amounts to insignificant extra-solution activity (e.g., pre/post-solution activity), such as mere data gathering (See MPEP 2106.05(g)), in addition to being no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Additionally, Applicant’s invention does not entail any improvements to the functionality of a computing device or any other technology. Examiner submits, as per step 2A Prong 1, that the invention is deemed to be directed to an abstract idea as explained in the below 101 rejection. A generic computer is merely automating the steps of the abstract idea that humans routinely perform in a commercial interaction. For example, as cited from Enfish, “the first step in the Alice inquiry in this case asks whether the focus of the claims is on the specific asserted improvement in computer capabilities (i.e., the self-referential table for a computer database) or, instead, on a process that qualifies as an “abstract idea” for which computers are invoked merely as a tool. As noted infra, in Bilski and Alice and virtually all of the computer-related § 101 cases we have issued in light of those Supreme Court decisions, it was clear that the claims were of the latter type—requiring that the analysis proceed to the second step of the Alice inquiry, which asks if nevertheless there is some inventive concept in the application of the abstract idea.” See Alice, 134 S. Ct. at 2355, 2357–59. In this case, however, the plain focus of the claims is not to an improvement to computer functionality itself, but “on economic or other tasks for which a computer is used in its ordinary capacity.” The instant claims are directed to a method of organizing human activity, which invokes generic computer components as a mere tool for implementation, rather to an improvement thereof. For example, the claims are not directed to an improvement in the functionality of a computing device or other technology; thus, the claims are directed to a judicial exception without significantly more, and the 101 rejection is maintained
Applicant’s arguments filed 02/06/2026 with respect to the previous prior art rejections of the claims have been considered but are not persuasive.
Applicant initially argues that “The Office Action points to a feature in Yanaga that involves notifying an administrator that a rental space is soiled. This notification merely describes the current state and does not teach or suggest generating restoration task contents identifying actions corresponding to the comparison result.”
Examiner respectfully disagrees, as Yanaga, in para. 68, discloses that “if the inner camera 42 or the sensor detects that the user has soiled the cabin of the vehicle 101, …the user… can be notified… to return the cabin of the vehicle 101 to the state from before the cabin was used.” Also see paras. 87 & 100 – 102. In other words, Yanaga discloses generating and transmitting user information comprising a cleaning (i.e., restoration action) request to a rental space user when the rental space is detected to be more soiled at the end of a rental period than at the beginning of the rental period. To the extent to which Yanaga does not appear to explicitly disclose sending this information to an administrator of the rental space, Hori, in at least paras. 17 & 49, teaches an “owner 51” of a rental space (i.e., administrator of the rental space), with a “communication terminal 50 owned by the owner 51.”
Since each individual element and its function are shown in the prior art, albeit shown in separate references, the difference between the claimed subject matter and the prior art rests not on any individual element or function but in the very combination itself. That is in the substitution of the administrator of the rental space of Hori for the rental space user of Yanaga. Thus, the simple substitution of one known element for another (i.e., one type of instruction for another) producing a predictable result renders the claim obvious.
Applicant next argues that “the combination of references does not teach or suggest keying the capture of first and second images exactly to reservation start and end times as received from the user, as recited in claim 1.”
Examiner respectfully disagrees, and initially submits that, under the broadest reasonable interpretation, the recited steps of “cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time” encompass capturing an image showing the rental space at any time before the user begins usage of the space, as well as capturing an image showing the rental space at any time after the user has finished using of the space. This is because these images would necessarily capture “an original state of the rental space at the reservation start time” (i.e., how the space appears in a photo at the start time) as well as “an end state of the rental space at the reservation end time” (i.e., how the space appears in a photo at the end time). For example, Yanaga discloses receiving a set time period as per paras. 61 – 62. Yanaga further discloses the functionality of capturing an image of how the space appears in a photo at the start time as well as an image depicting how the space appears in a photo at the end of the rental period in paras. 67 – 68, noting that “after the planned usage time has passed… the vehicle 101 may measure a change in the state of the vehicle cabin between before and after the user has used the vehicle 101.” As per para. 87, the system performs the step of “ascertaining the state of the vehicle before and after the user uses the vehicle cabin… if it is determined that the change in the state of the vehicle cabin is outside a predetermined range” using the captured images representing the cleanliness state at the start of the reservation and the cleanliness state at the end of the reservation. Therefore, Examiner respectfully submits that the combination of cited references discloses all of the limitations of the currently-amended claims.
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 – 7 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1
Claims 1 – 7 are directed to a system (i.e., a machine). Therefore, claims 1 – 7 all fall within the one of the four statutory categories of invention.
Step 2A, Prong One
Independent claim 1 substantially recites: store and set reservation information received from a user of a rental space, the reservation information including a reservation date, a reservation start time, and a reservation end time; determine whether original state restoration of the rental space is required by comparing the original state of the rental space in the first image... and the end state of the rental space in the second image…; and according to a determination that original state restoration of the rental space is required, generate restoration task contents identifying one or more restoration actions corresponding to a result of the comparison between the original state and the end state, and transmit the restoration task contents and user information to an administrator of the rental space.
The limitations stated above are processes that, under the broadest reasonable interpretation, covers performance of the limitation in a business relation or commercial interaction. That is, the functions in the context of this claim encompass managing rental space transactions. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in a commercial interaction, then it falls within the "Certain Methods of Organizing Human Activity" grouping of abstract ideas e.g., “commercial or legal interactions (including marketing or sales activities or behaviors; business relations).” Accordingly, the claim recites an abstract idea.
Step 2A, Prong Two
The judicial exception is not integrated into a practical application. Claim 1, as a whole, amounts to: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent) as well as (ii) adding insignificant extra-solution activity to the judicial exception. The claim recites the additional computer-related elements of: “management server,” “processor,” and “memory storing one or more programs for execution by the processor, the one or more programs including instructions,” as well as the additional elements of: “cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time” and “captured by the camera.”
The additional element of management server is recited at a high-level of generality (See Para. 26 of Applicant’s specification discussing the “management server 3”), such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
The additional element of processor is recited at a high-level of generality (See Para. 33 of Applicant’s specification discussing the “CPU”), such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
The additional element of “memory storing one or more programs for execution by the processor, the one or more programs including instructions” is recited at a high-level of generality (See Paras. 33, 52, & 54 of Applicant’s specification), such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
The additional elements of: “cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time” and “captured by the camera” amount to insignificant extra-solution activity (e.g., pre/post-solution activity), such as mere data gathering (See MPEP 2106.05(g)), in addition to being no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Accordingly, these additional elements, when viewed as a whole/ordered combination (See Figure. 1, showing all the additional elements in combination), do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Thus, the claim is directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent), and (ii) adding insignificant extra-solution activity to the judicial exception, and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)); and (ii) adding insignificant extra-solution activity (e.g., pre-solution activity, such as mere data storage / data gathering / data transmission) to the judicial exception (See MPEP2106.05(g)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
The extra-solution functionality of: “cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time” and “captured by the camera.” is recited at a high-level of generality and performs generic computer functions (data gathering) that are well-understood, routine and conventional activities previously known in the industry (See MPEP 2106.05(d)(II)). Additionally, Para. 29 of Applicant’s instant specification generically discloses the “image capturing unit 24” at a high-level of generality demonstrating the well-understood, routine, conventional nature of using a camera to capture images. Moreover, these limitations are also no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Therefore, the additional elements of: “management server,” “processor,” and “memory storing one or more programs for execution by the processor, the one or more programs including instructions,” as well as the additional elements of: “cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time” and “captured by the camera,” fail to integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claims adds significantly more (i.e., an inventive concept) to the abstract idea. There is no indication that the combination of elements, taken both individually and as an ordered combination, improves the functioning of a computer or improves any other technology. Thus, the claims are not patent eligible.
Furthermore, dependent claims 2 – 7 are merely directed to the particulars of the abstract idea and likewise do not add significantly more to the above-identified judicial exception. The limitations of the claims, when considered both individually and as an ordered combination, do not transform the abstract idea that they recite into patent-eligible subject matter because the claims simply instruct the practitioner to implement the abstract idea with generic computer components that conduct generic computer functions within a certain field of use, and thus are ineligible.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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, & 4 are rejected under 35 U.S.C. 103 as being unpatentable over Yanaga et al. (US 20190366979 A1) in view of Hori et al. (US 20190303999 A1).
As per claim 1, Yanaga discloses a rental space management system including:
• a management server, the management server including a processor and memory storing one or more programs for execution by the processor, the one or more programs including instructions (claim 1, paras. 6, 18 – 20, & 38 – 39, a server that manages a “cabin” of rental “vehicle 101” “by executing various types of programs”) that cause the processor to:
Regarding the following limitation,
• store and set reservation information received from a user of a rental space, the reservation information including a reservation date, a reservation start time, and a reservation end time,
Yanaga, in Fig. 1 & para. 18, discloses a “user terminal 103, which can communicate with… the management server 102,” which, as per paras. 20 – 21, 40, 53, 60 – 62, 75 transmits reservation request information to server 102 for storage as per 53 & 61 – 63. As per paras. 57, 61, 75, & 83, the user requests a “time period” for the reservation request information which is set by the server, which highly suggests, but does not appear to explicitly disclose wherein the reservation request information specifies a start and end time as well as a date for the reservation. However, Hori, in para. 52, teaches that reservation request information includes a requested “a reservation time/date (for example, a scheduled time/date of start of use and a scheduled time/date of end of use).”
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to include the date, start time, and end time of Hori in the reservation request information of Yanaga with the motivation to allow the rental space to be rented by a user having a “tendency which matches, as much as possible, the owner's own desire” of keeping the rental space’s “interior or exterior clean” as evidenced by Hori ([0034] & [0066]).
Yanaga further discloses:
• cause a camera to capture (i) a first image of an original state of the rental space at the reservation start time, and (ii) a second image of an end state of the rental space at the reservation end time; determine whether original state restoration of the rental space is required by comparing the original state of the rental space in the first image captured by the camera and the end state of the rental space in the second image captured by the camera (para. 29 & 87, “detection unit 43 is a sensor installed within the cabin. Also see paras. 67 – 68 & 99, noting monitoring a state of the rental cabin space. As per para. 68, the system can “measure a change in the state of the vehicle cabin between before and after the user has used the vehicle 101, by using the inner camera 42.” As per para. 87, the system performs the step of “ascertaining the state of the vehicle before and after the user uses the vehicle cabin… if it is determined that the change in the state of the vehicle cabin is outside a predetermined range” using the captured images representing the cleanliness state at the start of the reservation and the cleanliness state at the end of the reservation.);
Regarding the following limitations,
• and according to a determination that original state restoration of the rental space is required, generate restoration task contents identifying one or more restoration actions corresponding to a result of the comparison between the original state and the end state, and transmit the restoration task contents and user information to an administrator of the rental space,
Yanaga, in para. 68, discloses that “if the inner camera 42 or the sensor detects that the user has soiled the cabin of the vehicle 101, …the user… can be notified… to return the cabin of the vehicle 101 to the state from before the cabin was used.” Also see paras. 87 & 100 – 102. In other words, Yanaga discloses generating and transmitting user information comprising a cleaning (i.e., restoration action) request to a rental space user when the rental space is detected to be more soiled at the end of a rental period than at the beginning of the rental period. To the extent to which Yanaga does not appear to explicitly disclose sending this information to an administrator of the rental space, Hori, in at least paras. 17 & 49, teaches an “owner 51” of a rental space (i.e., administrator of the rental space), with a “communication terminal 50 owned by the owner 51.”
Since each individual element and its function are shown in the prior art, albeit shown in separate references, the difference between the claimed subject matter and the prior art rests not on any individual element or function but in the very combination itself. That is in the substitution of the administrator of the rental space of Hori for the rental space user of Yanaga. Thus, the simple substitution of one known element for another (i.e., one type of instruction for another) producing a predictable result renders the claim obvious.
As per claim 2, Yanaga / Hori discloses the limitations of claim 1. Yanaga further discloses:
• wherein the instructions further cause the processor to, according to the determination that original state restoration of the rental space is required, charge a cost of the original state restoration to the user of the rental space (para. 68, after “the inner camera 42 or the sensor detects that the user has soiled the cabin of the vehicle 101,” subsequently “the management server 102 can bill” the user “an additional fee” for the soil damage that was caused during the rental period.).
As per claim 4, Yanaga / Hori discloses the limitations of claim 1. Yanaga further discloses:
• wherein the instructions further cause the processor to, according to the determination that original state restoration of the rental space is required, transmit the restoration task contents to an original state restoration service for the rental space (para. 68, when the cabin needs to be returned to the original state “administrator can be notified.”).
Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Yanaga / Hori, in view of Il et al. (US 20210166302 A1).
As per Claim 3, Yanaga / Hori discloses the limitations of claim 1. Regarding the following limitation, Yanaga, in para. 68, discloses that the server 102 can charge users fees related to cabin states. To the extent to which Yanaga / Hori does not appear to explicitly disclose wherein the server can provide discounts, Il discloses wherein:
• the instructions further cause the processor to, according to the determination that original state restoration of the rental space is required, charge a subsequent user who uses the rental space after the reservation end time by discounting a usage fee of the rental space for the subsequent user (paras. 13 – 14, 53, 58, & 67 – 69, & 73 – 75, determines a discount amount according to the decline in cleanliness of a rental cabin space to offer a subsequent user the discount.).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to include the aforementioned teachings of Il in the invention of Yanaga / Hori with the motivation to offer a lower cost rental to users who are not worried about cleanliness, as evidenced by Il ([0069]).
Claims 5 – 6 are rejected under 35 U.S.C. 103 as being unpatentable over Yanaga / Hori, in view of Starns (US 20190204097 A1).
As per Claim 5, Yanaga / Hori discloses the limitations of claim 4. To the extent to which Yanaga / Hori does not appear to explicitly disclose the following limitation, Starns discloses:
• wherein the restoration task contents include work contents for performing the original state restoration (paras. 30 & 80 – 81, sending a cleaning request to a restorer which, as per para. 64, involves generating work contents for performing the original state restoration, such as a requested “cleaning type, such as wet cleaning or dry cleaning.”).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to include the aforementioned teachings of Starns in the invention of Yanaga / Hori with the motivation to “benefit the third-party service providers” by enabling them to “make use of their excess bandwidth,” as evidenced by Starns ([0018]).
As per Claim 6, Yanaga / Hori / Starns discloses the limitations of claim 5. To the extent to which Yanaga / Hori does not appear to explicitly disclose the following limitation, Starns discloses wherein:
• the work contents include restoring an arrangement of equipment in the rental space, replenishing equipment in the rental space, or repairing equipment in the rental space (paras. 30, 70, & 80 – 82, sending a cleaning order to a restorer which, as per para. 64, involves generating work contents for performing the original state restoration including repairing broken components “and/or address a wear-and-tear condition.”). Rationale to combine Starns persists.
Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over Yanaga / Hori, in view of Watts et al. (US 20200372556 A1).
As per Claim 7, Yanaga / Hori discloses the limitations of claim 4. To the extent to which Yanaga / Hori does not appear to explicitly disclose the following limitation, Watts discloses wherein:
• the instructions further cause the processor to pay a cost of the original state restoration to the original state restoration service for the rental space (paras. 57, 73, & 90, “service request platform 109 may disperse payment to the… cleaners immediately upon completion of the service.”).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to include the aforementioned teachings of Watts in the invention of Yanaga / Hori with the motivation to ensure that service providers are paid for their services.
Conclusion
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/BRYAN J KIRK/Examiner, Art Unit 3628