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 .
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, 3 –5, and 7 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. The claims do not fall within at least one of the four categories of patent eligible subject matter because the claims are directed to an Abstract Idea.
Step 1: Statutory Category
Claims 1, 3 – 5, and 7 are directed to a method or a system, which falls within the statutory categories of invention.
Step 2A – Prong One: Judicial Exception
Claim 1 recites limitations directed to acquiring manager information, and applicant-for-use information, determining whether a predetermined permission for use condition is established based on acquired information, and transmitting permission for use information to a user terminal when the condition is established.
These limitations collectively describe evaluating information and making a permission determination based on predefined criteria, which constitutes a mental process (evaluating information and making a permission decision), and organizing human activity (managing access to private resources) as such steps can be performed by a human using mental judgment or with a pen and paper.
Specifically, the claims recite:
Obtaining information about a manager and applicant
Determining whether a permission-for-use condition is satisfied
Determining whether a parking space is available; and
Granting permission if the conditions are met.
This is essentially a business/social rule governing how may use a private charging
facility. A human could conceptually perform the determination by reviewing:
Manager information
Applicant information
Current location information
Parking availability
and then deciding whether or not permission should be granted.
Additionally, the claimed subject matter is directed to organizing human activity, specifically the management and authorization of access to a privately owned charge facility, which is a fundamental activity relating to the administration of access rights between individuals.
Accordingly, claim 1 recites a judicial exception in the form of mental processes and methods of organizing human activity.
Claims 2 – 7 depend from claim 1 and merely further limit the abstract idea by specifying the type of information evaluated or the criteria used in the permission determination, and therefore also recite the same judicial exception.
Step 2A Prong Two: Integration into a Practical Application
The claims do not recite any additional element that integrates the abstract idea into a practical application.
Claim 1 further recites a user terminal database, and various “sections” configured to acquire information, determine whether a permission-for-use condition is established, and transmit permission information. However, these elements are recited at a high level of generality and merely function as generic computing components used to collect, compare and communicate information.
The claims do not recite
any improvement to the functioning of a computer, network, or charging infrastructure,
improvement to charging technology
an improved communication protocol
improved sensor operation; or
an improvement to EV charging itself.
The claims do not does implement the Abstract Idea in a manner that effects a particular transformation of an article. The claim also does not recite any specific technical means, data structures, or algorithms for performing the recited functions, nor does it control or optimize the operation of the private charge facility itself.
Instead, the claim merely automates the abstract permission-granting decision using conventional computer components as tools. Limiting the Abstract Idea to the context of a private charge facility or electric vehicle charging environment does not amount to a Practical Application as such a limitation represents intended use.
Claims 3 – 5, further specify the criteria used to determine whether the permission-for-use condition is established (e.g. matching providers, identification information, attributes, geography proximity, or facility availability), but these limitations likewise do not integrate the abstract idea into a practical application, as they merely recited additional abstract decision-making rules without imposing any technical improvement.
Claim 7 recites the same Abstract steps in method from and likewise fails to integrate the judicial exception into a practical application.
Step 2B, Prong 2: Additional elements
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements include:
an electric device,
a camera, and
communication of information (e.g. transmitting permission-for-use).
These elements are recited a high level of generality and represent well understood,
routine, conventional activities in the relevant field of electric vehicle charging and data processing.
For example:
acquiring permission information is conventional,
capturing images is conventional, and
communicating permission information is conventional.
The dependent claims further recite additional data sources and conventional techniques
(e.g determining whether a manager has been previously permitted to use a private facility), which likewise do not amount to significantly more than the Abstract Idea.
Taken individually and as an ordered combination, the additional elements do not add a specific limitation beyond the Abstract Idea that is not well understood, routine and conventional.
Hence, claims 1 and 7 are not patent eligible.
Dependent Claims 3-5 when analyzed as a whole, are held to be patent ineligible under 35
U.S.C. 101 because the additional recited limitation(s) fail(s) to establish that the claim(s) is/are not directed to an abstract idea. The additional elements, if any, in the dependent claims are not sufficient to amount to significantly more than the judicial exception for the same reasons as with Claim 1.
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.
Claims 1, 3-5, and 7 are rejected under 35 U.S.C. 103 as being unpatentable over Amano (US 20190355071) in view of Lee (US 20230264583).
Regarding claim 1, Amano teaches a charge support system communicates, through a communication network, with a management server including a manager database that stores manager information as information regarding a manager of a private charge facility which is a facility for charging an electric vehicle and a user database that stores applicant-for-use information as information regarding an applicant for use who wants to use the private charge
facility, and a user terminal used by the applicant for use, and that includes a processor, (figure 1 item 1 defined in paragraph [0023] as an information processing system) wherein the processor:
acquires the manager information from the manager database ([0024] discloses wherein the charge facility is private, such as a store, a house, company or other facility and the managers are registered (in a database) in advance. Figure 1 items 16 and 18 and paragraph [0027] disclose manager terminals 16 and management servers 18 which are used by managers. Paragraph [0029] discloses wherein the management server accesses a manager database (a data center) and processes information received and authorizes users);
acquires the applicant-for-use information from the user database (figure 1 item 14 and paragraphs [0030]-[0031] discloses an applicant-for-use information, interpreted as a “use request for an electric outlet.” The use request includes information specified by the applicant or user and information for identifying the user. This information is stored for the users that request to use the private charging facility); and
determines whether or not a predetermined permission-for-use condition is established between the applicant for use and the manager based on the applicant-for-use information, the manager information, and information of a current position of the applicant for use that is included in application-for-charge-facility-use information and that is detected by a position sensor included in the user terminal, upon receipt of the application-for-charge-facility-use information from the user terminal, the application-for-charge-facility use information being for applying for use of the private charge facility (paragraphs [0032]-[0033] discloses wherein the a permission for charge is determined by the management server transmitting an unlocking request, unlocking the electric outlet, thus granting permission to the user);
transmits permission-for-use information to the user terminal when the permission-for-use condition is established and the parking space for using the private charge facility is recognized as available (paragraphs [0032]-[0033] discloses wherein the a permission for charge is determined by the management server transmitting an unlocking request, unlocking the electric outlet, thus granting permission to the user),
the permission-for-use information being for making notification of permission for use of the private charge facility (figure 1 item 14 and paragraphs [0030]-[0031] discloses an applicant-for-use information, interpreted as a “use request for an electric outlet.” The use request includes information specified by the applicant or user and information for identifying the user. This information is stored for the users that request to use the private charging facility), wherein
the applicant-for-use information includes information of a manufacturer of the electric vehicle that the applicant for use wants to charge with the private charge facility (figure 1 item 14 and paragraphs [0030]-[0031] discloses an applicant-for-use information, interpreted as a “use request for an electric outlet.” The use request includes information specified by the applicant or user and information for identifying the user. This information is stored for the users that request to use the private charging facility),
the manager information includes information of a manufacturer of the private charge facility or an electric device that is used by the manager ([0024] discloses wherein the charge facility is private, such as a store, a house, company or other facility and the managers are registered (in a database) in advance. Figure 1 items 16 and 18 and paragraph [0027] disclose manager terminals 16 and management servers 18 which are used by managers. Paragraph [0029] discloses wherein the management server accesses a manager database (a data center) and processes information received and authorizes users), and
the permission-for-use condition to the effect that the manufacturer of the electric vehicle and the manufacturer of the private charge facility or the electric device are identical is set (paragraphs [0032]-[0033] discloses wherein the permission for charge is determined by the management server transmitting an unlocking request, unlocking the electric outlet, thus granting permission to the user).
Amano does not explicitly teach acquires a captured image of a parking space for using the private charge facility from a camera included in the private charge facility, and recognizes a usage situation of the parking space from the captured image acquired.
Lee teaches acquires a captured image of a parking space for using the private charge facility from a camera included in the private charge facility, and recognizes a usage situation of the parking space from the captured image acquired (defined in paragraph [0042] – [0043] wherein images acquired from camera data determines whether or not a vehicle is present in a parking spot).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the charging system of the Amano reference with the imaging system of the Lee reference so that an EV operator may be enabled to park and initiate a charging session without having to interact with the charging station (e.g., EVSE), with any software systems in the EV, or even with external applications (e.g., on a smart phone).
The suggestion/motivation for combination can be found in the Lee reference in paragraph [0025] wherein image data enables EV charging.
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Figure 1 shows a charge support system, an information processing system item 1 for authorizing charge at a private charging facility.
Regarding claim 3, Amano teaches the charge support system according to claim 1, wherein the applicant-for-use information includes identification information of the applicant for use (paragraph [0030] – [0031] discloses wherein the applicant-for use information, interpreted as a user terminal 14 includes information identifying the user and a request to use the charging facility), the manager information includes identification information of a subject person that the manager has previously permitted to use the private charge facility and the permission-for-use condition to the effect that the identification information of the applicant for use coincides with the identification information of the subject person that the manager has previously permitted to use the private charge facility is set (defined in paragraph [0041] wherein users are previously permitted or authorized to use the private charge facility. Paragraph [0046] discloses wherein information is stored, such as identifying information and charging information is stored, thus a previous user may be determined as an authorized user).
Regarding claim 7, Amano teaches a charge support method executed by a computer (figure 1 item 1 defined in paragraph [0023] as an information processing system),
a step of communicating, through a communication network, with a management server including a manager database that stores manager information as information regarding a manager of a private charge facility which is a facility for charging an electric vehicle and a user database that stores applicant-for-use information as information regarding an applicant for use who wants to use the private charge facility, and a user terminal used by the applicant for use (figure 1 item 1 defined in paragraph [0023] as an information processing system)
a manager information acquiring step of acquiring the manager information from the manager database ([0024] discloses wherein the charge facility is private, such as a store, a house, company or other facility and the managers are registered (in a database) in advance. Figure 1 items 16 and 18 and paragraph [0027] disclose manager terminals 16 and management servers 18 which are used by managers. Paragraph [0029] discloses wherein the management server accesses a manager database (a data center) and processes information received and authorizes users);
an applicant-for-use information acquiring step of acquiring the applicant- for-use information from the user database (figure 1 item 14 and paragraphs [0030]-[0031] discloses an applicant-for-use information, interpreted as a “use request for an electric outlet.” The use request includes information specified by the applicant or user and information for identifying the user. This information is stored for the users that request to use the private charging facility); and
step of determining whether or not a predetermined permission-for-use condition is established between the applicant for use and the manager based on the applicant-for-use information the manager information, and information of a current position of the applicant for use that is included in application-for-charge-facility-use information and that is detected by a position sensor included in the user terminal, upon receipt of the application-for-charge-facility-use information from the user terminal the application-for-charge-facility-use information being for applying for use of the private charge facility (paragraphs [0032]-[0033] discloses wherein the permission for charge is determined by the management server transmitting an unlocking request, unlocking the electric outlet, thus granting permission to the user);
wherein the applicant-for-use information includes information of a manufacturer of the electric vehicle that the applicant for use wants to charge with the private charge facility (figure 1 item 14 and paragraphs [0030]-[0031] discloses an applicant-for-use information, interpreted as a “use request for an electric outlet.” The use request includes information specified by the applicant or user and information for identifying the user. This information is stored for the users that request to use the private charging facility),
the manager information includes information of a manufacturer of the private charge facility or an electric device that is used by the manager ([0024] discloses wherein the charge facility is private, such as a store, a house, company or other facility and the managers are registered (in a database) in advance. Figure 1 items 16 and 18 and paragraph [0027] disclose manager terminals 16 and management servers 18 which are used by managers. Paragraph [0029] discloses wherein the management server accesses a manager database (a data center) and processes information received and authorizes users), and
the permission-for-use condition to the effect that the manufacturer of the electric vehicle and the manufacture of the private charge facility or the electric device are identical is set (figure 1 item 14 and paragraphs [0030]-[0031] discloses an applicant-for-use information, interpreted as a “use request for an electric outlet.” The use request includes information specified by the applicant or user and information for identifying the user. This information is stored for the users that request to use the private charging facility).
Amano does not explicitly teach a step of acquiring a captured image of a parking space for using the private charge facility from a camera included in the private charge facility, and recognizing a usage situation of the parking space from the captured image acquired.
Lee teaches a step of acquiring a captured image of a parking space for using the private charge facility from a camera included in the private charge facility, and recognizing a usage situation of the parking space from the captured image acquired.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the charging system of the Amano reference with the imaging system of the Lee reference so that an EV operator may be enabled to park and initiate a charging session without having to interact with the charging station (e.g., EVSE), with any software systems in the EV, or even with external applications (e.g., on a smart phone).
The suggestion/motivation for combination can be found in the Lee reference in paragraph [0025] wherein image data enables EV charging.
3. Claims 4 – 5 are rejected under 35 U.S.C. 103 as being unpatentable over Amano (US 20190355071) in view of Lee (US 20230264583) as applied to claim 1 in further view of Failing (US 20110302078).
Regarding claim 4, Amano and Lee teach the charge support system according to claim 1, but do not explicitly teach wherein the applicant-for-use information includes an attribute of the applicant for use, the manager information includes an attribute of the manager, and the permission-for-use condition to the effect that at least one element is common to the attribute of the applicant for use and the attribute of the manager is set.
Failing teaches wherein the applicant-for-use information includes an attribute of the applicant for use, the manager information includes an attribute of the manager, and the permission-for-use condition to the effect that at least one element is common to the attribute of the applicant for use and the attribute of the manager is set (defined in paragraphs [0136] and [0138] wherein information may be collected about the an applicant (a user), manager (owner) of the charging station with attributes related to the applicant and manager stored in a database).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the charging system of the Amano and Lee references with the charging system of the Failing reference so that vehicle charging is more efficient and convenient for the user.
The suggestion/motivation for combination can be found in the Failing reference in paragraph [0004] wherein charging is more efficient and convenient for the user.
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Failing figure 6 shows various databases to store various information about the applicant and manager to permit charging
Regarding claim 5, Amano and Lee teach the charge support system according to claim 1, but does not explicitly teach wherein, the manager information includes information of a place where the private charge facility is installed, and the processor determines whether or not the permission-for-use condition is established with the private charge facility that is installed at a place within a predetermined distance from the position where the applicant for use is positioned being as a target.
Failing teaches wherein the manager information includes information of a place where the private charge facility is installed, and the processor determines whether or not the permission-for-use condition is established with the private charge facility that is installed at a place within a predetermined distance from the position where the applicant for use is positioned being as a target (defined in paragraphs [0129] and [0345] wherein the position of the applicant (user) and vehicle is determined so that permission to charge is established).
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the charging system of the Amano and Lee references with the charging system of the Failing reference so that vehicle charging is more efficient and convenient for the user.
The suggestion/motivation for combination can be found in the Failing reference in paragraph [0004] wherein charging is more efficient and convenient for the user.
Response to Arguments
Applicant's arguments filed 05/05/2026 have been fully considered but they are not persuasive. Regarding rejections under 35 USC 101, as disclosed above, The amended claims do not overcome the rejection under 35 USC 101 and fall within at least one of the four categories of patent eligible subject matter because the claims are directed to an Abstract Idea. Specifically, the claims recite limitations directed to acquiring manager information, and applicant-for-use information, determining whether a predetermined permission for use condition is established based on acquired information, and transmitting permission for use information to a user terminal when the condition is established.
These limitations collectively describe evaluating information and making a permission determination based on predefined criteria, which constitutes a mental process (evaluating information and making a permission decision), and organizing human activity (managing access to private resources) as such steps can be performed by a human using mental judgment or with a pen and paper.
For these reasons, under 35 USC 101, the claims are not patent eligible.
Regarding the rejections under 35 USC 112, the amended claims overcome the rejection and the rejection is withdrawn.
Regarding the prior art rejections under 35 USC 102 and 35 USC 103, the Applicant’s arguments, see Arguments/Remarks, filed 05/05/2026, with respect to the rejection(s) of claims 1, 3-5, and 7 under Amano and Failing 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 Amano, Lee and Failing.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
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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.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALEXIS B PACHECO whose telephone number is (571)272-5979. The examiner can normally be reached M-F 9:00 - 5:30.
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ALEXIS BOATENG PACHECO
Primary Examiner
Art Unit 2859
/ALEXIS B PACHECO/Primary Examiner, Art Unit 2859
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