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 .
DETAILED ACTION
This Office Action is in response to an AMENDMENT entered September 22, 2026, for the patent application 18/324,666.
Continued Examination Under 37 C.F.R. §1.114
A request for continued examination ("RCE") under 37 C.F.R. §1.114, including the fee set forth in 37 C.F.R. §1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 C.F.R. §1.114, and the fee set forth in 37 C.F.R. §1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 on September 22, 2026 has been entered.
Information Disclosure Statement
The Information Disclosure Statement (IDS) submitted on July 28, 2026 was filed in compliance with the provisions of 37 CFR 1.97. Accordingly, this Information Disclosure Statement is being considered by the Examiner.
Status of Claims
Claims 1, 7 – 14, 16, 17, 20 and 22 - 29 are pending in the application.
Claims 1, 16 and 20 are currently amended in the application.
Claims 2 – 6, 15, 18, 19 and 21 are cancelled in the application without prejudice or disclaimer.
Claims 22 - 29 are added in the application.
Response to Arguments
Applicant’s arguments filed January 22, 2026 with respect to claims 1, 7 – 14, 16, 17, 20 and 22 - 29 have been fully considered but are moot in view of the new ground(s) of rejections.
A review of the claims and updated search necessitated the rejections below.
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.
Claim(s) 1, 7 – 14, 16, 17, 20 and 22 - 29 are rejected under 35 U.S.C. § 101 because the claimed invention is directed to an abstract idea without significantly more.
Claims 1, 7 – 14, 16, 17, 20 and 22 - 29 are either directed to a method or system or computer readable medium, which are statutory categories of invention. (Step 1: YES).
The Examiner has identified method claim 1 as the claim that represents the claimed invention for analysis and is similar to system claim 16. Claim 1 recites the limitations of:
( A ) operating the pollution reduction system to generate electricity from solar energy;
( B ) determining a baseline amount of greenhouse gases (GHGs) associated with operation of a facility operating the pollution reduction system, wherein the baseline amount of GHGs is determined based at least in part on an amount of electricity consumed by the facility from one or more GHG-producing energy sources using an equation comprising:
BEy =
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( C ) reducing, based at least in part on producing electricity as a result of operating the pollution reduction system, GHGs;
( D ) detecting, with the sensor that comprises the electricity meter physically installed at the facility and electrically coupled to an output of the at least one solar panel, an amount of electricity produced by the at least one solar panel;
( E ) detecting, an amount of reduction of GHGs based at least in part on the baseline amount of GHGs associated with operation of the facility offset with the amount of electricity produced;
( F ) automatically and continuously transmitting, in real time via the communications network, data associated with the detected amount of electricity produced from the sensor to the computing device;
( G ) automatically determining, by the computing device responsive to receiving data from the sensor, based at least in part on the amount of detected reduction of GHGs, an amount of carbon credits earned for the reduction of GHGs produced by the pollution reduction system using a carbon reduction calculation methodology that converts the amount of reduction of GHGs to the amount of carbon credits earned; and
( H ) transmitting, to the cryptocurrency system comprising a distributed computing system, an indication of the determined amount of carbon credits, wherein transmitting the indication results in awarding, by the cryptocurrency system, an amount of cryptocurrency corresponding to the reduction of GHGs produced by the pollution reduction system.
These limitations without the bolded limitations above, cover performance of the limitations as certain methods of organizing human activity under their broadest reasonable interpretation.
More specifically, these limitations cover performance of the limitations as a fundamental economic practice.
In summary, if claim 1 limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic practice, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea. Claim 16 are also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims are abstract).
The use of the pollution reduction system or any of the bolded limitations in claim 1 are just applying generic computer components to the recited abstract limitations. Similar arguments apply to claim 16.
Therefore, the above mentioned judicial exception is not integrated into a practical application by merely applying generic computer components (bolded elements).
Furthermore, the “operating” and “reducing” steps are recited at a high level of generality and amounts to mere data gathering/transmitting, which are forms of insignificant extra-solution activity (See MPEP 2106.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); and OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015)).
In addition, supported by specification, the computer hardware are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component., see MPEP 2106.05(f), where applying a computer or using a computer is not indicative of a practical application).
Claim 1, limitation ( A ) - ( C ), ( H ) and ( G ) above in Applicant’s specification para [0030], which discloses “The pollution reduction system 110 may include any system configured to reduce production of carbon or remove carbon from the environment. For example, the pollution reduction system 110 may include any system that produces electricity without carbon emissions or with reduced carbon emission, that increases recycling, that removes carbon from the environment, and/or reduces the production of carbon. The electricity generated by the system may be used to power homes, power electric cars, power businesses, power industrial facilities, and/or provide power to any energy consumer. The recycled carbon is used to create new products and the removed carbon may be stored. Thus, the pollution reduction system 110 reduces carbon emissions that are produced for productive purposes.“.
Also, claim 1, limitation ( D ), ( F ) and ( G )above in Applicant’s specification para [0024], which discloses “In some embodiments, the system comprises a recycling system, a sensor, a computing device, a communication network, and a cryptocurrency system. The method involves operating the recycling system to recycle plastic waste and detecting the amount of plastic recycled using a sensor. The computing device calculates the plastic credits earned for the amount of plastic recycled based on the weight of recycled plastic or a plastic emissions calculation methodology as a "Proof of Work". The cryptocurrency system awards an amount of cryptocurrency corresponding to the plastic credits earned. In some embodiments, the system may be installed within a facility to recycle plastic waste and generate plastic credits. The disclosed technology allows for the incentivization and tracking of plastic waste recycling through the use of cryptocurrency.“.
Also, claim 1, limitation ( D ) above in Applicant’s specification para [0051], which discloses “The method 300 further includes transmitting 310 data associated with the reduction in GHGs from the sensor 120 to the computing device 140 using the communications network 130. In some embodiments, the sensor 120 may include a standard electricity meter with wireless capabilities and the communications network 130 may include a wireless network. The data associated with the reduction in GHGs may be transmitted from the sensor 120 to the computing device 130 over the wireless network through the internet. In alternative embodiments, the communications network 130 maybe any type of communications network that transmits the data associated with the reduction in GHGs in any manner that enables the systems and methods described herein to operate as described herein.“.
Also, claim 1, limitation ( F ) and ( G ) above in Applicant’s specification para [0051], which discloses “The method 300 further includes transmitting 310 data associated with the reduction in GHGs from the sensor 120 to the computing device 140 using the communications network 130. In some embodiments, the sensor 120 may include a standard electricity meter with wireless capabilities and the communications network 130 may include a wireless network. The data associated with the reduction in GHGs may be transmitted from the sensor 120 to the computing device 130 over the wireless network through the internet. In alternative embodiments, the communications network 130 maybe any type of communications network that transmits the data associated with the reduction in GHGs in any manner that enables the systems and methods described herein to operate as described herein.“.
Also, claim 1, limitation ( H ) above in Applicant’s specification para [0038], which discloses “In the illustrated embodiment, the computing device 140 uses a calculation methodology to convert the reduction in GHGs or the amount of plastics recycled to a credit value suitable for the cryptocurrency system 150. For example, in some embodiments, the calculation methodology may include a GHG emission calculation methodology including a mathematical formula that converts the reduction in GHGs to the carbon credit value suitable for the cryptocurrency system 150. More specifically, in the illustrated embodiment, the computing device 140 may deter- mine a predetermine a baseline amount of GHGs that a facility, home, business, and/or other electricity consumer produces. The computing device 140 then compares the amount of GHGs produced or electricity consumed when the facility, home, business, and/or other electricity consumer is operating with the pollution reduction system 110. The computing device 140 then calculates the carbon credits based on the reduction of GHGs. The computing device 140 then sends data corresponding to the carbon credits that are to be awarded to the cryptocurrency system 150.“.
Also, claim 1, limitation ( H ) above in Applicant’s specification para [0041], which discloses “The cryptocurrency system 150 may include one or more computing devices including one or more processors and memory for processing information and storing information in one or more cryptocurrency data structures. The memory generally includes both volatile memory (e.g., RAM) and non-volatile memory (e.g., flash memory). An operating system resides in the memory and is executed by the processor(s). In some embodiments, the cryptocurrency system 150 may be a centralized cryptocurrency network including a server on a distributed decentralized computing system.“. Similar arguments apply to claim 16.
Additionally, claim 20 recites the limitations of:
( H ) operating the GHG reduction system comprising the vehicle charging station to reduce GHGs produced by a facility;
( I ) determining a baseline amount of GHGs associated with operation of a facility, wherein the baseline amount of GHGs is determined using an equation comprising:
BEy =
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( J ) where BEy is baseline emissions in a year y, EDi,v is electricity delivered by a project charging systems serving applicable fleet i in project year y,EF,rv is a emission factor for fossil fuel f used by a comparable fleet of fossil fuel vehicles j in project year y, IRi is a technology improvement rate factor for an applicable fleet i, AFEC,v is a weighted average electricity consumption per 100 miles rating for EVs in the applicable fleet i in projection year y, and MPG ,v is a weighted average miles per gallon rating for the fossil fuel vehicles comparable to each EV in the applicable fleet i in the project year y;
( K ) reducing, based at least in part on producing energy as a result of operating the vehicle charging station, greenhouse gases (GHGs);
( L ) detecting, with the sensor comprising the energy meter physically installed and electrically coupled to an output of the vehicle charging station, an amount of energy produced by the vehicle charging station;
( M ) detecting, responsive to operating the GHG reduction system, an amount of reduction of GHGs produced by the facility operating the vehicle charging station, wherein the amount of reduction of GHGs is based at least in part on the amount of energy produced by the vehicle charging station offset with the baseline amount of GHGs associated with operation of the facility;
( N ) determining an amount of carbon credits earned for the reduction of GHGs produced by the facility using a carbon reduction calculation methodology
BEy =
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,that converts the amount of reduction of GHGs to the amount of carbon credits earned; and
( O ) transmitting, to a cryptocurrency system comprising a distributed computing system, an indication of the determined amount of carbon credits, wherein transmitting the indication results in awarding, by the cryptocurrency system, an amount of cryptocurrency corresponding to the reduction of GHGs produced by the facility, wherein awarding the amount of cryptocurrency comprises:
verifying, that the determined amount of carbon credits satisfies one or more conditions set by an algorithm of the cryptocurrency system, wherein responsive to satisfying the one or more conditions, a proof of work is considered solved, a new block containing a blockchain containing a number of cryptocurrency units assigned to an owner address is created in a blockchain of the cryptocurrency system, and the blockchain with the new block is broadcasted across the distributed computing system.
These limitations without the bolded limitations above, cover performance of the limitations as certain methods of organizing human activity under their broadest reasonable interpretation.
More specifically, these limitations cover performance of the limitations as a fundamental economic practice and the mathematical concepts category of patent ineligible subject matter as a distinct calculation is taking place to achieve the baseline emissions number.
In summary, if claim 20 limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic practice and mathematical concepts, then it falls within the “Certain Methods of Organizing Human Activity” and “mathematical concepts “ grouping of abstract ideas. Accordingly, the claim recites an abstract idea. (Step 2A-Prong 1: YES. The claims are abstract).
The use of the GHG reduction system or any of the bolded limitations in claim 20 are just applying generic computer components to the recited abstract limitations.
Therefore, the above-mentioned judicial exception is not integrated into a practical application by merely applying generic computer components (bolded elements).
Furthermore, the “operating” and “reducing” steps are recited at a high level of generality and amounts to mere data gathering/transmitting, which are forms of insignificant extra-solution activity (See MPEP 2106.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); and OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015)).
In addition, supported by specification, the computer hardware are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component., see MPEP 2106.05(f), where applying a computer or using a computer is not indicative of a practical application).
Claim 20, limitation ( H ) and ( M ) above in Applicant’s specification para [0050], which discloses “The method 300 also includes detecting 308 a reduction in GHGs using the sensor 120. In some embodiments, the sensor 120 may include any sensor or meter that is configured to quantify the amount of GHGs the pollution reduction system 110 reduces or removes from the atmosphere. For example, in some embodiments, the sensor 120 may include a standard electricity meter that detects how much electricity is generated by the GHG reduction system 100. If the facility is the house and the pollution reduction system 110 is the solar panel, the electricity meter determines how much electricity is produced by the solar panel and how much electricity is consumed by the house from the grid or other GHG producing source of electricity.“.
Also, claim 20, limitation ( L ) above in Applicant’s specification para [0024], which discloses “In some embodiments, the system comprises a recycling system, a sensor, a computing device, a communication network, and a cryptocurrency system. The method involves operating the recycling system to recycle plastic waste and detecting the amount of plastic recycled using a sensor. The computing device calculates the plastic credits earned for the amount of plastic recycled based on the weight of recycled plastic or a plastic emissions calculation methodology as a "Proof of Work". The cryptocurrency system awards an amount of cryptocurrency corresponding to the plastic credits earned. In some embodiments, the system may be installed within a facility to recycle plastic waste and generate plastic credits. The disclosed technology allows for the incentivization and tracking of plastic waste recycling through the use of cryptocurrency.“.
Also, claim 20, limitation ( K ), ( L ) and ( M ) above in Applicant’s specification para [0039], which discloses “For example, when the pollution reduction system 110 includes an electric vehicle charging station, the GHG emissions calculation methodology includes calculating baseline emission based on Eqn. 1 shown below where BEY is the baseline emissions in a year y, EDi.y is the electricity delivered by a project charging systems serving applicable fleet i in project year y, EFu.y is the emission factor for the fossil fuel f used by comparable fleet vehicles j in project year y, IR; is the technology improvement rate factor for the applicable fleet i, AFECi.y is the weighted average electricity consumption per 100 miles rating for EVs in applicable fleet i in projection year y, and MPGi.y is the weighted average miles per gallon rating for the fossil fuel vehicles comparable to each EV in the applicable fleet i in the project year y:.“.
Also, claim 20, limitation ( O ) above in Applicant’s specification para [0038], which discloses “In the illustrated embodiment, the computing device 140 uses a calculation methodology to convert the reduction in GHGs or the amount of plastics recycled to a credit value suitable for the cryptocurrency system 150. For example, in some embodiments, the calculation methodology may include a GHG emission calculation methodology including a mathematical formula that converts the reduction in GHGs to the carbon credit value suitable for the cryptocurrency system 150. More specifically, in the illustrated embodiment, the computing device 140 may deter- mine a predetermine a baseline amount of GHGs that a facility, home, business, and/or other electricity consumer produces. The computing device 140 then compares the amount of GHGs produced or electricity consumed when the facility, home, business, and/or other electricity consumer is operating with the pollution reduction system 110. The computing device 140 then calculates the carbon credits based on the reduction of GHGs. The computing device 140 then sends data corresponding to the carbon credits that are to be awarded to the cryptocurrency system 150.“.
Also, claim 20, limitation ( O ) above in Applicant’s specification para [0044], which discloses “In some embodiments, the system 100 may include
one or more modules or segments, such as an emissions reduction application (not shown), loaded into an operating system on the memory (e.g., memory 220) and/or storage and executed by the processor(s). For example, these mod-ules may be located in the computing device 140. The emissions reduction application may include a calculation methodology implemented by a credit generation engine (not shown). Data such as emission measurements (e.g., a specified weight (e.g., one kilogram, one metric ton) of plastics recovered or recycled), hardware configurations, and hardware responses may be stored in the memory or storage and may be retrievable by the processor(s) for use by the credit generation engine. The storage may be local to the computing device 140 or may be remote and communicatively connected to the computing device 140 and may include another server. The storage may store resources that are requestable by other devices (not shown). The credit generation engine may execute on one or more processors to generate credits that should be awarded based on the measured emissions reduction. FIG. 2 illustrates a diagram of the cryptocurrency system 150. The cryptocurrency system 150 may be a decentralized network 200, such as a decentralized blockchain network, including one or more computing devices 140. Additionally, there may be no central authority controlling cryptocurrency network 200 and the data stored on the blockchain network 200 may be stored on a ledger 230 and may not be stored at a central location in its entirety. The blockchain network 200 may maintain one or more blockchains of continuously growing lists of data blocks, where each data block refers to previous blocks on its list. The requirement for each block to refer to all previous blocks in the blockchain, yields a chain of blocks that is hardened against tampering and revision, such that the information stored in the blockchain is immutable.”.
Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Therefore, claims 1, 16 and 20 are directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application).
The claims 1, 16 and 20 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements (bolded elements above) amount to no more than mere instructions to apply the abstract idea using generic computer components. In conclusion, merely "applying" the exception using generic computer components cannot provide an inventive concept. Therefore, the claims 1, 16, and 20 are not patent eligible under 35 USC 101. (Step 2B: NO. The claims do not provide significantly more).
Dependent Claims
Dependent claims 7 – 14, 17 and 22 - 29 are also rejected under 35 U.S.C. 101. Dependent claims 7 – 14, 17 and 22 - 29 are further define the abstract idea or further define the extra-solution activities that are present in independent claim 1 thus abstract idea correspond to certain methods of organizing human activity as presented above. Claims 7 – 14, 17 and 22 - 29 clearly further define the abstract idea as stated above and further define extra-solution activities such as presenting data and transmitting/receiving data.
Furthermore, dependent claims 7 – 14, 17 and 22 - 29 do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination.
Regarding claims 7 and 17, these claims merely recite, "comprising transmitting data associated with the reduction of GHGs produced by the pollution reduction system from the sensor to the computing device using the communications network.“. These limitations merely recite storing data in a server which amounts to no more than gathering/storing data which is a form of insignificant extra-solution activity (See MPEP 2106.0S(g)(3)(iii): GIP Technologies, 788 F.3d at 1363). This does not integrate the abstract idea into a practical application because it has been determined, by the courts, that the concept of storing data is well-understood, routine, and conventional activity (See MPEP 2106.0S(d)(II): Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015)). Similar arguments can be made for claim 13. Similar arguments can be made for claim 17.
Regarding claim 8, this claim merely provide further detail regarding the transmitting the amount of carbon credits, merely stating, “comprising transmitting the amount of carbon credits earned and/or the data associated with the reduction of GHGs produced by the pollution reduction system from the computing device to the cryptocurrency system using the communications network.”. This does not integrate the abstract idea into a practical application because it does not impose any meaningful limitation on practicing the abstract idea.
Regarding claim 9, this claim merely recite, "comprising verifying that the amount of carbon credits earned and/or the data associated with the reduction of GHGs produced by the pollution reduction system satisfies one or more conditions set by an algorithm of the cryptocurrency system.“. This limitation merely recites storing data in a server which amounts to no more than gathering/storing data which is a form of insignificant extra-solution activity (See MPEP 2106.0S(g)(3)(iii): GIP Technologies, 788 F.3d at 1363). This does not integrate the abstract idea into a practical application because it has been determined, by the courts, that the concept of storing data is well-understood, routine, and conventional activity (See MPEP 2106.0S(d)(II): Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015)).
Regarding claim 10, this claim merely provide further detail regarding the amount of cryptocurrency corresponding to the amount of carbon credits earned, recited merely stating “comprising awarding the amount of cryptocurrency corresponding to the amount of carbon credits earned and/or the data associated with the reduction of GHGs produced by the facility.". This does not integrate the abstract idea into a practical application because it does not impose any meaningful limitation on practicing the abstract idea.
Regarding claim 11, this claim merely add further description to the process of “comprising trading, selling, and/or buying the cryptocurrency.”. This amount to no more than mere data gathering/outputting as described in reference to claim 1 (see analysis above). Merely describing the trading, selling, and/or buying the cryptocurrency information does not integrate the abstract idea into a practical application, or amount to significantly more than the judicial exception, because it does not impose any meaningful limitations on practicing the abstract idea.
Regarding claim 12, merely recite additional steps that amount to no more than insignificant extra-solution activity. Specifically, claim 12 states, “wherein the calculation methodology comprises a mathematical formula.". This is a mathematical concept that is directed to the abstract idea in calculating the baseline emissions value. These steps amount to no more than mere data gathering/analysis, which is a form of insignificant extra- solution activity (See M PEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); and GIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015)). Such limitations do not integrate the abstract idea into a practical application, or amount to significantly than the abstract idea, because the courts have found the concept of data gathering to be well-understood, routine, and conventional activity (See MPEP 2106.05(d): GIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); and buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, (Fed. Cir. 2014)).
Regarding claim 13, this claim merely recite additional steps that amount to no more than insignificant extra-solution activity. Specifically, claim 13 states “wherein the system comprises the facility comprising a house.”. This does not integrate the abstract idea into a practical application because it does not impose any meaningful limitation on practicing the abstract idea.
Regarding claim 14, this claim merely recite, "further comprising at least one solar panel attached to the house, wherein the at least one solar panel operates and produces the electricity.“. This limitation merely recites describes that the system is made up of at least one solar panel attached to the house which is a form of insignificant extra-solution activity (See MPEP 2106.0S(g)(3)(iii): GIP Technologies, 788 F.3d at 1363). This does not integrate the abstract idea into a practical application because it has been determined, by the courts, that the concept of storing data is well-understood, routine, and conventional activity (See MPEP 2106.0S(d)(II): Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015)).
Regarding claims 22, 23 and 24 these claims merely recite additional steps that amount to no more than insignificant extra-solution activity. Specifically, claim 22 states “wherein the electricity meter is further configured to detect how much electricity is consumed by the facility from a grid or other GHG-producing source of electricity, and wherein the amount of reduction of GHGs is determined based at least in part on a difference between the amount of electricity consumed by the facility from the grid or other GHG-producing source of electricity and the amount of electricity produced by the at least one solar panel.”. These steps amount to no more than mere data gathering/analysis, which is a form of insignificant extra- solution activity (See M PEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); and GIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015)). Such limitations do not integrate the abstract idea into a practical application, or amount to significantly than the abstract idea, because the courts have found the concept of data gathering to be well-understood, routine, and conventional activity (See MPEP 2106.05(d): GIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); and buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, (Fed. Cir. 2014)). Similar arguments can be made for claims 23 and 24.
Regarding claims 25, 26 and 27 these claims merely recite additional steps that amount to no more than insignificant extra-solution activity. Specifically, claim 25 states “wherein the cryptocurrency system comprises a decentralized blockchain network including a plurality of computing devices forming nodes in the decentralized blockchain network, wherein each computing device of the plurality of computing devices stores a copy of at least a portion of a ledger of the decentralized blockchain network, and wherein the ledger is independently verifiable for accuracy by comparing the stored copies across the plurality of computing devices.”. These steps amount to no more than mere data gathering/analysis, which is a form of insignificant extra- solution activity (See M PEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); and GIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015)). Such limitations do not integrate the abstract idea into a practical application, or amount to significantly than the abstract idea, because the courts have found the concept of data gathering to be well-understood, routine, and conventional activity (See MPEP 2106.05(d): GIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); and buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, (Fed. Cir. 2014)). Similar arguments can be made for claims 26 and 27.
Regarding claims 28 and 29 these claims merely recite additional steps that amount to no more than insignificant extra-solution activity. Specifically, claim 28 states “wherein the blockchain of the cryptocurrency system maintains one or more continuously growing lists of data blocks, wherein each data block refers to previous data blocks on its list, yielding a chain of blocks that is hardened against tampering and revision such that information stored in the blockchain is immutable.”. This limitation merely recites describes that the blockchain has a growing list of data blocks that are hardened against tampering, which is a form of insignificant extra-solution activity (See MPEP 2106.0S(g)(3)(iii): GIP Technologies, 788 F.3d at 1363). This does not integrate the abstract idea into a practical application because it has been determined, by the courts, that the concept of storing data is well-understood, routine, and conventional activity (See MPEP 2106.0S(d)(II): Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334 (Fed. Cir. 2015)). Similar arguments can be made for claim 29.
The additional elements of the dependent claims merely refine and further limit the abstract idea of the independent claims and do not add any feature that is an "inventive concept" which cures the deficiencies of their respective parent claim under the 2019 PEG analysis. None of the dependent claims considered individually, including their respective limitations, include an "inventive concept" of some additional element or combination of elements sufficient to ensure that the claims in practice amount to something "significantly more" than patent-ineligible subject matter to which the claims are directed.
The elements of the instant process steps when taken in combination do not offer substantially more than the sum of the functions of the elements when each is taken alone. The claims as a whole, do not amount to significantly more than the abstract idea itself because the claims do not effect an improvement to another technology or technical field (e.g., the field of computer coding technology is not being improved); the claims do not amount to an improvement to the functioning of an electronic device itself which implements the abstract idea (e.g., the general purpose computer and/or the computer system which implements the process are not made more efficient or technologically improved); the claims do not perform a transformation or reduction of a particular article to a different state or thing (i.e., the claims do not use the abstract idea in the claimed process to bring about a physical change. See, e.g., Diamond v. Diehr, 450 U.S. 175 (1981), where a physical change, and thus patentability, was imparted by the claimed process; contrast, Parker v. Flook, 437 U.S. 584 (1978), where a physical change, and thus patentability, was not imparted by the claimed process); and the claims do not move beyond a general link of the use of the abstract idea to a particular technological environment (e.g., simply claiming the use of a computer and/or computer system to implement the abstract idea).
As a result, such limitations do not overcome the requirements as described above. Therefore, claims 7 – 14, 17 and 22 - 29 are directed to an abstract idea. Thus, claims 1, 7 – 14, 16, 17, 20 and 22 - 29 are not patent eligible.
Prior Art Not Relied Upon
The prior art made of record and not relied upon is considered pertinent to Applicant's disclosure. (See MPEP §707.05). The Examiner considers the following reference pertinent for disclosing various features relevant to the invention, but not all the features of the invention, for at least the following reasons:
MacArthur et al. (U.S. Pub. No. 2022/0156754) discloses a computing device that
receives carbon emissions data and that then generates token data based on the received emissions data. However, the invention in MacArthur does not describe the
following limitations found in claim 20 of the instant application:
"operating the GHG reduction system to reduce GHGs produced by a facility; detecting a reduction of GHGs produced by the facility using the sensor responsive to operating the GHG reduction system; determining carbon credits earned for the reduction of GHGs produced by the facility using a carbon reduction calculation methodology, wherein the carbon reduction calculation method calculates a baseline emissions of the facility using the following equation:
BE-=
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where BEy is the baseline emissions in a year y, EDi,y is the electricity delivered by a project charging systems serving applicable fleet i in project year y, EFj,f ,y is the emission factor for the fossil fuel fused by comparable fleet vehicles j in project year y, IRi is the technology improvement rate factor for the applicable fleet i, AFECi,y is the weighted average electricity consumption per 100 miles rating for EV s in applicable fleet i in projection year y, and MPGi,y is the weighted average miles per gallon rating for the fossil fuel vehicles comparable to each EV in the applicable fleet i in the project year y; and awarding an amount of cryptocurrency corresponding to the reduction of
GHGs produced by the facility."
The current invention includes all of this and calculates using a specific equation (see above) the amount of carbon credits earned for the reductions of GHGs produced by a facility. Although both MacArthur and the current invention do take in emissions data, only the current invention actually determines this data using a specific equation and then based on this reduction of GHGs, an amount of cryptocurrency is rewarded to the
facility.
Conclusion
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/John H. Holly/Primary Examiner, Art Unit 3696