DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Status of Claims
This action is in response to the reply filed February 23, 2026.
Claims 1-20 have been canceled.
Claims 21, 24, and 26-30 have been amended.
Claims 21-29 are currently pending and have been examined.
Response to Arguments
The previous claim objection for misnumbering has been withdrawn in response to the submitted amendments.
The previous rejections under 35 USC 112(b) to claims 21, 26, and 30 for improper antecedent basis have been withdrawn in response to the submitted amendments.
Applicant’s arguments filed February 23, 2026 have been fully considered but they are not persuasive.
Applicant submitted remarks in section B regarding the previous claim interpretation under 35 USC 112(f) arguing that Examiner has failed to identify a generic placeholder and a function.
Examiner respectfully disagrees. As explained in MPEP 2181(I), examiners will apply 35 U.S.C. 112(f) to a claim limitation if it meets the following 3-prong analysis: (A) the claim limitation uses the term "means" or "step" or a term used as a substitute for "means" that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term "means" or "step" or the generic placeholder is modified by functional language, typically, but not always linked by the transition word "for" (e.g., "means for") or another linking word or phrase, such as "configured to" or "so that"; and (C) the term "means" or "step" or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
As discussed in the rejection below, the following limitations have been interpreted to invoke 112(f): “a customer search web interface module configured to display” in claim 21; “a customer reservation web interface module configured to display” in claim 21; “a command query responsibility segregation service module configured to process access” in claim 21; “a customer purchase web interface module configured to receive” in claim 24. Applying the three-prong analysis, all the identified terms recite a generic placeholder, a transition word, and the modifier of the generic placeholder does not provide sufficient structure, material, or act for performing the claimed function. In step A, all the terms recite a “module” which is a generic placeholder. In step B, all the terms recite the module is “configured to” which is a linking phrase. In step C, the modifiers of the generic placeholder (i.e. the terms before the generic placeholder “module”) are not sufficient structure, material, or acts for performing the claimed function (i.e. the functions following the linking phrase “configured to”).
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. Applicant has done neither. Therefore, the interpretation under 35 USC 112(f) has been maintained.
Applicant submitted remarks in Section C regarding the previous rejection under 35 USC 112(a) and 35 USC 112(b) related to the interpretation under 35 USC 112(f) arguing that the modifiers of the generic placeholder provide sufficient structure.
Examiner respectfully disagrees. The written description fails to disclose the corresponding structure, material, or acts for performing the entire claimed function and to clearly link the structure, material, or acts to the function. The Specification in [038] refers to modules may be implemented entirely in software. Therefore, the specification must explicitly disclose the algorithm for performing the claimed function, and simply reciting the claimed function in the specification will not be a sufficient disclosure for an algorithm which, by definition, must contain a sequence of steps. Blackboard, 574 F.3d at 1384, 91 USPQ2d at 1492 (stating that language that simply describes the function to be performed describes an outcome, not a means for achieving that outcome). The specification is silent to “customer search web interface module,” however Specification [023] describes the customer search simply by the function to be performed, which describes an outcome, not a means for achieving that outcome. The specification is silent to “customer reservation web interface module.” The specification is silent to “command query responsibility segregation service module,” however Specification [039] describes the command query responsibility segregation service simply by the function to be performed, which describes an outcome, not a means for achieving that outcome. The specification is silent to “customer purchase web interface module,” however Specification [034] describes the customer purchases simply by the function to be performed, which describes an outcome, not a means for achieving that outcome. Therefore, the claim is indefinite and is rejected under 35 U.S.C. 112(b) or pre-AIA 35 U.S.C. 112, second paragraph.
Applicant submitted remarks in Section D regarding the previous rejection under 35 USC 101 arguing the claims contain words not included in the text of the rejection which makes the rejection deficient.
Examiner respectfully disagrees. All the claimed functions and additional elements, taken alone and in combination, have been addressed in the rejection below. Merely reciting claims that are a narrow application of the identified idea is not sufficient to recite patent eligible subject matter. See Electronic Communication v. Shopperschoice.com, LLC, 958 F.3d 1178, 1183 (Fed. Cir. 2020) (“patent eligibility turns on the content of the claims, not merely on the number of words recited in the claims”); BSG Tech LLC v. BuySeasons, Inc., 899 F.3d 1281, 1287 (Fed. Cir. 2018) (“a claim is not patent eligible merely because it applies an abstract idea in a narrow way”).
Examiner notes the use of color in drawings is dictated in 37 CFR 1.84 and according to 37 CFR 1.84(a)(2) color requires a petition. Examiner further notes that remarks are only accessible in black and white but applicant has mentioned green and yellow highlighting. The remarks are not drawings and applicant has not petitioned to use color therefore these colorful remarks could not be considered.
Applicant submitted remarks in Section D.1 regarding the previous rejection under 35 USC 101 arguing the claims cannot be directed to certain methods of human activity based on a case comparison approach of the examples provided in the sub-groupings.
Examiner respectfully disagrees. The Office has set forth an approach to identifying abstract ideas that distills the relevant case law into enumerated groupings of abstract ideas. The enumerated groupings are firmly rooted in Supreme Court precedent as well as Federal Circuit decisions interpreting that precedent, as is explained in MPEP § 2106.04(a)(2). This approach represents a shift from the former case-comparison approach that required examiners to rely on individual judicial cases when determining whether a claim recites an abstract idea. See MPEP 2106.04(a). By grouping the abstract ideas, the examiners’ focus has been shifted from relying on individual cases to generally applying the wide body of case law spanning all technologies and claim types.
The claims recite a method of organizing human activity because the identified idea is a commercial or legal interaction (including business relations) by reciting searching for available parking, selecting parking, and reserving the selected parking. See MPEP 2106.04(a)(2)(II)(B). The claims recite a method of organizing human activity because the identified idea is managing personal behavior or relationships or interactions between people (including following rules or instructions) by reciting rules or instructions to find available parking and reserve that parking. See MPEP 2106.04(a)(2)(II)(C).
Applicant submitted remarks in Section D.2 regarding the previous rejection under 35 USC 101 arguing the claims recite additional elements that integrate any judicial exception into a practical application because the claims recite a CQRS database access pattern.
Examiner respectfully disagrees. The CQRS database access pattern is a known software architecture developed sometime around 2010 and the use of CQRS in the field of parking does not amount to an improvement to the CQRS itself. In re TLI Communications LLC Patent Litigation, 823 F.3d 607, 612 (Fed. Cir. 2016) (The specification does not describe a new telephone, a new server, or a new physical combination of the two. The specification fails to provide any technical details for the tangible components, but instead predominately describes the system and methods in purely functional terms.) The benefits Applicant has alleged from using CQRS as a tool are simply the benefits of CQRS and this is similar to the speed improvements from performing calculations on a computer. Improving the performance of the abstract idea by using a computer as a tool does not materially alter the patent eligibility of the claimed subject matter under the Alice/Mayo framework. See Bancorp Servs., LLC v. Sun Life Assurance Co. of Can., 687 F.3d 1266, 1278 (Fed. Cir. 2012) (“[T]he fact that the required calculations could be performed more efficiently via a computer does not materially alter the patent eligibility of the claimed subject matter.”); CLS Bank, Int’l v. Alice Corp., 717 F.3d 1269, 1286 (Fed. Cir. 2013) (en banc) aff’d, 134 S. Ct. 2347 (2014) (“[S]imply appending generic computer functionality to lend speed or efficiency to the performance of an otherwise abstract concept does not meaningfully limit claim scope for purposes of patent eligibility.” (citations omitted)).
Ex Parte Kannan is not binding precedent on Examination and it does not address patents in the same family as the pending application, therefore the arguments regarding Ex Parte Kannan have not been considered.
Applicant submitted remarks in Section E regarding the previous rejection under 35 USC 103 arguing that the amended claim limitation beginning “a customer search web interface module configured to display …”is not taught by any single paragraph of Stefik.
Examiner respectfully disagrees. While the claimed options are discussed in various parts of Stefik that does not discredit their disclosure. The elements must be arranged as required by the claim, but this is not an ipsissimis verbis test, i.e., identity of terminology is not required. In re Bond, 910 F.2d 831, 15 USPQ2d 1566 (Fed. Cir. 1990). Stefik disclose the claimed user interface for identifying parking requirements (Stefik [0072], [0077]); the claimed start date, start time, end time, and end date (Stefik [0117], [0133], [0146], [0148]); and the recurrence measure (Stefik [0146], [0148]).
Claim Interpretation
The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are:
“a customer search web interface module configured to display” in claim 21;
“a customer reservation web interface module configured to display” in claim 21;
“a command query responsibility segregation service module configured to process access” in claim 21;
“a customer purchase web interface module configured to receive” in claim 24.
Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 21-30 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention.
The Claim limitations discussed in the “Claim Interpretation” section above invoke 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. However, the written description fails to disclose the corresponding structure, material, or acts for performing the entire claimed function and to clearly link the structure, material, or acts to the function. The Specification in [038] refers to modules may be implemented entirely in software. Therefore, the specification must explicitly disclose the algorithm for performing the claimed function, and simply reciting the claimed function in the specification will not be a sufficient disclosure for an algorithm which, by definition, must contain a sequence of steps. Blackboard, 574 F.3d at 1384, 91 USPQ2d at 1492 (stating that language that simply describes the function to be performed describes an outcome, not a means for achieving that outcome). The specification is silent to “customer search web interface module,” however Specification [023] describes the customer search simply by the function to be performed, which describes an outcome, not a means for achieving that outcome. The specification is silent to “customer reservation web interface module.” The specification is silent to “command query responsibility segregation service module,” however Specification [039] describes the command query responsibility segregation service simply by the function to be performed, which describes an outcome, not a means for achieving that outcome. The specification is silent to “customer purchase web interface module,” however Specification [034] describes the customer purchases simply by the function to be performed, which describes an outcome, not a means for achieving that outcome. Therefore, the claim is indefinite and is rejected under 35 U.S.C. 112(b) or pre-AIA 35 U.S.C. 112, second paragraph.
Applicant may:
(a) Amend the claim so that the claim limitation will no longer be interpreted as a limitation under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph;
(b) Amend the written description of the specification such that it expressly recites what structure, material, or acts perform the entire claimed function, without introducing any new matter (35 U.S.C. 132(a)); or
(c) Amend the written description of the specification such that it clearly links the structure, material, or acts disclosed therein to the function recited in the claim, without introducing any new matter (35 U.S.C. 132(a)).
If applicant is of the opinion that the written description of the specification already implicitly or inherently discloses the corresponding structure, material, or acts and clearly links them to the function so that one of ordinary skill in the art would recognize what structure, material, or acts perform the claimed function, applicant should clarify the record by either:
(a) Amending the written description of the specification such that it expressly recites the corresponding structure, material, or acts for performing the claimed function and clearly links or associates the structure, material, or acts to the claimed function, without introducing any new matter (35 U.S.C. 132(a)); or
(b) Stating on the record what the corresponding structure, material, or acts, which are implicitly or inherently set forth in the written description of the specification, perform the claimed function. For more information, see 37 CFR 1.75(d) and MPEP §§ 608.01(o) and 2181.
Claims 22-30 depend upon claim 21 and therefore inherit the above rejection of claim 21.
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 21-30 rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement.
The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The claim limitations discussed above in the “Claim Interpretation” section have been found to fail to disclose sufficient corresponding structure (e.g. the algorithm) in the specification that performs the entire claimed function and have been found to be indefinite under 35 USC 112(b). The specification does not demonstrate that applicant has made an invention that achieves the claimed function because the invention is not described with sufficient detail such that one of ordinary skill in the art can reasonably conclude that the inventor had possession of the claimed invention. Therefore, these claim limitations also fail to comply with the written description requirement.
Claims 22-30 depend upon claim 21 and therefore inherit the above rejection of claim 21.
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 21-30 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Alice/Mayo Framework Step 1:
Claims 21-30 recite a series of steps and therefore recite a process.
Alice/Mayo Framework Step 2A – Prong 1:
Claims 21, as a whole, are directed to the abstract idea of searching for available parking and making parking reservations, which is a method of organizing human activity. The claims recite a method of organizing human activity because the identified idea is a commercial or legal interaction (including business relations) by reciting searching for available parking, selecting parking, and reserving the selected parking. See MPEP 2106.04(a)(2)(II)(B). The claims recite a method of organizing human activity because the identified idea is managing personal behavior or relationships or interactions between people (including following rules or instructions) by reciting rules or instructions to find available parking and reserve that parking. See MPEP 2106.04(a)(2)(II)(C). The method of organizing human activity of “searching for available parking and making parking reservations,” is recited by claiming the following limitations: managing parking spaces, displaying search options for parking spaces, displaying a list of parking spaces, receiving a reservation request, and allocating the parking space. The mere nominal recitation of a processor, a memory, a read database, a write database, command query responsibility segregation, submitting a query, submitting a command service request, a parking management server, a computer network, and a user interface does not take the claim of the method of organizing human activity grouping. Thus, the claim recites an abstract idea.
With regards to Claims 24 and 29, the claims further recite the above-identified judicial exception (the abstract idea) by reciting the following limitations: receiving payment information, displaying a list of parking spaces with price schedule information.
Alice/Mayo Framework Step 2A – Prong 2:
Claims 21 recite the additional elements: a processor, a memory, a read database, a write database, command query responsibility segregation, submitting a query, submitting a command service request, a parking management server, a computer network, and a user interface. The submitting a query and submitting a command request in these steps are recited at a high level of generality, i.e., as generic computer protocols performing generic information retrieving and updating functions. The processor, memory, read database, write database, command query responsibility segregation, submitting a query, submitting a command service request, parking management server, computer network, and user interface limitations are no more than mere instructions to apply the exception using a generic computer component. Taken individually these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
Considering the limitations containing the judicial exception as well as the additional elements in the claim besides the judicial exception does not amount to a practical application of the abstract idea. The claim as a whole does not improve the functioning of a computer or improve other technology or improve a technical field. The claim as a whole is not implemented with a particular machine. The claim as a whole does not effect a transformation of a particular article to a different state. The claim as a whole is not applied in any meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception. The claim as a whole merely describes how to generally “apply” the concept of reserving parking in a computer environment. The claimed computer components are recited at a high level of generality and are merely invoked as tools to perform an existing parking reservation process. Simply implementing the abstract idea on a generic computer is not a practical application of the abstract idea. The claim is directed to the abstract idea.
Alice/Mayo Framework Step 2B:
Claims 21 do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claims recite a generic computer performing generic computer function by reciting a processor, a memory, a read database, a write database, parking management server, a computer network, and a user interface. See Intellectual Ventures I LLC v. Capital One Fin. Corp., 850 F.3d 1332, 1341 (describing a “processor” as a generic computer component); Mortg. Grader, Inc. v. First Choice Loan Servs. Inc., 811 F.3d 1314, 1324–25 (Fed. Cir. 2016) (claims reciting an “interface,” “network,” and a “database” are nevertheless directed to an abstract idea); Content Extraction & Transmission LLC v. Wells Fargo Bank, Nat’l Ass’n, 776 F.3d 1343, 1347–48 (discussing the same with respect to “data” and “memory”). The claims recite generic computer functions by reciting submitting a query, submitting a command service request, receiving and transmitting information (See MPEP 2106.05(d)(II) receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec; TLI Communications LLC; OIP Techs.; buySAFE, Inc.), processing information (See MPEP 2106.05(d)(II) performing repetitive calculations, Flook; Bancorp Services), presenting information (See MPEP 2106.05(d)(II), MPEP 2106.05(g) presenting offers gathering statistics, OIP Technologies), and storing and retrieving information (See MPEP 2106.05(d)(II) storing and retrieving information in memory, Versata Dev. Group, Inc. v. SAP Am., Inc.; OIP Technologies). The specification demonstrates the well-understood, routine, conventional nature of the following additional elements because they are described in a manner that indicates the elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. 112(a): a processor (Specification [0048]), a memory (Specification [0048]), a read database (Specification [0017], [0039]), a write database (Specification [0017], [0039]), command query responsibility segregation (Specification [0039]), parking management server (Specification [044]), a computer network (Specification [046]), and a user interface (Specification [023]). See MPEP 2106.05(d)(I)(2). The claims add the words “apply it” or words equivalent to “apply the abstract idea” such as instructions to implement the abstract idea on a computer by reciting a processor, a memory, a read database, a write database, command query responsibility segregation (CQRS) access pattern, submitting a query, submitting a command service request, a parking management server, a computer network, and a user interface. See MPEP 2106.05(f). The claims recite instructions to implement the abstract idea on a computer by providing a user interface, and responding to a user interface using the computer's ordinary ability to display and process data inputs. (See MPEP 2106.05(f) accessing information through a mobile interface Intellectual Ventures v. Erie Indem. Co.; Generating a second menu from a first menu and sending the second menu to another location as performed by generic computer components, Apple, Inc. v. Ameranth, Inc.) The claims limit the field of use by reciting the parking field. See MPEP 2106.05(h). Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. See MPEP 2106.05(a). Their collective functions merely provide conventional computer implementation. See MPEP 2106.05(b). Therefore, the claims do not include additional elements alone, and in combination, that are sufficient to amount to significantly more than the recited judicial exception.
With regards to Claims 25, the additional elements do not amount to significantly more than the judicial exception. Claims 25 recite a generic computer performing generic computer functions by reciting a command query responsibility segregation (CQRS) access pattern. Regarding claims 25, the specification demonstrates the well-understood, routine, conventional nature of the following additional elements because they are described in a manner that indicates the elements are sufficiently well-known that the specification does not need to describe the particulars of such additional elements to satisfy 35 U.S.C. 112(a): a command query responsibility segregation (CQRS) access pattern (Specification [0039]). See MPEP 2106.05(d)(I)(2). Claims 25 add the words “apply it” or words equivalent to “apply the abstract idea” such as instructions to implement the abstract idea on a computer by reciting a command query responsibility segregation (CQRS) access pattern. See MPEP 2106.05(f). Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. See MPEP 2106.05(a). Their collective functions merely provide conventional computer implementation. See MPEP 2106.05(b). Therefore, the claims do not include additional elements that are sufficient to amount to significantly more than the recited judicial exception.
Remaining Claims:
With regards to Claims 22-23, 26-28, and 30, these claims merely add a degree of particularity to the limitations discussed above rather than adding additional elements capable of transforming the nature of the claimed subject matter. Thus, taken alone, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology. Their collective functions merely provide conventional computer implementation. Therefore, the claims as a whole do not amount to significantly more than the abstract idea itself.
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 (i.e., changing from AIA to pre-AIA ) 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 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.
Claim(s) 21-25 and 28-30 is/are rejected under 35 U.S.C. 103 as being unpatentable over Stefik et al. (U.S. P.G. Pub. 2012/0095812 A1), hereinafter Stefik, in view of Rombouts (W.O. 2019/008548 A1), hereinafter Rombouts.
Claim 21.
Stefik discloses a computer-implemented method for providing variable granularity allocation of parking resources, comprising:
managing a plurality of parking spaces controlled by a parking management server configured to interface over a computer network and comprising a memory and a computer processor operatively coupled to the memory and configured to execute computer executable program modules (Stefik [0048], [0065]-[0066] server; [0072] users interface with the parking services remotely over a network; [0074] storage coupled to server), comprising:
a customer search web interface module configured to display, on a user interface screen of the customer device, search options to identify customer-specified requirements for a recurring parking reservation with a parking space search request comprising a customer-selected start date, customer-selected start time, customer-selected end time, customer-selected end date, and a customer-selected recurrence measure identifying customer-specified days for the recurring parking reservation (Stefik [0072] users interface with the parking services remotely over a network; [0077] parking is consumed by parking requests from users; [0117] 8:00 am Alice enters her preferred time of 10:00am for the start of the new reservation and her desired duration of 30 minutes. she indicates where she wants to park; [0133] reservations for give a specification of time; [0146] residents may require recurring parking at night for a month near one’s home; [0148] recurring reservation service enables user to reserve a parking space for a repeating period for each day throughout a subscription period);
a customer reservation web interface module configured to display, on the user interface screen, a list of one or more parking spaces which meet the customer-specified requirements for the parking space search request, and to receive a reservation request from the customer for one of the one or more parking spaces which meet the customer-specified requirements for a parking space search request (Stefik [0072] users interface with the parking services remotely over a network; [0083] time available for parking; [0107] driver selects terms of the parking agreement; [0117] 8:00 am, the web page shows Alice the following information: 1) what parking spaces are available, 2) how long each space is available, 3) the cost of parking in each space; [0117] 8:00 am, Alice picks parking space A); and
Regarding the following limitation:
a command query responsibility segregation service module configured to process access via separate pathways to a read database and a write database by:
Stefik discloses maintaining parking accounts in storage coupled to the server (Stefik [0074] storage). However, Stefik does not disclose a command query responsibility segregation module configured to process access via separate pathways to a read database and a write database, but Rombouts does (Rombouts (p. 6 Line 33- p. 7 Line 8), (p. 11 Line 6-16) CQRS; (p. 10 Lines 28-37) read and write permissions; (p. 12 Lines 1-30) parking).
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 CQRS system of Rombouts for the database structure of Stefik. Both the database of Stefik and the CQRS system of Rombouts are known database management techniques in the art of parking systems. Thus, the simple substitution of one known element in the art of parking for another producing a predictable result renders the claim obvious. Specifically, one of ordinary skill in the art would have recognized that only routine engineering would be required to substitute the above features and yield predictable result of Stefik’s system with the improved functionality to prevent accidental data corruption across different systems.
Stefik, as modified by Rombouts with CQRS, teaches:
submitting a query service request to the read database to retrieve the list of one or more parking spaces which meet the customer-specified requirements for the parking space search request (Stefik [0083] time available for parking; [0117] 8:00 am, the parking server determines what parking spaces are available near the requested location);
communicating with the customer purchase web interface module to display the list of one or more parking spaces which meet the customer-specified requirements for the parking space search request (Stefik [0072] users interface with the parking services remotely over a network; [0083] time available for parking; [0117] 8:00 am, the web page shows Alice the following information: 1) what parking spaces are available, 2) how long each space is available, 3) the cost of parking in each space); and
submitting a command service request to the write database to update a parking space allocation to reflect the reservation request from the customer for one of the one or more parking spaces which meet the customer-specified requirements for a parking space search request (Stefik [0076] parking services maintain a set of reservations; [0077] parking availability is continually revised; [0117] 8:05 am, the server verifies that parking space A is still available; [0149] parking services book the recurring reservation).
Claim 22.
Stefik in view of Rombouts teaches all the elements of claim 21, as shown above. Additionally, Stefik discloses:
where the start time and end time are specified using a customer-selected start time and defined timer interval selected by the customer (Stefik [0072] users interface with the parking services remotely over a network; [0077] parking is consumed by parking requests from users; [0117] 8:00 am Alice enters her preferred time of 10:00am for the start of the new reservation and her desired duration of 30 minutes. she indicates where she wants to park; [0133] reservations for give a specification of time; [0146] residents may require recurring parking at night for a month near one’s home; [0148] recurring reservation service enables user to reserve a parking space for a repeating period for each day throughout a subscription period).
Claim 23.
Stefik in view of Rombouts teaches all the elements of claim 21, as shown above. Additionally, Stefik discloses:
where the customer-selected recurrence measure is specified using a customer-selected configurable time interval specifying a customer-selected number of days, weeks, or months between a customer-selected start date and end date (Stefik [0072] users interface with the parking services remotely over a network; [0077] parking is consumed by parking requests from users; [0117] 8:00 am Alice enters her preferred time of 10:00am for the start of the new reservation and her desired duration of 30 minutes. she indicates where she wants to park; [0133] reservations for give a specification of time; [0146] residents may require recurring parking at night for a month near one’s home; [0148] recurring reservation service enables user to reserve a parking space for a repeating period for each day throughout a subscription period).
Claim 24.
Stefik in view of Rombouts teaches all the elements of claim 21, as shown above. Additionally, Stefik discloses:
a customer purchase web interface module configured to receive payment information for the one of the one or more parking spaces reserved by the customer which meet the customer-specified requirements for a parking space search request (Stefik [0074] parking accounts maintained in storage; [0075] parking accounts enable transaction based approaches to reserving, billing, and managing parking; [0079] monthly or periodic charges; [0117] creating a parking account includes providing credit card number for parking charges; [0183] merchant account).
Claim 25.
Stefik in view of Rombouts teaches all the elements of claim 21, as shown above. However, Stefik does not disclose the following limitation, but Rombouts does:
where the command query responsibility segregation service module comprises a command query responsibility segregation (CQRS) database access pattern (Rombouts (p. 6 Line 33- p. 7 Line 8), (p. 11 Line 6-16) CQRS; (p. 10 Lines 28-37) read and write permissions; (p. 12 Lines 1-30) parking).
One of ordinary skill in the art would have been motivated to include the teachings of Rombouts in the system of Stefik for the same reasons discussed in claim 21 above.
Claim 28.
Stefik in view of Rombouts teaches all the elements of claim 25, as shown above. However, Stefik does not disclose the following limitation, but Rombouts does:
where the CQRS database access pattern comprises an event bus for propagating changes to the write database to the read database using asynchronous messaging (Rombouts (p. 10 Lines 34-37) microservices can interact asynchronously via a message broker).
The known technique communicating using asynchronously using a message broker for CQRS of Rombouts, as shown above, is applicable to the system of Stefik as they both share characteristics and capabilities, namely, they are web based parking management systems. One of ordinary skill in the art would have recognized that applying the known technique of asynchronously using a message broker for CQRS of Rombouts to the web based communications of Stefik would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Rombouts to the teaching of Stefik would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such asynchronously using a message broker for CQRS into web based parking systems. Further, applying asynchronously using a message broker for CQRS to Stefik, would have been recognized by one of ordinary skill in the art as resulting in an improved system that would allow more efficient utilization of existing service platforms by allowing the API to communicate across different programming languages rather than replacing the service platform written in an undesirable language.
Claim 29.
Stefik in view of Rombouts teaches all the elements of claim 21, as shown above. Additionally, Stefik discloses:
where the customer reservation web interface module displays the list of one or more parking spaces which meet the customer-specified requirements for the parking space search request with price schedule information for the customer (Stefik [0072] users interface with the parking services remotely over a network; [0117] 8:00 am, the web page shows Alice the following information: 1) what parking spaces are available, 2) how long each space is available, 3) the cost of parking in each space; [0107] free parking period before rates go up with time; [0108] fixed period, fixed price; [0109] open-ended period, higher price; [0110] open ended period, escalating price; [0112] open-ended period, initially free parking; [0115] discount pricing).
Claim 30.
Stefik in view of Rombouts teaches all the elements of claim 29, as shown above. Additionally, Stefik discloses:
where the price schedule information includes different prices for different configurable time intervals (Stefik [0117] 8:00 am, the web page shows Alice the following information: 1) what parking spaces are available, 2) how long each space is available, 3) the cost of parking in each space; [0107] escalating rates that go up with time; [0108] fixed period, fixed price; [0109] open-ended period, higher price; [0110] open ended period, escalating price; [0112] open-ended period, initially free parking; [0115] discount pricing).
Claim(s) 26-27 is/are rejected under 35 U.S.C. 103 as being unpatentable over Stefik in view of Rombouts further in view Chandrakant, Kumar. "CQRS and Event Sourcing in Java." May 29, 2020. https://www.baeldung.com/cqrs-event-sourcing-java, Retrieved on October 16, 2025 from web.archive.org.
Claim 26.
The computer-implemented method of claim 25,
where the CQRS database access pattern comprises a client/presentation interface layer connected over a command class, command handler, and write model to the write database (Chandrakant (2.2 CQRS) showing a diagram having a client, command model, write store, read store, and query model connected by command, update state, read state, and query).
The known technique CQRS of Chandrakant, as shown above, is applicable to the system of Rombouts as they both share characteristics and capabilities, namely, they are using CQRS. One of ordinary skill in the art would have recognized that applying the known technique of CQRS of Chandrakant to the CQRS of Rombouts would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Chandrakant to the teaching of Rombouts would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such CQRS features into CQRS systems. Further, applying CQRS to Rombouts, would have been recognized by one of ordinary skill in the art as resulting in an improved system that would allow more efficient understanding of the read and write protocols required to implement CQRS.
Claim 27.
The computer-implemented method of claim 25,
where the CQRS database access pattern comprises a client/presentation interface layer connected over a query class, query handler, and read model to the read database (Chandrakant (2.2 CQRS) showing a diagram having a client, command model, write store, read store, and query model connected by command, update state, read state, and query).
One of ordinary skill in the art would have been motivated to include the teachings of Chandrakant in the system of Stefik in view of Rombouts for the same reasons discussed above in claim 26.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
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/SCOTT M TUNGATE/Primary Examiner, Art Unit 3628
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