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 is in reply to communication filed on 05/29/2026.
Claims 1-20 have been amended.
Claims 1-20 are currently pending and have been examined.
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 05/29/2026 has been entered.
Response to Arguments
In response to Applicant Arguments /Remarks made in an amendment filled on 05/29/2026:
Regarding 35 USC § 101 rejection:
Applicant argument submitted under the title “Rejections under 35 U.S.C. § 101” in pages 9-19.
Applicant's arguments have been fully considered but they are not persuasive.
In response, the examiner respectfully disagrees as the applicant argues that the claims are directed to technical operations involving bi-dedicational power flow, energy metering, outlet-type detection, charging-parameter configuration, and communication through multiple interfaces, rather than a commercial interaction. The rejection does not characterize every limitation of the claims as abstract. Rather claims 1, 9 and 17 recite, among other limitations receiving user-account information, determining energy usage, generating a usage record associating the energy usage with the user account, and transmitting the usage record to a remote system for reconciliation. These limitations collectively recite a commercial/accounting activity involving tracking consumption and reconciling such consumption with a user account, which falls within certain methods of organizing human activity. The presence of additional technical limitations does not negate that the claims recite the identified judicial exception.
Regarding Step 2A, Prong Two, applicant argues that the claims provide a technological improvement through the combination of bi-directional power conversion and metering, automatic outlet-type detection and configuration, and sequential communication attempts across multiple interfaces. Applicant further asserts that these features improve reliability and versatility of EV charging across different deployment environments.
The claims use the power-conversion circuitry to transfer energy, metering circuitry to measure that energy, outlet detection to configure charging parameters, and communication interfaces to establish communication for transmitting the resulting usage information. While these are technical operations, the claims do not recite a particular improvement to the operation of the power-conversion circuity, metering circuitry, outlet technology, or underlying communication interfaces or protocols. Rather, these components provide the technical mechanisms and environment in which the energy-usage/account-reconciliation activity is performed. Accordingly, considering the claims as a whole, the additional elements do not integrate the identified judicial exception into a practical application.
Regarding Step 2B, applicant argues that the additional elements, individually and as an ordered combination, amount to significantly more and emphasizes that the Office has not established that the claimed combination is well-understood, routine, conventional.
The argument have been fully considered but they are not persuasive, because the present determination does not rely upon a finding that the additional elements are well-understood, routine, conventional. Even accepting the additional elements as claimed, their ordered combination transfers and measures energy, obtains associated information, generates an account-associated usage record, and communicates that record for reconciliation. The claimed combination does not provide an inventive concept distinct form implementation of the identified abstract activity or otherwise transform the nature of the claims into patent-eligible subject matter.
Applicant arguments concerning Enfish and CardioNet are likewise unpersuasive because, unlike the technological improvements at issue in those cases, the present claims do not recite a specific improvement to the operation of the underlying computing or other technology; rather, the recited technology is used to carry out the claimed energy-usage and account-reconciliation process.
Accordingly, applicant’s arguments do not overcome the rejection, and the rejection of claims 1-20 under 35 USC § 101 rejection is maintained.
Regarding Claim Rejections - 35 USC § 103:
Applicant argument submitted under the title “Rejections under 35 U.S.C. § 103” in pages 19-22.
Applicant’s arguments, have been fully considered and are persuasive. The 35 USC § 103 rejection of claims 1-20 has been withdrawn.
Applicant’s arguments with respect to claim rejections - 35 USC § 103 have been fully considered and are persuasive. The reason to withdraw the prior art rejection of claims 1-20 in the instant application is because the prior art of record fails to teach the overall combination as claimed. Therefore, it would not have been obvious to one of ordinary skill in the art to modify the prior art to meet the combination above without unequivocal hindsight and one of ordinary skill would have no reason to do so. Upon further searching the examiner could not identify any prior art to teach these limitations. The prior art on record, alone or in combination, neither anticipates, reasonably teaches, not renders obvious the Applicant’s claimed invention. Therefore, the rejection has been withdrawn.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more.
Step 1:
Claims 1-8 recite a method, which is directed to a process.
Claims 9-16 recite a method, which is directed to a process.
Claims 17-20 recite an adapter, which is directed to a machine.
Therefore, each claim falls within one of the four statutory categories.
Step 2A, Prong 1 (Is a judicial exception recited?):
The independent claims 1, 9 and 17 recite, in method and apparatus form, receiving data indicative of a user account associated with a smart adapter; determining an amount of energy transferred during charging or discharging of an EV battery; generating a usage record based on the user-account data and amount of energy transferred; and transmitting the usage record to a remote system configured to reconcile the usage record with the user account.
1) These claims 1, 9 and 17 recite a certain method of organizing human activity. These limitations recite certain methods of organizing human activity, particularly commercial interactions involving tracking consumption of electrical energy, associating the consumption with a customer account, generating a corresponding usage record, and reconciling the usage with the account. Accordingly, claims 1, 9 and 17 recite a judicial exception.
2) Additionally, the independent claims 1, 9 and 17 recite a mental process. the claims additional recites obtaining information and performing determinations concerning the information, including receiving account data, determining the amount of energy transferred, and generating a corresponding usage record. To the extent these limitations encompass observing information, evaluating the information, and recording the resulting information, they additionally fall withing the mental-process grouping of abstract ideas.
Therefore, claims 1, 9 and 17 recite an abstract idea.
Step 2A, Prong 2 (Is the exception integrated into a practical application?):
This judicial exception is not integrated into a practical application because the claims satisfy the following criteria, which indicate that the claims do not integrate the abstract idea into practical application:
The claimed additional limitations are:
The independent claims 1, 9 and 17 recite a smart adapter, power-conversion circuitry for enabling bi-directional power flow between the EV battery and an outlet, metering circuitry for measuring transferred energy, detecting whether the outlet is a 120 VAC or 240 VAC outlet, configuring the metering circuitry and charging parameters based on the outlet type, and communicating with the remote system through a plurality of communicating interfaces. Claim 9 further recites establishing communication trough another communication interface when communication cannot be established through a first interface.
These additional elements do not integrate the exception into a practical application. The power-conversion circuity provides the energy transfer being accounted for, the metering circuitry measures the energy used to generated the usage record, and the communication interfaces provide connectivity for communicating the record to the remote system. Likewise, detecting the outlet type and configuring the charging/metering arrangement facilitate the charging or discharging transaction whose energy usage is subsequently measured and reconciled. The claims do not recite a particular improvement to power-conversion or metering circuitry, outlet technology, or communication protocols. Rather, the technological components provide the environment and mechanisms for implementing the recited energy-usage/account-reconciliation activity.
The use of an alternative communication interface in claim 9 similarly provides another communication path for establishing connectivity with the remote system, without reciting a technological improvement to the communication interfaces or their underlying operation.
Accordingly, the claims apply the identified abstract commercial activity using EV charging, metering , and communication technology without integrating the judicial exception into a practical application.
Accordingly, claims 1, 9 and 17 are directed to abstract idea as the judicial exception is not integrated into a practical application.
Step 2B (Does the claim recite additional elements that amount to significantly more that the judicial exception?):
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. Considering the additional elements individually and as an ordered combination, the claims recite transferring electrical energy, measuring the transferred energy, associating the measured amount with a user account in a usage record, and transmitting the record for reconciliation. The additional elements therefore provide the physical and communication mechanisms through which the identified account-reconciliation activity is carried out, but do not add and inventive concept distinct from that activity.
In particular, the claimed combination does not recite a technological improvement to the power-conversion circuitry, metering circuitry, communication interfaces, computing device, or another technical field that transforms the nature of the claims into a patent-eligible subject matter. Rather, the additional elements are used as tools for implementing the identified abstract commercial/accounting process.
When considered individually and as ordered combination, the additional elements amount to no more than applying the judicial exceptions using generic computer technology and therefore do not provide significantly more than the abstract idea themselves.
Accordingly, claims 1, 9 and 17 do not recite significantly more than the abstract idea and is therefore not directed to patent-eligible subject matter under 35 U.S.C. § 101.
In addition, the dependent claims recite:
Claims 2, 10 and 18 further specify that the remote system is associated with a billing network. This limitation further limits the claims to the commercial/accounting environment in which the identified abstract activity is performed and does not provide a technological improvement.
Claims 3, 7, 11, and 19 further specify particular communication interfaces, including power-line carrier, Bluetooth, and/or NFC interfaces. These limitations merely specify communication mechanisms used to carry out the claimed process and do not recite an improvement to the operation of those communication technologies.
Claims 4-6, 12-14 and 20 further specify information contained in the usage record, including the amount of energy transferred and associated user account, and other information concerning the EV or charging/discharging transaction, these limitations further define the information collected, generated, and used in performing the identified energy-usage/account-reconciliation activity and therefore do not integrate the exception into a practical application or provide significantly more.
Claim 15 further recites storing the usage record. The storage of information generated during the claimed process is ancillary to the underlying account-reconciliation activity and dose not recite a technological improvement in data storage or computer operation.
Claims 8 and 16 further recite debiting or charging an account according to the usage record. Such limitations constitute additional commercial or financial activity and therefore further limit the identified abstract idea itself rather than integrate the exception into a practical application.
Therefore, the limitations on the invention of claims 1-20, when viewed individually and in ordered combination are directed to in-eligible subject matter.
Distinguished Over Prior Art
The claims, in present form, render the claimed invention distinguished over the prior art. The prior art found by the examiner, alone or in combination, neither anticipates, reasonably teaches, nor renders obvious the applicant's claimed invention. It would not have been obvious to one of ordinary skill in the art to modify the prior art to meet the combination above without unequivocal hindsight and one of ordinary skill would have no reason to do so. The examiner has been unable to find the claimed limitations in any prior art.
The closest prior art found by the examiner are:
Goei (US 20210197682 A1) which teaches an adapter that converting a dumb charger into a smart charger includes a first input interface for interconnecting the adapter with a first charging connector of the dumb charger, EV/outlet connection, energy measurement, user/account information, usage records, billing/reconciliation, and multiple communication mechanisms.
Kudo (US 20180186246 A1) which teaches a system that performs power interchange between a power system including a commercial power network and an electric vehicle and when the electric vehicle is not used as a movement means, an electricity storage unit installed at the electric vehicle is used as a power storage facility.
Krauer (US 20120280662 A1) which teaches detecting whether the charging input is 120 VAC or 240 VAC and configuring charging operation differently based on the detected input voltage.
Johnson et al. (US 20130147272 A1) which teaches an energy- management system using configurable adapters having power-conversion and metering circuity. The system manages and measures di-directional electrical energy among energy sources and loads. The collected energy information may be used for billing and reconciliation.
Shuey (US 20100014332 A1) which teaches a power meter for a conventional 120/240-V split-phase system, with a processor coupled to a metering circuit, current sensor, and communications module. The metering circuit monitors voltage, and the circuitry accommodates input voltages including both 120 VAC and 240 VAC.
Yet, Goei in view of Kudo further in view of Krauer furthermore Johnson in view of Shuey do not teach the claimed invention as the independent claim 1, 9 and 17 recitation. Accordingly, the applicant needs to address the outstanding rejections above in order to issue an allowability notice. The reason to withdraw the 35 USC 103 rejection of claims 1-20 in the instant application is because the prior art of record fails to teach the overall combination as claimed. Therefore, it would not have been obvious to one of ordinary skill in the art to modify the prior art to meet the combination above without unequivocal hindsight and one of ordinary skill would have no reason to do so. Upon further searching the examiner could not identify any prior art to teach these limitations. The prior art on record, alone or in combination, neither anticipates, reasonably teaches, not renders obvious the Applicant’s claimed invention. Accordingly, the examiner recommends addressing the outstanding rejections above.
Conclusion
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/AVIA SALMAN/Primary Patent Examiner, Art Unit 3627
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