Notice of Pre-AIA or AIA Status
The present application is being examined under the pre-AIA first to invent provisions.
DETAILED ACTION
Status of Claims
This action is in reply to the RCE filed on 30th of December 2025.
Claims 1-20 were previously cancelled.
Claims 21, 25, 28, 32, and 35 were amended.
Claims 23-24, 26-27, 30-31, 34, 37-40 were also cancelled.
Claims 41-52 were newly added.
Claims 21-22, 25, 28-29, 32, 35-36, and 41-52 are currently pending and have been examined.
Claim Objections
Claim 33 is objected to because of the following informalities: claim 33 and its status are missing. Appropriate correction is required.
Response to Arguments
Applicant's arguments filed 30th of December 2025 have been fully considered but they are not persuasive.
With regard to the limitations of claims 21-22, 25, 28-29, 32, 35-36, and 41-52, Applicant argues “…amended claims 21, 28, and 35 to further clarify specific technological implementation of the claimed parts management system…These amendments demonstrate that the claims recite a specific technological process for multi-database coordination with conditional threshold-based processing, not the abstract organizing of human activities.” Further argues “…These specific technological implementations are not more “organizing human activities” but rather concrete improvements to how computerized parts management systems function…The Claims recite a specific Technological Process” The Examiner respectfully disagrees. These claims do not recite any specific technical process; instead, they merely set forth a series of steps performed in a business environment. The claimed technology is used only as a tool to implement an abstract idea. The additional limitations cited by the applicant, such as accessing or storing data, constitute routine and conventional extra-solution activity. The claims do not improve any particular technology or technical field; rather, they simply apply generic computer functionality to carry out the abstract idea.
With regard to the limitations of claims 21-22, 25, 28-29, 32, 35-36, and 41-52, Applicant argues “…The Claims are not directed to an abstract idea... Applicant respectfully disagrees and submits that this characterization fails to account for the specific technological processes recited in the amended claims, including accessing a historical information database, determining based on accessed vehicle information whether a threshold is exceeded, conditionally storing information in an inventory database, communicating to one or more repair shop systems, and automatically reserving parts by indicating reservation in the parts management system. These specific technological implementations are not mere "organizing human activities" but rather concrete improvements to how computerized parts management systems function.” The applicant asserts that the claims provide a “concrete” improvement to the functioning of a computerized parts management system. The examiner respectfully disagrees. The claims do not recite any specific technology that is improved; rather, they merely apply generic computer technology to implement an abstract idea. Such application does not constitute an improvement to computer functionality or to another technology or technical field, as required to overcome the 101 rejection.
With regard to the limitations of claims 21-22, 25, 28-29, 32, 35-36, and 41-52, Applicant argues “…the amended claims recite a specific technological process that improves computerized parts management system functionality. The claims are analogous to those found patent-eligible in McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299 (Fed. Cir. 2016), where the Federal Circuit held that claims reciting specific computer-implemented processes for automated lip synchronization were not directed to an abstract idea….” The Examiner respectfully disagrees. The applicant cites numerous cases, including McRO; however, none of the cited authority is analogous to the present claims. The applicant’s reliance on selective excerpts from various decisions to justify patent eligibility is unpersuasive. Merely invoking portions of cases law, without demonstrating a meaningful correspondence between the claimed subject matter and the technological improvements recognized in these cases, is insufficient to overcome the rejection.
With regard to the limitations of claims 21-22, 25, 28-29, 32, 35-36, and 41-52, Applicant argues “…The Claims improve computer functionality…the claims recite optimized databased operations through conditional processing…represents a specific technological implementation that improves how the computer system manages and coordinates information across multiple data stores…improves distributed system functionality by enabling real-time inventory sharing and automated parts reservation across multiple computer systems….” The Examiner respectfully disagrees. The applicant characterizes the claims as providing improvements such as an optimized database, enhanced computer system management, and improved distributer system functionality. However, these assertions overstate what is actually recited in the claims. The alleged improvements are not reflected in any specific technological features or processes. To the extent any such benefits might be realized, they represent expected results of using computer as a tool to implement the abstract idea. Accordingly, the claims do not improve computer functionality or any other technology or technical field; rather, they merely use generic computer components to carry out the abstract idea.
With regard to the limitations of claims 21-22, 25, 28-29, 32, 35-36, and 41-52, Applicant argues “…The Claims recite a non-conventional ordered combination…claims provide a specific technological solution through automated-based analysis….” Further argues “…The claims provide a technological solution to a computer-system problem…The Claims are properly characterized as technological implementations…” The applicant asserts that the claims recite a non-conventional order or combination of steps and therefore provides a specific technological solution. The examiner respectfully disagrees. While the applicant may have devised a unique abstract idea or business logic as to how the concept is implemented, that alone does not render the claims patent eligible. The claims merely recite generic technologies used as tools to implement the abstract idea, without any improvements to the underlying technology or to computer functionality.
With regard to the limitations of claims 21-22, 25, 28-29, 32, 35-36, and 41-52, Applicant argues “…The claims include significantly more than any alleged abstract idea…The claims recite specific technological implementations…The claims recite a specific configurations and method…The claims are distinguished from mere data processing cases…The dependent claims demonstrate the inventive concepts. The amendments strengthen the inventive concept…applicant respectfully submits is incorrect, the claims include additional elements that amount to significantly more than any alleged abstract idea….” The Examiner respectfully disagrees. With respect to step 2B of the 101 analysis, the applicant reiterates arguments previously addressed above. For this step, again, merely using generic computer technology as a tool to implement the abstract idea does not amount to significantly more. Accordingly, the examiner maintains the 101 rejection.
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 21-22, 25, 28-29, 32, 35-36, and 41-52 are rejected under 35 U.S.C. 101 because the claimed invention is directed to abstract idea without significantly more. The claims recite abstract idea of organizing human activities. This judicial exception is not integrated into a practical application and the claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception.
Analysis
First of all, claims are directed to one or more of the following statutory categories: a process, a machine, a manufacture, and a composition of matter. For claim 21, the claim recites an abstract idea of
“…determine, based on information indicative of damage to a vehicle, that at least one part of the vehicle is available for reuse; communicate an instruction to remove the at least one part from the vehicle; accessing a historical information storing vehicle information for a plurality of vehicles associated with an entity; determine, based on the stored vehicle information, that an amount of other vehicle capable of using the at least one part exceeds a threshold amount of vehicle; after the determination that the amount of other vehicle capable of using the at least one part exceeds the threshold amount of vehicles; store information corresponding to the at least one part in an inventory database; and communicate an instruction to store the at least one part at a storage location; communicate to one or more repair shop systems an indication that the at least one part has been added to inventory; and after receiving a request for the at least one part from a requesting repair shop system, reserve the at least one part by indicating in the parts management system that the at least one part is reserved.” This is an abstract idea of a certain method of organizing human activity, since it recites a commercial or legal interactions, namely evaluating accident claim data to identify parts available for reuse and taking various actions with the parts based on historical data. Besides reciting the abstract idea, the remaining claim limitations recite generic computer components/processes (e.g., processors, memory, parts of management system). “We conclude that claim 1 is “directed to a result or effect that itself is the abstract idea and merely invoke[s] generic processes and machinery” rather than “a specific means or method that improves the relevant technology.” Smart Sys. Innovations, LLC v. Chi. Transit Authority, 873 F.3d 1364, 1371
This recited abstract idea is not integrated into a practical application. In particular, the claim only recites generic computer components/processes (e.g., processors, memory, parts of management system) to receive/transmit/store data (extra-solution activities) and perform the abstract idea mentioned above. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). The additional elements (e.g., processors, memory, parts of management system) are recited at a high-level of generality such that they amount to no more than mere instructions to apply the exception using generic computer components or merely uses a computer as a tool to perform an abstract idea. Accordingly, 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. Therefore, the claim is directed to an abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements - (e.g., processors, memory, parts of management system) amount to no more than mere instructions to apply the abstract idea using generic computer components or merely uses a computer as a tool to perform an abstract idea. In conclusion, merely “applying” the exception using generic computer components cannot provide an inventive concept. Therefore, the claim is not patent eligible under 35 USC 101.
Again, the insignificant extra-solution activities mentioned above were re-evaluated in step 2B. The limitations do not amount to significantly more than the abstract idea because the courts found sending/receiving/storing of data to be well understood, routine, and conventional activities. (See at least MPEP 2016.05(g): CyberSource v. Retail Decisions, Inc., 654 F.3d 1366, 1375 (Fed. Cir. 2011); buySafe, Inc. v. Google, Inc., 765 F.3d 1350, 1355 (Fed. Cir. 2014); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015); Ultramercial, Inc. v. Hulu, LLC, 772 F.3D 709, 715 (Fed. Cir. 2014); Electric Power Group, LLC v. Alstom S.A., 830 F.3d 1350, 1354-55 (Fed. Cir. 2016); Intellectual Ventures I LLC v. Erie Indem. Co., 850 F.3d 1315, 1328-29 (Fed. Cir. 2017); Ameranth, 842 F.3d at 1245, 120 USPQ2d at 1857; Trading Technologies v. IBG LLC, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019)). Thus again, claims were not patent eligible under 35 USC 101.
Similar arguments can be extended to independent claims 28 and 35.
Dependent claims 22, 25-27, 29, 32-34, 36, and 41-52 have been given the full two-part analysis, analyzing the additional limitations both individually and in combination. The dependent claims when analyzed individually and in combination, are also held be patent ineligible under 35 U.S.C. 101.
For claims 22, 29, and 36, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…wherein the computer-executable instructions cause the parts management system to transmit a confirmation message indicating that the at least one part has been reserved.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claims 25 and 32, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further added, “…determine, based on at least one of the plurality of user inputs, the threshold amount.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claims 26 and 33, the recited limitations of these claims merely further narrow the abstract idea discussed above. These claims further define the parameters as, “…a plurality of parameters including at least one of: a threshold number of vehicles associated with a user of the parts management system, a threshold number of types of vehicles on which the at least one part may be used, a threshold amount of time within which the at least one part will be used, and a threshold percentage that the at least one part will be reused.” The limitations of these claims fail to integrate the abstract idea into a practical application because these claims do not introduce additional elements other than the generic components discussed above. These dependent claims, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitations of these dependent claims fail to establish that the claims provide an inventive concept because claims that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 27, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein each of the plurality of user inputs corresponds to one of the plurality of parameters.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 41, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the historical information database stores data associated with types of vehicles and a number of vehicles associated with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 42, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…transmit a confirmation to the requesting repair shop system indicating that the at least one part has been reserved, wherein the confirmation includes a date on which the at least one part will be transferred to the requesting repair shop system..” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 43, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein determining that the at least one part of the vehicle is available for reuse is performed before the at least one part is removed from the vehicle.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 44, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the parts management system is associated with an insurance company entity, and wherein the plurality of vehicles stored in the historical information database are vehicles insured by the insurance company entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 45, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the historical information database stores data associated with types of vehicles and a number of vehicles associated with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 46, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…transmitting a confirmation to the requesting repair shop system indicating that the at least one part has been reserved, wherein the confirmation includes a date on which the at least one part will be transferred to the requesting repair shop system.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 47, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein determining that the at least one part of the vehicle is available for reuse is performed before the at least one part is removed from the vehicle.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 48, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the parts management system is associated with an insurance company entity, and wherein the plurality of vehicles stored in the historical information database are vehicles insured by the insurance company entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 49, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the historical information database stores data associated with types of vehicles and a number of vehicles associated with the entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 50, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…transmitting, by the parts management system, a confirmation to the requesting repair shop system indicating that the at least one part has been reserved, wherein the confirmation includes a date on which the at least one part will be transferred to the requesting repair shop system.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 51, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein determining that the at least one part of the vehicle is available for reuse is performed before the at least one part is removed from the vehicle.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
For claim 52, the recited limitations of this claim merely further narrow the abstract idea discussed above. This claim further adds, “…wherein the parts management system is associated with an insurance company entity, and wherein the plurality of vehicles stored in the historical information database are vehicles insured by the insurance company entity.” The limitations of this claim fail to integrate the abstract idea into a practical application because this claim does not introduce additional elements other than the generic components discussed above. This dependent claim, therefore, also amounts to merely using a computer, in its ordinary capacity, as a tool to perform the abstract idea. Finally, the additional recited limitation of this dependent claim fails to establish that the claim provides an inventive concept because claim that merely use a computer, in its ordinary capacity, as a tool to perform the abstract idea cannot provide an inventive concept.
Conclusion
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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to EDWARD CHANG whose telephone number is (571)270-3092. The examiner can normally be reached M - F, 9-5.
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/EDWARD CHANG/Primary Examiner, Art Unit 3696 01/10/2026