Prosecution Insights
Last updated: April 19, 2026
Application No. 18/527,508

SERVER DEVICE

Final Rejection §101
Filed
Dec 04, 2023
Examiner
GODBOLD, DAVID GARRISON
Art Unit
3628
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Toyota Jidosha Kabushiki Kaisha
OA Round
2 (Final)
22%
Grant Probability
At Risk
3-4
OA Rounds
2y 1m
To Grant
55%
With Interview

Examiner Intelligence

Grants only 22% of cases
22%
Career Allow Rate
18 granted / 82 resolved
-30.0% vs TC avg
Strong +33% interview lift
Without
With
+33.3%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 1m
Avg Prosecution
34 currently pending
Career history
116
Total Applications
across all art units

Statute-Specific Performance

§101
46.2%
+6.2% vs TC avg
§103
29.0%
-11.0% vs TC avg
§102
6.1%
-33.9% vs TC avg
§112
17.7%
-22.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 82 resolved cases

Office Action

§101
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 Claims 1-4 were previously pending and subject to a non-final rejection dated August 1, 2025. In Response, submitted October 16, 2025, claims 1-4 were cancelled, and claim 5 was cancelled. Therefore, claim 5 is currently pending and subject to the following final rejection. Response to Arguments Applicant’s remarks on Page 5 of the Response regarding the previous specification objection, have been fully considered. This objection has been withdrawn. Applicant’s remarks on Page 7 of the Response, regarding the previous rejection of the claims under 35 U.S.C. 101, have been fully considered and are not found persuasive. On Page 7 of the Response, Applicant argues “New claim 5 includes the features that the Office suggests may integrate the abstract idea into a practical application (i.e., "the control unit of the power supply vehicle (See item 123 of Fig. 1) receives the instructions and controls the vehicle to move along a travel route that passes through the facility") (the Office Action at page 6). Claim 5 also recites the information and determinations, the connections between the information and determinations, and information flow that the Examiner suggested adding to overcome the rejection during the interview. The features have support in the instant specification at, e.g., paragraphs [0020], [0021], [0024], [0025], and [0038]-[0046]. In view of the foregoing, Applicant respectfully asserts that the original disclosure has support for new claim 5, and claim 5 is believed to be patent eligible.” Examiner notes, as discussed during the interview on September 17, 2025, additional limitations, such as “recit[ing] the information and determinations, the connections between the information and determinations, and information flow”, were needed in order to connect any potential additional elements regarding the movement of the vehicle to the abstract idea recited throughout the claim. While the additional limitations provided within the amended claims to generally connect the recited movement to the abstract idea recited within the body of the remainder of claim, it is further noted, as will be discussed further in the detailed rejection below, that these limitations which “recite the information and determinations, the connections between the information and determinations, and information flow”, insofar as they are claimed within the amended claims, are recitations of the abstract idea, and are themselves unable to bring the claims to eligibility. Examiner also notes, though the specification is not read into the claims, the claims must be interpreted in light of the specification. With this view, it is notable that the limitation “a second control unit configured to start moving the power supply vehicle along the second travel route in response to the instruction” may simply refer to providing the instructions to a human driver who then follows the route provided. Here the “a second control unit” and “the power supply vehicle” serve only as tools for performing the abstract idea of “start[ing] moving along the second travel route in response to the instruction”. This interpretation is further supported by para. 46 which provides as an example of “The control unit 103 send[ing] to the selected power supply vehicle 12 the travel route determined in S212 and an instruction to move to the power supply location” “[t]he power supply vehicle 12 … outputting the contents of the instruction to the occupant and starts moving according to the operation of the occupant, and moves to the power supply position.” Therefore, the claims remain rejected under 101. Applicant’s remarks on Pages 18-21 of the Response, regarding the previous rejection of the claims under 35 U.S.C. 103, have been fully considered and are found persuasive in light of the amended claims. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claim 5 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Step 1 Claim 5 are directed to a device (i.e., a machine). Therefore, claim 5 all fall within the one of the four statutory categories of invention. Step 2A, Prong One Independent claim 5 substantially recites sending an information request requesting information regarding an amount of power required for the vehicle to have a reference battery capacity, a location of the vehicle, and a desired time to receive power supply, sending a request for location information and remaining battery capacity information of the plurality of power supply vehicles, in response to receiving the information, selecting a power supply vehicle having maximum remaining battery capacity from the plurality of power supply vehicles present within a predetermined distance from the location of the vehicle, deriving a first travel route that the selected power supply vehicle reaches to the location of the vehicle from a current position in a shortest distance or time, deriving, based on the first travel route, candidate power purchase locations including a facility having a lowest power purchase price, selecting the facility for a power purchase location for the power supply vehicle, sending, to the facility, a scheduled time at which the power supply vehicle arrives and purchases power, determining a second travel route so as to pass through the facility, and sending an instruction to move along the second travel route, acquiring the location of the power supply vehicle, detecting the remaining battery capacity information of the battery, sending the location information and the remaining battery capacity information in response to the request sent, and receiving the instruction, and starting moving along the second travel route in response to the instruction. The limitations stated above are processes/functions that under broadest reasonable interpretation covers “certain methods of organizing human activity” (commercial interactions) of managing charging of power supply batteries (See specification, Para. 4). Therefore, the claim recites an abstract idea. Step 2A, Prong Two The judicial exception is not integrated into a practical application. Claim 5 as a whole amounts to: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent), and (ii) generally links the use of a judicial exception to a particular technological environment or field of use. The claim recites the additional elements of: (i) a first communication unit, (ii) a first control unit, (iii) a vehicle having a dead battery, (iv) a plurality of power supply vehicles/a power supply vehicle, (v) a battery configured to supply power to another vehicle, (vi) a positioning unit including a global navigation system (GPS), (vii) a detection unit, (viii) a sensor, (ix) a second communication unit, and (x) a second control unit. The additional elements of (i) a first communication unit, (ii) a first control unit, (vi) a positioning unit including a global navigation system (GPS), (vii) a detection unit, (viii) a sensor, (ix) a second communication unit, and (x) a second control unit are recited at a high level of generality (see [0013] of the Applicants’ Specification discussing the first communication unit, [0015] discussing the first control unit, [0021] discussing the positioning unit including a global navigation system (GPS), [0024] discussing the detection unit and the sensor, [0017] discussing the second communication unit, [0020] discussing the second control unit) such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)). The additional element of (iii) a vehicle having a dead battery, (iv) a plurality of power supply vehicles/a power supply vehicle, and (v) a battery configured to supply power to another vehicle are recited at a high level of generality (See [0010] of the Applicants’ Specification discussing the vehicle having a dead battery and the plurality of power supply vehicles/a power supply vehicle, the battery configured to supply power to another vehicle) such that when viewed as whole/ordered combination, do no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e., connected vehicles and bidirectional batteries) (See MPEP 2106.05(h)). Accordingly, these additional elements, when viewed as a whole/ordered combination [See Figure 1 showing all the additional elements (i) a first communication unit, (ii) a first control unit, (iii) a vehicle having a dead battery, (iv) a plurality of power supply vehicles/a power supply vehicle, (v) a battery configured to supply power to another vehicle, (vi) a positioning unit including a global navigation system (GPS), (vii) a detection unit, (viii) a sensor, (ix) a second communication unit, and (x) a second control unit in combination], do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Thus, the claim is directed to an abstract idea. Step 2B As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) “apply it” (or an equivalent), and (ii) generally link the use of a judicial exception to a particular technological environment or field of use, and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)); and (ii) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claims adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claim 5 is ineligible. Novel and Non-Obvious Over the Prior Art Claim 5 is novel and non-obvious over the prior art; however, these claims are subject to the above rejections. The closest prior art is U.S. Patent Application No. 2024/0034184 to Al Gafri et al (hereafter Al Gafri). Al Gafri discloses a server device gathering power requirements based on reference battery capacity and location of a vehicle needing charge, gathering location information for power supply vehicles to provide charge, and selecting a power supply vehicle within a predefine proximity to the vehicle needing charge and routing the selected power supply vehicle to vehicle needing charge. The next closest prior art is U.S. Patent Application No. 2020/0262305 to Chakraborty et al (hereafter Chakraborty). Chakraborty discloses the vehicle needing charge having a dead battery, the server gathering information on the remaining battery capacity of the plurality of power supply vehicles, the power supply vehicle having a battery configured to supply power to another vehicle, GPS configured to acquire its location, and a detection unit for detecting battery capacity information of the battery, and scheduling a charging session for the power supply vehicle at a charging station. The next closest prior art is U.S. Patent Application No. 2024/0010094 to Choi et al (hereafter Choi). Choi discloses the server gathering information regarding a desired time to receive power supply. The next closest prior art is U.S. Patent Application No. 2016/0139600 to Delp et al (hereafter Delp). Delp discloses determining charging locations along the previously determined route, which includes the lowest power purchase price included, and modifying the initial route to include the charging location. The next closest prior art is U.S. Patent Application No. 2023/0211697 to Xia et al (hereafter Xia). Xia discloses selecting the power supply vehicle having the maximum remaining battery capacity. While the closest prior art above teaches the various aspects of the claimed invention individually, the combination of these references are not obvious in such a way that they would have been obvious to one of ordinary skill in the art at the time of invention. Specifically, Al Gafri in view of Cakraborty, and further in view of Choi, and even further in view of Delp and even further in view of Xia fails to explicitly disclose selecting and scheduling the lowest purchase price facility derived from searching facilities along the first travel route. Therefore, the claims are rendered novel and non-obvious over the prior art. 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to DAVID G GODBOLD whose telephone number is (571)272-5036. The examiner can normally be reached M-F 8-5. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Shannon S Campbell can be reached at 571-272-5587. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /DAVID G. GODBOLD/Examiner, Art Unit 3628 /SHANNON S CAMPBELL/Supervisory Patent Examiner, Art Unit 3628
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Prosecution Timeline

Dec 04, 2023
Application Filed
Jul 27, 2025
Non-Final Rejection — §101
Sep 09, 2025
Interview Requested
Sep 17, 2025
Applicant Interview (Telephonic)
Sep 17, 2025
Examiner Interview Summary
Oct 16, 2025
Response Filed
Dec 01, 2025
Final Rejection — §101 (current)

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Prosecution Projections

3-4
Expected OA Rounds
22%
Grant Probability
55%
With Interview (+33.3%)
2y 1m
Median Time to Grant
Moderate
PTA Risk
Based on 82 resolved cases by this examiner. Grant probability derived from career allow rate.

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