Prosecution Insights
Last updated: October 04, 2026
Application No. 18/543,219

VEHICLE MANAGEMENT DEVICE

Non-Final OA §103
Filed
Dec 18, 2023
Priority
Feb 22, 2023 — JP 2023-026645
Examiner
PARK, SAMUEL SUNWOOK
Art Unit
Tech Center
Assignee
Toyota Motor Corporation
OA Round
1 (Non-Final)
Grant Probability
Favorable
1-2
OA Rounds

Office Action

§103
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 . 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. Claims 1, 3 and 4 are rejected under 35 U.S.C. 103 as being unpatentable over Salter et al. (US 20220379770 A1) in view of Lewchuk et al. (US 20230120740 A1). Independent claim 1, Salter teaches a vehicle management device (10) (Figs. 1-3, bidirectional energy transfer system; ¶31) to be used for a vehicle (12) (Figs. 1-3, electrified vehicle) including a drive unit for travel (¶’s [33, 39], i.e., engine, motor and inverter), a power storage device (16) (Figs. 1-3, traction battery pack) configured to supply electric power to the drive unit (see ¶39). Further Salter teaches the vehicle (12) (Figs. 1-3, electrified vehicle) being configured to supply the electric power to an outside of the vehicle (Fig. 2; ¶42). Salter fails to explicitly teach a solar cell system configured to generate electric power by a solar cell and supply the electric power to the power storage device, wherein the vehicle management device is configured to set an allowable power supply amount for the outside of the vehicle while the vehicle is parked within a range of a predicted power generation amount of the solar cell until a next scheduled travel start time. Lewchuk teaches a solar cell system (547) (Fig. 14, solar PV system; see ¶8, solar photovoltaic array) configured to generate electric power by a solar cell and supply the electric power to the power storage device (545) (Fig. 14, battery system, solar PV system; see ¶132). Lewchuk also teaches wherein the vehicle management device (Fig. 43, device 4380 for electric vehicle charging; ¶225) is configured to set an allowable power supply amount for the outside of the vehicle (Fig. 49; ¶318) while the vehicle is parked within a range of a predicted power generation amount of the solar cell (Fig. 50, predict generation 5006; ¶’s [330, 331]) until a next scheduled travel start time (see ¶’s [330, 331, 333, 343], the system predicts solar generation power until a departure time of a vehicle). Salter and Lewchuk are considered to be analogous to the claimed invention because they are in the same field of electric vehicle power management system. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Salter to incorporate the teachings of Lewchuk and provide the vehicle power management system coupled with a power storage device and a solar photovoltaic system because the claimed invention supplements the electric vehicle power system by connecting a solar cell system which could be used for a power source management for both an electric vehicle and home considering a predicted power generation amount from the solar cell (see ¶38 of Salter, where the solar cell system of Lewchuck would be included in the bidirectional power transfer system 34 or grid power source 32, which results in a predictable outcome that provides the power management system for both an electric vehicle and home utilizing solar power). PNG media_image1.png 382 502 media_image1.png Greyscale Fig. 1 (Salter) PNG media_image2.png 383 500 media_image2.png Greyscale Fig. 2 (Salter) PNG media_image3.png 572 676 media_image3.png Greyscale Fig. 3 (Salter) PNG media_image4.png 557 337 media_image4.png Greyscale Fig. 14 (Lewchuk) Dependent claim 3, Salter fails to explicitly teach wherein the vehicle management device is configured to notify a user about the allowable power supply amount to allow the user to change the allowable power supply amount. Lewchuk teaches wherein the vehicle management device (Fig. 43, device 4380 for electric vehicle charging; ¶225) is configured to notify a user (Fig. 45, programmable controller 4525; ¶291) about the allowable power supply amount to allow the user to change the allowable power supply amount (Fig. 49, determine in generation or consumption 4912; see ¶324, a user can change power supply amount through a user interface). Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Salter to incorporate the teachings of Lewchuk and provide a vehicle power management system coupled with a user-configurable system to be notified and to change the allowable power supply amount because the claimed invention supplements the power management system by connecting a user-configurable system which could be used to provide the information of the allowable power supply amount to a user who can change the allowable power amount (see Fig. 5; ¶’s [70, 71] of Salter, where the user-configurable system of Lewchuk would be included in the method 100, which results in a predictable outcome that provides the power management system notifying the allowable power amount to a user who can set a desired power amount). Dependent claim 4, Salter teaches wherein the vehicle management device (10) (Figs. 1-3, bidirectional energy transfer system; ¶31) is configured to notify the user together with information (Fig. 3, smart bidirectional charging schedule 78; ¶54) as to whether the vehicle participates in a virtual power plant (see ¶’s [31, 64, 68], the bidirectional charging schedule 78 is controlled by the cloud network 50 and the user is notified whether the vehicle participates in charging any type of structure 14 that is capable of transferring electric power). Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over Salter in view of Lewchuk, further in view of Go (US 20190176629 A1). Dependent claim 2, Salter teaches wherein the vehicle management device (10) (Figs. 1-3, bidirectional energy transfer system; ¶31) is configured to set the allowable power supply amount (¶20, charging storage limit) within an expanded range larger than the predicted power generation amount when the vehicle does not participate in the virtual power plant (see ¶59, the charging storage limit is raised by the control module 46 when the vehicle is on-plug). Salter fails to explicitly teach wherein the vehicle management device is configured to set the allowable power supply amount within the range of the predicted power generation amount when the vehicle participates in a virtual power plant. Go teaches wherein the vehicle management device (10) (Fig. 1, solar charging control device; ¶29) is configured to set the allowable power supply amount within the range of the predicted power generation amount (Fig. 1, power generation prediction unit 13; see ¶18, the charging system predicts the power generation amount in the solar power system) when the vehicle participates in a virtual power plant (see ¶15, an electric vehicle participates in a power network). Salter, Lewchuk and Go are considered to be analogous to the claimed invention because they are in the same field of electric vehicle power management system. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Salter to incorporate the teachings of Lewchuk and Go and provide that a vehicle power management system has the flexible range of allowable power amount interacted with a virtual power plant because the claimed invention supplements the electric vehicle power system by setting the allowable power supply amount within the range of the predicted power generation amount (see ¶59 of Salter, where the predicted power generation amount of Go would be included in determining the range of allowable power supply amount, which results in a predictable outcome that provides the flexible range of allowable power supply amount considering the supply and demand situations between the vehicle and home within the given virtual power plant). PNG media_image5.png 555 510 media_image5.png Greyscale Fig. 1 (Go) Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Samuel S. Park whose telephone number is 571-270-3327. The examiner can normally be reached Monday-Thursday, 7:30 AM - 4:30 PM ET. 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, Drew Dunn can be reached at 571-272-2312. 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. /SAMUEL S. PARK/ Examiner, Art Unit 2859 08/05/2026 /DREW A DUNN/ Supervisory Patent Examiner, Art Unit 2859
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Prosecution Timeline

Dec 18, 2023
Application Filed
Aug 25, 2026
Non-Final Rejection mailed — §103 (current)

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