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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 06/03/2026 has been entered.
Response to Amendment
The amendment filed on 06/03/2026 has been entered. Claims 1-7, 9-17, and 19-20 remain pending in this application. Claims 1, 7, 9, 10, 17, and 19-20 have been amended. Claims 8 and 18 have been cancelled. No claims are new.
Response to Arguments
Applicant’s arguments filed 06/03/2026 regarding prior art rejections have been fully considered and are persuasive. All prior art rejections are overcome in consideration of amendments which incorporate previously indicated allowable subject matter.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 06/03/2026 has been considered by the examiner.
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 1-7, 9-17, and 19-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more. The claim(s) are directed to a system and a method and recite(s) judicial exceptions as explained in the Step 2A, Prong 1 analysis below. The judicial exceptions are not integrated into a practical application as explained in the Step 2A, Prong 2 analysis below. The claim(s) do not include additional elements that are sufficient to amount to significantly more than the judicial exception as explained in the Step 2B analysis below.
Independent claim(s) 1, 10, and 20:
Step
Analysis
1: Statutory Category?
Yes. Claim 1 recites a series of steps and therefore, is a process. Claims 10 and 20 recites a device, and therefore, is a machine as such, the claim(s) are directed to one of the four categories of patent eligible subject matter, and are eligible for further analysis.
2A - Prong 1: Judicial Exception Recited (i.e., mathematical concepts, certain methods of organizing human activities such as a fundamental economic practice, or mental processes)?
Yes. Claim 1 recites the limitations of:
“determining a target relative clock offset between a target responder device of a first subset of the plurality of responder devices and the initiator device based on one or more reference responder devices of a second subset of the plurality of responder devices, the first subset of the plurality of responder devices having successful reception of either the ranging initiation message or the ranging final message, and the second subset of the plurality of responder devices having successful reception of the ranging initiation message and the ranging final message, wherein the determining the target relative clock offset comprises determining a set of relative clock offsets between the initiator device and the second subset of the plurality of responder devices”
The focus of the claim (i.e., determining a time of flight) is on selecting certain information and analyzing it. These observations or evaluations are simply mathematical concepts (algorithms, spatial relationships, coordinate transformations, residual/ interpolation, geometry, etc.). When given its broadest reasonable interpretation in light of the disclosure, it is simply selection and mathematical manipulation of data. Merely selecting information for collection and analysis does nothing significant to differentiate a process from an abstract idea.
Thus, the claim recites a mathematical concept. The same or similar reasoning is applied to claims 10 and 20
2A - Prong 2: Integrated into a Practical Application?
No.
The claim does not recite any additional elements that would integrate the judicial exception into a practical application.
Regarding claim 1, the additional limitation(s) merely is used to perform the abstract idea, and is merely invoked as tools of performing generic functions. The further recitation of limitation(s) of “transmitting a ranging initiation message to a plurality of responder devices based on a first radio access technology (RAT)”, “transmitting a ranging final message to the plurality of responder devices based on the first RAT”, and “receiving a plurality of indications from the plurality of responder devices based on a second RAT prior to the ranging initiation message being transmitted, the plurality of indications indicating that none of the plurality of responder devices are capable of providing an inter- responder clock offset between the target responder device and any one of the one or more reference responder devices” are considered insignificant extra-solution activities to the judicial exception.
The limitation(s) of “one or more memories; one or more transceivers; and one or more processors communicatively coupled to the one or more memories and the one or more transceivers, the one or more processors, either alone or in combination, configured to” of claim 10 is recited at a high level of generality. The additional limitation(s) merely is used to perform the abstract idea, and is merely invoked as tools of performing generic functions. The further recitation of limitation(s) of “transmit, via the one or more transceivers, a ranging initiation message to a plurality of responder devices based on a first radio access technology (RAT);transmit, via the one or more transceivers, a ranging final message to the plurality of responder devices based on the first RAT” and “receive, via the one or more transceivers, a plurality of indications from the plurality of responder devices based on a second RAT prior to the ranging initiation message being transmitted, the plurality of indications indicating that none of the plurality of responder devices are capable of providing an inter-responder clock offset between the target responder device and any one of the one or more reference responder devices” are considered insignificant extra-solution activities to the judicial exception.
Regarding claim 20, the additional limitation(s) merely is used to perform the abstract idea, and is merely invoked as tools of performing generic functions. The further recitation of limitation(s) of “means for transmitting a ranging initiation message to a plurality of responder devices based on a first radio access technology (RAT);means for transmitting a ranging final message to the plurality of responder devices based on the first RAT” and “means for receiving a plurality of indications from the plurality of responder devices based on a second RAT prior to the ranging initiation message being transmitted, the plurality of indications indicating that none of the plurality of responder devices are capable of providing an inter-responder clock offset between the target responder device and any one of the one or more reference responder devices” are considered insignificant extra-solution activities to the judicial exception.
Accordingly, the claim as a whole does not integrate the recited judicial exception into a practical application.
2B: Claim provides an Inventive Concept?
No.
Step 2 considers whether the claim provides limitations which amount to “significantly more” than the recited judicial exception. The claim as a whole does not provide any meaningful limitations which amount to significantly more than the mental process of claim 1/10/20.
The limitation(s) is/are at best the equivalent of merely adding the words “apply it” to the judicial exception.
Therefore, the claim as a whole does not provide meaningful limitations which amount to significantly more than the mathematical concept of claim 1/10/20 and does not state an inventive concept. The limitation(s) are just a nominal or tangential addition to the claim. Looking at the elements as a combination does not add anything more than the elements analyzed individually.
Applicant’s disclosure does not provide evidence that the additional element(s) recited in claim 1/10/20 (i.e., the claim element(s) in addition to the abstract idea) is sufficient to amount to significantly more than the abstract idea itself. This issue is explained by the Federal Circuit, as follows:
It has been clear since Alice that a claimed invention’s use of the ineligible concept to which it is directed cannot supply the inventive concept that renders the invention “significantly more” than that ineligible concept. In Alice, the Supreme Court held that claims directed to a computer-implemented scheme for mitigating settlement risks claimed a patent-ineligible abstract idea. 134 S.Ct. at 2352, 2355—56. Some of the claims at issue covered computer systems configured to mitigate risks through various financial transactions. Id. After determining that those claims were directed to the abstract idea of intermediated settlement, the Court considered whether the recitation of a generic computer added “significantly more” to the claims. Id. at 2357. Critically, the Court did not consider whether it was well-understood, routine, and conventional to execute the claimed intermediated settlement method on a generic computer. Instead, the Court only assessed whether the claim limitations other than the invention’s use of the ineligible concept to which it was directed were well-understood, routine and conventional. Id. at 2359-60. BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290 (2018) (emphases added).
Therefore, independent claim(s) 1, 10, and 20 are ineligible.
Claims 2-7, 9, 11-17, and 19:
Step
Analysis
1: Statutory Category?
Yes. Claim 2 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mental process (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from ordinary mental processes.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim(s) 2 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 3 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 3 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 4 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 4 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 5 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 5 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 6 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 6 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 7 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 7 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 9 recites a series of steps and therefore, is a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 9 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 11 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 11 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 12 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 12 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 13 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 13 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 14 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 14 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 15 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 15 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 16 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 16 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 17 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 17 is ineligible.
Step
Analysis
1: Statutory Category?
Yes. Claim 19 recites a system, and therefore, is a machine. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter.
2A - Prong 1: Judicial Exception Recited?
Yes. The claim is directed to the system of claim 10 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea.
2A - Prong 2: Integrated into a Practical Application?
No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions.
2B: Claim provides an Inventive Concept?
No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract.
Therefore, dependent claim 19 is ineligible.
Reasons for Allowance
The following is an examiner’s statement of reasons for allowance:
Potential allowance of claims 1-7, 9-17, and 19-20 is indicated because:
None of the prior art of record teach or suggest the subject matter of independent claims 1, 10, and 20. The prior art of record does not anticipate or render fairly obvious in combination to teach all of the additional limitations of the claimed invention, as best understood within the context of Applicant’s claimed invention as a whole, such as in claim 1, and similarly in claims 10, and 20, wherein the determining the target relative clock offset comprises determining a set of relative clock offsets between the initiator device and the second subset of the plurality of responder devices; determining a time of flight between the initiator device and the target responder device based on one or more time of flight measurements and the target relative clock offset; and receiving a plurality of indications from the plurality of responder devices based on a second RAT prior to the ranging initiation message being transmitted, the plurality of indications indicating that none of the plurality of responder devices are capable of providing an inter- responder clock offset between the target responder device and any one of the one or more reference responder devices.
Accordingly, independent claims 1, 10, and 20 are deemed to have allowable subject matter. Claims 2-7, 9, 11-17, and 19 would also be allowed by virtue of their dependence on allowable independent claims.
Claim(s) 1-7, 9-17, and 19-20 would be allowable if rewritten or amended to overcome the rejection(s) under 35 U.S.C. 101, set forth in this Office action. However, the Examiner would like to note that there is a possibility the scope of the claim(s) would be significantly changed after the claim(s) are rewritten or amended to overcome the rejection(s) under 35 U.S.C. 101, set forth in this Office action; thus, further search and consideration will be made after official amendment is filed on record.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to KENNETH W GOOD whose telephone number is (571)272-4186. The examiner can normally be reached Mon - Thu 7:30 am - 5:00 pm.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Resha H Desai can be reached at (571) 270-7792. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/KENNETH W GOOD/Examiner, Art Unit 3648
/RESHA DESAI/Supervisory Patent Examiner, Art Unit 3648
Prosecution Insights