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 the Claims
This Office Action is in response to the Applicant’s amendments and remarks filed February 17, 2026. Claims 1, 8, 15 have been amended. Claims 3, 10, and 17 have been canceled. Claims 21, and 22 have been added. Claims 1, 2, 4-9, 11-16, and 18-22 are pending.
Response to Remarks/Arguments
Applicant’s arguments and amendments filed February 17, 2026 with respect to the previous 35 U.S.C. 101 rejections have been fully considered.
Applicant argues the claimed invention is eligible subject matter under 35 U.S.C. 101 because Applicant argues the claimed invention is not directed to an abstract idea because the claimed invention cannot reasonable be performed in the human mind. Additionally, Applicant asserts if the claimed invention is construed as an abstract idea, the claimed invention is eligible subject matter because it is directed to an improvement to the technical field of vehicle data transfer by reciting specific data transfer protocols and techniques that prevent unnecessary transfers thereby improving communication efficiency.
Examiner respectfully disagrees. A persona can reasonably perform the claimed invention, but for the use of generic computing components, because a person can mentally decide how much data should be transferred based on various criteria, wherein the implementation of that mental decision via a generic computing environment, e.g., a data source system in communication with a client device, is an example of the “apply it” principle outlined by the courts.
Additionally, the asserted improvement is to the abstract idea itself, i.e., deciding/judging/evaluating/etc. which data to transfer. Applicant argues the claimed invention is directed to a specific protocol, however, Applicant’s protocol appears generic as it essentially comprises the steps of determining which data from an unspecific data set to transmit, according to unspecific criteria, i.e., “a particular data classification,” and a “context-based criterion.” These criteria are listed in the dependent claims but are directed to well-understood considerations in the vehicle control system arts, i.e., vehicle operational criteria, location-based criteria, or environmental-based criteria.
Applicant’s stated improvement is an example of an improvement to the abstract idea itself because the claimed invention is directed to determining which data from a larger data set should be transmitted to a client device, but does so “better” by reducing the amount of data to be transferred. This in an example of an improvement to the abstract idea itself as contrasted against subject matter eligibility examples like Example 39 where the claimed invention identified a specific problem with performing facial detection to account for shifts, distortions, and variations in facial images, and an improvement tailored to address that problem.
For at least the above, the claimed invention is not eligible and the previous rejections are maintained.
Applicant’s arguments and amendments filed February 17, 2026 with respect to the previous 35 U.S.C. 102 and 103 rejections have been fully considered.
With respect to the previous rejection under 35 U.S.C. 102 of claim 1, Applicant argues the cited art of record Srinivasan et al., US 20200226940 A1, hereinafter referred to as Srinivasan ‘940, fails to explicitly disclose all of the features of claim 1, as presently amended, specifically, “determining, using the context processing model and based at least on the at least one context-based criterion and the at least one client device being subscribed to the particular data classification, a subset of the plurality of data objects within the bulk vehicle-relevant data record that are relevant to the at least one client device; and transmitting, to the at least one client device, only the subset of the plurality of data objects in response to determining that the at least one context-based criterion is satisfied, and refraining from transmitting data objects of the bulk vehicle-relevant data record that are not included in the subset.”
Applicant argues the cited art fails to disclose the above because Srinivasan ‘940 is directed to selecting between different type of data for flight management cloud service but fails to explicitly disclose the claimed filtering of individual data objects within a bulk data record based jointly on subscription and context-based criteria.
Examiner respectfully disagrees. Srinivasan ‘940 explicitly discloses using large datastores, i.e., bulk records, (Data collector system receives data associated with flight management from data lake/database/etc. – See at least ¶39) and then determines which data to transmit on the basis of context criteria as part of a subscription service (Subscription based services using various types of devices – See at least ¶15; Recommender in response to satisfaction of various criteria including contexts – See at least Abstract and ¶35).
Examiner notes the same rationale applies to independent claims 8 and 15.
For at least the above, the claims are not in condition for allowance and the previous rejections are maintained.
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, 2, 4-9, 11-16, and 18-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter.
Claims 1, 2, 4-9, 11-16, and 18-22 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more. Claims 1, 2, 4-9, 11-16, and 18-22 are directed to the abstract idea of determining which data to transmit to a user, which is an abstract idea under its broadest reasonable interpretation because the claimed invention is directed to an observation, evaluation and/or judgment as to whether to transmit data to a user. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements are either directed to insignificant extra-solution activity, i.e., data gathering, and transmitting results, or generic hardware recited at a high level of generality, i.e., a data source system, a client device, etc., that provide conventional computer functions that do not add meaningful limits to practicing the abstract idea.
Claim 1 recites method comprising: receiving, from at least one data source system, a bulk vehicle-relevant data record comprising a plurality of data objects associated with a particular data classification of a plurality of data classifications; determining at least one client device is subscribed to the particular data classification; determining, based at least in part on vehicle context data, that at least one context-based criterion associated with the at least one client device is satisfied using a context processing model configured to learn the at least one context-based criterion; determining, using the context processing model and based at least on the at least one context-based criterion and the at least one client device being subscribed to the particular data classification, a subset of the plurality of data objects within the bulk vehicle-relevant data record that are relevant to the at least one client device; and transmitting, to the at least one client device, only the subset of the plurality of data objects in response to determining that the at least one context-based criterion is satisfied, and refraining from transmitting data objects of the bulk vehicle-relevant data record that are not included in the subset.
Under it its broadest reasonable interpretation, the claim recites a mental process because determining whether to transmit certain data to a user according to various criteria and considerations, i.e., whether a client device is subscribed to a given service, and refraining from transmitting other data based on various criteria and considerations is an example of an observation, evaluation and/or judgment, and observations, evaluations and/or judgments are examples of abstract ideas. The additional elements of receiving vehicle-relevant data, and transmitting the vehicle-relevant data are examples of insignificant extra-solution activity. The additional elements of the generic hardware of claim 1 are recited at a high level of generality such that they do not impose meaningful limits on practicing the claimed invention.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more than the abstract idea because looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually.
Claims 2, 4-7, and 21-22 depend on claim 1 but do not render the claimed invention eligible because they are directed to insignificant additional elements primarily directed to additional data gathering steps, i.e., receiving historical data or mental steps directed to the above described observation, evaluation and/or judgment, i.e., determining whether to transmit or refrain from transmitting data, etc., or generic hardware, i.e., stationary data source, mobile data source system, etc.
Independent claims 8 and 15 are rejected under the same rationale as claim 1 because the claims recite nearly identical subject matter but for insignificant differences as claims 8 and 15 include insignificant additional elements of processors, and memory.
Claims 9, and 11-14 depend from claim 9, and claims 16, and 18-20 depend from claim 15 and are rejected under the same rationale as claims 2, and 4-7.
Claims 1, 2, 4-9, 11-16, and 18-22 are therefore not drawn to eligible subject matter as they are directed to an abstract idea without significantly more.
Claim Rejections - 35 USC § 102
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 the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 1, 4-8, 10-15, 17-20, and 22 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Srinivasan et al., US 20200226940 A1, hereinafter referred to as Srinivasan.
As to claim 1, Srinivasan discloses a method comprising:
receiving, from at least one data source system, vehicle-relevant data associated with a particular data classification of a plurality of data classifications (Various types, i.e., classifications, of data including weather, etc. – See at least ¶5);
determining at least one client device is subscribed to the particular data classification (Subscription based services using various types of devices – See at least ¶15);
determining, based at least in part on vehicle context data, that at least one context-based criterion associated with the at least one client device is satisfied using a context processing model configured to learn the at least one context-based criterion (Context analysis parameters – See at least Abstract; Analytical model – See at least ¶34);
determining, using the context processing model and based at least on the at least one context-based criterion and the at least one client device being subscribed to the particular data classification, a subset of the plurality of data objects within the bulk vehicle-relevant data record that are relevant to the at least one client device (Data collector system receives data associated with flight management from data lake/database/etc. – See at least ¶39; Recommender in response to satisfaction of various criteria including contexts – See at least Abstract and ¶35); and
transmitting, to the at least one client device, only the subset of the plurality of data objects, at least the vehicle-relevant data in response to determining that the at least one context-based criterion is satisfied, and refraining from transmitting data objects of the bulk vehicle-relevant data record that are not included in the subset (Recommender in response to satisfaction of various criteria including contexts – See at least Abstract and ¶35; Examiner notes by only transmitting data which meets criteria, by implication Srinivisan is similarly refraining from transmitting data that does not meet the given criteria.).
Independent claims 8 and 15 are rejected under the same rationale as claim 1 because the claims recite nearly identical subject matter but for minor differences due to the claims being directed to different statutory categories of invention.
As to claims 4, 11, and 18, Srinivasan discloses the at least one context-based criterion comprises at least one of: (i) a vehicle operational criterion, (ii) a location-based criterion, or (iii) an environmental-based criterion (Various contexts include flight context, airport context, and weather context – See at least ¶31).
As to claims 5, 12, and 19, Srinivasan discloses the plurality of data classifications comprises at least one of: (i) a data classification associated with weather data, (ii) a data classification associated with flight plan data, (iii) a data classification associated with airport data, or (iv) a data classification associated with notice to airmen (NOTAM) data (Various contexts include flight context, airport context, and weather context – See at least ¶31).
As to claims 6, 13, and 20, Srinivasan discloses the at least one data source system comprises at least one of: (i) a stationary data source system or (ii) a mobile data source system (Various services – See at least ¶27-28 and Figs. 1-2).
As to claims 7, and 14, Srinivasan discloses the vehicle context data comprises at least one of: (i) motion data for a vehicle, (ii) position data for the vehicle, (iii) system data for the vehicle, (iv) passenger data for the vehicle, or (v) environmental data for the vehicle (Various data including flight plans, i.e., “motion data” and “position data,” and weather data – See at least Abstract and ¶31).
As to claim 22, Srinivasan discloses transmitting only the subset of the plurality of data objects reduces an amount of data communicated to the at least one client device relative to transmitting the bulk vehicle-relevant data record, and wherein the context processing model is configured to determine the subset in a manner that improves communication efficiency based on the at least one context-based criterion (Recommender in response to satisfaction of various criteria including contexts – See at least Abstract and ¶35; Examiner notes by only transmitting data which meets criteria by implication Srinivisan is reducing an amount of data to be communicated as compared to all the date in a given datastore. Additionally, “in a manner that improves communication efficiency” is an example of intended result and not given patentable weight.).
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.
Claims 2, 9, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Srinivasan et al., US 20200226940 A1, in view of Srinivasan et al., US 20210083696 A1, hereinafter referred to as Srinivasan ‘940, and Srinivasan ‘696, respectively.
As to claims 2, 9, and 16, Srinivasan ‘940 fails to explicitly disclose:
receiving historical data transfer information indicative of at least one data transfer event for historical vehicle-relevant data and at least one context corresponding to the at least one data transfer event; and
configuring the context processing model to learn the at least one context-based criterion based at least at part on the historical data transfer information.
However, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of Srinivasan ‘940 and include the feature of receiving historical data transfer information indicative of at least one data transfer event for historical vehicle-relevant data and at least one context corresponding to the at least one data transfer event and configuring the context processing model to learn the at least one context-based criterion based at least at part on the historical data transfer information, with a reasonable expectation of success, because Srinivasan ‘696 teaches it is useful to consider historical usage to better suit a current user (See at least ¶17 of Srinivasan ‘696).
Claim 21 is rejected under 35 U.S.C. 103 as being unpatentable over Srinivasan et al., US 20200226940 A1, in view of Hochwarth et al., US 20230271698 A1, hereinafter referred to as Srinivasan, and Hochwarth, respectively.
As to claim 21, Srinivasan fails to explicitly disclose determining the subset of the plurality of data objects comprises filtering the bulk vehicle-relevant data record using a publish-subscribe framework in which the data objects are associated with respective publishing topics, and the at least one client device is subscribed to the publishing topic corresponding to the particular data classification. However, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of Srinivasan and include the feature of determining the subset of the plurality of data objects comprises filtering the bulk vehicle-relevant data record using a publish-subscribe framework in which the data objects are associated with respective publishing topics, and the at least one client device is subscribed to the publishing topic corresponding to the particular data classification, with a reasonable expectation of success, because Hochwarth teaches using a publish-subscribe framework in order to provide relevant avionics data (See at least ¶44-45 of Hochwarth).
Conclusion
THIS ACTION IS MADE FINAL. 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 Lail Kleinman whose telephone number is (571)272-6286. The examiner can normally be reached M-F 8:00-5:00.
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/LAIL A KLEINMAN/Primary Examiner, Art Unit 3668
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