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
This action is responsive to Applicant’s claims filed 06/22/2026.
Claims 1-9 and 11-16 are currently pending and have been examined here.
Claims 1, 11-12, and 15-16 have been amended.
Response to Arguments
Applicant’s arguments with respect to the 35 U.S.C. 103 have been fully considered, and they are persuasive. The 35 U.S.C. 103 rejections have been withdrawn.
Applicant's arguments, see pages 7-8 of Applicant’s Response filed 03/10/2026, with respect to the 35 U.S.C. 101 rejections have been fully considered but they are not persuasive.
Applicant argues, on pages 7-8, that the claims bring forth a technical improvement through a machine-implemented navigation workflow governing how the navigation device itself generates, presents, and updates navigation guidance, and, therefore the claims are directed to patent eligible subject matter. Examiner respectfully disagrees. Examiner respectfully notes that the presentation of alternative travel paths which distinguish between routes with in-network charging stations and those without recites one or more abstract ideas, since a human using their mind and pen and paper could perform this step. The mere requirement to do so on a generic computer component such as the electronic device using a map application and a user interface does not amount to a technical improvement, and does not direct the claims to patent eligible subject matter. Applicant’s arguments are therefore unpersuasive.
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 1-9 and 11-16 are rejected under 35 U.S.C. § 101. The claims are drawn to ineligible patent subject matter, because the claims are directed to a recited judicial exception to patentability (an abstract idea), without claiming something significantly more than the judicial exception itself.
Claims are ineligible for patent protection if they are drawn to subject matter which is not within one of the four statutory categories, or, if the subject matter claimed does fall into one of the four statutory categories, the claims are ineligible if they recite a judicial exception, are directed to that judicial exception, and do not recite additional elements which amount to significantly more than the judicial exception itself. Alice Corp. v. CLS Bank Int'l, 375 U.S. ___ (2014). Accordingly, claims are first analyzed to determine whether they fall into one of the four statutory categories of patent eligible subject matter. Then, if the claims fall within one of the four statutory categories, it must be determined whether the claims are directed to a judicial exception to patentability (i.e., a law of nature, a natural phenomenon, or an abstract idea). In determining whether a claim is directed to a judicial exception, the claim is first analyzed to determine whether the claim recites a judicial exception. If the claim does not recite one of these exceptions, the claim is directed to patent eligible subject matter under 35 U.S.C. 101. If the claim recites one of these exceptions, the claim is then analyzed to determine whether the claim recites additional elements that integrate the exception into a practical application of that exception. Claims which integrate the exception into a practical application of that exception are directed to patent eligible subject matter under 35 U.S.C. 101. If the claim fails to integrate the exception into a practical application of that exception, the claim is directed to an abstract idea. Finally, if the claims are directed to a judicial exception to patentability, the claims are then analyzed determine whether the claims are directed to patent eligible subject matter by reciting meaningful limitations which transform the judicial exception into something significantly more than the judicial exception itself. If they do not, the claims are not directed towards eligible subject matter under 35 U.S.C. § 101.
Regarding independent claims 1, 15, and 16 the claims are directed to one of the four statutory categories (a process, a machine, and an article of manufacture, respectively.) The claimed invention of independent claims 1, 15, and 16 is directed to a judicial exception to patentability, an abstract idea. The claims include limitations which recite elements which can be properly characterized under at least one of the following groupings of subject matter recognized as abstract ideas by MPEP 2106.04(a):
Mathematical Concepts: mathematical relationships, mathematical formulas or equations, and mathematical calculations;
Certain methods of organizing human activity: fundamental economic principles or practices (including hedging, insurance, mitigating risk); commercial or legal interactions (including agreements in the form of contracts; legal obligations; advertising, marketing or sales activities or behaviors; business relations); managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions); and
Mental processes: concepts performed in the human mind (including an observation, evaluation, judgment, opinion)
Claims 1, 15, and 16, as a whole, recite the following limitations:
detecting. . . user input corresponding to a request to display one or more routes to a respective destination; (claims 1, 15, 16; the broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could detect user input corresponding to a request to display routes; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers)
displaying. . . a plurality of candidate routes to the respective destination, the plurality of candidate routes including: a first candidate route that is associated with a preferred charging network, and displayed in association with a visual indication that the first candidate route is associated with the preferred charging network; and a second candidate route that is not associated with the preferred charging network, and displayed in association with a visual indication that the second candidate route is not associated with the preferred charging network; (claims 1, 15, 16; the broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could display first and second routes, each with an indication as to whether the charging stations along the route are in network or not; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers)
detecting. . . an event (claims 1, 15, 16; the broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could detect an event; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers)
and in response to detecting the event: in accordance with a determination that the event satisfies one or more first criteria, including a criterion that is satisfied when a level of activity associated with a first destination that is included in the determined route is greater than a threshold level of activity, wherein the first destination is associated with a preferred charging network, initiating a process to modify the determined route to replace the first destination with a second destination, different from the first destination, in the determined route; (claims 1, 15, 16; the broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could initiate a process to modify a route based on criteria being met in this fashion; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers)
and in accordance with a determination that the event does not satisfy the one or more first criteria, forgoing the initiating of the process to modify the determined route to replace the first destination with the second destination in the determined route. (claims 1, 15, 16; the broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could refrain from updating a route if criteria are not met in this fashion; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers)
The above elements represent certain methods of organizing human activity, as a whole, since the claims recite a process for determining when a new destination is required and routing the vehicle accordingly, a business relation since commercial vehicle routing services would perform this step for their customers. Furthermore, as a whole, the claims recite mental processes since, but for the requirement to implement the above process on a set of generic computer components (or merely “apply” the abstract idea using these elements), the claims recite a mental process since a human using their mind, pen and paper, and simple observation, evaluation and judgment could determine when a new destination is required and route a vehicle accordingly.
Moving forward, the above recited abstract idea is not integrated into a practical application.
The added limitations do not represent an integration of the abstract idea into a practical application because:
the claims represent mere instructions to implement an abstract idea on a computer, and merely use a computer as a tool to perform an abstract idea. See MPEP 2106.05(f).
the claims merely add insignificant extra-solution activity to the judicial exception (activity which can be characterized as incidental to the primary purpose or product that is merely a nominal or tangential addition to the claim). See MPEP 2106.05(g) and/or
the claims represent mere general linking of the use of the judicial exception to a particular technological environment or field of use. See MPEP 2016.05(h)
Beyond those limitations which recite the abstract idea, the following limitations are added:
a user interface of a maps application, (claims 1, 15, and 16; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
at an electronic device that is in communication with one or more input devices and a display generation component: (claims 1, 15, and 16; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
while the electronic device is providing navigation directions for a determined route corresponding to the first candidate route or the second candidate route using the maps application, (claims 1, 15, and 16; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
. . . via the one or more input devices. . . (claims 1, 15, and 16; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
An electronic device comprising: (claim 15; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
one or more processors; (claim 15; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
memory; (claim 15; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
and one or more programs, wherein the one or more programs are stored in the memory and configured to be executed by the one or more processors, the one or more programs including instructions for: (claim 15; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
A non-transitory computer readable storage medium storing one or more programs, the one or more programs comprising instructions, which when executed by one or more processors of an electronic device, cause the electronic device to perform a method comprising: (claim 16; the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use)
The claims, as a whole, are directed to the abstract idea(s) which they recite. The claim limitations do not present improvements to another technological field, nor do they improve the functioning of a computer or another technology. Nor do the claim limitations apply the judicial exception with, or by use of a particular machine. The claims do not effect a transformation or reduction of a particular article to a different state or thing. See MPEP 2106.05(c). None of the hardware in the claims "offers a meaningful limitation beyond generally linking 'the use of the [method] to a particular technological environment' that is, implementation via computers” such that the claim as a whole is more than a drafting effort designed to monopolize the exception. See MPEP 2106.05(e); Alice Corp. v. CLS Bank Int’l (citing Bilski v. Kappos, 561 U.S. 610, 611 (U.S. 2010)). Therefore, because the claims recite a judicial exception (an abstract idea) and do not integrate the judicial exception into a practical application, the claims, as a whole, are directed to the judicial exception.
Turning to the final prong of the test (Step 2B), independent claims 1, 15, and 16 do not include additional elements that are sufficient to amount to significantly more than the judicial exception, because there are no meaningful limitations which transform the exception into a patent eligible application.
As outlined above, the claim limitations do not present improvements to another technological field, nor do they improve the functioning of a computer or another technology. Nor do the claim limitations apply the judicial exception with, or by use of a particular machine. The claims do not effect a transformation or reduction of a particular article to a different state or thing. See MPEP 2106.05(c). None of the hardware in the claims "offers a meaningful limitation beyond generally linking 'the use of the [method] to a particular technological environment' that is, implementation via computers” such that the claim as a whole is more than a drafting effort designed to monopolize the exception. See MPEP 2106.05(e); Alice Corp. v. CLS Bank Int’l (citing Bilski v. Kappos, 561 U.S. 610, 611 (U.S. 2010)).
Furthermore, no specific limitations are added which represent something other than what is well-understood, routine, and conventional activity in the field. See MPEP 2106.05(d). Besides performing the abstract idea itself, the generic computer components only serve to perform the court-recognized well-understood computer functions of receiving or transmitting data over a network, performing repetitive calculations, electronic record keeping, and storing and retrieving information in memory. See MPEP 2106.05(d). Looking at the limitations as an ordered combination adds nothing that is not already present when looking at the elements taken individually. Their collective functions merely provide conventional computer implementation. The specification details any combination of a generic computer system program to perform the method. Generically recited computer elements do not add a meaningful limitation to the abstract idea because they would be routine in any computer implementation and because the Alice decision noted that generic structures that merely apply the abstract ideas are not significantly more than the abstract ideas. Therefore, independent claims 1, 15, and 16 are rejected under 35 U.S.C. §101 as being directed to ineligible subject matter.
Claims 2-9 and 11-14, recite the same abstract idea as their respective independent claims.
The following additional features are added in the dependent claims:
Claim 2:
wherein the first destination includes a first charging station associated with a first user preference, and the second destination includes a second charging station associated with a second user preference.
The broadest reasonable interpretation of this limitation merely alters the types of destinations used in the abstract idea above and therefore further recites one or more abstract ideas for the reasons outlined above.
Claim 3:
wherein: before detecting the event, the second destination is included, and after the first destination, along the determined route, the one or more first criteria include a criterion that is satisfied when the maps application indicates a level of charge of one or more batteries of an electronic vehicle associated with the electronic device will be greater than a threshold level of charge when a location corresponding to the electronic device is estimated to reach the second destination, and the second destination is not associated with the preferred charging network.
The broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could include a destination before detecting an event, and proceed using the level of charge as a criteria in a case where the second destination does not belong to the preferred charging network; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers.
Claim 4:
wherein the one or more first criteria include a criterion that is satisfied when the maps application indicates a location corresponding to the electronic device is within a threshold distance of the first destination.
The broadest reasonable interpretation of this limitation merely alters the types of criteria used in the abstract idea above and therefore further recites one or more abstract ideas for the reasons outlined above.
Claim 5:
wherein the process to modify the determined route includes displaying, via the display generation component, a selectable option that is selectable to initiate a process to search for the second destination.
The broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could display a selectable option to initiate a route searching process; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers. Regarding the use of the display generation component, the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use; alternatively still, using a display and selectable option amounts to the mere requirement to “apply” the abstract idea using a display.
Claim 6:
wherein the one or more first criteria include a criterion that is satisfied when the maps application indicates that an estimated level of charge of one or more batteries of an electronic vehicle associated with the electronic device will be greater than a threshold level of charge when the electronic device reaches the first destination.
The broadest reasonable interpretation of this limitation merely alters the types of criteria used in the abstract idea above and therefore further recites one or more abstract ideas for the reasons outlined above.
Claim 7:
wherein the one or more first criteria include a criterion that is satisfied when the maps application indicates that an estimated level of charge of one or more batteries associated with an electronic vehicle will be less than a threshold level of charge when the electronic device reaches the first destination.
The broadest reasonable interpretation of this limitation merely alters the types of criteria used in the abstract idea above and therefore further recites one or more abstract ideas for the reasons outlined above.
Claim 8:
wherein the one or more first criteria include a criterion that is satisfied when the maps application indicates that a travel time to traverse a respective portion of the determined route, wherein the respective portion of the determined route includes the first destination, is greater than a threshold amount of time.
The broadest reasonable interpretation of this limitation merely alters the types of criteria used in the abstract idea above and therefore further recites one or more abstract ideas for the reasons outlined above.
Claim 9:
wherein modifying the determined route to replace the first destination with the second destination includes: in accordance with a determination that the first destination has one or more first characteristics, selecting a first respective destination as the second destination, wherein the first respective destination has the one or more first characteristics;
and in accordance with a determination that the first destination has one or more second characteristics different from the one or more first characteristics, selecting a second respective destination, different from the first respective destination, as the second destination, wherein the second respective destination has the one or more second characteristics.
The broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could select first and second destinations based on whether they have first or second characteristics; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers.
Claim 11:
wherein the first destination includes a first vehicle charging station, and the first candidate route does not include a respective vehicle charging station.
The broadest reasonable interpretation of this limitation merely alters the types of destinations and routes used in the abstract idea above and therefore further recites one or more abstract ideas for the reasons outlined above.
Claim 12:
wherein displaying the plurality of candidate routes includes displaying first information indicating a relationship between the determined route and the preferred charging network associated with a user account associated with the electronic device.
The broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could display a relationship between the charging network and a user account; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers. Regarding the use of the display generation component, the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use; alternatively still, using a display and selectable option amounts to the mere requirement to “apply” the abstract idea using a display.
Claim 13:
further comprising: while displaying a user interface of the maps application: in accordance with a determination that a user account associated with the electronic device does not satisfy one or more second criteria, different from the one or more first criteria, including a criterion that is satisfied when the user account is associated with a respective preferred charging network in the maps application, displaying, via the display generation component, a selectable option that is selectable to initiate a process to associate the user account with the respective preferred charging network in the maps application;
and in accordance with a determination that the user account associated with the electronic device satisfies the one or more second criteria, forgoing display of the selectable option that is selectable to initiate the process to associate the user account with the preferred charging network in the maps application.
The broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could display a selectable option or not do so based on whether the user account satisfies one or more criteria; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers. Regarding the use of the user interface and display generation component, the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use; alternatively still, using a display and selectable option amounts to the mere requirement to “apply” the abstract idea using a display.
Claim 14:
wherein the selectable option that is selectable to initiate the process to associate the user account with the preferred charging network is displayed concurrently with a user interface of the maps application that includes a representation of a map.
The broadest reasonable interpretation of this limitation recites mental processes since a human using their mind, pen and paper, and simple observation, evaluation, and judgment could display this information concurrently; alternatively, the broadest reasonable interpretation of this limitation recites certain methods of organizing human activity in the form of commercial interactions such as business relations and sales activities since commercial vehicle routing services would perform this step for their customers. Regarding the use of the user interface and display generation component, the broadest reasonable interpretation of this limitation represents mere instructions to implement the abstract idea on a generic computer used as a tool in its ordinary capacity; alternatively, the broadest reasonable interpretation of this limitation represents mere general linking of the abstract idea to a particular computer environment or field of use; alternatively still, using a display and selectable option amounts to the mere requirement to “apply” the abstract idea using a display.
The above limitations do not represent a practical application of the recited abstract idea. The claim limitations do not present improvements to another technological field, nor do they improve the functioning of a computer or another technology. Nor do the claim limitations apply the judicial exception with, or by use of a particular machine. The claims do not effect a transformation or reduction of a particular article to a different state or thing. See MPEP 2106.05(c). None of the hardware in the claims "offers a meaningful limitation beyond generally linking 'the use of the [method] to a particular technological environment' that is, implementation via computers” such that the claim as a whole is more than a drafting effort designed to monopolize the exception. See MPEP 2106.05(e); Alice Corp. v. CLS Bank Int’l (citing Bilski v. Kappos, 561 U.S. 610, 611 (U.S. 2010)). Therefore, because the claims recite a judicial exception (an abstract idea) and do not integrate the judicial exception into a practical application, the claims are also directed to the judicial exception.
Furthermore, the added limitations do not direct the claim to significantly more than the abstract idea. No specific limitations are added which represent something other than what is well-understood, routine, and conventional activity in the field. See MPEP 2106.05(d). Accordingly, none of the dependent claims 2-9 and 11-14, individually, or as an ordered combination, are directed to patent eligible subject matter under 35 U.S.C. 101.
Please see MPEP §2106.05(d)(II) for a discussion of elements that the Courts have recognized as well-understood, routine, conventional, activity in particular fields.
Please see MPEP §2106 for examination guidelines regarding patent subject matter eligibility.
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 EMMETT K WALSH whose telephone number is (571)272-2624. The examiner can normally be reached Mon.-Fri. 6 a.m. - 4:45 p.m..
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/EMMETT K. WALSH/Primary Examiner, Art Unit 3628