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 .
Response to Amendment
The amendment filed on 6/5/2026 has been entered. Claims 1 and 3-7 remain pending in the present application. Though the applicant has amended the claims to include previously identified allowable subject matter, the claims still have an outstanding 35 U.S.C. 101 rejection that must be resolved.
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 and 3-7 are rejected under 35 U.S.C. 101 because the claimed invention is directed towards an abstract idea without significantly more. Claim 1 recites, “a computer configured to specify a sheet metal processing machine as a notification destination of a state of the abnormality, from the plurality of sheet metal processing machines when the abnormality detection sensor detects the abnormality;” and “specify, when the abnormality detection sensor detects the abnormality, the sheet metal processing machine as the notification destination of the state of the abnormality, according to the current position information of the host-vehicle, the information on the plurality of sheet metal processing machines stored in the processing machine information memory , or the travel information stored in the travel information memory.”, which analyzed under Step 2A Prong One, includes limitations of simply specifying a destination for a notification which is an act that can reasonably be performed in the human mind/with pen and paper and thus, falls within the, “Mental Processes” grouping of abstract ideas.
This judicial exception is not integrated into a practical application. For instance, claim 1 further recites, “wirelessly transmits information for notifying the state of the abnormality, to the sheet metal processing machine as the notification destination specified by the computer.”, which analyzed under Step 2A Prong One, includes limitations of simply providing a notification to a machine without positively reciting a corresponding action in response and thus just merely applies the use of the judicial exception (see MPEP 2106.05(f)). Claim 1 additionally recites, “an abnormality detection sensor for detecting an abnormality that has occurred while the automated guided vehicle is traveling;” and “a travel information memory for storing travel information including position information of a starting point and position information of a destination point in relation to traveling,”, and “acquire, using a LiDAR technique, current position information of a host-vehicle”, which analyzed under Step 2A Prong Two, adds insignificant extra solution activity in the form of mere data gathering (see MPEP 2106.05(g)). Also, the limitations of, “An automated guided vehicle traveling in a sheet metal processing facility in which a plurality of sheet metal processing machines are installed,” and “a processing machine information memory for storing information on the plurality of sheet metal processing machines;”, which analyzed under Step 2A Prong Two, just generally links the use of the judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)). Finally, the limitations of, “a computer”, as generally recited merely represents generic computer components for implementing the abstract idea. Finally, the limitation of “a computer”, as generally recited represents merely generic computer components for implementing the abstract idea.
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because as analyzed under Step 2B, the additional elements merely amount to gathering abnormality data from sheet metal machines and sending the data over a network. Analyzed under Berkheimer, the act of gathering and sending data over a network has been deemed as well-understood, routine, and conventional by the courts (see MPEP 2106.05(d)(II), “sending/receiving data over a network”).
Independent claim 7 is substantially similar to claim 1 and is thus rejected using the same rationale.
Dependent claims 3-6 are rejected under 35 U.S.C. 101 because the claimed invention is directed towards an abstract idea without significantly more. Claim 6 includes all limitations of claim 1, which analyzed under Step 2A Prong One, include limitations which can reasonably be performed in the human mind/with pen and paper which falls within the, “Mental Processes” grouping of abstract ideas.
This judicial exception is not integrated into a practical application. Claim 5 includes additional limitations of providing a notification to a specified machine, which analyzed under Step 2A Prong Two, just merely applies the use of the judicial exception (see MPEP 2106.05(f)). And finally, claims 3-4 and 6, each describe conditions that can determine which machine is targeted for notification or describes various physical aspects of the system, which analyzed under Step 2A Prong Two, just generally links the use of the judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)).
The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception because as analyzed under Step 2B, the additional elements merely amount to gathering abnormality data from sheet metal machines and sending the data over a network. Analyzed under Berkheimer, the act of gathering and sending data over a network has been deemed as well-understood, routine, and conventional by the courts (see MPEP 2106.05(d)(II), “sending/receiving data over a network”).
Allowable Subject Matter
The office would first like to state that the identified claims are currently rejected under 35 U.S.C. 101 rejection that must be resolved prior to consideration of allowance.
The following is a statement of reasons for the indication of allowable subject matter:
The independent claims have been amended to include the following limitations, “a processing machine information memory for storing information on the plurality of sheet metal processing machines; and
a travel information memory for storing travel information including position information of a starting point and position information of a destination point in relation to traveling, wherein
the computer is further configured to:
acquire using a LiDAR technique, current position information of a host-vehicle, and
specify, when the abnormality detection sensor detects the abnormality, the sheet metal processing machine as the notification destination of the state of the abnormality, according to the current position information of the host-vehicle, the information on the plurality of sheet metal processing machines stored in the processing machine information memory , or the travel information stored in the travel information memory.”
The closest prior art of record is Ikawa (US PGPUB 20190243374). Ikawa disclose an autonomous carrier/vehicle system and method for monitoring a plurality of carriers/vehicles using onboard sensors which can identify any abnormal or error conditions. These readings are sent to a host system for analysis which can then determine a position location of the information from a transmitting carrier/vehicle, update a map according to the identified abnormal condition, and subsequently provide the information to all other carriers/vehicles such that operation commands can be initiated in order to account for the abnormal condition. However, Ikawa as well as all other cited prior art of record are silent on, “a processing machine information memory for storing information on the plurality of sheet metal processing machines; and
a travel information memory for storing travel information including position information of a starting point and position information of a destination point in relation to traveling, wherein
the computer is further configured to:
acquire using a LiDAR technique, current position information of a host-vehicle, and
specify, when the abnormality detection sensor detects the abnormality, the sheet metal processing machine as the notification destination of the state of the abnormality, according to the current position information of the host-vehicle, the information on the plurality of sheet metal processing machines stored in the processing machine information memory , or the travel information stored in the travel information memory.”
Response to Arguments
Applicant's arguments filed 6/5/2026 with respect to the 35 U.S.C. 101 rejection have been fully considered but they are not persuasive.
Applicant argues, see pages 6-9, that the present application is not directed towards the “Mental Processes” grouping of abstract ideas because the newly amended claims require an abnormality sensor and computer to perform every function which cannot be performed in the human mind and further, the use of using a LiDAR to gather information of the location of the vehicle also involves processes that is impossible for a human to perform mentally. Further, the applicant argues that the even assuming arguendo that the present application is directed towards an abstract idea, the invention is sufficiently integrated into a practical application as detailed by several paragraphs listed in the arguments and remarks.
The office respectfully disagrees.
With respect to the first argument, just because the claimed function is performed utilizing a computer/sensor, does not necessarily constitute that the claimed invention is not directed towards an abstract idea as detailed in MPEP 2106.04(a)(2)(III)(D) as shown below:
“C. A Claim That Requires a Computer May Still Recite a Mental Process[AltContent: rect]
Claims can recite a mental process even if they are claimed as being performed on a computer. The Supreme Court recognized this in Benson, determining that a mathematical algorithm for converting binary coded decimal to pure binary within a computer’s shift register was an abstract idea. The Court concluded that the algorithm could be performed purely mentally even though the claimed procedures "can be carried out in existing computers long in use, no new machinery being necessary." 409 U.S at 67, 175 USPQ at 675. See also Mortgage Grader, 811 F.3d at 1324, 117 USPQ2d at 1699 (concluding that concept of "anonymous loan shopping" recited in a computer system claim is an abstract idea because it could be "performed by humans without a computer"). [AltContent: rect]
In evaluating whether a claim that requires a computer recites a mental process, examiners should carefully consider the broadest reasonable interpretation of the claim in light of the specification. For instance, examiners should review the specification to determine if the claimed invention is described as a concept that is performed in the human mind and applicant is merely claiming that concept performed 1) on a generic computer, or 2) in a computer environment, or 3) is merely using a computer as a tool to perform the concept. In these situations, the claim is considered to recite a mental process. [AltContent: rect]
1. Performing a mental process on a generic computer. An example of a case identifying a mental process performed on a generic computer as an abstract idea is Voter Verified, Inc. v. Election Systems & Software, LLC, 887 F.3d 1376, 1385, 126 USPQ2d 1498, 1504 (Fed. Cir. 2018). In this case, the Federal Circuit relied upon the specification in explaining that the claimed steps of voting, verifying the vote, and submitting the vote for tabulation are "human cognitive actions" that humans have performed for hundreds of years. The claims therefore recited an abstract idea, despite the fact that the claimed voting steps were performed on a computer. 887 F.3d at 1385, 126 USPQ2d at 1504. Another example is Versata, in which the patentee claimed a system and method for determining a price of a product offered to a purchasing organization that was implemented using general purpose computer hardware. 793 F.3d at 1312-13, 1331, 115 USPQ2d at 1685, 1699. The Federal Circuit acknowledged that the claims were performed on a generic computer, but still described the claims as "directed to the abstract idea of determining a price, using organizational and product group hierarchies, in the same way that the claims in Alice were directed to the abstract idea of intermediated settlement, and the claims in Bilski were directed to the abstract idea of risk hedging." 793 F.3d at 1333; 115 USPQ2d at 1700-01. [AltContent: rect]
2. Performing a mental process in a computer environment. An example of a case identifying a mental process performed in a computer environment as an abstract idea is Symantec Corp., 838 F.3d at 1316-18, 120 USPQ2d at 1360. In this case, the Federal Circuit relied upon the specification when explaining that the claimed electronic post office, which recited limitations describing how the system would receive, screen and distribute email on a computer network, was analogous to how a person decides whether to read or dispose of a particular piece of mail and that "with the exception of generic computer-implemented steps, there is nothing in the claims themselves that foreclose them from being performed by a human, mentally or with pen and paper". 838 F.3d at 1318, 120 USPQ2d at 1360. Another example is FairWarning IP, LLC v. Iatric Sys., Inc., 839 F.3d 1089, 120 USPQ2d 1293 (Fed. Cir. 2016). The patentee in FairWarning claimed a system and method of detecting fraud and/or misuse in a computer environment, in which information regarding accesses of a patient’s personal health information was analyzed according to one of several rules (i.e., related to accesses in excess of a specific volume, accesses during a pre-determined time interval, or accesses by a specific user) to determine if the activity indicates improper access. 839 F.3d. at 1092, 120 USPQ2d at 1294. The court determined that these claims were directed to a mental process of detecting misuse, and that the claimed rules here were "the same questions (though perhaps phrased with different words) that humans in analogous situations detecting fraud have asked for decades, if not centuries." 839 F.3d. at 1094-95, 120 USPQ2d at 1296. [AltContent: rect]
3. Using a computer as a tool to perform a mental process. An example of a case in which a computer was used as a tool to perform a mental process is Mortgage Grader, 811 F.3d. at 1324, 117 USPQ2d at 1699. The patentee in Mortgage Grader claimed a computer-implemented system for enabling borrowers to anonymously shop for loan packages offered by a plurality of lenders, comprising a database that stores loan package data from the lenders, and a computer system providing an interface and a grading module. The interface prompts a borrower to enter personal information, which the grading module uses to calculate the borrower’s credit grading, and allows the borrower to identify and compare loan packages in the database using the credit grading. 811 F.3d. at 1318, 117 USPQ2d at 1695. The Federal Circuit determined that these claims were directed to the concept of "anonymous loan shopping", which was a concept that could be "performed by humans without a computer." 811 F.3d. at 1324, 117 USPQ2d at 1699. Another example is Berkheimer v. HP, Inc., 881 F.3d 1360, 125 USPQ2d 1649 (Fed. Cir. 2018), in which the patentee claimed methods for parsing and evaluating data using a computer processing system. The Federal Circuit determined that these claims were directed to mental processes of parsing and comparing data, because the steps were recited at a high level of generality and merely used computers as a tool to perform the processes. 881 F.3d at 1366, 125 USPQ2d at 1652-53. [AltContent: rect]
In the present application, we have two limitations that must be considered for a potential mental process in, “a computer configured to specify a sheet metal processing machine as a notification destination of a state of the abnormality, from the plurality of sheet metal processing machines when the abnormality detection sensor detects the abnormality;” and “specify, when the abnormality detection sensor detects the abnormality, the sheet metal processing machine as the notification destination of the state of the abnormality, according to the current position information of the host-vehicle, the information on the plurality of sheet metal processing machines stored in the processing machine information memory , or the travel information stored in the travel information memory.”.
The first limitation simply uses a computer to “specify”, which can be analogized to picking or selecting, a specific sheet metal machine from a plurality of machines based on data detected by a sensor. It is more than reasonable to provide gathered data from the sensor to a human to view and understand which machine information to be sent to and as such, the office maintains that this limitation is directed towards an abstract idea. Further, the second limitation, in the same vain as the first limitation, performs a similar function using specific gathered information, which again, a user can reasonably be provided any of this data and make a determination as to which machine should receive a notification. As such, based on this analysis, the independent claims are directed towards an abstract idea despite a computer performing the listed functionality.
Finally, the office agrees that a human cannot reasonably, “acquire using a LiDAR technique, current position information of a host-vehicle”, as this is a specific piece of technology using advanced features to determine specific data as identified by the applicant. However, the office does not argue that this limitation is an abstract idea, however, this limitation represents using a specialized sensor for gathering data, which falls under Step 2A Prong Two, as adding insignificant extra solution activity in the form of mere data gathering (see MPEP 2106.05(g)).
With respect to the second argument, the office must consider the guidance provided in MPEP 2106.04(d)(1) which states:
A claim reciting a judicial exception is not directed to the judicial exception if it also recites additional elements demonstrating that the claim as a whole integrates the exception into a practical application. One way to demonstrate such integration is when the claimed invention improves the functioning of a computer or improves another technology or technical field. The application or use of the judicial exception in this manner meaningfully limits the claim by going beyond generally linking the use of the judicial exception to a particular technological environment, and thus transforms a claim into patent-eligible subject matter. Such claims are eligible at Step 2A because they are not "directed to" the recited judicial exception. [AltContent: rect]
The courts have not provided an explicit test for this consideration, but have instead illustrated how it is evaluated in numerous decisions. These decisions, and a detailed explanation of how examiners should evaluate this consideration are provided in MPEP § 2106.05(a). In short, first the specification should be evaluated to determine if the disclosure provides sufficient details such that one of ordinary skill in the art would recognize the claimed invention as providing an improvement. The specification need not explicitly set forth the improvement, but it must describe the invention such that the improvement would be apparent to one of ordinary skill in the art. Conversely, if the specification explicitly sets forth an improvement but in a conclusory manner (i.e., a bare assertion of an improvement without the detail necessary to be apparent to a person of ordinary skill in the art), the examiner should not determine the claim improves technology. Second, if the specification sets forth an improvement in technology, the claim must be evaluated to ensure that the claim itself reflects the disclosed improvement. That is, the claim includes the components or steps of the invention that provide the improvement described in the specification. The claim itself does not need to explicitly recite the improvement described in the specification (e.g., "thereby increasing the bandwidth of the channel").[AltContent: rect]
Based on the provided support paragraphs in the arguments and remarks, paragraph [0010] of the filed specification provides the closest support as reproduced below: “One aspect of the present disclosure provides an automated guided vehicle, a conveying system, and an abnormality notification method of an automated guided vehicle, which, when an abnormality occurs in an automated guided vehicle traveling in a sheet metal processing facility and the automated guided vehicle stops, are capable of notifying a worker in the sheet metal processing facility of the abnormal state quickly and with high accuracy.”
However, based on the provided statement, this provides more of a conclusory statement on improvement rather than how the limitations combine to provide the stated improvement. The office believes an improvement is being made but the claims do not accurately reflect that in their current form. For instance, the claims currently only provide a specification as to which machine a notification should be sent to without actually performing any subsequent action to send the notification to the machine such that an operator can see it. Even so, that would still only merely apply the judicial exception in the present case as merely displaying information just generally applies the use of the judicial exception (see MPEP 2106.05(f)). The claims require additional support beyond just providing the notification such that additional actions are taken to correct the issue and possible control of the vehicle is performed based on the detected problems. Combining all of these elements would more sufficiently detail the improvement and help show that the present application is integrating the judicial exception into a practical application.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Matsuda (US PGPUB 20240402716): disclose work support system for providing automatic guidance of an autonomous work vehicle within a facility.
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.
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/CHRISTOPHER W CARTER/Examiner, Art Unit 2117
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