Prosecution Insights
Last updated: July 17, 2026
Application No. 18/745,836

Robotic Fulfillment System Carton Release Logic

Non-Final OA §101§103
Filed
Jun 17, 2024
Priority
Jun 30, 2020 — continuation of 12/012,283
Examiner
MITCHELL, NATHAN A
Art Unit
3627
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Staples Inc.
OA Round
1 (Non-Final)
73%
Grant Probability
Favorable
1-2
OA Rounds
6m
Est. Remaining
83%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
699 granted / 959 resolved
+20.9% vs TC avg
Moderate +10% lift
Without
With
+10.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
17 currently pending
Career history
985
Total Applications
across all art units

Statute-Specific Performance

§101
9.1%
-30.9% vs TC avg
§103
72.1%
+32.1% vs TC avg
§102
8.1%
-31.9% vs TC avg
§112
5.0%
-35.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 959 resolved cases

Office Action

§101 §103
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 . 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 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Exemplary claims 1-13 recite: 1. (Currently Amended) A computer-implemented method comprising: determining, by one or more processors, a score for a first container of a set of containers based on one or more attributes of a first pick of one or more picks for the first container in a fulfillment center; assigning, by the one or more processors, the first container to one or more robotic transportation devices device based on the score determined for the first container, the one or more robotic transportation devices being adapted to transport one or more containers to an end point; and instructing, by the one or more processors, the one or more robotic transportation devices to transport the first container to the end point based on the score for the first container. 2. (New) The computer-implemented method of claim 1, further comprising: grouping, by the one or more processors, the set of containers into a first subset of containers and a second subset of containers based on a first set of available items for pick-to-cart equipment and a second set of available items for goods-to-person equipment in the fulfillment center, the pick-to-cart equipment including a first robotic transportation device adapted to transport a plurality of containers through a pick-to-cart area of the fulfillment center, the first container receiving the first pick in the pick-to-cart area; the goods-to-person equipment including a stationary location and a second robotic transportation device adapted to transport the second set of available items to the stationary location at which the one or more containers receive the second set of available items; and selecting, by the one or more processors, the first container based on the first set of available items and the second set of available items. 3. (New) The computer-implemented method of claim 1, wherein: determining the score for the first container is based on a previously assigned pick of a second container previously assigned to the one or more robotic transportation devices. 4. (New) The computer-implemented method of claim 1, further comprising: selecting, by the one or more processors, a finalization station from among multiple finalization stations based on a cut time for the first container and an availability of the finalization station; and instructing, by the one or more processors, the one or more robotic transportation devices to which the first container is assigned to navigate to the selected finalization station, the finalization station including the end point. 5. (New) The computer-implemented method of claim 4, further comprising: identifying, by the one or more processors, a plurality of workstations adapted to prepare the set of containers for the one or more picks in the fulfillment center; and configuring, by the one or more processors, a first workstation of the plurality of workstations to prepare containers of the set of containers that are within a threshold time of the cut time of the selected finalization station, the containers including shipping cartons. 6. (New) The computer-implemented method of claim 1, further comprising: determining, by the one or more processors, a first throughput ratio of an assigned workload and a throughput of pick-to-cart equipment in the fulfillment center; determining, by the one or more processors, a second throughput ratio of an assigned workload and a throughput of goods-to-person equipment in the fulfillment center, the one or more robotic transportation devices including the pick-to-cart equipment and the goods-to-person equipment; and inducting, by the one or more processors, the set of containers based on the first throughput ratio and the second throughput ratio, the set of containers including a set of shipping cartons. 7. (New) The computer-implemented method of claim 6, wherein inducting the set of containers includes: determining, by the one or more processors, a workload balance of the pick-to-cart equipment and the goods-to-person equipment; and configuring, by the one or more processors, one or more workstations to induct the set of containers based on the workload balance, the first throughput ratio, and the second throughput ratio. 8. (New) The computer-implemented method of claim 1, wherein inducting the set of containers includes: configuring, by the one or more processors, one or more workstations to induct the set of containers by prioritizing a mixture of tasks for a first robotic transportation device of the one or more robotic transportation devices, the mixture of tasks including visits by the first robotic transportation device to a pick-to-cart area and a goods-to-person station of the fulfillment center. 9. (New) The computer-implemented method of claim 1, further comprising: determining, by the one or more processors, a first workload of pick-to-cart equipment of the fulfillment center, the first workload including one or more picks for a second container; determining, by the one or more processors, a second workload of goods-to-person equipment of the fulfillment center, the one or more robotic transportation devices including the pick-to-cart equipment and the goods-to-person equipment; determining, by the one or more processors, that the second container of the set of containers is swappable from the pick-to-cart equipment to the goods-to-person equipment based on a priority status of the second container; and reassigning, by the one or more processors, the one or more picks of the second container from the pick-to-cart equipment to the goods-to-person equipment. 10. (New) The computer-implemented method of claim 1, wherein determining the score for the first container includes: determining a proximity of a first location of the first pick to a defined focus zone in a pick-to-cart area of the fulfillment center for a first robotic transportation device of the one or more robotic transportation devices. 11. (New) The computer-implemented method of claim 10, wherein: the one or more robotic transportation devices include multiple robotic transportation devices assigned to navigate through the pick-to-cart area of the fulfillment center, each of the multiple robotic transportation devices being assigned a focus point used to score containers for the respective robotic transportation device. 12. (New) The computer-implemented method of claim 1, wherein determining the score for the first container includes: determining a score for each of multiple picks of the first container, the score for the first container being based on the multiple scores for of the multiple picks. 13. (New) The computer-implemented method of claim 1, wherein determining the score for the first container includes: determining that a second pick of the first container is on a new path previously unassigned to a first robotic transportation device of the one or more robotic transportation devices. All claims recite subject matter falling within one of the four categories of invention (Step 1 YES) Claims 1-13, but for the underlined elements recite steps for managing an order picking process in a warehouse, which is a commercial interaction. Per MPEP 2106.04(a)(2) commercial interactions are a method of organizing human activity which is in abstract idea (Step 2A_1 YES). The additional elements correspond to: 1) computer implementation via one or more processors 2) instructing AGVs to transport. The computer-related limitations are recited at a high degree of generality such that they amount to mere instructions to implement an abstract, which per MPEP 2106.05(f) means they do not provide a practical application or significantly more. Regarding the instruction of AGV to transport, this is generally linking an exception to a particular technical environment, which per MPEP 2106.05(h) means it does not provide a practical application or significantly more. Additionally, transmitting tasks to autonomous vehicles would also not be significantly more because it is recognized as conventional (see MPEP 2106.05(d) and Vestal US 20140365258 A1 paragraphs 3 and 19). Based on the above the additional elements considered alone and in combination do not provide a practical application or significantly more (Step 2A_2 and Step 2B No) and are ineligible. Claims 14-20 mirror claims 1-7 and are considered ineligible for the same reasons. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim(s) 1, 3, 12-14, 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jarvis (US 20180096299 A1) in view of Singh (US 20210387805 A1) Regarding claim 1, Jarvis discloses a computer-implemented method comprising (paragraph 7 computer software on a computer-accessible medium): Assigning, by the one or more processors, the first container to one or more robotic transportation devices Instructing, by the one or more processors, the one or more robotic transportation devices to transport the first container to the end point (fig. 2, fig. 4A, paragraph 86) Jarvis fails to disclose: 1) Determining, by one or more processors, a score for a first container of a set of containers based on one or more attributes of a first pick of one or more picks for the first container in a fulfillment center; 2) containers being assigned and the robotic vehicles based instructed based on the score. However in an analogous art, Singh discloses: Determining, by one or more processors, a score for a first order of a set of orders based on one or more attributes of a first pick of one or more picks for the first order in a fulfillment center (paragraph 73 pick locations of all picks in the order including the location attribute of the first pick) and adding the order to a pick assignment based on the score (paragraph 74). It would have been obvious to one of ordinary skill in the art to combine this teaching with those of Jarvis. Jarvis teaches multiple order containers assigned to a cart. Singh teaches grouping orders based on attributes of the orders including pick locations. Combined the combination teaches assigning containers based on a score related to pick attributes and controlling the AGV based on the score. The motivation for the combination is improved picking efficiency (paragraph 13). Claim 3 is rejected based on the combination made for claim 1. In the rejection made for claim 1 the teachings incorporated from Singh assign subsequent orders to a cart based on determining a score relatively to what is already assigned. Regarding claim 12, Jarvis discloses a container associated with an order, but fails to disclose and Singh discloses determining a score for each of multiple picks of the order, the score for the container being based on multiple scores for multiple picks (paragraph 73). It would have been obvious to one of ordinary skill in the art to combine this teaching with those of Jarvis by assessing how much picks alter a route. The motivation for the combination is improved picking efficiency (paragraph 13). Regarding claim 13, Jarvis fails to disclose and Singh further discloses wherein determining the score for the first container includes: determining that a second pick of the first container is on a new path previously unassigned to a first robotic transportation device of the one or more robotic transportation devices (paragraph 73). It would have been obvious to one of ordinary skill in the art to combine this teaching with those of Jarvis by assessing how much new picks alter a route. The motivation for the combination is improved picking efficiency (paragraph 13). Claim 14 is rejected for the same reasons as claim 1 and see paragraph 116 of Jarvis regarding hardware/software details. Claim 16 is rejected for the same reasons as claim 3. Claim Status Claims 2, 4-11, 15, 17-20 are considered to distinguish over the cited art. Regarding claims 2 and 15, the prior art of record fails to disclose in combination with claims 1/14 grouping, by the one or more processors, the set of containers into a first subset of containers and a second subset of containers based on a first set of available items for pick-to-cart equipment and a second set of available items for goods-to-person equipment in the fulfillment center, the pick-to-cart equipment including a first robotic transportation device adapted to transport a plurality of containers through a pick-to-cart area of the fulfillment center, the first container receiving the first pick in the pick-to-cart area; the goods-to-person equipment including a stationary location and a second robotic transportation device adapted to transport the second set of available items to the stationary location at which the one or more containers receive the second set of available items; and selecting, by the one or more processors, the first container based on the first set of available items and the second set of available items. Regarding claims 4-5 and 17-18, the prior art of record fails to disclose in combination with claim 1/14, selecting, by the one or more processors, a finalization station from among multiple finalization stations based on a cut time for the first container and an availability of the finalization station; and instructing, by the one or more processors, the one or more robotic transportation devices to which the first container is assigned to navigate to the selected finalization station, the finalization station including the end point. Regarding claim 6-7 and 19-20, the prior art of record fails to disclose in combination with claim 1/14 determining, by the one or more processors, a first throughput ratio of an assigned workload and a throughput of pick-to-cart equipment in the fulfillment center; determining, by the one or more processors, a second throughput ratio of an assigned workload and a throughput of goods-to-person equipment in the fulfillment center, the one or more robotic transportation devices including the pick-to-cart equipment and the goods-to-person equipment; and inducting, by the one or more processors, the set of containers based on the first throughput ratio and the second throughput ratio, the set of containers including a set of shipping cartons. Regarding claim 8, the prior art of record fails to disclose in combination with claim 1 wherein inducting the set of containers includes:configuring, by the one or more processors, one or more workstations to induct the set of containers by prioritizing a mixture of tasks for a first robotic transportation device of the one or more robotic transportation devices, the mixture of tasks including visits by the first robotic transportation device to a pick-to-cart area and a goods-to-person station of the fulfillment center. Regarding claim 9, the prior art of record fails to disclose in combination with claim 1 determining, by the one or more processors, a first workload of pick-to-cart equipment of the fulfillment center, the first workload including one or more picks for a second container; determining, by the one or more processors, a second workload of goods-to-person equipment of the fulfillment center, the one or more robotic transportation devices including the pick-to-cart equipment and the goods-to-person equipment; determining, by the one or more processors, that the second container of the set of containers is swappable from the pick-to-cart equipment to the goods-to-person equipment based on a priority status of the second container; and reassigning, by the one or more processors, the one or more picks of the second container from the pick-to-cart equipment to the goods-to-person equipment. Regarding claims 10-11 the prior art of record fails to disclose in combination with claim 1 wherein determining the score for the first container includes: determining a proximity of a first location of the first pick to a defined focus zone in a pick-to-cart area of the fulfillment center for a first robotic transportation device of the one or more robotic transportation devices. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Shakes (US 7516848 B1) discloses grouping orders to increase pick density. Any inquiry concerning this communication or earlier communications from the examiner should be directed to NATHAN A MITCHELL whose telephone number is (571)270-3117. The examiner can normally be reached M-F 9-5. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Ryan Zeender can be reached at 571-272-6790. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /NATHAN A MITCHELL/Primary Examiner, Art Unit 3627
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Prosecution Timeline

Jun 17, 2024
Application Filed
Jun 10, 2025
Response after Non-Final Action
May 01, 2026
Non-Final Rejection mailed — §101, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
73%
Grant Probability
83%
With Interview (+10.0%)
2y 7m (~6m remaining)
Median Time to Grant
Low
PTA Risk
Based on 959 resolved cases by this examiner. Grant probability derived from career allowance rate.

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