DETAILED ACTION
Examiner acknowledges receipt of amendment to application 18/791,113 filed on June 11, 2026. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on June 11, 2026 has been entered.
Status of Claims
Claims 1-21 are still pending, with claims 1 and 12 being currently amended.
Response to Arguments
On page 9 of the remarks filed June 11, 2026, Applicant argues:
The cited references, whether considered individually or in combination, fail to teach or suggest the claimed smart-meter-based remote electric power transfer management architecture. The rejection is predicated on an overly generalized characterization of the references and relies on impermissible hindsight reconstruction using Applicant's disclosure as a roadmap. Moreover, the claims require an external electric vehicle charging device, which is not disclosed by Bridges or Chong, whether considered alone or in combination.
Examiner respectfully disagrees. In response to applicant's argument that the examiner's conclusion of obviousness is based upon improper hindsight reasoning, it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin, 443 F.2d 1392, 170 USPQ 209 (CCPA 1971).
On page 10 of the remarks filed June 11, 2026, Applicant argues:
The IPF module 134 fails to teach or suggest first and second hard-wire connectors coupling the IPF module 134 to the power source and the external electrical vehicle charging device, respectively, as claimed. Rather, in sharp contrast to the claimed embodiment, the IPF module 134 in Bridges is described as either installed within or connected to the electric resource 112 (such as an electric vehicle or a battery storage system). Bridges at 1 [0121]. Notably, the resource 112 may be connected to the power source, for example, through power cord 208 illustrated in FIG. 2. Bridges at 1 [0047]. However, the IPF module 134 connecting to the electric resource 112, which has been plugged into the power grid is not same as the smart meter device comprising a first and second connector directly connecting to the power grid.
Examiner respectfully disagrees. Examiner notes that “first and second hard-wire connectors” are not claimed. Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
On pages 10-11 of the remarks filed June 11, 2026, Applicant argues:
Indeed, the IPF module 134 in Bridges serves as an intelligent control system for managing power flow between electric resources (such as electric vehicles) and the grid. Bridges at 1 [0045]. It ensures efficient, optimized transfer of power by communicating directly with the electric resources, charge stations, and the central flow control server. Id. at I [0052]. The IPF module 134 can adjust the direction, amount, and timing of power transfer, enabling dynamic aggregation of multiple electric resources to meet grid demand while also monitoring power usage and providing safety measures during power transfer. Id. at [0052]-[0055].
As amended, independent claims 1 and 12 recite a particular architecture in which a smart meter device is positioned between a power source and an electric vehicle charging device and is configured to both: (i) receive remote commands via a wireless network for selectively controlling electric power transfer, and (ii) transmit charging-related data associated with authenticated charging sessions. The claims further recite that a smart meter control server verifies authentication credentials associated with a user account and, responsive to successful verification, transmits start and stop commands that cause the smart meter device to selectively initiate and terminate transfer of electric power from the power source to the electric vehicle. Neither Bridges nor Chong teaches or suggests this arrangement.
Bridges discloses a distributed power aggregation framework for electric resources connected to a power grid. Bridges at 1 [0001], Abstract. Bridges is directed to grid balancing, distributed resource aggregation, scheduling, and electric resource location management. Bridges at 11 [0003], [0147]-[0158]. For example, Bridges discusses scheduling aggregated electric resources according to constraints, determining charging locations using identifiers, and supporting billing operations associated with distributed electric resources. Bridges at " [0140]-[0158].
Examiner respectfully notes that there doesn’t appear to be any specific arguments about Bridges or Chong here besides some general characterizations of Bridges and a general allegation that Bridges and Chong fails to teach the claimed invention. Thus, Applicant's arguments fail to comply with 37 CFR 1.111(b) because they amount to a general allegation that the claims define a patentable invention without specifically pointing out how the language of the claims patentably distinguishes them from the references.
On page 11 of the remarks filed June 11, 2026, Applicant argues:
Bridges also fails to disclose the claimed remote smart meter control operations. The presently amended claims require that the smart meter device itself receives remote commands and selectively initiates or terminates transfer of electric power. Bridges instead discusses high-level aggregation and monitoring concepts associated with distributed electric resources. Bridges at Abstract, " [0140]-[0145], [0200]-[0204]. Even where Bridges discusses billing and monitoring operations, the cited portions merely describe tracking energy usage and integrating with smart meters. Bridges does not disclose the claimed authenticated remote-control workflow tied to smart-meter- controlled authorization of EV charging power transfer.
Examiner respectfully disagrees. Examiner notes that the IPF receives commands from the flow control server that “direct the remote IPF module 134 to adjust the flow of power into or out of the electric vehicle 200” (cited paragraph 135) and signals to control charging and discharging of the vehicle battery (par. 135). Furthermore, the IPF of Bridges is explicitly disclosed as transmitting “meter” data to an aggregation server and in turn receives commands to control the start and stopping of charging. For example:
[0045] In one implementation, each participating electric resource 112 or group of local resources has a corresponding remote intelligent power flow (IPF) module 134 (hereinafter, "remote IPF module" 134). The centralized flow control center 102 administers the power aggregation system 100 by communicating with the remote IPF modules 134 distributed peripherally among the electric resources 112. The remote IPF modules 134 perform several different functions, including providing the flow control center 102 with the statuses of remote resources; controlling the amount, direction, and timing of power being transferred into or out of a remote electric resource 112; provide metering of power being transferred into or out of a remote electric resource 112; providing safety measures during power transfer and changes of conditions in the power grid 114; logging activities; and providing self-contained control of power transfer and safety measures when communication with the flow control center 102 is interrupted. The remote IPF modules 134 will be described in greater detail below.
Directing a module to adjust power flow into or out of the vehicle and control charging or discharging comprises remote commands to initiate or terminate transfer of power.
On pages 11-12 of the remarks filed June 11, 2026, Applicant argues:
However, Chong does not disclose the claimed smart meter architecture recited in amended claims 1 and 12. Specifically, Chong does not disclose: a smart meter device coupled between the power source and an external electric vehicle charging device; a smart meter device configured to selectively initiate or terminate transfer of electric power responsive to remote commands received from a smart meter control server; a smart meter control server configured to verify authentication credentials against stored user account credentials to permit power transfer. Instead, Chong relies on relay activation and charger scheduling mechanisms. Although Chong mentions ammeters and electricity meters, those components are merely used for measuring electricity consumption. Chong at " [0113]-[0114], [0124]- [0125], [0133]. Chong nowhere teaches using a smart meter device as an authenticated intermediary control device positioned between a power source and EV charging device that selectively governs initiation and termination of power transfer based on authenticated user credentials.
Importantly, amended independent claims 1 and 12 now expressly require that the smart meter device selectively initiates and terminates transfer of electric power from the power source to the electric vehicle responsive to remotely transmitted commands. Neither reference teaches or suggests this functionality.
Examiner respectfully disagrees, nothing that the only argued feature relevant to Chong is regarding the authentication credentials. Chong explicitly teaches that authentication credentials are verified before permitting power transfer in figure 12, step 1202 (“User authenticated?”) which is required before Step 1204 (“Charging”).
With respect to Applicant’s argument about the express requirement “that the smart meter device selectively initiates and terminates transfer of electric power from the power source to the electric vehicle responsive to remotely transmitted commands”, Examiner notes that this feature has been addressed in the updated rejections below, specifically by the Bridges reference.
On page 12 of the remarks filed June 11, 2026, Applicant argues:
The Office Action also fails to provide an adequate articulated rationale explaining why a person of ordinary skill in the art would have modified the distributed resource aggregation framework of Bridges using Chong's charger relay scheduling system to arrive at Applicant's claimed architecture. Bridges and Chong solve materially different problems and operate at different architectural layers.
Bridges focuses on fleet-scale power aggregation and distributed energy management, whereas Chong focuses on charger reservation systems and relay-based load management within parking facilities. Neither reference recognizes the problem addressed by Applicant, namely authenticated remote smart-meter-mediated control of EV charging sessions tied to charging-session-specific metering and billing operations.
Examiner respectfully disagrees. The rationale is provided in the 103 rejections below. Bridges is modified by Chong to include the authentication functionality “for the purpose of ensuring that the right user gets the associated priority, as taught by Chong (par. 109)”. With respect to the application of the Bridges and Chong references specifically, Examiner notes that the MPEP defines analogous art as references from the “same field of endeavor as the claimed invention (even if it addresses a different problem); or (2) the reference is reasonably pertinent to the problem faced by the inventor (even if it is not in the same field of endeavor as the claimed invention)” (MPEP 2141.01(a)). Bridges and Chong both teach smart meters (meters connected to communication systems; Chong fig. 1A, 130; Bridges figs. 2 & 8; IPF 134/connection module 210/bridge 120), and thus are from the same field of endeavor.
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 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 1-21 are rejected under 35 U.S.C. 103 as being unpatentable over Bridges et al. US PGPUB 2008/0039979 in view of Chong et al. US PGPUB 2018/0111493, and further in view of Levy et al. US PGPUB 2012/0253567.
Regarding claims 1 and 12, Bridges discloses a system for remotely managing electric power transfer [fig. 1; managing power transfer via the flow control center 102], the system comprising:
a power source [fig. 1; grid 114 and power distribution 122];
an electric vehicle charging device configured to transfer electric power from the power source to an electric vehicle [fig. 8; inverter/charger 804 transfers power from the grid source to the vehicle’s battery system 202; pars 117-118]; and
a smart meter device coupled to the electric vehicle charging device on one end and the power source on another end, wherein the smart meter device is configured to transmit electrical charging data and receive remote commands, via a wireless network, for controlling the electric power being transferred by the electric vehicle charging device [figs. 2 & 8; IPF 134/connection module 210/bridge 120 function as a smart meter (note that though fig. 8 illustrates vehicle system 800 as part of the IPF, par. 117 indicates that the vehicle systems can be excluded “from being counted as components of the remote IPF module 134”), they are connected to the grid power 206 on one end (fig. 2) and the charging device 804 on the other end (fig. 8) and control charging/discharging of the vehicle battery, including by remote commands; pars. 45-50 & 135-140; furthermore, the connection module 210/bridge 120 could also be considered the smart meter, since it controls power flow via commands sent from the internet to the IPF 134 via the bridge 120; fig. 7 & 18; pars. 45, 80-82, & 214-215; the IPF “provid[es] the flow control center 102 with the statuses of remote resources; controlling the amount, direction, and timing of power being transferred into or out of a remote electric resource 112; provide metering of power being transferred into or out of a remote electric resource 112; providing safety measures during power transfer and changes of conditions in the power grid 114; logging activities”, meter information is aggregated at the central service “flow control center 102”) such that the flow control center can control electric resources 112 (vehicles) via connection manager 702 and IPFs 134 to control demand, provide power factor correction ((pars. 94-95 & 113-114)];
and a smart meter control server communicatively coupled to the smart meter device, wherein the smart meter control server is configured to receive user input transmitted via a mobile network [fig. 7, web interface 718 718; fig. 22; pars. 78, 85, 201 & 226-228; the power control interface can be displayed and controlled through a user’s mobile device such as a cell phone, the interface resides on flow control server 106 (fig. 7)]; and
wherein the smart meter control server is configured to remotely control the smart meter device by:
transmitting a start command to the smart meter device in response to receiving a first user command from the user, wherein the start command causes the smart meter device to initiate transfer of electric power from the power source to the electric vehicle; transmitting a stop command to the smart meter device in response to receiving a second user command the user, wherein the stop command causes the smart meter device to terminate transfer of electric power from the power source to the electric vehicle [pars. 78, 80-81, 85, 116-118, 201 & 226-228; commands enter into the user interface can be executed by electric resources 112 (EV batteries) via 134/120/210, the user can control the extent of the vehicle’s participation in power aggregation; thus, on the basis of the user’s preferences (“in response to”) start and stop commands initiating charging or stopping charging are issued (pars. 45-50 & 135-140) via the flow control server 106 via connection manager 702 (par. 80-82); par. 131 & 202, furthermore the user interface allows the user to “override current system behavior”].
Bridges does not explicitly disclose wherein the smart meter control server is configured to verify that the user input comprising authentication credentials received from a mobile device operated by a user matches user account credentials associated with the user to permit power transfer to the electric vehicle; and upon verifying that the authentication credentials match the user account credentials allowing power transfer.
However, Chong discloses an electric vehicle charging system with a smart meter [fig. 1A, current meter 130 attached to power controller 101] wherein the smart meter control server is configured to verify that the user input comprising authentication credentials received from a mobile device operated by a user matches user account credentials associated with the user to initiate transfer of electric power from the power source to the electric vehicle; and upon verifying that the authentication credentials match the user account credentials allowing power transfer [pars. 105-107, 118 & 125; fig. 10 & 12; a user is authenticated first (fig. 12, 1202) before power transfer is allowed (fig. 12, 1204); authentication is based on various credentials such as NFC tag, RFID chip, or license plate (pars. 105-107, 118 & 125].
It would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify Bridges to further include wherein the smart meter control server is configured to verify that the user input comprising authentication credentials received from a mobile device operated by a user matches user account credentials associated with the user to initiate transfer of electric power from the power source to the electric vehicle; and upon verifying that the authentication credentials match the user account credentials allowing power transfer for the purpose of ensuring that the right user gets the associated priority, as taught by Chong (par. 109).
Regarding claim 12, the method steps disclosed therein would have been obvious to one of ordinary skill based on the teachings of the prior art reference(s) applied above, since the prior art of record herein is construed as teaching or suggesting all of the elements recited in the method claim, as pointed out in the above rejection of claim 1. The claim is accordingly rejected.
The combination of Bridges and Chong does not explicitly disclose the electric vehicle charging device is external.
However, Levy discloses an electric vehicle charging system using smart meters wherein the electric vehicle charging device is external [figs. 1-2; vehicles 51, 54, 57 are charged by charge stations 50, 53 and 56, which are connected on one end to smart meters 49, 52, and 55 (pars. 28-29, the power meters are “smart” meters)].
It would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify Bridges to further include the electric vehicle charging device is external for the purpose of providing public charge stations which can be used by various vehicles, as taught by Levy (pars. 15-17) and since it has been held to be within the general skill of a worker in the art to apply a known technique to a known device (method, or product) which was ready for improvement in order to yield results predictable by one of ordinary skill the art. KSR International Co. v Teleflex Inc., 550 U.S. 398, 127 S. Ct. 1727, 82 USPQ2d 1385, 1395-97 (2007).
Regarding claims 2 and 13, Chong as applied in claims 1 and 12, respectively discloses wherein the user input comprises an NFC tag information transmitted by the mobile device operated by the user [pars. 105-107, 118 & 125].
Regarding claims 3 and 14, Chong as applied in claims 1 and 12, discloses wherein the user input comprises an RFID badge information transmitted by an RFID scanner [pars. 105-107, 118 & 125].
Regarding claims 4 and 15, Chong as applied in claims 1 and 12, discloses wherein the user input comprises license plate information transmitted by an LPR scanner [pars. 105-107, 118 & 125]
Regarding claims 5 and 16, Bridges discloses wherein the smart meter device is configured to communicate with a smart meter control server via a smart meter network [fig. 3; 134/120/210 communicate with 106 over network 104; par. 43, 49 & 77-81 & 138-144]
Regarding claims 6 and 17, Bridges discloses wherein the smart meter device comprises a measurement module and a communication module [fig. 8, communications components 812/120/822/820/818; measurement components 808/824/810/816; pars. 118-119 & 132-133 & 138-144].
Regarding claims 7 and 18, Bridges discloses wherein the measurement module of the smart meter device comprises a processor and a memory [fig. 8, 810/812; pars. 128-133, processor 810 and 816 executing a program (thus on memory) to meter power flow], the measurement module configured to collect and store voltage and current information associated with electric power transferred from the power source to the electric vehicle via the electric vehicle charging device [par. 132, power meter data including voltage/current (fig. 8, 808/824) can be stored for later transaction/communication (pars. 132-133); fig. 18].
Regarding claims 8 and 19, Bridges discloses wherein the communication module of the smart meter device is configured to transmit the voltage and the current information collected by the measurement module to the smart meter control server [par. 132, power meter data including voltage/current (fig. 8, 808/824) can be stored for later transaction/communication (pars. 132-133); fig. 18; fig. 17, steps 1710/1704 followed by 1706/1708; the remote IPF 134 can transmit metering information to the server (a control command)].
Regarding claims 9 and 20, Bridges discloses wherein the measurement module of the smart meter device generates a data record for the electric power transferred from the power source to the electric vehicle via the electric vehicle charging device, wherein the record is transmitted to the smart meter server by the communication module of the smart meter device [par. 132, power meter data including voltage/current (fig. 8, 808/824) can be stored for later transaction/communication (pars. 132-133); fig. 18; fig. 17, steps 1710/1704 followed by 1706/1708; the remote IPF 134 can transmit metering information to the server (a control command); fig. 8, 810/812; fig. 18, steps 1802/1804; pars. 84, 96, 118-119, 128-133 & 213-215; the server receives power meter data from communication modules of IPFs 134 and controls power distribution based on the data, which is stored in data 716 (par. 84)].
Regarding claims 10 and 21, Bridges discloses wherein the smart meter control server is configured to determine electric power consumption by the electric vehicle based on the data record for the electric power transferred to the electric vehicle transmitted by the communication module of the smart meter device [fig. 8, 810/812; fig. 18, steps 1802/1804; pars. 84, 96, 118-119, 128-133 & 213-215; the server receives power meter data from communication modules of IPFs 134 and controls power distribution based on the data, which is stored in data 716 (par. 84)].
Regarding claim 11, Bridges disclose wherein the smart meter control server determines a total cost for charging the electric vehicle based on the electric power consumption determination [par. 45, 84, 132 & 180; the meters energy flow in and out of the vehicle; pars. 140-144 & 169; the total amount of energy used is billed].
Conclusion
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/DAVID V HENZE/Primary Examiner, Art Unit 2859
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