Prosecution Insights
Last updated: April 19, 2026
Application No. 18/791,113

MANAGING ELECTRIC VEHICLE CHARGING THROUGH A SMART METER

Final Rejection §103
Filed
Jul 31, 2024
Examiner
HENZE, DAVID V
Art Unit
2859
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
San Diego Gas & Electric Company
OA Round
2 (Final)
70%
Grant Probability
Favorable
3-4
OA Rounds
2y 10m
To Grant
94%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
492 granted / 699 resolved
+2.4% vs TC avg
Strong +24% interview lift
Without
With
+23.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
49 currently pending
Career history
748
Total Applications
across all art units

Statute-Specific Performance

§101
2.0%
-38.0% vs TC avg
§103
49.8%
+9.8% vs TC avg
§102
21.8%
-18.2% vs TC avg
§112
19.1%
-20.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 699 resolved cases

Office Action

§103
DETAILED ACTION Examiner acknowledges receipt of amendment to application 18/791,113 filed on December 30, 2025. 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 Claims 1-21 are still pending. Response to Arguments On page 9 of the remarks filed December 30, 2025, Applicant argues: By contrast, none of the devices described in Bridges (e.g., an IPF module, a connection locality module, a bridge, or other powerline communicators (PLCs)) are configured to transmit electrical charging data and to control the electric power being transferred by the electric vehicle charging device (i.e., to begin or end charging) in response to receiving remote commands from a smart meter control server. Furthermore, none of the devices are connected to an electric vehicle charging device in a one-to-one configuration. Chong fails to these deficiencies of Bridges. First, an intelligent remote power flow (IPF) module 134 in Bridges is described as "distributed peripherally among the electric resources 112" (e.g., batteries of electric vehicles) Bridges at [0044] - [0045]. For example, as illustrated, in FIG. 2 (reproduced and annotated below), the IPF 134 is associated with a vehicle which is connected to the power grid via a power cord 208. In other words, IPF 134 is an integral component of the vehicle which communicates with the power grid via the location-specific connection locality module 210 and/or bridge 120. Examiner respectfully disagrees. As stated in response to similar arguments in the Non-Final rejection mailed September 26, 2024 and the Final Rejection mailed June 17, 2024 in the parent application 17/468,513 (continuation-in-part), hereinafter the Parent Non-Final and the Parent Final, the IPF of Bridges indeed transmits electrical charging data and controls the power being transferred by the charging device in response to remote commands. 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. Furthermore, each EV is indeed connected in a “one-to-one” configuration contrary to Applicant’s arguments. 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. Furthermore, in the Parent Non-Final and the Parent Final, Examiner has already the argument that the IPF is a part of the vehicle. To reiterate, Bridges states in paragraph 117: [0117] The illustrated example of a remote IPF module 134 is represented by an implementation suited for an electric vehicle 200. Thus, some vehicle systems 800 are included as part of the exemplary remote IPF module 134 for the sake of description. However, in other implementations, the remote IPF module 134 may exclude some or all of the vehicles systems 800 from being counted as components of the remote IPF module 134. Thus, Bridges explicitly allows for the IPF module 134 to be distinct from the vehicle 200. Even assuming, arguendo, that the IPF module 134 of Bridges is part of the vehicle, which Examiner does not concede, claim 1 recites only that the “smart meter device” is coupled to the electric vehicle charging device” and the power source, not that the smart meter device is external to the vehicle. On page 11 of the remarks filed December 30, 2025, Applicant argues: Next, powerline communicators (PLCs), such as those that include Ethernet-over powerline bridges 120, are implemented at connection locations so that the "last mile" of Internet communication with remote resources is implemented over the same wire that connects each electric resource 112 to the power grid 114. Bridges at [0043]. In essence, PLCs or bridges are devices used for communication over electrical power lines by enabling data transmission by modulating signals onto the electrical wiring in a building or infrastructure. By using the Ethernet-over powerline bridge 120, which intervenes between the receptacle 204 and the network access point so that the power cord 208 can also carry network communications between the electric vehicle 200 and the receptacle 204, allows to extend the local area network (LAN) using existing electrical wiring. Bridges at [0047]. In other words, the PLCs enable to create a network connection in areas where traditional wired or wireless connections may be difficult to establish. Examiner respectfully notes that while Applicant’s characterization of Bridges may or may not be correct, there does not appear to be any argument here. On page 11 of the remarks filed December 30, 2025, Applicant argues: Moreover, the bridge 120 in Bridges fails to control the electric charging device (i.e., to permit the electric vehicle charging device to start the electric power transfer or to prevent the electric vehicle charging device from the electric power transfer) in response to receiving remote commands from the smart meter control server, as claimed by the amended claims. In fact, Bridges explicitly describes that "[t]he vehicle computer 802 . . . controls the inverter/charger 804 to charge the vehicle's battery bank 202 or to discharge the battery bank 202 in upload to the grid 114." Bridges at [0135]. That is, Bridges relies on the internal component of the vehicle to control the charging rather than the smart meter connected to the charging device. Examiner notes that the argument regarding Bridges’ IPF being controlled to stop or start EV charging in response to remote commands has already been addressed above. As stated in paragraph [0045], the flow control center 102 administers a plurality of IPFs including “controlling the amount, direction, and timing of power being transferred into or out of a remote electric resource 112”, thus including starting and stopping of a flow. Furthermore, Examiner notes that Applicant states in the “amended claims”, however none of the claims appear to have been amended. With respect to Applicant’s argument that, the vehicle computer 802 of Bridges controls the charge/discharge of the vehicle battery, this argument does not contradict the above. In fact, Bridges explicitly states that the IPF, on instructions from the flow control center, communicates commands to the vehicle computer to execute the charges and discharges: [0135] Continuing with electric vehicles 200 as representative of electric resources 112, during periods when such an electric vehicle 200 is parked and connected to the grid 114, the remote IPF module 134 initiates a connection to the flow control server 106, registers itself, and waits for signals from the flow control server 106 that direct the remote IPF module 134 to adjust the flow of power into or out of the electric vehicle 200. These signals are communicated to the vehicle computer 802 via the data interface, which may be any suitable interface including the RS-232 interface 818 or the CANbus interface 820. The vehicle computer 802, following the signals received from the flow control server 106, controls the inverter/charger 804 to charge the vehicle's battery bank 202 or to discharge the battery bank 202 in upload to the grid 114. With respect to Applicant’s remarks about the locality module 210 acting as a network access point, Examiner notes that there does not appear to be any argument here. On page 12 of the remarks filed December 30, 2025, Applicant argues: Finally, a location-specific connection locality module 210 performs the function of network access point-in this case, the Internet access point. Id. Like the bridge 120 discussed above, the locality module 210 (e.g., by virtue of having another instance of a bridge 120') is used for communication over electrical power lines. Accordingly, the Ethernet-over powerline bridge 120 and location-specific connection locality module 210 fail to teach all features of the Smart Meter device which is 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 to receive remote commands, via a wireless network, for controlling the electric power being transferred by the electric vehicle charging device(i.e., to begin or end charging), as claimed by the amended claim 1. Chong fails to cure the noted deficiencies of Bridges. Examiner respectfully notes that there does not appear to be an argument here. Regardless of whether or not Applicant’s characterization of Bridges here is accurate, it is not clear how Applicant is differentiating the instant claims from that of Bridges. Examiner has demonstrated in the above response and in the below rejections that Bridges indeed teaches the claimed features, apart from those taught by the secondary reference Chong. 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. 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 permit the electric vehicle charging device to start the electric power transfer; 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 prevent the electric vehicle charging device from the electric power transfer [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)]. 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 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 [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 permit power transfer 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. 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 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 DAVID V HENZE whose telephone number is (571)272-3317. The examiner can normally be reached M to F, 9am to 7pm. 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, Julian Huffman can be reached at 571-272-2147. 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. /DAVID V HENZE/ Primary Examiner, Art Unit 2859
Read full office action

Prosecution Timeline

Jul 31, 2024
Application Filed
Sep 29, 2025
Non-Final Rejection — §103
Dec 30, 2025
Response Filed
Mar 25, 2026
Final Rejection — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
70%
Grant Probability
94%
With Interview (+23.8%)
2y 10m
Median Time to Grant
Moderate
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