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 .
Priority
Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 11/26/2024, 03/12/2025 & 09/05/2025 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
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 1–10 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without significantly more.
Representative Claim 1 recites: A method for determining a grounding resistance in a target area, the method comprising the following steps:
a) providing a grounding resistance surveillance system with a plurality of measurement devices configured for measuring a grounding resistance value and being arranged at different locations within the target area, and at least one gateway device, wherein each of the plurality of measurement devices is communicatively coupled to at least one further measurement device of the plurality of measurement devices, and wherein at least one measurement device of the plurality of measurement devices is in direct communication with the at least one gateway device and at least one measurement device of the plurality of measurement devices is only in indirect communication with the at least one gateway device such that a mesh network of coupled measurement devices is formed;
b) measuring a grounding resistance value by each of the plurality of measurement devices at a pre-determined time stored in a control module of the respective measurement device;
c) forwarding the measured grounding resistance values to the gateway device;
d) forwarding, by the gateway device, an updated pre-determined time to the plurality of measurement devices; and
e) repeating steps b) to d) at least once with the pre-determined time being the updated pre-determined time.
The claim limitations in the abstract idea have been highlighted in steps a-e above. The remaining limitations are treated as additional elements.
Step 1 – Statutory Category
Under Step 1 of the eligibility analysis, we determine whether the claims are directed to a statutory category by considering whether the claimed subject matter falls within one of the four statutory categories of patent eligible subject matter identified by 35 U.S.C. 101: process, machine, manufacture, or composition of matter. Claim 1 is directed to a process, which is a statutory category.
Step 2A Prong One – Judicial Exception
Under Step 2A Prong One, we determine whether the claim recites a judicial exception.
In Claim 1, the highlighted limitations constitute an abstract idea because, under a broadest reasonable interpretation, they recite limitations that fall within the abstract idea groupings identified in the 2019 Revised Patent Subject Matter Eligibility Guidance, including the following.
A. Mental processes (observation, evaluation, judgment). The steps of: measuring a grounding resistance value; forwarding the measured grounding resistance values; forwarding an updated pre-determined time; repeating the measurement process, which represent the collection, evaluation, and transmission of measurement information.
Under a broadest reasonable interpretation, these steps correspond to observing measurement values, transmitting the information, scheduling a next observation time, and repeating the process. Such activities can be performed mentally or using routine information processing techniques.
For example, a technician could manually measure grounding resistance values at various locations, record the results, transmit the results to a central location, schedule a next measurement time, and repeat the process.
B. Mathematical concepts and logical relationships
The steps involving updating a pre-determined time and repeating measurements represent a logical rule for scheduling and repeating measurement cycles. These steps correspond to a mathematical or logical relationship governing periodic data collection and scheduling. Such logical rules for repeated data collection represent abstract data processing operations.
C. Certain methods of organizing human activity
The claimed steps also correspond to organizing and managing measurement activities through scheduled monitoring and reporting. Collecting measurements at scheduled times, transmitting data through a network, updating a schedule, and repeating the monitoring cycle represent a routine data collection, aggregation, and scheduled reporting scheme.
Under a broadest reasonable interpretation, these limitations cover performance of the claimed method through observation, evaluation, scheduling, and reporting of measurement results, either mentally or through routine calculations.
Accordingly, Claim 1 recites a judicial exception.
Step 2A Prong Two – Practical Application
Under Step 2A Prong Two, we determine whether the claim recites additional elements that integrate the judicial exception into a practical application.
Claim 1 comprises the following additional elements:
A. providing a grounding resistance surveillance system comprising measurement devices and at least one gateway device
B. communicative coupling of measurement devices forming a mesh network
C. storing a pre-determined time in a control module
D. forwarding measured data to a gateway device
These elements represent generic data collection devices and communication infrastructure used to perform the abstract idea.
The measurement devices, gateway device, and control modules are recited at a high level of generality and are used merely as tools to gather and transmit measurement data and to automate the abstract idea.
These elements therefore constitute insignificant extra-solution activity, including:
• gathering measurement data
• transmitting measurement data
• storing scheduling information
• forwarding information through a network
According to the October 2019 Update on Subject Matter Eligibility, such steps are performed in order to gather or transmit data used in the abstract idea and therefore represent extra-solution activity that does not integrate the judicial exception into a practical application.
Furthermore, the claim does not recite:
• an improvement to computer functionality;
• an improvement to network communication technology;
• an improvement to sensor technology or grounding resistance measurement techniques; or
• a particular technological improvement to grounding resistance measurement hardware.
Instead, the claim merely applies generic measurement devices and communication components to automate the abstract idea of collecting and transmitting grounding resistance data. The recited mesh network configuration, gateway communication, confirmation messaging, batch data sending, and seismic sensor interruption merely represent conventional implementations of distributed sensor networks and IoT monitoring systems used to collect and transmit measurement data.
Accordingly, Claim 1 does not integrate the abstract idea into a practical application.
Therefore, Claim 1 is directed to a judicial exception and requires further analysis under Step 2B.
Step 2B – Significantly More
Under Step 2B, we determine whether the claim includes additional elements that amount to significantly more than the judicial exception.
Claim 1 does not include additional elements sufficient to amount to significantly more than the judicial exception because the additional elements are well-understood, routine, and conventional in the relevant art.
In particular, the use of measurement devices to measure grounding resistance values, gather measurement data, and transmit the measurement data to a remote processing system is conventional.
For example, Nishimoto et al. (U.S. 2024/0241273 A1) discloses a signal detection device including:
• detection equipment including a photoelectric conversion element configured to convert a photon as a detection target into a current signal;
• a current-voltage converter configured to convert the current signal into a voltage signal;
• a transmission unit configured to transmit the voltage signal; and
• a data collection unit configured to detect and collect the transmitted voltage signal.
Nishimoto therefore discloses a conventional sensing architecture in which a physical phenomenon is detected by a sensor element, converted into an electrical signal, transmitted through a communication unit, and collected by a receiving device for monitoring or processing.
Similar to the present claims, Nishimoto demonstrates that sensing a physical parameter, converting the sensed signal into another electrical representation, transmitting the signal, and collecting the transmitted data are well-understood, routine, and conventional activities in electronic monitoring and sensing systems.
The claimed grounding resistance measurement devices and gateway communication therefore represent the application of routine sensing hardware and communication components to automate the abstract idea of collecting and transmitting measurement data.
Accordingly, the additional elements, individually and as an ordered combination, amount to nothing more than implementing abstract data collection and reporting using conventional sensing devices and communication components.
Therefore, Claim 1 does not include significantly more than the judicial exception and is not patent eligible under 35 U.S.C. 101.
Dependent Claims 2–10 are rejected under 35 U.S.C. 101 for similar reasons. The dependent claims recite additional limitations that merely expand upon the abstract idea of collecting, transmitting, and scheduling grounding resistance measurements and do not add meaningful limitations that integrate the judicial exception into a practical application or amount to significantly more.
• Claims 2–3 recite sending measurement data to a central computation device and waiting until measurements from all devices are received before transmission. These limitations represent conventional data aggregation and transmission operations.
• Claim 4 recites defining a time interval between measurements, which represents a scheduling rule and is a logical relationship governing periodic data collection.
• Claim 5 recites forwarding confirmation messages when scheduling information is received, which represents routine communication acknowledgments in distributed network systems.
• Claim 6 recites detecting seismic activity using a seismic sensor and transmitting an alarm signal. This limitation merely collects additional environmental data and transmits a notification, which constitutes additional data gathering and reporting activity.
• Claims 7–9 recite a grounding resistance surveillance system comprising measurement devices and gateway devices configured to perform the abstract method. These elements merely automate the abstract idea using conventional distributed sensor network components.
• Claim 10 recites a measurement device for use in the surveillance system, which represents generic measurement hardware used to gather grounding resistance data.
These limitations do not add meaningful technical features beyond generic measurement devices, communication components, and routine data processing.
Accordingly, Claims 2–10 do not recite additional elements that integrate the judicial exception into a practical application or amount to significantly more, for substantially the same reasons discussed with respect to Claim 1.
Examiner’s Note: All claims 1–10 are rejected under 35 U.S.C. 101 as set forth above.
The examiner asserts that the IDS search reports filed on 11/26/2024, 03/12/2025, and 09/05/2025, including PE2E searches (see attached), provide Kim et al. (U.S. 2019/0219620 A1), Chan et al. (U.S. 2017/0160761 A1), and Browne et al. (U.S. 2009/0058433 A1) which cannot be applied to reject claims 1–10 under 35 U.S.C. 102 or 103 for the following reasons:
In the above related arts, Browne et al. (U.S. 2009/0058433 A1) discloses a fall-of-potential method of determining earth ground resistance which utilizes an earth ground tester and eliminates the need for removable ground stakes. Rather than utilizing a “far stake,” the method provides connection of the earth ground tester to telephone wires, and rather than utilizing a “near stake,” the method provides connection of the earth ground tester to a cable shield. Browne therefore discloses a grounding resistance measurement technique using electrical connections to existing infrastructure rather than physical ground stakes. However, Browne does not disclose a distributed grounding resistance surveillance system including a plurality of measurement devices arranged throughout a target area and communicating with at least one gateway device through a mesh network for periodic automated measurements.
Chan et al. (U.S. 2017/0160761 A1) discloses a power distribution unit and a fault detecting method applied in the power distribution unit. The power distribution unit includes an input terminal electrically coupled to positive and negative power lines, an insulation fault detection circuit configured to detect an insulation resistance value between a ground terminal and the positive or negative power line, and a processing circuit configured to output a warning signal according to the detected insulation resistance value. Chan therefore discloses detection of insulation resistance conditions in a power distribution environment. However, Chan does not disclose a grounding resistance surveillance system comprising multiple distributed measurement devices arranged within a target area and communicating through a mesh network to a gateway device for periodic monitoring and forwarding of grounding resistance measurements.
Kim et al. (U.S. 2019/0219620 A1) discloses monitoring electrical conditions within an electrical system and generating signals or warnings based on detected electrical parameters. Kim therefore demonstrates that monitoring of electrical characteristics and generating signals based on detected electrical conditions were known in the relevant field. However, Kim does not disclose a grounding resistance surveillance system in which a plurality of measurement devices distributed within a target area measure grounding resistance values at predetermined times, forward the measurements through a mesh communication network to a gateway device, and repeat the measurements according to an updated predetermined time schedule.
The differences between claims 1–10 and the above prior art references lie at least in the recited method and system for:
providing a grounding resistance surveillance system comprising a plurality of measurement devices distributed throughout a target area and communicatively coupled in a mesh network configuration;
measuring grounding resistance values at predetermined times stored in control modules of the measurement devices;
forwarding the measured grounding resistance values through the mesh network to at least one gateway device;
forwarding an updated predetermined time from the gateway device to the measurement devices; and
repeating the measurement process according to the updated predetermined time.
None of the above references, either alone or in combination, disclose or suggest the complete distributed monitoring architecture recited in the claims, including the mesh network communication between measurement devices and the periodic scheduling of measurements coordinated through a gateway device.
Accordingly, while the above references demonstrate known techniques for measuring grounding resistance or detecting electrical insulation faults, the references do not disclose the particular distributed surveillance system and automated measurement scheduling architecture recited in claims 1–10. Therefore, the references identified in the IDS search reports and PE2E searches cannot presently be applied to reject claims 1–10 under 35 U.S.C. 102 or 35 U.S.C. 103.
However, as discussed in the rejection above, the claims remain directed to an abstract idea implemented using conventional measurement devices and communication components, and therefore claims 1–10 are rejected under 35 U.S.C. 101.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to TRUNG NGUYEN whose telephone number is (571)272-1966. The examiner can normally be reached on Mon- Friday 8AM - 4:00PM Eastern Time. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Huy Phan can be reached on 571-272-7924. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
Examiner: /Trung Q. Nguyen/- Art 2858
March 4, 2026
/HUY Q PHAN/Supervisory Patent Examiner, Art Unit 2858