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 1-8 are rejected under 35 U.S.C. 101 because the claimed invention is directed to abstract idea without significantly more.
Claim 1 recites:
An indoor optical wireless communications-oriented general geometry-based stochastic channel modeling method, wherein the method comprises the following steps performed by a processor:
Step S1: establishing an indoor optical wireless communication channel simulation scenario for modeling propagation of optical wireless signals in a three-dimensional indoor environment, and setting simulation scenario layout and frequency band parameters corresponding to physical characteristics of the indoor environment and a selected optical frequency band;
Step S2: generating an object reflection cluster birth-death process matrix of a transmitting-end array, a random number matrix for controlling whether a direct component exists, and a random number matrix for propagation component classification based on physical propagation conditions of the indoor environment;
Step S3: initializing an object reflection cluster, a particle scattering cluster and intra-cluster scatterers in a global coordinate system defined by the indoor optical wireless communication channel simulation scenario;
Step S4: updating and calculating model parameters varying with space and time for each propagation ray based on movement of the receiver and changes in the indoor environment;
Step S5: calculating a light source radiation intensity, an object reflection power distribution, a particle scattering power distribution, and a wavelength range-related equivalent reflection coefficient; and
Step S6: calculating an impulse response of each subchannel, and determining whether a direct component of the subchannel exists and whether an indirect component of object reflection exists, to obtain a final channel impulse response for the indoor optical wireless communication channel.
Analysis
The following analysis follows the flow chart of MPEP 2106(III).
Step 1: statutory category — Yes
The claim claims a method and includes at least one step; therefore, it falls within one of the four statutory categories.
Step 2A prong one: judicial exceptions — Yes
The claim is directed to an abstract idea. Steps S1, S2, S3, S4, S5 and S6 of the claim are directed to abstract ideas because the limitations can be performed in a human mind, or by a human using a pen and paper.
Step 2A prong two: additional elements that integrate the judicial exception into a practical application. — No
The claim does not contain any additional elements that integrate the judicial exception into a practical application.
Claim 1 recites in lines 22-23 “to obtain a final channel impulse response for the indoor optical wireless communication channel”. However, the claim fails to include limitations that relate or incorporate the impulse response to a real application.
Conclusion: Claim 1 is not eligible subject matter under 35 USC §101.
Dependent claims 2-8:
Claim 2 further refines the step of S1. The Examiner notes that a simulation is not a real scenario; it is a mathematical model. For example, the LED recited in claim 2 is not a real LED but a mathematical model of an LED characterized by its parameters. Therefore, claim 2 does not contain any further limitations that render the claim to be patent eligible.
Similarly, claim 3 further refines step S102 of claim 2; claim 4 further refines step S2; claim 5 further refines step of S3; claim 6 further refines S4; claim 7 further refines step S5; claim 8 further refines S6. These claims either introduce additional parameters of the model or define formulas for calculation results for the model. The model is finally represented by a final channel impulse response which is an abstract idea.
Therefore, claims 2-8 are ineligible under 35 USC §101.
Response to Arguments
Applicant's arguments filed 16 September 2026 have been fully considered but they are not persuasive.
The Applicant argues:
A. The Claims Do Not Recite a Mental Process
The Examiner asserts that the claimed steps "can be performed in a human mind, or by a human using a pen and paper." Applicant respectfully submits that this conclusion is incorrect under current USPTO guidance.
The August 2025 USPTO Memorandum expressly reminds the Examiners that the "mental process" grouping should not be expanded "in a manner that encompasses claim limitations that cannot practically be performed in the human mind". The Memorandum further states that "a claim does not recite a mental process when it contains limitation(s) that cannot practically be performed in the human mind, for instance when the human mind is not equipped to perform the claim limitation(s)".
The present claims require, among other things:
Establishing a three-dimensional global coordinate system for an indoor optical wireless communication scenario, including an LED array transmitter and a photodetector receiver, with the first-row first-column LED cell defining an x- axis (Step S1);
Generating a birth-death process matrix for object reflection clusters across the entire transmitting-end array, involving horizontal and vertical column evolution with
survival probabilities governed by exponential distributions (Step S2);
Initializing particle scattering clusters and intra-cluster scatterers according to three-dimensional elliptical Gaussian distributions (Step S3);
Updating model parameters varying with space and time, including angle parameters of departure and arrival for each propagation ray in local coordinate systems of each LED cell (Step S4);
Calculating particle scattering phase functions combining Rayleigh and Mie scattering components with wavelength-dependent model parameters (Step S5); and
Calculating channel impulse responses incorporating the combined effects of object reflection, particle scattering, and particle extinction (Step S6).
These steps involve simultaneous computation of coupled physical quantities across a multi-dimensional parameter space. For a typical indoor LED array (e.g., M_I x M_J LED cells), each with N_c, object reflection clusters, each cluster containing M_n scatterers, and each scatterer having time-varying position coordinates, the total computational burden involves thousands to millions of interdependent variables that must be updated at each time step. The human mind-even with pen and paper-is not equipped to perform such calculations within any reasonable timeframe.
The August 2025 Memorandum emphasizes that "claim limitations that encompass Al in a way that cannot practically be performed in the human mind do not fall within this grouping". By analogy, the complex, multi-variable, time-dependent physical modeling recited in the present claims likewise cannot practically be performed in the human mind.
The argument is not persuasive. The August 2025 USPTO Memorandum states: “claims do not recite a mental process when they contain limitations that cannot practically be performed in the human mind, for instance when the human mind is not equipped to perform the claim limitations.” In other words, it is the required capability of a step of the process rather than the complexity of the abstract idea of the process that determines whether a process can practically be performed in the human mind or not. Furthermore, MPEP 2106.04(a)(2)IIIC3 explains that a human can use a computer as a tool to perform a mental process and the process still falls into the category of abstract ideas. Since the claim fails to recite any limitations that differentiate the processor, as recited in claim 1, from a general-purpose computer, the claim is still considered to fall into the category of abstract ideas. The mathematical formulas recited in the dependent claims are abstract ideas under MPEP 2106.04(a)(2)I. Therefore, claim 1 and its dependent claims fall into the category of abstract ideas.
The Applicant continues to argue:
B. The Claims Recite More Than a Mathematical Concept
The Examiner's characterization of the claims as mere "mathematical calculations" overlooks the fact that the claims are directed to modeling physical propagation phenomena in a specific technical environment. Under the August 2025 Memorandum, "claims that merely involve an exception" are eligible and do not require further analysis.
The present claims recite specific physical modeling steps that go beyond abstract mathematical relationships:
Step S101 defines a global coordinate system based on physical hardware (LED array and photodetector) and the physical geometry of the indoor environment;
Step S201 models cluster birth-death processes that reflect the physical reality of
obstruction and visibility changes as signals propagate across an LED array;
Step S302 calculates equivalent normal directions and mirror reflection directions according to geometric relationships between physical objects;
Step S303 generates particle scattering clusters representing the physical scattering effect of ultraviolet light signals; and
Step S502-S503 apply Phong's reflection model and particle scattering phase functions that are physically grounded in the optical properties of materials and particles.
These limitations are not mere mathematical relationships; they are physical modeling constraints that limit the claimed method to a specific practical implementation for indoor optical wireless channel modeling.
(Step 2A, Prong Two)
The Specific Technological Problem:
Prior to the present invention, there existed no unified channel model capable of supporting all optical wireless frequency bands (infrared, visible, and ultraviolet) in indoor scenarios. As stated in the specification, existing models (focus on single frequency bands), and the few (general models only support outdoor non-line-of-sight scattering scenarios). No indoor general channel model supporting the full optical band had been proposed.
The Claim Limitations That Solve This Problem:
The present claims solve this problem through a parameterized unified framework that can be reduced to band-specific models by setting appropriate parameters:
Step S103 recites frequency band parameters including particle extinction coefficient k_e, particle Rayleigh scattering coefficient k_sr, particle Mie scattering coefficient k_sm, and the probability P_particle of particle scattering;
Step S5 recites calculations that incorporate these band-specific parameters into the power distributions; and
Step S6 recites how the model reduces to infrared/visible light models when k_e = 0 and P_particle = 0 (for IR/visible) or to ultraviolet models when these parameters
are non-zero.
The Abstract Idea Alone Does Not Solve This Problem:
The abstract idea of "mathematical calculations"—standing alone—cannot solve the problem of providing a unified indoor optical wireless channel model. The abstract idea provides no mechanism for parameterizing the model across different frequency bands, no framework for integrating object reflection and particle scattering, and no methodology for dynamically updating model parameters as the receiver moves.
The Claim as a Whole Does Solve The Problem:
The combination of the abstract calculations with the specific claim limitations-including the frequency band parameterization (S 103), the particle scattering model (S503), the equivalent reflection coefficient calculation (S504), and the impulse response determination (S6)-does solve the technological problem. The claimed method produces a final channel impulse response that is band-adaptive and scenario-specific, enabling simulation and performance evaluation of 6G indoor optical wireless communication systems across the full optical spectrum.
The argument is not persuasive. MPEP 2106.04(a)(2)IA cites examples where mathematical relationships are used to relate physical parameters such as reaction rate and temperature—Diamond v. Diehr; 450 U.S. at 178 n. 2, 179 n.5, 191-92, 209 USPQ at 4-5 (1981). That is, regardless of whether the numerical values involved in the mathematical calculation have physical meaning or not, the mathematical relationship is considered as abstract ideas. Please keep in mind that the exclusion of mathematical concepts from patent eligibility does not mean that mathematical concepts are not important or not useful.
The Applicant further argues:
C. The Examiner's Characterization of the LED as "Not a Real LED" Is Legally Irrelevant
The Examiner states that "the LED recited in claim 2 is not a real LED but a mathematical model of a LED characterized by its parameters." Applicant respectfully submits that this analysis is legally flawed.
Under the broadest reasonable interpretation, the claimed LED array and photodetector are physical components that are being modeled. The method claims are directed to modeling the propagation of physical signals between physical devices in a physical environment. The fact that the modeling process involves mathematical representations does not render the claimed method abstract-otherwise, all computer-implemented simulations of physical systems would be patent- ineligible.
The argument is not persuasive. The Examiner makes the comment to indicate that even though the claim recites an LED, it is the mathematical model of the LED that is used in the calculation. There is no step in the method that is performed by a real LED.
The Applicant argues:
D. The Claims Contain Significantly More Than the Judicial Exception (Step 2B)
The claims contain an inventive concept that amounts to "significantly more" under Step 2B.
The Combination of Limitations Is Not Well-Understood, Routine, or Conventional
Under Berkheimer v. HP, Inc., 881 F.3d 1360 (Fed. Cir. 2018), whether claim elements or combinations of elements are "well-understood, routine, and conventional" is a factual determination that must be supported by evidence. The Examiner has provided no factual support for the conclusion that the claimed combination of the following features constitutes "well-understood, routine, and conventional" activity:
A birth-death process matrix for object reflection clusters across an LED array;
Three-dimensional elliptical Gaussian distribution for intra-cluster scatterers;
Local coordinate system transformations for each LED cell;
Wavelength-dependent equivalent reflection coefficients;
Combined object reflection and particle scattering channel impulse responses;
This combination of features, applied to the specific problem of indoor optical wireless channel modeling, was not previously known in the art.
For at least the foregoing reasons, Applicant respectfully submits that claims 1-8 are patent-eligible under 35 U.S.C. § 101. The claims are directed to a specific technological solution to a specific technological problem-unified indoor optical wireless channel modeling across all optical frequency bands-and the claims as a whole integrate any alleged judicial exception into a practical application. The claims further contain significantly more than any abstract idea through the specific combination of physical modeling steps, parameter calculations, and propagation mechanism integrations.
The argument is not persuasive. As the Applicant admits, these are inventive concepts which are still under the category of abstract ideas that are not patent eligible. Claim 1 recites in lines 22-23 “to obtain a final channel impulse response for the indoor optical wireless communication channel”. The final channel impulse response would be a mathematical expression. However, the claim fails to include limitations that relate or incorporate the impulse response to a real application.
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 SHI K LI whose telephone number is (571)272-3031. The examiner can normally be reached M-F 6:53 a.m. -3:23 p.m.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, David Payne can be reached at 571 272-3024. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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skl1 October 2026
/SHI K LI/Primary Examiner, Art Unit 2635
