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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 01/20/2026 has been entered.
Status of the Claims
Claims 1-8 and 10-21 are pending. Claim 9 is cancelled. Claim 1 is amended.
Response to Arguments
Applicant’s arguments, filed 06/27/2025, with respect to the 101 rejection has been considered but is not persuasive.
Applicant argues, on page 11, that Amended independent claim 1 is not a method of organizing human activity but instead provides a technical solution to a problem associated with the electronic devices and the device information derived from those electronic devices. Therefore, amended independent claim 1 is not directed to the judicial exception of an abstract idea and satisfies step 2A, prong 1 of the Alice test.
Examiner respectfully disagrees. The claim limitations as drafted, recite a concept, that, under broadest reasonable interpretation, is a certain method of organizing human activity. The limitations are analogous to managing personal behavior or interactions between people (interactions between people), or a commercial or legal interaction (sales activity) such as determining and communicating statuses of devices within an organization (See specification, par. 0003). The generic computer implementations do not change the character of the limitations. The additional elements (computer elements, databases, electronic communication etc) are recited at a high-level of generality such that they amount to no more than generally linking the use of a judicial exception to a particular technological environment or field of use. Accordingly, the additional elements, when viewed individually and in combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use. The same analysis applies in 2B. The additional elements, when considered separately and in combination, do not add significantly more to the exception. They are generally linking the use of a judicial exception to a particular technological environment or field of use and cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. Therefore, the claims are ineligible.
Applicant argues, on pages 10-11, that Claim 1 as a whole integrates the method into a practical application by reciting a specific technical solution of ensuring and confirming the accuracy of device status information to a defined non abstract technical problem of device information provided to the client can being inconsistent and/or incorrect due to the reliance on external information regarding the electronic devices that may be inaccurate, incomplete, unverified, and/or out-of-date.
Examiner respectfully disagrees. As mentioned above, the additional elements do not integrate the judicial exception into a practical application. Additionally, it is important to keep in mind that an improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology. Here, the alleged improvement to gathering information from multiple sources automatically and determining the condition of many electronic devices quickly/accurately is an improvement to the business process of managing these devices and not a technology or technical field. Therefore, the claims are considered ineligible.
Novelty/Non-Obviousness
The closest prior art of record has been included in the office action mailed on 03/27/2025. The claims would be considered allowable if the claims can be rewritten or amended to overcome the rejection(s) in this office action.
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 and 10-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1
Claims 1-8 and 10-21 are directed to a system with multiple components, and therefore is a machine
Independent Claims
Step 2A Prong One
The limitation of Claim 1 recites:
a first portion of external information regarding the … (devices) and including at least one of client information, shipping information, lease information, disposal information, and inventory information with the first portion of external information being digital information made available at a first time with some of the first portion of external information being continuously updated before being made available at the first time; and
a second portion of external information regarding the … (devices) and including at least one of client information, shipping information, lease information, disposal information, and inventory information with the second portion of external information being … information made available at a second time with some of the second portion of external information being continuously updated between the first time and the second time;
obtain the first portion of external information at the first time in response to the first portion of external information being made available … by:
establishing an … connection with at least one … (source); and
at least one of accessing the first portion of external information in response to a … request and receiving the first portion of external information … from the at least one … (source);
automatically identify, for at least a first portion of the electronic devices concurrently and in response to access to the first portion of external information, a first status representative of the activity of the …(device) for each … (device) of the first portion of … (devices) with the first status being based on the first portion of external information obtained by the device tracking system at the first time;
obtain the second portion of external information at the second time in response to the second portion of external information being made available to … by:
establishing an … connection with the at least one … (source); and
at least one of accessing the second portion of external information in response to a … request and receiving the second portion of external information via … communication from the at least one … (source); and
automatically identify, for at least a second portion of the … (devices) concurrently and in response to access to the second portion of external information, a second status representative of the activity of the …(device) for each … (device) of the second portion of … (devices) with the second status being based on the second portion of external information obtained by the … at the second time that is after the first time;
automatically confirm the device status information is accurate for each … (device) for which both a first status and a second status was identified by:
identifying a status change from the first status to the second status;
comparing the status change to methodology that includes allowable status changes, unusual status changes, and prohibited status changes;
in response to the status change from the first status to the second status for the … (device) being an allowable status change, confirming the accuracy of the device status information for the respective … (device);
in response to the status change from the first status to the second status for the … (device) being one of an unusual status change and a prohibited status change, noting an inaccuracy of the device status information for the respective … (device); and
… configured to provide to a client, …, device status information dependent upon the external information with the statuses including the first status for each respective … (device) for which the second status was not identified and the second status for each respective … (device) for which the second status was identified and confirmed to be accurate with the device status information being provided to the client by the … after the identification and accuracy confirmation of the second status for each electronic device of the second portion of … (devices).
The claim limitations as drafted, recite a concept, that, under broadest reasonable interpretation, is a certain method of organizing human activity. The limitations are analogous to managing personal behavior or interactions between people (interactions between people), or a commercial or legal interaction (sales activity) such as determining and communicating statuses of devices within an organization. The generic computer implementations (see below) do not change the character of the limitations. Accordingly, the claims recite an abstract idea.
Step 2A Prong Two
The judicial exception is not integrated into a practical application. In particular, the claims recite the following additional elements:
Claim 1:
A system for ensuring and confirming an accuracy of device status information regarding an activity of each electronic device of multiple electronic devices with each electronic device being capable of having one of multiple statuses, the system comprising:
a device tracking database having the device status information that includes statuses representative of the activity of the electronic device for each of the electronic devices;
external information regarding the electronic devices stored in storage media distant from the device tracking database, the external information comprising:
Electronic device
Digital information
a device tracking system in electronic communication with the device tracking database and configured to:
Storage media
Electronic connection
Digital request
Electronic communication
External information source
device tracking system including at least one computer processor
transmission module
These additional elements are recited at a high-level of generality such that they amount to no more than generally linking the use of a judicial exception to a particular technological environment or field of use. Accordingly, the additional elements, when viewed individually and in combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use (see MPEP 2106.05(h))
Therefore, the claims recite an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements, amount to no more than generally linking the use of a judicial exception to a particular technological environment or field of use. The same analysis applies here in 2B. The additional elements, when considered separately and in combination, do not add significantly more to the exception. They are generally linking the use of a judicial exception to a particular technological environment or field of use and cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. The claims are ineligible.
Dependent Claims
Dependent claims 2-8 and 10-21 further narrow the same abstract ideas recited in Claim 1. Therefore, claims 2-8 and 10-21 are directed to an abstract idea for the reasons given above.
Step 2A Prong Two
The judicial exception is not integrated into a practical application. In particular, the dependent claims recite the following additional elements:
Claims 2
API
Claims 4
Active analysis module
Digital client communication system
Claims 10
Shipping module
Claim 14:
an enterprise resource planning (ERP) system of the client, a unified endpoint management (UEM) system of the client, and a mobile device management (MDM) system of the client
Claims 15
Stock module
Claims 17
ERP
Claims 20
Lease analysis module
These additional elements are recited at a high-level of generality such that they amount to no more than generally linking the use of a judicial exception to a particular technological environment or field of use. Accordingly, the additional elements, when viewed individually and in combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. The claims do not amount to more than generally linking the use of a judicial exception to a particular technological environment or field of use (see MPEP 2106.05(h)). Therefore, the claims recite an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements, amount to no more than generally linking the use of a judicial exception to a particular technological environment or field of use. The same analysis applies here in 2B. The additional elements, when considered separately and in combination, do not add significantly more to the exception. They are generally linking the use of a judicial exception to a particular technological environment or field of use and cannot integrate a judicial exception into a practical application at Step 2A or provide an inventive concept in Step 2B. The claims are ineligible.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ISMAIL A MANEJWALA whose telephone number is (571)272-8904. The examiner can normally be reached M-F 8-5.
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/ISMAIL A MANEJWALA/Primary Examiner, Art Unit 3628