DETAILED ACTION
This Office Action is in response to Applicant's Application filed on 10/11/2024 and Election filed on 3/3/2026.
Claim 1 was canceled.
Claims 14-21 are not elected.
Claims 2-13 are pending for examination.
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 .
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 12/2/2024 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
Election/Restrictions
Claims 14-21 withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention II, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 3/3/2026.
Claim Interpretation
The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: processing device in claim 10.
Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. In the specification paragraph 127, “the electronic processor determines a rate of change of the power expended over time, and the electronic processor determines if the rate of change exceeds a threshold rate of change, indicating that the grass cutter may have struck an object”. Accordingly, the processing device is interpreted as electronic processor.
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
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 2-13 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
101 Analysis-Step 1
Claims 2-9 are directed to A method (i.e., a process). Therefore, claims 2-9 are within at least one of the four statutory categories.
101 Analysis-Step 2A, Prong I
Regarding Prong I of the Step 2A analysis in the 2019 PEG, the claims are to be analyzed to determine whether they recite subject matter that falls within one of the follow groups of abstract ideas: a) mathematical concepts, b) certain methods of organizing human activity, and/or c) mental processes.
Independent claim 2 includes limitations that recite an abstract idea (emphasized below) and will be used as a representative claim for reminder of the 101 rejection. Claim 2 recites:
A method comprising:
obtaining position-referenced sensor data generated by an autonomous robot lawnmower as the autonomous robot lawnmower traverses a mowable area;
determining, based on the position-referenced sensor data, a location of debris in the mowable area; and
presenting, on a user interface of a computing device,
a map representing the mowable area,
a marker on the map at the location, and
a recommendation to check the location for the debris.
The examiner submits that the foregoing bolded limitation(s) constitute a "mental process" and/or “certain methods of organizing human activity” because under its broadest reasonable interpretation, the claim covers performance of the limitation by a user or in the human mind. For example, “determining, based on the position-referenced sensor data, a location of debris in the mowable area” in the context of this claim encompasses the user mentally determining location of debris based on gathered data. Accordingly, the claim recites at least one abstract idea.
101 Analysis-Step 2A, Prong II
Regarding Prong II of the Step 2A analysis in the 2019 PEG, the claims are to be analyzed to determine whether the claim as a whole, integrates the abstract into a partial application. As noted in the 2019 PEG, it must be determined whether there are any additional elements recited in the claim beyond the judicial exception(s), and whether those additional elements integrate the exception into a practical application of the exception.
In the present case, the additional limitations beyond the above-noted abstract idea are as follows (where the underlined portions are the “additional limitations” while the bolded portions continue to represent the “abstract idea”):
A method comprising:
obtaining position-referenced sensor data generated by an autonomous robot lawnmower as the autonomous robot lawnmower traverses a mowable area;
determining, based on the position-referenced sensor data, a location of debris in the mowable area; and
presenting, on a user interface of a computing device,
a map representing the mowable area,
a marker on the map at the location, and
a recommendation to check the location for the debris.
For the following reason(s), the examiner submits that the above identified additional limitations do not integrate the above-noted abstract idea into a practical application.
Regarding the additional limitations of “obtaining position-referenced sensor data generated by an autonomous robot lawnmower as the autonomous robot lawnmower traverses a mowable area”, the examiner submits that these limitations are mere data gathering in conjunction with a law of nature or abstract idea (MPEP § 2106.05). In particular, “obtaining position-referenced sensor data” indicate pre-solution activity such that it amounts no more than a step of gathering data for use in a claimed process.
Regarding the additional limitations of “presenting, on a user interface of a computing device, a map representing the mowable area, a marker on the map at the location, and a recommendation to check the location for the debris.”, the examiner submits that these limitations are mere data outputting in conjunction with a law of nature or abstract idea (MPEP § 2106.05). In particular, “presenting, on a user interface of a computing device” indicate post-solution activity such that it amounts no more than a step of outputting data for use in a claimed process.
Thus, taken alone, the additional elements do not integrate the abstract idea into a practical application. Further, looking at the additional limitation(s) as an ordered combination or as a whole, the limitation(s) add no thing that is nor already present when looking at the elements taken individually. For instance, there is no indication that the additional elements, when considered as a whole, reflect an improvement in the functioning of a computer or an improvement to another technology or technical field, apply or use the above-noted judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, implement/use the above-noted judicial exception with a particular machine or manufacture that is integral to the claim, effect a transformation or reduction of a particular article to a different state or thing, or apply or use the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment. Such that the claim as a whole is not more than a drafting effort designed to monopolize the exception (MPEP § 2 106.05). Accordingly, the additional limitation(s) do/does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea.
101 Analysis-Step 2B
Regarding Step 2B of the Revised Guidance, representative independent claim 2 does not include additional elements (considered both individually and as an ordered combination) that are sufficient to amount to significantly more than the judicial exception for the same reasons to those discussed above with respect to determining that the claim does not integrate the abstract idea into a practical application. As discussed above with respect to integration of the abstract idea into a practical application, the additional limitation of “obtaining position-referenced sensor data generated by an autonomous robot lawnmower as the autonomous robot lawnmower traverses a mowable area” and “presenting, on a user interface of a computing device, a map representing the mowable area, a marker on the map at the location, and a recommendation to check the location for the debris”, the examiner submits that the limitation merely adds insignificant extra-solution activity to the at least one abstract idea as previously discussed.
Hence the claim is not patent eligible.
Therefore, claim(s) 2 is/are ineligible under 35 U.S.C. 101.
Regarding Claim 3, the claim recites further narrowing limitation on the “the position-referenced sensor data comprises power data indicating power expended by a cutter of the autonomous robot lawnmower” which is merely insignificant extra solution activity and fail to integrate the abstract idea into a practical application while the claim further recites “determining the location of the debris is based on the power data” which further narrowing the abstract idea and fail to integrate the abstract idea into a practical application.
Regarding Claim 4, the claim recites “determining the location of the debris is based on the power exceeding a threshold power value” which further narrowing the abstract idea and fail to integrate the abstract idea into a practical application.
Regarding Claim 5, the claim recites “the threshold power value is based on an amount of power corresponding to mowing the mowable area with a defined grass height” which further narrowing the abstract idea and fail to integrate the abstract idea into a practical application.
Regarding Claim 6, the claim recites “the threshold power value is a defined multiple of an average power expended while mowing” which further narrowing the abstract idea and fail to integrate the abstract idea into a practical application.
Regarding Claim 7, the claim recites “determining the location of the debris is based on a rate of change of the power exceeding a threshold value” which further narrowing the abstract idea and fail to integrate the abstract idea into a practical application.
Regarding Claim 8, the claim recites further narrowing limitation on the “generating the power data at the autonomous robot lawnmower using a power sensor of the autonomous robot lawnmower” which is merely insignificant extra solution activity and fail to integrate the abstract idea into a practical application.
Regarding Claim 9, the claim recites further narrowing limitation on the “obtaining the position-referenced sensor data comprises: receiving sensor data and position data from the autonomous robot lawnmower at a server remote from the autonomous robot lawnmower; and generating the position-referenced sensor data at the server based on the sensor data and the position data” which is merely insignificant extra solution activity and fail to integrate the abstract idea into a practical application.
As per independent claim 10, it recites One or more non-transitory computer readable media storing instructions that, when executed by a processing device, cause the processing device to perform operations having limitations similar to those of claim 2 and therefore is rejected on the same basis.
As per dependent claims 11-13, it recites One or more non-transitory computer readable media storing instructions that, when executed by a processing device, cause the processing device to perform operations having limitations similar to those of claims 3, 4, 7 and therefore is rejected on the same basis.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claim(s) 2, 9-10 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Grufman (US20170345210A1).
Regarding claim 2, Grufman teaches A method comprising:
obtaining position-referenced sensor data generated by an autonomous robot lawnmower as the autonomous robot lawnmower traverses a mowable area(Grufman: Para 49 “the garden mapping unit 270 may be configured to enable image data to be combined with position data to generate location aware processing of data for creation of a virtual garden in the form of a base-map 280.”);
determining, based on the position-referenced sensor data, a location of debris in the mowable area(Grufman: Para 48 “problems such as the robotic vehicle 10 getting stuck, areas with bad GPS coverage, areas with poor grass quality, swampy or dry areas, and/or the like may be identified and associated with the locations and times during which such conditions occurred. The information may be used to define areas that the robotic vehicle 10 should avoid or take special actions when entering such areas. The occurrence of certain natural or artificial phenomena may therefore be monitored, such as the falling of a tree limb, the intrusion of an animal or person into a garden, or the leaving of toys, furniture or other objects on the parcel 20”; Para 49 “the garden mapping unit 270 may be configured to enable image data to be combined with position data to generate location aware processing of data for creation of a virtual garden in the form of a base-map 280. The virtual garden may be a 2D or 3D representation of the garden and may include content items that include image data and perhaps other sensor data that is correlated by time and/or location with the representation of the garden. The operator may therefore be enabled to conduct a virtual inspection of the garden from anywhere in the world in an intuitive and natural way. Various problems, obstacles and items in the garden may be automatically or manually identified by reviewing image data content items so that the overall quality of lawn and garden activities (e.g., mowing) may be improved. Additionally, automatic masking of image data for objects outside boundaries of the parcel 20 on which the robotic vehicle 10 operates may also be accomplished to address any privacy concerns”); and
presenting, on a user interface of a computing device(Grufman: Fig. 5; Para 38 “processing circuitry 272 of the garden mapping unit 270 may be configured to generate a base-map 280 of the parcel 20 based on the image data and position information received from the image capture module 110 and the positioning module 100, respectively. In this regard, position and heading information may be integrated with image data to generate a two or three dimensional base-map 280 of the parcel. The base-map 280 may then be interacted with by the user to enable the user to accomplish various tasks.”),
a map representing the mowable area(Grufman: Fig. 5 Element 291; Para 44 “the work area 291 may be defined as an area that is to be mowed in its entirety”),
a marker on the map at the location(Grufman: Fig. 5 Element 296; Para 45 “an icon, thumbnail view or other indicator (e.g., content item indicator 296) may be placed on the map view itself, and the user may select the indicator to view image data for the location”), and
a recommendation to check the location for the debris(Grufman: Fig. 5; Para 48 “The timeline function may serve as an event log so that potential problems or changes of interest may be identified either automatically or by the operator. For example, logged data may include pictures or image data taken of various structures or situations on the parcel 20. The image data may be presented to the operator so the operator can identify or appreciate the changes, or image processing techniques may be employed to compare images of the same area at different times to identify objects or other changes and the operator may be notified of such changes (e.g., via email, MMS or other alerting mechanisms). Accordingly, for example, the garden mapping unit 270 may be configured to perform automatic change detection (e.g., based on image comparisons) and notification based, in some cases, on logged data. The logged data may therefore include images, sensor readings, component activity data and/or the like for given times or periods of time”).
Regarding claim 9, Grufman teaches the method of claim 2, wherein obtaining the position-referenced sensor data comprises:
receiving sensor data and position data from the autonomous robot lawnmower at a server remote from the autonomous robot lawnmower(Grufman: Para 22 “In embodiments where the wireless network 46 is employed, the wireless network 46 may be a data network, such as a local area network (LAN), a metropolitan area network (MAN), a wide area network (WAN) (e.g., the Internet), and/or the like, which may couple the robotic vehicle 10 to devices such as processing elements (e.g., personal computers, server computers or the like) or databases. Accordingly, communication between the wireless network 46 and the devices or databases (e.g., servers, electronic device 42, control circuitry 12) may be accomplished by either wireline or wireless communication mechanisms and corresponding protocols”); and
generating the position-referenced sensor data at the server based on the sensor data and the position data(Grufman: Para 32 “one or more databases that may store a variety of data sets responsive to input from various sensors or components of the robotic vehicle 10. Among the contents of the memory 214, applications may be stored for execution by the processor 212 in order to carry out the functionality associated with each respective application. In some cases, the applications may include an algorithm for capturing image data and correlating the image data to the corresponding location of the robotic vehicle 10 at the time the image data was captured.”).
As per claim 10, it recites One or more non-transitory computer readable media storing instructions that, when executed by a processing device, cause the processing device to perform operations having limitations similar to those of claim 2 and therefore is rejected on the same basis. Grufman further teaches One or more non-transitory computer readable media(Grufman: Para 30 “the processing circuitry 210 may include one or more instances of a processor 212 and memory 214 that may be in communication with or otherwise control a device interface 220 and, in some cases, a user interface 230 (e.g., display 66). As such, the processing circuitry 210 may be embodied as a circuit chip (e.g., an integrated circuit chip) configured (e.g., with hardware, software or a combination of hardware and software) to perform operations described herein”)
Allowable Subject Matter
Claim 3-8, 11-13 would be allowable if rewritten or amended to overcome the rejection(s) under 35 U.S.C. 101, set forth in this Office action.
The features “the position-referenced sensor data comprises power data indicating power expended by a cutter of the autonomous robot lawnmower, and wherein determining the location of the debris is based on the power data” in claims 3 and 11 when taken in the context of the claims as a whole, were not uncovered in the prior art teachings. In particular, determining the location of the debris is based on the power expended by the cutter of lawnmower is not disclosed in the prior art.
Claims 4-8, 12-13 would be allowable based on the dependence on claims 3 and 11 therefor inheriting the allowable subject matter disclosed in claim 3 and 11.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Grufman (US20170364090A1) disclosed a method for recording data from at least one sensor of a robotic vehicle responsive to the robotic vehicle transiting a portion of a parcel and determining a confidence score associated with the recorded data for each of a plurality of potential detection events. The confidence score may correspond to a probability that the recorded data corresponds to an object or feature.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to WENYUAN YANG whose telephone number is (571)272-5455. The examiner can normally be reached Monday - Thursday 9:00AM-5:00PM EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Hitesh Patel can be reached at (571) 270-5442. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/W.Y./Examiner, Art Unit 3667
/Hitesh Patel/Supervisory Patent Examiner, Art Unit 3667
3/20/26