DETAILED ACTION
This Office Action is in response to Applicant Amendment and Argument filed on 04/01/2026. This Action is made FINAL.
Claims 1-12 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 .
Response to Amendment
Amendments to claims 4 and 8 removing “fifth” and “eighth” overcome the previous objections, therefore the objections to claims 4-9 are withdrawn.
Amendments to claims no longer invoke interpretation under 112(f) therefore 112(b) rejections linked to interpretation under 112(f) are withdrawn.
Amendments to claim 2 clarify the claimed limitations, therefore the previous rejection under 112(b) is withdrawn.
Amendments to claim 6 clarify the claimed limitations, therefore the previous rejection under 112(b) is withdrawn.
Response to Arguments
Applicant’s arguments, see Remarks pages 10-13, filed 04/01/2026, with respect to the rejection(s) of claim(s) 12under 1 have been fully considered and are not persuasive.
In the Remarks, Applicant argued the following:
Claims do not recite a mental process
Claim 1 integrates into a practical application
Regarding point (i), independent claims 1, 4, and 8 recite at least a step of determination, which, while carried out by electrical circuitry, is a mental process as described in the rejection below.
Regarding point (ii), as discussed in the rejections below the claims fail to integrate into a practical application. Further applicant argues that the battery management device detects whether external charging or replacement of the battery has been performed based on the integrated value and the aver value of currents, eliminated complex equivalent circuit models to perform the determination as an improvement to the computer capacities. Examiner maintains the 101 rejection of the claims as discussed in the rejections below.
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 1-12 are rejected under 35 U.S.C. 101 because the invention is directed to an abstract idea without significantly more.
101 Analysis - Step 1: Applicant’s independent claim 1 is directed toward a battery management device. Therefore, it can be seen that it/they fall(s) within one of the four statutory categories of invention.
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 following groups of abstract ideas: a) mathematical concepts, b) certain methods of organizing human activity, and/or c) mental processes.
Independent claim 1 includes limitations that recite and abstract idea (emphasized below) and will be used as a representative claim for the remainder of the 101 rejection. Claim 1 recites :
A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to:
receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle;
derive, based on the data, an integrated value of currents that have been charged and discharged by the battery and an average value of currents charged and discharged by the battery during a latest activation period of the vehicle; and
determine that external charging or replacement of the battery has been performed when the integrated value of the currents is smaller than a first threshold value and the average value of the currents is smaller than a second threshold value.
The examiner submits that the foregoing bolded limitation(s) constitute a “mental process” because under its broadest reasonable interpretation, the claim covers performance of the limitation in the human mind. Specifically, the steps “derive” and “determine” encompasses a user making an observation, evaluation, or judgement, based on data to derive currents charges and discharged by a batter and to determine when charging or replacement of the battery has been performed when comparing the derived value to two other values, 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 idea into a practical application. As noted in the 2019 PEG, it must be determined whether any additional elements in the claim beyond the abstract idea integrate the exception into a practical application in a manner that imposes a meaningful limit on the judicial exception. The courts have indicated that additional elements merely using a computer to implement an abstract idea, adding insignificant extra solution activity, or generally linking use of a judicial exception to a particular technological environment or field of use do not integrate a judicial exception into a “practical application.”
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 battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to:
receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle;
derive, based on the data, an integrated value of currents that have been charged and discharged by the battery and an average value of currents charged and discharged by the battery during a latest activation period of the vehicle; and
determine that external charging or replacement of the battery has been performed when the integrated value of the currents is smaller than a first threshold value and the average value of the currents is smaller than a second threshold value.
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 limitation of “A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to” the examiner submits that this limitation amounts to no more than generally linking to the technological field of electrical components of vehicle batteries.
Regarding the additional limitation of “receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle” the examiner submits this is the pre-solution activity of data gathering.
101 Analysis - Step 2B: Regarding Step 2B of the Revised Guidance, representative independent claim 1 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 as 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 element of “A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to” amount to no more than generally linking to the technological field of electrical components of vehicles, the additional element “receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle” amounts to no more than the pre-solution activity of data gathering. Therefore, as a whole the claim is directed to an abstract idea implemented on a generic computer generally linked to the technological fields of vehicles with insignificant extra solution activities of data gathering.
Dependent claim(s) 2-3 do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claims are directed toward additional aspects of the judicial exception and/or well-understood, routine and conventional additional elements that do not integrate the judicial exception into a practical application as discussed below. Therefore, dependent claims 2-3 are not patent eligible under the same rationale as provided for in the rejection of claim 1.
Therefore, claim(s) 2-3 is/are ineligible under 35 USC §101.
Regarding claim 2, which is dependent on claim 1, it merely adds the limitations “the integrated value of the currents and the average value of the currents are derived each time the vehicle is acting; and
It is determined that the external charging or the replacement of the battery has been performed when amount of a state is larger than a third threshold value, the state being the integrated value of the currents smaller than the first threshold value and the average value of the currents smaller than the second threshold value” which is merely further defining the abstract ideas of derivation of values by defining at what time the derivation occurs and further defining the abstract idea of determination by further defining values that the derived values are compared to.
Regarding claim 3, which is dependent on claim 1, it merely adds the limitation “wherein the electrical circuitry does not perform the determination when the activation period of the vehicle is shorter than a time threshold value” which is merely further defining the abstract idea by further determining when the determination is to take place based on a comparison of values
Regarding claim 10, which is dependent on claim 1, it merely adds the limitation “wherein the electrical circuitry transmits information to display a message to a user of the vehicle indicating that the external charging or the replacement of the battery ahs been performed in response to a detection flag being turned ON” which is merely the extra solution activity of data transmission along with the additional mental process of determination of a value being turned ON.
Regarding claim 11, which is dependent on claim 1, it merely adds the limitation “wherein the electrical circuitry is configured to turn a detection flag ON when it is determine that the external charging or the replacement of the battery has been performed” which is merely the extra solution activity of data manipulation/selection.
Regarding claim 12, which is dependent on claim 2, it merely adds the limitation “wherein the electrical circuitry is configured to turn a detection flag ON when it is determined that the external charging or the replacement of the battery has been performed, and
wherein a parameter used for another logic necessary for management of the battery is reset and the count of the state is cleared based on the detection flag being turned ON” which is merely the addition of the abstract idea of a determination modified by the extra solution activity of data manipulation as a generic computing device acting in its typical capacity.
101 Analysis - Step 1: Applicant’s independent claim 4 is directed toward a battery management device. Therefore, it can be seen that it/they fall(s) within one of the four statutory categories of invention.
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 following groups of abstract ideas: a) mathematical concepts, b) certain methods of organizing human activity, and/or c) mental processes.
Independent claim 4 includes limitations that recite and abstract idea (emphasized below) and will be used as a representative claim for the remainder of the 101 rejection. Claim 4 recites :
A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to:
receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle;
derive, based on the data, a first voltage difference that is a difference value between an activation voltage of the battery at a time of current activation and an activation voltage of the battery at a time of previous activation, and a second voltage difference obtained by converting, into a voltage, a difference value between an integrated value of currents charged and discharged by the battery before the current activation and an integrated value of currents charged and discharged by the battery before the previous activation; and
determine that external charging or replacement of the battery has been performed when a value obtained by subtracting the second voltage difference from the first voltage difference is larger than a voltage threshold value.
The examiner submits that the foregoing bolded limitation(s) constitute a “mental process” because under its broadest reasonable interpretation, the claim covers performance of the limitation in the human mind. Specifically, the steps “derive” and “determine” encompasses a user making an observation, evaluation, or judgement, based on data to derive currents charges and discharged by a batter and to determine when charging or replacement of the battery has been performed when comparing the derived value to two other values, 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 idea into a practical application. As noted in the 2019 PEG, it must be determined whether any additional elements in the claim beyond the abstract idea integrate the exception into a practical application in a manner that imposes a meaningful limit on the judicial exception. The courts have indicated that additional elements merely using a computer to implement an abstract idea, adding insignificant extra solution activity, or generally linking use of a judicial exception to a particular technological environment or field of use do not integrate a judicial exception into a “practical application.”
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 battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to:
receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle;
derive, based on the data, a first voltage difference that is a difference value between an activation voltage of the battery at a time of current activation and an activation voltage of the battery at a time of previous activation, and a second voltage difference obtained by converting, into a voltage, a difference value between an integrated value of currents charged and discharged by the battery before the current activation and an integrated value of currents charged and discharged by the battery before the previous activation; and
determine that external charging or replacement of the battery has been performed when a value obtained by subtracting the second voltage difference from the first voltage difference is larger than a voltage threshold value.
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 limitation of “A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to” the examiner submits that this limitation amounts to no more than generally linking to the technological field of vehicle batteries.
Regarding the additional limitation of “receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle” the examiner submits this is the pre-solution activity of data gathering.
101 Analysis - Step 2B: Regarding Step 2B of the Revised Guidance, representative independent claim 1 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 as 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 element of “A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising” amount to no more than generally linking to the technological field of vehicles, the additional element “configured to acquire, from the vehicle, data including information on a current of the battery and information on activation of the vehicle” amounts to no more than the pre-solution activity of data gathering. Therefore, as a whole the claim is directed to an abstract idea implemented on a generic computer generally linked to the technological fields of vehicles with insignificant extra solution activities of data gathering.
Dependent claim(s) 5-7 do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claims are directed toward additional aspects of the judicial exception and/or well-understood, routine and conventional additional elements that do not integrate the judicial exception into a practical application as discussed below. Therefore, dependent claims 2-3 are not patent eligible under the same rationale as provided for in the rejection of claim 4.
Therefore, claim(s) 5-7 is/are ineligible under 35 USC §101.
Regarding claim 5, which is dependent on claim 4, it merely adds the limitations “the first voltage difference by converting the activation voltage in a current state of the battery into an activation voltage at a predetermined reference temperature of the batter and at a reference activation current” which is merely further defining the abstract ideas of derivation of values by defining at what time the derivation occurs and which values are used for the derivation.
Regarding claim 6, which is dependent on claim 4, it merely adds the limitation “it is determined that the external charging or the replacement of the battery has been performed when a count of a state is larger than a count threshold value, the state being the value obtained by subtracting the second voltage difference from the first voltage difference larger than the voltage threshold value” which is merely further defining the abstract idea by further determining when the determination is to take place based on a comparison of values.
Regarding claim 7, which is dependent on claim 4, it merely adds the limitation “wherein the electrical circuitry does not perform the determination when a period from an end of the previous activation of the vehicle to the current activation of the vehicle is smaller than a time threshold value” which is merely further defining the abstract idea by further determining when the determination is to take place based on a comparison of values.
101 Analysis - Step 1: Applicant’s independent claim 8 is directed toward a battery management device. Therefore, it can be seen that it/they fall(s) within one of the four statutory categories of invention.
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 following groups of abstract ideas: a) mathematical concepts, b) certain methods of organizing human activity, and/or c) mental processes.
Independent claim 8 includes limitations that recite and abstract idea (emphasized below) and will be used as a representative claim for the remainder of the 101 rejection. Claim 8 recites :
A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to:
receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle;
derive, based on the data, a base voltage value obtained by updating a predetermined initial voltage in accordance with a relative difference from an activation voltage of the battery at a time of activation, and a reference voltage value obtained by updating the initial voltage in accordance with a difference value between an activation voltage of the battery at a time of current activation and an activation voltage of the battery at a time of previous activation; and
determine that external charging or replacement of the battery has been performed when a value obtained by subtracting the base voltage value from the reference voltage value is larger than a voltage threshold value.
The examiner submits that the foregoing bolded limitation(s) constitute a “mental process” because under its broadest reasonable interpretation, the claim covers performance of the limitation in the human mind. Specifically, the steps “derive” and “determine” encompasses a user making an observation, evaluation, or judgement, based on data to derive currents charges and discharged by a batter and to determine when charging or replacement of the battery has been performed when comparing the derived value to two other values, 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 idea into a practical application. As noted in the 2019 PEG, it must be determined whether any additional elements in the claim beyond the abstract idea integrate the exception into a practical application in a manner that imposes a meaningful limit on the judicial exception. The courts have indicated that additional elements merely using a computer to implement an abstract idea, adding insignificant extra solution activity, or generally linking use of a judicial exception to a particular technological environment or field of use do not integrate a judicial exception into a “practical application.”
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 battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to:
receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle;
derive, based on the data, a base voltage value obtained by updating a predetermined initial voltage in accordance with a relative difference from an activation voltage of the battery at a time of activation, and a reference voltage value obtained by updating the initial voltage in accordance with a difference value between an activation voltage of the battery at a time of current activation and an activation voltage of the battery at a time of previous activation; and
determine that external charging or replacement of the battery has been performed when a value obtained by subtracting the base voltage value from the reference voltage value is larger than a voltage threshold value.
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 limitation of “A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising electrical circuitry configured to” the examiner submits that this limitation amounts to no more than generally linking to the technological field of vehicle batteries.
Regarding the additional limitation of “receive, from electrical circuitry of the vehicle for data communication, data including information on a current of the battery and information on activation of the vehicle” the examiner submits this is the pre-solution activity of data gathering.
101 Analysis - Step 2B: Regarding Step 2B of the Revised Guidance, representative independent claim 1 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 as 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 element of “A battery management device configured to manage a battery mounted on a vehicle, the battery management device comprising” amount to no more than generally linking to the technological field of vehicles, the additional element “configured to acquire, from the vehicle, data including information on a current of the battery and information on activation of the vehicle” amounts to no more than the pre-solution activity of data gathering. Therefore, as a whole the claim is directed to an abstract idea implemented on a generic computer generally linked to the technological fields of vehicles with insignificant extra solution activities of data gathering.
Dependent claim(s) 9 do not recite any further limitations that cause the claim(s) to be patent eligible. Rather, the limitations of dependent claims are directed toward additional aspects of the judicial exception and/or well-understood, routine and conventional additional elements that do not integrate the judicial exception into a practical application as discussed below. Therefore, dependent claims 2-3 are not patent eligible under the same rationale as provided for in the rejection of claim 8.
Therefore, claim(s) 9 is/are ineligible under 35 USC §101.
Regarding claim 9, which is dependent on claim 8, it merely adds the limitation “wherein the base voltage value is derived by reducing a voltage change amount from a previous time to a current time as a difference between the activation voltage of the battery at the time of current activation and the base voltage value updated at the time of previous activation increases, and the reference voltage value is derived by reducing the voltage change amount from the previous time to the current time as a difference between the activation voltage of the battery at the time of current activation and the activation voltage of the battery at the time of previous activation increases.” which is merely further defining the abstract ideas of derivation of values by defining at what time the derivation occurs and further defining the abstract idea of determination by further defining values that the derived values are compared to.
Allowable Subject Matter
Claims 1-12 would be allowable if rewritten or amended to overcome the rejection(s) under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), 2nd paragraph, 35 U.S.C. 112(a), and 35 U.S.C. 101 set forth in this Office action.
The closest prior arts found are :
Tawa et al (US 20210286020 A1) teaches an inspection apparatus for an assembled battery having a plurality of energy storage devices connected in series, based on a voltage difference between a first energy storage device with the first-lowest voltage and a second energy storage device with the second-lowest voltage during charge or discharge among the plurality of energy storage devices, an abnormality of the first energy storage device is detected.
Watanabe et al (US 20120032647 A1) teaches a method for determining completion of charge a lithium ion secondary battery including one lithium compound having an olivine crystal structure as a positive electrode active material, and a graphite material as a negative electrode active material, includes: (S1) charging the battery by an amount of electricity Xc in time Ti1; (S2) stopping the charging for time Yc after completion of (S1), and measuring a battery voltage Vi1 after the time Yc has passed; (S3) charging the amount of electricity Xc in the time Ti1 after completion of (S2); (S4) stopping the charging for the time Yc after completion of (S3), and measuring a battery voltage Vi2 after the time Yc has passed; and comparing Vi2-Vi1 with a predetermined voltage difference Vi3 to determine that the charge has been completed when Vi2-Vi1>Vi3, and determine that the charge has not been completed when Vi2-Vi1<Vi3.
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.
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/D.H./Examiner, Art Unit 3668
/IMRAN K MUSTAFA/Primary Examiner, Art Unit 3668
6/26/2026
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