Prosecution Insights
Last updated: July 17, 2026
Application No. 19/062,271

ARTICLE MANAGEMENT SYSTEM, ARTICLE MANAGEMENT METHOD, AND RECORDING MEDIUM HAVING RECORDED THEREON ARTICLE MANAGEMENT PROGRAM

Non-Final OA §101§103
Filed
Feb 25, 2025
Priority
Mar 22, 2024 — JP 2024-046026
Examiner
AUSTIN, JAMIE H
Art Unit
3625
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Sharp Corporation
OA Round
1 (Non-Final)
25%
Grant Probability
At Risk
1-2
OA Rounds
3y 6m
Est. Remaining
57%
With Interview

Examiner Intelligence

Grants only 25% of cases
25%
Career Allowance Rate
104 granted / 421 resolved
-27.3% vs TC avg
Strong +33% interview lift
Without
With
+32.6%
Interview Lift
resolved cases with interview
Typical timeline
4y 11m
Avg Prosecution
25 currently pending
Career history
463
Total Applications
across all art units

Statute-Specific Performance

§101
9.7%
-30.3% vs TC avg
§103
80.4%
+40.4% vs TC avg
§102
3.3%
-36.7% vs TC avg
§112
5.1%
-34.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 421 resolved cases

Office Action

§101 §103
CTNF 19/062,271 CTNF 83105 DETAILED ACTION Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia 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 07-04-01 AIA 07-04 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 1-11 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e. abstract idea) without anything significantly more. Step 1: Claims 1-9 are directed to a system, claim 10 is directed to a method, and claim 11 is directed to a computer readable recording medium. Therefore, claims 1-11 are directed to patent eligible categories of invention. Step 2A, Prong 1: The claim(s) recite(s) (mathematical relationships/formulas, mental process or certain methods of organizing human activity). Specifically the independent claims recite: mental process : as drafted, the claim recites the limitations of acquiring individual picking processing time, acquiring picking prediction information, evaluating a combination picking processing time, and determining an optimal arrangement position combination which is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. That is, other than reciting “ one or more processors ,” nothing in the claim precludes the determining step from practically being performed in the human mind. For example, but for the “processor” language, the claim encompasses a user manually receiving data, evaluating the data, and making a determination. The claims compare historical data and predict future outcomes. The mere nominal recitation of a generic computing device does not take the claim limitation out of the mental processes grouping. This limitation is a mental process. mathematical formula: The claims 5-9 recites a mathematical concept (which can include a mathematical relationships, mathematical formulas or equations, and mathematical calculations), and in this case the claims evaluate an objective function and manipulate it . Thus, the claim recites a mathematical relationship. certain methods of organizing human activity: The claim as a whole recites a method of organizing human activity. The claimed invention is a method that allows for users to optimize warehouse shelf assignments which is a method of managing personal behavior and warehouse optimization. Thus, the claim recites an abstract idea. Dependent claims 2-9 further narrow the abstract idea identified in the independent claims and do not introduce further additional elements for consideration. Step 2A, Prong 2: Independent claims 1, 10, and 11 do not integrate the judicial exception into a practical application. Claim 1 is a system comprising “ one or more processors .” Claim 10 is a method that recites limitations performed “ one or more processors.” Claim 11 is a non-transitory computer-readable recording medium that comprises “ one or more processors. ” These additional elements are mere instructions to implement an abstract idea using a computer in its ordinary capacity, or merely uses the computer as a tool to perform the identified abstract idea. Use of a computer or other machinery in its ordinary capacity for performing the steps of the abstract idea or other tasks (e.g., to acquire, evaluate, and determine data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., certain methods of organizing human activity) does not integrate a judicial exception into a practical application. See MPEP 2106.05(f). Therefore, the additional elements of the independent claims, when considered both individually and in combination, are not sufficient to prove integration into a practical application. Dependent claims 2-9 further narrow the abstract idea identified in the independent claims and do not introduce further additional elements for consideration, which does not integrate the judicial exception into a practical application. Therefore, the additional elements of the dependent claims, when considered both individually and in the context of the independent claims, are not sufficient to prove integration into a practical application. Step 2B: Independent claims 1, 10, and 11 do not comprise anything significantly more than the judicial exception. As can be seen above with respect to Step 2A, Prong 2, claim 1 is a system comprising “ one or more processors .” Claim 10 is a method that recites limitations performed “ one or more processors.” Claim 11 is a non-transitory computer-readable recording medium that comprises “ one or more processors. ” These additional elements are mere instructions to implement an abstract idea using a computer in its ordinary capacity, or merely uses the computer as a tool to perform the identified abstract idea. Use of a computer or other machinery in its ordinary capacity for performing the steps of the abstract idea or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea (e.g., certain methods of organizing human activity) is not anything significantly more than the judicial exception. See MPEP 2106.05(f). The additional elements of the independent claims, when considered both individually and in combination, do not comprise anything significantly more than the judicial exception. Dependent claims 2-9 further narrow the abstract idea identified in the independent claims and do not introduce further additional elements for consideration, which is not anything significantly more than the judicial exception. The additional elements of the dependent claims, when considered both individually and in the context of the independent claims, are not anything significantly more than the judicial exception. Therefore based on the above analysis as conducted based on MPEP 2106 from the United States Patent and Trademark Office the claims are viewed as a court recognized abstract idea, are viewed as a judicial exception, does not integrate the claims into a practical application, does not provide significantly more, and does not provide an inventive concept, therefore the claims are ineligible. Accordingly, claims 1-11 are rejected under 35 USC 101. Claim Rejections - 35 USC § 103 07-06 AIA 15-10-15 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 07-20-aia AIA The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. 07-21-aia AIA Claim (s) 1-11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hance et al. (US 20180068255 A1) in view of Bhatt et al. (US 20250217738 A1) . Regarding claim 1, Hance teaches an article management system comprising: one or more processors (¶ 3, 4, 41-43, disclose a processor), the article management system determining an arrangement position combination of a plurality of articles with respect to a plurality of arrangement positions, wherein the one or more processors (¶ 20, discloses the real-time locations of the pallet items in a warehouse. ¶ 39, 72, 81, discloses choosing an optimal warehouse pallet location. ¶ 55, 61, 62, 23, 75); acquire an individual picking processing time when each of the plurality of articles is arranged at each of the plurality of arrangement positions (¶ 75-77, discloses the time it takes to perform tasks including moving a pallet. ¶ 46-48); acquire picking prediction information of the article (¶ 46, 59, disclose the time is takes a robotic device to complete a task. ¶ 32, 48, 23); and determine one arrangement position combination from among the plurality of arrangement position combinations (¶ 32, 76, 81, discloses determining pick up positions. ¶ 48, 54). Hance does not specifically teach evaluating a picking process time. However, Bhatt teaches pick predictions and information, evaluate a combination picking processing time corresponding to a plurality of arrangement position combinations based on the individual picking processing time and the picking prediction information (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on pick time. ¶ 197, 212, 229, Fig. 16s, 21); and determine one arrangement position combination from among the plurality of arrangement position combinations based on the combination picking processing time (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on pick time. ¶ 114, 197, 212, 229, Fig. 16s, 21). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform picking processing time, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying picking processing time would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow additional data to give the user the ability to make educated modifications to the warehouse inventory storage. Regarding claim 2, the combination of Hance and Bhatt teach the limitations of claim 1. Hance teaches an article management system with processors. Hance does not specifically teach a historical picking and picking processing time. However, Bhatt teaches acquire picking history information in which a past picking processing time of the article for each of the arrangement positions is recorded (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on historical pick time data. ¶ 198, 212, 229, Fig. 16s, 21); and acquire the individual picking processing time based on the picking history information (¶ 23, disclose evaluating pick times based on locations. ¶ 105-109, disclose pick time based on historical pick information. ¶ 114, 121, 197, 212, 229, Fig. 16s, 21). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform evaluating a picking process time, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying evaluating a picking process time would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow additional data to give the user the ability to make educated modifications to the warehouse inventory storage. Regarding claim 3, the combination of Hance and Bhatt teach the limitations of claim 2. Hance teaches an article management system with processors. Hance does not specifically teach a historical picking and picking processing time. However, Bhatt teaches wherein the picking history information includes characteristic information of the arrangement position and characteristic information of the article (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on historical pick time data based on their arrangement. ¶ 198, 212, 229, Fig. 16s, 21); and the one or more processors acquire combination determination target information including characteristic information of the arrangement position and characteristic information of the article of an arrangement position combination determination target, and acquire the individual picking processing time based on identity or similarity of the characteristic information of the arrangement position and identity or similarity of the characteristic information of the article in comparison between the picking history information and the combination determination target information (¶ 26-27, discloses figuring placement based on demand and seasonality ¶ 23, disclose evaluating pick times based on locations. ¶ 105-109, discloses slotting based on product characteristics and pick time based on historical pick information. ¶ 114, 121, 197, 212, 229, Fig. 16s, 21). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform a historical picking and picking processing time, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying a historical picking and picking processing time would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow additional data to give the user the ability to make educated modifications to the warehouse inventory storage. Regarding claim 4, the combination of Hance and Bhatt teach the limitations of claim 3. Hance teaches an article management system with processors. Hance does not specifically teach information related to a size or a shape of the arrangement position. However, Bhatt teaches wherein the characteristic information of the arrangement position includes information related to a size or a shape of the arrangement position (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on historical pick time data based on their arrangement. ¶ 109, 112-114, 126, 184, disclose product characteristics (size, weight, dimensions), ¶ 198, 212, 229, Fig. 16s, 21); the characteristic information of the article includes information related to a type, a size, or a weight of the article (¶ 23, disclose evaluating pick times based on locations. ¶ 105-109, 112-114, 126, discloses product characteristics (size, weight, dimensions). ¶ 121, 197, 212, 229, Fig. 16s, 21). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform information related to a size or a shape of the arrangement position, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying information related to a size or a shape of the arrangement position would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow additional data to give the user the ability to make educated modifications to the warehouse inventory storage and location. Regarding claim 5, the combination of Hance and Bhatt teach the limitations of claim 1. Hance teaches an objective function (¶ 78). Hance does not specifically teach obtain an objective function including an evaluation term. However, Bhatt teaches obtain an objective function including an evaluation term of the combination picking processing time (¶ 138-139, discloses warehouse optimization using an objective function. ¶ 174, discloses using the objective function to minimize cost per hour. ¶ 198-199); and determine the arrangement position combination in which the objective function is minimized (¶ 138-139, discloses warehouse optimization using an objective function. Specifically linear programing may be used for placement of products in the warehouse. ¶ 174, discloses using the objective function to minimize cost per hour. ¶ 198-199). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform obtain an objective function including an evaluation term, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying obtain an objective function including an evaluation term would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow the user an additional method of analyzing the data. Regarding claim 6, the combination of Hance and Bhatt teach the limitations of claim 5. Hance further teaches wherein the evaluation term of the combination picking processing time includes an evaluation term of a work time required for a picking work of the article at the arrangement position and an evaluation term of a transport time required to transport the article from the arrangement position to a predetermined shipping location (¶ 3, 4, 28, 59, 61, discloses both work time and transport time for objects to a shipping location. ¶ 78). Also taught by Bhatt (¶ 138, 153-154, 212-214). Regarding claim 7, the combination of Hance and Bhatt teach the limitations of claim 5, including teaching objective functions. Hance further teaches wherein the objective function includes an evaluation term of a cost of changing an arrangement position of the article (¶ 78, discloses the use of a cost objection function to generate a cost to rearrange a warehouse.) Also taught by Bhatt (¶ 138, 153-154, 212-214). Regarding claim 8, the combination of Hance and Bhatt teach the limitations of claim 5, including teaching objective functions. Hance further teaches wherein the objective function includes an evaluation term of a constraint condition related to an arrangement position of the article (¶ 78, discloses the use of a cost objection function to generate a cost to rearrange a warehouse.) Also taught by Bhatt (¶ 138, 153-154, 212-214). Regarding claim 9, the combination of Hance and Bhatt teach the limitations of claim 5, including teaching objective functions. Hance further teaches wherein the evaluation term of the constraint condition is a function that increases the objective function when the same article is arranged at two or more arrangement positions (¶ 78, discloses optimizing a cost objection function to generate a cost to rearrange a warehouse.) Also taught by Bhatt (¶ 138-139, 153-154, 174, 198, 212-214). Regarding claim 10, Hance teaches an article management method comprising: one or more processors (¶ 3, 4, 41-43, disclose a processor), determining an arrangement position combination of a plurality of articles with respect to a plurality of arrangement positions, wherein the one or more processors (¶ 20, discloses the real-time locations of the pallet items in a warehouse. ¶ 39, 72, 81, discloses choosing an optimal warehouse pallet location. ¶ 55, 61, 62, 23, 75); acquiring an individual picking processing time when each of the plurality of articles is arranged at each of the plurality of arrangement positions (¶ 75-77, discloses the time it takes to perform tasks including moving a pallet. ¶ 46-48); acquiring picking prediction information of the article (¶ 46, 59, disclose the time it takes a robotic device to complete a task. ¶ 32, 48, 23); and determining one arrangement position combination from among the plurality of arrangement position combinations (¶ 32, 76, 81, discloses determining pick up positions. ¶ 48, 54). Hance does not specifically teach evaluating a picking process time. However, Bhatt teaches picking predictions and information, evaluating a combination picking processing time corresponding to a plurality of arrangement position combinations based on the individual picking processing time and the picking prediction information (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on pick time. ¶ 197, 212, 229, Fig. 16s, 21); and determining one arrangement position combination from among the plurality of arrangement position combinations based on the combination picking processing time (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on pick time. ¶ 114, 197, 212, 229, Fig. 16s, 21). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform picking processing time, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying picking processing time would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow additional data to give the user the ability to make educated modifications to the warehouse inventory storage. Regarding claim 11, Hance teaches a non-transitory computer-readable recording medium (¶ 4, 41, 43, 64) having recorded thereon an article management program that determines an arrangement position combination of a plurality of articles arranged at a plurality of arrangement positions, the article management program causing one or more processors to execute (¶ 20, discloses the real-time locations of the pallet items in a warehouse. ¶ 39, 72, 81, discloses choosing an optimal warehouse pallet location. ¶ 3, 4, 41-43, 55, 61, 62, 23, 75); acquiring an individual picking processing time when each of the plurality of articles is arranged at each of the plurality of arrangement positions (¶ 75-77, discloses the time it takes to perform tasks including moving a pallet. ¶ 46-48); acquiring picking prediction information of the article (¶ 46, 59, disclose the time it takes a robotic device to complete a task. ¶ 32, 48, 23); and determining one arrangement position combination from among the plurality of arrangement position combinations (¶ 32, 76, 81, discloses determining pick up positions. ¶ 48, 54). Hance does not specifically teach evaluating a picking process time. However, Bhatt teaches picking predictions and information, evaluating a combination picking processing time corresponding to a plurality of arrangement position combinations based on the individual picking processing time and the picking prediction information (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on pick time. ¶ 197, 212, 229, Fig. 16s, 21); and determining one arrangement position combination from among the plurality of arrangement position combinations based on the combination picking processing time (¶ 23, disclose evaluating pick times based on locations. ¶ 105-108, disclose analyzing product placement based on pick time. ¶ 114, 197, 212, 229, Fig. 16s, 21). It would have been obvious to one of ordinary skill in the art at the time of filing to modify to Hance include/perform picking processing time, as taught/suggested by Bhatt. This known technique is applicable to the system of Hance as they both share characteristics and capabilities, namely, they are directed to warehouse inventory placement management. One of ordinary skill in the art would have recognized that applying the known technique of Bhatt would have yielded predictable results and resulted in an improved system. It would have been recognized that applying the technique of Bhatt to the teachings of Hance would have yielded predictable results because the level of ordinary skill in the art demonstrated by the references applied shows the ability to incorporate such inventory features into similar systems. Further, applying picking processing time would have been recognized by those of ordinary skill in the art as resulting in an improved system that would allow additional data to give the user the ability to make educated modifications to the warehouse inventory storage. Other pertinent prior art includes Li et al. (US 20230062937 A1) discloses an online concierge system generates a suggested picking sequence to reduce the amount of time for a shopper to fulfill an online order of items from a warehouse. Cacioppo (US 20220179416 A1) discloses inventory management and order collection by autonomous vehicles. Janert et al. (US 7243001 B2) automatically generating and using maps based on movement times between locations in warehouse. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAMIE H AUSTIN whose telephone number is (571)272-7363. The examiner can normally be reached Monday, Tuesday, Thursday, Friday 7am-2pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Brian Epstein can be reached at (571) 270 5389. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. JAMIE H. AUSTIN Examiner Art Unit 3625 /JAMIE H AUSTIN/Primary Examiner, Art Unit 3625 Application/Control Number: 19/062,271 Page 2 Art Unit: 3625 Application/Control Number: 19/062,271 Page 3 Art Unit: 3625 Application/Control Number: 19/062,271 Page 4 Art Unit: 3625 Application/Control Number: 19/062,271 Page 5 Art Unit: 3625
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Prosecution Timeline

Feb 25, 2025
Application Filed
Jun 03, 2026
Non-Final Rejection mailed — §101, §103 (current)

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