DETAILED ACTION
Status of the Claims
This office action is submitted in response to the amendment filed on 4/30/26.
Examiner notes that this application claims foreign priority to 2024-039981.
Examiner further notes Applicant’s priority date of 3/14/24, which stems from the aforementioned parent application.
Claims 1-11 have been amended.
Claims 1-11 are currently pending and have been examined.
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 1-11 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Step 1: Claims 1-3, 7, and 9 are directed to a management server, which is a machine. Claims 4-6, 8, and 10-11 are directed to a management system, which is also a machine. Thus, claims 1-11 fall within the statutory categories of 35 U.S.C. 101. See MPEP § 2106.03.
Step 2A, Prong One: Step 2A, Prong One: Independent claims 1 and 4, in part, recite: managing, for each of one or more projectors, a first management information; extracting, referring to the first management information, start propriety information corresponding to a device identification information included in the first inquiry request; determining a remaining time of the projector; wherein the first management information associates the device identification information to identify the projector with the start propriety information; and the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors. Independent claim 4 further recites generating the first inquiry request based on operation of a user of the first projector and processing a start procedure of the first projector based on the first inquiry response. As such, the invention is directed to the abstract idea of managing/controlling (i.e., turning on or off) a projector to be viewed by a user based on their subscription status, payment history, and remaining authorized usage time, which, pursuant to MPEP § 2106.04(a), is aptly categorized as a method of organizing human activity (commercial transactions, contractual relationships, and subscription-based access control) as well as a mental process (comparing device identification information to stored records, determining remaining authorized usage time, retrieving corresponding authorization data, and determining whether to grant or deny access based on that data).
The aforementioned claims also recite additional elements that are associated with the judicial exception, including: acquiring a first inquiry request, wherein the first inquiry request comprises inquiring, from the first projector, a propriety of a start of the first projector (claim 1 — data transmission); outputting the start propriety information indicating the propriety of the start of the first projector (claim 1 — providing output); transmitting the first inquiry request to the management server (claim 4 — data transmission); receiving a first inquiry response including the start propriety information from the management server (claim 4 — data transmission); notifies a third expiration date of use of the first projector to the user of the first projector (claim 10 — providing output); and a display device and a display controller configured to cause the display device to display the third expiration date of use (claim 11 — displaying data). Examiner understands these limitations to be insignificant extra-solution activity. See Accenture, 728 F.3d 1336, 108 U.S.P.Q.2d 1173 (Fed. Cir. 2013), citing Cf. Diamond v. Diehr, 450 U.S. 175, 191-192 (1981) ("[I]nsignificant post-solution activity will not transform an unpatentable principle into a patentable process.").
The aforementioned claims also recite additional elements including: a management server; projectors; light sources for the projectors; and an information management device. These limitations are recited at a high level of generality and appear to be nothing more than generic computer components (a server, a projector device, a database management device) used to automate the mental processes of looking up subscription records, determining remaining usage time, and authorizing device usage, with the abstract idea merely being applied to projector hardware in a subscription-based device-control context as a field-of-use limitation. See MPEP § 2106.05(h). Claims that amount to nothing more than an instruction to apply the abstract idea using a generic computer do not render an abstract idea eligible. Alice Corp., 134 S. Ct. at 2358, 110 USPQ2d at 1983. See also 134 S. Ct. at 2389, 110 USPQ2d at 1984.
The amended limitations reciting the start propriety information controls whether a light source for each of the one or more projectors turns on, and the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors are additional elements recited at a high level of generality. The claimed relationship between the light source and its functionality — that the authorization determination controls whether the light source turns on — merely applies the result of the abstract idea's authorization logic to that generic hardware component. This amounts to nothing more than an instruction to "apply it" on generic hardware. See MPEP § 2106.05(f). The claims do not recite any particular manner of controlling the light source that would improve projector technology or provide a technical solution to a technical problem; rather, the light source is simply the hardware to which the authorization decision is applied.
Step 2A, Prong Two: Looking at the elements individually and in combination, under Step 2A, Prong Two, the claims as a whole do not integrate the judicial exception into a practical application because they fail to: improve the functioning of a computer or a technical field, apply the judicial exception in the treatment or prophylaxis of a disease, apply the judicial exception with a particular machine, effect a transformation or reduction of a particular article to a different state or thing, or apply the judicial exception beyond generally linking the use of the judicial exception to a particular technological environment. Rather, the claims merely use database lookup and comparison processes to perform subscription-based authorization and remaining-time-based access control, merely using a computer as a tool to perform the abstract idea(s), and/or add insignificant extra-solution activity to the judicial exception (e.g., acquiring inquiry requests, outputting start propriety information, transmitting inquiry requests and responses, notifying the user of expiration dates, displaying expiration dates), and/or generally link the use of the judicial exception to a particular technological environment (e.g., a generic server-client system controlling projector startup based on subscription status and remaining usage time).
Applicant's amended limitations adding determining a remaining time of the projector and the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors do not integrate the abstract idea into a practical application because determining remaining authorized usage time is part of the abstract idea itself (it is the core authorization logic of checking whether a user's time-based subscription entitlement is sufficient to permit device startup), and applying that determination to control whether a generic light source turns on merely uses the projector's light source as a tool to implement the abstract idea's authorization result. The claims do not recite any particular manner of controlling the light source that improves projector technology or provides a technical solution to a technical problem; rather, the light source is simply the hardware to which the authorization decision is applied.
Step 2B: Additionally, pursuant to the requirement under Berkheimer, the following citations are provided to demonstrate that the additional elements, identified as extra-solution activity, amount to activities that are well-understood, routine, and conventional. See MPEP § 2106.05(d).
Receiving and transmitting data over a network (acquiring inquiry requests, receiving inquiry responses, transmitting inquiry requests and responses): Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362; OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93.
Outputting/presenting data to a user (outputting start propriety information, notifying user of expiration date, displaying expiration date): Mayo, 566 U.S. at 79, 101 USPQ2d at 1968; OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1092-93 (Fed. Cir. 2015); MPEP § 2106.05(g)(3).
Thus, taken alone and in combination, the additional elements do not amount to significantly more than the above-identified judicial exception (the abstract idea), and the independent claims are ineligible under 35 U.S.C. 101.
Dependent Claims: Claims 2-3, 5-11 are dependent on the aforementioned independent claims and include the following additional limitations:
Claims 2 and 3 further limit the abstract idea. Managing the start propriety information based on payment history information that is a history of fees that one or more users who use the one or more projectors paid in order to use the one or more projectors (claim 2) and managing the start propriety information based on time information indicating a start possible time that is a time length in which one or more users who use the one or more projectors can start the one or more projectors (claim 3) merely specify the types of data consulted to determine authorization status — payment fees and time lengths — which are variations on the fundamental practice of granting or denying access based on whether a user has paid or whether their subscription time remains. These are well-known data inputs to authorization decisions and do not provide significantly more than the underlying abstract idea.
Claims 5 and 6 further limit the abstract idea. The first projector starts into an unusable state that is state limited a content projection function, when transmitting the first inquiry request to the management server did not succeed (claim 5) and the first projector starts into an unusable state that is state limited a content projection function, when receiving the first inquiry response from the management server did not succeed (claim 6) merely apply generic fail-safe conditional logic — if communication fails, restrict device functionality — which is a well-known programming technique that does not provide significantly more than the underlying abstract idea.
Claim 7 further limits the abstract idea. Setting a first expiration date of use of the one or more projectors; determining whether a present point in time passed the first expiration date of use; setting a second expiration date of use later than the first expiration date of use according to the payment history information; and managing the start propriety information corresponding to the first projector, based on the second expiration date of use of the first projector, when the present point in time passed the first expiration date of use of the first projector merely involve date-time comparisons and conditional branching based on payment records — well-known data management operations that do not provide significantly more than the underlying abstract idea.
Claim 8 further limits the abstract idea and adds extra-solution activity. Managing the payment history information for each of one or more projectors; extracting the payment history information corresponding to the user of the first projector by referring to the payment history information managed by the management unit using the user identification information for identifying the user of the first projector; and the payment history information includes user identification information for identifying the one or more users merely specify data management operations — looking up and retrieving payment records using user identification — which are well-known database operations that do not provide significantly more than the underlying abstract idea. Acquiring, from the management server, a second inquiry request including the user identification information for identifying a user of the first projector and transmitting, to the management server, a second inquiry response including the payment history information corresponding to the user of the first projector extracted by the extraction unit are extra-solution data-transmission activity that is well-understood, routine, and conventional per Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362. The recitation of an information management device configured to manage information concerning the one or more users adds a generic computer component at a high level of generality that does not provide significantly more.
Claim 9 further limits the abstract idea. Determining whether a present point in time is within a maintenance period of the management server, wherein the management server associates the device identification information of the first projector and start propriety information indicating that propriety of a start of the first projector is appropriate, when the present point in time is within the maintenance period merely involves a time-window comparison and conditional override logic (if the current time is within a maintenance window, set authorization to "appropriate"), which is a well-known scheduling and conditional-branching operation that does not provide significantly more than the underlying abstract idea.
Claims 10 and 11 further limit the abstract idea and add extra-solution activity. The first projector processes the start procedure of the first projector and notifies a third expiration date of use of the first projector to the user of the first projector, when receiving the first inquiry response from the management server, that the communication control unit did not successfully receive the first inquiry response (claim 10) involves fallback conditional logic (if communication fails, continue startup and notify user of expiration date), which is well-known conditional branching applied to generic data output. The first projector further includes: a display device; and a display controller configured to cause the display device to display the third expiration date of use (claim 11) adds generic display hardware for presenting data to a user, which is well-understood, routine, and conventional per Mayo, 566 U.S. at 79, 101 USPQ2d at 1968; OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93. See MPEP § 2106.05(d).
Therefore, claims 1-11 are not drawn to eligible subject matter, as they are directed to an abstract idea without significantly more.
Claim Rejections - 35 USC § 103
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.
Claims 1 and 4 are rejected under 35 U.S.C. 103 as being unpatentable over Seiler (US 2019/0391817 A1) in view of Ozawa (US 8,992,027 B2) and further in view of Ricket (US 8,355,805 B2).
Claim 1: Seiler discloses a management server configured to execute one or more operations, the operations comprising: (Abstract; Paragraphs 16, 31, 39; Figs. 1, 4-5; authentication server 199, 499, 599 manages device authentication across a network)
managing … a first management information (Paragraphs 31, 43-44; the authentication server manages authentication information for devices, including encrypted keys and authentication states);
acquiring a first inquiry request, wherein the first inquiry request comprises inquiring, from the first [device], a propriety of a start of the first [device] (Paragraphs 16, 24, 31; claims 1, 8; devices establish a connection with the authentication server over a network and transmit an encrypted key during boot/startup; the authentication server receives these authentication requests to determine whether the device is permitted to start);
extracting, referring to the first management information, start propriety information corresponding to a device identification information included in the first inquiry request (Paragraphs 16, 24, 31; claim 1; the authentication server validates the encrypted key received from the device against stored authentication information to determine whether the device is authorized to boot);
outputting the start propriety information indicating the propriety of the start of the first [device] (Paragraphs 24, 31; claims 1, 8-9; the authentication server responds to the device indicating whether boot is permitted to proceed or denied); and
wherein the first management information associates the device identification information to identify the [device] with the start propriety information (Paragraphs 16, 24, 31; the authentication server associates each device's encrypted key with an authentication state that determines whether startup is permitted).
Seiler does not disclose that the devices are one or more projectors or the first projector, does not disclose determining a remaining time of the projector, does not disclose that the start propriety information controls whether a light source for each of the one or more projectors turns on, and does not disclose that the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors.
Ozawa, however, discloses managing, for each of one or more projectors, a first management information (col. 2, ll. 1-8; col. 3, ll. 21-40, 45-62; claim 1; a projector modulates and projects light emitted from a light source according to image information; multiple projectors PJ1, PJ2, PJ3 can be connected; use permission information P1 and identification information 21a, 21b are managed for the projectors);
acquiring a first inquiry request, wherein the first inquiry request comprises inquiring, from the first projector, a propriety of a start of the first projector (col. 4, ll. 33-48; Fig. 3, steps S101-S103; the user operates a power key on input operation unit 23 to power on the projector and trigger an authentication process);
extracting, referring to the first management information, start propriety information corresponding to a device identification information included in the first inquiry request (col. 3, ll. 45-62; col. 4, ll. 1-30; the receiving projector checks whether received second identification information 21b coincides with its first identification information 21a to determine whether to become available for use);
the start propriety information controls whether a light source for each of the one or more projectors turns on (col. 3, ll. 8-20; col. 5, ll. 45-52; col. 6, ll. 37-55; Fig. 3, steps S107, S113-S117; light source control unit 25 controls light source 11 to supply or stop power; when use permission information P1 is received and validated, the projector proceeds to project an image at step S107, turning on the light source; when use permission information is not received or does not match, the projector powers off to a standby state at step S117 without turning on the light source); and
wherein the first management information associates the device identification information to identify the projector with the start propriety information (col. 3, ll. 45-62; col. 4, ll. 1-30; first identification information 21a identifies the projector and is checked against use permission information P1 and second identification information 21b).
Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to combine these features of Ozawa with those of Seiler. One would have been motivated to do this in order to apply Seiler's centralized server-based authentication architecture to the projector management context of Ozawa, thereby enabling a remote management server to control startup authorization for multiple projectors based on validated device identification information and use permission status.
Next, the Seiler/Ozawa combination does not appear to explicitly disclose determining a remaining time of the projector or that the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors.
Ricket, however, discloses determining a remaining time of the [appliance] (claim 1; col. 2, ll. 63-col. 3, l. 10; col. 5, ll. 58-col. 6, l. 14; Fig. 6, steps 604-612; Fig. 7; the system tracks usage of an appliance against a threshold amount, the threshold amount being defined as a period of time during which the appliance is to be in the enabled state or an amount of time for which the appliance is usable in the enabled state; the specification discloses that usage may be tracked by the passage of time, where an installment plan may grant a user one month of usage per payment, or may be tracked as an amount of time of active use, where an installment plan may grant a user 20 hours of active use for a $5.00 payment; the system periodically calculates a current usage fee, subtracts the fee from a current balance, and determines whether the balance is greater than zero).
It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to incorporate Ricket's time-based usage threshold into the Seiler/Ozawa startup-authorization framework so that the management server determines whether sufficient authorized remaining usage time exists for a projector and sets the start propriety information accordingly, such that the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors. One would have been motivated to do this in order to implement a consumable time-based pay-per-use model for projector access, thereby enabling the management server to gate projector startup based on whether the user has sufficient remaining authorized usage time and disabling the projector's light source when that time is exhausted.
Claim 4: The Seiler/Ozawa/Ricket combination discloses those limitations cited above.
Seiler further discloses a management system comprising: the management server … and the first [device] (Abstract; Paragraphs 16, 31, 39; Figs. 1, 4-5; the system includes authentication server and devices that communicate over a network);
transmitting the first inquiry request to the management server (Paragraphs 16, 24, 31; claim 1; the device establishes a connection with the authentication server and transmits an encrypted key for authentication);
receiving a first inquiry response including the start propriety information from the management server (Paragraphs 24, 31; claims 1, 8-9; the device receives an authentication response indicating whether boot is permitted); and
processing a start procedure of the first [device] based on the first inquiry response (Paragraphs 24, 31; claims 1, 8; upon receiving the authentication response, the device proceeds with boot if authentication succeeds or initiates a security procedure preventing startup if authentication fails).
Seiler does not disclose the first projector or generating the first inquiry request based on operation of a user of the first projector.
Ozawa, however, discloses the first projector (col. 2, ll. 1-8; col. 3, ll. 21-40);
generating the first inquiry request based on operation of a user of the first projector (col. 4, ll. 33-48; Fig. 3, steps S101-S103; the user operates a power key on input operation unit 23 to power on the projector and trigger the authentication process); and
processing a start procedure of the first projector based on the first inquiry response (col. 5, ll. 45-52; col. 6, ll. 37-55; Fig. 3, steps S107, S117; use permission information governs whether the projector becomes available for use or returns to standby).
The rationale for combining Ozawa and Ricket with Seiler is articulated in the rejection of claim 1 above and is incorporated herein by reference.
Claims 5-6 are rejected under 35 U.S.C. 103 as being unpatentable over Seiler (US 2019/0391817 A1) in view of Ozawa (US 8,992,027 B2) and Ricket (US 8,355,805 B2) and further in view of Yadav (US 7,750,923 B2).
Claim 5: The Seiler/Ozawa/Ricket combination discloses those limitations cited above, but does not explicitly disclose the first projector starts into an unusable state that is state limited a content projection function, when transmitting the first inquiry request to the management server did not succeed.
Yadav, however, discloses the first projector starts into an unusable state that is state limited a content projection function, when transmitting the first inquiry request to the management server did not succeed (col. 5, ll. 45-67; col. 6, ll. 25-40; Fig. 7, steps 705, 714-716; Fig. 8; a display device enters a limited function mode upon detecting a communication error with a computer greater than a specified error threshold; in the limited function mode, the display device is powered on and operating but output to a portion of the screen is disabled; the display device may enter the limited function mode on initial power-up, corresponding to the projector starting into the unusable state when the transmission of the inquiry request did not succeed).
It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to incorporate Yadav's limited-function-mode behavior into the Seiler/Ozawa/Ricket projector management framework to provide a limited-function startup mode upon communication failure associated with authorization exchange. One would have been motivated to do this in order to provide a degraded operating mode that restricts the projector's content projection function until communication with the management server can be established.
Claim 6: The Seiler/Ozawa/Ricket combination discloses those limitations cited above, but does not explicitly disclose the first projector starts into an unusable state that is state limited a content projection function, when receiving the first inquiry response from the management server did not succeed.
Yadav, however, discloses the first projector starts into an unusable state that is state limited a content projection function, when receiving the first inquiry response from the management server did not succeed (col. 5, ll. 45-67; col. 6, ll. 25-40; Fig. 7, steps 714-716; Fig. 8; a display device enters a limited function mode upon detecting a communication timeout with a computer greater than a specified time duration; in the limited function mode, the display device is powered on and operating but output to a portion of the screen is disabled; the communication timeout corresponds to the projector not successfully receiving the inquiry response from the management server).
The rationale for combining Yadav with Seiler/Ozawa/Ricket is articulated above and reincorporated herein by reference.
Claims 2-3, 7-8, and 10-11 are rejected under 35 U.S.C. 103 as being unpatentable over Seiler (US 2019/0391817 A1) in view of Ozawa (US 8,992,027 B2) and Ricket (US 8,355,805 B2) and further in view of Phatak (US 2018/0063564 A1).
Claim 2: The Seiler/Ozawa/Ricket combination discloses the limitations of claim 1 as set forth above, but does not explicitly disclose the operations further comprising managing the start propriety information based on payment history information that is a history of fees that one or more users who use the one or more projectors paid in order to use the one or more projectors.
Phatak, however, discloses managing … information based on payment history information that is a history of fees that one or more users … paid in order to use [devices] (Paragraphs 22, 42, 61-64; Table 2; the subscription service manages authorization and entitlements based on payment status; the payment service provider processes subscription payments; the subscription service communicates with the payment service provider to confirm that authenticated subscribers are authorized to receive content based on whether payment has been made).
It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to combine these features of Phatak with those of Seiler, Ozawa, and Ricket. One would have been motivated to do this in order to manage projector start authorization based on subscriber payment status, thereby ensuring that the start propriety information is managed based on payment history information that is a history of fees that one or more users who use the one or more projectors paid in order to use the one or more projectors.
Claim 3: The Seiler/Ozawa/Ricket combination discloses those limitations cited above.
Ricket further discloses managing the start propriety information based on time information indicating a start possible time that is a time length in which one or more users who use the one or more [appliances] can start the one or more [appliances], as set forth in the rejection of claim 1 above (claim 1; col. 2, ll. 63-col. 3, l. 10; the threshold amount is defined as a period of time during which the appliance is to be in the enabled state or an amount of time for which the appliance is usable in the enabled state; the specification discloses examples including one month of usage per payment and 20 hours of active use for a $5.00 payment).
Phatak further discloses managing … information based on time information indicating a start possible time that is a time length in which one or more users … can [access devices] (Paragraphs 31, 70; Tables 2-3; the subscription service manages time-based subscriptions that define time periods during which users are authorized to access content, including subscription terms such as monthly, quarterly, and yearly durations).
The rationale for combining Seiler, Ozawa, Ricket, and Phatak is articulated above and reincorporated herein by reference.
Claim 7: The Seiler/Ozawa/Ricket/Phatak combination discloses those limitations cited above.
Phatak further discloses the operations further comprising: setting a first expiration date of use of the one or more [devices] (Paragraph 70; Table 3; the subscription service sets activation dates and end dates for subscription plans);
determining whether a present point in time passed the first expiration date of use (Paragraphs 22, 42; the subscription service checks whether a subscriber is authorized by determining current subscription status and whether the subscription has expired);
setting a second expiration date of use later than the first expiration date of use according to the payment history information (Paragraphs 22, 42; Table 2; the subscription service manages auto-renewal; the payment service provider processes subscription payments and the subscription service extends access based on payment status); and
managing the start propriety information corresponding to the first projector, based on the second expiration date of use of the first projector, when the present point in time passed the first expiration date of use of the first projector (Paragraphs 22, 26, 42; the subscription service manages entitlements based on subscription status and expiration dates; when a subscription expires, the system checks for renewal and updates authorization based on the new subscription period).
The rationale for combining Phatak with Seiler, Ozawa, and Ricket is articulated above and incorporated herein by reference.
Claim 8: The Seiler/Ozawa/Ricket/Phatak combination discloses those limitations cited above.
Phatak further discloses an information management device configured to manage information concerning the one or more users (Paragraphs 39-41, 60-61; Fig. 1; payment service provider 110 manages user subscription and payment information);
the payment history information includes user identification information for identifying the one or more users (Paragraphs 58-59; Tables 1-2; the subscription and payment information includes subscriber identification such as username, email address, and subscriber name);
the information management device executes one or more operations, the operations comprising: managing the payment history information for each of one or more projectors (Paragraphs 42, 61-62; the payment service provider manages payment processing and subscription information on a per-subscriber basis; as each subscriber is associated with the device the subscriber seeks to operate, Phatak's per-subscriber entitlement management corresponds to managing payment history information for each projector);
acquiring, from the management server, a second inquiry request including the user identification information for identifying a user of the first projector, the second inquiry request inquiring the payment history information corresponding to the user of the first projector (Paragraphs 8-9, 22, 42; the subscription service transmits an entitlement check request including subscriber information to the payment service provider to determine whether the subscriber is authorized);
extracting the payment history information corresponding to the user of the first projector by referring to the payment history information managed by the management unit using the user identification information for identifying the user of the first projector (Paragraphs 22, 42, 66-67; the payment service provider retrieves entitlement information and subscription status from a distributed cache or database using subscriber identification information); and
transmitting, to the management server, a second inquiry response including the payment history information corresponding to the user of the first projector extracted by the extraction unit (Paragraphs 8-9, 22, 42; the payment service provider responds to the subscription service with an entitlement check response indicating whether the subscriber is authorized based on payment and subscription status).
The rationale for combining Seiler, Ozawa, Ricket, and Phatak is articulated above and reincorporated herein by reference.
Claim 10: The Seiler/Ozawa/Ricket combination discloses those limitations cited above, but does not explicitly disclose the first projector processes the start procedure of the first projector and notifies a third expiration date of use of the first projector to the user of the first projector, when receiving the first inquiry response from the management server, that the communication control unit did not successfully receive the first inquiry response.
Ozawa discloses the first projector processes the start procedure of the first projector … when … the communication control unit did not successfully receive the first inquiry response (col. 6, ll. 20-36; Fig. 3, steps S110-S112, S116; when the projector does not receive use permission information within a predetermined time, the projector displays a warning message to the user and shifts to an authentication mode rather than shutting down, thereby continuing a start procedure upon communication failure).
Ricket discloses notifies … the user of the first projector of authorization-time status (col. 6, ll. 5-14; Fig. 6, step 614; when an appliance is placed in a disabled state based on time-based usage thresholds, the system displays a message prompting the user to purchase more credit).
Phatak discloses a third expiration date of use of the first projector (Paragraph 70; Table 3; the subscription service manages expiration dates for subscription periods, including end dates that define when user access expires).
The rationale for combining Seiler, Ozawa, Ricket, and Phatak is articulated above and reincorporated herein by reference.
Claim 11: The Seiler/Ozawa/Ricket/Phatak combination discloses those limitations cited above.
Ozawa further discloses the first projector further includes: a display device; and a display controller configured to cause the display device to display … [information] (col. 3, ll. 8-20; col. 6, ll. 46-55; Figs. 1, 4A-4C; the projector includes OSD processing unit 16 and image projection unit 10; the OSD processing unit functions as a display controller to display warning messages M1, M2, M3 on screen SC via the projection system).
The rationale for combining Seiler, Ozawa, Ricket, and Phatak is articulated above and reincorporated herein by reference.
Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Seiler (US 2019/0391817 A1) in view of Ozawa (US 8,992,027 B2) and Ricket (US 8,355,805 B2) and further in view of Pulaski (US 10,042,677 B2) and Andersson (US 2023/0336543 A1).
The Seiler/Ozawa/Ricket combination discloses those limitations cited above, but does not explicitly disclose the operations further comprising determining whether a present point in time is within a maintenance period of the management server, wherein the management server associates the device identification information of the first projector and start propriety information indicating that propriety of a start of the first projector is appropriate, when the present point in time is within the maintenance period.
Pulaski, however, discloses determining whether a present point in time is within a maintenance period of [a] management server (col. 5, ll. 1-15; col. 6, ll. 4-16, 39-63; Fig. 3, steps 305, 310; the system stores a maintenance schedule indicating a period of time during which maintenance is scheduled to occur on a server and determines whether a scheduled time is within the maintenance period).
It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to incorporate Pulaski's maintenance-period determination into the Seiler/Ozawa/Ricket management server so that the management server determines whether a present point in time is within a maintenance period of the management server. One would have been motivated to do this in order to enable the management server to recognize when it is undergoing scheduled maintenance and adjust its handling of projector startup requests accordingly.
Andersson further discloses the management server associates the device identification information of the first [device] and start propriety information indicating that propriety of a start of the first [device] is appropriate, when the present point in time is within the [authorized] period (Paragraphs 0035, 0039-0041; Fig. 3B; the authorization server sends access tokens with permission values defining access time periods and refresh tokens defining refresh time periods to a first computing device, which stores the tokens and can then authorize second computing devices to access computing services even while the authorization server is offline or otherwise unable to be reached; Paragraph 41 discloses a scenario where the authorization server has only intermittent connectivity and proactively provides authorization tokens during its connectivity window so devices can operate during periods when real-time communication with the authorization server is not available).
It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to incorporate Andersson's pre-granted authorization into the Seiler/Ozawa/Ricket/Pulaski combination so that the management server associates the device identification information of the first projector and start propriety information indicating that propriety of a start of the first projector is appropriate, when the present point in time is within the maintenance period. One would have been motivated to do this in order to ensure that projectors can start during scheduled management server maintenance windows by pre-associating startup authorization with device identification, rather than denying all projector startups when the management server is undergoing maintenance and unable to process authorization requests in real time.
Other Relevant Prior Art
Though not cited in the above rejections, the following references are nevertheless deemed to be relevant to Applicant’s disclosures:
Zhang et al. (12113804), directed to a method for authorized use of a projector.
Miller et al. (20140150080), directed to a method for authorizing access to digital content.
Suzuki et al. (12412207), directed to a registration apparatus and control method.
Li et al. (20190147441), directed to a method and device for providing and obtaining graphic code information.
Prasad et al. (11763305), directed to a distribution ledger for device management.
Response to Arguments
Applicant’s arguments regarding the sufficiency of the claims under 35 USC 101 are unpersuasive.
First, Applicant argues that amended claim 1 specifically controls whether a light source of a projector turns on based on a calculation of time remaining on the projector, and that such activities cannot practically be performed in the human mind, so claim 1 does not recite an abstract idea under Step 2A, Prong One. Examiner disagrees.
The amended limitations — determining a remaining time of the projector; the start propriety information controls whether a light source for each of the one or more projectors turns on; and the remaining time determines whether the start proprietary information turns on the light source for each of the one or more projectors — do not remove the claims from the enumerated groupings of abstract ideas. The core of the claim remains the authorization decision: managing subscription/authorization records, looking up a device's authorization status, determining whether sufficient remaining time exists, and deciding whether to permit startup. That a human cannot physically turn on a projector's light source with their mind does not mean the underlying decision logic — checking a remaining-time balance against a threshold and granting or denying access based on the result — is not a mental process. The mental-process inquiry focuses on whether the claimed concept can be performed in the human mind or with pen and paper, not on whether the physical hardware action resulting from the decision can be so performed. See MPEP § 2106.04(a)(2)(III). A person could mentally determine a remaining time, compare it to a threshold, and decide whether to permit a projector to start. The fact that the authorization decision is then applied to a light source does not change the character of the underlying abstract idea; it merely specifies the hardware to which the decision is applied. See MPEP § 2106.05(f).
Applicant further argues that, even if the concepts constitute an abstract idea, claim 1 integrates the abstract idea into a practical application under Step 2A, Prong Two, by analogy to USPTO Example 25 (the Arrhenius equation applied to rubber molding). Applicant contends that, like Example 25, claim 1 recites a tangible act — controlling the actual light of the projector — that integrates the abstract idea into the start process for projectors. Examiner disagrees.
Example 25 is distinguishable because the claims in that example used the mathematical calculation (the Arrhenius equation) to control a specific industrial process — curing rubber — in a way that improved the molding process itself. The meaningful limits in Example 25 were the specific steps of constantly measuring the temperature inside the mold, feeding the measurements into the Arrhenius equation, and automatically opening the mold press at the precise moment calculated by the equation. Those steps integrated the mathematical calculation into the rubber-curing process by improving the process's precision and outcome. Here, by contrast, the amended claim limitations do not improve the functioning of the projector or the projection process itself. The claims do not recite any particular manner of controlling the light source that improves projector technology; rather, the light source limitation merely specifies that the authorization result (start propriety information) is applied to a generic projector component (the light source) to either permit or deny startup. This is analogous to applying a calculated result to turn a generic switch on or off — it does not integrate the abstract idea into the projector's operation in the way that Example 25's claims integrated the Arrhenius equation into the rubber-molding process. The specification confirms this understanding: paragraph [0078] of applicant's specification discloses that the start propriety information controls whether the light source turns on, but does not describe any particular technical improvement to the projector's light-source control mechanism, the projection process, or projector hardware. The light source is simply the hardware to which the binary authorization decision (permit/deny) is applied.
Applicant further argues, assuming arguendo that claim 1 is found ineligible under both prongs of Step 2A, that the claim elements amount to significantly more under Step 2B because controlling whether a light source turns on is not managing data in a database, performing database lookups, or outputting data to a user, and that operating a projector is very different from "presenting offers and gathering statistics." Examiner disagrees.
Examiner does not characterize the light-source control limitation as managing data, performing database lookups, or outputting data. Rather, the light-source control limitation is an additional element treated as an instruction to "apply it" — to apply the abstract idea's authorization result to a generic hardware component (the projector's light source) at a high level of generality. See MPEP § 2106.05(f). The Berkheimer analysis in the rejection addresses the extra-solution activity of receiving and transmitting data over a network and outputting/presenting data to a user, which are well-understood, routine, and conventional per Symantec, Mayo, and OIP Techs. The light-source limitation is addressed separately as a generic hardware element that does not amount to significantly more because it merely specifies the hardware endpoint to which the authorization decision is applied, without reciting any particular technological improvement to the projector, the light source, or the projection process. Accordingly, the claims do not amount to significantly more than the abstract idea.
Applicant’s arguments regarding the rejections under 35 USC 103 have been fully considered, but are rendered moot in view of the new grounds of rejection cited above, which were necessitated by the amendments.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTOPHER BUSCH whose telephone number is (571)270-7953. The examiner can normally be reached M-F 10-7.
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/CHRISTOPHER C BUSCH/Examiner, Art Unit 3621
/WASEEM ASHRAF/Supervisory Patent Examiner, Art Unit 3621
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