DETAILED ACTION
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 .
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.
Claim Status
This action is in response to applicant’s filing on 6/9/2025. Claims 1-20 are pending and considered 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 1-20 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 integrating the judicial exception into a practical application and without an additional element which amounts to significantly more than the judicial exception.
Regarding claims 1-10, step 1 analysis, the subject matter of claims 1-10 is included in the four patent-eligible subject matter categories (e.g., process, machine, manufacture or composition of matter). Claims 1-10 are directed to a device (a transceiver and a processing module).
Claims 1-10 are directed to a judicial exception. The claim limitations recite a revised step 2A, prong one, abstract idea (a mental process involving observation and evaluation which could be performed in the human mind). Claims 1-10 are directed to a device for applying spatial and temporal filter constraints to agricultural data; and computing a difference between actual execution of one or more parameters of the operational phase of an agricultural prescription and expected execution of the one or more parameters of the operational phase of the agricultural prescription. This limitation is a simple process that, under the broadest reasonable interpretation, covers performance of the limitation in the mind. For example, the claims encompass a farmer comparing data regarding current water usage for a specific field and season with historic water usage data for the same field and season. Thus, the claims recite a mental process.
Claims 1-10 include the revised step 2A, prong two, additional elements of receiving sensor data and/or controller data; and transmitting a settings alert. Receiving sensor data and/or controller data is insignificant data gathering. Transmitting a settings alert is insignificant post-solution activity. Claims 1-10 do not recite revised step 2A, prong two, additional elements that integrate the abstract idea into a practical application. Claims 1-10 generally link the use of the abstract idea to a particular technological environment or field of use (control systems for farm equipment).
Claims 1-10 include the step 2B additional elements of a transceiver and a processing module. Applicant’s specification does not provide any indication that the transceiver and processing module are anything other than conventional transceivers and processing modules. Receiving and transmitting data is a well-understood, routine and conventional function when claimed using a generic transceiver. Filtering and computing data is a well-understood, routine and conventional function when claimed using a generic processing module. Transceivers and processing modules are widely prevalent and in common use in farm equipment control systems. Transceivers and processing modules are not significantly more than the judicial exception since they are well-understood, routine and conventional features previously known to the farm equipment industry. Therefore, claims 1-10 are rejected under 35 U.S.C. 101.
Regarding claims 11-12, step 1 analysis, the subject matter of claims 11-12 is included in the four patent-eligible subject matter categories. Claims 11-12 are directed to a device (a transceiver; a processing module; and one or more sensors and/or an actuator set).
Claims 11-12 are directed to a judicial exception. The claim limitations recite a revised step 2A, prong one, abstract idea (a mental process involving observation and evaluation which could be performed in the human mind). Claims 11-12 are directed to a device for applying spatial and temporal filter constraints to agricultural data; and computing a difference between actual execution of one or more parameters of the operational phase of an agricultural prescription and expected execution of the one or more parameters of the operational phase of the agricultural prescription. This limitation is a simple process that, under the broadest reasonable interpretation, covers performance of the limitation in the mind. For example, the claims encompass a farmer comparing data regarding current water usage for a specific field and season with historic water usage data for the same field and season. Thus, the claims recite a mental process.
Claims 11-12 include the revised step 2A, prong two, additional elements of receiving sensor data and/or controller data; and transmitting a settings alert. Receiving sensor data and/or controller data is insignificant data gathering. Transmitting a settings alert is insignificant post-solution activity. Claims 11-12 do not recite revised step 2A, prong two, additional elements that integrate the abstract idea into a practical application. Claims 11-12 generally link the use of the abstract idea to a particular technological environment or field of use (control systems for farm equipment).
Claims 11-12 include the step 2B additional elements of a transceiver; a processing module; and one or more sensors and/or an actuator set. Applicant’s specification does not provide any indication that the transceiver; processing module; and sensors and/or actuator set are anything other than conventional transceivers, processing modules, sensors and actuators. Receiving and transmitting data is a well-understood, routine and conventional function when claimed using a generic transceiver. Filtering and computing data is a well-understood, routine and conventional function when claimed using a generic processing module. Transceivers, processing modules, sensors and actuators are widely prevalent and in common use in farm equipment control systems. Transceivers, processing modules, sensors and actuators are not significantly more than the judicial exception since they are well-understood, routine and conventional features previously known to the farm equipment industry. Therefore, claims 11-12 are rejected under 35 U.S.C. 101.
Regarding claims 13-18, step 1 analysis, the subject matter of claims 13-18 is included in the four patent-eligible subject matter categories. Claims 13-18 are directed to a method.
Claims 13-18 are directed to a judicial exception. The claim limitations recite a revised step 2A, prong one, abstract idea (a mental process involving observation and evaluation which could be performed in the human mind). Claims 13-18 are directed to a method for applying spatial and temporal filter constraints to agricultural data; and computing a difference between actual execution of one or more parameters of the current operational phase of an agricultural prescription and expected execution of the one or more parameters of the current operational phase of the agricultural prescription. This limitation is a simple process that, under the broadest reasonable interpretation, covers performance of the limitation in the mind. For example, the claims encompass a farmer comparing data regarding current water usage for a specific field and season with historic water usage data for the same field and season. Thus, the claims recite a mental process.
Claims 13-18 include the revised step 2A, prong two, additional elements of receiving sensor data and/or controller data; transmitting a settings alert; receiving an updated agricultural prescription; and transmitting controller data. Receiving sensor data and/or controller data; and receiving an updated agricultural prescription is insignificant data gathering. Transmitting a settings alert; and transmitting controller data is insignificant post-solution activity. Claims 13-18 do not recite revised step 2A, prong two, additional elements that integrate the abstract idea into a practical application. Claims 13-18 generally link the use of the abstract idea to a particular technological environment or field of use (control systems for farm equipment).
Claims 13-18 do not include any step 2B additional elements. Therefore, claims 13-18 are rejected under 35 U.S.C. 101.
Regarding claims 19-20, step 1 analysis, the subject matter of claims 19-20 is included in the four patent-eligible subject matter categories. Claims 19-20 are directed to a device (a non-transitory computer-readable storage medium and at least one processor).
Claims 19-20 are directed to a judicial exception. The claim limitations recite a revised step 2A, prong one, abstract idea (a mental process involving observation and evaluation which could be performed in the human mind). Claims 19-20 are directed to a device for applying spatial and temporal filter constraints to agricultural data; and computing a difference between actual execution of one or more parameters of the current operational phase of an agricultural prescription and expected execution of the one or more parameters of the current operational phase of the agricultural prescription. This limitation is a simple process that, under the broadest reasonable interpretation, covers performance of the limitation in the mind. For example, the claims encompass a farmer comparing data regarding current water usage for a specific field and season with historic water usage data for the same field and season. Thus, the claims recite a mental process.
Claims 19-20 include the revised step 2A, prong two, additional elements of receiving sensor data and controller data; and transmitting a settings alert. Receiving sensor data and controller data is insignificant data gathering. Transmitting a settings alert is insignificant post-solution activity. Claims 19-20 do not recite revised step 2A, prong two, additional elements that integrate the abstract idea into a practical application. Claims 19-20 generally link the use of the abstract idea to a particular technological environment or field of use (control systems for farm equipment).
Claims 19-20 include the step 2B additional elements of a non-transitory computer-readable storage medium and at least one processor. Applicant’s specification does not provide any indication that the medium and processor are anything other than conventional media and processors. Filtering and computing data is a well-understood, routine and conventional function when claimed using generic media and processors. Media and processors are widely prevalent and in common use in farm equipment control systems. Media and processors are not significantly more than the judicial exception since they are well-understood, routine and conventional features previously known to the farm equipment industry. Therefore, claims 19-20 are rejected under 35 U.S.C. 101.
Examiner suggests amending the independent claims to positively recite a control function of the farm equipment in order to provide a revised step 2A, prong two, additional element that integrates the abstract idea into a practical application. For instance, the independent claims could be amended to include “executing, by the farm equipment, one or more parameters of the updated agricultural prescription”.
See, the 2019 Revised Patent Subject Matter Eligibility Guidance, which is available on the USPTO Website.
Conclusion
Lindores (US-2014/0012732-A1) is the closest prior art to the applicant’s invention. Lindores discloses a system for generating a crop recommendation (Abstract). A farmer inputs parameters of a particular agricultural field; and the system filters data collected across a wide geographic area based on attributes common with those of the particular agricultural field to generate a report relevant to the particular agricultural field (paragraphs [0082] and [0093]). Then, the system generates a prescription for application of chemicals to the particular agricultural field (paragraph [0094]). The system generates a harvest path for an unharvested field based on an estimated crop characteristic map (paragraph [0166]). The harvest path is forwarded via a communication network to a steering control
of a combine and utilized to auto steer the combine through a field (paragraph [0167]).
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Lange et al. (US-2012/0237083-A1) discloses a system for gathering, filtering, and distributing data relevant to agricultural operations based upon the participation of farmers over a wide area (paragraph [0086]). An aggregating agent filters data for information which is relevant to a particular user and/or a particular field. The aggregating agent automatically generates reports and alerts (paragraphs [0087-0088]).
Any inquiry concerning this communication or earlier communications from the examiner should be directed to TAMARA L WEBER whose telephone number is (303)297-4249. The examiner can normally be reached 8:30-5:00 MTN.
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TAMARA L. WEBER
Examiner
Art Unit 3667
/TAMARA L WEBER/Examiner, Art Unit 3667
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