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 .
Detailed Action
This action is in response to the application filed on 7/30/2025.
Priority
Acknowledgment is made of applicant's claim for prior priority dates including:
This application has PRO 63/677,960 07/31/2024
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.
All claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
The claims are directed to a system, method, or product, which are/is one of the statutory categories of invention. (Step 1: YES).
The Examiner has identified independent method Claim 1 (herein called the Primary Independent Claim) as the claim that represents the claimed invention for analysis and is similar to independent system Claim 19 and product Claim 10 (herein called Additional Independent Claims). The Primary Independent Claim recites the limitations of:
A computer-implemented method for extracting and validating structured vehicle title data, the method comprising: transmitting, by an online system, instructions for presenting a user interface on a client device, the user interface allowing a user of the client device to input a request associated with a vehicle; receiving, at the online system, the request via the user interface presented on the client device, the request including an image of a physical vehicle title document captured by a camera of the client device; executing, by an optical character recognition (OCR) module, text extraction on the image to generate OCR text output; constructing, by a preprocessing engine, a multi-modal input tensor comprising the image, the OCR text output, and one or more schema-based structured data templates representing expected field formats for information to be extracted from the image; providing the multi-modal input tensor to a machine-learned model configured to output a structured data object comprising title information, vehicle information, and ownership information associated with the vehicle; retrieving, by the online system, reference title metadata associated with the vehicle in response to an application programming interface (API) request transmitted to an external database system configured to maintain vehicle title records; validating, by a validation module of the online system, information included in the structured data object based on the reference title metadata and a predetermined set of rules; and executing, by the online system, a predetermined action based on the validation.
These limitations, under their broadest reasonable interpretation, cover performance of the limitation as “Certain Methods of Organizing Human Activity”. The limitation of at least “transmitting, receiving constructing and validating information included in the structured data object based on the reference title metadata and a predetermined set of rules; and executing a predetermined action based on the validation.” recites a fundamental economic practice. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation as a fundamental economic practice, then it falls within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas. Accordingly, the claim recites an abstract idea.
The limitation of at least “by the online system, API, OCR” in the Primary Independent Claim is just applying generic computer components to the recited abstract limitations. The recitation of generic computer components in a claim does not necessarily preclude that claim from reciting an abstract idea. The Additional Independent Claims are also abstract for similar reasons. (Step 2A-Prong 1: YES. The claims recite an abstract idea)
This judicial exception is not integrated into a practical application. The examiner did not find any additional elements that would cause further analysis. The computer hardware/software is/are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. Accordingly, these additional elements, when considered separately and as an ordered combination, do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea and are at a high level of generality. Therefore, all the independent claims are directed to an abstract idea without a practical application. (Step 2A-Prong 2: NO. The additional claimed elements are not integrated into a practical application)
The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when considered separately and as an ordered combination, they do not add significantly more (also known as an “inventive concept”) to the exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of using a computer hardware and software per se amounts to no more than mere instructions to apply the exception using a generic computer component. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. See MPEP 2106.05(f) where applying a computer as a tool is not indicative of significantly more as well as MPEP 2106.05(d). Accordingly, these additional elements, do not change the outcome of the analysis, when considered separately and as an ordered combination. Thus, all independent claims are not patent eligible. (Step 2B: NO. The claims do not provide significantly more)
Dependent claims further define the abstract idea that is present in their respective independent claims, and thus correspond to Certain Methods of Organizing Human Activity and hence are abstract for the reasons presented above. The dependent claims do not include any additional elements that integrate the abstract idea into a practical application or are sufficient to amount to significantly more than the judicial exception when considered both individually and as an ordered combination. Therefore, the dependent claims are directed to an abstract idea. Thus, all the claims are not patent-eligible.
Claim Rejections - 35 USC § 103
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 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.
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.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 1-20 listed below are rejected under 35 U.S.C. 103 as being unpatentable over Baird (U.S. Patent Pub 2021/0256520) in view of McCarthy (U.S. Patent Pub 20210287313) in view of Mittal (U.S. Patent Pub 20250299251)
Re claim 1 & 10 & 19: Baird discloses:
A computer-implemented method for extracting and validating structured vehicle title data, the method comprising: (see Baird Fig 1, 5)
transmitting, by an online system, instructions for presenting a user interface on a client device, the user interface allowing a user of the client device to input a request associated with a vehicle; (see Baird Fig 4 item 410, Fig 510, Fig 1-2 item 101 + 201, 213)
receiving, at the online system, the request via the user interface presented on the client device, the request including an image of a physical vehicle title document captured by a camera of the client device; (see Baird Fig 4 item 410-440, Fig 510-540, Fig 1-2 item 101 + 201, 213 + 211 + para 0025 + 0009 + 0031)
executing, by an optical character recognition (OCR) module, text extraction on the image to generate OCR text output; (see Baird Fig 4 item 410-440, Fig 510-540, Fig 1-2 item 101 + 201, 213 + para 0025 + 0009 + 0031)
constructing, by a preprocessing engine, a multi-modal input tensor comprising the image, the OCR text output, and one or more schema-based structured data templates representing expected field formats for information to be extracted from the image; (see Baird Fig 4 item 420-450, Fig 520-550, Fig 1-2 item 204, 110 + para 0030-0031)
providing the multi-modal input tensor to a machine-learned model configured to output a structured data object comprising title information, vehicle information, and ownership information associated with the vehicle; (see Baird Fig 4 item 420-450, Fig 520-550, Fig 1-2 item 204, 110 + para 0030-0031)
retrieving, by the online system, reference title metadata associated with the vehicle in response to an application programming interface (API) request transmitted to an external database system configured to maintain vehicle title records; (see Baird Fig 4 item 420-450, Fig 520-550, Fig 1-2 item 204, 110 + para 0030-0031)
validating, by a validation module of the online system, information included in the structured data object based on the reference title metadata and a predetermined set of rules; and (see Baird Fig 4 item 420-450, Fig 520-550, Fig 1-2 item 204, 110 + para 0030-0031)
executing, by the online system, a predetermined action based on the validation. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031)
Although Baird does not explicitly have machine-learned, McCathy and Mittal more clearly claims machine-learned see McCathy Fig 12 and Mittal Fig 7
Therefore it would have been obvious to one of ordinary skill in the art at the effect filling date was made to modify Baird by adapting any features of Lee.
It is clear that one would be motivated by the teaching in the prior art that would have led one of ordinary skill to modify the prior art reference or to combine prior art reference teachings to arrive at the claimed invention. Specifically, both Baird teaches Vehicle title registration with OCR and multi data that is adapted in McCathy and Mittal system see McCathy Fig 12 and Mittal Fig 7
Re claim 2 & 11 & 20: see claim 1 +
wherein executing the predetermined action comprises: determining that the vehicle is eligible for placement of a lien on the vehicle; and transmitting a lien registration request to the external database system, the lien registration request including at least information identifying the vehicle and a holder of the lien. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031 + see McCathy Fig 12)
Re claim 3 & 12: see claim 1 +
wherein executing the predetermined action comprises: determining that the vehicle has passed the validation; and transmitting a notification to the user interface presented on the client device, the notification indicating that the vehicle has passed the validation. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031 + see McCathy Fig 12)
Re claim 4 & 13: see claim 1 +
wherein executing the predetermined action comprises: determining that the vehicle did not pass the validation; and transmitting an error message to the user interface presented on the client device, the error message indicating a failure condition. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031 + see McCathy Fig 12 para 0199)
Re claim 5 & 14: see claim 1 +
further comprising: obtaining a training set including a plurality of annotated images of labeled vehicle title documents, each annotated image in the training set comprising an image and associated annotations identifying ground-truth values for predefined fields including vehicle information, title information, and ownership information; updating the training set to be a multi-modal training set by including, for each annotated image, OCR text extracted from the annotated image, and structured data templates defining expected field types and formats; and training the machine-learned model using the multi-modal training set to optimize a network based on a loss function that penalizes incorrect structured output. (see Baird Fig 4 item 410-440, Fig 510-540, Fig 1-2 item 101 + 201, 213 + para 0025 + 0009 + 0031 + see McCathy Fig 12 para 0035)
Re claim 6 & 15: see claim 1 +
further comprising: generating validation information based on a result of the validation; and updating the structured data object to include the validation information. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031 + see McCathy Fig 12 para 0121)
Re claim 7 & 16: see claim 1 +
wherein the structured data object is encoded in a machine-readable format comprising key-value pairs corresponding to the title information, the vehicle information, the ownership information, and the validation information. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031 + see McCathy Fig 12)
Re claim 8 & 17: see claim 1 +
wherein the validation information comprises at least one of: an indicator of whether the physical vehicle title document corresponding to the image is a valid vehicle title, an indicator of whether the physical vehicle title document represents a most recent title for the vehicle, a validity flag for a vehicle identification number (VIN) of the vehicle, a classification of an owner of the vehicle as an individual, co-owner, or a business, an indicator of whether an owner name extracted from the physical vehicle title document matches a registered owner identified in the reference title metadata, a flag indicating a presence of title remarks or brand designations, or a flag indicating whether a lien or lien release is present on the physical vehicle title document. (see Baird Fig 4 item 450, Fig 550, Fig 1-2 item 204, 110 + para 0030-0031 + see McCathy Fig 12 para 0121)
Re claim 9 & 18: see claim 1 +
wherein: the vehicle information comprises at least one of a vehicle identification number (VIN),make, model, year, odometer reading, or license plate number; the title information comprises at least one of a document type, issuing authority, title issue date, or title control number; and the ownership information comprises at least one of an owner name, owner address, co- owner indicator, or prior owner name. (see Baird Fig 4 item 410-440, Fig 510-540, Fig 1-2 item 101 + 201, 213 + para 0003, 0025+ see McCathy Fig 12)
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Underwood, U.S. Patent Pub 20010011221, discloses an apparatus is used to select and present title status information relating to one or more vehicle titles.
Contact Information
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Kirsten Apple whose telephone number is (571)272-5588. The examiner can normally be reached on M-F 9-5.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael Anderson can be reached on (571) 270-0508. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/KIRSTEN S APPLE/Primary Examiner, Art Unit 3693
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