DETAILED ACTION
Status of Claims
This is a first office action on the merits in response to the application filed on 19 September 2025
Claims 1-20 are currently pending and have been considered by the examiner
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 § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claim 3 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
Claim 3 recites the limitation "a third mobile device" in line 2. There is insufficient antecedent basis for this limitation in the claim. Specifically, the parent claim, independent claim 1, previously recites “a third mobile device” in lines 28-29. It is unclear whether the “third mobile device” recited in claim 3 is meant to refer to the same device as claimed in claim 1 or rather to a separate device entirely. Thus, the claim is indefinite and must be rejected under 35 USC 112(b). Appropriate correction is required.
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 an abstract idea without significantly more.
In the instant case, claims 1-20 are directed towards a method. Therefore, these claims fall within the four statutory categories of invention.
Claim 1 recites the following:
A method comprising:
during a first time period:
receiving a first charge request for a first charge session from a first mobile device accessed by a first user, the first charge request defining a first set of request characteristics comprising:
a first station identifier associated with a first charging station;
a first vehicle identifier associated with a first electric vehicle affiliated with the first user; and
a first set of charge parameters comprising a first charge window; and
in response to receiving the first charge request:
accessing a first owner profile, in a set of owner profiles, associated with an owner of the first charging station based on the first station identifier;
extracting a set of target charge parameters defined by the first owner from the first owner profile;
characterizing a first difference between the first set of charge parameters and the set of target charge parameters; and
in response to the first difference exceeding a threshold difference:
generating a first verification request comprising a first prompt to review the first charge request for the first charge session;
transmitting the first verification request to a second mobile device affiliated with the owner; and
in response to receiving authorization of the first charge session from the owner at the second mobile device, approving the first charge request; and
during a second time period:
receiving a second charge request for a second charge session from a third mobile device accessed by a second user, the second request defining a second set of request characteristics comprising:
the first station identifier associated with the first charging station;
a second vehicle identifier associated with a second electric vehicle affiliated with the second user; and
a second set of charge parameters comprising a second charge window; and
in response to receiving the second charge request:
accessing the first owner profile associated with the owner of the first charging station based on the first station identifier;
extracting the set of target charge parameters defined by the first owner;
characterizing a second difference between the first set of charge parameters and the set of target charge parameters; and
in response to the second difference falling below the threshold difference, approving the second charge request.
Regarding Step 2A Prong One, the claims recite the abstract idea of performing a mental process. Specifically, the claims recite the limitations underlined above which recite concepts which can be performed in the human mind such as observation, evaluation, judgement, and opinion which is grouped within the Mental Processes grouping of abstract ideas in prong one of step 2A of the Alice/Mayo test (See MPEP § 2106.04) because the claims involve the process of mitigating risk in an economic transaction. Accordingly, the claims recite an abstract idea (See pages 7, 10, Alice Corporation Pty. Ltd. v. CLS Bank International, et al., US Supreme Court, No. 13-298, June 19, 2014; 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50, 53-54 (January 7, 2019)).
Regarding Step 2A Prong Two, the recited abstract idea is not integrated into a practical application because, when analyzed under prong two of step 2A of the Alice/Mayo test (See MPEP § 2106.04(d)), the additional element(s) of the claim(s) such as a “first mobile device”, “second mobile device”, and “third mobile device” merely use(s) a computer as a tool to perform an abstract idea. Specifically, the “first mobile device”, “second mobile device”, and “third mobile device” perform(s) the steps or functions underlined above. The use of a processor/computer as a tool to implement the abstract idea does not integrate the abstract idea into a practical application because it requires no more than a computer performing functions that correspond to acts required to carry out the abstract idea. The additional elements do not involve improvements to the functioning of a computer, or to any other technology or technical field (MPEP 2106.05(a)), the claims do not apply or use the abstract idea to effect a particular treatment or prophylaxis for a disease or medical condition (Vanda Memo), the claims do not apply the abstract idea with, or by use of, a particular machine (MPEP 2106.05(b)), the claims do not effect a transformation or reduction of a particular article to a different state or thing (MPEP 2106.05(c)), and the claims do not apply or use the abstract idea in some other meaningful way beyond generally linking the use of the abstract idea to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception (MPEP 2106.05(e) and Vanda Memo). Therefore, the claims do not, for example, purport to improve the functioning of a computer. Nor do they effect an improvement in any other technology or technical field. Accordingly, the additional elements do not impose any meaningful limits on practicing the abstract idea, and the claims are directed to an abstract idea.
The claim(s) do not include additional elements that are sufficient to amount to significantly more than the judicial exception because, when analyzed under step 2B of the Alice/Mayo test (See MPEP § 2106.05), the additional element(s) of a “first mobile device”, “second mobile device”, and “third mobile device” amounts to no more than using a computer or processor to automate and/or implement the abstract idea. As discussed above, taking the claim elements separately, the “first mobile device”, “second mobile device”, and “third mobile device” perform(s) the steps or functions underlined above. These functions correspond to the actions required to perform the abstract idea. Viewed as a whole, the combination of elements recited in the claims merely recite risk mitigation. Therefore, the use of these additional elements does no more than employ the computer as a tool to automate and/or implement the abstract idea. The use of a computer or processor to merely automate and/or implement the abstract idea cannot provide significantly more than the abstract idea itself (MPEP 2106.05(I)(A)(f) & (h)). Therefore, the claim is not patent eligible.
Dependent claims 2-17 and 19 further describe the recited abstract idea. The dependent claims do not include additional elements that integrate the abstract idea into a practical application or that provide significantly more than the abstract idea. Specifically:
Claims 2-3, 7-8, 10-11, 15, and 17 recites additional limitations which are also directed towards the abstract idea.
Claims 4, 6, and 9 merely further describes the information being observed and evaluated when performing the claimed abstract idea.
Claim 5, 12, 16, and 19 merely further describes the method by which the claimed processes of observation and evaluation are being performed wherein said processes can reasonably be performed by the human mind.
Therefore, as the dependent claims do not include additional elements that integrate the abstract idea into a practical application nor provide significantly more than the abstract idea, the dependent claims are also not patent eligible.
Allowable Subject Matter
Claims 1-20 recite allowable subject matter, provided the 101 and 112 rejections outlined above are overcome.
The following is the examiner’s statement of reasons for indication of allowable subject matter:
Claim 1 recites: “A method comprising: during a first time period: receiving a first charge request for a first charge session from a first mobile device accessed by a first user, the first charge request defining a first set of request characteristics comprising: a first station identifier associated with a first charging station; a first vehicle identifier associated with a first electric vehicle affiliated with the first user; and a first set of charge parameters comprising a first charge window; and in response to receiving the first charge request: accessing a first owner profile, in a set of owner profiles, associated with an owner of the first charging station based on the first station identifier; extracting a set of target charge parameters defined by the first owner from the first owner profile; characterizing a first difference between the first set of charge parameters and the set of target charge parameters; and in response to the first difference exceeding a threshold difference: generating a first verification request comprising a first prompt to review the first charge request for the first charge session; transmitting the first verification request to a second mobile device affiliated with the owner; and in response to receiving authorization of the first charge session from the owner at the second mobile device, approving the first charge request; and during a second time period: receiving a second charge request for a second charge session from a third mobile device accessed by a second user, the second request defining a second set of request characteristics comprising: the first station identifier associated with the first charging station; a second vehicle identifier associated with a second electric vehicle affiliated with the second user; and a second set of charge parameters comprising a second charge window; and in response to receiving the second charge request: accessing the first owner profile associated with the owner of the first charging station based on the first station identifier; extracting the set of target charge parameters defined by the first owner; characterizing a second difference between the first set of charge parameters and the set of target charge parameters; and in response to the second difference falling below the threshold difference, approving the second charge request.”
The closest art of record is as follows:
Verma et al. (US 20230306535 A1) generally discloses systems and methods for operating an electrical vehicle charging station which verifies the identity of users prior to providing charging services.
Borkar et al. (US 20190222576 A1) generally discloses systems and method for authenticating users using a mobile device interface.
Sharma et al. (US 20200311712 A1) generally discloses systems and methods for facilitating networks transaction based upon user authorization verification provided via a mobile device interface.
However, the cited references, alone or in combination fail to disclose the combination of elements including: “during a first time period: receiving a first charge request for a first charge session from a first mobile device accessed by a first user, the first charge request defining a first set of request characteristics comprising: a first station identifier associated with a first charging station; a first vehicle identifier associated with a first electric vehicle affiliated with the first user; and a first set of charge parameters comprising a first charge window; and in response to receiving the first charge request: accessing a first owner profile, in a set of owner profiles, associated with an owner of the first charging station based on the first station identifier; extracting a set of target charge parameters defined by the first owner from the first owner profile; characterizing a first difference between the first set of charge parameters and the set of target charge parameters; and in response to the first difference exceeding a threshold difference: generating a first verification request comprising a first prompt to review the first charge request for the first charge session; transmitting the first verification request to a second mobile device affiliated with the owner; and in response to receiving authorization of the first charge session from the owner at the second mobile device, approving the first charge request; and during a second time period: receiving a second charge request for a second charge session from a third mobile device accessed by a second user, the second request defining a second set of request characteristics comprising: the first station identifier associated with the first charging station; a second vehicle identifier associated with a second electric vehicle affiliated with the second user; and a second set of charge parameters comprising a second charge window; and in response to receiving the second charge request: accessing the first owner profile associated with the owner of the first charging station based on the first station identifier; extracting the set of target charge parameters defined by the first owner; characterizing a second difference between the first set of charge parameters and the set of target charge parameters; and in response to the second difference falling below the threshold difference, approving the second charge request.”
Moreover, the missing claim limitations from the combination of Verma, Borkar, and Sharma are not found in a reasonable number of references.
Yet even if the missing claimed elements were found in a reasonable number of references, a person of ordinary skill in the art would not have been motivated to include these elements in Noe because Noe is not concerned with use multiple card credentials or permanent card credentials based upon determining logic.
Foreign prior art and NPL searches were conducted. However, no additional relevant prior art was found.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to NICHOLAS K PHAN whose telephone number is (571)272-6748. The examiner can normally be reached M-F 1 pm-9 pm EST.
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, Neha Patel can be reached on 571-270-1492. 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.
/NICHOLAS K PHAN/Examiner, Art Unit 3699