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 .
Status of Claims
Claims 1-20 were previously pending, claims 17-20 were withdrawn, and claims 1-16 were examined and subject to a non-final rejection dated April 2, 2026. In Response, submitted July 2, 2026, claims 1, 3, and 9 were amended, and claims 4, 12, and 13 were cancelled. Therefore, claims 1-3, 5-11, and 14-20 are currently pending, claims 17-20 remain withdrawn, and claims 1-3, 5-11, and 14-16 have been examined and subject to the following final rejection.
Response to Arguments
Applicant’s remarks on Page 6 of the Response, regarding the previous objection to claim 3, have been fully considered and are found persuasive in light of the amended claims.
Applicant’s remarks on Pages 6-7 of the Response, regarding the previous rejection of the claims under 35 U.S.C. 101, have been fully considered and are not found persuasive.
On Pages 6-7 of the Response, Applicant argue “Claims 1-16 were rejected under 35 U.S.C. § 101 as allegedly being directed to an abstract idea without significantly more. Applicant respectfully traverses this rejection for at least the reasons set forth below. Independent claims 1 and 9 have been amended to recite, inter alia, ‘detect or receive a notification of a parking violation of the consumer’ and ‘transmit, to the device, a notification to make a purchase at the one or more businesses to satisfy the parking violation.’ Applicant respectfully submits that the claims as amended integrate any alleged abstract idea into a practical application under Step 2A Prong Two of the eligibility analysis. … Specifically, the claims employ information from the parking violation detection to control operation of the parking and advertising system in a specific way by transmitting a notification to the consumer's device offering an alternative resolution mechanism through purchases at nearby businesses. This approach is analogous to USPTO eligibility examples where using information obtained via a judicial exception to take corrective action constitutes an ‘other meaningful limitation’ that integrates the judicial exception into a practical application. For example, in Example 46 (Livestock Management), the USPTO found that using analysis results to automatically send a control signal to dispense feed ‘adds a meaningful limitation in that it can employ the information provided by the judicial exception... to operate’ the system. Similarly, the amended claims here employ parking violation information to operate the parking and advertising system in a particular way providing consumers with an option to satisfy parking violations through local business purchases rather than traditional payment methods.”
Examiner notes, as discussed further in the detailed rejection below, “detect[ing] or receiv[ing] a notification of a parking violation of the consumer’ and ‘transmit[ting …] a notification to make a purchase at the one or more businesses to satisfy the parking violation” are recitations of the abstract idea, and therefore unhelpful in bringing the claims eligibility over 101. Further, the abstract processes of “employ[ing] information from the parking violation detection … in a specific way by transmitting a notification to the consumer… offering an alternative resolution mechanism through purchases at nearby businesses” are performed using generic processor and memory (in the case of representative claim 1) merely as tools to perform these abstract ideas, where the “consumer’s device” is disclosed as a generic tool used to perform abstract ideas such as receiving the transmitted notifications. That is, these additional elements (of the processor, memory, and consumer’s device) insofar as they are claimed amount to merely apply it, and the argued “practical application” is not actually practical but rather using one abstract idea (“employ[ing] information from the parking violation detection … in a specific way”) to cause a subsequent abstract idea (“transmitting a notification to the consumer… offering an alternative resolution mechanism through purchases at nearby businesses” also argued as “providing consumers with an option to satisfy parking violations through local business purchases rather than traditional payment methods”). This stands in stark contrast to Example 46 where abstract ideas are used to provide direct control over the recited additional elements causing the cattle gate to physically operate in accordance with the recited abstract idea, thereby integrating the abstract idea into a practical application.
On Page 7 of the Response, Applicant argues “The claims as amended provide a technical solution to the problem of parking violation resolution by integrating violation detection with the advertising network to offer purchase-based satisfaction options. … This represents a specific improvement to parking management technology that goes beyond merely ‘applying’ an abstract idea on a computer. Accordingly, Applicant respectfully submits that amended claims 1 and 9, as well as their dependent claims, integrate any alleged abstract idea into a practical application and are therefore patent eligible under 35 U.S.C. § 101. Applicant respectfully requests withdrawal of the rejection.”
Examiner notes, the high level of generic disclosure regarding how the invention is able to “detect, or receive a notification... of the violation” provides the support that these aspects represent abstract processes such as receiving or processing data, rather than any sort of practical application. Further, the similar generality regarding the sending “a notification of the violation” including “an option for consumer 80 to visit a website, or provide a code (QR, barcode, other) to a physical store, to spend a certain amount of money at certain stores in lieu of paying a parking fine” as disclosed in specification, para. 46 similarly supports the determination that these represent the abstract ideas of sending/receiving data. That is, these claims do not represent any technical improvements to the additional elements or the relevant technologies (i.e. to the processor, the memory, the consumer’s device, or communication networks) but rather represent solutions to the abstract problems of parking violation resolution through alleged improvements to abstract processes such as violation detection and offering purchase-based satisfaction options. As noted in MPEP 2106.05(a)(II), an improvement to the abstract idea is not an improvement in technology.
Applicant’s remarks on Pages 7-9 of the Response, regarding the previous rejection of the claims under 35 U.S.C. 102 and 103, have been fully considered and are found persuasive in light of the amended claims.
Information Disclosure Statement
The information disclosure statements (IDS) submitted on May 18, 2026 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
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 1-3, 5-11, and 14-16 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more.
Step 1
Claims 1-3 and 5-8 are directed to a system (i.e., a machine); claims 9-11 and 14-16 are directed to a method (i.e., a process). Therefore, claims 1-3, 5-11, and 14-16 all fall within the one of the four statutory categories of invention.
Step 2A, Prong One
Independent claims 1 and 9 substantially recite detecting or predicting a location of a consumer;
transmitting, to the consumer, a notification of one or more available parking spaces near the location;
receiving a selection of a parking space of the one or more available parking spaces;
receiving one or more payment information to pay for the parking space; and
transmitting one or more marketing materials related to one or more businesses near the location;
detecting or receiving a notification of a parking violation of the consumer; and
transmitting a notification to make a purchase at the one or more businesses to satisfy the parking violation.
The limitations stated above are processes/functions that under broadest reasonable interpretation covers “certain methods of organizing human activity” (commercial interactions, including advertising, marketing, or sales activities) of “integrating parking payments and advertising” (Specification, Para. 2). Therefore, the claim recites an abstract idea.
Step 2A, Prong Two
The judicial exception is not integrated into a practical application. Claims 1 and 9 as a whole amount to: (i) merely invoking generic components as a tool to perform the abstract idea or “apply it” (or an equivalent). The claim recites the additional elements of: (i) a processor (claim 1), (ii) a memory storing instructions (claim 1), and (iii) a device (claims 1, 9).
The additional elements of (i) a processor, (ii) a memory storing instructions, and (iii) a device are recited at a high level of generality (See [0098] of the Applicant’s Specification discussing the processor, [0101] discussing the memory storing instructions, and discussing the [0116] discussing the device) such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Accordingly, these additional elements, when viewed as a whole/ordered combination [See Figures 1, and 10 showing all the additional elements of (i) a processor, (ii) a memory storing instructions, and (iii) a device in combination], do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. Thus, the claim is directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) “apply it” (or an equivalent), and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claims adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, the claims 1 and 9 are ineligible.
Dependent Claims 2, 5, 8, 10, 14, and 16 merely narrow the previously recited abstract idea limitations. For reasons described above with respect to claims 1 and 9 these judicial exceptions are not meaningfully integrated into a practical application or significantly more than the abstract idea. Thus, claims 2, 5, 8, 10, 14, and 16 are also ineligible.
Step 2A, Prong Two
Dependent Claims 3 and 11 further narrow the previously recited abstract idea limitations. Claims 3 and 11 also recites the additional elements of an artificial intelligence and a machine learning model, which is recited at a high-level of generality (See [0078-0079] of the Applicants PG Publication disclosing the artificial intelligence and the machine learning model) such that when viewed as whole/ordered combination, the additional elements do no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e., machine learning modeling) (See MPEP 2106.05(h)).
Accordingly, the additional elements, when viewed individually and as a whole/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. Thus, the claims are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional element amounts to no more than: generally linking the use of a judicial exception to a particular technological environment or field of use, and is not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional elements of an artificial intelligence and a machine learning model do not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claim adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claims 3 and 11 are ineligible.
Step 2A, Prong Two
Dependent Claims 6 and 15 further narrow the previously recited abstract idea limitations. Claims 6 and 15 also recite the additional element of a digital wallet, which is recited at a high-level of generality (See [0047] of the Applicants PG Publication disclosing the digital wallet) such that when viewed as whole/ordered combination, the additional elements do no more than generally link the use of the judicial exception to a particular technological environment or field of use (i.e., digital wallets) (See MPEP 2106.05(h)).
Accordingly, the additional elements, when viewed individually and as a whole/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. Thus, the claims are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional element amounts to no more than: generally linking the use of a judicial exception to a particular technological environment or field of use, and is not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) generally linking the use of a judicial exception to a particular technological environment or field of use (See MPEP 2106.05(h)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional element of a digital wallet does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claim adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claims 6 and 15 are ineligible.
Step 2A, Prong Two
Dependent Claim 7 further narrows the previously recited abstract idea limitations. Claim 7 also recites the additional elements of a computing device, a Wi-Fi router, a Bluetooth device, a near field communication device, and a store payment kiosk which are recited at a high-level of generality (See [0033] of the Applicants PG Publication disclosing the computing device, the Wi-Fi router, the Bluetooth device, the near field communication device, and the store payment kiosk) such that, when viewed as whole/ordered combination, it amounts to no more than mere instruction to apply the judicial exception using generic computer components or “apply it” (See MPEP 2106.05(f)).
Accordingly, the additional elements, when viewed individually and as a whole/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. Thus, the claims are directed to an abstract idea.
Step 2B
As discussed above with respect to Step 2A Prong Two, the additional elements amount to no more than: (i) “apply it” (or an equivalent), and are not a practical application of the abstract idea. The same analysis applies here in Step 2B, i.e., (i) merely invoking the generic components as a tool to perform the abstract idea or “apply it” (See MPEP 2106.05(f)), does not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B.
Therefore, the additional elements of a computing device, a Wi-Fi router, a Bluetooth device, a near field communication device, and a store payment kiosk do not integrate the abstract idea into a practical application at Step 2A or provide an inventive concept at Step 2B. Thus, even when viewed as a whole/ordered combination, nothing in the claim adds significantly more (i.e., an inventive concept) to the abstract idea. Thus, claim 7 is ineligible.
Novel and Non-Obvious Over the Prior Art
Claims 1-3, 5-11, and 14-16 are novel and non-obvious over the prior art; however, this claim is subject to the above rejections.
The closest prior art is U.S. Patent Application No. 2018/0225650 to Vossoughi et al (hereafter Vossoughi). Vossoughi discloses a parking system that is able to determine, reserve, and process payment for parking for a user as well as provide targeted advertising to the user regarding businesses in the vicinity of the location.
The next closest prior art is U.S. Patent Application No. 2012/0127308 to Eldershaw et al (hereafter Eldershaw). Eldershaw discloses a parking system where purchases at merchant locations using merchant promotions are used to subsidize parking service costs.
The next closest prior art is Non-Patent Literature “Parking for 'customers only' - can you buy something, go to another nearby building and stay parked?” by r/LegalAdviceUK et al (hereafter r/LegalAdviceUK). r/LegalAdviceUK discloses a parking system where a purchase at a business is used to satisfy a parking violation.
While the closest prior art above teaches the various aspects of the claimed invention individually, the combination of these references are not obvious in such a way that they would have been obvious to one of ordinary skill in the art at the time of invention. Specifically, Vossoughi in view of Eldershaw and further in view of r/LegalAdviceUK fails to explicitly disclose the transmitting of a notification to the device to make a purchase at the one or more businesses to satisfy the parking violation in combination with the other limitations of the claims. Therefore, the claims are rendered novel and non-obvious over the prior art.
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 DAVID G GODBOLD whose telephone number is (571)272-5036. The examiner can normally be reached M-F 8-5.
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/DAVID G. GODBOLD/Examiner, Art Unit 3628
/RUPANGINI SINGH/Primary Examiner, Art Unit 3628
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