Prosecution Insights
Last updated: April 19, 2026
Application No. 17/789,538

LOCATION-AWARE REMINDERS

Final Rejection §101§103
Filed
Jun 28, 2022
Examiner
MANSFIELD, THOMAS L
Art Unit
3624
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Cerence Operating Company
OA Round
4 (Final)
50%
Grant Probability
Moderate
5-6
OA Rounds
4y 5m
To Grant
84%
With Interview

Examiner Intelligence

Grants 50% of resolved cases
50%
Career Allow Rate
294 granted / 584 resolved
-1.7% vs TC avg
Strong +34% interview lift
Without
With
+34.0%
Interview Lift
resolved cases with interview
Typical timeline
4y 5m
Avg Prosecution
45 currently pending
Career history
629
Total Applications
across all art units

Statute-Specific Performance

§101
37.9%
-2.1% vs TC avg
§103
24.1%
-15.9% vs TC avg
§102
20.6%
-19.4% vs TC avg
§112
13.2%
-26.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 584 resolved cases

Office Action

§101 §103
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 1. This Final Office action is in reply to the Applicant amendment filed on 30 October 2025. 2. Claim 1 has been amended. New claims 19-22 have been added. 3. Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22 are currently pending and have been examined. Response to Amendment In the previous office action, Claims 1, 4, 5, 7, 10, 11, 13-17 were rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter (abstract idea). Applicants have not amended now Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22 to provide statutory support and the rejection is maintained. Response to Arguments Applicant’s arguments filed 30 October 2025 have been fully considered but they are not persuasive. In the remarks regarding the 35 USC § 101 rejection for Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22, Applicant argues that: (1) the claims are not directed to an abstract idea, and even if they were, they would amount to significantly more than the abstract idea. Examiner respectfully disagrees. Still commensurate to the two-part subject matter eligibility framework decision in the Federal court decision in Alice Corp. Pty. Ltd. V. CLS Bank International et al., (Alice), 2019 revised patent subject matter eligibility guidance (2019 PEG) and the October 2019 Update: Subject Matter Eligibility (“October 2019 Update), and the new “July 2024 Guidance Update on Patent Subject Matter Eligibility Examples, including on Artificial Intelligence”, and the Examiner details the maintained rejection under 35 U.S.C. 101 in the below rejection with further explanation. At present, Applicant basically submits at least claim 1 cannot be classified as mental processes [see Remarks page 7]. However and seen in the below detailed and maintained rejection, the Examiner has provided additional clarification in that these claims still fall under the abstract idea (judicial exception) categories: Certain methods of organizing human activity –managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions). Specifically: the claims (creating, storing, and triggering a location-aware reminder based on user location and proximity to a place) are directed to methods of organizing human activity grouping of abstract ideas (specifically, managing personal behavior/reminders) and focus on managing personal affairs, tracking user activity, and organizing behavioral tasks (e.g., "reminder message for an actor to perform an action"). Mental processes – concepts performed in the human mind (including an observation, evaluation, judgment, opinion). The core concept of remembering an action at a certain location is something that can be performed in the human mind or with pen and paper, making its automated version an abstract concept. Hence, the claims are ineligible under step 2A prong one. Furthermore, the dependent claims are merely directed to the particulars of the abstract idea and likewise do not add significantly more to the above-identified judicial exception. The limitations of the claims do not transform the abstract idea that they recite into patent-eligible subject matter because the claims simply instruct the practitioner to implement the abstract idea using generally-recited computer components. In summary as indicated below through Steps 1-2B, the recitation of a computer (one or more processors) to perform the claim limitations amount to no more that mere instruction to apply the exception using a generic computer component (x). Even when considered in combination, these additional elements represent mere instructions to implement an abstract idea or other exception on a computer and insignificant extra-solution activity, which do not provide an inventive concept. For at least these reasons, the rejection is maintained. Applicant submits that: (2) Adler et al (Adler) (US 2016/0358451) in view of Moore, Jr. et al. (Moore) (US 2016/0379105) do not teach or suggest in amended Claim 1: “detecting, via an identification module configured to determine that the second user is present in the automobile using biometric identification of the second user, the presence of a mobile device associated with the second user based on detection of short wireless communication signals from the mobile device, or a manual identification of the second user to the automobile” [see Remarks pages 8-9]. With regard to argument (2), the Examiner respectfully disagrees. Due to amendments, the Examiner notes additional clarification and citations from Adler as teaching “detecting, via an identification module configured to determine that the second user (At step 150, it is determined whether the state of the device is on an opportune list (also called a trigger list). That is, it is determined whether the state of the device is a state which is opportune for receiving the reminder as requested by the user. The opportune list can be, for example, a list including one or more trigger states which a user has identified as being appropriate for receiving the reminder) is present in the automobile using one or more of identification of the second user (When a user inputs the location-based reminder via audio, such as through a voice command, the user can verbally enter the reminder on their device. For example, the user can select an audio input button on the device, speak into the microphone of the device, and enter a reminder such as “Call Bob when I get to work using opportune mode.” Therefore, the reminder can be triggered when the user is at work (i.e., location information) and when the opportune mode requirements have been met), the presence of a mobile device associated with the second user, or a manual identification of the second user to the automobile (At step 140, the state of the device can be determined based on sensors. One or more sensors of the device can provide information for determining the state, several states, or a sequence of states of the device in order to determine whether or not the device has entered a trigger state for triggering the reminder. For example, motion sensors and input sensors or a combination of motion sensors and input sensors can be used to detect whether motion activity or input activity has occurred. The motion activity and input activity can be directed to states which indicate that the device has entered an opportune mode for receiving a reminder) (see at least paragraphs 33-50). Adler does not specifically teach biometric identification. As previously presented and maintained, Moore teaches biometric identification (biometric and environmental data) in analogous art of recognize patterns of user behaviors for the purposes of: “as the digital assistant typically maintains awareness of device state and other context, it may be invoked or controlled by specific context such as user input, received notifications, or detected events associated with biometric or environmental data. For example, the digital assistant can behave in particular ways and surface appropriate user experiences when biometric and environmental data indicates that the user is active and moving around outdoors as compared to occasions when the user is sitting quietly inside (see at least paragraphs 31-39, 104-105). It would have been obvious to one of ordinary skill in the art at the time of the invention to include behavior recognition and automation using a mobile device as taught by Moore in the system of Adler, since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art would have recognized that the results of the combination were predictable. Additionally, the Examiner notes Applicant's arguments fail to comply with 37 CFR 1.111(b) because they amount to a general allegation that the claims define a patentable invention without specifically pointing out how the language of the claims patentably distinguishes them from the references. Applicant's arguments do not comply with 37 CFR 1.111(c) because they do not clearly point out the patentable novelty which he or she thinks the claims present in view of the state of the art disclosed by the references cited or the objections made. Further, they do not show how the amendments avoid such references or objections. In response to applicant's arguments against the references individually, one cannot show non-obviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). It is noted that any citations to specific, pages, columns, paragraphs, lines, or figures in the prior art references and any interpretation of the reference should not be considered to be limiting in any way. A reference is relevant for all it contains and may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art. See MPEP 2123. The Examiner has a duty and responsibility to the public and to Applicant to interpret the claims as broadly as reasonably possible during prosecution. In re Prater, 415 F.2d 1 393, 1404-05, 162 USPQ 541, 550-51 (CCPA 1969). 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, 4, 5, 7, 10, 11, 13-17, and 19-22 are rejected under 35 U.S.C. §101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, natural phenomenon, or an abstract idea) because the claimed invention is directed to a judicial exception (i.e., a law of nature, natural phenomenon, or an abstract idea) without significantly more. The claims as a whole recite certain grouping of an abstract idea and are analyzed in the following step process: Step 1: Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22 are each focused to a statutory category of invention, namely “method” sets. Step 2A: Prong One: 1, 4, 5, 7, 10, 11, 13-17, and 19-22 recite limitations that set forth abstract ideas. The claims recite steps for, generally, “managing location-aware reminders in an automobile”. Representative independent Claims 1 and 21 encompass processing information by: “receiving a voice activated command issued inside the automobile to create a first location-aware reminder including a reminder message for an actor to perform an action, the first location-aware reminder including a class of places where the action is capable of being performed, each place in the class of places being in proximity to a different geographic region; maintaining a cloud database including a plurality of location-aware reminders, wherein a first location-aware reminder of the plurality of location-aware reminders was created by a first user, is directed to a second user, includes a reminder message for the second user to perform an action, and includes a class of places where the second user can perform the action, each place in the class of places being in proximity to a different geographic region; detecting, via an identification module configured to determine that the second user is present in the automobile using biometric identification of the second user, the presence of a mobile device associated with the second user based on detection of short wireless communication signals from the mobile device, or a manual identification of the second user to the automobile; monitoring a geographic location of the automobile using a computer system installed in the automobile; detecting, using the computer system, that the automobile has entered a geographic region in proximity to any one of the places where the second user can perform the action for the first location-aware reminder; issuing, from the computer system, the reminder message for the second user to perform the action based on the detection of the second user in the automobile and the detection of the automobile in the geographic region in proximity to the place where the second user can perform the action” In the above bolded phrase limitations, these claims fall under the categories: Certain methods of organizing human activity –managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions), specifically: the claims (creating, storing, and triggering a location-aware reminder based on user location and proximity to a place) are directed to the "methods of organizing human activity" grouping of abstract ideas (specifically, managing personal behavior/reminders) and focus on managing personal affairs, tracking user activity, and organizing behavioral tasks (e.g., "reminder message for an actor to perform an action"). Mental processes – concepts performed in the human mind (including an observation, evaluation, judgment, opinion). The core concept of remembering an action at a certain location is something that can be performed in the human mind or with pen and paper, making its automated version an abstract concept. Hence, the claims are ineligible under step 2A prong one. Furthermore, the dependent claims are merely directed to the particulars of the abstract idea and likewise do not add significantly more to the above-identified judicial exception. The limitations of the claims do not transform the abstract idea that they recite into patent-eligible subject matter because the claims simply instruct the practitioner to implement the abstract idea using generally-recited computer components. Prong Two: Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22: The judicial exception is not integrated into a practical application because the claims as a whole describe how to generally “managing location-aware reminders in an automobile”. The additional elements for the claims contain computer components (i.e., database; module sensor; GPS; computer system, etc.) that are cited at a high level of generality and are merely invoked as a tool to perform the abstract idea. Simply implementing an abstract idea on a computer is not a practical application of the abstract idea. It is notable that mere physicality or tangibility of an additional element or elements is not a relevant consideration in Step 2A Prong Two. As the Supreme Court explained in Alice Corp., mere physical or tangible implementation of an exception does not guarantee eligibility. Alice Corp. Pty. Ltd. v. CLS Bank Int’l, 573 U.S. 208, 224, 110 USPQ2d 1976, 1983-84 (2014) ("The fact that a computer ‘necessarily exist[s] in the physical, rather than purely conceptual, realm,’ is beside the point"). See also Genetic Technologies Ltd. v. Merial LLC, 818 F.3d 1369, 1377, 118 USPQ2d 1541, 1547 (Fed. Cir. 2016) (steps of DNA amplification and analysis are not "sufficient" to render claim 1 patent eligible merely because they are physical steps). Conversely, the presence of a non-physical or intangible additional element does not doom the claims, because tangibility is not necessary for eligibility under the Alice/Mayo test. Enfish, LLC v. Microsoft Corp., 822 F.3d 1327, 118 USPQ2d 1684 (Fed. Cir. 2016) ("that the improvement is not defined by reference to ‘physical’ components does not doom the claims"). See also McRO, Inc. v. Bandai Namco Games Am. Inc., 837 F.3d 1299, 1315, 120 USPQ2d 1091, 1102 (Fed. Cir. 2016), (holding that a process producing an intangible result (a sequence of synchronized, animated characters) was eligible because it improved an existing technological process). Furthermore, the dependent claims are merely directed to the particulars of the abstract idea and likewise do not add significantly more to the above-identified judicial exception. The limitations of the claims do not transform the abstract idea that they recite into patent-eligible subject matter because the claims simply instruct the practitioner to implement the abstract idea using generally-recited computer components, and furthermore do not amount to an improvement to a computer or any other technology, and thus are ineligible. Step 2B: Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more than the abstract idea nor recites additional elements that integrate the judicial exception into a practical application. The additional elements of “database; module sensor; GPS; computer system”, etc. are generically-recited computer-related elements that amount to a mere instruction to “apply it” (the abstract idea) on the computer-related elements (see MPEP § 2106.05 (f) – Mere Instructions to Apply an Exception). These additional elements in the claims are recited at a high level of generality and are merely limiting the field of use of the judicial exception (see MPEP §2106.05 (h) – Field of Use and Technological Environment). There is no indication that the combination of elements improves the function of a computer or improves any other technology. Furthermore, the dependent claims are merely directed to the particulars of the abstract idea and likewise do not add significantly more to the above-identified judicial exception. The limitations of the claims do not transform the abstract idea that they recite into patent-eligible subject matter because the claims simply instruct the practitioner to implement the abstract idea using generally-recited computer components, and furthermore do not amount to an improvement to a computer or any other technology, and thus are ineligible. Examiner interprets that the steps of the claimed invention both individually and as an ordered combination result in Mere Instructions to Apply a Judicial Exception (see MPEP §2106.05 (f)). These claims recite only the idea of a solution or outcome with no restriction on how the result is accomplished and no description of the mechanism used for accomplishing the result. Here, the claims utilize a computer or other machinery (e.g., see Applicant Specification ¶’s 3-18, 45-48) regarding using existing computer processors as well as program products comprising machine-readable media for carrying or having machine-executable instructions or data structures stored. “system 100” in its ordinary capacity for performing tasks (e.g., to receive, analyze, transmit and display data) and/or use computer components after the fact to an abstract idea (e.g., a fundamental economic practice and certain methods of organization human activities) and does not provide significantly more. See Affinity Labs v. DirecTV, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016)). Software implementations are accomplished with standard programming techniques with logic to perform connection steps, processing steps, comparison steps and decisions steps. These claims are directed to being a commonplace business method being applied on a general-purpose computer (see Alice Corp. Pty, Ltd. V. CLS Bank Int’l, 134 S. Ct. 2347, 1357, 110 USPQ2d 1976, 1983 (2014)); Versata Dev. Group, Inc., v. SAP Am., Inc., 793 D.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015)) and require the use of software such as via a server to tailor information and provide it to the user on a generic computer. Based on all these, Examiner finds that when viewed either individually or in combination, these additional claim element(s) do not provide meaningful limitation(s) that raise to the high standards of eligibility to transform the abstract idea(s) into a patent eligible application of the abstract idea(s) such that the claim(s) amounts to significantly more than the abstract idea(s) itself. Accordingly, broadly recited Claims 1, 4, 5, 7, 10, 11, 13-17, and 19-22 are rejected under 35 U.S.C. §101 because the claimed invention is directed to a judicial exception (i.e. abstract idea exception) 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. 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, 4, 5, 7, 10, 11, 13-17, and 19-22 are rejected under 35 U.S.C. 103 as being unpatentable over Adler et al (Adler) (US 2016/0358451) in view of Moore, Jr. et al. (Moore) (US 2016/0379105). With regard to Claims 1, 21, Adler teaches a method for managing location-aware reminders in an automobile (FIG. 1 is a flowchart of a method for providing a location-based reminder according to an exemplary embodiment. Method 100, as shown in FIG. 1, can be performed by a device (e.g., a mobile device, such as a mobile phone, laptop, tablet, or desktop computer); vehicle; car) (see at least paragraphs 25-30, 58, 88, 129), the method comprising: receiving a voice activated command (The reminder can be created via, for example, voice command or by entering the reminder on a user interface) issued inside the automobile (e.g., a mobile device, such as a mobile phone, laptop, tablet, or desktop computer); vehicle; car) to create a first location-aware reminder including a reminder message for an actor to perform an action (a location-based reminder such as “Get bag out of trunk when I get out of car” can be created. The reminder includes the description and content of the reminder. In addition, the reminder can include location information of the car. The location information can include a general location, such as the user's home address, where the car is located), the first location-aware reminder including a class of places where the action is capable of being performed, each place in the class of places being in proximity to a different geographic region ((The reminder information which is input in input module 210 is sent to reminder creator 220. Reminder creator 220 can be a software module or other construct that can be used to initiate the creation of a location-based reminder. The reminder creator 220 receives the information that is input in the input module 220 for creating a location-based reminder; For example, a location-based reminder such as “Buy fruit at grocery store” can be created. The reminder includes the description and content of the reminder which was input. In addition, the reminder can include location information of the grocery store from which the user would like to buy the fruit. The location information can include a name of a grocery store or a specific address of a grocery store; The input sensor 270 determines whether there is input activity with the device. For example, the input sensor 270 determines whether the device is in a connected or disconnected state from a Bluetooth device of the vehicle or whether the device is connected to or disconnected from a network, such as a cloud) (see at least paragraphs 25-30, 49, 50, 58, 68-71, 88, 129); maintaining a cloud database (The input sensor 270 determines whether there is input activity with the device. For example, the input sensor 270 determines whether the device is in a connected or disconnected state from a Bluetooth device of the vehicle or whether the device is connected to or disconnected from a network, such as a cloud. Further, the input sensor can determine whether an input has been made on the device. For example, the input sensor can detect that the device was initially in a sleeping mode and has changed to an awake mode due to user activity on the device) including a plurality of location-aware reminders (providing a reminder to a user of a mobile device are provided. The method includes receiving a request to establish a first geographical area for the mobile device for triggering a first location-based reminder, the request including a flag indicating that other sensor information is to be used to determine when to provide the first location-based reminder to the user) wherein a/the first location-aware reminder of the plurality of location-aware reminders was created by a first user, is directed to a second user (When a user inputs the location-based reminder via audio, such as through a voice command, the user can verbally enter the reminder on their device. For example, the user can select an audio input button on the device, speak into the microphone of the device, and enter a reminder such as “Call Bob when I get to work using opportune mode.” Therefore, the reminder can be triggered when the user is at work (i.e., location information) and when the opportune mode requirements have been met), includes a reminder message for the second user to perform an action, and includes a class of places where the second user can perform the action, each place in the class of places being in proximity to a different geographic region (The reminder information which is input in input module 210 is sent to reminder creator 220. Reminder creator 220 can be a software module or other construct that can be used to initiate the creation of a location-based reminder. The reminder creator 220 receives the information that is input in the input module 220 for creating a location-based reminder; For example, a location-based reminder such as “Buy fruit at grocery store” can be created. The reminder includes the description and content of the reminder which was input. In addition, the reminder can include location information of the grocery store from which the user would like to buy the fruit. The location information can include a name of a grocery store or a specific address of a grocery store; The input sensor 270 determines whether there is input activity with the device. For example, the input sensor 270 determines whether the device is in a connected or disconnected state from a Bluetooth device of the vehicle or whether the device is connected to or disconnected from a network, such as a cloud. Further, the input sensor can determine whether an input has been made on the device. For example, the input sensor can detect that the device was initially in a sleeping mode and has changed to an awake mode due to user activity on the device; Location/motion module 926 can assist in determining the current position (e.g., coordinates or other geographic location identifier) and motion of device 900. Modern positioning systems include satellite based positioning systems, such as Global Positioning System (GPS), cellular network positioning based on “cell IDs,” and Wi-Fi positioning technology based on a Wi-Fi networks. GPS also relies on the visibility of multiple satellites to determine a position estimate, which may not be visible (or have weak signals) indoors or in “urban canyons.” In some embodiments, location/motion module 926 receives data from GPS unit 948 and analyzes the signals to determine the current position of the mobile device. In some embodiments, location/motion module 926 can determine a current location using Wi-Fi or cellular location technology. For example, the location of the mobile device can be estimated using knowledge of nearby cell sites and/or Wi-Fi access points with knowledge also of their locations. Information identifying the Wi-Fi or cellular transmitter is received at wireless circuitry 908 and is passed to location/motion module 926. In some embodiments, the location module receives the one or more transmitter IDs. In some embodiments, a sequence of transmitter IDs can be compared with a reference database (e.g., Cell ID database, Wi-Fi reference database) that maps or correlates the transmitter IDs to position coordinates of corresponding transmitters, and computes estimated position coordinates for device 900 based on the position coordinates of the corresponding transmitters. Regardless of the specific location technology used, location/motion module 926 receives information from which a location fix can be derived, interprets that information, and returns location information, such as geographic coordinates, latitude/longitude, or other location fix data) (see at least paragraphs 40-47, 58, 88, 129, Abstract); detecting, via an identification module configured to determine that the second user (At step 150, it is determined whether the state of the device is on an opportune list (also called a trigger list). That is, it is determined whether the state of the device is a state which is opportune for receiving the reminder as requested by the user. The opportune list can be, for example, a list including one or more trigger states which a user has identified as being appropriate for receiving the reminder) is present in the automobile using one or more of identification of the second user (When a user inputs the location-based reminder via audio, such as through a voice command, the user can verbally enter the reminder on their device. For example, the user can select an audio input button on the device, speak into the microphone of the device, and enter a reminder such as “Call Bob when I get to work using opportune mode.” Therefore, the reminder can be triggered when the user is at work (i.e., location information) and when the opportune mode requirements have been met), the presence of a mobile device associated with the second user, or a manual identification of the second user to the automobile (At step 140, the state of the device can be determined based on sensors. One or more sensors of the device can provide information for determining the state, several states, or a sequence of states of the device in order to determine whether or not the device has entered a trigger state for triggering the reminder. For example, motion sensors and input sensors or a combination of motion sensors and input sensors can be used to detect whether motion activity or input activity has occurred. The motion activity and input activity can be directed to states which indicate that the device has entered an opportune mode for receiving a reminder) (see at least paragraphs 33-50); monitoring a geographic location of the automobile using a computer system (Specifically, the device monitors, using location circuitry, a location of the device to identify whether a geographical area is triggered by the device arriving at a boundary of the geographical area) installed in the automobile (Motion activity can be used to determine when the device has transitioned from a sedentary state (e.g., mobile device is placed in car device holder) to a dynamic state, such as running or walking. Further, if the device is in a static state (e.g., device is sitting in a user's car) and then the device is moved (e.g., beyond a threshold), it can be determined that the device is picked up, and thus it is an opportune time to trigger a reminder) (see at least paragraphs 25-36, 58, 88); detecting, using the computer system, that the automobile has entered a geographic region in proximity to any one of the places (grocery store; location information) where the second user can perform the action for the first location-aware reminder (A geo-fence is a geographical boundary. Specifically, the geo-fence is a point, line, boundary or geographical area and can be of various shapes and sizes. The geo-fence can be set according to global positioning system (GPS) information; however, a geo-fence is not limited to GPS information and other location services can be used. For example, the user's home or a grocery store can be set as a geo-fence or a boundary of a geographical area. A device has crossed a geo-fence or boundary area when it has reached the boundary area or has gone past the designated boundary area) (see at least paragraphs 25-34, 47, 48, 58, 88); issuing, from the computer system/via conversion of the reminder message from text to speech (Voice and data information received by wireless circuitry 908 (e.g., in speech recognition or voice command applications) is sent to one or more processors 918 via peripherals interface 916), an audible reminder (Selection of an audio input button is described, however, any method of inputting audio by a user can be used. Use of a voice command and a user interface for creating a reminder has been described; For example, the user can select an audio input button on the device, speak into the microphone of the device, and enter a reminder such as “Call Bob when I get to work using opportune mode.” Therefore, the reminder can be triggered when the user is at work (i.e., location information) and when the opportune mode requirements have been met), the reminder message for the second user to perform the action to the second user based on the detection of the second user in the automobile (the state of the device can be determined based on sensors. One or more sensors of the device can provide information for determining the state, several states, or a sequence of states of the device in order to determine whether or not the device has entered a trigger state for triggering the reminder. For example, motion sensors and input sensors or a combination of motion sensors and input sensors can be used to detect whether motion activity or input activity has occurred. The motion activity and input activity can be directed to states which indicate that the device has entered an opportune mode for receiving a reminder) and the detection of the automobile in the geographic region in proximity to the place (a location-based reminder such as “Get bag out of trunk when I get out of car” can be created. The reminder includes the description and content of the reminder. In addition, the reminder can include location information of the car. The location information can include a general location, such as the user's home address, where the car is located) where the second user can perform the action (a location-based reminder such as “Buy fruit at grocery store” can be created. The reminder includes the description and content of the reminder which was input. In addition, the reminder can include location information of the grocery store from which the user would like to buy the fruit. The location information can include a name of a grocery store or a specific address of a grocery store) (see at least paragraphs 25-34, 47-50, 58, 71, 88, 121); Adler does not specifically teach biometric identification. Moore teaches biometric identification (biometric and environmental data) in analogous art of recognize patterns of user behaviors for the purposes of: “as the digital assistant typically maintains awareness of device state and other context, it may be invoked or controlled by specific context such as user input, received notifications, or detected events associated with biometric or environmental data. For example, the digital assistant can behave in particular ways and surface appropriate user experiences when biometric and environmental data indicates that the user is active and moving around outdoors as compared to occasions when the user is sitting quietly inside (see at least paragraphs 31-39, 104-105). It would have been obvious to one of ordinary skill in the art at the time of the invention to include behavior recognition and automation using a mobile device as taught by Moore in the system of Adler, since the claimed invention is merely a combination of old elements, and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art would have recognized that the results of the combination were predictable. With regard to Claim 4, Adler teaches wherein issuing the reminder message includes audibly emitting the reminder message from a loudspeaker of the reminder system (see at least paragraph 69). With regard to Claim 5, Adler teaches wherein issuing the reminder message includes presenting a textual representation of the reminder message on a display of the computer system (see at least paragraph 40). With regard to Claim 7, Adler teaches wherein the detecting further includes accessing the cloud database from the automobile over a network connection (see at least paragraphs 37, 47, 58). With regard to Claim 10, Adler teaches: receiving, at the navigation system, a command to create the first location-aware reminder from the first user, processing the command to generate the first location-aware reminder, and storing the location-aware reminder in the cloud database (see at least paragraphs 25-30, 37, 47, 58). With regard to Claim 11, Adler teaches wherein processing the command to generate the first location-aware reminder includes determining an identity of the first user, an identity of the second user, and information related to the class of places where the second user can perform the action (see at least paragraphs 28, 39, 47, 58, 98). With regard to Claim 13, Adler teaches wherein the command is received as a voice command (see at least paragraph 27). With regard to Claim 14, Adler teaches wherein the computer system includes a navigation system configured to monitor the geographic location of the vehicle (see at least paragraph 125). With regard to Claim 15, Adler teaches wherein the computer system includes an infotainment system including a display through which the reminder message is issued (see at least paragraphs 131-135). With regard to Claim 16, Adler teaches wherein the location-aware reminder includes a reminder data structure stored in the cloud database, the reminder data structure including the reminder location data, an addressee for the reminder, and a reminder message (see at least paragraphs 47, 94-96, Abstract). With regard to Claim 17, Adler teaches wherein detecting that the automobile has entered a geographic region in proximity to any one of the places where the second user can perform the action for the first location aware reminder includes extracting the reminder data structure for the first location-aware reminder from the reminder database and extracting the reminder location from the cloud data structure (see at least paragraphs 47, 94-96, Abstract). With regard to Claim 19, Adler teaches wherein a polling module regularly polls the cloud database to determined whether any reminders exist for a current geographical position of the automobile (the user may receive a call even though the user has not addressed a reminders which is appearing on their lock screen. In order to answer the call, the user unlocks the device 800, as shown in FIG. 8B. In accordance with an exemplary embodiment, after the user has completed their phone call and their device is again locked, the reminders can continue to remain on the lock screen or stick to the lock screen, as shown in FIG. 8C; Therefore, even if the user unlocks their device, the reminders can still remain or stick to the lock screen, even though they have unlocked their device, until the user has addressed the reminder. Consequently, the reminder will not be lost when the user unlocks their screen) (see at least paragraphs 115, 116). With regard to Claim 20, Adler teaches wherein voice activated commands issued inside the automobile are used to create the first location-aware reminder (see at least paragraph 27). With regard to Claim 22, Adler teaches wherein a camera in the automobile is used to detect the presence of the actor (see at least paragraph 124). Conclusion The prior art made of record and not relied upon is considered pertinent to Applicant's disclosure: Colligan et al. (US 2010/0161720) 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to THOMAS L MANSFIELD whose telephone number is (571)270-1904. The examiner can normally be reached M-Thurs, alt. Fri. (9-6). 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, Patricia Munson can be reached at (571) 270-5396. 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. THOMAS L. MANSFIELD Examiner Art Unit 3623 /THOMAS L MANSFIELD/Primary Examiner, Art Unit 3624
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Prosecution Timeline

Jun 28, 2022
Application Filed
Jan 13, 2024
Non-Final Rejection — §101, §103
Jun 11, 2024
Response Filed
Sep 09, 2024
Final Rejection — §101, §103
Dec 06, 2024
Response after Non-Final Action
Dec 18, 2024
Request for Continued Examination
Dec 19, 2024
Response after Non-Final Action
Jul 26, 2025
Non-Final Rejection — §101, §103
Oct 30, 2025
Response Filed
Feb 02, 2026
Final Rejection — §101, §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
50%
Grant Probability
84%
With Interview (+34.0%)
4y 5m
Median Time to Grant
High
PTA Risk
Based on 584 resolved cases by this examiner. Grant probability derived from career allow rate.

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