Prosecution Insights
Last updated: April 19, 2026
Application No. 17/806,440

COMPUTING INVERSE TEMPERATURE UPPER AND LOWER BOUNDS

Final Rejection §101
Filed
Jun 10, 2022
Examiner
LE, PHAT NGOC
Art Unit
2182
Tech Center
2100 — Computer Architecture & Software
Assignee
Microsoft Technology Licensing, LLC
OA Round
2 (Final)
67%
Grant Probability
Favorable
3-4
OA Rounds
4y 2m
To Grant
0%
With Interview

Examiner Intelligence

Grants 67% — above average
67%
Career Allow Rate
4 granted / 6 resolved
+11.7% vs TC avg
Minimal -67% lift
Without
With
+-66.7%
Interview Lift
resolved cases with interview
Typical timeline
4y 2m
Avg Prosecution
29 currently pending
Career history
35
Total Applications
across all art units

Statute-Specific Performance

§101
15.9%
-24.1% vs TC avg
§103
39.2%
-0.8% vs TC avg
§102
10.1%
-29.9% vs TC avg
§112
33.3%
-6.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 6 resolved cases

Office Action

§101
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 . Response to Arguments Claim Rejections – 35 USC 101 Applicant's arguments filed 01/22/2026 have been fully considered but they are not persuasive. Applicant asserts the claim recites an improvement in the functioning of the computing device itself by reciting steps to programmatically select the inverse temperature upper bound and lower bound to reduce the amount of manual selection and experimental testing the user has to perform, which is integrated in the practical application of solving a combinatorial optimization problem. Examiner respectfully disagrees. The claimed invention programmatically selecting temperature upper and lower bounds is the result of applying the mathematical process onto a processor, or execution in a computer environment, rather than a function of the processor itself, and thus generally linking the use of the judicial exception to a particular technological environment. Therefore, the additional elements do not contribute to the improvement, and the claim is not integrated in a practical application. Furthermore, the judicial exception alone cannot provide the improvement. See MPEP 2106.05(a). 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, 9-12, 14, 18-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Regarding claim 1, at Step 1, the claim is directed to a computing device, which is a statutory category of invention (Machine). At Step 2A Prong 1, Examiner notes that the claims are directed towards an abstract idea. The claim language has been reproduced below: A computing device comprising: a processor configured to: receive an energy function of a combinatorial optimization problem to which a solution is configured to be estimated over a plurality of timesteps (mathematical process); compute an inverse temperature lower bound for the combinatorial optimization problem, wherein computing the inverse temperature lower bound includes estimating a maximum change in the energy function between successive timesteps of the plurality of timesteps, at least in part by computing, over a plurality of variables of the energy function, a maximum of: a sum of absolute values of respective weights of terms (mathematical process) that each have a shared variable of the plurality of variables (mathematical relationship); compute an inverse temperature upper bound for the combinatorial optimization problem, wherein computing the inverse temperature upper bound includes estimating a minimum change in the energy function between successive timesteps of the plurality of timesteps, at least in part by computing, over the plurality of variables of the energy function, a minimum of: a difference between corresponding highest and second-highest absolute values of respective weights of the terms (mathematical process) that each have a shared variables (mathematical relationship); compute the solution to the combinatorial optimization problem at least in part by executing a Markov chain Monte Carlo (MCMC) algorithm over the plurality of timesteps (mathematical process), wherein: an inverse temperature of the MCMC algorithm is set to the inverse temperature lower bound during an initial timestep of the plurality of timesteps (mathematical process); and the inverse temperature of the MCMC algorithm is set to the inverse temperature upper bound during a final timestep of the plurality of timesteps (mathematical process); and output the solution. At Step 2A Prong 2, the additional elements are bolded above. The additional elements do not integrate the abstract ideas into a practical application because the computer elements, which are recited at a high level of generality, provide conventional computer functions that do not impose any meaningful limits on practicing the abstract ideas. See MPEP 2106.05(f). The limitation “a processor” is merely recited at a high level of generality. The limitations “receive an energy function” and “output the solution” are insignificant extra-solution activities of selecting type of data to be manipulated and data outputting, respectively. At Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Regarding claim 3, under Step 2A Prong 2, the claim recites additional element “wherein the combinatorial optimization problem is an Ising problem”. The additional element does not integrate the abstract ideas into a practical application because it is generally linking the judicial exception to a field of use, see 2106.05(h), and does not impose any meaningful limits on practicing the abstract idea. Under Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Regarding claim 9, under Step 2A Prong 2, the claim recites additional element “the MCMC algorithm is a simulated annealing algorithm, a parallel tempering algorithm, a simulated quantum annealing algorithm, or a population annealing algorithm”. The additional element does not integrate the abstract ideas into a practical application because it is generally linking the judicial exception to a field of use, see 2106.05(h), and does not impose any meaningful limits on practicing the abstract idea. Under Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Regarding claim 10, it is directed to the mathematical concept and/or mental process of “estimate the minimum change in the energy function at least in part by: determining that the estimate of the minimum change in the energy function is equal to zero; and in response to determining the estimate of the minimum change in the energy function is equal to zero, setting the estimate of the minimum change in the energy function to a predefined positive number”. Under Step 2A Prong 2, the claim does not recite additional elements. Under Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Regarding claim 11, under Step 2A Prong 2, the claim recites additional element “receive the energy function via a graphical user interface (GUI) without receiving the inverse temperature lower bound or the inverse temperature upper bound at the GUI;” and “output the solution to the GUI”. The additional elements do not integrate the abstract ideas into a practical application because they are insignificant extra-solution activities of data gathering and data outputting, respectively, and do not impose any meaningful limits on practicing the abstract idea. Under Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Regarding claims 12, 14, 18-19, the claims are directed to a method corresponding to the computing device of claims 1, 3, 9-10, respectively and are rejected for the same reasons therein. Regarding claim 20, at Step 1, the claim is directed to a computing device, which is a statutory category of invention (Machine). At Step 2A Prong 1, Examiner notes that the claims are directed towards an abstract idea. The claim language has been reproduced below: A computing device comprising: a processor configured to: receive an energy function of a combinatorial optimization problem to which a solution is configured to be estimated over a plurality of timesteps (mathematical process), wherein the combinatorial optimization problem is a polynomial unconstrained binary optimization (PUBO) problem (mathematical relationship); compute an inverse temperature lower bound for the combinatorial optimization problem, wherein computing the inverse temperature lower bound includes estimating a maximum change in the energy function between successive timesteps of the plurality of timesteps at least in part by computing, over a plurality of variables of the energy function, a maximum of: a sum of absolute values of respective weights of terms that each have a shared variable of the plurality of variables (mathematical process); compute an inverse temperature upper bound for the combinatorial optimization problem, wherein computing the inverse temperature upper bound includes estimating a minimum change in the energy function between successive timesteps of the plurality of timesteps at least in part by estimating, over the plurality of variables of the energy function, a minimum of: a one-variable minimum change in the energy function when a value of a variable of the plurality of variables is changed while respective values of each other variable of the plurality of variables are held constant (mathematical process); compute the solution to the combinatorial optimization problem at least in part by executing a Markov chain Monte Carlo (MCMC) algorithm over the plurality of timesteps, wherein: an inverse temperature of the MCMC algorithm is set to the inverse temperature lower bound during an initial timestep of the plurality of timesteps (mathematical process); and the inverse temperature of the MCMC algorithm is set to the inverse temperature upper bound during a final timestep of the plurality of timesteps (mathematical process); and output the solution. At Step 2A Prong 2, the additional elements are bolded above. The additional elements do not integrate the abstract ideas into a practical application because the computer elements, which are recited at a high level of generality, provide conventional computer functions that do not impose any meaningful limits on practicing the abstract ideas. See MPEP 2106.05(f). The limitation “a processor” is merely recited at a high level of generality. The limitations “receive an energy function” and “output the solution” are insignificant extra-solution activities of selecting type of data to be manipulated and data outputting, respectively. At Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Regarding claims 21-22, 24, the claims merely recite functions for computing a minimum, specifying the algorithm, and estimating the minimum that further mathematically limit the mathematical concepts, or provide additional mathematical functions, of claim 20. They do not include additional elements that would require further analysis under steps 2A prong 2 and step 2B. Regarding claim 23, under Step 2A Prong 2, the claim recites additional element “the MCMC algorithm is a simulated annealing algorithm, a parallel tempering algorithm, a simulated quantum annealing algorithm, or a population annealing algorithm”. The additional element does not integrate the abstract ideas into a practical application because it is generally linking the judicial exception to a field of use, see 2106.05(h), and does not impose any meaningful limits on practicing the abstract idea. Under Step 2B, the additional elements do not, alone or in combination, amount to significantly more than the recited judicial exception. Conclusion THIS ACTION IS MADE FINAL. 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 PHAT N LE whose telephone number is (571)272-0546. The examiner can normally be reached Monday-Friday 8:30AM-5PM ET. 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, Andrew T Caldwell can be reached at (571) 272-3702. 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. /P.N.L./ Phat LeExaminer, Art Unit 2182 (571) 272-0546 /ANDREW CALDWELL/Supervisory Patent Examiner, Art Unit 2182
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Prosecution Timeline

Jun 10, 2022
Application Filed
Oct 14, 2025
Non-Final Rejection — §101
Jan 08, 2026
Examiner Interview Summary
Jan 08, 2026
Applicant Interview (Telephonic)
Jan 22, 2026
Response Filed
Mar 26, 2026
Final Rejection — §101 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12541340
ACCUMULATOR FOR DIGITAL COMPUTATION-IN-MEMORY ARCHITECTURES
2y 5m to grant Granted Feb 03, 2026
Patent 12499175
MATRIX MULTIPLICATION METHOD AND DEVICE BASED ON WINOGRAD ALGORITHM
2y 5m to grant Granted Dec 16, 2025
Study what changed to get past this examiner. Based on 2 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
67%
Grant Probability
0%
With Interview (-66.7%)
4y 2m
Median Time to Grant
Moderate
PTA Risk
Based on 6 resolved cases by this examiner. Grant probability derived from career allow rate.

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