Prosecution Insights
Last updated: May 29, 2026
Application No. 18/046,054

PATHNAME RECOMMENDATIONS WHEN SAVING, RENAMING OR MOVING FILES

Final Rejection §101
Filed
Oct 12, 2022
Examiner
THAI, HANH B
Art Unit
2163
Tech Center
2100 — Computer Architecture & Software
Assignee
International Business Machines Corporation
OA Round
2 (Final)
87%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
90%
With Interview

Examiner Intelligence

Grants 87% — above average
87%
Career Allowance Rate
695 granted / 798 resolved
+32.1% vs TC avg
Minimal +3% lift
Without
With
+2.6%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
18 currently pending
Career history
816
Total Applications
across all art units

Statute-Specific Performance

§101
6.7%
-33.3% vs TC avg
§103
71.8%
+31.8% vs TC avg
§102
9.3%
-30.7% vs TC avg
§112
0.5%
-39.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 798 resolved cases

Office Action

§101
DETAILED ACTION This is Final Office Action in response to amendment filed on February 23, 2026. Claims 1-20 are presented for examination. Response to Arguments Applicant's arguments have been fully considered but they are not persuasive. Applicant argues that the claims does not recite abstract idea “judicial exception” and are integrated into a practical application such an “automatically generating pathnames and filenames base on contextual data of the user” using computer implemented (response 2/23/2026, pages 2-3). The examiner respectfully disagrees. The claim reciting “automatically generating pathnames and filenames base on contextual data of the user” is directed to an abstract idea because it amounts to mental processes and methods of organizing and managing information, which can be performed in the human mind. Generating pathnames or filenames based on contextual information is a form of data organization and categorization, which is a abstract idea. The merely recitation of “computer implemented” does not integrate the abstract idea into a practical application, but instead merely indicates the use of a computer as a tool to perform the abstract idea. Accordingly, the additional recitation of computer implementation does not impose meaningful limits on the abstract idea and fails to transform the claim into patent-eligible subject matter. Applicant further argues that the claim recite an improvement using machine learning techniques to provide practical application of generating pathname and filename to save, move, or copy files for the user, and therefore are not directed to abstract idea (response 2/23/2026, pages 4-5 ). The examiner respectfully disagrees. The use of a ”machine learning model to generate pathname and filename to save, move, or copy files” merely applies the abstract idea of generating pathname and filename using generic computer technology recited at a high level of generality, such generic computer components are considered well-understood, routine, and conventional under Step 2A Prong Two. The claimed amendment does not overcome the rejection under 35 USC § 101. The claims continue to recite patent ineligible subject matter under the framework set forth in the 2019 Revised Patent Subject Matter Eligibility Guidance, as explained in detailed in the rejection below. 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 of mental process without significantly more. The claims recite “receiving a request to save, rename or move a file; determining real-time context data and meta-data for the file in response to receiving the request to save, rename or move the file; collecting the context data in real time associated with a user of the file; classifying, by a deep learning processing technique, the context data and meta-data; ranking the context data and meta-data based on relevancy and accuracy; generating a suggested pathname …; and presenting the suggested pathname to a user”. This judicial exception is not integrated into a practical application because the steps can be performed manually in human mind. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the claim here merely uses the processor “computer” as a tool to perform the otherwise mental processes. See October Update at Section I(C)(ii). Thus, the limitations recite concepts that fall into the “mental process” grouping of abstract ideas. ANALYSIS under Revised Guidance of 2019 PEG: Statutory Category: The claims 1-20 are directed to one of the four statutory category (claims 1-11 a method or a process, claim 12 a computer readable storage medium and claims 13-20 a system or a machine). Step 2A – Prong 1: Is there a Judicial Exception (e.g. abstract idea)? (See MPEP§§2106.04(II)(A)(1), 2106.04(a)(2)). Claim 1 recites, at its core, the limitations directed to collecting data (e.g., context data and metadata), analyzing or classifying data (e.g., via deep learning, ranking), generating a result (e.g., suggested pathname), and presenting the result. These limitations can be characterized as collecting data and evaluating, ranking, classifying, or organizing information, which falls within mental processes, and certain methods of organizing human activity (e.g., file organization or renaming), Although the claim recites “deep learning,” this is merely generic data analysis and does not provide any specific technical implementation. Accordingly, claim 1 recites an abstract idea under step 2A, prong 1. Step 2A – Prong 2: Is the abstract idea integrated into a practical application? (See MPEP§§2106.04(II)(A)(2), 2106.04(d)). Claim 1 recites additional elements such as “IoT sensor”, “image processing,” and “speech recognition,” which are merely data sources rather than technical improvements, and do not provide any improvement to computer functionality, file systems, data structures, or storage mechanisms. These elements are generic computer components. The claim further recites using AI to suggest a file name or pathname, but does not improve how files are stored, accessed, or managed at a technical level. The claim does not recite any improvement to storage architecture, any improvement to processor efficiency at a technical level, or any specific mechanism for reducing energy usage (e.g., hardware control, or a caching strategy). Instead, the claim merely uses a computer as a tool to perform the abstract idea, rather than improving the computer itself. Therefore, the claim does not provide meaningful integration into a practical application and fails to meet step 2A, prong 2. Step 2B: significantly more or amounting to an incentive concept. (See MPEP§2106.05). Claim 1 recites additional elements such as “IOT sensors,” “speech recognition,” and “image processing”. These elements are well-understood, routine, and conventional, and are described functionally rather than structurally. The claim does not recite a specific model architecture, training technique, technical constraint, or system level improvement. Thus, the additional elements amounts to no more than mere instructions to apply the judicial exception and do not integrate a judicial exception into a practical application or provide an inventive concept. Accordingly, the claim fails under step 2B because the mere implementation on a computer does not provide significantly more. Dependent claim 2 recites “the folder or directory name is determined based on the filetype for the file” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claims 3-4 recites “…edit and approve the suggested pathname” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claim 5 recites “saving the file to the suggested pathname in response to the user approving the suggested pathname” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claim 6 recites “a password hint for the file, storage attributes for the file, collaboration data for the file, calendar data for the user, and a file naming policy for an organization” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claim 7 recite “wherein the context data comprises a topic determined from content within the file and wherein the content comprises one or more of text, an image, and video” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claim 8 recite “automatically organizing pathnames based on the context data and the meta-data for the file” abstract idea under step 2A(ii). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claims 9-10 recite “content comprises one or more of text, an image, and video and real-time IoT data…” abstract idea under step 2A(ii). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Dependent claim 11 recite “presenting multiple suggested pathnames to the user” abstract idea under step 2A(i). Therefore, the claimed elements fail to integrate the judicial exception into a practical application. Claims 12 and 13 are rejected due to the similar analysis of claim 1 Claims 14-20 are similar to claims 2-10 and therefore not drawn to eligible subject matter as they are directed to an abstract idea without significantly more. Therefore, claims 1-20 are not patent eligible. Allowable Subject Matter Claims 1-20 are allowable over the prior art of record. However, they would be in condition for allowance if rewritten in a manner that overcomes the abstract idea issues. The following is a statement of reasons for the indication of allowable subject matter: Regarding claim 1, the closest art, Kumar (US 20180121825 A1) disclose a computer-implemented method for saving, renaming, or moving a file (¶[0017], Kumar), the method comprising: receiving a request to save, rename or move a file (¶[0017],[0024] and [0041]-[0042], Kumar, i.e., request to name a content item); determining real-time context data and meta-data for the file in response to receiving the request to save, rename or move the file (¶[0017], [0024], [0036]-[0039] and [0051], Kumar, i.e., determining characteristics of the content item in response to request to name content item when the user attempts to store the content item to a storage device); generating a suggested pathname using the real-time context data and meta-data (¶[0017], [0041], [0046] and [0050], Kumar, i.e., generating name suggestions for naming the content item); presenting the suggested pathname to a user (¶[0018] and [0028], Kumar, i.e., displaying name suggestions as graphical elements on a display device of the user's client device or providing the name suggestions to the user); and wherein the suggested pathname comprises a folder or directory name and a filename (¶[0021] and [0028], Kumar, i.e., suggestions of file or folder name). Cohen et al. (US 20160132606 A1) discloses semantically-oriented structure for organizing and accessing content items that determining context data and metadata for the file (¶[0063]-[0065], Cohen) and generating a suggested pathname (¶[0049], [0052] and [0063]-[0067], Cohen). However, the prior art fails to disclose or suggest “receiving the request to save, rename or move the file further comprising: collecting the context data in real time associated with a user of the file, wherein a source of the context data is collected from, at least but not limited to, a loT sensor set associated with the user, an imaging processing technique associated with the user, speech recognition used to extract text from audio files associated with the user; classifying, by a deep learning processing technique, the context data and meta-data; and ranking the context data and meta-data based on relevancy and accuracy; automatically generating a suggested pathname based on the ranking and classification of using the real time context data and meta-data.” 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 HANH B THAI whose telephone number is (571)272-4029. The examiner can normally be reached Mon-Friday 7-4:30. 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, Tony Mahmoudi can be reached at 571-272-4078. 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. /HANH B THAI/Primary Examiner, Art Unit 2163 November 15, 2025
Read full office action

Prosecution Timeline

Oct 12, 2022
Application Filed
Nov 14, 2023
Response after Non-Final Action
Nov 28, 2025
Non-Final Rejection mailed — §101
Feb 11, 2026
Interview Requested
Feb 18, 2026
Examiner Interview (Telephonic)
Feb 18, 2026
Examiner Interview Summary
Feb 23, 2026
Response Filed
Apr 28, 2026
Final Rejection mailed — §101 (current)

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Prosecution Projections

3-4
Expected OA Rounds
87%
Grant Probability
90%
With Interview (+2.6%)
2y 7m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 798 resolved cases by this examiner. Grant probability derived from career allowance rate.

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