Prosecution Insights
Last updated: April 19, 2026
Application No. 18/104,146

AUTOMATED TRANSLATION OF MESSAGES WITHIN A GROUP COMMUNICATION SESSION

Non-Final OA §101§102§103
Filed
Jan 31, 2023
Examiner
WEAVER, ADAM MICHAEL
Art Unit
2658
Tech Center
2600 — Communications
Assignee
Zoom Video Communications, Inc.
OA Round
3 (Non-Final)
92%
Grant Probability
Favorable
3-4
OA Rounds
2y 9m
To Grant
99%
With Interview

Examiner Intelligence

Grants 92% — above average
92%
Career Allow Rate
11 granted / 12 resolved
+29.7% vs TC avg
Strong +20% interview lift
Without
With
+20.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
27 currently pending
Career history
39
Total Applications
across all art units

Statute-Specific Performance

§101
33.2%
-6.8% vs TC avg
§103
44.7%
+4.7% vs TC avg
§102
19.0%
-21.0% vs TC avg
§112
2.1%
-37.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 12 resolved cases

Office Action

§101 §102 §103
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 Amendment The Amendment filed 02/11/2026 has been entered. Claims 1-20 remain pending in the application. Response to Arguments Applicant’s arguments filed 02/11/2026 have been fully considered but they are not persuasive. With respect to the 35 U.S.C. 101 rejection, on pages 9-13, the Applicant asserts that independent claims, as amended, includes additional elements that constitute an improvement to automated translation technologies, and therefore is not directed to an abstract idea without significantly more. The Applicant attests that the independent claims constitute an improvement to automated translation devices. The Applicant also attests that the inclusion of “wherein the initial chat message is automatically replaced with the translation in the target language” integrates the alleged mental process into a practical application. The Applicant also states that existing technologies have an inadequate user interface and fail to take into account all available information. The Examiner respectfully disagrees. It appears the applicant is restating what is in the claim language without specifically identifying what elements and how each limitation is significantly more. The Applicant provides Figs. 3A and 3B as support for this improvement to automated translation technology, but the support of “translating, in real-time” and “displaying… the translated message within the display section of the UI, wherein the initial chat message is automatically replaced with the translation in the target language” is still regarded as a mental process. More specifically, this language is a purely post-solutional activity of displaying data. The Examiner has considered all of the limitations as noted by the Applicant as part of the abstract idea as mental activities. The Applicant has not provided any reasoning or evidence as to why the noted limitations are not mental activities. The Examiner also noted in the rejection noted below that the claims only recited a few additional limitations of “a client device”, “a user interface (UI)”, and “the display section”. These elements, as stated below, are general purpose computing elements. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Hence, the Applicant’s arguments are not persuasive. With respect to the 35 U.S.C. 102 rejection, on pages 13-14, of claims 1-17 and 20 under Lai et al. (US Patent Application Publication No. 2010/0293230), hereinafter referred to as Lai, and to the 35 U.S.C. 103 rejection, on page 14, of claims 18-19 under Lai et al., in view of Orsini et al. (US Patent Application Publication No. 2014/0337989), hereinafter referred to as Orsini, the Applicant asserts that Lai does not disclose or suggest “[conversational contexts comprising] a previous group communication session in which at least one participant of the two or more participants was a participant” or “displaying… wherein the initial chat message is automatically replaced with the translation in the target language” as recited in amended claim 1. In response to Lai not disclosing or suggesting “[conversational contexts comprising] a previous group communication session in which at least one participant of the two or more participants was a participant”, Lai para [0078] states “In an illustrative embodiment, once group chat session 706 is established, group chat server computer 703 or one or more participant computers 701 and 702 transmit group chat session history 714 to messaging client computer 704. Messaging client computer 704 passes group chat session history 714 to translation manager process 705. Translation manager process 705 analyzes group chat session history 714 and determines one or more group chat session history languages 721.” This shows that Lai determines the languages to be translated, i.e. a conversational context, based on the historical messages sent between the parties within the chat system. In response to Lai not disclosing or suggesting “displaying… wherein the initial chat message is automatically replaced with the translation in the target language”, Lai para [0087] states “In this example, the user has set the display options to display the translated content in text box 804, with the original text available by hovering the mouse over the translated text.” This shows that the sent message is automatically translated, since the user has selected the option to display the translated text content, where the user is also able to see the original text by hovering their cursor over the automatically translated text. 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. Claim(s) 1-20 rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Independent claims 1, 13, and 20 recite “displaying, at a client device associated with a user, a user interface (UI) for a group communication session”, “receiving a plurality of chat messages”, “determining one or more conversational contexts between two or more participants”, “determining, based on at least one of the conversational contexts, at least one target language for translation”, “determining a source language”, “determining whether there is a match between the source language for the initial chat message and the at least one target language”, “translating, in real-time, the initial chat message”, “replacing the initial chat message with the translation”, and “displaying, at the client device, the translated chat message”. These limitations, as drafted, are a process that, under a broadest reasonable interpretation, covers the abstract idea of “mental processes” because they cover concepts performed in the human mind, including observation, evaluation, judgement, and opinion. See MPEP 2106.04(a)(2). Nothing in the claimed elements preclude the steps from practically being performed by a person receiving and reading a chat message from another person, determining a context of conversation based on a history of the group messages, and translating the message into a preferred language. This judicial exception is not integrated into a practical application because the additional elements “a client device”, “a user interface (UI)”, and “the display section” are all recited at a high- level of generality. Accordingly, these additional elements 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 as a whole are directed to an abstract idea (Step 2A, prong two). Claims 1, 13, and 20 do not include any additional elements that are sufficient to amount to significantly more than the judicial exception because, as discussed above with respect to integration of the abstract idea into a practical applications, the additional elements of “a client device”, “a user interface (UI)”, and “the display section” amount to no more than mere instructions to apply the exception using generic computer components. Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept (Step 2B). Dependent claims 1-12 and 14-19 are directed to the communication session, the conversational context, the language for translation, and user preferences. That is, nothing in the claimed elements, preclude the steps from practically being performed by a person receiving and reading a chat message from another person, determining a context of conversation based on a history of the group messages, and translating the message into a preferred language. Even when considered individually and in combination, the additional elements in claims 1-20 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 (Step 2B). Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 1-17 and 20 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Lai et al. (US Patent Application No. 20100293230), hereinafter Lai. Regarding claim 1, Lai discloses a method, comprising: displaying, at a client device associated with a user, a user interface (UI) for a group communication session, the UI comprising a display section for receiving chat messages associated with a plurality of participants of the group communication session (Fig. 7-9 show block diagrams and UIs of group chat sessions that show receiving messages from all session members); receiving a plurality of chat messages sent by at least a subset of the plurality of participants (Fig. 9 shows a UI for a group chat session, reference character 903 shows where all text messages sent appear); determining one or more conversational contexts between two or more participants of the group communication session ("In illustrative embodiments, translation manager process 309 analyzes incoming electronic communication 311 and automatically identifies incoming communication language 312," Lai para [0054], this is done through an algorithm, such as tri-gram language modeling, which inherently determines the context of the conversation as well since it looks multiple words into the past of the conversation), wherein the one or more conversational contexts comprise a previous group communication session in which at least one participant of the two or more participants was a participant (“In an illustrative embodiment, once group chat session 706 is established, group chat server computer 703 or one or more participant computers 701 and 702 transmit group chat session history 714 to messaging client computer 704. Messaging client computer 704 passes group chat session history 714 to translation manager process 705. Translation manager process 705 analyzes group chat session history 714 and determines one or more group chat session history languages 721,” Lai para [0078]); determining, based on at least one of the conversational contexts, at least one target language for translation (Fig. 10 reference character 1008 and "The messaging client computer then identifies a desired display language (1008). The desired display language may be identified using, for example, user input or default settings of the system," Lai para [0091]); and upon receiving the plurality of chat messages: determining a source language for an (Fig. 10 reference character 1006 and "The messaging client computer then determines an incoming electronic communication language (1006). The determination may be made using well-known algorithms, such as the trigrams algorithm," Lai para [0091]); determining whether there is a match between the source language for the initial chat message and the at least one target language (Fig. 10 reference character 1012 and "The incoming electronic communication is translated into the desired display language using a translation service to form a translated incoming electronic communication responsive to a determination that the language differs from the desired display language," Lai para [0007]); if there is no match, translating, in real-time, the initial chat message into the at least one target language (Fig. 10 reference character 1016 and "The incoming electronic communication is translated into the desired display language using a translation service to form a translated incoming electronic communication responsive to a determination that the language differs from the desired display language," Lai para [0007]); and displaying, at the client device, the translated chat message within the display section of the UI (Fig. 10 reference character 1018 and "The translated incoming electronic communication is displayed in the session on a display device," Lai para [0007]), wherein the initial chat message is automatically replaced with the translation in the target language (“In this example, the user has set the display options to display the translated content in text box 804, with the original text available by hovering the mouse over the translated text,” Lai para [0087]). Regarding claim 2, Lai discloses the method of claim 1, wherein the group communication session is one or more of: chat-based, video-based, and audio-based ("Electronic communication 303 and electronic communication 306 may consist of text, audio, video, and/or some other suitable information," Lai para [0050]). Regarding claim 3, Lai discloses the method of claim 1, wherein at least one of the conversational contexts relates to a language shared between the participants in the conversational context, the user being one of the participants in the conversational context ("In one illustrative embodiment, a language is identified using a processor for an incoming electronic communication received from a sender computer in the session," Lai para [0007] and "The messaging client computer then identifies a desired display language (1008). The desired display language may be identified using, for example, user input or default settings of the system," Lai para [0091]). Regarding claim 4, Lai discloses the method of claim 1, wherein at least one of the conversational contexts relates to a language shared between the participants in the conversational context, the user being different from the participants in the conversational context ("In one illustrative embodiment, a language is identified using a processor for an incoming electronic communication received from a sender computer in the session," Lai para [0007]). Regarding claim 5, Lai discloses the method of claim 1, wherein at least one of the conversational contexts is inferred from one or more of: chat messages, audio messages, or video messages between two or more of the participants in the group communication session ("Electronic communication 303 and electronic communication 306 may consist of text, audio, video, and/or some other suitable information," Lai para [0050]). Regarding claim 6, Lai discloses the method of claim 1, wherein determining the at least one target language for translation is further based on one or more preconfigured user preferences ("The messaging client computer then identifies a desired display language (1008). The desired display language may be identified using, for example, user input or default settings of the system," Lai para [0091]). Regarding claim 7, Lai discloses the method of claim 1, wherein determining the at least one target language for translation is further based on one or more inferred user preferences ("The messaging client computer then identifies a desired display language (1008). The desired display language may be identified using, for example, user input or default settings of the system," Lai para [0091]). Regarding claim 8, Lai discloses the method of claim 7, wherein at least one of the inferred user preferences is inferred from analyzing one or more of: transcripts of past conversations, and determined conversational contexts of past group communication sessions (Fig. 13 reference characters 1310, 1312, 1314, and 1316). Regarding claim 9, Lai discloses the method of claim 1, wherein the group communication session is a channel maintained on a communication platform, a target language being prespecified for all chat messages received within the channel ("Each session 310 and 315 may contain desired display languages 314 and 319, respectively. Desired display language 314 and 319 may be set by the user on a per-session basis and may be changed at any time," Lai para [0052]). Regarding claim 10, Lai discloses the method of claim 9, wherein for each received chat message, one translation is performed for all participants within the channel ("Translation service computer 413 performs machine translation on outgoing electronic communication 408 and returns translated outgoing electronic communication 412 to messaging client computer 404. Messaging client computer 404 transmits outgoing electronic communication 408 to communication server computer 403," Lai para [0067]; this only shows one translation occurring from messaging client compute to recipient computer). Regarding claim 11, Lai discloses the method of claim 1, wherein the at least one target language comprises two or more target languages, and wherein the two or more target languages are displayed simultaneously for each of the translated chat messages that are displayed ("Translated incoming electronic communications from all participants in list 905 are displayed in text box 903. The user sets the incoming communication language using dropdown field 906, and the desired display language using dropdown field 907," Lai para [0089]). Regarding claim 12, Lai discloses the method of claim 1, wherein the at least one target language comprises two or more target languages, and wherein any of the two or more target languages may be displayed for each of the translated chat messages based on a ("The user may also set display options in dropdown 908. In this example, the user has set the display options to display the translated content in text box 903, with the original text available by hovering the mouse over the translated text," Lai para [0090]). As to claim 13, system claim 13 and method claim 1 are related as method and system of using same, with each claimed element’s function corresponding to the method step. Accordingly, claim 13 is similarly rejected under the same rationale as applied above with respect to the method claim. Regarding claim 14, Lai discloses the communication system of claim 13, the one or more processors being further configured to perform the operation of: displaying, on one or more additional client devices associated with one or more of the participants other than the user, a notification that chat messages sent to the user are being translated into the at least one target language ("The user may also set display options in dropdown 813. In this example, the user has set the display options to display the translated content in text box 807, with the original text available by hovering the mouse over the translated text," Lai para [0088], other display options in dropdown 813 could include notifications of translations, or displaying both the original message and translation and stating what the languages are). Regarding claim 15, Lai discloses the communication system of claim 13, the one or more processors being further configured to perform the operation of: displaying, at an additional client device associated with a sending participant of the initial chat message, the translated chat message in the target language ("A session may be a chat between two or more users of a messaging system," Lai para [0027] and "Translated incoming electronic communications from all participants in list 905 are displayed in text box 903," Lai para [0089]). Regarding claim 16, Lai discloses the communication system of claim 13, the one or more processors being further configured to perform the operation of: displaying, at the client device, the initial chat message as originally sent alongside the translated chat message within the display section of the UI ("The user may also set display options in dropdown 908. In this example, the user has set the display options to display the translated content in text box 903, with the original text available by hovering the mouse over the translated text," Lai para [0090]). Regarding claim 17, Lai discloses the communication system of claim 13, wherein the translating is performed via one or more of: a translation Application Programming Interface (API) associated with a communication platform which maintains the group communication session, and a third-party translation API ("Translation manager process 309 may request incoming electronic communication 311 be translated by translation service computer 320 by using, for example, an application programming interface (API) call, remote procedure call (RPC), or a service-oriented architecture (SOA) request," Lai para [0055]). As to claim 20, computer-readable medium (CRM) claim 20 and method claim 1 are related as method and CRM of using same, with each claimed element’s function corresponding to the method step. Accordingly, claim 20 is similarly rejected under the same rationale as applied above with respect to the method claim. 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. Claim(s) 18-19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lai in view of Orsini et al. (US Patent Application No. 20140337989), hereinafter Orsini. Regarding claim 18, Lai discloses the system of claim 13. Lai fails to disclose: upon the group communication session being terminated, providing a UI for the user to review a transcript of the translated chat messages within the group communication session. Orsini teaches various forms of multi-lingual communications. Orsini teaches the communication system of claim 13, the one or more processors being further configured to perform the operation of: upon the group communication session being terminated, providing a UI for the user to review a transcript of the translated chat messages within the group communication session (Fig. 33B reference character 3312). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Lai’s teachings of automatic understanding and translation of incoming and outgoing messages with Orisini’s teaching of a system for viewing a transcript of the translated chat messages that were sent and received during the messaging session. This would allow for all users to be able to catalog what was said in their own history for later review, allowing call-backs or written histories that are important or relevant to users. This would have been obvious to one of ordinary skill in the art. Regarding claim 19, Lai discloses the system of claim 13. Lai fails to disclose: upon the group communication session being terminated, providing, at the client device, a UI for the user to request translation of the chat messages from the group communication session into one or more additional languages different from the at least one target language; translating the chat messages from the group communication session into the one or more additional languages; and displaying, at the client device, a transcript of the translated chat messages in the one or more additional languages within the group communication session. Orsini teaches the communication system of claim 13, the one or more processors being further configured to perform the operation of: upon the group communication session being terminated, providing, at the client device, a UI for the user to request translation of the chat messages from the group communication session into one or more additional languages different from the at least one target language (Fig. 33B reference character 3314 and 3316); translating the chat messages from the group communication session into the one or more additional languages (Fig. 33B reference character 3314 and 3316); and displaying, at the client device, a transcript of the translated chat messages in the one or more additional languages within the group communication session ("The chat history module 3300 preferably performs the transformations and/or translations in real-time, as the user scrolls through the chat history," Orsini para [0345]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Lai’s teachings of automatic understanding and translation of incoming and outgoing messages with Orisini’s teaching of a system for translating the transcript of the messages sent into various other languages of the user’s choice. This would allow for users to be able to review the chat history in any language of their choosing, helping to further understand what was said in the time of the messaging session. This would have been obvious to one of ordinary skill in the art. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: US Patent Application Publication No. 2018/0089172 US Patent Application Publication No. 2021/0286956 Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADAM MICHAEL WEAVER whose telephone number is (571)272-7062. The examiner can normally be reached Monday-Friday, 8AM-5PM EST. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Richemond Dorvil can be reached at (571) 272-7602. 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. /ADAM MICHAEL WEAVER/ Examiner, Art Unit 2658 /RICHEMOND DORVIL/ Supervisory Patent Examiner, Art Unit 2658
Read full office action

Prosecution Timeline

Jan 31, 2023
Application Filed
May 28, 2025
Non-Final Rejection — §101, §102, §103
Aug 08, 2025
Response Filed
Dec 05, 2025
Final Rejection — §101, §102, §103
Jan 28, 2026
Applicant Interview (Telephonic)
Jan 29, 2026
Examiner Interview Summary
Feb 11, 2026
Response after Non-Final Action
Mar 04, 2026
Request for Continued Examination
Mar 06, 2026
Response after Non-Final Action
Mar 19, 2026
Non-Final Rejection — §101, §102, §103 (current)

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Study what changed to get past this examiner. Based on 4 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
92%
Grant Probability
99%
With Interview (+20.0%)
2y 9m
Median Time to Grant
High
PTA Risk
Based on 12 resolved cases by this examiner. Grant probability derived from career allow rate.

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