DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013 is being examined under the first inventor to file provisions of the AIA .
Status of the Application
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 04/23/2026 has been entered.
Status of Claims
Claims 1-23 are currently pending following this response.
New matter
No new matter has been added to the amended claims.
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 1-23 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-statutory subject matter. Specifically, claims 1-23 are directed to an abstract idea without additional elements to integrate the claims into a practical application or to amount to significantly more than the abstract idea.
Claims 1-23 are directed to a process, machine, or manufacture (Step 1), however the claims are directed to the abstract idea of creating an electronic calendar based on discussions of various topics in electronic messages by identifying calendar properties from message contents.
With respect to Step 2A Prong One of the frameworks, claim 1 recites an abstract idea. Claim 1 includes limitations for “A method for creating calendar event, comprising: receiving a first electronic message thread comprising one or more electronic messages; parsing message content and message metadata of the one or more of electronic messages of the first electronic message thread to identify a first set of event properties of a first event; determining whether the first set of event properties of the first event satisfies one or more event criteria; responsive to determining that the first set of event properties of the first event satisfies the one or more event creation criteria causing a first calendar event with event attributes to be created based on the first set of event properties of the first event and event access rights, wherein the event access rights define different access rules with respect to the event attributes of the first calendar event for different users, including a first user associated with a first client device, and causing an access link to the first calendar event to be included in a subsequent electronic message to the first client device that lacks support for features of the event management system; receiving a second electronic message thread comprising one or more electronic messages; parsing message content and message metadata of the one or more electronic messages of the second electronic message thread to identify a second set of event properties of a second event; determining whether the second set of event properties of the second event satisfies the one or more event criteria; and responsive to determining that the second set of event properties of the second event does not satisfy the one or more event creation criteria, refraining from causing a second calendar event to be created”
The limitations above recite an abstract idea under Step 2A Prong One. More particularly, the limitations above recite Certain Method of Organizing Human Activities grouping (managing calendar events, assigning permissions rules), and specifically, managing personal behavior or relationships or interactions between people (including social activities, teaching, and following rules or instructions). The claims also recite mathematical concept/data manipulation (parsing data, filtering metadata, and transmitting data from one system to another. This mirrors a traditional, non-automated administrative task. Historically, a secretary would read an office memo thread, identify the sender “initiator), the person who requested the meeting (trigger), and other recipients. The secretary would then schedule a meeting on a master calendar, granting different editing rules to the boss versus the attendees, and send a note with meeting details. As a result, claim 1 recites an abstract idea under Step 2A Prong One.
Claims 11 and 21 recite substantially similar limitations to those presented with respect to claim 1. As a result, claims 11 and 21 recite an abstract idea under Step 2A Prong One for the same reasons as stated above with respect to claim 1. Similarly, claims 2-10, 12-20, and 22-23 recite a Certain Method of Organizing Human Activities because the claimed elements describe a process for creating an event calendar for participants in an electronic message thread. As a result, claims 2-10, 12-20, and 22-23 recite an abstract idea under Step 2A Prong One.
With respect to Step 2A Prong Two of the framework, claim 1 does not include additional elements that integrate the abstract idea into a practical application. Claim 1 includes additional elements that does not recite an abstract idea. The additional elements of claim 1 include “computer-implemented”, “an electronic”, “by a processor of an event management system”, “created by the messaging system”, “wherein the first electronic message thread is received via an application programming interface (API) between the messaging system and the event management system”, “electronic”, “in a calendar system”, “wherein the calendar system is separate from the messaging system”, “wherein the second electronic message thread is received via the API between the messaging system and the event management system”. When considered in view of the claim as a whole, the steps of “receiving” do not integrate the abstract idea into a practical application because “receiving” is an insignificant extra solution activity to the judicial exception. When considered in view of the claim as a whole, the recited computer elements do not integrate the abstract idea into a practical application because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. As a result, claim 1 does not include additional elements that integrate the abstract idea into a practical application under Step 2A Prong Two.
As noted above, claims 11 and 21 recite substantially similar limitations to those recited with respect to claim 1. Although claim 11 further recites “A computing system for creating an electronic calendar event, comprising: a memory; and a processor of an event management system, the processor coupled to the memory”, and claim 21 further recites “A non-transitory computer-readable medium”, when considered in view of the claims as a whole, the recited computer elements do not integrate the abstract idea into a practical application because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. As a result, claims 11 and 21 do not include additional elements that integrate the abstract idea into a practical application under Step 2A Prong Two.
Claims 2-10, 12-20, and 22-23 include additional elements beyond those recited by independent claims 1, 11, and 21. The additional elements in the dependent claims include “event interface”, claims 4 and 14, “message interface”, claims 10 and 20. When considered in view of the claim as a whole, the recited computer element does not integrate the abstract idea into a practical application because the computer element is generic computer element that is merely used as a tool to perform the recited abstract idea. As a result, claims 2-10, 12-20, and 22-23 do not include additional elements that integrate the abstract idea into a practical application under Step 2A Prong Two.
With respect to Step 2B of the framework, claim 1 does not include additional elements amounting to significantly more than the abstract idea. As noted above, claim 1 includes additional elements that does not recite an abstract idea. The additional elements of claim 1 include “computer-implemented”, “an electronic”, “by a processor of an event management system”, “created by the messaging system”, “wherein the first electronic message thread is received via an application programming interface (API) between the messaging system and the event management system”, “electronic”, “in a calendar system”, “wherein the calendar system is separate from the messaging system”, “wherein the second electronic message thread is received via the API between the messaging system and the event management system”. The steps of “receiving” do not amount to significantly more than the abstract idea because “receiving” is well-understood, routine, and conventional computer function in view of MPEP 2106.05(d)(ll). The recited computer elements do not amount to significantly more than the abstract idea because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. As a result, claim 1 does not include additional elements that amount to significantly more than the abstract idea under Step 2B.
As noted above, claims 11 and 21 recite substantially similar limitations to those recited with respect to claim 1. Although claim 11 further recites “A computing system for creating an electronic calendar event, comprising: a memory; and a processor of an event management system, the processor coupled to the memory”, and claim 21 further recites “A non-transitory computer-readable medium”, the recited computer elements do not amount to significantly more than the abstract idea because the computer elements are generic computer elements that are merely used as a tool to perform the recited abstract idea. Further, looking at the additional elements as an ordered combination adds nothing that is not already present when considering the additional elements individually. As a result, claims 11 and 21 do not include additional elements that amount to significantly more than the abstract idea under Step 2B.
Claims 2-10, 12-20, and 22-23 include additional elements beyond those recited by independent claims 1, 11, and 21. The additional elements in the dependent claims include “event interface”, claims 4 and 14, “message interface”, claims 10 and 20. When considered in view of the claim as a whole, the recited computer element does not integrate the abstract idea into a practical application because the computer element is generic computer element that is merely used as a tool to perform the recited abstract idea. As a result, claims 2-10, 12-20, and 22-23 do not include additional elements that amount to significantly more than the abstract idea under Step 2B.
Therefore, the claims are directed to an abstract idea without additional elements amounting to significantly more than the abstract idea. Accordingly, claims 1-23 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter.
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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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 non-obviousness.
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
Claims 1-20 are rejected under 35 U.S.C. 103 as being un-patentable over Kumahara (US20170200128A1) in view of Meltzer et al. (US 20140310044 A1).
Regarding claim 1. A computer-implemented method for creating an electronic calendar event, comprising: receiving, by a processor of an event management system and from a messaging system, a first electronic message thread comprising one or more electronic messages created by the messaging system, wherein the first electronic message thread is received via an application programming interface (API) between the messaging system and the event management system; parsing, by the processor of the event management system, message content and message metadata of the one or more of electronic messages of the first electronic message thread to identify a first set of event properties of a first event; determining, by the processor of the event management system, whether the first set of event properties of the first event satisfies one or more event criteria; responsive to determining, by the processor of the event management system, that the first set of event properties of the first event satisfies the one or more event creation criteria causing, by the processor of the event management system, a first electronic calendar event with event attributes to be created in a calendar system based on thefirst set of event properties of the first event and event access rights, wherein the event access rights define different access rules with respect to the event attributes of the first electronic calendar event for different users, including a first user associated with a first client device, and causing an access link to the first electronic calendar event, created in the calendar system, to be included in a subsequent electronic message to the first client device that lacks support for features of the event management system, wherein the calendar system is separate from the messaging system; receiving, by the processor of the event management system and from the messaging system, a second electronic message thread comprising one or more electronic messages created by the messaging system, wherein the second electronic message thread is received via the API between the messaging system and the event management system; parsing, by the processor of the event management system, message content and message metadata of the one or more electronic messages of the second electronic message thread to identify a second set of event properties of a second event; determining, by the processor of the event management system, whether the second set of event properties of the second event satisfies the one or more event criteria; and responsive to determining, by the processor of the event management system, that the second set of event properties of the second event does not satisfy the one or more event creation criteria, refraining, by the processor of the event management system, from causing a second electronic calendar event to be created in the calendar system.
Kumahara teaches the following: “systems and methods that create digital events based on text contained in one or more electronic communications” (Abstract). “For instance, the event generation system can detect an event detail from a first thread of electronic communications indicating that a user intends to plan a family reunion in six months” receiving a first thread of electronic communications (para. 0071). In addition, claim 1 teaches “detecting, by at least one processor, event details from text in at least one electronic communication shared between a plurality of users of a communication application.” “In particular, in one or more embodiments, the event generation system utilizes natural language processing to identify event details and create, modify, transmit, and share digital events” (para. 0036). Also, para. 0052 teaches “the term "event details" refers to characteristics of an event. In particular, "event details" include characteristics relating to date, time, duration, location, participants, activities, schedules, performers, attendees, assignments, or organizers of an event. Thus, for example, event details related to a sporting event for a group of friends may include starting time, date, teams, venue, friends attending, food assignments, meeting place, seats, tickets, etc.” “In particular, in one or more embodiments, the event generation system utilizes natural language processing to identify event details” (para. 0036). Also, para. 0052 teaches “the term "event details" refers to characteristics of an event. In particular, "event details" include characteristics relating to date, time, duration, location, participants, activities, schedules, performers, attendees. “For example, the event generation system can train the natural language processing algorithm to distinguish between electronic communications discussing event details applicable to an old event and more recent electronic communications discussing event details applicable to a current event” (para. 0067). “More particularly, in one or more embodiments, the event generation system utilizes natural language processing techniques to identify words (e.g., nouns, adjectives, verbs, etc.) corresponding to one or more event details” (para. 0060). “The natural language processing algorithm predicts event details from the provided text and compares the prediction to the known event details. By repeatedly predicting event details based on one or more electronic communications and comparing the prediction to known event details” (para. 0061). “In response to a request including a user name, the social networking system can access a user node corresponding to the user’s name, and construct a profile page including the name, a profile picture, and other information associated with the user” (para. 0243)
Wherein architecture, Using separate APIs for different system integrations (messaging VS. calendar) is standard software architecture practice obvious to skilled persons.
Meltzer teaches identifying, by at least one server computer communicatively coupled to a network, within a database communicatively coupled to the network, the at least one invitee associated in the database with the calendar event an attendance status of the at least one invitee. In addition, Meltzer teaches in para. 0046 “Access to the API then may be governed by an access-protected URL that permits access only to properly-identified entities.” Wherein Meltzer teaches event owner designation and differential access control concepts.
The specific edit rights management system is an obvious implementation of known access control principles disclosed in Meltzer combined with participant management of Kumahara. The skilled person, faced with the need to manage different user privileges in calendar event creation from message threads, would find it obvious to implement differentiated rights based on user roles with the benefit of optimizing calendar creation (Meltzer, para. 0031)
As a result, Kumahara in view of Meltzer teaches all of the limitations of the independent claims.
Regarding Claims 2-10. Claims 2-10 recite identifying, from contents of the subsequent electronic message received additional set of event properties and event attributes including time and location, assigning the event access rights and edit rights, a user interface for receiving user’s input and displaying event information, and providing access link. The recited limitations in the dependent claims do not serve a specific technical purpose and cannot contribute to the invention's technical character. Claims 2-10 do not produce any technical effect beyond the provision of their computer implementation. Features that do not contribute to an invention's technical character cannot support the presence of an inventive step. Claims 2-10 are generic matter of routine computer programming and configuration that is obvious to the skilled person given the non-technical aspects of the disclosed subject matter as part of the aforementioned requirements specification. For these reasons, when confronted with the objective technical problem, the skilled person would implement the subject matter of claims 2-10 in the context of closest prior art of Kumahara in view of Meltzer and arrive at the subject matter of claims 2-10 without exercising any inventive skill.
Regarding claim 11, the claim recites analogous limitations to claim 1 above, and is therefore rejected on the same premise. Claim 1 is a method claim while claim 11 is directed to a system which is anticipated by Kumahara claim 11.
Regarding claims 12-20, claims 12-20 recite substantially similar limitations as claim 2-10, respectively; therefore, claims 12-20 are rejected with the same rationale, reasoning, and motivation provided above for claims 2-10, respectively. Claims 2-10 are method claims while claims 12-20 are directed to a computing system which is anticipated by Kumahara para. 0200.
Regarding claim 21, the claim recites analogous limitations to claim 1 above, and is therefore rejected on the same premise. Claim 1 is a method claim while claim 21 is directed to a non-transitory computer-readable medium which is anticipated by Kumahara claim 11.
Regarding claims 22-23, claims 22-23 recite substantially similar limitations as claim 2-3, respectively; therefore, claims 22-23 are rejected with the same rationale, reasoning, and motivation provided above for claims 2-3, respectively. Claims 2-3 are method claims while claims 22-23 are directed to a non-transitory computer-readable medium which is anticipated by Kumahara claim 11.
Conclusion
Any inquiry concerning this communication from the examiner should be directed to Abdallah El-Hagehassan whose contact information is (571) 272-0819 and Abdallah.el-hagehassan@uspto.gov The examiner can normally be reached on Monday- Friday 8 am to 5 pm.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Rutao Wu can be reached on (571) 272-6045. The fax phone number for the organization where this application or proceeding is assigned is (571) 273-3734.
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/ABDALLAH A EL-HAGE HASSAN/
Primary Examiner, Art Unit 3623
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