Prosecution Insights
Last updated: April 19, 2026
Application No. 18/339,848

FOUNDATION MODEL INTEGRATIONS FOR PERSONALIZED ENGAGEMENT WITH SOFTWARE APPLICATIONS

Final Rejection §101
Filed
Jun 22, 2023
Examiner
EL-BATHY, MOHAMED N
Art Unit
3624
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Microsoft Technology Licensing, LLC
OA Round
2 (Final)
30%
Grant Probability
At Risk
3-4
OA Rounds
3y 10m
To Grant
64%
With Interview

Examiner Intelligence

Grants only 30% of cases
30%
Career Allow Rate
71 granted / 235 resolved
-21.8% vs TC avg
Strong +33% interview lift
Without
With
+33.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 10m
Avg Prosecution
53 currently pending
Career history
288
Total Applications
across all art units

Statute-Specific Performance

§101
37.8%
-2.2% vs TC avg
§103
45.5%
+5.5% vs TC avg
§102
10.6%
-29.4% vs TC avg
§112
4.9%
-35.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 235 resolved cases

Office Action

§101
DETAILED ACTION This Final Office Action is in response Applicant communication filed on 11/3/2025. In Applicant’s amendment, claims 1, 6, 7, and 9-17 were amended. Claims 1-20 are currently pending and have been rejected as follows. IDS filed 1/7/2026 has been considered. Response to Amendments Rejections under 35 USC 101 are maintained. Rejections under 35 USC 102(a)(1) are withdrawn. Response to Arguments Applicant’s 35 USC 101 rebuttal arguments and amendments have been fully considered but they are not persuasive to overcome the rejection. Applicant argues on p. 9-10 that the claims are not directed to an abstract idea at Step 2A, Prong 1 because the claims recite a specific technological process and include functionality involving specific inter-system communication protocols between the application service and the application assistance engine. Examiner respectfully disagrees. The core focus of the claim is still to identify one or more tasks relating to a job, identify a recommended application associated with each task, and recommend a design template of the recommended application for the task. This still falls under certain methods of organizing human activity and mental processes. The use of a foundation model service does not preclude the claim from being directed to an abstract idea. The claim’s tailoring to user specific job requirements merely adds user context to make the recommendation. The claimed launching of the recommended application with the design template merely presents the output of the recited abstract idea and amounts to insignificant post-solution activity. The claims also do not recite any protocol. They merely recite to send and receive data in a functional manner without a specific communication protocol. Applicant argues on p. 10-11 that the claims integrate any abstract idea into a practical application because they recite specific technological improvements to computer functionality by the claimed communication protocol between the application service and the application assistance engine, which is an improvement because it enables seamless integration between recommendation systems and target applications. Applicant further points to a reduction in the number of prompt-reply cycles needed to generate relevant content and streamlining user interactions, described in the specification. Examiner respectfully disagrees.Examiner respectfully disagrees. Under Step 2A, Prong 2, examiners should evaluate whether the claim as a whole integrates the recited judicial exception into a practical application of the exception. Limitations the courts have found indicative that an additional element (or combination of elements) may have integrated the exception into a practical application include: An improvement in the functioning of a computer, or an improvement to other technology or technical field, as discussed in MPEP §§ 2106.04(d)(1) and 2106.05(a); Applying or using a judicial exception to effect a particular treatment or prophylaxis for a disease or medical condition, as discussed in MPEP § 2106.04(d)(2); Implementing a judicial exception with, or using a judicial exception in conjunction with, a particular machine or manufacture that is integral to the claim, as discussed in MPEP § 2106.05(b); Effecting a transformation or reduction of a particular article to a different state or thing, as discussed in MPEP § 2106.05(c); and Applying or using the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment, such that the claim as a whole is more than a drafting effort designed to monopolize the exception, as discussed in MPEP § 2106.05(e). The courts have also identified limitations that did not integrate a judicial exception into a practical application: Merely reciting the words "apply it" (or an equivalent) with the judicial exception, or merely including instructions to implement an abstract idea on a computer, or merely using a computer as a tool to perform an abstract idea, as discussed in MPEP § 2106.05(f); Adding insignificant extra-solution activity to the judicial exception, as discussed in MPEP § 2106.05(g); and Generally linking the use of a judicial exception to a particular technological environment or field of use, as discussed in MPEP § 2106.05(h). Here, the alleged integration receives natural language input, receives user context from the AI engine, prompts a foundation model for tasks, applications, and design templates, shows the results, and launches the application with the design template. This is an improvement to the organizational workflow of a user engaging with a suite of applications. The claims do not recite an improvement to the function of a computer, or an improvement to other technology or technical field. The claims merely use computers as tools to perform the abstract idea.The claims do not recite a technical communication pathway. Sending the design template to be opened when the recommended application is launched is a functional statement lacking technical detail. The claims do not reflect the technical mechanisms to achieve the efficiency improvements claimed by the specification. Applicant argues on p. 11 that the additional elements amount to significantly more than any judicial exception because they recite technological improvements that go beyond routine computer operations, asserting a non-conventional arrangement that solves context preservation across applications through a specific protocol and technical benefits described in the specification. Examiner respectfully disagrees.The claimed arrangement is conventional because it recites generic processors, storage, and interfaces to receive and display data, send data to another engine, and launch an application. The claims do not recite a particular communication protocol. The claims generically recite functional language to receive and send data. The asserted inventive concept of using the foundation model service to generate application recommendations and design templates, followed by the transmission and launching of the application with the design template is the abstract idea described in Step 2A, Prong 1. Step 2B requires the additional elements to amount to significantly more than the abstract idea. The claims do not reflect the technical mechanisms to achieve the efficiency improvements claimed by the specification. Applicant's prior art arguments have been fully considered and they are persuasive to overcome the rejection. In particular, see Applicant’s Remarks on p. 12-14. 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 clearly drawn to at least one of the four categories of patent eligible subject matter recited in 35 U.S.C. 101 (method, apparatus, non-transitory computer-readable storage media). Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without integrating the abstract idea into a practical application or amounting to significantly more than the abstract idea. Regarding Step 1 of the 2019 Revised Patent Subject Matter Eligibility Guidance (‘2019 PEG”), Claims 1-8 are directed toward the statutory category of a machine (reciting an “apparatus”). Claims 9-16 are directed toward the statutory category of an article of manufacturer (reciting a “non-transitory computer-readable storage media”). Claims 17-20 are directed toward the statutory category of a process (reciting a “method”). Regarding Step 2A, prong 1 of the 2019 PEG, Claims 1, 9, and 17 are directed to an abstract idea by reciting […] receive … natural language input from a user relating to a job … wherein the targeted portion includes information relating to the user with respect to the one or more applications; generate a prompt with which to elicit a reply from a foundation model service, wherein the prompt includes a global portion and the targeted portion and wherein the prompt tasks the foundation model service with identifying one or more tasks relating to the job and identifying a recommended application in association with each task, wherein the recommended application is an application of the one or more applications recommended by the foundation model service for accomplishing the associated task, and recommending a design template of the recommended application for the associated task; […]; receive user input comprising an indication to launch the recommended application; […] (Example Claim 1). The claims are considered abstract because these steps recite certain methods of organizing human activity like marketing or sales activities or behaviors and mental processes. The claims recite steps to parse user input, match tasks with applications and displaying recommendations on an interface. Applicant’s disclosure suggests that the claimed steps aim to solve the problem of new users of a suite of applications unable to engage with an application in a lasting way (Applicant’s Specification, [0002]-[0003]). By this evidence, the claims recite a type of certain methods of organizing human activity like marketing or sales activities or behaviors and mental processes common to judicial exception to patent-eligibility. By preponderance, the claims recite an abstract idea (e.g., a “foundation model integrations” for personalized engagement with software applications). Regarding Step 2A, prong 2 of the 2019 PEG, the judicial exception is not integrated into a practical application because the claims (the judicial exception and the additional elements such as one or more computer-readable storage media; one or more processors operatively coupled with the one or more computer-readable storage media; and program instructions stored on the one or more computer-readable storage media that, when executed by the one or more processors, direct the computing apparatus to at least; via a user interface; wherein the job is to be performed by one or more applications; receive, from an artificial intelligence (AI) engine, a targeted portion generated by the AI engine; enable display of the one or more tasks and the recommended application from the foundation model service in the user interface; send, to an application assistance engine of the recommended application, the design template to be opened in the user interface when the recommended application is launched; and cause the recommended application to be launched in the user interface including a display of the recommended template) are not an improvement to a computer or a technology, the claims do not apply the judicial exception with a particular machine, the claims do not effect a transformation or reduction of a particular article to a different state or thing nor do the claims apply the judicial exception in some other meaningful way beyond generally linking the use of the judicial exception to a particular technological environment such that the claims as a whole is more than a drafting effort designed to monopolize the exception (see MPEP §§ 2106.05(a-c, e)). Dependent claims 2-8, 10-16, and 18-20 do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the limitations recite mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea ‐ see MPEP 2106.05(f). Regarding Step 2B of the 2019 PEG, the additional elements have been considered above in Step 2A Prong 2. The claim limitations do not amount to significantly more than the judicial exception because they are directed to limitations referenced in MPEP 2106.05I.A. that are not enough to qualify as significantly more when recited in a claim with an abstract idea because the limitations recite mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea ‐ see MPEP 2106.05(f). Applicant's claims mimic conventional, routine, and generic computing by their similarity to other concepts already deemed routine, generic, and conventional [Berkheimer Memorandum, Page 4, item 2] by the following [MPEP § 2106.05(d) Part (II)]. The claims recite steps like: “Receiving or transmitting data over a network, e.g., using the Internet to gather data,” Symantec, “Performing repetitive calculations,” Flook, and “storing and retrieving information in memory,” Versata Dev. Group, Inc. v. SAP Am., Inc. (citations omitted), by performing steps to “receive” input from a user, “receive” a target portion, “generate” a prompt, “enable” display of a task and a recommended application, “receive” user input, “send” the design template to be opened, and “cause” the recommended application to be launched including a display of the recommended template (Example Claim 1). By the above, the claimed computing “call[s] for performance of the claimed information collection, analysis, and display functions ‘on a set of generic computer components' and display devices” [Elec. Power Group, 830 F.3d at 1355] operating in a “normal, expected manner” [DDR Holdings, LLC v. Hotels.com, L.P., 773 F.3d at 1245, 1258 (Fed. Cir. 2014)]. Conclusively, Applicant's invention is patent-ineligible. When viewed both individually and as a whole, Claims 1-20 are directed toward an abstract idea without integration into a practical application and lacking an inventive concept. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 20230135794 A1; WO 2023091275 A1; Zhang et al., Recommendation as Instruction Following: A Large Language Model Empowered Recommendation Approach, 2023. 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 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 mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MOHAMED EL-BATHY whose telephone number is (571)270-5847. The examiner can normally be reached on M-F 8AM-4:30PM. 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 on (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 an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /MOHAMED N EL-BATHY/Primary Examiner, Art Unit 3624
Read full office action

Prosecution Timeline

Jun 22, 2023
Application Filed
Jun 28, 2025
Non-Final Rejection — §101
Aug 01, 2025
Interview Requested
Aug 11, 2025
Applicant Interview (Telephonic)
Aug 11, 2025
Examiner Interview Summary
Nov 03, 2025
Response Filed
Feb 16, 2026
Final Rejection — §101
Apr 10, 2026
Applicant Interview (Telephonic)
Apr 16, 2026
Examiner Interview Summary

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

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Prosecution Projections

3-4
Expected OA Rounds
30%
Grant Probability
64%
With Interview (+33.3%)
3y 10m
Median Time to Grant
Moderate
PTA Risk
Based on 235 resolved cases by this examiner. Grant probability derived from career allow rate.

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