Prosecution Insights
Last updated: October 02, 2026
Application No. 18/370,374

MANAGING CONTENT BASED ON BATTERY USAGE IN DISPLAYING THE CONTENT ON DEVICES

Final Rejection §103§112
Filed
Sep 19, 2023
Priority
Feb 06, 2017 — continuation of PCTUS2017016744 +5 more
Examiner
PRIFTI, AUREL
Art Unit
2175
Tech Center
2100 — Computer Architecture & Software
Assignee
Google LLC
OA Round
5 (Final)
83%
Grant Probability
Favorable
6-7
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allowance Rate
527 granted / 635 resolved
+28.0% vs TC avg
Strong +22% interview lift
Without
With
+22.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
27 currently pending
Career history
655
Total Applications
across all art units

Statute-Specific Performance

§101
9.5%
-30.5% vs TC avg
§103
59.2%
+19.2% vs TC avg
§102
14.5%
-25.5% vs TC avg
§112
13.9%
-26.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 635 resolved cases

Office Action

§103 §112
DETAILED ACTION Claims 1-20 are presented for examination. The present application is being examined under the AIA (America Invents Act) First Inventor to File. This Office Action is Final. This action is responsive to the following communication: the response filed on 05-22-2026. Information Disclosure Statement The information disclosure statement (IDS) submitted on 07-13-2026 and 05-28-2026 are in compliance with the provisions of 37 CFR 1.97 Claim Rejections - 35 USC § 112 Claim rejections under USC § 112 during the Non-Final Office Action are withdrawn, in light of the remarks filed on 05-22-2026 by Applicant(s). 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) 1-3, 5-10,12-17,19-20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Publication No. 2005/0114721 (hereinafter, “Azadet”) in view of U.S. Publication No. 2015/0301587 (hereinafter, “Chae”) and further view of U.S. Publication No. 2012/0131145 (hereinafter, “Garg”) and further view of U.S. Publication No. 2015/0227445 (hereinafter, “Arscott”). As per claim(s) 1, 8, 15, 1Azadet discloses a method of improving battery life of a mobile device, the method being performed by a data processing system configured to communicate via a network with at least one mobile device, comprising: receiving a plurality of battery change indications, each battery change indication indicating a variation of battery level of a respective mobile device of a plurality of mobile devices between a first battery level at a first time of a respective content item of a plurality of content items on the mobile device and a second battery level at a second time of the respective content item on the mobile device; (Fig. 1 illustrates a plurality of electronic devices which may be cellular telephones and are battery operated. ¶ [0014] Further, FIG. 3 illustrates a number of records 301-305 that are collected to indicate changes from the different battery levels. It is therefore apparent for the Office to submit that a person of ordinary skill in the art would recognize that the number of different time events for which battery levels are collected is similar to the claimed expressions directed to first battery level at a first time and second battery level at a second time as currently claimed.) determining relationships between variation of battery level and content items of the plurality of content items based upon the plurality of battery change indications; (Fig. 3 illustrates relationship between the associated changes to the different battery levels and bit rates for supplying data packets ) modifying the plurality of content items based upon the determined relationships to generate a modified plurality of content items; and (Fig. 3 illustrates relationship between the associated changes to the different battery levels and bit rates for supplying data packets) providing content items of the modified plurality of content items to present on one or more mobile devices. (Fig. 3 illustrates relationship between the associated changes to the different battery levels and bit rates for supplying data packets) Azadet does not distinctly disclose receiving power information associated when presenting content items, wherein each of the plurality of content items includes one or more of an image, an audio, a video, a text file, or a multimedia file; . However, Chae explicitly discloses that. In particular Chae discloses the following: receiving a plurality of battery change indications, (power change information at the local level that at least includes “a battery power lower than a predefined value”; ¶ [0069] ) each battery change indication indicating a variation of battery level of a respective mobile device of a plurality of mobile devices between a first battery level at a first time when presenting of a respective content item of a plurality of content items on the mobile device and a second battery level at a second time 2when presenting of the respective content item on the mobile device; (inter alia: ¶s [0150]-[0151] state that: “ the normal power control data may be data for displaying the screen on the display unit 530 with a specific FPS set as a default. For example, the graphic processing unit 520 may control the application to output display data on the display unit 530 with a normal frame rate (e.g., a frame rate of 60 FPS in case of an application with 60 FPS, a frame rate of 30 FPS in case of an application with 30 FPS, etc.)” and “ the power control data may be data for displaying the screen with a specific FPS lower than normal power data. Then the graphic processing unit 520 may output display data to the display unit 530 with FPS adjusted by the power control data. The power control data may be data to be used for the graphic processing unit 520 to adjust and control a display frame of the display unit 530. That is, a changed power level may be used for the graphic processing unit 520 to process FPS to a lower value than a predetermined FPS. As discussed above, FPS is the frequency unit of redrawing a frame on the display unit 530. Even though the FPS is lowered by a proper value, users may be unaware of any change in the screen. The changed power level may be determined at the server. Specifically, the server may collect power level change values of each application from the respective electronic devices, average the collected values for each application, and determine the power control data, i.e., a sweet spot, which is optimized to execute the application in a state where a battery fails to maintain a predetermined quantity of charge.” ) wherein each of the plurality of content items includes one or more of an image, an audio, a video, a text file, or a multimedia file; (changed power level may be used for the graphic processing unit 520 to process FPS to a lower value than a predetermined FPS. As discussed above, FPS is the frequency unit of redrawing a frame on the display unit 530; ¶s [0150]-[0151] ) determining relationships between variation of battery level and content items of the plurality of content items based upon the plurality of battery change indications; (inter alia: ¶s [0150]-[0151] state that: “ the normal power control data may be data for displaying the screen on the display unit 530 with a specific FPS set as a default. For example, the graphic processing unit 520 may control the application to output display data on the display unit 530 with a normal frame rate (e.g., a frame rate of 60 FPS in case of an application with 60 FPS, a frame rate of 30 FPS in case of an application with 30 FPS, etc.)” and “ the power control data may be data for displaying the screen with a specific FPS lower than normal power data. Then the graphic processing unit 520 may output display data to the display unit 530 with FPS adjusted by the power control data. The power control data may be data to be used for the graphic processing unit 520 to adjust and control a display frame of the display unit 530. That is, a changed power level may be used for the graphic processing unit 520 to process FPS to a lower value than a predetermined FPS. As discussed above, FPS is the frequency unit of redrawing a frame on the display unit 530. Even though the FPS is lowered by a proper value, users may be unaware of any change in the screen. The changed power level may be determined at the server. Specifically, the server may collect power level change values of each application from the respective electronic devices, average the collected values for each application, and determine the power control data, i.e., a sweet spot, which is optimized to execute the application in a state where a battery fails to maintain a predetermined quantity of charge.” ) modifying the plurality of content items based upon the determined relationships to generate a modified plurality of content items; and (inter alia: ¶s [0150]-[0151] state that: “ the normal power control data may be data for displaying the screen on the display unit 530 with a specific FPS set as a default. For example, the graphic processing unit 520 may control the application to output display data on the display unit 530 with a normal frame rate (e.g., a frame rate of 60 FPS in case of an application with 60 FPS, a frame rate of 30 FPS in case of an application with 30 FPS, etc.)” and “ the power control data may be data for displaying the screen with a specific FPS lower than normal power data. Then the graphic processing unit 520 may output display data to the display unit 530 with FPS adjusted by the power control data. The power control data may be data to be used for the graphic processing unit 520 to adjust and control a display frame of the display unit 530. That is, a changed power level may be used for the graphic processing unit 520 to process FPS to a lower value than a predetermined FPS. As discussed above, FPS is the frequency unit of redrawing a frame on the display unit 530. Even though the FPS is lowered by a proper value, users may be unaware of any change in the screen. The changed power level may be determined at the server. Specifically, the server may collect power level change values of each application from the respective electronic devices, average the collected values for each application, and determine the power control data, i.e., a sweet spot, which is optimized to execute the application in a state where a battery fails to maintain a predetermined quantity of charge.” ) providing content items of the modified plurality of content items to present on one or more mobile devices. (inter alia: ¶s [0150]-[0151] state that: “ the normal power control data may be data for displaying the screen on the display unit 530 with a specific FPS set as a default. For example, the graphic processing unit 520 may control the application to output display data on the display unit 530 with a normal frame rate (e.g., a frame rate of 60 FPS in case of an application with 60 FPS, a frame rate of 30 FPS in case of an application with 30 FPS, etc.)” and “ the power control data may be data for displaying the screen with a specific FPS lower than normal power data. Then the graphic processing unit 520 may output display data to the display unit 530 with FPS adjusted by the power control data. The power control data may be data to be used for the graphic processing unit 520 to adjust and control a display frame of the display unit 530. That is, a changed power level may be used for the graphic processing unit 520 to process FPS to a lower value than a predetermined FPS. As discussed above, FPS is the frequency unit of redrawing a frame on the display unit 530. Even though the FPS is lowered by a proper value, users may be unaware of any change in the screen. The changed power level may be determined at the server. Specifically, the server may collect power level change values of each application from the respective electronic devices, average the collected values for each application, and determine the power control data, i.e., a sweet spot, which is optimized to execute the application in a state where a battery fails to maintain a predetermined quantity of charge.” ) It would have been obvious before the effective filing date of the claimed invention to modify the teachings of Azadet and Chae because both references are in the same field of endeavor. Chae’s teaching of changing the frame rate would enhance Azadet's system by allowing the system to optimize power consumption based on specific applications associated with presenting image data. Azadet as modified does not distinctly disclose where the content is a “text”, for example, text associated with a web server. However, Garg explicitly discloses that. In particular, Garg discloses the following: receiving a plurality of battery change indications, each battery change indication indicating a variation of battery level of a respective mobile device of a plurality of mobile devices between a first battery level at a first time when presenting a respective content item of a plurality of content items on the mobile device and a second battery level at a second time when presenting the respective content item on the mobile device; (¶ [0006] states “the mobile device provides, responsive to the device-capability-inquiry, an indication of an amount of power that is available on the mobile device, and the web server and “the mobile device provides, responsive to the device-capability-inquiry, an indication of an amount of power that is available on the mobile device, and the web server modifies the requested content based upon the amount of power that is available on the mobile device” .) wherein each of the plurality of content items includes one or more of an image, an audio, a video, a text file, or a multimedia file; (¶ [0035] states “The display 212 generally operates to provide visual images to a user” and ¶ [0025] states “the remote server may send video content at one or more resolution levels depending upon the power capability of the mobile device 100 (e.g., video resolution may decrease as available power decreases”. ) determining relationships between variation of battery level and content items of the plurality of content items based upon the plurality of battery change indications; (¶ [0025] states “the remote server may send video content at one or more resolution levels depending upon the power capability of the mobile device 100 (e.g., video resolution may decrease as available power decreases”. ) modifying the plurality of content items based upon the determined relationships to generate a modified plurality of content items; and (¶ [0025] states “the remote server may send video content at one or more resolution levels depending upon the power capability of the mobile device 100 (e.g., video resolution may decrease as available power decreases”. ) providing content items of the modified plurality of content items to present one or more mobile devices. (¶ [0025] states “the remote server may send video content at one or more resolution levels depending upon the power capability of the mobile device 100 (e.g., video resolution may decrease as available power decreases”. ) It would have been obvious before the effective filing date of the claimed invention to modify the teachings of Azadet as modified and Garg because all references are in the same field of endeavor. Garg’s teaching of changing specific parameters would enhance Azadet's as modified system by allowing interface quality and optimization between the mobile device and the web server. Azadet as modified does not distinctly disclose wherein the variation of battery level is associated with an amount of change in power consumption of the mobile device. However, Arscott explicitly discloses that. In particular, Arscott discloses the following: receiving a plurality of battery change indications, each battery change indication indicating a variation of battery level of a respective mobile device of a plurality of mobile devices between a first battery level at a first time when presenting a respective content item of a plurality of content items on the mobile device and a second battery level at a second time when presenting the respective content item on the mobile device; (Fig 4 illustrates a system for collecting “markers and indicators” for a plurality of mobile devices 100a-c. Based on the collected marker and indicators, the system is further configured to display an “overlay the displayed power draw profile or graph with indicators or markers of one or more events or actions that occurred during the operation of the computing device”. Furthermore, the system further includes a battery power draw monitor configured to “provide a time profile of battery power draw during the operation of the computing device, and an event logger configured to record and time-stamp events and/or user actions occurring in the operation of the computing device.” (¶s [009]-[0012], Fig. 2. ) In other words, the system is configured to log “time-stamped records” (e.g., every two seconds or less; ¶ [0026] ) for monitoring battery power draw for mobile devices. ¶ [0041] wherein each of the plurality of content items includes one or more of an image, an audio, a video, a text file, or a multimedia file; (playing a video; Fig 2) wherein the variation of battery level is associated with an amount of change in power consumption of the mobile device; (Fig 4 illustrates a system for collecting “markers and indicators” for a plurality of mobile devices 100a-c. Based on the collected marker and indicators, the system is further configured to display an “overlay the displayed power draw profile or graph with indicators or markers of one or more events or actions that occurred during the operation of the computing device”. (¶s [009]-[0012], Fig. 2.) determining relationships between the variation of battery level and content items of the plurality of content items based upon the plurality of battery change indications; ( ¶ [0033] states “providing a local display of the correlation of battery power draw with events or user actions, computing device 100 may be configured to report the correlation to a remote device (e.g., a web server)”. It would have been obvious before the effective filing date of the claimed invention to modify the teachings of Azadet as modified and Arscott because all references are in the same field of endeavor. Arscott’s teaching of displaying power draw information associated with different computer operations would enhance Azadet's as modified system by allowing the user to take prophylactic power management measures, thus enhancing user’s power management control of their mobile device. As per claim 2, Azadet as modified discloses a method wherein content items of the plurality of content items have associated content item properties, and wherein determining relationships between variation of battery level and content items of the plurality of content items comprises determining relationships between variation of battery level and content item properties. (Garg: web content; ¶ [006]) ) (Garg: network selection; Fig 7) , (Chae: adjustment of brightness (or resolution); ¶ [0047]) As per claim 3, Azadet as modified discloses a method wherein modifying the plurality of content items comprises: selecting a content item property based upon the determined relationships between variation of battery level and content item properties; selecting content items having an associated property corresponding to the content item property; and modifying the selected content items. (Garg: web content and cache based on power level; ¶ [006]) ) (Garg: network selection based on power level; Fig 7) , (Chae: adjustment of brightness (or resolution) based on power level; ¶ [0047]) As per claim 5, Azadet as modified discloses a method wherein each battery change indication is obtained by: transmitting a content item to a mobile device, the content item comprising content to be displayed at the mobile device and a script; (Garg: ¶ [0038]) wherein the script is arranged to cause a battery level of the mobile device to be measured at the first time and at the second subsequent time and to transmit data indicative of variation of the battery level between the first time and the second time to a server. (Garg: ¶ [0038]) & (Garg: web content and cache based on power level; ¶ [006]) ) (Garg: network selection based on power level; Fig 7) , (Chae: adjustment of brightness (or resolution) based on power level; ¶ [0047]) As per claim 6, Azadet as modified discloses a method wherein the script is embedded in the content item. (Garg: ¶ [0038]) As per claim 7, Azadet as modified discloses a method further comprising receiving mobile device property data, the mobile device property data indicating one or more mobile device properties with respective mobile devices of the plurality of mobile devices, wherein the generated modified plurality of content items is associated with at least one of the one or more mobile device properties, and wherein content items of the modified plurality of content items are provided to mobile devices based upon the at least one associated mobile device property and properties associated with the mobile devices, and wherein the one or more mobile device properties comprise a property of the mobile device selected from a group consisting of: a web page displayed with the content item; (Garg: ¶ [006]) a data communication protocol; (Garg: network selection; Fig 7) and a screen brightness. (Chae: adjustment of brightness (or resolution); ¶ [0047]) As per claims 9-10,12-14, 16-17, 19-20 recite similar features to those recited in claims 2-3,5-7, and therefore, claims 9-10,12-14, 16-17, 19-20 are rejected for reasons similar to those discussed above. Claim(s) 4, 11, 18, are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Publication No. 2005/0114721 (hereinafter, “Azadet”) in view of U.S. Publication No. 2015/0301587 (hereinafter, “Chae”) and further view of U.S. Publication No. 2012/0131145 (hereinafter, “Garg”) and further view of U.S. Publication No. 2015/0227445 (hereinafter, “Arscott”) and further view of U.S. Publication No. 2011/0301890 (hereinafter, “Shirrif”). As per claims 4, 11, 18, Azadet as modified discloses a method wherein determining relationships between variation of battery level and content items of the plurality of content items based upon the plurality of battery change indications comprises processing the plurality of battery change indications (Garg: web content and cache based on power level; ¶ [006]) ) (Garg: network selection based on power level; Fig 7) , (Chae: adjustment of brightness (or resolution) based on power level; ¶ [0047]) Azadet as modified does not distinctly discloses the process of using a regression model. However, Shirrif teaches another system for use with mobile devices, wherein determining relationships between variation of battery level and content items of the plurality of content items based upon the plurality of battery change indications and the mobile device property data comprises processing the plurality of battery change indications and the mobile device property data using a regression model [0034, 0058, 0061; reporting module may generate a report including a linear regression of percentage of battery life versus time based on a common usage pattern] [Figs 7-11]. It would have been obvious to one of ordinary skill in the art to combine the teachings of Azadet as modified and Shirrif. Azadet as modified teaches adjusting parameters based one remaining power available. Shirrif teaches collecting battery life data from mobile devices and using regression techniques to analyze battery life over time based on usage patterns of the mobile device. One of ordinary skill in the art would recognize the applicability of using a regression model to model battery life over time. Furthermore, one of ordinary skill in the art would be motivated to use the regression techniques from Shirrif to monitor battery level and supply selected content as disclosed in Azadet as modified. Response to Arguments Applicant's arguments filed on 05-22-2026 associated with the newly added features presented with the amendment have been considered but are moot in view of the new ground(s) of rejection of Arscott. On the other hand, Applicants arguments to the existing features are not found persuasive for the following reasons: In particular, Applicants assert that Chae allegedly fails to disclose at least “indicating a variation of battery level . . . between a first battery level at a first time ... and a second battery level at a second time when presenting the respective content item” as recited by claim 1 As an initial matter, the Office agrees with Applicant that at least Chae does disclose teaching directed to “the server collects power change information about a specific application transmitted from the electronic devices ….. and then changes power control data of the application for each electronic device" where "the power change level may be a predetermined global power level in an automatic mode or a local power level set by a user.” However, Applicants have failed to show how and why these teachings are not the same as the broad limitations currently claimed other than merely pointing to some disparate teachings and concluding that Chae does not disclose the recited claimed features. As noted in the previous Office Action, Chae teaches the claimed expression of battery change indications by disclosing how the system is configured to collect power change information that includes “power change values” associated with one or more electronic systems. (Fig’s 2 3, ¶ [0054]- [0084] ) In response to the power change values, the system is further configured to modify various computer operations by setting the most “suitable frame per second (FPS) for each application”. Indeed, ¶ [0070] recites “determining a display of an execution screen of an application. For example, the sweet spot may be a value for adjusting the (FPS which is the frequency unit of redrawing a frame at a display”. ¶ [0070]) Therefore, clearly Chae discloses the language associated with “indicating a variation of battery level . . . between a first battery level at a first time ... and a second battery level at a second time when presenting the respective content item” as recited by claim 1. Notwithstanding the teachings of Chae, Applicant has failed to show how the teaching of Azadet and Garg do not disclose the language of “indicating a variation of battery level . . . between a first battery level at a first time ... and a second battery level at a second time when presenting the respective content item” as recited by claim 1 For at least the above reasons the rejections are believed to be proper and maintained. 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 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to AUREL PRIFTI whose telephone number is (571)270-1743. The examiner can normally be reached on M-F 8 a.m.- 6 p.m.. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Andrew J. Jung can be reached on 571-270-3779. 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. /AUREL PRIFTI/Primary Examiner, Art Unit 2175 Aurel Prifti Primary Examiner Art Unit 2175 Tel. (571) 270-1743 Fax (571) 270-2743 aurel.prifti@uspto.gov 1 As per independent claim(s) 8 and 15, these claims are substantially equivalent to the rejected method claim 1, because the additional feature(s) are present on any off the shelf general-purpose computer. Therefore, for at least this reason, claims 1 and 8 also stand rejected. Indeed, at least Fig’s 1-3 of the cited prior art illustrate a memory for storing instructions that are executed by a processor. 2 Chae: The server may process the application power change information in real time or at regular/predetermined intervals; ¶ [0141]
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Prosecution Timeline

Show 10 earlier events
Jan 20, 2026
Response after Non-Final Action
Feb 05, 2026
Request for Continued Examination
Feb 17, 2026
Response after Non-Final Action
Feb 25, 2026
Non-Final Rejection mailed — §103, §112
May 13, 2026
Applicant Interview (Telephonic)
May 15, 2026
Examiner Interview Summary
May 22, 2026
Response Filed
Aug 28, 2026
Final Rejection mailed — §103, §112 (current)

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