Prosecution Insights
Last updated: August 16, 2026
Application No. 18/566,356

DIRECT VOICEMAIL CALL SERVICE

Non-Final OA §103
Filed
Dec 01, 2023
Priority
Jun 03, 2021 — CN PCT/CN2021/098131 +1 more
Examiner
MATAR, AHMAD
Art Unit
2693
Tech Center
2600 — Communications
Assignee
Orange
OA Round
3 (Non-Final)
56%
Grant Probability
Moderate
3-4
OA Rounds
1y 3m
Est. Remaining
70%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allowance Rate
10 granted / 18 resolved
-6.4% vs TC avg
Moderate +14% lift
Without
With
+13.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 11m
Avg Prosecution
9 currently pending
Career history
21
Total Applications
across all art units

Statute-Specific Performance

§101
7.7%
-32.3% vs TC avg
§103
47.4%
+7.4% vs TC avg
§102
20.5%
-19.5% vs TC avg
§112
21.8%
-18.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 18 resolved cases

Office Action

§103
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 Arguments Applicant’s arguments filed 6/5/2026 with respect to the 102 rejection over Clift have been fully considered and are partially persuasive (the issue as seen by the examiner is merely inherency vs. obviousness with regards to the use if SIP in Clift). In order to remove any doubt and to positively apply the prior art, the previous Final action dated 2/5/2026 has been withdrawn. In PP [0043], Clift which mainly uses the PSTN states: “However, it is understood that any other suitable identification criteria associated with the users or the devices which they use could be stored instead (for example, if needed to support other network types), such as IP (internet protocol) addresses or SIP (session initiation protocol) addresses.” Other network types as suggested by Clift should cover using an entire network (from A to Z), starting with initiating the request at the caller’s side. Applicant’s arguments on pages 13 and 14 imply that Clift will only use the SIP at the callee’s end. Clift suggested that other network types may be used, but it appears that applicant ignored this part and continued to attack the reference for using the PSTN option (dialing a three-digit prefix by the calling party to be analyzed by the LEC and then using CLI, etc.) It appears that the suggestion of Clift to “support other network types, such as IP (internet protocol) addresses or SIP (session initiation protocol) addresses” has been given no weight (or just partial weight) by Applicant. Again, using another type of network will have to mean at the calling party’s end and at the callee’s end. In view of applicant’s arguments against the suggestion of Clift and to remove any potential of ambiguity, this office action will “modify” Clift according with Clift’s own suggestion of supporting other network types to utilize SIP. The previous 102 rejection over Clift will be changed to 103 rejection to include Clift’s own suggestion of using the old and well-known (1990’s) SIP. Thus, Applicant’s arguments are moot because of the new grounds of rejection. Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1 – 7 and 9 – 12 are rejected under 35 U.S.C. 103 as being unpatentable over by Clift et al (US 20070168428 A1), hereinafter “Clift” in view of Applicant’s Admitted Prior Art (“AAPA”) and/or in view of DonoVan et al -hereinafter “DonoVan” (US 20020129093 A1) Clift discloses a “Communications System with Direct Access Mailbox.” It teaches (PP 0040) that user A (caller) can elect to send an audio-visual communication directly to the mailbox of user B (callee). That is, user A decides to directly leave a voice mail message for user B. Regarding Claim 1, Clift discloses a computer-implemented method to directly record a voice message (user A decides to directly leave a voice mail message for user B, PP 0040 and Fig. 4), Clift teaches that the method comprising: receiving, from a user equipment of a caller (device 2 of user A, Fig. 4) a call set-up request comprising information (such as prefix – which depends on the type of network being used, SIP messages may be used as taught by Clift) indicating a request by the caller to record a voice message directly on a voicemail server (mail platform 11, Fig. 4) serving a callee (user A/caller uses telephone 2 to dial a three-digit prefix followed by the telephone number of user B/callee, PP 0040). Again, SIP messages may be utilized, as suggested by Clift. While Clift teaches an example of using the prefix, it clearly teaches: “[0043] In the specific embodiment, the entries in the database relate to the standard telephone numbers associated with the users, since these can be easily be compared against the calling line identifiers presented by the current service. However, it is understood that any other suitable identification criteria associated with the users or the devices which they use could be stored instead (for example, if needed to support other network types), such as IP (internet protocol) addresses or SIP (session initiation protocol) addresses. discriminating, in the received call set-up request, said information indicating a request for direct recording of a voice message (e.g., CLI of the caller is relayed to the intelligent network together with an indication that the caller is requesting direct access to mailbox. The Intelligent Network messaging application stores the CLI for calling party A for later use, PP 0040 and 0041); SIP messaging may be utilized according to Clif. responsive to said discriminating, in the received call set-up request, said information indicating a request for direct recording of a voice message, retrieving callee status information (in order to give subscriber/callee B control over the direct access to his or her voice mailbox, the direct voice mail access DVMA feature can be activated, deactivated or temporarily blocked by subscriber/callee B , PP 0004). Also, the claimed “callee status” may read on the teaching of determining that the callee (user B) is a subscriber for direct voice mail service, see pp 0035. discriminating direct-voicemail authorization data in the retrieved callee status information (see P0004 and step 6, Fig.1 for determining if direct mailbox access is activated/allowed). This may also read on determining that the callee/user B is a subscriber for this special service. responsive to said discriminating direct-voicemail authorization data in the retrieved callee status information, setting up a communication session between the user equipment of the caller (device 2 of user A, Fig. 4) and said voicemail server (platform 11) serving the callee (user B) to enable recording of said voice message, (user A leaves a voicemail message in mailbox 11a of the mail platform, see abstract and PPs 0038 and 0044.) While Clift primarily provides details about the use of PSTN (3-digits prefix, LEC, CLI, etc.), Clift does suggest supporting “other network types, such as IP (internet protocol) addresses or SIP (session initiation protocol) addresses.” The old and well-known SIP (session initiation protocol) has been used since the 1990’s. Thus, it would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to use the “direct voicemail” feature as taught by Clift in another type of network (e.g., VoIP with SIP) as explicitly suggested by Clift. The use of proxy server while using SIP is old (1990’s), well-known and shown, for example, in AAPA, Fig. 1. Using Clift’s direct voicemail feature in “other network types” provides added versatility and is still within the suggestion of Clift. In the combination which utilizes the old and well-known SIP, the method would be performed by the proxy server such as proxy/SIP server 2 in Fig. 1 (AAPA). Also, DonoVan discloses a SIP-BASED FEATURE CONTROL and teaches providing an addition to the Session Initiation Protocol (SIP). The addition is a new field header, preferably entitled ''Feature'', that is added to the register (1) message. This field would contain control information for various feature services, like the Do Not Disturb feature and other services. Thus, since 1) the use of SIP is old and well-known, 2) the use of SIP is suggested by Clift, 3) the use of SIP is admitted as prior art (Fig. 1, applicant’s specification) and 4) DonoVan teaches the use of SIP to add features, it would have been obvious to one of ordinary skill in the art before the effective filing date of the current invention to implement the direct voicemail feature taught by Clift in a SIP environment as suggested by Clift since using one invention in multiple environment is obvious and supports versatility. Regarding Claim 2, as discussed above, in Clift, if the callee (user B) authorizes (reads on subscribing for the service, and/or activating the service) direct recoding of voice messages, then voicemail server serving the callee (mail platform 11) is accessed and the caller/user A is enabled to record a voice message. Regarding Claim 3, Clift teaches determining that the callee authorizes direct recording of voice messages conditionally dependent on the caller identity and determining the identity of the caller and: if the determined caller is authorized by the callee to directly record voicemails, determining which voicemail server is the voicemail server (platform 11) serving the callee (user B) and setting up said communication session between the user equipment of the caller (device 2) and said voicemail server (platform 11) serving the callee, to enable recording of said voicemail voice message (PP 0041, the IN messaging application 6 compares the identity of the calling party with the CLI recorded earlier, to determine whether this caller has requested direct access to the mailbox. If so, then at step S6, the messaging application consults the contents of database 7 to determine whether this caller is allowed direct access to the mailbox of user B.) Regarding Claim 4, Clift teaches an example of using the CLI (line identification) for the user B/callee and determining that the called user B/callee uses mailbox 11a within the mail platform 11, see PP 0038 and 0056. Again, SIP addresses may also be utilized as explicitly taught by Clift in PP 0043. Regarding Claims 5, 6 and 7, the use of the INVITE message and HEADER is old, well-known and discussed, for example, in relation to AAPA. The INVITE and HEADER have been used in the well-known SIP commands for many years. The INVITE and HEADER are explicitly taught by DonoVan, see for example, PP 0010, 0017, 0022. Claims 9 and 10 are rejected for the same reasons as discussed with respect to Claims 1 and 4. The processor and the communication interface are inherent. Claim 11 recites a user equipment which reads on device 2 of user A in Fig. 4 of Clift (or user 1 “Tom” in AAPA). The claim recites a processor (inherent in both) in the user equipment which functions to: generate a call set-up request comprising information indicating a request to record a voice message directly on a voicemail server serving the callee” (as discussed above), and send said call set-up request to a proxy server in order to trigger, depending on direct-voicemail authorization data discriminated within callee status information retrieved by said proxy server, the setup of a communication session between the user equipment and a voicemail server serving the callee, to enable recording of said voice message (this limitation has been discussed above in the rejection of claim 1.). Regarding Claim 12, the “input element” may simply read on the dialing buttons shown in Fig. 2 and 4 for device 2 which enable the user to use to input a prefix to trigger the service, as discussed above. In the combination, the user’s device ( device 2 of user A in Fig. 4 of Clift or the device of user 1 “Tom” in AAPA) will send out the needed SIP to make the request. Claims 11 and 12 are also rejected under 35 U.S.C. 103 as being unpatentable over Clift and AAPA and/or DonoVan as applied to claim 1 above, and further in view of Rothschild (US 20170359458 A1). As discussed above, Clift teaches the use of user device 2 to generate a call set-up request to record a voice message directly on a voicemail server of the callee and teaches enabling the caller to record a voice message depending on the authorization data in the callee status. The combination of Clift and AAPA and/or DonoVan does not explicitly teach that the user device comprises a processor. Rothschild teaches downloading and installing an application on a mobile/smart phone 202 to enable options. The smart phone 202 comprises a processor 206, input/output 204 for the user to provide input. In PP 0001, it teaches that a user can preset a single button to speed dial a series of individual numbers. Thus, it would have been obvious to use such a smart phone to access the service provided by the combination since smart phones, which are widely available, are more user-friendly than conventional phones. The use of a smart phone may provide added convenience, efficiency and ease of use. Claims 1 – 7 and 9 -12 are rejected under 35 U.S.C. 103 as being unpatentable over Jackson (US 20090168986 A1) in view of Clift (US 20070168428 A1). Regarding claim 1, Jackson discloses : a computer-implemented method to directly record a voicemail message (Jackson teaches (abstract) routing a communication session directly to a voicemail mailbox) and teaches (PP 0009) that “…a caller at an originating communication device (105, Fig. 1) can request that an initiated communication session be directed to a voicemail server…” associated with callee device 106, said method being implemented by a proxy server” (Jackson teaches ([0019]–[0021]) the use of “feature server A 155” to process the direct-to-voicemail request. Feature server 155 or feature servers 155-157 may read on the claimed “proxy server”. receiving, from a caller’s user equipment, a call set-up request comprising information indicating a request by the caller to record a voice message directly on a voicemail server serving a callee (Jackson teaches (Abstract; [0009]; [0018]; [0020]; [0044]) that the caller sends a communication session initiation message including a destination telephone number and a direct voicemail feature identifier. See also [0018]: “a communication session initiation message … having a destination that includes a direct-to-voicemail feature identifier (“information indicating a request ……..”), discriminating, in the received call set-up request, said information indicating a request for direct recording of a voice message (Jackson teaches ([0020], [0022], [0040], [0044]) the feature server “determines that the direct voicemail feature identifier indicates that the caller requests that the call be sent directly to a voicemail mailbox.” setting up a communication session between the user equipment of the caller and said voicemail server serving the callee, to enable recording of said voice message (Jackson teaches (Abstract; [0009]; [0020]; [0022]; [0046]–[0047]) forwarding the call directly to voicemail and routing directly to the voicemail mailbox without ringing the destination telephone number. Jackson does not explicitly teach “responsive to discriminating … said information … retrieving callee status information”, “discriminating direct-voicemail authorization data in the retrieved callee status information” and “responsive to discriminating direct-voicemail authorization data in the retrieved callee status information, setting up …..”. That is, Jackson does not expressly disclose a callee status/authorization check before setting up to enable recording of the voice message. On one hand, it is extremely obvious to verify if the callee authorizes callers to leave voice messages on his/her voicemail in order to reduce usage of voicemail storage, lower the rick for spam voicemail including spam voicemail from robots, and to provide added privacy/security to the callee. Many telephony services are provided based on user/callee authorization/subscription. Simply put, it is obvious to give the callee control over his/her own voicemail. On the other hand, Clift teaches direct access to mailbox without disturbing/ringing the callee (abstract), and teaches : in order to give subscriber/callee B control over the direct access to his or her voice mailbox, the direct voice mail access DVMA feature can be activated, deactivated or temporarily blocked by subscriber/callee B dialing the appropriate service codes, PP 0004). Also, the claimed "callee status" may read on the teaching of determining that the callee (user B) is a subscriber for direct voice mail service, see pp 0035. For the “authorization”, see P0004 and step 6, Fig.: for determining if direct mailbox access is activated/allowed. Thus, it would have been obvious to one of ordinary skill in the art before the filing date of the current invention to utilize the “callee status/authorization” feature as taught by Clift in the system/method of Jackson in order to provide the callee with control over his/her voicemail (e.g., provide privacy/security, reduce risk of “junk voicemail” messages, and avoid voicemail storage problem. Claim 2 is taught by Clift as discussed above. Claim 3 is taught by Clift as discussed above. Note that Jackson teaches ([0020], [0021], [0022], [0044]) that the session initiation message includes a source telephone number and destination telephone number. Claim 4 is taught by Clift as discussed above. Furthermore, Jackson discloses (Abstract; [0020]; [0021]; [0022]) a destination telephone number / destination identifier, discloses ([0018], [0020], [0044]) the use of the destination number to identify the voicemail routing path, and discloses ([0020], [0022], [0026]–[0027], [0037], [0040], [0044]) querying ENUM and selecting a voicemail URI associated with the destination. For claim 5, Jackson discloses ([0018], [0019], [0020], [0039]) SIP / S-CSCF / feature server functionality, and discloses ([0018], [0020], [0044], claim 1, claim 11) that the communication session initiation message may be a SIP INVITE. For claim 6, Jackson teaches ([0020], [0021], [0040], [0049]) insertion/use of the Diversion Header, redirecting number field, and a reason code in a header, according to the Session Initiation Protocol (see [0018], [0039], [0040]). For claim 7, Jackson specifically uses the phrase “dedicated header field,” and it expressly teaches inserting an identification in a header, including a diversion header, to indicate caller-requested voicemail routing. See [0020], [0021], [0022], [0040]. Jackson also teaches (Abstract; [0020]; [0022]; [0040]) a direct voicemail feature identifier and “caller-requested” indication. Claim 9 is rejected for the same reasons as claim 1. The claimed communication interface is inherent and may also read on Jackson’s interfaces for the ENUM server and feature server architecture; the proxy/call-control elements necessarily communicate via network interfaces. The same for the claimed “processor” (Jackson citation: [0043]–[0054], especially FIG. 6). For claim 10, Jackson teaches ([0020], [0022], [0026]–[0027], [0037], [0040], [0044]) ENUM lookup to obtain voicemail URI/server for the destination telephone number. Claim 11 is rejected for the same reasons as claim 1. Note that Jackson teaches (Abstract) caller at a source telephone number requests voicemail routing, ([0009]) caller uses originating communication device to direct session to voicemail server, see IMS device 105. Regarding Claim 12, the “input element” may simply read on the dialing buttons shown in Figs. 2 and 4 for device 2 of Clift which enable the user to use to provide input to trigger the service, as discussed above. The input element may also belong to the internet Protocol (IP) Multimedia Subsystem (IMS) of the calling device 105. (e.g., a voice over internet protocol phone (VoIP)) phone, an IMS enabled personal computer (PC), an IMS endpoint, a wireless IMS device (e.g., a wireless-fidelity (WiFi) IP phone)), see Jackson, PP 0010. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to AHMAD F. MATAR whose telephone number is (571)272-7488. The examiner can normally be reached M-F 9 - 5:30. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. 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. /AHMAD F. MATAR/ Supervisory Patent Examiner, Art Unit 2693
Read full office action

Prosecution Timeline

Dec 01, 2023
Application Filed
Jul 16, 2025
Non-Final Rejection mailed — §103
Nov 17, 2025
Response Filed
Feb 05, 2026
Final Rejection mailed — §103
May 12, 2026
Examiner Interview Summary
May 12, 2026
Applicant Interview (Telephonic)
Jun 05, 2026
Response after Non-Final Action
Jun 24, 2026
Non-Final Rejection mailed — §103 (current)

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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
56%
Grant Probability
70%
With Interview (+13.9%)
3y 11m (~1y 3m remaining)
Median Time to Grant
High
PTA Risk
Based on 18 resolved cases by this examiner. Grant probability derived from career allowance rate.

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