Prosecution Insights
Last updated: April 19, 2026
Application No. 18/592,008

COMPOSITION OF COMPLEX CONTENT VIA USER INTERACTION WITH AN AUTOMATED ASSISTANT

Final Rejection §103
Filed
Feb 29, 2024
Examiner
GEORGANDELLIS, ANDREW C
Art Unit
2459
Tech Center
2400 — Computer Networks
Assignee
Google LLC
OA Round
2 (Final)
56%
Grant Probability
Moderate
3-4
OA Rounds
4y 0m
To Grant
96%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allow Rate
274 granted / 490 resolved
-2.1% vs TC avg
Strong +40% interview lift
Without
With
+40.4%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
18 currently pending
Career history
508
Total Applications
across all art units

Statute-Specific Performance

§101
0.8%
-39.2% vs TC avg
§103
84.3%
+44.3% vs TC avg
§102
6.0%
-34.0% vs TC avg
§112
3.1%
-36.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 490 resolved cases

Office Action

§103
DETAILED ACTION Introduction Claims 1, 4-8, 1-12, 15-18, and 20-24 are pending. Claims 2-3, 9-10, 13-14, and 19 are cancelled. Claims 21-24 are new. This This Office action is in response to Applicant’s request for reconsideration after non-final rejection filed on 11/26/2025. Other Relevant Prior Art Makela (US 2006/0245555) teaches system for automatically filling in fields of a message template based on context. Response to Arguments Examiner discusses the arguments of Applicant’s representative below. Rejection of claims 1, 12, and 20 under 35 U.S.C. 102 Applicant’s representative has amended claims 1, 12, and 20 to recite new features and now argues that Miklos does not anticipate claims 1, 12, and 20, as amended. Examiner agrees. Nonetheless, the combination of Miklos and Ramakrishnan teach the system of amended claims 1, 12, and 20, as discussed in the rejection below. Claim Objections Claim 15 depends on cancelled claim 14. Examiner assumes that claim 15 is intended to depend on claim 12. Claim Rejections: 35 U.S.C. 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. Claims 1, 4-5, 11-12, 15, and 20 are rejected under 35 U.S.C. 103 because they are unpatentable over Miklos (US 2017/0192953) in view of Ramakrishnan (US 2020/0334639). Regarding claims 1, 12, and 20, Miklos teaches a method implemented by one or more processors, the method comprising: identifying, by an automated assistant or an application associated with the automated assistant, multiple different instances of content associated with a user of the automated assistant (The system identifies messages sent by a user. See par. 43-49), wherein the multiple different instances of content are identified based on one or more shared features at least shared between a first instance of content and a second instance of content of the multiple different instances of content (Specifically, the system identifies messages with similar content and/or attributes and groups the messages into a cluster. See par. 43-49); generating, based on the one or more shared features, a template that includes a first section and a second section (The system generates a template for the cluster that includes fixed segments 444-466 and transient segments 468-474; fig. 4B. See par. 50), wherein the template is accessed by the automated assistant in response to the user subsequently providing a request for the automated assistant to create an additional instance of content 444 (When the user submits a subsequent request to send a message, the system accesses the template to create the message. See par. 51); generating, based on the one or more shared features, configuration data that is stored in association with the template (The template comprises configuration data that identifies the fixed segments and the transient segments, as well as the text associated with each segment. See par. 40; fig. 4B), wherein the configuration data indicates that a first type of content is to be assigned to the first section of the template in response to the request, and a second type of content is to be assigned to the second section of the template in response to the request (The configuration data indicates that a first type of content (i.e., “fixed” content) is to be assigned to segments 444-466, and a second type of content (i.e., “transient” content) is to be assigned to segments 468-474. See par. 23, 40; fig. 4B), wherein the first type of content includes static content that does not change each time the template is accessed by the automated assistant (As indicated above, the first type of content is fixed content, meaning that the first type of content “does not change much across emails” or “may be entirely static.” See par. 35), and storing the template in association with the automated assistant (One of ordinary skill in the art would appreciate that the template is stored in a manner that makes it accessible for use in generating new messages in the manner described in paragraphs 51-53 and fig. 5, steps 510-514). However, Miklos does not teach that the second type of content is different from the first type of content, and includes annotations that are descriptive of documents historically included, by the user, in corresponding portions of the instances of content that correspond to the second portion of the template; and wherein generating the configuration data comprises generating the annotations based on processing the documents historically included, by the user, in the corresponding portions of the instances of content that correspond to the second section of the template. Nonetheless, Ramakrishnan teaches a system for automatically attaching a file to an email that is being drafted, whereby the system generates configuration data comprising a name of a file that is determined by processing files that are historically attached to a set of previous emails, determines that the email being drafted is similar to the set of previous emails, and automatically attaches the file to the email based on the name of the file in the configuration data and the detected similarity between the email being drafted and the set of previous emails. See par. 51-52; fig. 4. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Miklos so that the second type of content is a file, and so that the configuration data for the template includes the name of a file that is determined based on processing of files that are historically attached to the group of messages from which the template is generated (i.e., the messages with similar content and/or attributes), because doing so allows the system to automatically attach a file to an email generated using the template. Regarding claim 4, Miklos teaches the method of claim 1, wherein generating the configuration data that is stored in association with the template includes: determining, based on the multiple different instances of content, whether one or more particular features that are unshared between the first instance of content and the second instance of content are affected by a particular condition, wherein the configuration data characterizes the particular condition (The system determines, based on two different alphanumeric strings in a same location of two different messages, that the two different alphanumeric strings represent a date on which the messages were sent, and stores this information in the configuration data of the template in association with data regarding segment 444. See par. 35; fig. 4B). Regarding claims 5 and 15, Miklos teaches the method of claim 4, wherein the particular condition is based upon certain content that is dynamically updated from a particular source of data that is separate from the automated assistant (The date to be used when populating segment 444 of the template is understood to be obtained from an external source, i.e., a system clock or a time server). Regarding claim 11, Miklos teaches the method of claim 1, wherein the second section includes a document address field for attaching a document (The system looks for templates with attachments when selecting a template, which indicates that at least some templates include attachments. See par. 31). Claims 6 and 16 are rejected under 35 U.S.C. 103 because they are unpatentable over Miklos and Ramakrishnan, as applied to claims 1 and 12 above, in further view of Zhang (US 2014/0189027). Regarding claims 6 and 16, Miklos and Ramakrishnan do not teach the method of claim 1, wherein the multiple different instances of content are messages from the user to a particular recipient, and generating the configuration data that is stored in association with the template includes: determining that a context, in which the user generated a particular message of the messages, affected a phraseology of the particular message, wherein the configuration data characterizes a correspondence between the context and content phraseology of certain content to be incorporated into the template in response to a subsequent request from the user. However, Zhang teaches a system for generating a message for a user whereby the system analyzes the user’s historical message interaction information (comprising past messages communicated between the user and a recipient) and first context data associated with the historical message interaction information, whereby the system generates message interaction preferences (i.e., configuration data) that indicate a correspondence between the first context data and a particular writing style based on the analysis, and whereby the system generates the message according to the particular writing style based on the message interaction preferences and second context data associated with the message. See par. 22. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Miklos and Ramakrishnan so that the system analyzes the messages to a recipient in conjunction with context data to determine a correspondence between a writing style of the messages and the context data for use in drafting the subsequent message, because doing so allows the system to customize the writing style of the subsequent message based on context data. Claims 7, 8, 17, and 18 are rejected under 35 U.S.C. 103 because they are unpatentable over Miklos, Ramakrishnan, and Zhang, as applied to claims 6 and 16 above, in further view of McEvilly (US 2006/0069728). Regarding claims 7 and 17, Miklos, Ramakrishnan, and Zhang do not teach the method of claim 6, wherein the content phraseology corresponds to a verbiage of the certain content, and the configuration data directs the automated assistant to modify the verbiage of the certain content according to a temporal aspect of a subsequent context of the subsequent request from the user. Nonetheless, McEvilly teaches a system for transforming a style of a message whereby the system uses configuration data to transform content of a message according to a writing style that is selected based on a time of day (i.e., temporal context) associated with the message. See par. 97. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Miklos, Ramakrishnan, and Zhang so that the system modifies the writing style of the subsequent message according to a temporal context associated with the subsequent message, because doing so allows the system to customize the writing style of the subsequent message based on temporal context data such as the time of day. Regarding claims 8 and 18, Miklos, Ramakrishnan, Zhang, and McEvilly teach the method of claim 7, wherein the content phraseology corresponds to a vocabulary of the certain content, and the configuration data directs the automated assistant to: select a first vocabulary for the certain content when the subsequent request from the user is provided in a first context, and select a second vocabulary for the certain content when the subsequent request from the user is provided in a second context that is different than the first context (McEvilly teaches transforming the message according to a first writing style based on a first time of day associated with the message, and transforming the message according to a second writing style based on a second time of day. See par. 97. Thus, McEvilly suggests further modifying the system of Miklos, Ramakrishnan, Zhang, and McEvilly so that the configuration data directs the system to select a first writing style for content of the message when the subsequent request is associated with a first time of day, and the configuration data directs the system to select a second writing style for the content of the message when the subsequent message is associated with a second time of day, because doing so allows the system to generate the content of the message according to a writing style that is most suitable for a time of day associated with the message. Claims 21-24 are rejected under 35 U.S.C. 103 because they are unpatentable over Miklos and Ramakrishnan, as applied to claims 1 and 12 above, in further view of Yu (US 2018/0157408). Regarding claims 21-22, Miklos and Ramakrishnan do not teach the method of claim 1, wherein the documents historically included, by the user, in the corresponding portions of the instances of content, are most-recently modified documents and wherein the attachments are descriptive of a most-recently modified document. However, Yu teaches a system for automatically attaching a file to a message that is currently being drafted, whereby configuration data specifies that a file that is to be automatically attached to the message is the most recently processed or most recently modified file. See par. 204. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Miklos and Ramakrishnan so that the files that are historically attached to the group of messages from which the template is generated are most recently modified files, because doing so allows the system to automatically attach a most recently modified file to messages generated using the template. Regarding claims 23-24, Miklos, Ramakrishnan, and Yu teach the method of claim 21, further comprising: accessing, by the automated assistant, the template in response to the user subsequently providing the request for the automated assistant to create a given additional instances of the content (Miklos teaches that the system accesses the template when the user submits a subsequent request to send a message. See par. 51), processing the annotations stored in associated with the template to identify a given most-recently modified document, wherein the given most-recently modified document is identified based on the annotations being descriptive of the most-recently modified document, and using the most-recently modified document to fill the second section of the template (Ramakrishnan teaches configuration data that specifies a name of a file that is to be attached to an email when the email is similar to a set of previous emails to which the file was attached, which suggests further modifying the system of Miklos, Ramakrishnan, and Yu so that the name of the file specified by the configuration data is processed to identify a file to attach to the email (See par. 51-52; fig. 4), because doing so is beneficial for the reasons provided above with respect to claim 1. Yu teaches attaching the most recently modified file to a message based on configuration data (See par. 204), which suggests further modifying the system of Miklos, Ramakrishnan, and Yu so that the file specified by the configuration data is the most recently modified file, because doing so is beneficial for the reasons provided above with respect to claim 23). 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 Andrew Georgandellis whose telephone number is 571-270-3991. The examiner can normally be reached on Monday through Friday, 7:30-5:00 PM EST. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Tonia Dollinger, can be reached on 571-272-4170. 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. /ANDREW C GEORGANDELLIS/Primary Examiner, Art Unit 2459
Read full office action

Prosecution Timeline

Feb 29, 2024
Application Filed
Aug 25, 2025
Non-Final Rejection — §103
Nov 26, 2025
Response Filed
Jan 09, 2026
Final Rejection — §103
Mar 06, 2026
Applicant Interview (Telephonic)
Mar 20, 2026
Examiner Interview Summary

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12574425
SYSTEMS AND METHODS FOR APPLICATION OF CONTEXT-BASED POLICIES TO VIDEO COMMUNICATION CONTENT
2y 5m to grant Granted Mar 10, 2026
Patent 12549510
METHODS AND SYSTEMS FOR ACCESSING CONTENT
2y 5m to grant Granted Feb 10, 2026
Patent 12526335
NONSTOP VIRTUAL REMOTE DIRECT MEMORY ACCESS
2y 5m to grant Granted Jan 13, 2026
Patent 12493537
SYSTEM AND METHOD FOR BOOTING SERVERS IN A DISTRIBUTED STORAGE TO IMPROVE FAULT TOLERANCE
2y 5m to grant Granted Dec 09, 2025
Patent 12476870
DATA COLLECTION METHOD AND DEVICE
2y 5m to grant Granted Nov 18, 2025
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
56%
Grant Probability
96%
With Interview (+40.4%)
4y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 490 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month