Prosecution Insights
Last updated: April 19, 2026
Application No. 18/604,990

STORING SEMI-STRUCTURED DATA

Non-Final OA §101
Filed
Mar 14, 2024
Examiner
MOSER, BRUCE M
Art Unit
2154
Tech Center
2100 — Computer Architecture & Software
Assignee
Google LLC
OA Round
4 (Non-Final)
85%
Grant Probability
Favorable
4-5
OA Rounds
2y 10m
To Grant
99%
With Interview

Examiner Intelligence

Grants 85% — above average
85%
Career Allow Rate
631 granted / 745 resolved
+29.7% vs TC avg
Strong +20% interview lift
Without
With
+20.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
47 currently pending
Career history
792
Total Applications
across all art units

Statute-Specific Performance

§101
10.9%
-29.1% vs TC avg
§103
33.4%
-6.6% vs TC avg
§102
31.1%
-8.9% vs TC avg
§112
6.3%
-33.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 745 resolved cases

Office Action

§101
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 . Detailed Action 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 1/29/26 has been entered. In amendments dated 12/17/25, Applicant amended claims 1, 11, and 21, canceled claims 2-3 and 12-13, and added no new claims. Claims 1, 4-9, 11, 14-19, and 21 are presented for examination. Rejections under 35 U.S.C. 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. 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, 4-9, 11, 14-19, and 21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to mental processes without significantly more. Independent claims 1, 11, and 20 each recites identifying, by the computing system, a matching schema from the plurality of schemas for the semi-structured data item; in response to determining that no matching schema exists in the plurality of schemas, dynamically generating, by the computing system, a new schema for the semi-structured data item, the new schema defining a mapping from the key to a storage location in the data item repository, assigning a unique identifier to the new schema; and identifying, by the computing system, the new schema based on the unique identifier and the storage location of the value based on the mapping defined by the new schema. Identifying a matching schema is evaluating and a mental process, generating a new schema is recited broadly and is a mental process accomplishable in the human mind or on paper, and identifying a matching schema is evaluating and a mental process. Each claim recites additional elements of maintaining, by one or more processors of a computing system, a plurality of schemas, each schema defining a mapping from a key to a storage location in a data item repository, and associated with one or more data items stored in a data format in a data item repository, each data item storing a respective value, wherein each schema of the plurality of schemas is assigned a unique identifier; receiving, by the computing system, a semi-structured data item in a semi-structured data format, the semi-structured data item comprising a key/value pair; in response (to identifying a matching schema), storing, by the computing system, a value of the key/value pair at a storage location defined by the matching schema the data item repository; storing the value at the storage location defined by the new schema in the data item repository in a format that omits the key to reduce storage overhead; receiving, by the computing system, a query for the semi-structured data item, wherein the query specifies a value requirement for the key; and based on the value requirement, retrieving, by the computing system, the value from the storage location. Maintaining a plurality of schemas is storing schemas and is insignificant extra-solution activity, both instances of storing a value of a key/value pair at a storage location are also insignificant extra-solution activity; and receiving a semi-structured data item and receiving a query for the semi-structured data item are both input steps and also insignificant extra-solution activity, and retrieving the value from the storage location is also insignificant extra-solution activity. Claim 11 recites data processing hardware and memory hardware and claim 21 recites non-transitory computer-readable storage media, which are each generic components of a computer system. Examiner notes the last limitation recites “storing the value at the storage location defined by the new schema in the data item repository in a format that omits the key to reduce storage overhead” and, while Examiner found support for this limitation in specification paragraph 0027 and figure 2, omitting a key to reduce storage overhead is not discussed among the improvements in paragraphs 0010 and 0024. Paragraph 0010 also states “queries for data items stored in the efficient data format can be processed efficiently” but the claims do not recite any improvements related to receiving a query, identifying the new schema, and retrieving the value from storage as claimed. Furthermore, the identifying and generating steps are recited lacking inventive details showing how a matching schema is identified or a new schema is generated and Examiner does not see how dynamically generating a new schema improves upon storage of semi-structured data. Thus the claim steps do not recite a particular improvement in any technology or function of a computer per MPEP 2106.04(d) and do not recite any unconventional steps in the invention per MPEP 2106.05(a). Therefore, the recited mental processes are not integrated into a practical application. Taking the clams as a whole the maintaining and storing steps are storing data and are routine and conventional activity per the list of such activities in MPEP 2106.05(d) part II, and the input steps are recited broadly and amount to receiving data across a network per specification pages 15-16 lines 30-8 (pre-grant publication paragraph 0059) and are routine and conventional activities per the list of such activities in MPEP 2106.05(d) part II. The data processing hardware and memory hardware and non-transitory computer-readable storage media are each still generic components of a computer system. Thus thee claims do not include additional elements that are sufficient to amount to significantly more than the recited mental processes. Claims 4 and 14 each recites wherein each schema of the plurality of schemas identifies requirements for values of the one or more data items, and a schema is data and a mental process accomplishable in the human mind or on paper. Claims 5 and 15 each recites wherein each schema of the plurality of schemas identifies a required data type for values of the one or more data items, and a schema is data and a mental process accomplishable in the human mind or on paper. Claims 6 and 16 each recites wherein the plurality of schemas are stored in a schema repository, and storing data is routine and conventional per the list of such activities in MPEP 2106.05(d) part II. Claims 7 and 17 each recites receiving a modification to a particular key in the plurality of schemas, and receiving a modification is receiving data across a network which is routine and conventional per the list of such activities in MPEP 2106.05(d) part II; and modifying the particular key without modifying the one or more data items stored in the data item repository is modifying data and a mental process accomplishable in the human mind or on paper. Claims 8 and 18 each recites encoding the value of the key/value pair, and encoding a data item is generating the data item in a data format per specification paragraphs 0022 and 0026 and figure 2, which is a mental process accomplishable in the human mind or on paper; storing the encoded value at the data item repository, which is routine and conventional per the list of such activities in MPEP 2106.05(d) part II; and associating the stored encoded value with the matching schema identified from the plurality of schemas for the semi-structured data item or the new schema generated for the semi-structured data item when no matching schema exists, and associating a value with a schema is recited broadly and is a mental process accomplishable in the human mind or on paper. Claims 9 and 19 each recites wherein encoding the value of the key/value pair comprises encoding the value into an ordered list, which is a mental process accomplishable in the human mind or on paper. Relevant Prior Art During his search for prior art, Examiner found the following references to be relevant to Applicant's claimed invention. Each reference is listed on the Notice of References form included in this office action: Abadi et al (US 20150088924) teaches accessing stored partially structured data using a structured query language, does not teach dynamically creating new schema and identifying a matching schema to a semi-structured data item upon receipt of said semi-structured data item (paragraphs 0006, 0013, 0035, 0050, and 0056); and Tsirogiannis et al (US 20140279838) teaches dynamically creating schema for objects retrieved from a data source by inferring the schema according to the objects, does not teach receiving a semi-structured data item, maintaining a plurality of schemas, identifying a matching schema, a unique identifier for each schema, and identifying a matching schema or a query and retrieving a value based on the identified new schema (paragraphs 0020, 0066, 0073-74). Responses to Applicant’s Remarks Regarding rejections to claims 1-9, 11-19, and 21 under 35 U.S.C. 101 for reciting mental processes without significantly more, Applicant’s amendments and arguments have been considered but are not persuasive. On pages 7-8 of his Remarks Applicant discusses specification paragraph 0010 and asserts the amendments more clearly demonstrate technical improvements of the invention. Examiner disagrees as the limitations are broad, for example “identifying, by the computing system, the new schema based on the unique identifier and the storage location of the value based on the mapping defined by the new schema” which does not recite specifically how the new schema or the storage location are identified, and the recited additional elements are routine and conventional actions of receiving a query and retrieving a value. Thus the amended claims still do not recite inventive details showing any technological improvements per MPEP 2106.04(d) and do not make the claims eligible. Furthermore, Applicant excerpts from paragraph 0010 ("Queries for data items stored in the efficient data format can be processed efficiently. Using the dynamically generated schemas, users can easily and effectively analyze the semi-structured data that has been stored by an application in a data item repository. For example, users can easily identify potential data quality issues, e.g., by querying for data items that don't follow an expected schema or schemas that match very few data items.") and asserts “the amendments now recite technical improvements that integrate a practical application.” Examiner disagrees and does not see where the amended claim limitations recite how the invention easily and effectively analyzes the stored semi-structured data using dynamically generated schemas; or identify potential data quality issues by querying data items. Examiner notes specification page 5 lines 18-25 (pre-grant publication paragraph 0020) states “generally, the data storage format is an efficient data storage format, i.e., a data format that is defined such that encoding a received data item in the efficient data storage format and storing the encoded data item in the data item repository 106 requires less storage space than storing the received data item directly in the semi-structured data format in which the data item was received.” Specification pages 5-6 lines 26-2 (pre-grant publication paragraph 0021) states “for example, the efficient data storage format can specify that the values be stored as a sequence of bytes or as a sequence of elements, e.g., as an ordered list of values, without storing the corresponding keys from the key/value pairs [emphasis added].” Dependent claims 8 and 18 each recites “encoding the value of the key/value pair; storing the encoded value at the data item repository; and associating the stored encoded value with the matching schema identified from the plurality of schemas for the semi-structured data item or the new schema generated for the semi- structured data item when no matching schema exists.” Dependent claims 9 and 19 depend on claims 8 and 18, respectively, and each recite “wherein encoding the value of the key/value pair comprises encoding the value into an ordered list,” and Examiner believes that this, along with omitting the storage of the corresponding keys from the key/value pairs, would realize the improvement of reducing storage overhead described specification page 5 lines 18-25 as noted above and direct the claimed invention in 1, 11, and 20 towards a practical application. Inquiry Any inquiry concerning this communication or earlier communications from the examiner should be directed to BRUCE M MOSER whose telephone number is (571)270-1718. The examiner can normally be reached M-F 9a-5p. 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, Boris Gorney can be reached at 571 270-5626. 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. /BRUCE M MOSER/Primary Examiner, Art Unit 2154 3/19/26
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Prosecution Timeline

Mar 14, 2024
Application Filed
Dec 13, 2024
Non-Final Rejection — §101
Mar 07, 2025
Response Filed
Apr 25, 2025
Non-Final Rejection — §101
Jul 08, 2025
Interview Requested
Jul 16, 2025
Applicant Interview (Telephonic)
Jul 16, 2025
Examiner Interview Summary
Aug 29, 2025
Response Filed
Nov 17, 2025
Final Rejection — §101
Dec 17, 2025
Response after Non-Final Action
Jan 29, 2026
Request for Continued Examination
Feb 08, 2026
Response after Non-Final Action
Mar 19, 2026
Non-Final Rejection — §101 (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

4-5
Expected OA Rounds
85%
Grant Probability
99%
With Interview (+20.4%)
2y 10m
Median Time to Grant
High
PTA Risk
Based on 745 resolved cases by this examiner. Grant probability derived from career allow rate.

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