Prosecution Insights
Last updated: April 19, 2026
Application No. 18/624,236

COVERT AND RESILIENT COMMUNICATION OVER NON-COOPERATIVE NETWORKS

Non-Final OA §101§103
Filed
Apr 02, 2024
Examiner
KABIR, JAHANGIR
Art Unit
2439
Tech Center
2400 — Computer Networks
Assignee
George Mason University
OA Round
1 (Non-Final)
80%
Grant Probability
Favorable
1-2
OA Rounds
3y 6m
To Grant
99%
With Interview

Examiner Intelligence

Grants 80% — above average
80%
Career Allow Rate
445 granted / 553 resolved
+22.5% vs TC avg
Strong +37% interview lift
Without
With
+36.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
14 currently pending
Career history
567
Total Applications
across all art units

Statute-Specific Performance

§101
13.5%
-26.5% vs TC avg
§103
60.4%
+20.4% vs TC avg
§102
6.5%
-33.5% vs TC avg
§112
8.9%
-31.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 553 resolved cases

Office Action

§101 §103
DETAILED ACTION This Office Action is in response to the application 18/624236, filed on 04/02/2024. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Claims 1-20 have been examined and are pending in this application. Claim 1 is independent. Priority/Continuity Provisional Application No. 63/494001, filed on 04/03/2023. Information Disclosure Statement No information disclosure statement (IDS) has been filed for this application. The Examination is conducted without any PriorArt search help from the Applicant. Applicant is reminded of the duty to disclose from section 2100 of the MPEP: 37 C.F.R. 1.56; Duty to disclose information material to patentability. A patent by its very nature is affected with a public interest. The public interest is best served, and the most effective patent examination occurs when, at the time an application is being examined, the Office is aware of and evaluates the teachings of all information material to patentability. Each individual associated with the filing and prosecution of a patent application has a duty of candor and good faith in dealing with the Office, which includes a duty to disclose to the Office all information known to that individual to be material to patentability as defined in this section. Claim Interpretations As to claim 1, the claim cite limitation, in lines 6-8, “to be decoupled from the original content and to have an assigned context in the target language that corresponds to the network communication in the target language,” are intended use, and may not be given patentable weight (See Ex parte Chow; Appeal No. 2010-002121). The applicant may amend the claim, positively reciting to the functional steps. 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, 10, 18 and 20 are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. As to claim 1, the claim cites, performing two function steps: “encoding a ciphertext into a stegotext,” and “transmitting the stegotext to a receiver” along with refining limitations. The limitations, in the context of this claim, encompasses the user manually performs the function steps. The limitations, is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind, then it falls within the “Mental Processes” of abstract ideas. Accordingly, the claim recites an abstract idea. This judicial exception is not integrated into a practical application. Additional element of the function steps does not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception, Viewing the limitations in combination, also fails to amount to significantly more than the abstract idea. The addressed claimed functions, even with the additional limitations, reflect mental process steps, as would be recognized by those of ordinary skill in the field of data processing, and does not add significantly more to a judicial exception. Even considering, that the functions are performed by a claimed, a sender and a receiver, in communication network, they are generic computing functions that a person is able to conceptualize them mentally. Therefore, the claims are not patent eligible. As to the dependent claims 2-5, 7-20, the claims do not include additional steps/element that are sufficient to amount to significantly more to transform the abstract idea into patent-eligible subject matter. Therefore, these claims are also rejected under 35 USC 101 as being directed to non-statutory subject matter. 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 of this title, 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. This application currently names joint inventors. In considering patentability of the claims the Examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the Examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 1-5, 7-20 are rejected under 35 U.S.C. 103 as being unpatentable over Tew et al (“Tew,” US 2021/007577, published on 03/11/2021), in view of Marlow et al (“Marlow,” US 2014/0025952, patented on 01/23/2014). As to claim 1, Tew teaches a method (Tew: pars 0010, 0013, 0020, a system and method of protecting confidentiality of messages, including audio, video, image message, for transmission) comprising: at a sender side of a network communication between a sender and a receiver in communication network (Tew: pars 0013-0014, 0016, 0020; Fig 1, a communication architecture of computing devices, where one or more message source device configured to transmit message [i.e., sender] to one or more output device [i.e. receiver]): encoding [ ] into a stegotext [ ], the ciphertext based upon an original content in a source language (Tew: pars 0013-0014, 0016, 0020, the input message is partitioned into a plurality of content segments, where each content segment is modified [i.e., encoding into a stegotext] based on the respective confidentiality level); and transmitting the stegotext to a receiver over multiple communication channels of a communication network using one or more applications on an application layer of the communication network (Tew: pars 0013-0014, 0016, 0020, the modified message segments are transmitted over one or more communication links [i.e., over multiple communication channels] to the respective output device [i.e., the receiver]). Tew does not explicitly teach [encoding] a ciphertext, in a target language using a randomized language model, the stegotext randomly generated by the language model to be decoupled from the original content and to have an assigned context in the target language that corresponds to the network communication in the target language. However, in an analogous art, Marlow teaches [encoding] a ciphertext, in a target language using a randomized language model (Malow: pars 0009, 0023-0024, title, a system and method for hiding ciphertext using linguistics algorithm before transmission. Where any message oriented communications such as MMS, picture messages, email messages, other text documents/attachments, command and control messages, alerts messages, machine to machine messages, etc. that is encrypted for security [i.e., cyphertext], is further converted to into text, masquerading as natural language [i.e., target language] messaging to disguises the fact that the message was encrypted in the first place for further security), the stegotext randomly generated by the language model to be decoupled from the original content and to have an assigned context in the target language that corresponds to the network communication in the target language (Malow: pars 0009, 0023-0024, 0098, at the receiver side, the converted/disguised natural language message is decoded using a reversal process of the encoding process). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Marlow with the method/system of Tew to include the limitation(s), [encoding] a ciphertext, in a target language using a randomized language model the stegotext randomly generated by the language model to be decoupled from the original content and to have an assigned context in the target language that corresponds to the network communication in the target language, where one would have been motivated for the benefit of providing an additional layer of security in transmitting a cyphertext message in an converted format to disguise or pass off as natural language messages so that an attacker will not think that transmitted message is an encrypted message and would not try to break/decode (Malow: pars 0009, 0023-0024, 0098). As to claim 2, the combination of Tew and Marlow teaches the method of claim 1, Tew further teaches where prior to transmitting the stegotext to the receiver, further comprising: generating a plurality of messages of the stegotext (Tew: pars 0013-0014, 0016, 0020, the input message is partitioned into a plurality of content segments, where each content segment is modified); and transmitting the plurality of messages of the stegotext to the receiver by distributing the plurality of messages across a plurality of communication channels using the one or more applications (Tew: pars 0013-0014, 0016, 0020, the modified message segments are transmitted over one or more communication links [i.e., across a plurality of communication channels] to the respective output device [i.e., the receiver]). As to claim 3, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches where prior to transmitting the stegotext to the receiver, further comprising an automatic machine translation (MT) system translating the stegotext into the target language (Malow: pars 0023-0024, 0071, 0104, the message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process [i.e., automatic machine translation], considering dictionary, grammar and syntax/punctuation marks of a specific natural language). As to claim 4, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches further comprising at a receiver side of the network communication: inverting the received stegotext to retrieve the original content (Malow: pars 0024, 0098, 0101, at the receiver side, the converted/disguised natural language message is decoded using a reversal process of the encoding process for getting output back to its original representation). As to claim 5, the combination of Tew and Marlow teaches the method of claim 4, Marlow further teaches where inverting the received stegotext to retrieve the original content comprises: the language model decoding the received stegotext into encrypted ciphertext; and decrypting the encrypted ciphertext to retrieve the original content (Malow: pars 0024, 0098, 0101, at the receiver side, the converted/disguised natural language message is decoded using a reversal process of the encoding process for getting output back to its original representation. Then, if the system determines that the content was in fact encrypted, the system proceeds with to decrypt the message to produce original message content). As to claim 7, the combination of Tew and Marlow teaches the method of claim 1, Tew and Marlow further teaches where the network communication is a network conversation between the sender and the receiver and responsive to the receiver receiving the stegotext, further comprising at the receiver side of the network conversation: generating using the language model reply stegotext in the target language, where the reply stegotext is decoupled from the original content and has a context responsive to the stegotext received from the sender in the target language of the network conversation (Malow: pars 0023-0024, 0071, 0100, 0104, 0107, the encrypted message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language. As an option, the masquerade text output can be in different languages and alphabets. The original message can be Multimedia Messaging Service (MMS)); and transmitting to the sender the reply stegotext across one or more communication channels of the communication network using the one or more applications (Tew: pars 0013-0014, 0016, 0020, the modified message segments are transmitted over one or more communication links [i.e., across one or more communication channels] to the respective output device. Malow: pars 0024, 0098, 0101, at the receiver side, the converted/disguised natural language message is decoded using a reversal process of the encoding process for getting output back to its original representation. Then, if the system determines that the content was in fact encrypted, the system proceeds with to decrypt the message to produce original message content). As to claim 8, the combination of Tew and Marlow teaches the method of claim 1, Tew and Marlow further teaches where the randomized language model converting the ciphertext into the stegotext in the target language includes the randomized language model generating one or more portions of a multi-modal stegotext (Malow: pars 0023-0024, 0071, 0100, 0104, 0107, the message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language. As an option, the masquerade text output can be in different languages and alphabets. The original message can be Multimedia Messaging Service (MMS). Tew: pars 0013-0014, 0016, 0020, the input message, can be in a format of audio, still, image, video, or digitally converted text strings). As to claim 9, the combination of Tew and Marlow teaches the method of claim 8, Tew further teaches where the one or more portions of the multi-modal stegotext include one or more of text, audio, image and voice (Tew: pars 0013-0014, 0016, 0020, the input message, can be audio, still, image, video, or digitally converted text strings). As to claim 10, the combination of Tew and Marlow teaches the method of claim 8, Marlow further teaches the randomized language model converting the original content into multi-modal cover content having text and audio responsive to receiving a ciphertext encrypted from the original content and one or more characteristics for an audio portion of the multi-modal stegotext, the text and the audio of the multi-modal stegotext measured in bits (Malow: pars 0023-0024, 0071, 0100, 0104, 0107, the encrypted message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language. As an option, the masquerade text output can be in different languages and alphabets. The original message can be Multimedia Messaging Service (MMS)). As to claim 11, the combination of Tew and Marlow teaches the method of claim 8, Tew further teaches where the original content is a voice message and prior to encoding the ciphertext into the stegotext, transcribing the voice message to a text message (Tew: pars 0016, 0020, 0030, the process converts the received audio/voice message into a digital text string before modifying). As to claim 12, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches the ciphertext generated by encrypting the original content into a random bit string (Malow: pars 0013, 0046-0049, the message is encrypted using ASCII encoding techniques for producing in a string format). As to claim 13, the combination of Tew and Marlow teaches the method of claim 12, Marlow further teaches further comprising encrypting the original content into the random bit string using a secret key shared by the sender and the receiver (Malow: pars 0013, 0046-0049, 0098, 0101, the message is encrypted using ASCII encoding techniques, using secret key, public key or other material/process used for cryptographic operations. At the receiver side, after decoding the converted/disguised natural language message, if the system determines that the content was in fact encrypted, the system proceeds with to decrypt the message to produce original message content). As to claim 14, the combination of Tew and Marlow teaches the method of claim 13, Marlow further teaches where the shared secret key is established by a key exchange protocol based on a public key certificate (Malow: pars 0013, 0046-0049, 0098, 0101, the message is encrypted using ASCII encoding techniques, using secret key, public key or other material/process used for cryptographic operations). As to claim 15, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches where the source language of the original content and the target language of the stegotext are the same language (Malow: pars 0100, 0104, 0107, the encrypted message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language [i.e., same language]. As an option, the masquerade text output can be in different languages and alphabets). As to claim 16, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches where encoding the ciphertext, via the language model, by controlling how a next token is chosen at recurrent steps further comprising: choosing the next token to be sampled based on a probability distribution determined by the language model and the ciphertext (Malow: pars 0023-0024, 0071, 0100, 0104, 0107, the encrypted message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language, automatically generating individual sentence parameters such as how many words to a sentence, and with use of syntax). As to claim 17, the combination of Tew and Marlow teaches the method of claim 16, Marlow further teaches where the language model is a byte-level language model or a subword language model that generates a byte in each recurrent step. As to claim 18, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches the context of the stegotext generated by the language model being coherent to one or more of operational context and dialog context (Malow: pars 0023-0024, 0071, 0100, 0104, 0107, the encrypted message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language, in an readable and sensible text format [i.e. coherent dialog context]). As to claim 19, the combination of Tew and Marlow teaches the method of claim 1, Marlow further teaches the language model applying chatbots to randomly generate the context of the stegotext, the stegotext having randomized frequency and time characteristics (Malow: pars 0023-0024, 0071, 0100, 0104, 0107, the encrypted message is converted to into text, masquerading as natural language messaging, using an automatic computer translation process, considering dictionary in a randomized process, grammar and syntax/punctuation marks of a specific natural language. In the randomized process, the output content may be different even for the same input content on each invocation, further shielding the original content). As to claim 20, the combination of Tew and Marlow teaches the method of claim 19, Tew and Marlow further teaches the user profiles of the sender and receiver of the network communication and metadata of the network communication are obfuscated by the chatbots (Tew: pars 0010, 0013, 0020, a system and method of protecting confidentiality of messages, including audio, video, image message, for transmission. Malow: pars 0023-0024, 0104, obfuscating encrypted data content in SMS, Twitter or other short messaging, including MMS format data). Allowable Subject Matter The present invention is directed to method and system for provideing network communication between a sender and a receiver in a communication network. At a sender side of the network communication a ciphertext is encoded into a stegotext in a target language using a randomized language model, the ciphertext based upon an original content in a source language. The stegotext randomly generated by the language model to be decoupled from the original content and to have an assigned context in the target language that corresponds to the network communication in the target language. The stegotext is transmitted to a receiver over multiple communication channels of a communication network using one or more applications on an application layer of the communication network. The Examiner concludes that, none of Tew and Marlow, nor any other art teaches or suggests, alone or in combination, the particular combination of steps or elements as recited in the dependent claim 6, as a whole including with the limitations of claims 1, 4, and 5. Therefore, the claim 6 is considered allowable over the cited prior art. As to the dependent claim 14, the claim limitations are similar to the claim limitation of claim 2, and therefore, also considered allowable over the cited prior art. The dependent claim 6, which is considered allowable over the cited prior art, is objected as it is depend on the associated rejected base claims, including independent claim, which are rejected above, and would be considered to be allowable if rewritten in independent form including all of the limitations of the associated rejected base claim(s) 1, 4, and 5. Conclusion Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Jahangir Kabir whose telephone number is (571) 270-3355. The Examiner can normally be reached on 9:00- 5:00 Mon-Thu. If attempts to reach the Examiner by telephone are unsuccessful, the Examiner’s supervisor, Luu Pham can be reached on (571) 270-5002. The fax 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 Patent Center and the Private Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from Patent Center or Private PAIR. Status information for unpublished applications is available through Patent Center and Private PAIR for authorized users only. Should you have questions about access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). 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) Form at https://www.uspto.gov/patents/uspto-automated- interview-request-air-form. /JAHANGIR KABIR/ Primary Examiner, Art Unit 2439
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Prosecution Timeline

Apr 02, 2024
Application Filed
Oct 14, 2025
Non-Final Rejection — §101, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
80%
Grant Probability
99%
With Interview (+36.9%)
3y 6m
Median Time to Grant
Low
PTA Risk
Based on 553 resolved cases by this examiner. Grant probability derived from career allow rate.

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