Prosecution Insights
Last updated: April 19, 2026
Application No. 18/692,519

PROVIDING COMMUNICATION SESSIONS BASED ON MOBILE APPLICATION ENGAGEMENT

Final Rejection §101§103
Filed
Mar 15, 2024
Examiner
DURAN, ARTHUR D
Art Unit
3622
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Viasat, Inc.
OA Round
2 (Final)
16%
Grant Probability
At Risk
3-4
OA Rounds
6y 0m
To Grant
41%
With Interview

Examiner Intelligence

Grants only 16% of cases
16%
Career Allow Rate
67 granted / 427 resolved
-36.3% vs TC avg
Strong +26% interview lift
Without
With
+25.7%
Interview Lift
resolved cases with interview
Typical timeline
6y 0m
Avg Prosecution
36 currently pending
Career history
463
Total Applications
across all art units

Statute-Specific Performance

§101
27.4%
-12.6% vs TC avg
§103
48.9%
+8.9% vs TC avg
§102
12.7%
-27.3% vs TC avg
§112
8.1%
-31.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 427 resolved cases

Office Action

§101 §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 . DETAILED ACTION Claims 1-24 have been examined. Response to Arguments Applicant's arguments with respect to the claims have been considered but are moot in view of the new ground(s) of rejection. On 3/4/26, Applicant amended the independent claims. Applicant’s remarks address these new features. See the new 103 that addresses these new features. In regards to 101, the 101 is still found to apply. No new additional elements beyond the generic have been found. See the 101 below. Also, since the Applicant was given the opportunity, with the 3/4/26 submission, and has failed to traverse the Examiner's assertion of Official Notice, the common knowledge or well known in the art statement is taken to be admitted prior art (see MPEP 2144.03.C). Applicant did not challenge the use of Official Notice with the 3/4/26 submission. 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. Independent Claims 1, 13 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The claims are in a statutory category of invention. However, the claims recite establishing, a communication session with a passenger on the transport vessel, the communication session restricted; presenting, from the passenger via the communication session, one or more reward offers; receiving, an indication of selection of a first reward offer, the first reward offer associated with engagement of the passenger; redirecting the communication session, associated with installation of applications for the personal electronic device. This is considered in the Abstract Idea grouping of certain methods of organizing human activity - advertising, marketing or sales activities or behaviors. This judicial exception is not integrated into a practical application because the claim is directed to an abstract idea with additional generic computer elements. The additional elements are considered a multi-user access terminal on the transport vessel, a personal electronic device of, to a first domain, of an application for execution on the personal electronic device, to a second domain, the second domain, to the first domain, the second domain, and a third domain associated with an application server for the application, based at least in part on redirecting the communication session to the second domain, a communication session delivery system on the transport vessel, a link to an application, a firewall restricts provision of network address translation for traffic communicated by the personal electronic device to traffic between the personal electronic device and one or more of the first domain, the second domain, or the third domain. These are considered generic. The use of firewalls is considered generic since no specific technical steps are stated or claimed. The generically recited computer elements do not add a practical application or meaningful limitation to the abstract idea because they amount to simply implementing the abstract idea on a computer. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. The additional limitations only perform well-understood, routine, conventional computer functions as recognized by the court decisions listed in MPEP § 2106.05(d). Also, the additional hardware elements are: (i) mere instructions to implement the idea on a computer, and/or (ii) recitation of generic computer structure that serves to perform generic computer functions. Viewed separately or as a whole, these additional claim elements do not provide meaningful limitations to transform the abstract idea into a patent eligible application of the abstract idea such that the claims amounts to significantly more than the abstract idea itself. The claim does not provide significantly more than the identified abstract idea, in that there is no improvement to another technology or technical field, no improvement to the functioning of a computer, no application with, or by use of a particular machine, no transformation or reduction of a particular article to a different state or thing, no specific limitation other than what is well-understood, routing and conventional in the field, no unconventional step that confines the claim to a particular useful application, or meaningful limitations that amount to more than generally linking the use of the abstract idea to a particular technological environment. Therefore, the claims are rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter. Dependent claims 2-12, 14-24 are not considered directed to any additional non-abstract claim elements. Rather, these claims offer further descriptive limitations of elements found in the independent claims and addressed above. The time and packet limits, and size limits are considered generic and routine use of network management. While these descriptive elements may provide further helpful description for the claimed invention, these elements do not confer subject matter eligibility to the invention since their individual and combined significance is still not more than the abstract concepts identified in the claimed invention. Hence, these dependent claims are also rejected under 101. Please see the 35 USC 101 section at the Examination Guidance and Training Materials page on the USPTO website. 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. Claims 1-10, 12-22, 24 are rejected under 35 U.S.C. 103 as being unpatentable over Chang (20200334703) in view of Spencer (20200162890). Claim 1, 13. Chang discloses a method for communication within a transport vessel served via a wireless communication link, comprising: establishing, by a multi-user access terminal on the transport vessel, a communication session with a personal electronic device of a passenger on the transport vessel, the communication session restricted to a first domain of a communication session delivery system on the transport vessel (see plurality of devices connected on airplane at [14]; Fig. 1; see offer of inflight connectivity at [40]; also for communication session delivery system, see IFE at [12, 1]; also for domain note different connectivity segments and public and private segments at [16]); presenting, from the communication session delivery system to the passenger via the communication session, one or more reward offers (see rewards and inflight connectivity [12, 16, 40]); receiving, at the communication session delivery system from the personal electronic device, an indication of selection of a first reward offer (see rewards and inflight connectivity [12, 16, 40]), the first reward offer associated with engagement of an application for execution on the personal electronic device of the passenger (see task and survey at [41, 12], see reward and ad at [42]). Chang does not explicitly disclose redirecting the communication session to a second domain, the second domain associated with installation of applications for the personal electronic device. However, Chang discloses the 2nd domain and different domains (see Fig. 1). Also for domain note different connectivity segments and public and private segments at [16]. And, Chang further discloses loadable files at [20] and also applications [46, 56, 57] and portals [53] for use with the system. Also, Examiner notes that based on Applicant Spec a domain can be interpreted as a portal [20]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Chang’s loadable files to Chang’s applications and portals such that Chang can install/load the applications/portals used. One would have been motivated to do this in order to better make accessible the applications/portals and functions disclosed. Chang does not explicitly disclose wherein the redirecting comprises sending, to the personal electronic device, a link to the application within the second domain. However, Chang discloses sending to the PED a link to further info relevant to the user including user reward or reward info [51] and also that the passenger can access portals for further reward info [53]. And, as shown preceding, Chang renders obvious loadable files/installing and applications and portals. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Chang’s providing links to further user relevant info and functions at a second domain/portal to Chang’s loadable files to Chang’s obvious installable applications so that Chang can provide links functions/applications at a portal/domain. One would have been motivated to do this in order to better make accessible the applications/portals and functions disclosed. Chang further discloses restricting the communication session to the first domain, the second domain, and a third domain associated with an server for the application/functions based at least in part on redirecting the communication session to the second domain (for domain note different connectivity segments and public and private segments at [16]; see portals and note there are multiple different portals at [53], hence there are different domains of public and private and also user portal and provider portal; also see direct via link to a domain/portal at [51]; Fig. 1) the first domain, the second domain, and a third domain associated with an server for the application based at least in part on redirecting the communication session to the second domain (see obvious statement preceding where the link redirects to particular portal/domain with particular functions associated with rewards, Fig. 1). Chang does not explicitly disclose restricting, by a firewall, or an application server, or wherein the firewall restricts provision of network address translation for traffic communicated by the personal electronic device to traffic between the personal electronic device and one or more of the first domain, the second domain, or the third domain. However, Spencer discloses applications [56] and applications servers [59, 167, 169] and that it is common that apps are installed [115] and providing specific functions or apps as awards to users [62] and restricted access to these VBAs (Value Based Applications) [65] including firewalls and restricted access to particular VBAs [65, 160, 167, 170]. Also, in regards to restricting network address translation, Examiner notes Applicant Spec at [36] and firewalls and only certain devices are allowed access. And, Spencer discloses firewalls and specific access for specific devices and access control lists [158, 167] and filtering or restricting traffic based on source or destination or access limit rules [158] and limiting protocols and firewall rules based on application needed inbound/outbound ports [169] and blocking access to disallowed domains/portals by manipulating transport protocols and DNS names and header info, etc [170] and combining these into user specific firewall rules [177]. This disclosed functionality of Spencer is interpreted to read on a firewall restricting network address translation for traffic communication. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s firewalls and limiting access via firewalls to applications as awards for particular users to Chang’s applications/functions and awards to users and limited access to particular portals/segments/domains. One would have been motivated to do this in order to better manage networks and applications/functions as awards to users on a network. In further regards to claim 13, Chang further discloses a communication interface, a brand interaction controller (Figs. 1, 2). Claim 2, 14. Chang does not explicitly disclose the method of claim 1, further comprising: comparing an amount of traffic communicated between the second domain and the personal electronic device to a size of the application. However, Examiner notes that Applicant Spec at [66] shows that application size has to do with packet size. And, Spencer discloses comparing an amount of traffic communicated between the second domain and the personal electronic device to a size of the application [57, 65, 158, 161]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s comparing traffic and application size to Chang’s airplane networks. One would have been motivated to do this in order to better operate a resource limited network. Claim 3, 15. Chang does not explicitly disclose the method of claim 2, further comprising: restricting the communication session to the first domain based at least in part on determining that the amount of traffic communicated between the second domain and the personal electronic device has exceeded the size of the application by a threshold. has to do with packet size. However, Spencer discloses restricting sessions based on traffic and size of the application [57, 65, 158, 161]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s comparing traffic and application size and restricting to Chang’s airplane networks. One would have been motivated to do this in order to better operate a resource limited network. Claim 4, 16. The prior art further discloses the method of claim 2 further comprising: initiating a timer upon redirecting the communication session to the second domain; and restricting the communication session to the first domain based at least in part on determining that the amount of traffic communicated between the second domain and the personal electronic device is less than the size of the application upon expiration of the timer (see above citations to claim 2, and further see Chang and limited period of time at [40]). Claim 5, 17. Chang does not explicitly disclose the method of claim 4, further comprising: determining a duration of the timer based at least in part on a network speed associated with the communication session and the size of the application. However, Chang discloses limited period of time [40]. And, Spencer discloses time limitation [64] and extended time [67]. And, Spencer discloses restricting sessions based on traffic and size of the application [57, 65, 158, 161]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s time limitations and comparing traffic and application size and restricting to Chang’s airplane networks and time limitations. One would have been motivated to do this in order to better operate a resource limited network. Claim 6, 18. Chang does not explicitly disclose the method of claim 2, further comprising: unrestricting the communication session based at least in part on determining that the amount of traffic communicated between the second domain and the personal electronic device has exceeded the size of the application. However, Spencer discloses restricting or modifying sessions based on traffic and size of the application [57, 65, 158, 161]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s comparing traffic and application size and restricting or modifying to Chang’s airplane networks. One would have been motivated to do this in order to better operate a resource limited network. Claim 7, 19. Chang does not explicitly disclose the method of claim 1, further comprising: comparing an amount of traffic communicated between the personal electronic device and the third domain to a threshold; and unrestricting the communication session based at least in part on determining that the amount of traffic communicated between the personal electronic device and the third domain has exceeded the threshold. However, Spencer discloses restricting or modifying sessions based on traffic and size of the application [57, 65, 158, 161]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s comparing traffic and application size and restricting or modifying to Chang’s airplane networks. One would have been motivated to do this in order to better operate a resource limited network. Claim 8, 20. Chang does not explicitly disclose the method of claim 1,further comprising: unrestricting the communication session based at least in part on receiving an indication that the application has been installed on the personal electronic device. However, Chang discloses rewarding users for actions ([12, 16, 40, 41, 42]) and also also loadable files at [20] and applications [46, 56, 57] and portals [53] for use with the system and also time limits [40]. And, the above obviousness statement in claim 1 renders obvious installing applications. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Chang’s rewarding actions with network use and Chang’s network use timers to Chang’s obvious installation of applications that Chang uses such that Chang can reward through less restriction for installation of needed applications. One would have been motivated to do this in order to better reward desired actions. Claims 9, 21. Chang further discloses the method of claim 1, wherein redirecting the communication session to the second domain comprises: sending a context for the application to the personal electronic device (see rewards and inflight connectivity [12, 16, 40] where the context is interpreted that the passenger gets the use of Internet in exchange for actions in the application/portal, see citations to application/portal above). Claim 10, 22. Chang does not explicitly disclose the method of 1, further comprising: unrestricting the communication session based at least in part on determining that the application has been previously installed on the personal electronic device. However, Chang discloses rewarding users for actions ([12, 16, 40, 41, 42]) and also also loadable files at [20] and applications [46, 56, 57] and portals [53] for use with the system and also time limits [40]. And, the above obviousness statement in claim 1 renders obvious installing applications. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Chang’s rewarding actions with network use and Chang’s network use timers to Chang’s obvious installation of applications that Chang uses such that Chang can reward through less restriction for previous installation of needed applications. One would have been motivated to do this in order to better reward desired actions. Claim 12, 24. Chang does not explicitly disclose the method of claim 1, wherein: restricting the communication session to the first domain, the second domain, and the third domain comprises providing an allow list associated with the personal electronic device to the firewall for the wireless communication link, and the allow list includes the first domain, the second domain, and the third domain. However, Chang discloses limited period of time [40]. And, Spencer discloses limited access to some services or full access [47, 52, 57] or restricted hotspot [47] and also restricted access to selected VBAs and firewall rules [65] and firewalls which block or filter or restrict specific sites and resources and domains [158]. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add Spencer’s network limitations and restricting to Chang’s airplane networks and time limitations. One would have been motivated to do this in order to better operate a resource limited network. Claims 11, 23 are rejected under 35 U.S.C. 103 as being unpatentable over Chang (20200334703) in view of Spencer (20200162890) in view of Admitted Prior Art (Official Notice). Claim 11, 23. Chang does not explicitly disclose the method of claim 1,wherein communication between the personal electronic device and the second domain is encrypted. However, Chang discloses the use of networks and domains, Fig. 1 and the Internet and wi-fi (see Internet connectivity citations for claim 1) and also purchasing [32]. And, Examiner takes Official Notice that encryption over the Internet or wireless networks is old and well known. Encryption has been used to secure communications over wireless networks well before Applicant’s priority date. Therefore, it would have been obvious to one having ordinary skill in the art at the time the invention was made to add well known encryption techniques to Chang’s airplane networks. One would have been motivated to do this in order to better secure the network for things like purchasing (see purchase at Chang [32]). Also, since the Applicant was given the opportunity, with the 3/4/26 submission, and has failed to traverse the Examiner's assertion of Official Notice, the common knowledge or well known in the art statement is taken to be admitted prior art (see MPEP 2144.03.C). Applicant did not challenge the use of Official Notice with the 3/4/26 submission. Conclusion The following prior art made of record and not relied upon is considered pertinent to applicant's disclosure: a) Examiner notes the PCT and the Global Dossier on this case; b) note related application 17947015 and the use of Wayne Chang and Berger, 18692666 and the use of WO prior art; c) Note similar or related cases to Murray and O’Sullivan; d) see Huggett 20070191035 [103], Mohan at [91], Billore [58], Balasubramanian[23], Sagong [54], Spencer [57, 161] with packet size and application traffic and restricting traffic; e) These discloses free Internet and/or airplanes: Outwater [0026] ; Rajago [0003]; Gagnon and Glenn disclose free internet on airplane for blockchain mining; Hermes free Internet for watching advertising. 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 ARTHUR DURAN whose telephone number is (571)272-6718. The examiner can normally be reached Mon-Thurs, 7-5pm. 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, Ilana Spar can be reached at (571) 270-7537. 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. /ARTHUR DURAN/Primary Examiner, Art Unit 3622 3/18/26
Read full office action

Prosecution Timeline

Mar 15, 2024
Application Filed
Nov 03, 2025
Non-Final Rejection — §101, §103
Mar 04, 2026
Response Filed
Mar 18, 2026
Final Rejection — §101, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
16%
Grant Probability
41%
With Interview (+25.7%)
6y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 427 resolved cases by this examiner. Grant probability derived from career allow rate.

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