Prosecution Insights
Last updated: April 19, 2026
Application No. 18/785,740

VIRTUALIZING DISCRETE AND MIGRATABLE TRUSTED PLATFORM MODULES (TPMS)

Non-Final OA §102§112
Filed
Jul 26, 2024
Examiner
DAVIS, ZACHARY A
Art Unit
2492
Tech Center
2400 — Computer Networks
Assignee
Microsoft Technology Licensing, LLC
OA Round
1 (Non-Final)
54%
Grant Probability
Moderate
1-2
OA Rounds
4y 6m
To Grant
77%
With Interview

Examiner Intelligence

Grants 54% of resolved cases
54%
Career Allow Rate
269 granted / 499 resolved
-4.1% vs TC avg
Strong +23% interview lift
Without
With
+22.9%
Interview Lift
resolved cases with interview
Typical timeline
4y 6m
Avg Prosecution
58 currently pending
Career history
557
Total Applications
across all art units

Statute-Specific Performance

§101
15.0%
-25.0% vs TC avg
§103
26.5%
-13.5% vs TC avg
§102
15.9%
-24.1% vs TC avg
§112
39.0%
-1.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 499 resolved cases

Office Action

§102 §112
DETAILED ACTION Election/Restrictions Applicant’s election without traverse of Invention I in the reply filed on 25 November 2025 is acknowledged. Claims 9-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 25 November 2025. Claim Objections Claims 1 and 8 are objected to because of the following informalities: In Claim 1, lines 10 and 11, it appears these steps should also be indented. In Claim 8, line 4, it appears that this step should also be indented. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 2-7 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 2 recites limitations on the first and second cryptographic processor emulators; however, these are not clearly elements of the claimed system, and therefore, it is not clear how these are intended to provide a further limit on Claim 1. Claim 3 recites “the first buffer and the second buffer stores” in lines 5-6. The verb “stores” does not agree with the plural subject. The claim further recites “or encrypted response bytes…” in line 9. It is not grammatically clear what this phrase is intended to modify or be coordinated with. Claim 5 recites “a key” in line 6. It is not clear whether this is intended to refer to the first endorsement key or a distinct key. The claim further recites “the key used to encrypt the sealed secrets” in lines 7-8. There is not clear antecedent basis for this limitation in the claims. Claims not explicitly referred to above are rejected due to their dependence on a rejected base claim. Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1-8 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Farley et al, US Patent Application Publication 2025/0077256. In reference to Claim 1, Farley discloses a system that includes an orchestrator (see paragraph 0022, SCPM orchestrator 140) configured to perform operations that include receiving a request to migrate secret data from a first cryptographic processor emulator on a first platform root of trust to a second cryptographic processor emulator on a second platform root of trust (paragraph 0020, see also paragraph 0106 item xx, transferring keys); requesting first secret data stored in a first memory of the first emulator and receiving the first secret data (see paragraph 0106, item xx); instantiating the second emulator based on the first secret data and transferring the secret data to a second memory of the second emulator (see paragraph 0126, new system added; paragraph 0106, transferring data); instructing the first emulator to delete the first secret data (see paragraphs 0109 and 0112, deletion of expired keys); and sending a status (paragraphs 0112, 0144). In reference to Claim 2, Farley further discloses that the emulators communicate with bare metal nodes (paragraphs 0062, 0106, and 0129, bare metal nodes/resources; paragraphs 0151-0152 and Figures 2.1-2.2, vTPMs communicating, system buses, memory 204 which provides a buffer; see also paragraph 0058). In reference to Claims 3 and 4, Farley further discloses TPM emulators that store bytes corresponding to commands and responses (paragraph 0164, commands), where commands include encrypting or decrypting or extending a PCR (paragraph 0111, encryption and decryption). In reference to Claims 5 and 6, Farley further discloses endorsement seeds and sealed secrets for generating endorsement keys (see paragraph 0109, generating keys). In reference to Claim 7, Farley further discloses a motherboard or node management controllers (paragraph 0120-0121 and 0106, BMC; paragraph 0016, motherboard). In reference to Claim 8, Farley further discloses serializing data and establishing the second root of trust on a second node based on the serialized data (see paragraph 0092). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Berger et al, US Patent 7444670, discloses a method for migrating a virtual TPM instance. Movva et al, US Patent 8015408, discloses a method that includes TPM state migration. Ellison, US Patent 8208637, discloses technique for migrating computer secrets using a virtual TPM. Smith et al, US Patent 8259948, discloses key migrations between virtual TPMs. Spiers et al, US Patent 8799997, discloses a system using migration keys for TPM transport, which uses a cloud orchestrator. Ferguson et al, US Patent 9578017, discloses a system that orchestrates operations including key transfer in virtual TPMs. Aigner et al, US Patent 12158980, discloses a system that uses transfer keys for virtual TPMs. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Zachary A Davis whose telephone number is (571)272-3870. The examiner can normally be reached Monday-Friday, 9:00am-5:30pm, Eastern Time. Examiner interviews are available via telephone 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, Rupal D Dharia can be reached at (571) 272-3880. 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. /Zachary A. Davis/Primary Examiner, Art Unit 2492
Read full office action

Prosecution Timeline

Jul 26, 2024
Application Filed
Jan 10, 2026
Non-Final Rejection — §102, §112 (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

1-2
Expected OA Rounds
54%
Grant Probability
77%
With Interview (+22.9%)
4y 6m
Median Time to Grant
Low
PTA Risk
Based on 499 resolved cases by this examiner. Grant probability derived from career allow rate.

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