DETAILED ACTION
The following is a non-final office action upon examination of application number 18/806078.
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 .
Continued Examination Under 37 CFR 1.114
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 7/27/2026 has been entered.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 4/9/2026 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
Response to Amendment
Claims 1-5, 8-13, 15, and 17-24 are pending in the application and have been examined on the merits discussed below.
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 1-5, 8-13, 15, 17, and 19-24 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
(Step 1) Claims 1-5, 8-12, and 22, are directed to a non-transitory computer-readable medium, which is a manufacture, and this a statutory category of invention. Claims 13, 15, 17, 21, and 23, are directed to a method; thus these claims are directed to a process, which is one of the statutory categories of invention. Claims 19-20 and 24 are directed to a system comprising one or more processors; thus the system comprises a device or set of devices, and therefore, is directed to a machine which is a statutory category of invention.
(Step 2A) The claims recite an abstract idea instructing how to generate meeting proposals based on user input and generating a calendar entry, which is described by claim limitations reciting:
identify based upon one or more communication messages provided …, an indication of a meeting between a first user … and second user …, wherein the one or more communication messages are generated …;
in response to identifying the indication of the meeting from the one or more communication messages, determine, whether at least one meeting parameter is missing from the one or more communication messages, wherein the at least one missing meeting parameter comprises a proposed meeting time;
in response to determining that the at least one meeting parameter is missing from the one or more communication messages, …a recommendation to generate an … meeting proposal for the meeting;
receive, … input providing a response to the recommendation, the response to the recommendation indicating to generate the … meeting proposal; and
in response to receiving the … input;
identify, based at least in part on the one or more communication messages, a range of time that the meeting will likely occur within;
query a first … calendar … for a first plurality of existing calendar entries based on the range of time that the meeting will likely occur within;
a calendar view depicting the first plurality of existing calendar entries and a timeslot proposal affordance enabling selection of a plurality of timeslots to propose for the meeting, wherein the plurality of timeslots are to be selected by the second user…;
generate a meeting proposal … comprising an indication of the plurality of timeslots; and
provide the meeting proposal … for selection of one of the plurality of timeslots …;
in response to determining that the meeting parameter is not missing from the one or more communication messages:
…a recommendation to generate an … calendar entry for the meeting;
receive a second … input providing a response to the recommendation to generate the … calendar entry for the meeting, indicating to generate the … calendar entry; and
in response to receiving the second … input, generate the … calendar entry in the … first calendar … and a second calendar, wherein the calendar entry comprises meeting parameters extracted from the one or more communication messages.
The identified limitations in the claims describing generating meeting proposals based on user input and generating a calendar entry (i.e., the abstract idea) fall within the “Certain Methods of Organizing Human Activity” grouping of abstract ideas, which covers managing interactions between people. Dependent claims 3, and 11, recite limitations that further describe/narrow generating meeting proposals based on user input and generating a calendar entry (i.e., the abstract idea); therefore, these claims are also found to recite an abstract idea.
This judicial exception is not integrated into a practical application because additional elements such as the tangible, non-transitory, computer-readable medium, comprising computer-readable instructions; first electronic device; second electronic device; and communications application in claim 1; the processor; first electronic device; second electronic device; and communications application in claim 13; and the memory; one or more processors configured to: host a communications application; first electronic device; and second electronic device in claim 19, do not add a meaningful limitation to the abstract idea since these elements are only broadly applied to the abstract ideas at a high level of generality; thus, none of recited hardware offers a meaningful limitation beyond generally linking the abstract idea to a particular technological environment, in this case, implementation via a computer/processor.
Additional elements related to an electronic calendar meeting proposal; electronic calendar entry; first local electronic calendar application; query a first local electronic calendar application of the first electronic device…; meeting proposal data object; and second local electronic calendar application of the second electronic device… do not provide an improvement; these additional elements are recited at a high level of generality and only generally link the abstract idea to a technological environment. Additional elements such as …communication messages provided between a first electronic device and a second electronic device, within the communications application…; …messages are generated via a first communications application graphical user interface (GUI) of the first electronic device, a second communications application GUI of the second electronic device, or both...; render, in the first communications application GUI…; receive, via the first communications application GUI, a GUI input…; … render, in the first communications application GUI, a meeting proposal generator GUI element …; render in the first communications application GUI…; … receive a second GUI input…; and provide the meeting proposal data object to the second electronic device for selection of one of the plurality of options via the second communications application GUI of the second electronic device do not yield an improvement in the functioning of the computer itself, nor do they yield improvements to a technical field or technology; further, these additional elements only add insignificant extra-solution activities (data gathering/display). Similarly, additional elements in claims 2, 4, 5, 8, 9, 10, 12, 15, 17, 20, 22, 23, and 24 related to rendering…, transmitting…, and generating…GUI… do not provide and improvement and only add insignificant extra-solution activities. Additional elements in claim 21 related to using a natural language processing (NLP) model do not provide an improvement to the computer or technology; these additional elements are recited at a high level of generality and only generally link the abstract idea to a technological environment. Accordingly, these additional elements do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea.
(Step 2B) The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because as discussed above with respect to integration of the abstract idea into a practical application, the hardware additional elements amount to no more than mere instructions to apply the exception using a generic computer component (see Spec. [0023]). Mere instructions to apply an exception using a generic computer component cannot provide an inventive concept. Additional elements related to an electronic calendar meeting proposal; electronic calendar entry; first local electronic calendar application; query a first local electronic calendar application of the first electronic device…; meeting proposal data object; and second local electronic calendar application of the second electronic device… do not provide an improvement; these additional elements are recited at a high level of generality and only generally link the abstract idea to a technological environment. Additional elements such as …communication messages provided between a first electronic device and a second electronic device, within the communications application…; …messages are generated via a first communications application graphical user interface (GUI) of the first electronic device, a second communications application GUI of the second electronic device, or both...; render, in the first communications application GUI…; receive, via the first communications application GUI, a GUI input…; … render, in the first communications application GUI, a meeting proposal generator GUI element…; render in the first communications application GUI…; … receive a second GUI input…; and provide the meeting proposal data object to the second electronic device for selection of one of the plurality of options via the second communications application GUI of the second electronic device do not yield an improvement in the functioning of the computer itself, nor do they yield improvements to a technical field or technology; further, these additional elements only add insignificant extra-solution activities (data gathering/display). Additional elements in claims 2, 4, 5, 8, 9, 10, 12, 15, 17, 20, 22, 23, and 24, related to rendering…, transmitting…, and generating…GUI… do not provide and improvement and only add insignificant extra-solution activities. With respect to data gathering limitations, the courts have recognized the use of computers to receive and transmit data as a well-understood, routine, and conventional, OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network). With respect to data display limitations, the courts have found the presentation of data to be a well-understood, routine, conventional activity, OIP Techs., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93 (see MPEP 2106.05(d)). Additional elements in claim 21 related to using a natural language processing (NLP) model do not provide an improvement to the computer or technology; these additional elements are recited at a high level of generality and only generally link the abstract idea to a technological environment. In addition, when taken as an ordered combination, the ordered combination adds nothing that is not already present as when the elements are taken individually. There is no indication that the combination of elements improves the functioning of a computer or improves any other technology.
Response to Arguments
Applicant's arguments filed 7/27/2026 have been fully considered but they are not persuasive.
With respect to the rejection under 35 USC 101, Applicant argues that the claims are integrated into a practical application.
Examiner respectfully disagrees. Problems related to identifying a time and location for an event involving multiple parties exist outside of the realm of technology. The use of a general purpose computer to speed up the gathering of calendar information from multiple parties and identification of a time/location for an event does not amount to an improvement to the technology or the performance of the computer. In FairWarning, the court found that accelerating a process did not show an improvement when the increased speed comes solely from the capabilities of a general-purpose computer, FairWarning IP, LLC v. Iatric Sys., 839 F.3d 1089, 1095, 120 USPQ2d 1293, 1296 (Fed. Cir. 2016).
Additionally, the use of data from messages to aid in the selection of a time/location for an event do not improve the technology. An improvement in the abstract idea itself (e.g. a recited fundamental economic concept) is not an improvement in technology. For example, in Trading Technologies Int’l v. IBG, 921 F.3d 1084, 1093-94, 2019 USPQ2d 138290 (Fed. Cir. 2019), the court determined that the claimed user interface simply provided a trader with more information to facilitate market trades, which improved the business process of market trading but did not improve computers or technology.
Allowable Subject Matter
Claim 18 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALAN TORRICO-LOPEZ whose telephone number is (571)272-3247. The examiner can normally be reached M-F 10AM-5PM.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Beth Boswell can be reached at (571)272-6737. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ALAN TORRICO-LOPEZ/Primary Examiner, Art Unit 3625
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