Prosecution Insights
Last updated: July 17, 2026
Application No. 18/826,501

METHOD AND APPARATUS FOR PROVIDING CONTENT

Final Rejection §101§102
Filed
Sep 06, 2024
Priority
Mar 18, 2014 — RE 10-2014-0031823 +4 more
Examiner
AUGUSTINE, NICHOLAS
Art Unit
2178
Tech Center
2100 — Computer Architecture & Software
Assignee
Samsung Electronics Co., Ltd.
OA Round
2 (Final)
73%
Grant Probability
Favorable
3-4
OA Rounds
1y 9m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
601 granted / 823 resolved
+18.0% vs TC avg
Strong +28% interview lift
Without
With
+27.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
29 currently pending
Career history
869
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
45.6%
+5.6% vs TC avg
§102
53.1%
+13.1% vs TC avg
§112
0.2%
-39.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 823 resolved cases

Office Action

§101 §102
DETAILED ACTION A. This action is in response to the following communications: Amendment filed: 01/20/2026 This action is made Final. B. Claims 1-2,4-12 and 14-20 remain pending. 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 1-2,4-12 and 14-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to certain methods of organizing human activity without significantly more. The claim(s) 1, 11 and 20 recite(s) “obtaining messages, extracting elements, generate content, transmit generated content”, grouping of abstract ideas. The mere nominal recitation of a generic computing devices and generic network-based storage devices does not take the claim out of the “certain methods of organizing human activity” grouping. Thus, the claim recites an abstract idea. This judicial exception is not integrated into a practical application because the claim as a whole merely describes how to generally “apply” the concept of obtaining first message, extracting key elements, generating content related to extracted data in a computer environment. The claimed “network based non-transitory storage devices” and “terminal” are recited at a high level of generality and are merely invoked as tools perform an obtaining data, extracting data and generating data. Even considered in combination, simply implementing the abstract idea on a generic computer with storage devices recited at a high level of generality is not a practical application of the abstract idea.The limitation generating content related to first message and second message on a generic user interface executed by a generic computer, as drafted, is a process that, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components. That is, other than reciting “by a terminal,” nothing in the claim element precludes the step from practically being performed in the mind. For example, but for the “by a terminal” language, “generating content” in the context of this claim encompasses the user manually organizing data from looking at first to the nth messages. The claim does not include additional elements that are sufficient to amount to the significantly more than the judicial exception because as noted previously, the terminal and the storage devices individually and in combination merely describe how to generally “apply” the concept of obtaining, extracting, generating, transmitting and displaying in a computer environment. The same applies here. (MPEP 2106.05(d). Thus, even when viewed as a whole, nothing in the claims adds significantly more (i.e. an inventive concept) to the abstract idea. The claim is ineligible. Claims 2,4-10,12 and 14-19 do not include elements that amount to significantly more than the abstract idea and are also rejected under the same rational. Claim Rejections - 35 USC § 102 4. 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 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. 5. 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)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale or otherwise available to the public before the effective filing date of the claimed invention. 6. Claim(s) 1-2,4-12 and 14-20 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Yuezhong, Tang et al. (US Pub. 2010/0100371 A1), herein referred to as “Yuezhong”. As for claims 1, 11 and 20, Yuezhong teaches . A method and corresponding terminal of claim 11 for and non-transitory computer-readable recording medium of claim 20 having stored thereon a program that is executed by computer to perform a method of transmitting content through a terminal of transmitting content in a terminal, the method comprising: a memory storing at least one program; and at least one controller configured to execute the at least one program to (par. 49 describes various hardware environment to carryout software execution): Receiving an input through a user interface of the terminal (par. 24 The keywords 104 are passed from the user interface 114 to a data collector 116, which uses the keywords 104 to gather additional relevant data. ); obtaining a first message based on the input received through the user interface of the terminal, wherein the user interface is provided by a messaging application that executes a messaging service in the terminal (Par. 28 user executes a messaging application on device “ John may only need to input some keywords 206, 208 (e.g., “6:30,” “QuanJuDe”) into message input screen 209. “); extracting key elements from the first message and a second message stored in the terminal (par. 28 program running on device extracts key words from user; the data collector 116 has determined that the keyword 206 is an event time, and this is annotated using tags in an output data 210. Further, the context component 130 determines the edit time is 10:00 AM, the time is automatically adjusted to 6:30 PM (e.g., as opposed to 6:30 AM) as seen in the output data 210); generating content related to the first message and the second message based on the extracted key elements (generating content related to the first message and the second message based on the extracted key elements as shown in paragraph 23 and 24 The keywords 104 are passed from the user interface 114 to a data collector 116, which uses the keywords 104 to gather additional relevant data. Thus the keywords are transmitted to a remotely stored data. Par. 29 keyword data is searched to determine contextual information; par. 30 mapping services are deployed to generate location information based upon extracted text; par. 31 message generator forms reply with extract data in the message); transmitting the generated content to a first terminal that is different from the terminal, via the terminal (par. 31 message generator transfers via an MMS client). Displaying, on a display of the terminal a result content indicating completion of the transmission of the generated content to the first terminal (fig. 2, par. 31 message is displayed in a first and second users device via a user interface the content generated is displayed on the user interface as a final form of remote transmission from remote stored data based upon transmission of keywords to remote data store to determine final message generated and displayed to recipient; Previously sent SMS (or other messages) may also be searched to find similar phrases, sentences, templates, etc., associated with the keywords. In this way, the message generator 138 could form a message 222 having complete sentences as follows: “We will gather at the QuanJuDe restaurant at 6:30 pm. The restaurant is in QianMen. To get there you could take the Line 2 subway. The restaurant contact number is 826939911”. Moreover, the message generator even could transfer it via an MMS client (e.g., client 146 shown in FIG. 10) with the pictures of QuanJuDe map and the toast duck). As for claims 2 and 12, Yuezhong teaches. The method of claim 1, further comprising obtaining the second message from the first terminal, via the messaging application (par. 31 The search may be done locally, or via the Internet, e.g., using a specific Web Service which is tailored to natural language generation services. Previously sent SMS (or other messages) may also be searched to find similar phrases, sentences, templates, etc., associated with the keywords). As for claims 4 and 14, Yuezhong teaches. The method of claim 1, wherein the displaying the result content comprises: displaying the result content on at least one region of the display unit of the terminal or outputting the result content by a sound outputter of the terminal (fig. 3 show graphical user interface that renders message that is going to be sent to second user as generated by software through local and remote information lookup). As for claims 5 and 15, Yuezhong teaches. The method of claim 1, further comprising: receiving an input that includes a command to transmit the generated content to the first terminal; and transmitting the generated content to the first terminal, based on the received the input (fig. 7, 710 the created message is sent to the message recipient; par. 59). As for claims 6 and 16, Yuezhong teaches. The method of claim 1, wherein the first message and the second message are obtained from the present conversation window by a plurality of users using the messaging application, wherein the extracted key elements comprise information about the plurality of users using the messaging application and another user, and wherein the generated content comprises an invitation that invites the another user to the present conversation window (par. 31 conversation GUI is between plurality of users utilizing messaging application on the user devices respectively and extracted data comprises information from previous conversation stored locally; The search may be done locally, or via the Internet, e.g., using a specific Web Service which is tailored to natural language generation services. Previously sent SMS (or other messages) may also be searched to find similar phrases, sentences, templates, etc., associated with the keywords). As for claims 7 and 17, Yuezhong teaches. The method of claim 6, further comprising: displaying the invitation on the display of the terminal; receiving an input that selects the invitation displayed on the display of the terminal; and transmitting the invitation to the first terminal, based on the received the input (par. 33 example of invitation through calendar entries; par. 34 The generator 138 may select the following example sentences based on the inputs 316, 320: “We will go to Flander to meet Juha at 2:30 in Flander's Bogota meeting room. We discuss our future cooperation. Flander is located on Main Street, No. 75. The phone number is 13232342342341”. This is used to form completed message 322, that may be sent via SMS). As for claim 8, Yuezhong teaches. The method of claim 7, further comprising: displaying the result content indicating the invitation of the another user to the present conversation window, after the transmitting the invitation to the first terminal (par. 34 The contents of this message 322 could also be transferred to Holly 304 via MMS and/or email, and include the map to Flander (e.g., via the help of map service 216 in FIG. 2). As for claims 9 and 18, Yuezhong teaches. The method of claim 1, wherein the first message and the second message are obtained from a present conversation window by a plurality of users using the messaging application, wherein the extracted key elements comprise information about the plurality of users using the messaging application and another user, and wherein the generated content comprises an invitation that invites the plurality of users and the another user to a new conversation window that is different from the present conversation window (par. 32-34 other users are identified and included to be sent a message via MMS and/or email to have a calendar entry created to invite to a meeting at a location as generated through extracted text from a conversation between users, such that users Flander, Yuha, Juha and Holly are added to this meeting through contextual extraction of data). As for claims 10 and 19, Yuezhong teaches. The method of claim 9, further comprising: displaying the invitation on the display of the terminal; receiving an input that selects the invitation displayed on the display of the terminal; and transmitting the invitation to the first terminal, based on the received the input (par. 34 sending of the system generated messages to other users via MMS and or email). (Note :) It is noted that any citation to specific, pages, columns, lines, or figures in the prior art references and any interpretation of the references should not be considered to be limiting in any way. A reference is relevant for all it contains and may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art. In re Heck, 699 F.2d 1331, 1332-33, 216 USPQ 1038, 1039 (Fed. Cir. 1983) (quoting In re Lemelson, 397 F.2d 1006,1009, 158 USPQ 275, 277 (CCPA 1968)). Response to Arguments Applicant's arguments filed 01/20/2026 have been fully considered but they are not persuasive. A1. Applicant argues that amendments overcome the 35 USC 101. R1. Examiner does not agree, as the mere addition to adding a displaying step done on a display of a terminal does not add significantly more than an abstract idea and the use of a terminal and display are basic computer functions. Note example 22 Dietgoal Innovations which was found that “The analyzed claim is to a user interface, a database, and a "meal builder" which caused meals to be displayed on the user interface. Meal planning is a mental process of managing behavior, and as such is abstract (compared to SmartGene and Cybersource). As database and interface provide only basic computer functions, the claim does not amount to significantly more than the abstract idea.” Mental Processes & Organizing Activity: Claims that involve gathering, displaying, or manipulating information that could be performed in the human mind, or by a human using pen and paper, are considered abstract. "Generic Display" Defined: Using a computer as a tool to merely display data, or using standard UI elements (windows, menus) without a specific technical improvement in how that information is displayed, is generally considered abstract. A2. Applicant argues that Yuezhong does not teach generating content related to the first message and the second message based on the extracted key elements; transmitting the generated content to a first terminal that is different from the terminal; and displaying, on a display of the terminal, a result content indicating completion of the transmission of the generated content to the first terminal. R2. Examiner does not agree, Yuezhong teaches generating content related to the first message and the second message based on the extracted key elements as shown in paragraph 23 and 24 The keywords 104 are passed from the user interface 114 to a data collector 116, which uses the keywords 104 to gather additional relevant data. Thus the keywords are transmitted to a remotely stored data. In paragraph 29 keyword data is searched to determine contextual information. Paragraph 30 mapping services are deployed to generate location information based upon extracted text. And paragraph 31 message generator forms reply with extract data in the message. Yuezhong teaches transmitting the generated content to a first terminal that is different from the terminal, via the terminal in paragraph 31 that the message generator transfers via an MMS client). Yuezhong further discusses that this message is displayed in a first and second users device via a user interface the content generated is displayed on the user interface as a final form of remote transmission from remote stored data based upon transmission of keywords to remote data store to determine final message generated and displayed to recipient. Examiner recommends an amendment that details the interface differently and narrows how completion is indicated because the prior art display of a completed message sent to a recipient is sufficient to arrive at the claimed limitation. Conclusion THIS ACTION IS MADE FINAL. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action. Inquires Any inquiry concerning this communication should be directed to NICHOLAS AUGUSTINE at telephone number (571)270-1056. 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. PNG media_image1.png 213 559 media_image1.png Greyscale /NICHOLAS AUGUSTINE/Primary Examiner, Art Unit 2178 May 12, 2026
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Prosecution Timeline

Sep 06, 2024
Application Filed
Oct 20, 2025
Non-Final Rejection mailed — §101, §102
Dec 15, 2025
Examiner Interview Summary
Dec 15, 2025
Applicant Interview (Telephonic)
Jan 20, 2026
Response Filed
May 14, 2026
Final Rejection mailed — §101, §102 (current)

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Prosecution Projections

3-4
Expected OA Rounds
73%
Grant Probability
99%
With Interview (+27.6%)
3y 8m (~1y 9m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 823 resolved cases by this examiner. Grant probability derived from career allowance rate.

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