Prosecution Insights
Last updated: October 27, 2026
Application No. 18/887,751

LARGE LANGUAGE MODEL OUTPUT ENTAILMENT

Final Rejection §101§103
Filed
Sep 17, 2024
Priority
Sep 18, 2023 — provisional 63/539,033
Examiner
PEREZ-ARROYO, RAQUEL
Art Unit
2169
Tech Center
2100 — Computer Architecture & Software
Assignee
Google LLC
OA Round
2 (Final)
59%
Grant Probability
Moderate
3-4
OA Rounds
1y 2m
Est. Remaining
89%
With Interview

Examiner Intelligence

Grants 59% of resolved cases
59%
Career Allowance Rate
183 granted / 311 resolved
+3.8% vs TC avg
Strong +30% interview lift
Without
With
+30.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
24 currently pending
Career history
342
Total Applications
across all art units

Statute-Specific Performance

§101
10.3%
-29.7% vs TC avg
§103
73.7%
+33.7% vs TC avg
§102
4.3%
-35.7% vs TC avg
§112
10.1%
-29.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 311 resolved cases

Office Action

§101 §103
DETAILED ACTION 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 . Response to Amendment This Office Action has been issued in response to Applicant’s Communication of amended application S/N 18/887,751 filed on July 7, 2026. Claims 1, 4 to 16, and 19 are currently pending with the application. 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, 4 to 7, 9, 13 to 16, and 19 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Claims 1, 16, and 19 recite extracting, classifying, and analyzing fragments, and generating predictions. The limitation of extracting fragments, which specifically recites “extracting a plurality of textual fragments from the generative model output”, 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 one or more processors”, nothing in the claim element precludes the steps from practically being performed in a human mind. For example, but for the “by one or more processors” language, “extracting”, in the context of this claim encompasses the user mentally, with the aid of pen and paper, reading information and separating the information into fragments. The limitation of classifying fragments, which specifically recites “classifying a subset of the textual fragments as being suitable for textual entailment analysis”, 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 the one or more processors”, nothing in the claim element precludes the steps from practically being performed in a human mind. For example, but for the “by the one or more processors” language, “classifying”, in the context of this claim encompasses the user mentally and with the aid of pen and paper, determining whether or not the previously identified fragments are suitable for entailment analysis, or express a verifiable assertion. The limitation of analyzing fragments, which specifically recites “individually performing textual entailment analysis on each textual fragment of the subset, wherein the textual entailment analysis includes, for each textual fragment of the subset: formulating a search query based on the textual fragment, retrieving at least one document that is responsive to the search query, and processing the textual fragment and the at least one document to generate a corroboration score indicative of whether the at least one document corroborates the textual fragment and a contradiction score indicative of whether the at least one document contradicts the textual fragment, evaluating the corroboration and contradiction scores together, and based on the evaluating, generating a prediction of whether the at least one document corroborates or contradicts the textual fragment”, 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 one or more processors”, nothing in the claim element precludes the steps from practically being performed in a human mind. For example, but for the “by one or more processors” language, “analyzing”, in the context of this claim encompasses the user mentally, with the aid of pen and paper, determining questions based on each fragment, reading information related to the question, and comparing the fragment with the information to generate corroboration and contradiction scores, evaluate the scores together, and determine a prediction of whether the fragment is true or false. If a claim limitation, under its broadest reasonable interpretation, covers mental processes but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, the claims recite an abstract idea. This judicial exception is not integrated into a practical application. In particular, the claims recite the additional elements – “receiving a query associated with a client device operated by the user”, “generating generative model output based on processing, using a generative model, data indicative of the query”, “using both a corroboration machine learning model and a contradiction machine learning model”, “causing natural language (NL) responsive to the query to be rendered at the client device”, “causing one or more visual annotations of one or more of the textual fragments of the subset to be rendered at the client device, wherein the one or more annotations express one or more of the predictions for one or more of the textual fragments of the subset”, one or more processors, and memory. The limitations “receiving a query associated with a client device operated by the user”, “causing natural language (NL) responsive to the query to be rendered at the client device”, and “causing one or more visual annotations of one or more of the textual fragments of the subset to be rendered at the client device, wherein the one or more annotations express one or more of the predictions for one or more of the textual fragments of the subset” amount to data-gathering steps which is considered to be insignificant extra-solution activity (See MPEP 2106.05(g)). Continuing with the analysis of the additional elements, the limitation “generating generative model output based on processing, using a generative model, data indicative of the query” is recited at a high-level of generality, with no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result, and is equivalent to merely saying “applying it”, therefore, does not integrate the judicial exception into a practical application nor amount to significantly more. The limitation “using both a corroboration machine learning model and a contradiction machine learning model”, the one or more processors and one or more storage devices in these steps are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component. 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. The claims are directed to an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The insignificant extra-solution activity identified above, which include the data gathering steps, is recognized by the courts as well-understood, routine, and conventional activity when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity (See MPEP 2106.05(d)(II)(i) Receiving or transmitting data over a network, e.g., using the Internet to gather data, 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)). The claims are not patent eligible. Claim 4 is dependent on claim 1 and includes all the limitations of claim 1. Therefore, claim 4 recites the same abstract idea of claim 1. The claim recites the additional limitations of “the annotations is rendered using one or more visual attributes that are selected based on the evaluating”, which amounts to data presentation steps, considered to be insignificant extra-solution activity, (See MPEP 2106.05(g)), and recognized by the courts as well-understood, routine, and conventional activities when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity (See MPEP 2106.05(d) (II)(v) Presenting offers and gathering statistics, OIP Techs., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93)). Therefore, the limitations do not amount to significantly more than the abstract idea. Same rationale applies to claims 13 and 14. Claim 5 is dependent on claim 1 and includes all the limitations of claim 1. Therefore, claim 5 recites the same abstract idea of claim 1. The claim recites the additional limitation of “each textual fragment of the subset is classified as suitable for textual entailment analysis using a classifier machine learning model that is trained to classify textual fragments as capable or incapable of textual entailment analysis”, which is recited at a high-level of generality, with no restriction on how the result is accomplished and no description of the mechanism for accomplishing the result, and is equivalent to merely saying “applying it”, therefore, does not integrate the judicial exception into a practical application nor amount to significantly more. Same rationale applies to claims 6, and 7. Claim 9 is dependent on claim 1 and includes all the limitations of claim 1. Therefore, claim 9 recites the same abstract idea of claim 1. The claim recites the additional limitation of “a given annotation of the annotations expressing one or more of the predictions is operable to retrieve at least a portion of the document that corroborates or contradicts the textual fragment underlying the given annotation”, which amounts to data gathering steps, which is considered to be insignificant extra-solution activity (See MPEP 2106.05(g)), and recognized by the courts as well-understood, routine, and conventional activities when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity (See MPEP 2106.05(d) (II)(i) Receiving or transmitting data over a network, e.g., using the Internet to gather data, 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)). The claim does not amount to significantly more than the abstract idea. Claim 15 is dependent on claim 1 and includes all the limitations of claim 1. Therefore, claim 15 recites the same abstract idea of claim 1. The claim recites the additional limitations of “the one or more predictions of whether the at least one document corroborates or contradicts the textual fragment are generated conditionally based on a responsive content quality metric determined for the at least one document”, which can be performed in the human mind with the aid of pen and paper, and therefore is further elaborating on the abstract idea. The claim does not amount to significantly more. Additionally, the claims do not include a requirement of anything other than conventional, generic computer technology for executing the abstract idea, and therefore, do not amount to significantly more than the abstract idea. Claims 1, 4 to 7, 9, 13 to 16, and 19 are therefore not drawn to eligible subject matter as they are directed to an abstract idea without significantly more. Allowable Subject Matter Claims 8, and 10 to 12 are 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. Response to Arguments The following is in response to arguments filed on July 7, 2026. Arguments have been fully and respectfully considered. Claim Rejections - 35 USC § 101 Applicant’s arguments have been respectfully and carefully considered. In response to Applicant’s arguments and in view of the claim amendments, it has been determined that the claims are directed to an abstract idea without significantly more. The newly incorporated language including the generation and evaluation of the corroboration and contradiction scores, and further generation of the prediction score based on the evaluation, can be performed in the human mind with the aid of pen and paper, and therefore is part of the abstract idea. Further, the elements “using both a corroboration machine learning model and a contradiction machine learning model” to generate the corroboration score and the contradiction score, which are part of the additional limitations, are recited at a high-level of generality (i.e., as a generic processor performing a generic computer function) such that it amounts no more than mere instructions to apply the exception using a generic computer component, and therefore, do not amount to significantly more than the abstract idea. The claims are directed to an abstract idea without significantly more, under the “Mental Processes” group of abstract ideas. 101 Rejections are hereby sustained. Claim Rejections - 35 USC § 103 Applicant’s arguments have been respectfully and carefully considered. In view of claim amendments and arguments, 103 Rejections are hereby withdrawn. Relevant Prior Art The prior art made of record and not relied upon is considered pertinent to Applicant’s disclosure. Maschmeyer et al., (U.S. Publication No. 2024/0256764) is directed to large language model generating descriptions of content with indications of any unsubstantiated information, where one or more portions of unsubstantiated information are annotated and displayed. However, Maschmeyer does not appear to expressly disclose both a corroboration and a contradiction machine learning models. Conclusion 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 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to RAQUEL PEREZ-ARROYO whose telephone number is (571)272-8969. The examiner can normally be reached Monday - Friday, 8:00am - 5:30pm, Alt Friday, EST. 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, Sherief Badawi can be reached at 571-272-9782. 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. /RAQUEL PEREZ-ARROYO/Primary Examiner, Art Unit 2169
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Prosecution Timeline

Sep 17, 2024
Application Filed
Apr 08, 2026
Non-Final Rejection mailed — §101, §103
Jun 19, 2026
Interview Requested
Jul 07, 2026
Response Filed
Jul 07, 2026
Examiner Interview Summary
Jul 07, 2026
Applicant Interview (Telephonic)
Sep 30, 2026
Final Rejection mailed — §101, §103 (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

3-4
Expected OA Rounds
59%
Grant Probability
89%
With Interview (+30.5%)
3y 4m (~1y 2m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 311 resolved cases by this examiner. Grant probability derived from career allowance rate.

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