Prosecution Insights
Last updated: April 19, 2026
Application No. 18/982,617

SYSTEM AND METHOD FOR EVENT DRIVEN GENERATION OF CONTENT

Final Rejection §101§103
Filed
Dec 16, 2024
Examiner
ALLEN, NICHOLAS E
Art Unit
2154
Tech Center
2100 — Computer Architecture & Software
Assignee
Open Text Holdings Inc.
OA Round
2 (Final)
77%
Grant Probability
Favorable
3-4
OA Rounds
3y 3m
To Grant
93%
With Interview

Examiner Intelligence

Grants 77% — above average
77%
Career Allow Rate
585 granted / 760 resolved
+22.0% vs TC avg
Strong +16% interview lift
Without
With
+16.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
68 currently pending
Career history
828
Total Applications
across all art units

Statute-Specific Performance

§101
22.7%
-17.3% vs TC avg
§103
50.6%
+10.6% vs TC avg
§102
16.1%
-23.9% vs TC avg
§112
4.7%
-35.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 760 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 . In response to Applicant’s claims filed on December 16, 2025, claims 1-21 are now pending for examination in the application. Terminal Disclaimer The terminal disclaimer filed on December 16, 2025 disclaiming the terminal portion of any patent granted on this application which would extend beyond the expiration date of U.S. Patent No. 11,537,670 is acknowledged. The terminal disclaimer has been recorded. Response to Arguments The 112 rejection set forth in the 09/17/2025 office action is hereby withdrawn. This office action is in response to amendment filed 12/26/2025. In this action claim(s) 1-21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hance et al. (US Pub. No. 20200117705) in view of Sharifi et al. (US Pub. No. 20160027044). The Sharifi et al. reference has been added to address the amendment wherein the electronic snapshot includes the first set of documents determined to be associated with the received event. Response to Arguments Applicant’s arguments: In regards to claim 1 on Pages 15, applicant argues “Applicant points out that Claim 1 has been amended to clarify that an electronic event is received by the processor, that data is extracted by a processor from the electronic event and the set of documents, and that an electronic snapshot is formed that includes the documents determined to be associated with the received event. Applicant submits that these limitations, as understood by a person of ordinary skill in the art upon reading the instant disclosure, are not actions that can be performed by the human mind. Accordingly, the claim is believed to be patent eligible.” Examiner’s Reply: Receiving event data is an additional elements that is nothing more than insignificant extra solution activity that amounts to data gathering. If a claim limitation, under its broadest reasonable interpretation, covers a commercial interaction or mental process eg managing content (a computer being used as a generic tool)), then it falls within the “Mental process” grouping of abstract ideas set forth in the 2019 PEG. Evaluating, determining, and generating are steps performed in the human mind. Accordingly, the claim recites an abstract idea. 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 1-21 are rejected under 35 U.S.C. 101 because the claimed invention is directed to non-patentable subject matter. The claims are directed to an abstract idea without significantly more. Claim 1-21 is rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. The judicial exception is not integrated into a practical application. The claims do not include additional elements that are sufficient to amount to significantly more than judicial exception. The eligibility analysis in support of these findings is provided below, on Claim Rejections - 35 USC 101 accordance with the "2019 Revised Patent Subject Matter Eligibility Guidance" (published on 1/7/2019 in Fed, Register, Vol. 84, No. 4 at pgs. 50-57, hereinafter referred to as the "2019 PEG"). Step 1. in accordance with Step 1 of the eligibility inquiry (as explained in MPEP 2106), it is first noted the claim system (claims 1-7), method (claims 8-14), and medium (claims 15-21) is/are directed to one of the eligible categories of subject matter and therefore satisfies Step 1. Step 2A. In accordance with Step 2A, prong one of the 2019 PEG, it is noted that the independent claims recite an abstract idea falling within the Mental Processes enumerated groupings of abstract ideas set forth in the 2019 PEG. Examiner is of the position that independent claims 1, 8, and 15 are directed towards the Mental Process Grouping of Abstract Ideas. Independent claims 1, 8, and 15 recites the following limitations directed towards a Mental Processes: Evaluating, by the processor, a virtual document based on the received event to form an electronic snapshot associated with the virtual document by determining a first set of documents associated with the received event based on metadata extracted from the first set of documents, or data extracted from the event (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by evaluating a document), and wherein the electronic snapshot includes the first set of documents determined to be associated with the received event (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by using computer as a tool to form a snapshot). Step 2A. In accordance with Step 2A, prong two of the 2019 PEG, the judicial exception is not integrated into a practical application because of the recitation in claim(s) 1 and 11: a processor (i.e., as a generic processor/component performing a generic computer function); and a non-transitory computer readable medium (i.e., as a generic processor/component performing a generic computer function), storing instructions for: receiving an event (recites insignificant extra solution activity of mere data gathering). Step 2B. Similar to the analysis under 2A Prong Two, the claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception. Because the additional elements of the independent claims amount to insignificant extra solution activity and/or mere instructions, the additional elements do not add significantly more to the judicial exception such that the independent claims as a whole would be patent eligible. Therefore, independent claims 1, 8, and 15 are rejected under 35 U.S.C. 101. With respect to claim(s) 2, 9, and 16: Step 2A, prong one of the 2019 PEG: wherein the first set of documents include a version of each of the set of documents, the version of each document determined based on the event (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by evaluating a document). Step 2A Prong Two Analysis: This judicial exception is not integrated into a practical application because the claim as drafted recites insignificant extrasolution activity. Step 2B Analysis: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claim is not patent eligible. With respect to claim(s) 3, 10, and 17: Step 2A, prong one of the 2019 PEG: wherein the event is associated with an event identifier and the version of each document is associated with the event identifier (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by evaluating a document). Step 2A Prong Two Analysis: This judicial exception is not integrated into a practical application because the claim as drafted recites insignificant extrasolution activity. Step 2B Analysis: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claim is not patent eligible. With respect to claim(s) 4, 11, and 18: Step 2A, prong one of the 2019 PEG: wherein the virtual document is defined by a schema defining each of a second set of documents comprising the virtual document (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by evaluating a document). Step 2A Prong Two Analysis: This judicial exception is not integrated into a practical application because the claim as drafted recites insignificant extrasolution activity. Step 2B Analysis: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claim is not patent eligible. With respect to claim(s) 5, 12, and 19: Step 2A, prong one of the 2019 PEG: wherein the first set of documents of the snapshot is a subset of the second set of documents (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by evaluating a document). Step 2A Prong Two Analysis: This judicial exception is not integrated into a practical application because the claim as drafted recites insignificant extrasolution activity. Step 2B Analysis: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claim is not patent eligible. With respect to claim(s) 6, 13, and 20: Step 2A, prong one of the 2019 PEG: wherein evaluating a virtual document based on the event comprises determining that the snapshot should be formed based on the event (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by determining a snapshot formation). Step 2A Prong Two Analysis: This judicial exception is not integrated into a practical application because the claim as drafted recites insignificant extrasolution activity. Step 2B Analysis: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claim is not patent eligible. With respect to claim(s) 7, 14, and 21: Step 2A, prong one of the 2019 PEG: wherein determining the snapshot should be formed based on the event comprises determining an event rule associated with the event, and wherein determining the first set of documents associated with the event comprises applying the event rule to the virtual document (The limitation recites a mental process of observation and/or evaluation capable of being performed by the human mind by determining a snapshot formation). Step 2A Prong Two Analysis: This judicial exception is not integrated into a practical application because the claim as drafted recites insignificant extrasolution activity. Step 2B Analysis: The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. The claim is not patent eligible. 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. Claim(s) 1-21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hance et al. (US Pub. No. 20200117705) in view of Sharifi et al. (US Pub. No. 20160027044). With respect to claim 1, Hance et al. teaches a system, comprising: a processor (See Fig. 15A); and a non-transitory computer readable medium (See Fig. 15A), storing instructions for: receiving, by the processor, an electronic event (Paragraph 73 discloses content management system 110 can track, create, and store events involving content items and/or user activity); evaluating, by the processor, a virtual document based on the received event to form an electronic snapshot associated with the virtual document by determining a first set of documents associated with the received event based on metadata extracted from the first set of documents, or data extracted from the received event (Paragraph 127 discloses content management service 116 may cross reference each revision with metadata associated therewith to determine an user associated with each revision). Hance does not disclose forming the snapshot to include the first set of documents. However, Sharifi et al. teaches wherein the electronic snapshot includes the first set of documents determined to be associated with the received event (Paragraph 22 discloses For each snapshot, for example, the snapshot evaluation engine 121 can identify entities and/or events included in the snapshot and store the identified entities/events along with a timestamp associated with a time that a respective snapshot was captured or presentation time). Therefore, it would have been obvious at the time the invention was made to a person having ordinary skill in the art to modify Hance et al. with Sharifi et al. to include forming the snapshot to include the first set of documents. This would have facilitated snapshot generation. The Hance et al. reference as modified by Sharifi et al. teaches all the limitations of claim 1. With respect to claim 2, Hance et al. teaches the system of claim 1, wherein the first set of documents include a version of each of the set of documents, the version of each document determined based on the event (Paragraph 117 discloses version history 312 may provide a snapshot of the one or more revisions associated with the collaboration document. Version history 312 may be provided in chronological order, such that a user can easily identify the order in which one or more versions of collaboration document was created). The Hance et al. reference as modified by Sharifi et al. teaches all the limitations of claim 2. With respect to claim 3, Hance et al. teaches the system of claim 2, wherein the event is associated with an event identifier and the version of each document is associated with the event identifier (Paragraph 73 discloses event service 118 detects a user interaction with a content item and/or another user, event service 118 can create an event identifier (e.g., unique event identifier) and event type, and associate the event identifier and event type with the user (e.g., user identifier and namespace identifier) to create an event or event record for the interaction). The Hance et al. reference as modified by Sharifi et al. teaches all the limitations of claim 2. With respect to claim 4, Sharifi et al. teaches the system of claim 2, wherein the virtual document is defined by a schema defining each of a second set of documents comprising the virtual document (Paragraphs 24-25 discloses A website 104 includes one or more resources 105 associated with a domain name and hosted by one or more servers. An example website is a collection of webpages formatted in hypertext markup language (HTML) that can contain text, images, multimedia content, and programming elements, such as scripts. Each website 104 can be maintained by a content publisher, which is an entity that controls, manages and/or owns the website 104. A resource 105 can be any data that can be provided over the network 102. A resource 105 can be identified by a resource address that is associated with the resource 105. Resources include HTML pages, word processing documents, portable document format (PDF) documents, images, video, and news feed sources, to name only a few. The resources can include content, such as words, phrases, images, video and sounds, that may include embedded information (such as meta-information hyperlinks) and/or embedded instructions). The motivation to combine statement previously provided in the rejection of dependent claim 2 provided above, combining the Hance et al. reference and the Sharifi et al. reference is applicable to dependent claim 4. The Hance et al. reference as modified by Sharifi et al. teaches all the limitations of claim 4. With respect to claim 5, Sharifi et al. teaches the system of claim 4, wherein the first set of documents of the snapshot is a subset of the second set of documents (Paragraph 23 discloses An information card engine 122, for example, can perform functions associated with gathering information for use in information cards, generating the information cards, and determining times for presenting the information cards. For example, after the received snapshots are evaluated, the information card engine 122 can determine content for inclusion in an information card and a time to present one or more information cards to the user, including determining a target time for the presentation. Selection of content and timing of presentation is discussed in greater detail below). The motivation to combine statement previously provided in the rejection of dependent claim 4 provided above, combining the Hance et al. reference and the Sharifi et al. reference is applicable to dependent claim 5. The Hance et al. reference as modified by Sharifi et al. teaches all the limitations of claim 1. With respect to claim 6, Sharifi et al. teaches the system of claim 1, wherein evaluating a virtual document based on the event comprises determining that the snapshot should be formed based on the event (Paragraphs 22-23 discloses content management system 110 can include plural engines, some or all of which may be combined or separate, and may be co-located or distributed (e.g., connected over the network 102). A snapshot evaluation engine 121, for example, can evaluate snapshots of content presented to a user on a device. For each snapshot, for example, the snapshot evaluation engine 121 can identify entities and/or events included in the snapshot and store the identified entities/events along with a timestamp associated with a time that a respective snapshot was captured or presentation time. An information card engine 122, for example, can perform functions associated with gathering information for use in information cards, generating the information cards, and determining times for presenting the information cards. For example, after the received snapshots are evaluated, the information card engine 122 can determine content for inclusion in an information card and a time to present one or more information cards to the user, including determining a target time for the presentation. Selection of content and timing of presentation is discussed in greater detail below). The motivation to combine statement previously provided in the rejection of dependent claim 1 provided above, combining the Hance et al. reference and the Sharifi et al. reference is applicable to dependent claim 6. The Hance et al. reference as modified by Sharifi et al. teaches all the limitations of claim 6. With respect to claim 7, Sharifi et al. teaches the system of claim 6, wherein determining the snapshot should be formed based on the event comprises determining an event rule associated with the event, and wherein determining the first set of documents associated with the event comprises applying the event rule to the virtual document (Paragraphs 22-23 discloses content management system 110 can include plural engines, some or all of which may be combined or separate, and may be co-located or distributed (e.g., connected over the network 102). A snapshot evaluation engine 121, for example, can evaluate snapshots of content presented to a user on a device. For each snapshot, for example, the snapshot evaluation engine 121 can identify entities and/or events included in the snapshot and store the identified entities/events along with a timestamp associated with a time that a respective snapshot was captured or presentation time. An information card engine 122, for example, can perform functions associated with gathering information for use in information cards, generating the information cards, and determining times for presenting the information cards. For example, after the received snapshots are evaluated, the information card engine 122 can determine content for inclusion in an information card and a time to present one or more information cards to the user, including determining a target time for the presentation. Selection of content and timing of presentation is discussed in greater detail below). The motivation to combine statement previously provided in the rejection of dependent claim 1 provided above, combining the Hance et al. reference and the Sharifi et al. reference is applicable to dependent claim 7. With respect to claim 8, Hance et al. teaches a method, comprising: receiving, by the processor, an electronic event (Paragraph 73 discloses content management system 110 can track, create, and store events involving content items and/or user activity); evaluating, by the processor, a virtual document based on the received event to form an electronic snapshot associated with the virtual document by determining a first set of documents associated with the received event based on metadata extracted from the first set of documents, or data extracted from the received event (Paragraph 127 discloses content management service 116 may cross reference each revision with metadata associated therewith to determine an user associated with each revision). Hance does not disclose forming the snapshot to include the first set of documents. However, Sharifi et al. teaches wherein the electronic snapshot includes the first set of documents determined to be associated with the received event (Paragraph 22 discloses For each snapshot, for example, the snapshot evaluation engine 121 can identify entities and/or events included in the snapshot and store the identified entities/events along with a timestamp associated with a time that a respective snapshot was captured or presentation time). Therefore, it would have been obvious at the time the invention was made to a person having ordinary skill in the art to modify Hance et al. with Sharifi et al. to include forming the snapshot to include the first set of documents. This would have facilitated snapshot generation. With respect to claim 9, it is rejected on grounds corresponding to above rejected claim 2, because claim 9 is substantially equivalent to claim 2. With respect to claim 10, it is rejected on grounds corresponding to above rejected claim 3, because claim 10 is substantially equivalent to claim 3. With respect to claim 11, it is rejected on grounds corresponding to above rejected claim 4, because claim 11 is substantially equivalent to claim 4. With respect to claim 12, it is rejected on grounds corresponding to above rejected claim 5, because claim 12 is substantially equivalent to claim 5. With respect to claim 13, it is rejected on grounds corresponding to above rejected claim 6, because claim 13 is substantially equivalent to claim 6. With respect to claim 14, it is rejected on grounds corresponding to above rejected claim 7, because claim 14 is substantially equivalent to claim 7. With respect to claim 15, Hance et al. teaches a non-transitory computer readable medium, comprising instructions for: receiving, by the processor, an electronic event (Paragraph 73 discloses content management system 110 can track, create, and store events involving content items and/or user activity); evaluating, by the processor, a virtual document based on the received event to form an electronic snapshot associated with the virtual document by determining a first set of documents associated with the received event based on metadata extracted from the first set of documents, or data extracted from the received event (Paragraph 127 discloses content management service 116 may cross reference each revision with metadata associated therewith to determine an user associated with each revision). Hance does not disclose forming the snapshot to include the first set of documents. However, Sharifi et al. teaches wherein the electronic snapshot includes the first set of documents determined to be associated with the received event (Paragraph 22 discloses For each snapshot, for example, the snapshot evaluation engine 121 can identify entities and/or events included in the snapshot and store the identified entities/events along with a timestamp associated with a time that a respective snapshot was captured or presentation time). Therefore, it would have been obvious at the time the invention was made to a person having ordinary skill in the art to modify Hance et al. with Sharifi et al. to include forming the snapshot to include the first set of documents. This would have facilitated snapshot generation. With respect to claim 16, it is rejected on grounds corresponding to above rejected claim 2, because claim 16 is substantially equivalent to claim 2. With respect to claim 17, it is rejected on grounds corresponding to above rejected claim 3, because claim 17 is substantially equivalent to claim 3. With respect to claim 18, it is rejected on grounds corresponding to above rejected claim 4, because claim 18 is substantially equivalent to claim 4. With respect to claim 19, it is rejected on grounds corresponding to above rejected claim 5, because claim 19 is substantially equivalent to claim 5. With respect to claim 20, it is rejected on grounds corresponding to above rejected claim 6, because claim 20 is substantially equivalent to claim 6. With respect to claim 21, it is rejected on grounds corresponding to above rejected claim 7, because claim 21 is substantially equivalent to claim 7. Relevant Prior Art The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US PG-Pub. No. 20190325009 is directed to CALCULATING AND PRESENTING USER-SPECIFIC DIFFERENCES: [0068] Based on the retrieved metadata, at step 440, the last time (e.g., by timestamp or sequence number or other version designation), that the requesting user has seen the document is determined, and then a corresponding earlier version 451 is retrieved from object storage 351 (at step 450). In some cases, the version of a document that corresponds to the timestamp or sequence number or other version designation is constructed by applying a sequence of snapshots or operational transformation statements to a base document, possibly generating a snapshot associated with a timestamp of an editing change event or set of editing changes. In other cases, the version of a document that corresponds to the timestamp or sequence number (or other version designation) can be persisted as a saved document that can be retrieved from object storage 351. 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. 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). Any inquiry concerning this communication or earlier communications from the examiner should be directed to NICHOLAS E ALLEN whose telephone number is (571)270-3562. The examiner can normally be reached Monday through Thursday 830-630. 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, Boris Gorney can be reached at (571) 270-5626. 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. /N.E.A/Examiner, Art Unit 2154 /SYED H HASAN/Primary Examiner, Art Unit 2154
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Prosecution Timeline

Dec 16, 2024
Application Filed
Sep 15, 2025
Non-Final Rejection — §101, §103
Dec 09, 2025
Applicant Interview (Telephonic)
Dec 09, 2025
Examiner Interview Summary
Dec 16, 2025
Response Filed
Jan 09, 2026
Final Rejection — §101, §103
Apr 08, 2026
Request for Continued Examination
Apr 11, 2026
Response after Non-Final Action

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3-4
Expected OA Rounds
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3y 3m
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