Prosecution Insights
Last updated: April 19, 2026
Application No. 19/018,744

COMBINED ACTIVITIES HISTORY ON A DEVICE

Non-Final OA §103§112
Filed
Jan 13, 2025
Examiner
PHAM, KHANH B
Art Unit
2166
Tech Center
2100 — Computer Architecture & Software
Assignee
Google LLC
OA Round
3 (Non-Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
3y 5m
To Grant
88%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
604 granted / 835 resolved
+17.3% vs TC avg
Strong +15% interview lift
Without
With
+15.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
34 currently pending
Career history
869
Total Applications
across all art units

Statute-Specific Performance

§101
10.3%
-29.7% vs TC avg
§103
38.9%
-1.1% vs TC avg
§102
30.7%
-9.3% vs TC avg
§112
9.2%
-30.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 835 resolved cases

Office Action

§103 §112
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application is being examined under the pre-AIA first to invent provisions. 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 2/10/2026 has been entered. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1, 12, 16 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Claims 1, 12, 16 recite “establishing, via an application, an application state by performing an action using content associated with a content type and populating a first memory location with data associated with the application state”… “encoding the data from the first memory location into the object”, “decoding the object from the second memory location to reconstruct the action and the content”, which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The specification does not disclose “establishing… an application state”, does not explain what is “an application state” nor “data associated with the application state”, does not disclose “populating a first memory location with data associated with the application state”, does not disclose “encoding the data from the first memory location into the object”, does not disclose “decoding the object from the second memory to reconstruct the action and the content” as recited in the claims. Claims 1, 12, 16 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the enablement requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to enable one skilled in the art to which it pertains, or with which it is most nearly connected, to make and/or use the invention. Claim 1, 12, 16 recite “establishing, via an application, an application state by performing an action using content associated with a content type and populating a first memory location with data associated with the application state”, “encoding the data from the first memory location into the object”, “decoding the object from the second memory location to reconstruct the action and the content”, which was not described in the specification in such a way as to enable one skilled in the art to which it pertains, or with which it is most nearly connected, to make and/or use the invention. The specification does not disclose “establishing… an application state”, does not explain what is “an application state” nor “data associated with the application state”, does not disclose “populating a first memory location with data associated with the application state”, does not disclose “encoding the data from the first memory location into the object”, does not disclose “decoding the object from the second memory to reconstruct the action and the content” as recited in the claims. Claim Rejections - 35 USC § 103 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 pre-AIA 35 U.S.C. 103(a) which forms the basis for all obviousness rejections set forth in this Office action: (a) A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-3, 6, 8-9, 12, 14, 16-18, 22, 24-25 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Borenstein et al. (US 2008/0276179 A1, Applicant’s submitted IDS filed 1/13/2025), hereinafter “Borenstein”, and in view of Roskowski (US 2009/0210516 A1, Applicant’s submitted IDS filed 1/13/2025), hereinafter “Roskowski”. As per claim 1, Borenstein teaches a method comprising: “establishing, via an application, an application state by performing an action using content associated with a content type and populating in a first memory location with data associated with the application state” at [0018], [0028]-[0029]; (Borenstein teaches user activities such as reading, opening, scrolling, closing an email message or opening, modifying, saving a document are recorded in an activity log (i.e., “first memory location”). An activity logging module 160 that records user activities occurring in the heterogeneous system. For example, the activity logging module 160 of a mail system can be configured to record the source address, destination address, subject, and keyword of each email. A document management system that traces user activities (e.g., edit, check-in, check-out, print, and access) affecting document stored in the system. Web browser records user’s web browsing activity, mobile phones track phone call in a call logs) “in response to performing the action, generating, via the application an object representing the application state by encoding the data from the first memory location into the object, the object including an action string specifying the action and content string specifying the content, wherein the object conforms to a data format shared by a plurality of applications” at [0041]-[0043], [0062]-[0065]; (Borenstein teaches setting up a trigger that can be activated by user activities. Once activated, the trigger can instruct local applications or activity logging modules 160 to retrieve information about user activity and transmit it to the monitor module 312. The monitor module 312 encodes the user activity records into a standard format according to conversion rules. The activity records include action string specifying the action (e.g., opening, reading, editing, browsing, printing) and content string specifying the content (e.g., email, document, web page)) “storing, via the application, the object to a second memory location in accordance with the data format” at [0042]; (Borenstein teaches the monitor module 312 can be configured to store a record of monitored user activities in the data store 330 (i.e., “second memory location”)) “displaying (Borenstein teaches displaying recorded user activities which include actions and contents) Borenstein does not explicitly teach “displaying selectable affordance…” as claimed. However, Roskowski teaches a method for collecting event and event-related data to create an activity record, including a user interface configured to "displaying, via a client device, a user-selectable affordance associated with the action and the content" at [0023]-[0029] and Figs. 2-4. Thus, it would have been obvious to one of ordinary skill in the art to combine Roskowski with Borenstein's teaching in order to present the activity records to the user and allow the user to interact with the activity record. As per claim 2, Borenstein and Roskowski teach the method of claim 1 discussed above. Borenstein also teaches: wherein “the data format includes an action specification and a content specification, the method further comprising: generating, via the application, the action string according to the action specification and the content string according to the content specification” at [0056], [0061]-[0062], [0065]. As per claim 3, Borenstein and Roskowski teach the method of claim 1 discussed above. Borenstein also teaches: wherein “storing the object to the second memory location includes providing the object from the application to a logging module, the logging module configured to store the object to the second memory location” at [0041]-[0043]. As per claim 6, Borenstein and Roskowski teach the method of claim 1 discussed above. Roskowski also teaches: wherein “the selectable affordance includes displaying a chronological order list of a subset of a plurality of activities associated with the selectable affordance” at Figs. 2, 4. As per claim 8, Borenstein and Roskowski teach the method of claim 1 discussed above. Roskowski also teaches: “generating the selectable affordance based on a mapping associating the content and a display name” at [0033]-[0045] and Figs. 2, 4. As per claim 9, Borenstein and Roskowski teach the method of claim 1 discussed above. Roskowski also teaches: “generating the selectable affordance based on the action and a grouping associated with the action” at [0033]-[0045] and Figs. 2, 4. Claims 12, 14, 16-18 recite similar limitations as in claims 1-3, 6, 8-9 above and are therefore rejected by the same reasons. As per claim 22, Borenstein and Roskowski teach the method of claim 1 discussed above. Roskowski also teaches: “detecting an interaction with the selectable affordance; and in response to the interaction, re-establishing, via the application, the application state by using the data associated with the application state” at [0033]-[0045] and Figs. 2, 4. As per claim 24, Borenstein and Roskowski teach the method of claim 1 discussed above. Borenstein also teaches: wherein “the plurality of applications includes the applications” at [0018], [0028]-[0029]. As per claim 25, Borenstein and Roskowski teach the method of claim 1 discussed above. Roskowski also teaches: “the object includes metadata associated with the content and reconstructing the action and the content includes selecting a graphical representation for the selectable affordance based on the metadata” at [0033]-[0045] and Figs. 2, 4. Claim 11 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Borenstein and Roskowski as applied to claims 1-3, 6, 8-9, 12, 14, 16-18 above, and further in view of Denoue et al. (US 2009/0006371 A1), hereinafter “Denoue”. As per claim 11, Borenstein and Roskowski teach the method of claim 1 discussed above. Borenstein and Roskowski does not teach: “grouping the action with a plurality of previously logged actions based at least in part on a common key derived from a respective content string and according to a predefined key specification, wherein displaying the selectable affordance includes displaying a single selectable affordance representing the group” as claimed. However, Denoue teaches a similar method for logging user's online activity, grouping the activities based on common domain associated with the website visited by the user and display a single user's online activity representing the group at [0029]-[0034], [0052]-[0053] and Fig. 5. Thus, it would have been obvious to one of ordinary skill in the art to combine Denoue with Borenstein's teaching in order to provide a cleaner user interface by grouping similar activity together. Claims 23 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Borenstein and Roskowski as applied to claims 1-3, 6, 8-9, 12, 14, 16-18 above, and further in view of Morris (US 2006/0230058 A1, Applicant’s submitted IDS filed 1/13/2025), hereinafter “Morris”. As per claim 23, Borenstein and Roskowski teach the method of claim 22 discussed above. Borenstein does not teach: “the data format includes a Uniform Resource Identifier syntax, the object is a Uniform Resource Identifier-encoded string including the action string and the content string, and re-establishing the application state includes extracting a target address from the Uniform Resource Identifier-encoded string and restoring the application to a resource location defined by the action string and the content string” as claimed. However, Morris teaches a method for tracking user activity related to network resource and to form an activity record object representing activity-resource pair, in a data format which includes “a Uniform Resource Identifier syntax, the object is a Uniform Resource Identifier-encoded string including the action string and the content string, and re-establishing the application state includes extracting a target address from the Uniform Resource Identifier-encoded string and restoring the application to a resource location defined by the action string and the content string” at [0030]-[0037]. Thus, it would have been obvious to one of ordinary skill in the art to combine Morris with Borenstein-Roskowski’s teaching in order to provide an improved method for tracking user activity which “capable of tracking both user-initiated activities related to network resources in the browser as well as any corresponding results received by the browser as a result of the activities that are not accessible by servers”, as suggested by Morris at [0007]. Response to Arguments Applicant's arguments filed 2/10/2026 have been fully considered but they are not persuasive. The examiner respectfully traverses Applicant’s arguments. Regarding claims, 1, 12, 16, Applicant argued that “Borenstein fails to teach or suggest an application that encodes state data into an object to serve as direct source for reconstructing the action and the content”. On the contrary, Borenstein teaches at [0041]-[0043], [0062]-[0065] the monitor module 312 (i.e., “the application”) encodes the user activity records into a standard format according to conversion rules. The activity records include action string specifying the action (e.g., opening, reading, editing, browsing, printing) and content string specifying the content (e.g., email, document, web page)) Conclusion Examiner's Note: Examiner has cited particular columns and line numbers in the references applied to the claims above for the convenience of the applicant. Although the specified citations are representative of the teachings of the art and are applied to specific limitations within the individual claim, other passages and figures may apply as well. It is respectfully requested from the applicant in preparing responses, to fully consider the references in entirety as potentially teaching all or part of the claimed invention, as well as the context of the passage as taught by the prior art or disclosed by the Examiner. In the case of amending the Claimed invention, Applicant is respectfully requested to indicate the portion(s) of the specification which dictate(s) the structure relied on for proper interpretation and also to verify and ascertain the metes and bounds of the claimed invention. Any inquiry concerning this communication or earlier communications from the examiner should be directed to KHANH B PHAM whose telephone number is (571)272-4116. The examiner can normally be reached Monday - Friday, 8am to 4pm. 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, Sanjiv Shah can be reached at (571)272-4098. 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. /KHANH B PHAM/Primary Examiner, Art Unit 2166 April 6, 2026
Read full office action

Prosecution Timeline

Jan 13, 2025
Application Filed
Oct 14, 2025
Non-Final Rejection — §103, §112
Nov 18, 2025
Examiner Interview Summary
Nov 18, 2025
Applicant Interview (Telephonic)
Nov 19, 2025
Response Filed
Dec 17, 2025
Final Rejection — §103, §112
Jan 30, 2026
Examiner Interview Summary
Jan 30, 2026
Applicant Interview (Telephonic)
Feb 10, 2026
Request for Continued Examination
Feb 23, 2026
Response after Non-Final Action
Apr 06, 2026
Non-Final Rejection — §103, §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

3-4
Expected OA Rounds
72%
Grant Probability
88%
With Interview (+15.2%)
3y 5m
Median Time to Grant
High
PTA Risk
Based on 835 resolved cases by this examiner. Grant probability derived from career allow rate.

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