Prosecution Insights
Last updated: October 02, 2026
Application No. 19/052,027

Access Control Techniques for Media Playback Systems

Final Rejection §103
Filed
Feb 12, 2025
Priority
Apr 01, 2019 — continuation of 11/184,666 +3 more
Examiner
DAVIS, CHENEA
Art Unit
2421
Tech Center
2400 — Computer Networks
Assignee
Sonos Inc.
OA Round
2 (Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
1y 2m
Est. Remaining
89%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allowance Rate
388 granted / 536 resolved
+14.4% vs TC avg
Strong +16% interview lift
Without
With
+16.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
28 currently pending
Career history
563
Total Applications
across all art units

Statute-Specific Performance

§101
12.9%
-27.1% vs TC avg
§103
50.9%
+10.9% vs TC avg
§102
9.4%
-30.6% vs TC avg
§112
18.0%
-22.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 536 resolved cases

Office Action

§103
DETAILED ACTION 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 is in response to communications filed 6/12/2026. Claims 9, 14, and 19 are amended. Claims 1-20 are pending in this application. Response to Arguments Applicant's arguments filed 6/12/2026 have been fully considered but they are not persuasive. In response to Applicant’s arguments on pages 10-11 that “Independent claim 1 is patentable over Tan, Wahl, and Graham because these references fail to disclose or suggest each and every feature of claim 1 including, "generating a token based on the user's determined user type for the media playback system." The present Office Action points to Wahl at [0038]-[0040], [0044], [0051], [0058]-[0059], "and other related text" as disclosing this feature. (Office Action, pp. 3-4.) During the interview, Examiner Davis further clarified that she is relying on Wahl's "authentication level" as corresponding to the recited "user type." However, the relied-upon portions of Wahl neither disclose nor suggest the generation of a token based on an authentication level, let alone a user type, as claim 1 recites. Wahl describes techniques "for managing access to services (e.g., Web sites, applications, results of executable operations, etc.)" (Wahl, Abstract) by, for example, authenticating and authorizing users via a "management policy rule" that correlates relationships between entities and services with "access rights assigned to those relationships." (Wahl, [0044].) In some cases, Wahl determines "[w]hich identity provider to contact for authentication and authorization of [an] entity by using a card selector application" that "stores information cards pertaining to a user." (Wahl, [0048].) Each information card corresponds to an identity provider and includes, for example, "an identifier of the user," "an authentication level of the credentials of the user," and "references to the types of claims which the identity provider may generate." (Wahl, [0048].) In response to an access request, "the card selector application reviews the user's cards and determines which information cards indicate an authentication level of the user and claim types generated by the identity provider that satisfy the requirements specified in the server's request," the user then selects from among any of satisfactory information cards, and the corresponding identity provider performs operations to authenticate the user and determine the user's access rights. (Wahl, [0048]-[0051].) Wahl further describes using a user or entity's access rights to generate tokens. For example, Wahl describes 1) generating a claim specifying a user's access rights, incorporating the claim into a token and, optionally, encrypting and signing the token ( [0051]) or 2) generating a rights claim indicating an entity's access rights, including the generated rights claim in a token and, optionally, encrypting and signing the token (Wahl, [0058]-[0059]). Thus, the generation of Wahl's tokens are based on an individual user or entity's access rights, not based on a "user group," as recited. Furthermore, Wahl's "authentication level" is used to identify one or more identity providers, not as a basis for generating a token. Thus, even assuming, for the sake of argument, that an "authentication level" is a "user type," which applicant does not concede, the relied-upon portions of the applied references fail to disclose or suggest generating a token based on the authentication level, let alone "generating a token based on the user's determined user type for the media playback system," as claim 1 recites. Thus, Tan, Wahl, and Graham fail to disclose or suggest each and every feature of claim 1 and cannot support a Section 103 rejection of claim 1. Therefore, the Section 103 rejection of claim 1 should be withdrawn”, the Examiner respectfully disagrees. The Examiner notes that, per the rejection of record, the “access rights” of Wahl is used to teach the user type (see office action of 3/27/26, page 3). And Wahl teaches, at least at: [0058] that “Authorization database 208 is configured to store access rights for each of a plurality of entities with respect to a plurality of services. Accordingly, authorization database 208 stores access rights associated with the entity regarding the services that the entity is allowed to access. Security token service module 206 compares identifier 216 to the access rights stored in authorization database 208 to determine whether the entity is authorized to access one or more services of the relying party”; and at [0059] that “If security token service module 206 determines that the entity is authorized to access one or more services provided by relying party 108, for example, security token service module 206 generates a rights claim. A rights claim is a claim that indicates access rights of an entity with respect to service(s) of a relying party. In this example, the rights claim generated by security token service module 206 indicates the access rights of the entity with respect to the one or more services provided by relying party 108. Security token service module 206 may be configured to generate a token that includes the rights claim. For instance, security token service module 206 may encrypt the token, sign the token, and provide the token to client 114, which may then forward the token to relying party 108 for further processing”. Therefore, given the broadest reasonable interpretation of the limitation of “generating a token based on the user’s determined user type”, the teaching of Wahl sufficiently meets the limitation as claimed, and the rejection of record is maintained. 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. Claims 1, 3-5, 9, 11-13, 15 and 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Tan (of record) in view of Wahl (of record) and Graham (of record). Regarding claims 1, 9, and 15, Tan discloses a method to be performed by a computing system (see Tan, at least at [0053], Figs. 2, and other related text) the method comprising: receiving, via one or more network interfaces from a user device (see Tan, at least at [0053]-[0057], [0081], and other related text), (i) one or more login credentials associated with a user (see Tan, at least at [0055], [0082], and other related text); and (ii) a request for an authentication credential (i.e., Tier 2 activation, see Tan, at least at [0083]-[0085], and other related text), determining that the login credentials associated with the user are valid (see Tan, at least at [0055], [0072], [0082], and other related text); and after determining that the login credentials associated with the user are valid, generating a token (see Tan, at least at [0083]-[0085], and other related text), and transmitting, via the one or more network interfaces, the generated token to the user device (see Tan, at least at [0085], and other related text). Tan does not specifically disclose the user device being of a media playback system; or the user having a user type for the media playback system; or determining, based on the received one or more login credentials associated with the user, the user’s user type for the media playback system; and generating the token based on the user’s determined user type for the media playback system, wherein the generated token grants the user a level of access to the media playback system that is tailored to the user’s determined user type. In an analogous art relating to a system for access control, Wahl discloses the user having a user type for the system (i.e., access rights, see Wahl, at least at [0027]-[0028], [0031], [0044], [0048], [0058]-[0059], [0074]-[0075], and other related text); and determining, based on a received one or more login credentials associated with a user, the user’s user type for a system (see Wahl, at least at [0025], [0034]-[0035], [0038], and other related text); and generating a token based on the user’s determined user type for the media playback system (see Wahl, at least at [0038]-[0040], [0044], [0051],[0058]-[0059], and other related text), wherein the generated token grants the user a level of access to the media playback system that is tailored to the user's determined user type (see Wahl, at least at [0038]-[0040], [0044], [0051], [0058]-[0059], and other related text). It would have been obvious to a person having ordinary skill in the art before the effective date of the invention to modify the system of the system of Tan to include the limitations as taught by Wahl for the advantage of more efficiently providing access to services and/or content while maintaining security of the service and/or content. Tan in view of Wahl does not specifically disclose the system being a media playback system. In an analogous art relating to a system for access control, Graham discloses a method to be performed by a computing system (see Graham, at least at Figs. 1 and 11-12 and related text), the method comprising: receiving, via one or more network interfaces from a user device of a media playback system (see Graham, at least at Figs. 1 and 11-12 and related text); and (i) one or more login credentials associated with a user (user credentials, see Graham, at least at [0104], Fig. 11 and related text) and (ii) a request for an authentication credential (see Graham, at least at [0104]-[0105], Fig. 11 and related text); and transmitting, via the one or more network interfaces, the generated token to the user device (see Graham, at least at [0104]-[0107], Fig. 11 and related text). It would have been obvious to a person having ordinary skill in the art before the effective date of the invention to modify the system of the system of Tan in view of Wahl to include the limitations as taught by Graham for the advantage of more efficiently providing access to more services and/or content while maintaining security of the service and/or content. Regarding claims 3, 11, and 17, Tan in view of Wahl and Graham discloses wherein the one or more login credentials associated with the user include a first identifier obtained from a playback device of the media playback system. (i.e., session ID, see Tan, at least at [0056], and other related text, and see Wahl, at least at [0037], [0056]-[0057], and other related text, and i.e., device ID, see Graham, at least at Fig. 11 and related text). Regarding claims 4, 12, and 19, Tan in view of Wahl and Graham discloses wherein determining that the one or more login credentials associated with the user are valid comprises determining that the one or more login credentials associated with the user include the first identifier (see Tan, at least at [0056], and other related text). Regarding claims 5, 13, and 20Tan in view of Wahl and Graham discloses wherein generating the token comprises: identifying a set of permissions associated with the user's determined user type for the media playback system (see Wahl, at least at [0038]-[0040], [0044], [0051], [0058]-[0059], and other related text); and storing the identified set of permissions associated with the user's determined user type for the media playback system in data storage (see Wahl, at least at [0038]-[0040], [0044], [0051], [0058]-[0059], and other related text). Claims 2, 10, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Tan (previously cited) in view of Wahl (previously cited) and Graham (previously cited), as applied to claims 2, 10, and 16 and above, and further in view of Reddy et al. (US9172724, hereinafter Reddy). Regarding claims 2, 10, and 16, Tan in view of Wahl and Graham discloses setting an expiration time for the generated token (see Tan, at least at [0042], and other related text), does not specifically disclose setting an expiration time for the generated token based on the user's determined user type for the media playback system. In an analogous art relating to a system for access control, Reddy discloses setting an expiration time for the generated token based on the user's determined user type for the media playback system (see Reddy, at least at col 3, line 61 – col 4, lines 6, col 9, lines 14-24, col 10, lines 12-40, and other related text). It would have been obvious to a person having ordinary skill in the art before the effective date of the invention to modify the system of the system of Tan in view of Wahl and Graham to include the limitations as taught by Reddy for the advantage of more efficiently providing access to more services and/or content while maintaining security of the service and/or content. Allowable Subject Matter Claims 6-8, 14 and 16 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. 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHENEA DAVIS whose telephone number is (571)272-9524 and whose email address is CHENEA.SMITH@USPTO.GOV. The examiner can normally be reached M-F: 8:00 am - 4:00 pm. 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, Nathan Flynn can be reached at 571-272-1915. 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. /CHENEA DAVIS/Primary Examiner, Art Unit 2421
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Prosecution Timeline

Feb 12, 2025
Application Filed
Mar 27, 2026
Non-Final Rejection mailed — §103
May 13, 2026
Interview Requested
May 21, 2026
Examiner Interview Summary
May 21, 2026
Applicant Interview (Telephonic)
Jun 12, 2026
Response Filed
Aug 20, 2026
Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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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
89%
With Interview (+16.2%)
2y 10m (~1y 2m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 536 resolved cases by this examiner. Grant probability derived from career allowance rate.

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