Prosecution Insights
Last updated: July 17, 2026
Application No. 19/061,517

Email Review System

Non-Final OA §103
Filed
Feb 24, 2025
Priority
Feb 02, 2023 — continuation of 12/238,055
Examiner
JOO, JOSHUA
Art Unit
Tech Center
Assignee
Yahoo Assets LLC
OA Round
1 (Non-Final)
78%
Grant Probability
Favorable
1-2
OA Rounds
1y 9m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 78% — above average
78%
Career Allowance Rate
774 granted / 988 resolved
+18.3% vs TC avg
Strong +23% interview lift
Without
With
+23.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
32 currently pending
Career history
1013
Total Applications
across all art units

Statute-Specific Performance

§101
3.4%
-36.6% vs TC avg
§103
70.3%
+30.3% vs TC avg
§102
3.0%
-37.0% vs TC avg
§112
20.6%
-19.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 988 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 . Claims 1-20 are pending in the application. Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. Claims 1-20 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-20 of U.S. Patent No. 12,238,055 (“Patent ‘055”). Although the claims at issue are not identical, they are not patentably distinct from each other because as shown below, the claims are anticipated by claims of Patent ‘055. Instant Application Patent ‘055 1. A method, comprising: receiving a review initiation request from a first email account, wherein the review initiation request is indicative of: proposed email content; a reviewer of the proposed email content; and a second reviewer of the proposed email content; 1. A method, comprising: receiving a review initiation request from a first email account, wherein the review initiation request is indicative of: proposed email content; a reviewer of the proposed email content; and a second reviewer of the proposed email content; generating, based upon the review initiation request, an email comprising: the proposed email content; and an email review interface comprising: a feedback entry field; and an approval selectable input; generating, based upon the review initiation request, an email comprising: the proposed email content; and an email review interface comprising: a feedback entry field; and an approval selectable input; transmitting the email to a reviewer email account of the reviewer; receiving, from the reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content, submitted via a first instance of the feedback entry field; or an approval indicator, indicating approval of the proposed email content, submitted via a first instance of the approval selectable input; and transmitting the email to a reviewer email account of the reviewer; transmitting the email to a second reviewer email account of the second reviewer; receiving, from the reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content, submitted via a first instance of the feedback entry field; or an approval indicator, indicating approval of the proposed email content, submitted via a first instance of the approval selectable input; receiving, from the second reviewer email account and via a second instance of the email review interface, a second review response indicating at least one of: second feedback, indicating one or more second suggestions associated with the proposed email content, submitted via a second instance of the feedback entry field; or a second approval indicator, indicating second approval of the proposed email content, submitted via a second instance of the approval selectable input; and generating, by an email review system and based upon the review response from the reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content. generating, by an email review system and based upon (i) the review response from the reviewer email account and (ii) the second review response from the second reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content and an email content revision field concurrently displaying (i) at least some of the proposed email content within a first field, (ii) a first representation of the one or more suggestions, from the reviewer email account, within the first field comprising at least some of the proposed email content and (iii) a second representation of the one or more second suggestions, from the second reviewer email account, within the first field comprising at least some of the proposed email content. Claims 2-13 are unpatentable of claims 2-13 of Patent ‘055. Claims 14-18 are unpatentable of claims 14-18 of Patent ‘055. Claims 19-20 are unpatentable of claims 19-20 of Patent ‘055. 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, 3-4, 14-17, 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Lowe US Patent Publication No. 2005/0144245 (“Lowe”) in view of Meisels et al. US Patent Publication No. 2012/0278401 (“Meisels”), Ganta US Patent Publication No. 2020/0226323 (“Ganta”), and Willner et al. US Patent Publication No. 2009/0216843 (Willner”). Regarding claim 1, Lowe teaches a method, comprising: receiving a review initiation request from a first email account, wherein the review initiation request is indicative of: proposed email content; a reviewer of the proposed email content; and a second reviewer of the proposed email content (see fig. 10. see text of email, “To Reviewer,” “Send for Review” 1010. para. [0051] user may enter the name and email address of the intended reviewer(s). para. [0064] reviewer name field 1006); and generating, based upon the review initiation request, an email comprising: the proposed email content (see fig. 8. para. [0059] interface presented to a reviewer that is editing an email. body 801 of email 702 is displayed to the reviewer. may make desired changes to the text in the body); and transmitting the email to a reviewer email account of the reviewer (para. [0064] selecting send for review option 1010 may send the email directly to the reviewer); receiving, from the reviewer email account, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content (para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author); and generating, by an email review system, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content (para. [0054] "skip review option 612, and "send for review" option 616. skip review option 612… skip the second person review and have the email instead sent as a normal email to the destination address(es). send for review option 616 may cause email review tool 336 to send the email to the reviewer. para. [0063] “send for review” option, send option 510). Lowe does not teach the email comprising: an email review interface comprising: a feedback entry field; and an approval selectable input. Lowe does not teach receiving, from the reviewer email account and via a first instance of the email review interface, a review response indicates at least one of: feedback, indicating one or more suggestions associated with the proposed email content, submitted via a first instance of the feedback entry field; or an approval indicator, indicating approval of the proposed email content, submitted via a first instance of the approval selectable input. Lowe does not teach: generating, by an email review system and based upon the review response from the reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content. Meisels teaches a request indicative of a first reviewer of a proposed email content and a second reviewer of a proposed email content (para. [0029] creates new electronic messages that are addressed to other reviewers that are collaborating on a document. para. [0030] messaging application 218 may be used to send electronic messages of one or more types to the reviewers that are collaborating on the document); generating an email comprising an email review interface comprising a feedback entry field (para. [0042] box 316 allows a user to add a comment to the change. claim 1, 5. sending the electronic message to at least a portion of the reviewers. creating the electronic message comprises including a comment area that is used to enter a comment); receiving, from a reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: the feedback via a first instance of the feedback entry field (para. [0059] one or more replies may be received in response to the sent electronic message(s). a reply may be received from all/portion of the reviewers. fig. 3. para. [0040] reviewer… has received an email message summarizing changes that were made). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Meisels’ disclosure of providing an email comprising an email review interface comprising a feedback entry field such that the email of Lowe comprises an email review interface, and receiving, via instances of the email review interface, review responses indicating at least one of: the feedback from a plurality of reviewers. Meisels is also directed to providing an email for review by a plurality of reviewers. One of ordinary skill in the art would have been motivated to do so because Meisels would have improved Lowe by enabling collaborative editing on the email by reviewers and providing an area for comments. Ganta teaches generating an email comprising an email review interface comprising an approval selectable input (fig. 4, para. [0044] email 400 includes an approve button 401). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Ganta’s disclosure such that the email review interface further comprises an approval selectable input. One of ordinary skill in the art would have been motivated to do so because Lowe discloses providing users with a simple and quick method for implementing second person review (para. [0042]). It would have been desirable to have implemented Ganta’s disclosure of an approval button, which would have enabled a reviewer to efficiently indicate approval of the email. Willner teaches generating, by an email review system and based upon a review response from a reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content (para. [0035] user 46 may again select, via onscreen pointer 154, send draft button 156. para. [0038] receive 108 response email from 250 from the one or more specified reviewing recipients. Fig. 6 see send button and draft button. para. [0042] send button). Lowe already discloses an interface comprising a first selectable input associated with providing one or more reviewers with a version of a proposed email content, and a second selectable input associated with providing one or more intended recipients with an email corresponding to the version of the proposed email content. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Willner’s disclosure such that an interface is provided with inputs to send the revised email to a reviewer or to recipient(s). One of ordinary skill in the art would have been motivated to do so because it would have been desirable to enable a user to conveniently send the revised email to the recipients or send the revised email for additional review by one or more reviewers. Regarding claim 14, Lowe teaches a computing device comprising: a processor; and memory comprising processor-executable instructions that when executed by the processor cause performance of operations, the operations comprising: receiving a review initiation request from a first email account, wherein the review initiation request is indicative of: proposed email content; a reviewer of the proposed email content; and a second reviewer of the proposed email content (see fig. 10. see text of email, “To Reviewer,” “Send for Review” 1010. para. [0051] user may enter the name and email address of the intended reviewer(s). para. [0064] reviewer name field 1006); generating, based upon the review initiation request, an email comprising: the proposed email content (see fig. 8. para. [0059] interface presented to a reviewer that is editing an email. body 801 of email 702 is displayed to the reviewer. may make desired changes to the text in the body); and transmitting the email to a reviewer email account of the reviewer (para. [0064] selecting send for review option 1010 may send the email directly to the reviewer); receiving, from the reviewer email account, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content (para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author); and generating, by an email review system, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the version of the proposed email content (para. [0054] "skip review option 612, and "send for review" option 616. Skip review option 612… skip the second person review and have the email instead sent as a normal email to the destination address(es). send for review option 616 may cause email review tool 336 to send the email to the reviewer. para. [0063] “send for review” option, send option 510). Lowe does not teach the email comprising: an email review interface comprising: a feedback entry field; and an approval selectable input; Lowe does not teach receiving, from the reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content, submitted via a first instance of the feedback entry field; or an approval indicator, indicating approval of the proposed email content, submitted via a first instance of the approval selectable input. Lowe does not teach generating, by an email review system and based upon the review response from the reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content. Meisels teaches a request indicative of a first reviewer of a proposed email content and a second reviewer of a proposed email content (para. [0029] creates new electronic messages that are addressed to other reviewers that are collaborating on a document. para. [0030] messaging application 218 may be used to send electronic messages of one or more types to the reviewers that are collaborating on the document); generating an email comprising an email review interface comprising a feedback entry field (para. [0042] box 316 allows a user to add a comment to the change. claim 1, 5. sending the electronic message to at least a portion of the reviewers. creating the electronic message comprises including a comment area that is used to enter a comment); receiving, from a reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: the feedback via a first instance of the feedback entry field (para. [0059] one or more replies may be received in response to the sent electronic message(s). a reply may be received from all/portion of the reviewers. fig. 3. para. [0040] reviewer… has received an email message summarizing changes that were made). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Meisels’ disclosure of providing an email comprising an email review interface comprising a feedback entry field such that the email of Lowe comprises an email review interface, and receiving, via instances of the email review interface, review responses indicating at least one of: the feedback from a plurality of reviewers. Meisels is also directed to providing an email for review by a plurality of reviewers. One of ordinary skill in the art would have been motivated to do so because Meisels would have improved Lowe by enabling collaborative editing on the email by reviewers and providing an area for comments. Ganta teaches generating an email comprising an email review interface comprising an approval selectable input (fig. 4, para. [0044] email 400 includes an approve button 401). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Ganta’s disclosure such that the email review interface further comprises an approval selectable input. One of ordinary skill in the art would have been motivated to do so because Lowe discloses providing users with a simple and quick method for implementing second person review (para. [0042]). It would have been desirable to have implemented Ganta’s disclosure of an approval button, which would have enabled a reviewer to efficiently indicate approval of the email. Willner teaches generating, by an email review system and based upon a review response from a reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content (para. [0035] user 46 may again select, via onscreen pointer 154, send draft button 156. para. [0038] receive 108 response email from 250 from the one or more specified reviewing recipients. fig. 6 see send button and draft button. para. [0042] send button). Lowe already discloses an interface comprising a first selectable input associated with providing one or more reviewers with a version of a proposed email content, and a second selectable input associated with providing one or more intended recipients with an email corresponding to the version of the proposed email content. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Willner’s disclosure such that an interface is provided with inputs to send the revised email to a reviewer or to recipient(s). One of ordinary skill in the art would have been motivated to do so because it would have been desirable to enable a user to conveniently send the revised email to the recipients or send the revised email for additional review by one or more reviewers. Regarding claim 19, Lowe teaches a non-transitory machine readable medium having stored thereon processor-executable instructions that when executed cause performance of operations, the operations comprising: receiving a review initiation request from a first email account, wherein the review initiation request is indicative of: proposed email content; a reviewer of the proposed email content; and a second reviewer of the proposed email content (see fig. 10. see text of email, “To Reviewer,” “Send for Review” 1010. para. [0051] user may enter the name and email address of the intended reviewer(s). para. [0064] reviewer name field 1006); generating, based upon the review initiation request, an email comprising: the proposed email content (see fig. 8. para. [0059] interface presented to a reviewer that is editing an email. body 801 of email 702 is displayed to the reviewer. may make desired changes to the text in the body); transmitting the email to a reviewer email account associated with the reviewer (para. [0064] selecting send for review option 1010 may send the email directly to the reviewer); receiving, from the reviewer email account, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content (para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author); and generating, by an email review system, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the version of the proposed email content (para. [0054] "skip review option 612, and "send for review" option 616. Skip review option 612… skip the second person review and have the email instead sent as a normal email to the destination address(es). send for review option 616 may cause email review tool 336 to send the email to the reviewer. para. [0063] “send for review” option, send option 510). Lowe does not teach the email comprising: the proposed email content; and an email review interface comprising: a feedback entry field; and an approval selectable input. Lowe does not teach receiving, from the reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: feedback, indicating one or more suggestions associated with the proposed email content, submitted via a first instance of the feedback entry field; or an approval indicator, indicating approval of the proposed email content, submitted via a first instance of the approval selectable input. Lowe does not teach generating, by an email review system and based upon the review response from the reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content. Meisels teaches a request indicative of a first reviewer of a proposed email content and a second reviewer of a proposed email content (para. [0029] creates new electronic messages that are addressed to other reviewers that are collaborating on a document. para. [0030] messaging application 218 may be used to send electronic messages of one or more types to the reviewers that are collaborating on the document); generating an email comprising an email review interface comprising a feedback entry field (para. [0042] box 316 allows a user to add a comment to the change. claim 1,5. sending the electronic message to at least a portion of the reviewers. creating the electronic message comprises including a comment area that is used to enter a comment); receiving, from a reviewer email account and via a first instance of the email review interface, a review response indicating at least one of: the feedback via a first instance of the feedback entry field (para. [0059] one or more replies may be received in response to the sent electronic message(s). a reply may be received from all/portion of the reviewers. fig. 3. para. [0040] reviewer… has received an email message summarizing changes that were made). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Meisels’ disclosure of providing an email comprising an email review interface comprising a feedback entry field such that the email of Lowe comprises an email review interface, and receiving, via instances of the email review interface, review responses indicating at least one of: the feedback from a plurality of reviewers. Meisels is also directed to providing an email for review by a plurality of reviewers. One of ordinary skill in the art would have been motivated to do so because Meisels would have improved Lowe by enabling collaborative editing on the email by reviewers and providing an area for comments. Ganta teaches generating an email comprising an email review interface comprising an approval selectable input (fig. 4, para. [0044] email 400 includes an approve button 401). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Ganta’s disclosure such that the email review interface further comprises an approval selectable input. One of ordinary skill in the art would have been motivated to do so because Lowe discloses providing users with a simple and quick method for implementing second person review (para. [0042]). It would have been desirable to have implemented Ganta’s disclosure of an approval button, which would have enabled a reviewer to efficiently indicate approval of the email. Willner teaches generating, by an email review system and based upon the review response from the reviewer email account, an email revision interface comprising a first selectable input associated with providing one or more reviewers with a revised version of the proposed email content, and a second selectable input associated with providing one or more intended recipients with a second email corresponding to the revised version of the proposed email content (para. [0035] user 46 may again select, via onscreen pointer 154, send draft button 156. para. [0038] receive 108 response email from 250 from the one or more specified reviewing recipients. fig. 6 see send button and draft button. para. [0042] send button). Lowe already discloses an interface comprising a first selectable input associated with providing one or more reviewers with a version of a proposed email content, and a second selectable input associated with providing one or more intended recipients with an email corresponding to the version of the proposed email content. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Willner’s disclosure such that an interface is provided with inputs to send the revised email to a reviewer or to recipient(s). One of ordinary skill in the art would have been motivated to do so because it would have been desirable to enable a user to conveniently send the revised email to the recipients or send the revised email for additional review by one or more reviewers. Regarding claim 3, Lowe in view of Meisels and Willner teach the method of claim 1, comprising: generating, by the email review system, a third email; and transmitting, by the email review system, the third email to the first email account, wherein the third email comprises at least one of: an indication of the feedback in the review response; or an indication of the approval indicator (Lowe: para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author). Meisels does not teach the third email comprising the email revision interface. Meisels discloses generating, by an email review system, a third email comprising an email revision interface; and transmitting, by the email review system, the third email to the first email account, wherein the third email comprises at least one of: an indication of the feedback in the review response (para. [0025] reviewer receiving the electronic message may accept/reject changes and/or make comments/text modifications to the document changes that are contained within the electronic message. para. [0032] may edit a document, such as document 232 on network share 230 that requires input from one or more reviewers (e.g. Reviewer 1 and Reviewer 2)). Meisels is similarly directed to providing an email for review to a plurality of reviewers. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Willner with Meisels’ disclosure of providing an email comprising an email review interface comprising indication of a feedback. One of ordinary skill in the art would have been motivated to do so in order to have provided an area to view edits from a reviewer. Regarding claim 4, Lowe in view of Meisels, Ganta, and Willner teach the method of claim 3, wherein: the method comprises: receiving, from the first email account and via the email revision interface, a revised version of the proposed email content (Lowe: para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author. para. [0061] reviewed email may be viewable by the author); and transmitting the fourth email to the reviewer email account (para. [0062] author may select second icon 510 and skip review icon 612. fig. 6 also shows “Send for Review” icon 616, which suggests that the revised email may be send for review. fig. 10; para. [0064] send for review. Willner: see above for “send” button and “draft” button). Lowe does not teach generating, based upon the revised version of the proposed email content, a fourth email comprising: the revised version of the proposed email content; and a second email review interface comprising: a second feedback entry field; and a second approval selectable input; and transmitting the fourth email to the reviewer email account. Meisels teaches generating, based upon a revised version of the proposed email content, an email comprising: a revised version of a proposed email content; and a second email review interface comprising: a second feedback entry field (para. [0042] box 316 allows a user to add a comment to the change. para. [0059] one or more replies may be received in response to the sent electronic message(s). reply may be received from all/portion of the reviewers. fig. 3. para. [0040] reviewer… has received an email message summarizing changes that were made. claim 1. sending the electronic message to at least a portion of the reviewers. claim 5. creating the electronic message comprises including a comment area that is used to enter a comment). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Meisels’ disclosure of providing an email comprising an email review interface comprising a feedback entry field. One of ordinary skill in the art would have been motivated to do so because Meisels would have improved Lowe by enabling collaborative editing on the email by the plurality of reviewers and providing an area for comments. Ganta teaches generating an email comprising an email review interface comprising an approval selectable input (fig. 4, para. [0044] email 400 includes an approve button 401). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Ganta’s disclosure such that the email review interface further comprises an approval selectable input. One of ordinary skill in the art would have been motivated to do so because Lowe discloses providing users with a simple and quick method for implementing second person review (para. [0042]). Ganta’s disclosure of providing an approval button would have enabled the reviewer to efficiently indicate approval of the contents of the email. Regarding claim 15, Lowe in view of Meisels, Ganta, and Willner teach the computing device of claim 14, the operations comprising: generating a third email comprising the email revision interface; and transmitting the third email to the first email account (Lowe: para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author. Meisels: see fig. 5, 6. para. [0047],[0048] electronic message… comment box). Regarding claim 16, Lowe in view of Meisels, Ganta, and Willner teach the computing device of claim 15, wherein: the third email comprises at least one of: an indication of the feedback in the review response; or an indication of the approval indicator (Lowe: para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author. para. [0061] reviewed email may be viewable by the author. Meisels: see fig. 5, 6. para. [0047],[0048] electronic message… comment box). Regarding claim 17, Lowe in view of Meisels, Ganta, and Willner teach the computing device of claim 16, wherein: the operations comprise: receiving, from the first email account and via the email revision interface, a revised version of the proposed email content; generating, based upon the revised version of the proposed email content, a fourth email; and transmitting the fourth email to the reviewer email account (Lowe: para. [0062] author may select second icon 510 and skip review icon 612. fig. 6 also shows “Send for Review” icon 616, which suggests that the revised email may be send for review. fig. 10; para. [0064] send for review. Willner: see above for “send” button and “draft” button). Lowe does not teach generating, based upon the revised version of the proposed email content, a fourth email comprising: the revised version of the proposed email content; and a second email review interface comprising: a second feedback entry field; and a second approval selectable input; and transmitting the fourth email to the reviewer email account. Meisels teaches generating, based upon a revised version of the proposed email content, an email comprising: a revised version of a proposed email content; and a second email review interface comprising: a second feedback entry field (para. [0042] box 316 allows a user to add a comment to the change. para. [0059] one or more replies may be received in response to the sent electronic message(s). reply may be received from all/portion of the reviewers. fig. 3. para. [0040] reviewer… has received an email message summarizing changes that were made. claim 1. sending the electronic message to at least a portion of the reviewers. claim 5. creating the electronic message comprises including a comment area that is used to enter a comment). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Meisels’ disclosure of providing an email comprising an email review interface comprising a feedback entry field. One of ordinary skill in the art would have been motivated to do so because Meisels would have improved Lowe by enabling collaborative editing on the email by the plurality of reviewers and providing an area for comments. Ganta teaches generating an email comprising an email review interface comprising an approval selectable input (fig. 4, para. [0044] email 400 includes an approve button 401). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Ganta’s disclosure such that the email review interface further comprises an approval selectable input. One of ordinary skill in the art would have been motivated to do so because Ganta’s disclosure of providing an approval button would have enabled the reviewer to efficiently indicate approval of the email. Regarding claim 20, Lowe in view of Meisels, Ganta, and Willner teach the non-transitory machine readable medium of claim 19, the operations comprising: generating a third email comprising the email revision interface; and transmitting the third email to the first email account (Lowe: para. [0060] select review complete option 810 to send the email, including any changes to body 801… back to the author. Meisels: see fig. 5, 6. para. [0047],[0048] electronic message… comment box). Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, and Harris et al. US Patent Publication No. 2013/0326330 (“Harris”). Regarding claim 2, Lowe does not teach the method of claim 1, wherein: the email revision interface concurrently displays a third selectable input for at least one of accepting or rejecting the one or more suggestions from the reviewer email account. Harris teaches an email revision interface concurrently displays a third selectable input for at least one of accepting or rejecting one or more suggestions from the reviewer email account (see fig. 2A. para. [0044] editor 108 can select to accept or reject each suggested edit 222a or 222b by selecting the appropriate option in box 224a and 224b). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Harris’ disclosure of generating a revision interface that displays inputs for accepting or rejecting suggests from reviewers such that inputs for accepting or rejecting suggestions are provided for the feedbacks from reviewer accounts as disclosed by Lowe and Meisels. One of ordinary skill in the art would have been motivated to do so for a benefit of for tracking changes so that an author may conveniently view and manage edits within the message. Claims 5, 7, and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, and Lu US Patent Publication No. 2015/0341303 (“Lu”). Regarding claim 5, Lowe in view of Meisels, Ganta, and Willner teach the method of claim 1, wherein: the review initiation request is indicative of an intended recipient of the proposed email content. (Lowe: see fig. 10 “To:”). Lowe does not teach the method comprises: determining, based upon the review response, whether an approval condition associated with the proposed email content is met; and in response to determining that the approval condition is met, transmitting a third email, comprising the proposed email content, to the intended recipient. Lu teaches determining, based upon a review response, whether an approval condition associated with a proposed email content is met; and in response to determining that the approval condition is met, transmitting an email, comprising the proposed email content, to an intended recipient (para. [0021] supervisory recipient… provided with a viewing screen having one or more control panels that allow supervisory recipient to approve or reject the electronic message for receipt by intended recipient 150. para. [0022] approval may include a manual procedure performed by supervisory recipient 160 such as entering a command or pressing a key. para. [0023] automatically routing the electronic message to the intended recipient if the message is deemed acceptable for forwarding). Lu comes from a similar field of endeavor of transmitting a message to a reviewer for review and approval. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Lu’s disclosure. One of ordinary skill in the art would have been motivated to do for a benefit of automatic routing of approved messages. Regarding claim 7, Lowe does not teach the method of claim 5, wherein: determining that the approval condition is met is based upon a determination that the review response comprises the approval indicator. Lu teaches determining that an approval condition is met is based upon a determination that the review response comprises the approval indicator (para. [0021] supervisory recipient… provided with a viewing screen having one or more control panels that allow supervisory recipient to approve or reject the electronic message for receipt by intended recipient 150. para. [0022] approval may include a manual procedure performed by supervisory recipient 160 such as entering a command or pressing a key. automatically routing the electronic message to the intended recipient if the message is deemed acceptable for forwarding). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Lu’s disclosure of determining that an approval condition is met based upon a determination that the review response comprises the approval indicator. One of ordinary skill in the art would have been motivated to do for a benefit of identifying approved messages and providing automatic routing of approved messages. Regarding claim 18, Lowe in view of Meisels, Ganta, and Willner teach the computing device of claim 14, wherein: the review initiation request is indicative of an intended recipient of the proposed email content (see fig. 10 “To:”). Lowe does not teach the operations comprise: determining, based upon the review response, whether an approval condition associated with the proposed email content is met; and in response to determining that the approval condition is met, transmitting a third email, comprising the proposed email content, to the intended recipient. Lu teaches determining, based upon a review response, whether an approval condition associated with a proposed email content is met; and in response to determining that the approval condition is met, transmitting an email, comprising the proposed email content, to an intended recipient (para. [0021] supervisory recipient… provided with a viewing screen having one or more control panels that allow supervisory recipient to approve or reject the electronic message for receipt by intended recipient 150. para. [0022] approval may include a manual procedure performed by supervisory recipient 160 such as entering a command or pressing a key. para. [0023] automatically routing the electronic message to the intended recipient if the message is deemed acceptable for forwarding). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Lu’s disclosure. One of ordinary skill in the art would have been motivated to do for a similar benefit of providing automatic routing of approved messages. Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, Lu, and O’Sullivan et al. US Patent Publication No. 2008/0140784 (“O’Sullivan”). Regarding claim 6, Lowe does not teach the method of claim 5, wherein: transmitting the third email to the intended recipient is performed based upon a determination that the review initiation request indicates enablement of an automatic delivery-upon-approval function. O’Sullivan teaches transmitting an email to an intended recipient based upon a determination that a review initiation request indicates enablement of an automatic delivery-upon-approval function (para. [0033] depending upon preferences established by the original sender 135, the message 170… can be sent directly to the messaging client 130 of the recipient 150 from the messaging client 125 without first being routed back to the original sender 135. see fig. 5. para. [0038] allow the original sender to specify how the message is to be handled. cause the messaging system to send the message back to the original sender prior to delivering the message to the recipient. once the additional sender provides approval…the message can be sent back to the messaging client corresponding to Joe Smith). O’Sullivan is also directed to providing a message for review and approval. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with O’Sullivan’s disclosure of transmitting an email to an intended recipient based upon a determination that a review initiation request indicates enablement of an automatic delivery-upon-approval function. One of ordinary skill in the art would have been motivated to do so because it would have been desirable to have provided options to have allowed a sender to control how messages are to be handled and provided efficient delivery of messages. Claims 8-9 are rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, O’Sullivan et al. US Patent Publication No. 2008/0140784 (“O’Sullivan”), and Yurchenko US Patent Publication No. 2013/0342635 (“Yurchenko”). Regarding claim 8, Lowe in view of Meisels, Ganta, and Willner teach the method of claim 1, wherein: the review initiation request is indicative of an intended recipient of the proposed email content. Lowe does not teach the method comprises: determining, based upon the review response, whether an approval condition associated with the proposed email content is met; in response to determining that the approval condition is met, transmitting a third email to the first email account, wherein the third email comprises: the proposed email content; an indication that the proposed email content is approved; and an email delivery selectable input; and in response to receiving a selection of the email delivery selectable input, transmitting a fourth email, comprising the proposed email content, to the intended recipient. O’Sullivan teaches determining, based upon the review response, whether an approval condition associated with the proposed email content is met; in response to determining that the approval condition is met, transmitting a second email to the first email account, wherein the second email comprises: the proposed email content; an indication that the proposed email content is approved (para. [0038] once the additional sender provides approval…the message can be sent back to the messaging client corresponding to Joe Smith); and in response to receiving a selection of an email delivery selectable input, transmitting a third email, comprising the proposed email content, to the intended recipient (para. [0059] once the original sender provides an input indicating approval, the message can be sent to the recipient from the messaging client of the original sender). O’Sullivan is also directed to providing a message for review and approval. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with O’Sullivan’s disclosure of transmitting an email, comprising the proposed email content, to the intended recipient transmitting an email to an intended recipient in response to receiving a selection. One of ordinary skill in the art would have been motivated to do so in order to have allowed a sender to control how messages are to be handled and enabled sending of the message by the sender. O’Sullivan suggests an email delivery selectable input as the sender is able to provide input to send the message to the recipient. However, O’Sullivan does not expressly disclose the email comprising an email delivery selectable input. Yurchenko discloses providing an email comprising a selectable input; and receiving a selection of the selectable input (para. [0051] email including selectable buttons). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and O’Sullivan with Yurchenko’s disclosure of providing an email with a selectable button such that an email delivery button is provided with the email. One of ordinary skill in the art would have been motivated to do so because O’Sullivan discloses providing input to send the approved email, and it would have been convenient to the sender to be provided with a selectable input to input the sending of the email. Regarding claim 9, Lowe does not teach the method of claim 8, wherein: transmitting the third email to the first email account is performed based upon a determination that the review initiation request indicates disablement of an automatic delivery-upon-approval function associated with automatic transmission of the proposed email content to the intended recipient in response to the approval condition being met. O’Sullivan teaches transmitting an email to a first email account is performed based upon a determination that the review initiation request indicates disablement of an automatic delivery-upon-approval function associated with automatic transmission of the proposed email content to the intended recipient in response to the approval condition being met (para. [0033] depending upon preferences established by the original sender 135, the message 170… can be sent directly to the messaging client 130 of the recipient 150 from the messaging client 125 without first being routed back to the original sender 135. see fig. 5. para. [0038] allow the original sender to specify how the message is to be handled. cause the messaging system to send the message back to the original sender prior to delivering the message to the recipient. once the additional sender provides approval…the message can be sent back to the messaging client corresponding to Joe Smith). O’Sullivan is also directed to providing a message for review and approval. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with O’Sullivan’s disclosure of transmitting an email to a first email account based upon a determination that the review initiation request indicates disablement of an automatic delivery-upon-approval function associated with automatic transmission of the proposed email content to the intended recipient in response to the approval condition being met. One of ordinary skill in the art would have been motivated to do so in order to have allowed a sender to control how messages are to be handled. Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, and Vagell et al. US Patent Publication No. 2019/0361964 (“Vagell”) Regarding claim 10, Lowe does not teach the method of claim 1, wherein: at least some of a first representation of the one or more suggestions from the reviewer email account is displayed between a first portion of the proposed email content and a second portion of the proposed email content. Vagell discloses at least some of a first representation of one or more suggestions from a reviewer account displayed between a first portion of proposed content and a second portion of the proposed content (fig. 3. see edits from at least reviewer A, C, editor D. fig. 6; para. [0051] see edits within the markup version of document. see fig. 8; para. [0059] suggested edits from reviewers A-C and editor D. suggested edit from user, and markup version of document. all the suggested edits may be shown in the display. Note: One of ordinary skill in the art would have recognized that the edits may occur on any text of the document, e.g., within the middle of a paragraph). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Meisels with Vagell’s disclosure. One of ordinary skill in the art would have been motivated to do so for benefits of enabling a user to clearly identify the suggested edits within the document. Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, and Burkholder et al. US Patent Publication No. 2007/0038717 (“Burkholder”). Regarding claim 11, Lowe does not teach the method of claim 1, wherein: generating the email comprises including, in the email, dynamic email content comprising the email review interface based upon a determination that the reviewer email account is associated with a dynamic email function. Burkholder teaches generating an email comprises including, in an email, dynamic email content comprising an email interface based upon a determination that a reviewer email account is associated with a dynamic email function (para. [0071] determines, based on a comparison of the recipient's email with rules stored in the rules database, whether the recipient is likely to support FLASH (or other equivalent web-animation and interface software. HTML email is generated in step 108, with the FLASH (or other equivalent web-animation and interface software) template embedded in it). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe, Meisels, and Ganta with Burkholder’s disclosure. One of ordinary skill in the art would have been motivated to do so in order to have provided an email in a format that is supported by the recipient. Claims 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over Lowe in view of Meisels, Ganta, Willner, Burkholder and Innocenti et al. US Patent Publication No. 2021/0203771 (“Innocenti”). Regarding claim 12, Lowe does not teach the method of claim 11, wherein: the review initiation request is indicative of a third reviewer of the proposed email content; and the method comprises: generating, based upon the review initiation request, a static email comprising the proposed email content; and transmitting the static email to a third reviewer email account associated with the third reviewer. Innocenti teaches a review initiation request indicative of a third reviewer of a proposed email content; generating, based upon the review initiation request, an email comprising the proposed email content; and transmitting the email to a third reviewer email account associated with the third reviewer (para. [0021] identifies and/or selects users as reviewers. receiving a request to facilitate a review of the message. para. [0063] reviewers… include one or more users within a list of contacts stored by the mobile device associated with the user). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Innocenti’s disclosure of providing a review request indicating a second reviewer and transmitting the email to the second reviewer. One of ordinary skill in the art would have been motivated to do so because it would have been desirable for a user to be able to specify and request review of the email by a plurality of reviews. Burkholder teaches providing a static email comprising email content (para. [0071] determines, based on a comparison of the recipient's email with rules stored in the rules database, whether the recipient is likely to support FLASH. HTML or text-only email is generated). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe and Innocenti with Burkholder’s disclosure. One of ordinary skill in the art would have been motivated to do so in order to have provided an email in a format that is supported by the recipient. Regarding claim 13, Lowe does not teach the method of claim 12, wherein: the dynamic email content is not included in the static email based upon a determination that the third reviewer email account is not associated with a dynamic email function. Burkholder teaches dynamic email content not being included in the static email based upon a determination that the third reviewer email account is not associated with a dynamic email function (para. [0071] determines, based on a comparison of the recipient's email with rules stored in the rules database, whether the recipient is likely to support FLASH. HTML or text-only email is generated). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Lowe with Burkholder’s disclosure. One of ordinary skill in the art would have been motivated to do so in order to have provided an email in a format that is supported by the recipient. Conclusion A shortened statutory period for reply to this Office action is set to expire THREE MONTHS from the mailing date of this action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Joshua Joo whose telephone number is (571)272-3966. The examiner can normally be reached Monday-Friday 7am-3pm. 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, Oscar Louie can be reached at 571-270-1684. 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. /JOSHUA JOO/Primary Examiner, Art Unit 2445
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Prosecution Timeline

Feb 24, 2025
Application Filed
Jun 09, 2026
Non-Final Rejection mailed — §103 (current)

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