Prosecution Insights
Last updated: October 26, 2026
Application No. 19/191,841

UNIFIED MESSAGE SEARCH

Final Rejection §101§112
Filed
Apr 28, 2025
Priority
May 17, 2016 — continuation of 10/795,947 +3 more
Examiner
CORRIELUS, JEAN M
Art Unit
2159
Tech Center
2100 — Computer Architecture & Software
Assignee
Google LLC
OA Round
2 (Final)
84%
Grant Probability
Favorable
3-4
OA Rounds
1y 3m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 84% — above average
84%
Career Allowance Rate
871 granted / 1036 resolved
+29.1% vs TC avg
Moderate +12% lift
Without
With
+12.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
30 currently pending
Career history
1072
Total Applications
across all art units

Statute-Specific Performance

§101
22.7%
-17.3% vs TC avg
§103
34.5%
-5.5% vs TC avg
§102
13.9%
-26.1% vs TC avg
§112
16.0%
-24.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1036 resolved cases

Office Action

§101 §112
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This office action is in response to the claimed amendment filed on August 03, 2026, in which claims 1-20 are presented for further examination. Response to Arguments Applicants’ arguments with respect to claims 1-20 have been considered but are moot in view of a new ground of rejection necessitated by amendment. Remark The independent claims 1, 11 and 20 recite “a first graphical user interface (GUI) element that is to be rendered at a single unified GUI” and “the first GUI element is to be rendered”. The phrase “is to be” introduces ambiguity as to whether the operation that follows will actually be executed or performed. Furthermore, the phrase “is to be” is abstract and does not render the claims eligible and patenting under 35 USC 101. The 35 USC 101 rejection set forth in the last office action is hereby sustained. Specification The amendment to specification filed on August 03, 2026, has been entered in the application file. The information provided therein has been considered as to the merits. The objection to the specification set forth in the last office action has been withdrawn. Double Patenting The terminal disclaimer filed on August 03, 2026, has been entered in the application file. The information provided therein has been considered as to the merits. The double patenting rejection set forth in the last office action has been withdrawn. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-20 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. The independent claims 1, 11 and 20 recite “a first graphical user interface (GUI) element that is to be rendered at a single unified GUI” and “the first GUI element is to be rendered”. The phrase “is to be” introduces ambiguity as to whether the operation that follows will actually be executed or performed. The independent claims 1, 11 and 20 also recite “generating, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element that is to be rendered at a single unified GUI”. However, the claims fail to specify an outcome under the condition in which the plurality of messages does not satisfy the threshold quantity. Claims 2-10 and 12-19 are rejected for incorporating, by dependency, the deficiencies of their respective base claims. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract without significantly more. Step 1, Statutory Category: Claims 1-10 are directed to a method Claims 11-19 are directed to a system. Claim 20 is directed to a non-transitory computer readable medium. Therefore, claims 1-20 fall into at least one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. Step 2A, Prong One (Judicial exception recited) The limitation “determining, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages” in claims 1, 11 and 20, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement, but for the recitation of generic computer components. One can manually with the aid of pen and paper determine whether a plurality of messages satisfies a threshold quantity of messages based on processing the message data. The limitation “generating, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element that is to be rendered at a single unified GUI, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages, and wherein the first GUI element is generated based on one or more dimensions of the single unified GUI at which the first GUI element is to be rendered” in claims 1, 11 and 20, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement, but for the recitation of generic computer components. One can manually with the aid of pen and paper generate a first graphical user interface (GUI) element that is to be rendered at a single unified GUI in response to determining that the plurality of messages satisfies a threshold quantity of messages. Step 2A, Prong Two (Integrated into a practical application): This judicial exception is not integrated into a practical application. In particular, the claims recite the following additional elements: The limitation “obtaining, by the one or more computing devices, message data comprising a plurality of messages” amounts to data-gathering steps which is considered to be insignificant extra-solution activity, (See MPEP 2106.05(g)). The limitation “causing the first GUI element to be rendered for presentation to a user.” recites insignificant extra-solution activity such as mere outputting of the result. The mere outputting of data does not meaningfully limit the abstract idea. Viewing the additional limitations together and the claim as a whole, nothing provides integration into a practical application. (See MPEP 2106.05 (g)). The limitation “memory, one or more processors, one or more computing devices and non-transitory computer readable storage medium” are recited at a high level of generality such that they amount to on more than mere instructions to apply the exception using a generic component. (see MPEP 2106.05(f)). These limitations can also be viewed as nothing more than an attempt to generally link the use of the judicial exception to the technological environment of a computer (see MPEP 2106.05(h)). Note, the mere instructions to apply an exception on a generic computer cannot integrate a judicial exception into a practical application. Step 2B (claim provides an inventive concept): With respect to the recited “obtaining, by the one or more computing devices, message data comprising a plurality of messages” identified as insignificant extra-solution activity above, which include the data-gathering, when re-evaluated this element is well-understood, routine, and conventional as evidenced by the court cases in MPEP 2106.05(d)(II), "i. Receiving or transmitting data over a network, e.g., using the Internet to gather data, Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); … OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network);" and thus remains insignificant extra-solution activity that does not provide significantly more. With respect to the recited “causing the first GUI element to be rendered for presentation to a user” identified as insignificant extra-solution activity above when re-evaluated this element is well-understood, routine, and conventional as evidenced by the court cases in MPEP 2106.05(d)(II), " iv. Presenting offers and gathering statistics, OIP Techs., 788 F.3d at 1362-63, 115 USPQ2d at 1092-93" and "i. … transmitting data over a network, …Symantec, 838 F.3d at 1321, 120 USPQ2d at 1362 (utilizing an intermediary computer to forward information); … OIP Techs., Inc., v. Amazon.com, Inc., 788 F.3d 1359, 1363, 115 USPQ2d 1090, 1093 (Fed. Cir. 2015) (sending messages over a network); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350, 1355, 112 USPQ2d 1093, 1096 (Fed. Cir. 2014) (computer receives and sends information over a network)". With respect to the “memory, one or more processors, one or more computing devices and non-transitory computer readable storage medium” amount to elements that have been recognized as well-understood, routine, and conventional activity in particular fields, as demonstrate by: Relevant court decision: the followings are examples of court decisions demonstrating well-understood, routine and conventional activities, see e.g., MPEP 2106.05(d)(II) and MPEP 2106.05(f)(2): Computer readable storage media comprising instructions to implement a method, e.g., see Versata Dev. Group, Inc. v. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015). The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the additional elements when considered both individually and as an ordered combination do not amount to significantly more than the abstract idea. Looking at the claim as a whole does not change this conclusion and the claim appears to be ineligible. Accordingly, claim 1 is directed to an abstract idea. The remaining independent claims 11 and 20 fall short the 35 USC 101 requirement under the same rationale. The dependent claims 2-10 and 12-19 when analyzed and each taken as a whole are held to be patent ineligible under 35 USC 101 because the additional recited limitations fail to establish that the claims are not directed to an abstract idea. Claim 2 recites “generating, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a second GUI element, wherein the second GUI element includes a second summary of one or more additional messages of the plurality of messages”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. The recited “causing the second GUI element to be rendered for presentation to the user” identified as insignificant extra-solution activity such as mere outputting of the result. The mere outputting of data does not meaningfully limit the abstract idea. Viewing the additional limitations together and the claim as a whole, nothing provides integration into a practical application. (See MPEP 2106.05 (g)). Claim 3 recites “determining that the one or more messages of the plurality of messages were received using a first application; and determining that the one or more additional messages of the plurality of messages were received using a second application”. These limitations, as drafted, are processes that, under their broadest reasonable interpretation, cover a mental process as a form of evaluation or judgement. Claim 4 recites “wherein generating the first GUI element is based on determining that the one or more messages of the plurality of messages were received using the first application and wherein generating the second GUI element is based on determining that the one or more additional messages of the plurality of messages were received using the second application”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. Claim 5 recites “wherein causing the first GUI element to be rendered for presentation to the user includes causing the first summary to be presented to the user using an audio interface” identified as insignificant extra-solution activity such as mere outputting of the result. The mere outputting of data does not meaningfully limit the abstract idea. Viewing the additional limitations together and the claim as a whole, nothing provides integration into a practical application. (See MPEP 2106.05 (g)). Claim 6 recites “wherein causing the first GUI element to be rendered for presentation to the user comprises providing the first GUI element for output by a display device” identified as insignificant extra-solution activity such as mere outputting of the result. The mere outputting of data does not meaningfully limit the abstract idea. Viewing the additional limitations together and the claim as a whole, nothing provides integration into a practical application. (See MPEP 2106.05 (g)). Claim 7 recites “wherein the first summary includes at least a portion of each of one or more messages of the plurality of messages”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. Claim 8 recites “wherein the first summary includes an indication of one or more senders of at least one message of the one or more messages in the plurality of messages”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. Claim 9 recites “determining that the plurality of messages were received within a particular period of time”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. The recited “obtaining, in response to determining that the plurality of messages were received within the particular period of time, the message data comprising the plurality of messages” identified as data-gathering steps which is considered to be insignificant extra-solution activity, (See MPEP 2106.05(g)). Claim 10 recites “wherein obtaining the message data comprises identifying, as the plurality of messages, messages associated with a specific sender, specific recipient, and/or specific messaging platform” identified as data-gathering steps which is considered to be insignificant extra-solution activity, (See MPEP 2106.05(g)). As to claims 12-19, the same analysis of the rejection of claims 2-10 above is also applied to claims 12-19. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. CN-120340446-A (involved in generating music content including at least lyric content and music creation content using a Generating Model (GM). The processor of the system may: receiving a user input associated with the user ' s client device, the user input including a request for music content; generating music content; and causing the music content to be audibly rendered at the client device). US 20170142056 (involved in retrieving (802) a first electronic mail (email) that is originated from a user of an email service and a second email destined to the user of the email service. A first summary data of the first email and a second summary data of the second email are identified by an electronic device. A first and a second message element are generated that are associated with the first and the second email respectively. A display of the first and the second message element is triggered concurrently.) US 20170142049 (involved in acquiring multiple emails from the server. The grouped message element is generated. The individual message element is generated. Determination is made that the individual email is not associated with the grouped message element. The grouped message element and the individual message element are displayed, concurrently such that the grouped message element is visually distinguishable from the individual message element. The portion of a most recent email is displayed within the group of emails.) US 20160182430 (involved in displaying summaries of messages within a summary pane of a messaging user interface (UI). An action activating an importance filter control is detected, where the importance filter control includes operations to identify a subset of the summaries associated with the messages classified as important. The messages are processed to identify the messages classified as important. The subset of the summaries corresponding to the messages classified as important is displayed, while hiding a remaining subset of the summaries on the summary pane.) US 20160065521 (involved in representing an event type or entity by single graphic compilation, where a first discrete portion of the compilation includes content from a data source, and a second discrete portion of the compilation includes a listing of event items in a set of event items. A listing of a set of objects is included in a third discrete portion of the single graphic compilation, where each object in the set of objects is synopsis of a respective message in subset of messages. The compilation is sent to a remote client device associated with a user). US 20150082189 (involved in detecting multiple items received through a communication application. The initial visualization is displayed for new and unread items displayed on a user interface of the communication application. The selection of an item is detected from multiple items. The selected item is updated to display a new visualization in which the new visualization for the selected item provides summary information about the selected item on the user interface. The new visualization is selected from a collection of templates.) Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JEAN M CORRIELUS whose telephone number is (571)272-4032. The examiner can normally be reached Monday-Friday 6:30a-10p(Midflex). 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, Ann J Lo can be reached at (571)272-9767. 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. /JEAN M CORRIELUS/Primary Examiner, Art Unit 2159 October 3, 2026
Read full office action

Prosecution Timeline

Apr 28, 2025
Application Filed
May 01, 2026
Non-Final Rejection mailed — §101, §112
Aug 03, 2026
Examiner Interview Summary
Aug 03, 2026
Response Filed
Aug 03, 2026
Applicant Interview (Telephonic)
Oct 06, 2026
Final Rejection mailed — §101, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
84%
Grant Probability
97%
With Interview (+12.5%)
2y 9m (~1y 3m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 1036 resolved cases by this examiner. Grant probability derived from career allowance rate.

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