Prosecution Insights
Last updated: May 29, 2026
Application No. 19/191,841

UNIFIED MESSAGE SEARCH

Non-Final OA §101§DOUBLEPATENT§DP
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
1 (Non-Final)
84%
Grant Probability
Favorable
1-2
OA Rounds
1y 8m
Est. Remaining
98%
With Interview

Examiner Intelligence

Grants 84% — above average
84%
Career Allowance Rate
857 granted / 1018 resolved
+29.2% vs TC avg
Moderate +13% lift
Without
With
+13.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
22 currently pending
Career history
1045
Total Applications
across all art units

Statute-Specific Performance

§101
13.0%
-27.0% vs TC avg
§103
54.6%
+14.6% vs TC avg
§102
14.3%
-25.7% vs TC avg
§112
6.1%
-33.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1018 resolved cases

Office Action

§101 §DOUBLEPATENT §DP
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 invention filed on April 28, 2025, in which claims 1-20 are presented for examination. Information Disclosure Statement The information disclosure statement filed on October 15, 2025 and August 19, 2025 complies with the provisions of 37 CFR 1.97, 1.98 and MPEP § 609. It has been placed in the application file. The information referred to therein has been considered as to the merits. Specification The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed. 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. At Step 1: With respect to subject matter eligibility under 35 USC 101, it is determined that the claims are directed to one of the four statutory categories of invention, i.e., process, machine, manufacture, or composition of matter. At Step 2A, Prong One: 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 mentally or manually with the aid of pen and paper determine a plurality of messages that satisfies a threshold quantity of messages. 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, wherein the first GUI element includes a first summary of one or more messages of the plurality 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 mentally or manually with the aid of pen and paper generate a graphical user interface (GUI) element. If a claim limitation, under its broadest reasonable interpretation, covers mental processes but for the recitation of generic computer components, then it falls within the "Mental Processes" grouping of abstract ideas (concepts performed in the human mind including an observation, evaluation, judgement, and opinion). Accordingly, the claim recites an abstract idea. At Step 2A, Prong Two: This judicial exception is not integrated into a practical application. In particular, the claims recite the following additional elements: That the method is "implemented by a computing system” is a high-level recitation of a generic computer components and represents mere instructions to apply on a computer as in MPEP 2106.05(f), which does not provide integration into a practical application. 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 “a memory, one or more processors 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. At Step 2B: The conclusions for the mere implementation using a computer are carried over and does not provide significantly more. With respect to the "obtaining ….." 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), "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 “causing …..” identified as insignificant extra-solution activity above when re-evaluated this element is well-understood, routine, and conventional in displaying information 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 “processor and non-transitory computer-readable storage me a memory, one or more processors and non-transitory computer readable storage medium dia” 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 claim 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; and causing the second GUI element to be rendered for presentation to the user”. This additional element is recited at a high level of generality and would function in its ordinary capacity for causing the second GUI element to be rendered for presentation to the user, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. 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”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. 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. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. 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”. This additional element is recited at a high level of generality and would function in its ordinary capacity for causing the first GUI element to be rendered for presentation, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. 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”. This additional element is recited at a high level of generality and would function in its ordinary capacity for providing the first GUI element for output by a display device, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. 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. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. 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. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. Claim 9 recites “wherein obtaining the message data comprising the plurality of messages comprises: determining that the plurality of messages were received within a particular period of time; and 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”. This additional element is recited at a high level of generality and would function in its ordinary capacity for obtaining the message data comprising the plurality of messages, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. 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”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. Claim 12 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; and causing the second GUI element to be rendered for presentation to the user”. This additional element is recited at a high level of generality and would function in its ordinary capacity for causing the second GUI element to be rendered for presentation to the user, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. Claim 13 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”. This limitation, as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process as a form of evaluation or judgement. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. Claim 14 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. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. Claim 15 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”. This additional element is recited at a high level of generality and would function in its ordinary capacity for causing the first GUI element to be rendered for presentation, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. Claim 16 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”. This additional element is recited at a high level of generality and would function in its ordinary capacity for providing the first GUI element for output by a display device, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. Claim 17 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. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. Claim 18 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. There is no additional elements recited which tie the abstract idea into a practical application and does not amount to significant more than the identified judicial exception. Claim 19 recites “wherein obtaining the message data comprising the plurality of messages comprises: determining that the plurality of messages were received within a particular period of time; and 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”. This additional element is recited at a high level of generality and would function in its ordinary capacity for obtaining the message data comprising the plurality of messages, this additional element does not integrate the integrate the judicial exception into a practical application and does not amount to significantly more. 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 1-23 of U.S. Patent No. US 10795947. Although the claims at issue are not identical, they are not patentably distinct from each other because claims 1-20 under examination are obvious, respectively, by claims 1-23 of the reference Patent. Every limitations in the instant application under examination claims are recited in the conflicting reference patent claims, and the differences or additional limitations between the claims are highlighted below by underlining and bolding all limitations. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the independent claim 1 of the instant application to receive, by one or more processors, a query at a communications device; identify by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform and provide, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user, in order to identify multiple messages across multiple messaging platforms based on the search terms, and to present a single interface to enable a user to interact with the identified messages generated by multiple messaging platform, thereby allowing the user to search for messages generated across various communication platforms using a single search query. Note, such deviation would not interfere with the functionality of the claims that are already patented, and would achieve the same end result. Please, see the comparison table below: Application Patent 1. A method performed by one or more computing devices, the method comprising: obtaining, by the one or more computing devices, message data comprising a plurality of messages; determining, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages; generating, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages; and causing the first GUI element to be rendered for presentation to a user. 1. A computer-implemented method, comprising: receiving, by one or more processors, a query at a communications device; obtaining, by the one or more processors, message data responsive to the received query, the message data comprising a plurality of messages, the plurality of messages including messages respectively sent through different messaging platforms; identifying, by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform; determining, by the one or more processors, that a count of the identified first messages satisfies a threshold for a minimum number of messages, wherein the threshold is greater than one; in response to the determination that the count of the identified first messages satisfies the threshold, generating, by the one or more processors, a summary of the first messages sent through the first messaging platform, wherein the summary includes at least a portion of each of multiple of the first messages that were each sent through the first messaging platform; and in response to receiving the query, providing, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user. Claims 2-10 are rejected for incorporating the deficiency of their respective base claims by dependency. Application Patent 2. The method of claim 1, further comprising: 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; and causing the second GUI element to be rendered for presentation to the user. 3. The method of claim 2, further comprising: 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. 4. The method of claim 3, 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. 5. The method of claim 1, 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. 6. The method of claim 1, 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. 7. The method of claim 1, wherein the first summary includes at least a portion of each of one or more messages of the plurality of messages. 8. The method of claim 1, 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. 9. The method of claim 1, wherein obtaining the message data comprising the plurality of messages comprises: determining that the plurality of messages were received within a particular period of time; and 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. 10. The method of claim 1, 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. 2. The method of claim 1, wherein: the method further comprises receiving the first messages at the client device; the message data further comprises temporal data indicative of at least one of a time or date at which the communications device received each of the first messages; and the method includes generating a first interface element that includes the summary, comprising: establishing a chronological ordering of the received first messages based on the temporal data; and arranging portions of the first messages within the first interface element in accordance with the established chronological ordering. 3. The method of claim 2, wherein: the portions of the first messages comprise at least one of textual content or image data; and the first interface element further comprises a portion of the temporal data associated with an initial one of the first messages within the chronological ordering. 4. The method of claim 1, further comprising: presenting the summary in a first interface element of a user interface; detecting a user input associated with the presented first interface element; in response to the detected input, generating second interface elements associated with each of the first messages, the second interface elements comprising portions of corresponding ones of the first messages; modifying at least a portion of the user interface to include the second interface elements; and providing the modified user interface to the display device for presentation to the user. 5. The method of claim 1, wherein generating the summary comprises generating a digest card, the digest card providing a summary of the first messages. 6. The method of claim 1, further comprising: generating a first interface element of a user interface, wherein the first interface element includes the summary; identifying, from among the plurality of messages, second messages from a second messaging platform; determining that a count of the second messages fails to satisfy the threshold; and in response to determining that the count of the second messages fails to satisfy the threshold, generating a second interface element for each of the second messages, wherein each of the second interface elements comprises at least a portion of a different message of the second messages. 7. The method of claim 1, further comprising: generating, for a user interface, a first interface element including the summary; and generating, for the user interface, a second interface element that includes at least a portion of a second message of the plurality of messages. 8. The method of claim 7, wherein: the query comprises at least one keyword; the portion of the second message comprises textual content that includes the keyword; and the method further comprises modifying, within the second interface element, at least one visual characteristic of the textual content that includes the keyword. 9. The method of claim 7, wherein: the generated user interface includes the second interface element; and the method further comprises: detecting a user input associated with the second interface element; and in response to the detected input, at least one of (i) executing an application program associated with the messaging platform corresponding to the message indicated by the second interface element or (ii) performing operations that initiate an assistant flow. 10. The method of claim 1, further comprising: determining that a body of a second one of the messages exceeds a predetermined size; and in response to the determination, generating an interface element, different from the summary, that includes a portion of the body of the second message. 11. The method of claim 1, wherein: the summary is included in a first interface element of a user interface; the method further comprises generating a plurality of second interface elements for the user interface, the second interface elements being associated with corresponding second messages of the plurality of messages; the message data further comprises temporal data indicative of at least one of a time or date for each of the corresponding second messages; and the method further includes: establishing a chronological ordering of the second messages based on the temporal data; and arranging the second interface elements within the user interface in accordance with the established chronological ordering. 12. The method of claim 1, further comprising: receiving audio data at the communications device, the audio data comprising an utterance spoken by a user into a microphone of the communications device; and generating the query based on at least a portion of the received audio data. 13. The method of claim 1, further comprising: transmitting at least a portion of the received query to a computing system across a communications network; and receiving at least a portion of the message data from the computing system in response to the transmission. 14. The method of claim 1, wherein at least two of the plurality of messages are selected from a different one of the group consisting of: email, instant messaging, SMS/MMS text messaging, social networking application, and chat-based application. 15. The method of claim 1, wherein the plurality of messaging platforms comprise two or more from the group consisting of an email platform, a social-networking platform, a text messaging platform, an instant messaging platform, a text-based chat platform, a voice-based chat platform, and a video-based chat platform. 16. The method of claim 1, further comprising generating, by the one or more processors, a user interface that includes multiple sections, wherein each section corresponds with a single messaging platform and a first section of the multiple sections includes the summary. 17. The method of claim 1, wherein: each of multiple of the first messages are messages sent by different users through the first messaging platform, and the first messaging platform is an email platform, a social-networking platform, a text messaging platform, an instant messaging platform, a text-based chat platform, a voice-based chat platform, or a video-based chat platform. With respect to claim 11, one having ordinary skill in the art before the effective filing date of the claimed invention to modify the independent claim 11, of the instant application to receive, by one or more processors, a query at a communications device; identify by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform and provide, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user, in order to identify multiple messages across multiple messaging platforms based on the search terms, and to present a single interface to enable a user to interact with the identified messages generated by multiple messaging platform, thereby allowing the user to search for messages generated across various communication platforms using a single search query. Note, such deviation would not interfere with the functionality of the claims that are already patented, and would achieve the same end result. Application Patent 11. A system comprising: memory storing instructions; and one or more processors operable to execute the instructions to: obtain, by one or more computing devices, message data comprising a plurality of messages; determine, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages; generate, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages; and cause the first GUI element to be rendered for presentation to a user. 18. A communications device, comprising: at least one processor; and a memory storing executable instructions that, when executed by the at least one processor, causes the at least one processor to perform operations comprising: receiving a query; obtaining message data responsive to the received query, the message data comprising a plurality of messages, the plurality of messages including messages respectively sent through different messaging platforms; identifying, among the plurality of messages, multiple first messages that were each sent through a first messaging platform; and determining that a count of the identified first messages satisfies a threshold for a minimum number of messages, wherein the threshold is greater than one; in response to the determination that the count of the identified first messages satisfies the threshold, generating a summary of the first messages sent through the first messaging platform, wherein the summary includes at least a portion of each of multiple of the first messages that were each sent through the first messaging platform; and in response to receiving the query, providing the summary to at least one of a display device or an audio interface for presentation to a user. Claims 12-19 are rejected for incorporating the deficiency of their respective base claims by dependency. Application Patent 12. The system of claim 11, wherein one or more of the processors are further operable to: generate, 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; and cause the second GUI element to be rendered for presentation to the user. 13. The system of claim 12, wherein one or more of the processors are further operable to: determine that the one or more messages of the plurality of messages were received using a first application; and determine that the one or more additional messages of the plurality of messages were received using a second application. 14. The system of claim 13, 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. 15. The system of claim 11, wherein in causing the first GUI element to be rendered for presentation to the user, one or more of the processors are to cause the first summary to be presented to the user using an audio interface. 16. The system of claim 11, wherein in causing the first GUI element to be rendered for presentation to the user, one or more of the processors are to provide the first GUI element for output by a display device. 17. The system of claim 11, wherein the first summary includes at least a portion of each of one or more messages of the plurality of messages. 18. The system of claim 11, 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. 19. The system of claim 11, wherein in obtaining the message data comprising the plurality of messages, one or more of the processors are to: determine that the plurality of messages were received within a particular period of time; and obtain, 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. 19. The communications device of claim 18, wherein: the operations further comprise receiving the first messages at the client device; the message data further comprises temporal data indicative of at least one of a time or date for each of the first messages; and the operations further comprise: establishing a chronological ordering of the received first messages based on the temporal data; and arranging portions of the first messages in the summary in accordance with the established chronological ordering. 20. The communications device of claim 18, wherein the operations further comprise: presenting the summary in a first interface element of a user interface; detecting a user input associated with the presented first interface element; in response to the detected input, generating second interface elements associated with each of the first messages, the second interface elements comprising portions of corresponding ones of the first messages; modifying at least a portion of the user interface to include the second interface elements; and providing the modified user interface to the display device for presentation to the user. 21. The communications device of claim 18, wherein the operations further comprise: generating a first interface element of a user interface, wherein the first interface element includes the summary; identifying, from among the plurality of messages, second messages from a second messaging platform; determining that a count of the second messages fails to satisfy the threshold; and in response to determining that the count of the second messages fails to satisfy the threshold, generating second interface elements associated with each of the second messages, wherein each of the second interface elements comprises at least a portion of a different message of the second messages. 22. The communications device of claim 18, wherein at least two of the plurality of messages are from different communication platforms of the group consisting of: email, instant messaging, SMS/MMS text messaging, a social networking application, and a chat-based application. With respect to claim 20, one having ordinary skill in the art before the effective filing date of the claimed invention to modify the independent claim 20, of the instant application to receive, by one or more processors, a query at a communications device; identify by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform and provide, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user, in order to identify multiple messages across multiple messaging platforms based on the search terms, and to present a single interface to enable a user to interact with the identified messages generated by multiple messaging platform, thereby allowing the user to search for messages generated across various communication platforms using a single search query. Note, such deviation would not interfere with the functionality of the claims that are already patented, and would achieve the same end result. Application Patent 20. A non-transitory computer readable storage medium configured to store instructions that, when executed by one or more processors, cause one or more of the processors to: obtain, by one or more computing devices, message data comprising a plurality of messages; determine, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages; generate, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages; and cause the first GUI element to be rendered for presentation to a user. 23. One or more tangible, non-transitory computer-readable media storing instructions that, when executed by at least one processor of a client device, cause the client device to perform operations comprising: receiving a query at a communications device; obtaining message data responsive to the received query, the message data comprising a plurality of messages, the plurality of messages including messages respectively sent through different messaging platforms; identifying, from among the plurality of messages, multiple first messages that were each sent through a first messaging platform; determining that a count of the identified first messages satisfies a threshold for a minimum number of messages, wherein the threshold is greater than one; in response to the determination that the count of the identified first messages satisfies the threshold, generating a summary of the first messages sent through the first messaging platform, wherein the summary includes at least a portion of each of multiple of the first messages that were each sent through the first messaging platform; in response to receiving the query, providing the summary to at least one of a display device or an audio interface for presentation to a user. Claims 1-20 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-18 of U.S. Patent No. US 11562036. Although the claims at issue are not identical, they are not patentably distinct from each other because claims 1-20 under examination are obvious, respectively, by claims 1-18 of the reference Patent. Every limitations in the instant application under examination claims are recited in the conflicting reference patent claims, and the differences or additional limitations between the claims are highlighted below by underlining and bolding all limitations. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the independent claim 1 of the instant application to receive, by one or more processors, a query at a communications device; identify by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform and provide, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user, in order to identify multiple messages across multiple messaging platforms based on the search terms, and to present a single interface to enable a user to interact with the identified messages generated by multiple messaging platform, thereby allowing the user to search for messages generated across various communication platforms using a single search query. Note, such deviation would not interfere with the functionality of the claims that are already patented, and would achieve the same end result. Please, see the comparison table below: Application Patent 1. A method performed by one or more computing devices, the method comprising: obtaining, by the one or more computing devices, message data comprising a plurality of messages; determining, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages; generating, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages; and causing the first GUI element to be rendered for presentation to a user. 1. A method performed by one or more computing devices, the method comprising: receiving, by the one or more computing devices, data indicating a request from a user for message data, wherein the request from the user is a spoken request for message data; and in response to receiving the spoken request: obtaining, by the one or more computing devices, message data comprising a plurality of messages sent to the user within a predetermined time period prior to the spoken request, generating, by the one or more computing devices, a summary of the plurality of messages, wherein when the plurality of messages are obtained from different messaging applications: the summary divides the plurality of messages into groups with each group corresponding to one of the different messaging applications, and the summary in which the plurality of messages are divided into groups with each group corresponding to one of the different messaging applications is displayed at a single interface, and providing, by the one or more computing devices, the summary for presentation in a response to the request from the user. Claims 2-10 are rejected for incorporating the deficiency of their respective base claims by dependency. Application Patent 2. The method of claim 1, further comprising: 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; and causing the second GUI element to be rendered for presentation to the user. 3. The method of claim 2, further comprising: 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. 4. The method of claim 3, 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. 5. The method of claim 1, 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. 6. The method of claim 1, 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. 7. The method of claim 1, wherein the first summary includes at least a portion of each of one or more messages of the plurality of messages. 8. The method of claim 1, 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. 9. The method of claim 1, wherein obtaining the message data comprising the plurality of messages comprises: determining that the plurality of messages were received within a particular period of time; and 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. 10. The method of claim 1, 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. 2. The method of claim 1, comprising obtaining a transcription of the utterance of the user using a speech recognition module of the one or more computers; wherein the message data is obtained based on the transcription of the utterance. 3. The method of claim 1, wherein providing the summary for presentation comprises providing data causing the summary to be presented to the user using an audio interface. 4. The method of claim 1, wherein the summary includes at least a portion of each of multiple messages from the plurality of messages. 5. The method of claim 1, wherein the summary includes an indication of one or more senders of at least one message in the plurality of messages. 6. The method of claim 1, wherein the request is a request for e-mail messages, and the summary is a summary of e-mail messages. 7. The method of claim 6, wherein the e-mail messages are e-mail received within the predetermined time period prior to the request. 8. The method of claim 1, wherein providing the summary for presentation comprises providing the summary for output by a display device. 9. The method of claim 1, wherein providing the summary for presentation comprises providing a digest card that includes textual and graphical content characterizing multiple messages sent to the user. 10. The method of claim 1, wherein obtaining the messages comprises obtaining a set of messages that is limited to messages received within a particular period of time, wherein the particular period of time is not specified in the request. 11. The method of claim 10, wherein the particular period of time is a predetermined amount of time preceding the request. 12. The method of claim 10, wherein the request identifies at least one of a specific sender, specific recipient, or specific messaging platform; wherein obtaining the message data comprises identifying, as the plurality of messages, a plurality of messages associated with the specific sender, specific recipient, and/or specific messaging platform. With respect to claim 11, one having ordinary skill in the art before the effective filing date of the claimed invention to modify the independent claim 11, of the instant application to receive, by one or more processors, a query at a communications device; identify by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform and provide, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user, in order to identify multiple messages across multiple messaging platforms based on the search terms, and to present a single interface to enable a user to interact with the identified messages generated by multiple messaging platform, thereby allowing the user to search for messages generated across various communication platforms using a single search query. Note, such deviation would not interfere with the functionality of the claims that are already patented, and would achieve the same end result. Application Patent 11. A system comprising: memory storing instructions; and one or more processors operable to execute the instructions to: obtain, by one or more computing devices, message data comprising a plurality of messages; determine, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages; generate, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages; and cause the first GUI element to be rendered for presentation to a user. 13. A system comprising: one or more computing devices: and one or more computer-readable media that store instructions that, when executed by the one or more computing devices, cause the one or more computing devices to perform operations comprising: receiving, by the one or more computing devices, a spoken request from a user for message data, wherein the request from the user is a spoken request for message data; and in response to receiving the spoken request: obtaining, by the one or more computing devices, message data comprising a plurality of messages sent to the user within a predetermined time period prior to the spoken request, generating, by the one or more computing devices, a summary of the plurality of messages, wherein when the plurality of messages are obtained from different messaging applications: the summary divides the plurality of messages into groups with each group corresponding to one of the different messaging applications, and the summary in which the plurality of messages are divided into groups with each group corresponding to one of the different messaging applications is displayed at a single interface, and providing, by the one or more computing devices, the summary for presentation in a response to the request from the user. Claims 12-19 are rejected for incorporating the deficiency of their respective base claims by dependency. Application Patent 12. The system of claim 11, wherein one or more of the processors are further operable to: generate, 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; and cause the second GUI element to be rendered for presentation to the user. 13. The system of claim 12, wherein one or more of the processors are further operable to: determine that the one or more messages of the plurality of messages were received using a first application; and determine that the one or more additional messages of the plurality of messages were received using a second application. 14. The system of claim 13, 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. 15. The system of claim 11, wherein in causing the first GUI element to be rendered for presentation to the user, one or more of the processors are to cause the first summary to be presented to the user using an audio interface. 16. The system of claim 11, wherein in causing the first GUI element to be rendered for presentation to the user, one or more of the processors are to provide the first GUI element for output by a display device. 17. The system of claim 11, wherein the first summary includes at least a portion of each of one or more messages of the plurality of messages. 18. The system of claim 11, 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. 19. The system of claim 11, wherein in obtaining the message data comprising the plurality of messages, one or more of the processors are to: determine that the plurality of messages were received within a particular period of time; and obtain, 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. 14. The system of claim 13, comprising obtaining a transcription of the utterance of the user using a speech recognition module of the one or more computers; wherein the message data is obtained based on the transcription of the utterance. 15. The system of claim 13, wherein providing the summary for presentation comprises providing data causing the summary to be presented to the user using an audio interface. 16. The system of claim 13, wherein the summary includes at least a portion of each of multiple messages from the plurality of messages. 17. The system of claim 13, wherein the summary includes an indication of one or more senders of at least one message in the plurality of messages. . With respect to claim 20, one having ordinary skill in the art before the effective filing date of the claimed invention to modify the independent claim 20, of the instant application to receive, by one or more processors, a query at a communications device; identify by the one or more processors and from among the plurality of messages, multiple first messages that were each sent through a first messaging platform and provide, by the one or more processors, the summary to at least one of a display device or an audio interface for presentation to a user, in order to identify multiple messages across multiple messaging platforms based on the search terms, and to present a single interface to enable a user to interact with the identified messages generated by multiple messaging platform, thereby allowing the user to search for messages generated across various communication platforms using a single search query. Note, such deviation would not interfere with the functionality of the claims that are already patented, and would achieve the same end result. Application Patent 20. A non-transitory computer readable storage medium configured to store instructions that, when executed by one or more processors, cause one or more of the processors to: obtain, by one or more computing devices, message data comprising a plurality of messages; determine, based on processing the message data, that the plurality of messages satisfies a threshold quantity of messages; generate, in response to determining that the plurality of messages satisfies the threshold quantity of messages, a first graphical user interface (GUI) element, wherein the first GUI element includes a first summary of one or more messages of the plurality of messages; and cause the first GUI element to be rendered for presentation to a user. 18. One or more non-transitory computer-readable media that store instructions that, when executed by the one or more computing devices, cause the one or more computing devices to perform operations comprising: receiving, by the one or more computing devices, a spoken request from a user for message data, wherein the request from the user is a spoken request for message data; and in response to receiving the spoken request: obtaining, by the one or more computing devices, message data comprising a plurality of messages sent to the user within a predetermined time period prior to the spoken request, generating, by the one or more computing devices, a summary of the plurality of messages, wherein when the plurality of messages are obtained from different messaging applications: the summary divides the plurality of messages into groups with each group corresponding to one of the different messaging applications, and the summary in which the plurality of messages are divided into groups with each group corresponding to one of the different messaging applications is displayed at a single interface, and providing, by the one or more computing devices, the summary for presentation in a response to the request from the user. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 20060031340 (involved in helping manage the complexity of multi-media messaging over numerous devices, unified communications solutions consolidate different types of messages into a single platform). US 6430177 (involved a Universal Messaging system in accordance with the present invention comprises a messaging platform supporting an e-mail messaging system and a voice/fax messaging system, and content manager means for receiving information from a content provider and formatting the information into "multimedia containers" for distribution to remote clients via a wide area communications network such as the Internet.) 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 April 27, 2026
Read full office action

Prosecution Timeline

Apr 28, 2025
Application Filed
May 01, 2026
Non-Final Rejection mailed — §101, §DOUBLEPATENT, §DP (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12626091
MODULARIZED AND CORRELATION-BASED CONFIGURATION PROCESS FRAMEWORK FOR MACHINE LEARNING MODELS
3y 6m to grant Granted May 12, 2026
Patent 12619997
SYSTEM AND METHOD FOR GENERATING PERSONA DATA OBJECTS USING BIG DATA ANALYTICS
4y 5m to grant Granted May 05, 2026
Patent 12615226
DATABASE SYSTEMS AND RELATED MULTICHANNEL COMMUNICATION METHODS
2y 11m to grant Granted Apr 28, 2026
Patent 12613651
Quality of Service Management in a Distributed Storage System
2y 1m to grant Granted Apr 28, 2026
Patent 12596816
Performing deduplication on Multi-Tenancy dataset
2y 3m to grant Granted Apr 07, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

1-2
Expected OA Rounds
84%
Grant Probability
98%
With Interview (+13.3%)
2y 9m (~1y 8m remaining)
Median Time to Grant
Low
PTA Risk
Based on 1018 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month