DETAILED ACTION
Application No. 19/284,094 filed on 07/29/2025 has been examined. In this Office Action, claims 1-20 are pending.
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 .
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 10/02/2025 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner.
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 a judicial exception (i.e., a law of nature, a natural phenomenon, or an abstract idea) without significantly more.
Based upon consideration of all of the relevant factors with respect to the claims as a whole, claims 1-20 are determined to be directed to an abstract idea and not significantly more than the abstract idea itself. The rationale for this determination is explained below:
Claims 1, 13, 17:
At Step 1:
Regarding with independent claims 1, 13 and 17 recite detect a command received at a computing device to retrieve content; in response to the command being received, cause the computing device to open a first application on the computing device, wherein the first application is configured to retrieve content of a second application without opening the second application on the computing device; and cause the first application to present a result including at least an indication of particular content of the second application based on a content retrieval query input to the first application, wherein the result satisfies the content retrieval query.
At Step 2A, Prong One:
The claims recite limitations that can be performed in the human mind or with pen and paper. Specifically, the limitation of “detect a command received to retrieve content,” “retrieve content of a second application,” and “present a result including at least an indication of particular content of the second application based on a content retrieval query.” These steps describe receiving a request for content, identifying responsive content from another source, and presenting an indication of that content, recites a mental process because human mind can mentally receive a request, determine where responsive content is located, identify particular content from a second source, and provide an indication of that content to another person.
The limitation “wherein the first application is configured to retrieve content of a second application without opening the second application” does not remove the claim from the mental-process category. This limitation merely describes retrieving information from another source without fully accessing or opening that source. A person can similarly identify or retrieve information from a second source by using prior knowledge, an index, preview, shortcut, or other available indication without fully opening or reviewing the entire second source. Such activities are mental steps that can be practically performed in the human mind or with the aid of pen and paper. Accordingly, the claims recite a mental process, which is an abstract idea.
At Step 2A, Prong Two:
The claims recite additional elements of including the “computing device,” “first application,” “second application,” “data processor,” and “non-transitory, computer-readable storage medium” to perform steps. However, the limitations merely amount to adding the words "apply it" (or an equivalent) with the judicial exception, or mere instructions to implement an abstract idea on a computer, or merely uses a computer as a tool to perform an abstract idea, as discussed in MPEP 2106.05(f) and generally linking the use of the judicial exception to a particular technological environment or field of use, as discussed in MPEP 2106.05(h) and Electric Power, 830 F.3d at 1354, 119 USPQ2d at 1742 (limiting application of abstract idea to power grid data). Therefore, the limitation does not recite any improvement to the technology.
Viewing the additional limitations together and the claim as a whole, nothing provides integration into a practical application.
At Step 2B:
The claim does not recite additional elements that amount to significantly more than the judicial exception. The additional elements, including the “computing device,” “first application,” “second application,” “data processor,” and “non-transitory, computer-readable storage medium”, are recited at a high level of generality and perform well-understood, routine, and conventional computer functions such as receiving a content retrieval query, retrieving responsive content, and presenting an indication of the responsive content. The claim does not recite a specific improvement to computer functionality, application interoperability, content retrieval technology, or user-interface operation. Instead, the claim merely uses generic computer implementation to automate the information-retrieval process. Viewed individually and as an ordered combination, the additional elements merely apply the abstract idea using generic computer components and therefore do not provide an inventive concept sufficient to transform the judicial exception into patent-eligible subject matter. Accordingly, claims are not directed to significantly more than the recited abstract idea and is patent-ineligible under 35 U.S.C. § 101. As explained by the Supreme Court, the addition of insignificant extra-solution activity does not amount to an inventive concept, particularly when the activity is well- understood or conventional. The courts have recognized the following computer functions as well-understood, routine, and conventional functions when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra- solution activity such as 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); TLI Communications LLC V. AV Auto. LLC, 823 F.3d 607, 610, 118 USPQ2d 1744, 1745 (Fed. Cir. 2016); (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); iv. Storing and retrieving information in memory, Versata Dev. Group, Inc. V. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); OIP Techs., 788 F.3d at 1363, 115 USPQ2d at 1092-93. See MPEP 2106.05(d) and 2106.05(g). Examples that the courts have indicated may not be sufficient to show an improvement in computer-functionality: iii. Mere automation of manual processes, such as using a generic computer to process an application for financing a purchase, Credit Acceptance Corp. V. Westlake Services, 859 F.3d 1044, 1055, 123 USPQ2d 1100, 1108-09 (Fed. Cir. 2017) See MPEP 2106.05(a). Use of a computer or other machinery in its ordinary capacity for economic or other tasks (e.g., to receive, store, or transmit data) or simply adding a general purpose computer or computer components after the fact to an abstract idea does not integrate a judicial exception into a practical application or provide significantly more. See Affinity Labs V. DirecTV, 838 F.3d 1253, 1262, 120 USPQ2d 1201, 1207 (Fed. Cir. 2016) (cellular telephone); TLI Communications LLC V. AV Auto, LLC, 823 F.3d 607, 613, 118 USPQ2d 1744, 1748 (Fed. Cir. 2016) (computer server and telephone unit). Similarly, "claiming the improved speed or efficiency inherent with applying the abstract idea on a computer" does not integrate a judicial exception into a practical application or provide an inventive concept. Intellectual Ventures / LLC V. Capital One Bank (USA), 792 F.3d 1363, 1367, 115 USPQ2d 1636, 1639 (Fed. Cir. 2015). Examples that the courts have indicated may not be sufficient to show an improvement to technology include: i. A commonplace business method being applied on a general purpose computer, Alice Corp., 573 U.S. at 223, 110 USPQ2d at 1976; Versata Dev. Group, Inc. V. SAP Am., Inc., 793 F.3d 1306, 1334, 115 USPQ2d 1681, 1701 (Fed. Cir. 2015); and iii. Gathering and analyzing information using conventional techniques and displaying the result, TLI Communications, 823 F.3d at 612-13, 118 USPQ2d at 1747-48. See MPEP 2106.05(a) and MPEP 2106.05(f). Thus, the claims are not patent eligible.
Claim 2 does not recite any additional abstract ideas, but does recite the additional element of wherein the result includes a link to the particular content of the second application, the system being further caused to: cause the computing device to open the second application of the computing device in response to the link being selected; and present the particular content in the second application on the computing device. This additional element is recited at a high level of generality, does not integrate the judicial exception into a practical application, does not amount to significantly more, and is well- understood, routine, and conventional activity.
Claims 3, 14-15, 18-19 do not recite any additional abstract ideas, but does recite the additional element of detect selection of the link; in response to the selection of the link, cause the computing device to: identify a particular environment of the second application that includes the particular content; and present the particular content in the particular environment of the second application on the computing device, detecting selection of the link to the particular content; in open the second application of the computing device; and present the particular content in the second application of the computing device. This additional element is recited at a high level of generality, does not integrate the judicial exception into a practical application, does not amount to significantly more, and is well- understood, routine, and conventional activity.
Claims 4, 16, 20 do not recite any additional abstract ideas, but does recite the additional element of retrieve the particular content from the second application and present the particular content in the first application on the computing device. This additional element is recited at a high level of generality, does not integrate the judicial exception into a practical application, does not amount to significantly more, and is well- understood, routine, and conventional activity.
Claim 5 recites cause the first application to present a control configured to enable selection of a particular environment of the second application; and detect selection of the particular environment, wherein the first application is configured to retrieve content only from the particular environment of the second application. As disclosed, this limitation is directed to a mental process. There are no additional elements recited, thus, the claim does not provide a practical application and is not considered to be significantly more.
Claim 6 recites cause the first application to present a control configured to enable selection of a particular environment of the second application, wherein the first application is configured to send content retrieval queries for only the particular environment of the second application. As disclosed, this limitation is directed to a mental process. There are no additional elements recited, thus, the claim does not provide a practical application and is not considered to be significantly more.
Claim 7 recites cause the first application to present a control configured to enable selection of one or more environments of the second application, wherein, upon selection of the one or more environments, the content retrieval query has a scope limited to the one or more environments. As disclosed, this limitation is directed to a mental process. There are no additional elements recited, thus, the claim does not provide a practical application and is not considered to be significantly more.
Claim 8 recites restrict the first application to retrieve content from a preselected environment of the second application, wherein any environment of the second application other than the preselected environment is excluded from content retrieval by the first application, and wherein the preselected environment includes the particular content. As disclosed, this limitation is directed to a mental process. There are no additional elements recited, thus, the claim does not provide a practical application and is not considered to be significantly more.
Claims 9-10 recite authorize the first application to access the second application based on a common criterion that couples the first application with the second application; and authorize the first application to search only a particular environment of the second application based on the common criterion of the first application and the particular environment of the second application and authorize the first application to access the second application based on a common electronic address set for each of the first application and the second application; and authorize the first application to search an environment of the second application based on the electronic address set for each of the first application and the environment of the second application. As disclosed, this limitation is directed to a mental process. There are no additional elements recited, thus, the claim does not provide a practical application and is not considered to be significantly more.
Claim 11 does not recite any additional abstract ideas, but does recite the additional element of detect input of a keyboard shortcut to the computing device, wherein the keyboard shortcut is preset to cause the computing device to open the first application independent of whether the second application is open on the computing device. This additional element is recited at a high level of generality, does not integrate the judicial exception into a practical application, does not amount to significantly more, and is well- understood, routine, and conventional activity.
Claim 12 recites wherein the content retrieval query is indicative of: a type of environment of the second application, a property of an environment of the second application, an attribute of an environment of the second application, an environment of multiple environments of the second application, or a member of multiple members of an environment of the second application. As disclosed, this limitation is directed to a mental process. There are no additional elements recited, thus, the claim does not provide a practical application and is not considered to be significantly more.
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 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 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Ji (US 2015/0074687 A1) in view of Valade et al (US 10,956,032 B2).
As per claim 1, Ji teaches a non-transitory, computer-readable storage medium comprising instructions recorded thereon, wherein the instructions, when executed by at least one data processor of a system, cause the system to ([0134], e.g. teaches one or more processors 501, a network interface 502, memory 503 and an input/output interface 504): detect a command received at a computing device to retrieve content ([0080], e.g., teaches that the first application sends a query request to an acquisition program and receives information of the second application associated with the first application. The query request maps to detecting/receiving a command or request to retrieve content or information); in response to the command being received, cause the computing device to open a first application on the computing device ([0075], e.g., teaches running a first application, where the running interface of the first application includes entry information of a second application associated with the first application. This maps to opening/running the first application on the computing device), wherein the result satisfies the content retrieval query ([0080]-[0081], e.g., teaches that the first application sends a query request and receives information of the second application in response, then loads entry information of the found second application into the running interface of the first application. The returned and displayed information satisfies the query request).
Ji does not explicitly teach wherein the first application is configured to retrieve content of a second application without opening the second application on the computing device; and cause the first application to present a result including at least an indication of particular content of the second application based on a content retrieval query input to the first application.
However, Valade teaches wherein the first application is configured to retrieve content of a second application without opening the second application on the computing device (col.3, lines 17-31, e.g., teaches displaying a view including information obtained from a secondary application as a keyboard utility so that the user may directly input data associated with the secondary application into the primary application without opening and/or activating the secondary application. This maps to the first application retrieving content of a second application without opening the second application); and cause the first application to present a result including at least an indication of particular content of the second application based on a content retrieval query input to the first application (fig.4, col.1, lines 45-60, e.g., teaches a keyboard utility may be rendered on a user interface of a client computing device for inputting data into a primary application. Information may be obtained from a calendar application. A view may be generated using the information obtained from the calendar application. The view may be displayed as the keyboard utility on the user interface of the client computing device. The displayed view, such as calendar information, maps to presenting a result including an indication of particular content of the second application).
Thus, it would have been obvious to one of the ordinary skills in the art before the effective filing date of the claimed invention to apply the teachings of Valade with the teachings of Ji in order to efficiently enabling a system to allow a user to directly input data associated with the secondary application into the primary application without opening and/or activating the secondary application (Valade).
As per claim 2, wherein the result includes a link to the particular content of the second application (see description of claim 1 / claim 9 teaches generating data including “at least a selectable link” including date, time, location, and time zone, and inputting that data into the primary/mobile application, The claimed “link to the particular content of the second application” maps to selectable link generated from secondary-application information and input into the primary application, Valade), the system being further caused to: cause the computing device to open the second application of the computing device in response to the link being selected; and present the particular content in the second application on the computing device (description of claim 16 teaches detecting a specified operation on entry information of the associated second application and switching from the first application to the associated second application and [0040], teaches that the user can execute an operation on the entry of another application and switch to the other application for running, Ji, further see fig.4, col.1, lines 45-60, Valade).
As per claim 3, wherein the result includes a link to the particular content of the second application (description of claim 1 / claim 9 teaches generating data including a selectable link and inputting that data into the primary application, Valade), the system being further caused to: detect selection of the link; in response to the selection of the link (description of claim 7 / claim 8 / claim 14 teach actions performed “in response to a selection of the selectable link,” including creating an event or updating the calendar application, Valade), cause the computing device to: identify a particular environment of the second application that includes the particular content; and present the particular content in the particular environment of the second application on the computing device (description of claim 1/claim 9 teaches that the secondary application may be a calendar application and that the keyboard utility may display information obtained from the secondary application, including calendar information such as dates, times, events, meetings, and appointments, Valade).
As per claim 4, wherein the computing device is further caused to: retrieve the particular content from the second application; and present the particular content in the first application on the computing device (Fig. 4 / operations 404–408 teaches obtaining information from a secondary application, generating a view using that information, and displaying the view as the keyboard utility, col. 13–14 further teaches obtaining information from a secondary/calendar application and displaying it in the keyboard utility while the primary application is active, Valade).
As per claim 5, wherein the system is further caused to: cause the first application to present a control configured to enable selection of a particular environment of the second application; and detect selection of the particular environment, wherein the first application is configured to retrieve content only from the particular environment of the second application (Figs. 2B, 3, 6, and 7 show calendar controls/views with selectable dates, times, events, contacts, and meeting information, col. 15 teaches receiving input on the keyboard utility, such as selecting date/time information, and generating event data, user-selected date/time information in the keyboard utility is used to generate event data associated with the secondary application, Valade).
As per claim 6, wherein the system is further caused to: cause the first application to present a control configured to enable selection of a particular environment of the second application, wherein the first application is configured to send content retrieval queries for only the particular environment of the second application (Fig. 4 / operations 404–408, Valade teaches obtaining information from the secondary application and displaying a generated view of and paragraph [0080] of Ji teaches that the first application sends a query request and receives information of the second application).
As per claim 7, wherein the system is further caused to: cause the first application to present a control configured to enable selection of one or more environments of the second application, wherein, upon selection of the one or more environments, the content retrieval query has a scope limited to the one or more environments (Figs. 6–7 of Valade shows calendar views with multiple dates/events/contacts and col. 15 teaches selecting date/time information and generating data from that selected information, The one or more environments map to one or more calendar contexts, such as dates, time slots, events, or contact-related calendar regions. The scope-limited query is rendered obvious by using the selected calendar context to limit retrieval).
As per claim 8, wherein the system is further caused to: restrict the first application to retrieve content from a preselected environment of the second application, wherein any environment of the second application other than the preselected environment is excluded from content retrieval by the first application, and wherein the preselected environment includes the particular content (Valade, col. 15 teaches generating data based on selected date/time information from the keyboard utility. Ji ¶[0061] teaches selecting associated second applications based on specified time ranges, such as morning, afternoon, or evening).
As per claim 9, wherein the system is further caused to: authorize the first application to access the second application based on a common criterion that couples the first application with the second application; and authorize the first application to search only a particular environment of the second application based on the common criterion of the first application and the particular environment of the second application (Ji ¶[0047]–¶[0050] teaches determining an association between a first application and a second application based on usage habits/order of use. Valade, col. 2–3 teaches primary and secondary applications being linked so that data from the secondary application can be input into the primary application and col. 15 teaches the keyboard utility receiving selected date/time information and generating data associated with the secondary calendar application).
As per claim 10, wherein the system is further caused to: authorize the first application to access the second application based on a common electronic address set for each of the first application and the second application; and authorize the first application to search an environment of the second application based on the electronic address set for each of the first application and the environment of the second application (col. 2 teaches a primary application with a “To” field and a calendar application associated with the person identified in the “To” field being updated after confirmation, Figs. 3 and 7 show email/calendar information, including electronic address/contact information and, col. 2 teaches calendar updates associated with the person in the “To” field, and Fig. 7 shows recipient/contact-related calendar information, The electronic address set maps to recipient/contact/email-address information shared between the primary communication application and the secondary calendar application, Valade).
As per claim 11, wherein to detect the command received at the computing device comprises causing the system to: detect input of a keyboard shortcut to the computing device, wherein the keyboard shortcut is preset to cause the computing device to open the first application independent of whether the second application is open on the computing device (Valade col.3, lines 17-31, col.10, lines 16-36, teaches a keyboard utility rendered on the user interface of a primary application and linked to a secondary application, where the secondary application need not be opened or activated and the keyboard utility icon 258/shortcut may facilitate switching between the calendar schedule 265 and the displayed views associated with selecting the setting icon 252, the location icon 254, and the time duration icon 256. For example, after a user has selected the location icon 254, for example, and a mapping application and/or any other location based application is displayed, the user may select the keyboard utility icon 258 to get back to the calendar schedule 265).
As per claim 12, wherein the content retrieval query is indicative of: a type of environment of the second application, a property of an environment of the second application, an attribute of an environment of the second application, an environment of multiple environments of the second application, or a member of multiple members of an environment of the second application (Valade, col. 15 teaches that secondary-application/calendar data may include date, time, location, contacts, meetings, events, and appointments).
Regarding claims 13, 17, claims 13, 17 are rejected for substantially the same reason as claim 1 above.
Regarding claims 14-16, 18-20, claims 14-16, 18-20 are rejected for substantially the same reason as claims 3-5 above.
It is noted that any citation [[s]] to specific, pages, columns, lines, or figures in the prior art references and any interpretation of the references should not be considered to be limiting in any wav. A reference is relevant for all it contains and may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art. [[See, MPEP 2123]].
Citation of Pertinent Prior Arts
The prior art made of record and not relied upon in form PTO-892, if any, is considered pertinent to applicant's disclosure.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Mohammad A Sana whose telephone number is (571)270-1753. The examiner can normally be reached Monday-Friday 9-5.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Sanjiv Shah can be reached at 5712724098. 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.
/Mohammad A Sana/Primary Examiner, Art Unit 2166
Prosecution Insights