Prosecution Insights
Last updated: October 02, 2026
Application No. 19/300,194

ELECTRONIC DEVICE AND METHOD FOR PROTECTING DATABASE USING SAME

Non-Final OA §101§103
Filed
Aug 14, 2025
Priority
Feb 14, 2023 — RE 10-2023-0019288 +2 more
Examiner
HU, JENSEN
Art Unit
Tech Center
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
68%
Grant Probability
Favorable
1-2
OA Rounds
2y 5m
Est. Remaining
95%
With Interview

Examiner Intelligence

Grants 68% — above average
68%
Career Allowance Rate
372 granted / 546 resolved
+8.1% vs TC avg
Strong +27% interview lift
Without
With
+26.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
8 currently pending
Career history
560
Total Applications
across all art units

Statute-Specific Performance

§101
19.1%
-20.9% vs TC avg
§103
48.7%
+8.7% vs TC avg
§102
20.0%
-20.0% vs TC avg
§112
6.6%
-33.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 546 resolved cases

Office Action

§101 §103
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 . Claims 1-20 are pending in this application. 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 20 is rejected under 35 U.S.C. 101 as being directed to non-statutory subject matter (Software per se). Claim 20 recites a “computer-readable recording medium storing a program.” The claim does not recite any hardware elements for executing substantive limitations and is interpreted as being merely directed to software elements. An appropriate correction is required. Claims 1-20 are rejected under 35 U.S.C. 101 as being directed to an abstract idea without significantly more. Independent claim 1 recites: “in case that the specified operation command is received, identifying an integrity check level specified for the application”; “in case that the specified integrity check level of the application is greater than or equal to a reference level, performing an integrity check in the data in response to reception of the specified operation command”; and “determining whether or not to execute the specified operation command for the data according to a result of the integrity check”. The limitations “in case that the specified operation command is received, identifying an integrity check level specified for the application”; “in case that the specified integrity check level of the application is greater than or equal to a reference level, performing an integrity check in the data in response to reception of the specified operation command”; and “determining whether or not to execute the specified operation command for the data according to a result of the integrity check” as drafted, is a process that, under its broadest reasonable interpretation, covers a mental process but from the recitation of implementing it on generic computer components. That is nothing in the claim element precludes the step from practically being performed in the mind. For example, “identifying” “performing” and “determining” in the context of this claim encompasses a user observing given data and identifying an integrity check level, mentally comparing the level to a given reference and performing an integrity check based on the comparison and then making a mental determination as to whether the command should be executed based on the results of the integrity check. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. Accordingly, claim 1 recites an abstract idea. This judicial exception is not integrated into a practical application. In particular, the claim recites implementation of the method on “an electronic device” The device is recited at a high level of generality that does not meaningfully integrate the abstract idea into a practical application. In addition, the claim recites “identifying whether or not a specified operation command for data related to an application executed in the electronic device is received.” This limitation represents mere extra-solution activity to the judicial exception. The additional elements represent mere data gathering steps. Accordingly, these additional elements do not integrate the abstract idea into a practical application because it does not impose any meaningful limits on practicing the abstract idea. The claim 1 is directed to an abstract idea. The claim does not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional element of “electronic device” is recited at a high level of generality and is merely a computing tool to carry out the abstract idea steps. The other additional elements represent insignificant extra solution activity of mere data gathering that amount to simply appending well-understood, routine, conventional activities previously known to the industry and specified at a high level of generality. According to the courts data gathering steps do not constitute limitations that provide significant steps that amount to more than the judicial exception. Claim 1, as a whole, is directed to an abstract idea. The additional elements are not sufficient to overcome the mental nature of these claims. Accordingly, claim 1 is not patent eligible. Claim 11 and Claim 20 are similarly rejected as Claim 1 above. Claims 2-10, 12-19 depend on claims 1, 11 and include all the limitations of claims 1, 11. Therefore, claims 2-10, 12-19 recite the same abstract idea practically being performed in the mind, and the analysis must therefore proceed to Step 2A Prong Two. Claims 2, 12 recite the additional limitation “wherein the specified operation command comprises at least one of an open operation, a commit operation, or a WAL file checkpoint operation command for a database file related to the application”. This judicial exception is not integrated into a practical application. The additional limitations merely indicate a field of use or technological environment in which to apply a judicial exception that does not amount to significantly more than the exception itself. The claims merely associate the mental process with a particular data source or particular type of data. This limitation is merely an incidental or token additional to the claim that does not alter or affect the mental process steps performed. Claims 2, 12 are ineligible. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements merely indicate a field of use or technological environment in which to apply a judicial exception that does not amount to significantly more than the exception itself. The claims merely limit the mental process to a particular data source or particular type of data. Claims 2, 12 are not patent eligible. Claims 3-4, 13-14 recite “performing a page integrity check on the data in case that a commit operation command is received according to a transaction operation for the related data according to the execution of the application”. This judicial exception is not integrated into a practical application. The additional elements represent a further mental process step of performing a page integrity check on associated data. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. Accordingly, claims 3-4, 13-14 recite an abstract idea and is ineligible. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements represent a further mental process step. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. An additional abstract idea (mental process step) is not sufficient to amount to significantly more than the judicial exception. Claims 3-4, 13-14 are not patent eligible. Claims 5, 15 recite the additional limitation “wherein the integrity check level is relatively configured based on at least one required level of stability, security, or processing speed required for the application”. This judicial exception is not integrated into a practical application. The additional limitations merely indicate a field of use or technological environment in which to apply a judicial exception that does not amount to significantly more than the exception itself. The claims merely associate the mental process with a particular data source or particular type of data. This limitation is merely an incidental or token additional to the claim that does not alter or affect the mental process steps performed. Claims 5, 15 are ineligible. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements merely indicate a field of use or technological environment in which to apply a judicial exception that does not amount to significantly more than the exception itself. The claims merely limit the mental process to a particular data source or particular type of data. Claims 5, 15 are not patent eligible. Claims 6, 16 recite “wherein a checkpoint integrity check is performed, in case that the WAL file checkpoint operation command is received, on the WAL frames subject to the checkpoint in sequence, and wherein the checkpoint integrity check further comprises: performing a page integrity check on WAL frames included in a list of WAL frames subject to the checkpoint; and performing an integrity check of the WAL frames included in the list of WAL frames”. This judicial exception is not integrated into a practical application. The additional elements represent a further mental process step of performing an integrity check on data associated with WAL frame data. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. Accordingly, claims 6, 16 recite an abstract idea and is ineligible. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements represent a further mental process step. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. An additional abstract idea (mental process step) is not sufficient to amount to significantly more than the judicial exception. Claims 6, 16 are not patent eligible. Claims 7, 17 recite “performing a file hole check in case that the specified integrity check level of the application exceeds the reference level”. This judicial exception is not integrated into a practical application. The additional elements represent a further mental process step of performing a file hole check on associated data. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. Accordingly, claims 7, 17 recite an abstract idea and is ineligible. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements represent a further mental process step. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. An additional abstract idea (mental process step) is not sufficient to amount to significantly more than the judicial exception. Claims 7, 17 are not patent eligible. Claims 8-9, 18-19 recite “wherein the performing of the integrity check of the WAL frames comprises: performing an integrity check on a header of the WAL frame; and performing a WAL frame checksum check in case that the specified integrity check level of the application exceeds the reference level”. This judicial exception is not integrated into a practical application. The additional elements represent a further mental process step of performing an integrity check and WAL frame checksum on associated data. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. Accordingly, claims 8-9, 18-19 recite an abstract idea and is ineligible. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements represent a further mental process step. If a claim limitation, under its broadest reasonable interpretation, covers performance of the limitation in the mind but for the recitation of generic computer components, then it falls within the “Mental Processes” grouping of abstract ideas. This additional step is considered an abstract idea (mental process step) and does not integrate the judicial exception into a practical application. An additional abstract idea (mental process step) is not sufficient to amount to significantly more than the judicial exception. Claims 8-9, 18-19 are not patent eligible. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claim(s) 1-6, 8-16, 18-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lee et al., US 2020/0218710 (hereinafter Lee) in view of Bogacz US 11,386,235 (hereinafter Bogacz). For claims 1, 11, 20, Lee teaches an operation method of an electronic device, the method comprising: identifying whether or not a specified operation command for data related to an application executed in the electronic device is received (see Lee [0084], [0095], [0097], “receive a command” that is operation “related to the application 146”); in case that the specified operation command is received, identifying an integrity check level specified for the application (see Lee, [0059], [0066], [0081], [0084] – [0085], [0110], receiving “checkpoint message” from “application 146” representing integrity check level for application). Bogacz teaches “in case that the specified integrity check level of the application is greater than or equal to a reference level, performing an integrity check on the data in response to reception of the specified operation command” (see Bogacz, col. 4 lines 20-39, col. 6 lines 32-50, where “file metadata” from “legal and engineering” application “source” is a “higher” integrity level than reference “lower second level” or “different levels of integrity verification” for selection to perform integrity verification on the data). It would have been obvious to one skilled in the art at the time of the invention to modify the teachings of Lee with the teachings of Bogacz to only perform resource intensive check operations on designated important data and skip the operations for other less important data (see Bogacz, col. 4 lines 1-19, identify “resource and/or time intensive tasks”, col. 6 lines 32-50, “integrity verification” for “higher levels” of data from “legal and engineering” application source and skip for other sources from other applications; see Lee, [0059], [0066], [0081], [0084] – [0085], [0110], modifies Lee’s “perform a checkpoint operation” based on receiving “checkpoint message” from “application 146”). The combination further teaches determining whether or not to execute the specified operation command for the data according to a result of the integrity check (see Lee, [0085], where result of “valid” checkpoint operation determines execution of “change the database” operation command). For claims 2, 12, the combination teaches wherein the specified operation command comprises at least one of an open operation, a commit operation, or a WAL file checkpoint operation command for a database file related to the application (see Lee, [0066], [0085], “checkpoint operation” for determining validity of “Wal file”). For claims 3, 13, the combination teaches further comprising performing a page integrity check on the data in case that a commit operation command is received according to a transaction operation for the related data according to the execution of the application (see Lee, [0078] - [0079], [0110], check “page” data associated with received “commit” operation during “checkpoint operation”). For claims 4, 14, the combination teaches wherein the performing of the page integrity check comprises performing an integrity check for each page, based on information included in a page header of each page, which is included in a list of pages subject to the commit operation (see Lee, [0077], [0110], “frame header” representing page header). For claims 5, 15, the combination teaches wherein the integrity check level is relatively configured based on at least one required level of stability, security, or processing speed required for the application (see Bogacz, col. 6 lines 32-50 where important or critical data represents level of security). For claims 6, 16, the combination teaches wherein a checkpoint integrity check is performed, in case that the WAL file checkpoint operation command is received, on the WAL frames subject to the checkpoint in sequence (see Lee, [0066], [0085], “perform checkpoint operation” to determine “validity of frames in the WAL file”), and wherein the checkpoint integrity check further comprises: performing a page integrity check on WAL frames included in a list of WAL frames subject to the checkpoint (see Lee, [0085], [0110], “checkpoint operation” on associated “page data”); and performing an integrity check of the WAL frames included in the list of WAL frames (see Lee, [0085], [0109] – [0110], “checkpoint operation” on “frames in WAL file”). Claims 8, 18, the combination teaches wherein the performing of the integrity check of the WAL frames comprises: performing an integrity check on a header of the WAL frame (see Lee, [0081], “checkpoint operation” involving “header of the first frame”); and performing a WAL frame checksum check in case that the specified integrity check level of the application exceeds the reference level (see Lee, [0076], [0081], [0085], perform integrity check comprising “checksum” of the associated “WAL file header”). Claims 9, 19, the combination teaches further comprising: in case that the page integrity check on WAL frames and the integrity check of the WAL frames are identified to be successful, reading page data from the WAL frame and writing on the database file; and in case that the page integrity check on WAL frames and the integrity check of the WAL frames are identified to have failed, not reading page data from the WAL frame and not writing on the database file (see Lee, [0085], “determine that the frame 320 [of the WAL file] is valid and change the database” represents successful integrity check, and “no valid frame…skip the checkpoint operation” where data is not read and written to database represents failed integrity check). For claim 10, the combination teaches the method of claim 1, further comprising performing, in case that the specified operation command is determined to be performed as a result of the integrity check, the specified operation command on the data for a database file related to the application (see Lee, [0085], [0095], when frame is “valid” then “change the database” associated with operation on application). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Lee et al., US 2022/0222216. (same assignee and inventors, but earlier publication date) Fachan et al., US 11,722,150. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JENSEN HU whose telephone number is (571)270-3803. The examiner can normally be reached Monday - Friday 9-5 PT. 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, Sherief Badawi can be reached at 571-272-9782. 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. /JENSEN HU/Primary Examiner, Art Unit 2169
Read full office action

Prosecution Timeline

Aug 14, 2025
Application Filed
Aug 20, 2026
Non-Final Rejection mailed — §101, §103
Sep 29, 2026
Interview Requested

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
68%
Grant Probability
95%
With Interview (+26.9%)
3y 7m (~2y 5m remaining)
Median Time to Grant
Low
PTA Risk
Based on 546 resolved cases by this examiner. Grant probability derived from career allowance rate.

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