Prosecution Insights
Last updated: August 09, 2026
Application No. 17/646,976

EFFICIENT PATH HISTORY AND FULL CERTIFICATE INCLUSION IN SAFETY MESSAGES

Non-Final OA §103
Filed
Jan 04, 2022
Examiner
NGO, RICKY QUOC
Art Unit
2464
Tech Center
2400 — Computer Networks
Assignee
Qualcomm Incorporated
OA Round
4 (Non-Final)
41%
Grant Probability
Moderate
4-5
OA Rounds
0m
Est. Remaining
80%
With Interview

Examiner Intelligence

Grants 41% of resolved cases
41%
Career Allowance Rate
12 granted / 29 resolved
-16.6% vs TC avg
Strong +39% interview lift
Without
With
+39.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
11 currently pending
Career history
34
Total Applications
across all art units

Statute-Specific Performance

§101
2.9%
-37.1% vs TC avg
§103
45.6%
+5.6% vs TC avg
§102
35.9%
-4.1% vs TC avg
§112
13.6%
-26.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 29 resolved cases

Office Action

§103
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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after allowance or after an Office action under Ex Parte Quayle, 25 USPQ 74, 453 O.G. 213 (Comm'r Pat. 1935). Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, prosecution in this application has been reopened pursuant to 37 CFR 1.114. Applicant's submission filed on 03/02/2026 has been entered. Information Disclosure Statement The information disclosure statement (IDS) submitted on 03/02/2026 was filed after the mailing date of the notice of allowance on 02/23/2026. The submission 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 § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1, 3-6, 8, 9, 15-18, 20-22, 24, 32 & 35 are rejected under 35 U.S.C. 103 as being unpatentable over Li et al. (WO 2021/184562 cited in Taiwan Search Report, hereinafter referred as “Li”) in view of Hwang et al (US 12,267,750, hereinafter referred as “Hwang”). Regarding claims 1 and 32, Li teaches a method of wireless communication comprising: receiving, by a wireless communication device, a cellular vehicle-to-everything (C-V2X) message from another wireless communication device, and transmitting, by the wireless communication device, a safety message (e.g., BSMs) including path history information (See Abstract, Fig. 2; Fig. 4; and process flows in Figs. 5A–5C) responsive to determining a path history information trigger condition is satisfied based on the C-V2X message (See Summary; Figs. 5A–5C; 6; 7A/7B). However, Li fails to specifically teach wherein the path history information trigger condition is satisfied based on a determination that a new or unknown device is detected in a collision zone. It is known in the art that using Local Dynamic Map (LDM) in ITS/V2X systems can track object overtime and decide whether a nearby object is already known, newly detected, moving into a risk zone, or no longer present. In the same field of endeavor, Hwang teaches the use LDM in ITS/V2X systems (see para 104 & 105). It would have been obvious to a person of ordinary skill in the art before the filing date of the claimed invention to apply Li’s selective‑inclusion framework to include PH when a newly detected vehicle presents a collision risk per Hwang’s LDM/TTC logic for determining new/unknown devices for the path history information trigger condition in collision zones. The combination yields the predictable result of providing additional information when collision risk is elevated. Regarding claim 3, Li teaches wherein safety message transmissions which do not satisfy the path history information trigger condition do not include the path history information (See Para 0078-0079, Figs. 5A–5C; 7A/7B: Not all BSMs contain the Path History information). Regarding claim 4, Li teaches wherein the safety message comprises a basic safety message (BSM), a Co-operative Awareness Message (CAM), or a Decentralized Environment Notification Message (DENM) (Li uses BSMs which is standard equivalent to CAM/DENM.) Regarding 5, Li teaches wherein the path history information comprises multiple previous positions of the wireless communication device (See para 0055 7 0021: Li teaches the PH is multiple points (e.g., five points; 8 bytes/point; 40‑byte PH field) (Detailed Description passage beginning “Path History (PH) is a field…”) Regarding claim 6, Li teaches wherein the C-V2X message from the other wireless communication device comprises …, a basic safety message (BSM), .. (Li teaches using BSMs for Path History). Regarding claim 8 recites a method comprising similar limitations of claim 1, which is rejected in the same manner as of claim 1. Regarding claim 9, Li teaches an apparatus comprising at least one transceiver, a memory, and at least one processor coupled to the at least one transceiver and the memory (see para 008), the at least one processor configured to perform the method of claim 1, as discussed in the rejection of claim 1 above. Regarding 15, Li teaches wherein the apparatus comprises a host vehicle (HV) or a user equipment (UE), and wherein the wireless communication device comprises a remote vehicle (RV) (see Figs. 1A, 1B, & 1C). Regarding claim 16, Li teaches a method of wireless communication comprising receiving, by a wireless communication device, a cellular vehicle-to-everything (C-V2X) message from another wireless communication device, and transmitting, by the wireless communication device, a safety message including certificate information responsive to determining a certificate information trigger condition is satisfied based on the C-V2X message (See, e.g., Abstract; Fig. 5A, blocks 502–506; Fig. 5B, blocks 508–510; Fig. 5C, blocks 562–566). However, Li fails to specifically teach wherein the certificate information trigger condition is satisfied based on a determination that a new or unknown device is detected in a collision zone. It is known in the art that using Local Dynamic Map (LDM) in ITS/V2X systems can track object overtime and decide whether a nearby object is already known, newly detected, moving into a risk zone, or no longer present. In the same field of endeavor, Hwang teaches the use LDM in ITS/V2X systems (see para 104 & 105). It would have been obvious to a person of ordinary skill in the art before the filing date of the claimed invention to apply Li’s selective‑inclusion framework to include the certificate when a newly detected vehicle presents a collision risk per Hwang’s LDM/TTC logic for determining new/unknown devices for the certificate information trigger condition in collision zones. The combination yields the predictable result of providing additional information when collision risk is elevated. Regarding claim 17, Li further teaches wherein the certificate information trigger condition is further based on a range condition, a time to collision condition, a timer condition, a critical event condition, or a combination thereof (See US 12,273,715 B2, FIG. 5B, blocks 508 and 510: an alternative trigger based on tracking error: determining whether an estimated tracking error exceeds an error threshold, and broadcasting a BSM including Path History in response to that determination.) Regarding claim 18, Li further teaches determining, by the wireless communication device, the certificate information trigger condition is not satisfied, refraining, by the wireless communication device, from including the certificate information in a second safety message based on determining the certificate information trigger condition is not satisfied, and sending, by the wireless communication device, the second safety message without the certificate information. (See Para 0078-0079, Figs. 5A–5C; 7A/7B) Regarding claim 20, wherein the safety message comprises a basic safety message (BSM), a Co-operative Awareness Message (CAM), or a Decentralized Environment Notification Message (DENM). Li teaches using BSMs for Path History as the safety message. Regarding claim 21, wherein the certificate information comprises a full certificate. Li teaches “a pseudonym certificate is used in C-V2X to protect a vehicle/user’s privacy,” and “a vehicle must change its pseudonym certificate every 300 seconds.” (see para 0007). Regarding claim 22, wherein the C-V2X message from the other wireless communication device comprises a beacon message, a basic safety message (BSM), a Co-operative Awareness Message (CAM), or a Decentralized Environment Notification Message (DENM). Li teaches using BSMs for Path History as the safety message. Regarding claims 24 and 35, Li teaches an apparatus comprising at least one transceiver, a memory, and at least one processor coupled to the at least one transceiver and the memory (see para 008), the at least one processor configured to perform the method of claim 16, as discussed in the rejection of claim 16 above. Claim 30 is rejected under 35 U.S.C. 103 as being unpatentable over Li et al. (WO 2021/184562 cited in Taiwan Search Report, hereinafter referred as “Li”) in view of Hwang et al (US 12,267,750, hereinafter referred as “Hwang”) and further in view of Mach (US 2021/0321233). Regarding 30, Li and Hwang, in combination, teach all the aspect of the claimed invention, except wherein the apparatus is operating Society of Automotive engineers (SAE) International or a European Telecommunications Standards Institute (ETSI) Intelligent Transportation System (ITS) mode. These standards are well-known in the art. Mach teaches V2X communication modes may be used to transmit messages, for example ETSI Cooperative Awareness Messages (CAM) or SAE Basic Safety Messages (BSM), including safety critical or operational information, for example vehicle type, speed, location, acceleration, heading, physical vehicle parameters, to enhance safety by supporting C-ITS applications, avoiding vehicle collisions, improving transport efficiency and comfort (driving assistance) or supporting cooperative driving (i.e. vehicle platooning). It would have been obvious to one of ordinary skill in the art before the filing date of the claimed invention to implement the apparatus of Li et al. in such an SAE or ETSI mode because Li et al.’s C-V2X safety messaging is already directed to the same field of vehicular communications and the same type of interoperability requirements. The combination would merely involve applying known ITS standardization requirements to Li et al.’s vehicle communication apparatus, yielding the expected result of an apparatus that operates in an SAE or ETSI ITS mode while performing the same safety-message functions already taught by Li and Hwang Allowable Subject Matter Claims 13 & 34 are allowed. Claims 7, 10, 11, 12, 23, 25, 26, 27, 29, 31, 33 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to RICKY QUOC NGO whose telephone number is (571)272-3139. The examiner can normally be reached Monday - Friday, 8:00 AM - 5:00 PM. 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. 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. /RICKY Q NGO/Supervisory Patent Examiner, Art Unit 2464
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Prosecution Timeline

Show 5 earlier events
Jul 22, 2025
Non-Final Rejection mailed — §103
Oct 08, 2025
Interview Requested
Oct 14, 2025
Applicant Interview (Telephonic)
Oct 14, 2025
Examiner Interview Summary
Oct 21, 2025
Response Filed
Mar 02, 2026
Request for Continued Examination
Mar 15, 2026
Response after Non-Final Action
May 15, 2026
Non-Final Rejection mailed — §103 (current)

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

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Prosecution Projections

4-5
Expected OA Rounds
41%
Grant Probability
80%
With Interview (+39.0%)
2y 11m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 29 resolved cases by this examiner. Grant probability derived from career allowance rate.

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