Prosecution Insights
Last updated: April 19, 2026
Application No. 18/004,865

DIRECT LINK RESOURCE RELEASING MECHANISM IN A MULTI-USER TXOP

Non-Final OA §103
Filed
Jan 09, 2023
Examiner
HUANG, WEIBIN
Art Unit
2471
Tech Center
2400 — Computer Networks
Assignee
Canon Kabushiki Kaisha
OA Round
3 (Non-Final)
89%
Grant Probability
Favorable
3-4
OA Rounds
2y 8m
To Grant
94%
With Interview

Examiner Intelligence

Grants 89% — above average
89%
Career Allow Rate
573 granted / 646 resolved
+30.7% vs TC avg
Moderate +6% lift
Without
With
+5.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
44 currently pending
Career history
690
Total Applications
across all art units

Statute-Specific Performance

§101
8.0%
-32.0% vs TC avg
§103
40.6%
+0.6% vs TC avg
§102
24.8%
-15.2% vs TC avg
§112
12.2%
-27.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 646 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 . Claim Status This office action is in response to the communication(s) filed on 02/13/2026. Claim(s) 1-18 is/are currently presenting for examination. Claim(s) 1 and 5 is/are independent claim(s). Claim(s) 1-7, 9-11, and 13-18 is/are rejected. Claim(s) 8 is/are objected to. This action has been made NON-FINAL. Response to Arguments Applicant's arguments filed on 02/13/2026 have been considered but are moot in view of the new ground(s) of rejection. Claim Objections Claims 1 and 5 are objected to because of the following informalities: the acronym “QoS” is not defined in the claim. Appropriate correction is required. 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. The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 1-3, 5-6, 13, 15-18 is/are rejected under 35 U.S.C. 103 as being unpatentable over US_20230180314_A1_Kim (hereinafter, “Kim-14”) in view of US_20180020372_A1_Viger. Regarding claim 1, Kim-14 discloses a communication method in a wireless network, comprising at a station: receiving, from an access point, AP, a trigger frame providing the station with a resource used in data transmission during a transmission opportunity, TxOP, granted to the AP (Kim-14 paragraph 110, “The AP MLD may transmit a trigger frame including information for P2P transmission…”), performing the data transmission by using the provided resource (Kim-14 paragraph 111, “P2P transmission may entirely use the TXOP obtained by the AP, or may share the TXOP with general transmission (ie, transmission between the STA and the AP)...”), and upon finishing the data transmission, sending a frame that causes releasing of the provided resource to the AP by using the provided resource (Kim-14 paragraph 116, “D. When the P2P transmission terminates earlier than the predetermined period, the source P2P device (ie, the P2P initiator) may transmit, to the AP MLD a release message indicating that the P2P transmission is terminated”), but does not disclose wherein the resource releasing frame is an enhanced 802.11 QoS Null frame including a Buffer Status Report, BSR. Viger discloses wherein the resource releasing frame is an enhanced 802.11 QoS Null frame including a Buffer Status Report, BSR (Viger figure 4b, element 410-BSR, and paragraphs 129, “In order to minimize the duration of the buffer state report, the frames sent inside resource units 410-BSR should be limited and of same size to avoiding inefficient padding. For example, a QoS_Null frame seems better appropriated…”, paragraph 169, “…These embodiments supplement the 802.llax by specifying how the stations can report their buffer status to the access point, either in the existing 802.lle frames or in newly 802.llax multi-user QoS Data/Null frames…”). Thus it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the teachings of Viger’s the stations can report their buffer status to the access point, either in the existing 802.lle frames or in newly 802.llax multi-user QoS Data/Null frames in Kim-14’s system to minimize the duration of the buffer state report (Viger paragraph 129). This method for improving the system of Kim-14 was within the ordinary ability of one of ordinary skill in the art based on the teachings of Viger. Therefore, it would have been obvious to one of ordinary skill in the art to combine the teachings of Kim-14 and Viger to obtain the invention as specified in claim 2. Regarding claim 2, Kim-14 and Viger disclose the method of claim 1, and Kim-14 further discloses wherein the resource unit is provided for a predefined duration, and the frame causing releasing of the provided resource is sent before the end of the predefined duration (Kim-14 paragraph 116, “D. When the P2P transmission terminates earlier than the predetermined period, the source P2P device (ie, the P2P initiator) may transmit, to the AP MLD a release message indicating that the P2P transmission is terminated”). Regarding claim 3, Kim-14 and Viger disclose the method of claim 1, and Kim-14 further discloses further comprising, at the station, sending, responsive to the reception of the trigger frame, a resource acknowledging frame for acknowledging the provided resource to the AP before starting performing the data transmission (Kim-14 paragraph 112, “…The P2P transmission in the TXOP may be performed after the P2P start frame indicating the start of P2P transmission by the P2P transmitting STA (ie, the P2P initiator STA). …”). Regarding claim 5, Kim-14 and Viger disclose the limitations as set forth in claim 1. Regarding claim 6, Kim-14 and Viger disclose the limitations as set forth in claim 2. Regarding claim 13, Kim-14 and Viger disclose the method of claim 10, and Viger further discloses wherein the BSR includes DiL needs for the peer station (Viger paragraph 30, “…This mechanism provides a means for a station to report to the access point station the amount of data held in an emission buffer ready to be transmitted to the access point station.…”). Regarding claim 15, Kim-14 and Viger disclose a wireless communication device comprising at least one microprocessor configured for carrying out the steps of the method of claim 1 (Kim-14 figure 1). Regarding claim 16, Kim-14 and Viger disclose a non-transitory computer-readable medium storing a program which, when executed by a microprocessor or computer system in a wireless device, causes the wireless device to perform the method of claim 1 (Kim-14 paragraph 173). Regarding claim 17, Kim-14 and Viger disclose the method of Claim 1, and Kim-14 further discloses wherein the provided resource is a frequency resource having a bandwidth that is a multiple of 20MHz, and the data transmission is performed by using the frequency resource (Kim-14 paragraph 118). Regarding claim 18, Kim-14 and Viger disclose the method of Claim 5, and Kim-14 further discloses wherein the provided resource is a frequency resource having a bandwidth that is a multiple of 20MHz, and the data transmission is performed by using the frequency resource (Kim-14 paragraph 118). Claim(s) 4 and 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over US_20230180314_A1_Kim (hereinafter, “Kim-14”) in view of US_20180020372_A1_Viger and US_10771126_B2_Zhu (Hereinafter, “Zhu-26”). Regarding claim 4, Kim-14 and Viger disclose the method of claim 1, further comprising receiving, from the AP during the granted TxOP, one or more triggering frames trigger multi-user, MU, transmissions. Zhu-26 discloses receiving, from the AP during the granted TxOP, one or more triggering frames trigger multi-user, MU, transmissions (Zhu-26 column 23 line 66 – column 24 line 3, “…transmitting, by the first communication device, a trigger communication frame during the TXOP to trigger the group of second communication devices to transmit simultaneously as part of the uplink multi-user transmission…”). Thus it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the teachings of Zhu-26’s transmitting a trigger communication frame during the TXOP to trigger the group of second communication devices to transmit simultaneously as part of the uplink multi-user transmission in Kim-14 and Viger’s system to improve resource efficiency by allowing multiple devices to transmit concurrently. This method for improving the system of Kim-14 and Viger was within the ordinary ability of one of ordinary skill in the art based on the teachings of Zhu-26. Therefore, it would have been obvious to one of ordinary skill in the art to combine the teachings of Kim-14, Viger and Zhu-26 to obtain the invention as specified in claim 4. Regarding claim 9, Kim-14, Viger and Zhu-26 disclose the limitations as set forth in claim 4. Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over US_20230180314_A1_Kim (hereinafter, “Kim-14”) in view of US_20180020372_A1_Viger and US_20220369159_A1_Kim (Hereinafter, “Kim-59”). Regarding claim 7, Kim-14 and Viger disclose the method of claim 6, but does not disclose further comprising setting a network allocation vector, NAV, to defer a medium access by the AP to the end of the predefined duration. Kim-59 discloses setting a network allocation vector, NAV, to defer a medium access by the AP to the end of the predefined duration (Kim-59 paragraph 229, “…a STA (that is, other stations) whose address is not indicated through the RTS frame may establish a NAV, and defer the media access during the NAV.…”). Thus it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the teachings of Kim-59’s a STA (that is, other stations) whose address is not indicated through the RTS frame may establish a NAV, and defer the media access during the NAV in Kim-14 and Viger’s system to avoid collision in the shared wireless medium. This method for improving the system of Kim-14 and Viger was within the ordinary ability of one of ordinary skill in the art based on the teachings of Kim-59. Therefore, it would have been obvious to one of ordinary skill in the art to combine the teachings of Kim-14, Viger and Kim-59 to obtain the invention as specified in claim 7. Claim(s) 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over US_20230180314_A1_Kim (hereinafter, “Kim-14”) in view of US_20180020372_A1_Viger, US_20190386714_A1_Yang. Regarding claim 10, Kim-14 and Viger disclose the method of claim 1, but do not disclose wherein the frame for releasing the provide resource is a Single User, SU, data frame. Yang discloses wherein the frame for releasing the provide resource is a Single User, SU, data frame (Yang paragraph 282, “…the EDMG STA that initiates the SU-MIMO TXOP may send a CF END to cancel the NAY on SU-MIMO channels and release unused TXOP. …”). Thus it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the teachings of Yang’s the EDMG STA that initiates the SU-MIMO TXOP may send a CF END to cancel the NAY on SU-MIMO channels and release unused TXOP in Kim-14 and Viger’s system to ensure the transmission of the TxOP releasing message. This method for improving the system of Kim-14 and Viger was within the ordinary ability of one of ordinary skill in the art based on the teachings of Yang. Therefore, it would have been obvious to one of ordinary skill in the art to combine the teachings of Kim-14, Viger and Yang to obtain the invention as specified in claim 10. Claim(s) 11 and 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over US_20230180314_A1_Kim (hereinafter, “Kim-14”) in view of US_20180020372_A1_Viger, US_20190386714_A1_Yang and US_20150071051_A1_Zhu (Hereinafter, “Zhu-51”). Regarding claim 11, Kim-14, Viger and Yang disclose the method of claim 10, but do not disclose wherein the resource releasing frame is an 802.11 QoS Null frame. Zhu-51 discloses wherein the resource releasing frame is an 802.11 QoS Null frame (Zhu-51 paragraph 65, “…Therefore, if a STA is polled by the AP for UL transmission using a UTI method, and it has no data to send, it should send a QoS Null frame back to the AP with "0" in the Queue Size subfield or "0" in the TXOP Duration Requested subfield…”, paragraph 92, “…if the TX OP owner STA fails to get the UTI frame PIPS after the end of the UTR frame, it shall send out a CF-End to release the ownership of the TXOP and…”, and paragraph 39, 46-47 for 802.11). Thus it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the teachings of Zhu-51’s sending a QoS Null frame back to the AP to release the ownership of the TXOP in Kim-14, Viger and Yang’s system to for ease of implementation. This method for improving the system of Kim-14, Viger and Yang was within the ordinary ability of one of ordinary skill in the art based on the teachings of Zhu-51. Therefore, it would have been obvious to one of ordinary skill in the art to combine the teachings of Kim-14, Viger, Yang and Zhu-51 to obtain the invention as specified in claim 11. Regarding claim 14, Kim-14, Viger and Yang disclose the method of claim 10, but do not disclose wherein the resource releasing frame is a unicast 802.11 CF-End frame addressed to the AP. Zhu-51discloses wherein the resource releasing frame is a unicast 802.11 CF-End frame addressed to the AP (Zhu-51 paragraph 65, “…Therefore, if a STA is polled by the AP for UL transmission using a UTI method, and it has no data to send, it should send a QoS Null frame back to the AP with "0" in the Queue Size subfield or "0" in the TXOP Duration Requested subfield…”, paragraph 92, “…if the TX OP owner STA fails to get the UTI frame PIPS after the end of the UTR frame, it shall send out a CF-End to release the ownership of the TXOP and…”, and paragraph 39, 46-47 for 802.11). Thus it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the teachings of Zhu-51’s sending a QoS Null frame back to the AP to release the ownership of the TXOP in Kim-14, Viger and Yang’s system to for ease of implementation. This method for improving the system of Kim-14, Viger and Yang was within the ordinary ability of one of ordinary skill in the art based on the teachings of Zhu-51. Therefore, it would have been obvious to one of ordinary skill in the art to combine the teachings of Kim-14, Viger, Yang and Zhu-51 to obtain the invention as specified in claim 14. Allowable Subject Matter Claim 8 is/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 WEIBIN HUANG whose telephone number is (571)270-3695. The examiner can normally be reached Monday - Friday 9:30AM - 6:00PM. 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, Sujoy Kundu can be reached at (571)272-8586. 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. /W.H/Examiner, Art Unit 2471 /SUJOY K KUNDU/Supervisory Patent Examiner, Art Unit 2471
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Prosecution Timeline

Jan 09, 2023
Application Filed
Jun 14, 2025
Non-Final Rejection — §103
Sep 15, 2025
Response Filed
Dec 13, 2025
Final Rejection — §103
Feb 13, 2026
Response after Non-Final Action
Mar 29, 2026
Non-Final Rejection — §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

3-4
Expected OA Rounds
89%
Grant Probability
94%
With Interview (+5.8%)
2y 8m
Median Time to Grant
High
PTA Risk
Based on 646 resolved cases by this examiner. Grant probability derived from career allow rate.

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