Prosecution Insights
Last updated: July 15, 2026
Application No. 18/079,506

METHOD FOR ADDING 3GPP PDN LEG TO AN MA PDU SESSION WITH NON-3GPP LEG

Final Rejection §103
Filed
Dec 12, 2022
Priority
Jan 03, 2022 — provisional 63/296,025
Examiner
BALLOWE, CALEB JAMES
Art Unit
2419
Tech Center
2400 — Computer Networks
Assignee
MediaTek Inc.
OA Round
4 (Final)
18%
Grant Probability
At Risk
5-6
OA Rounds
0m
Est. Remaining
57%
With Interview

Examiner Intelligence

Grants only 18% of cases
18%
Career Allowance Rate
3 granted / 17 resolved
-40.4% vs TC avg
Strong +39% interview lift
Without
With
+39.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
35 currently pending
Career history
73
Total Applications
across all art units

Statute-Specific Performance

§103
98.8%
+58.8% vs TC avg
§102
1.2%
-38.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 17 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 . Response to Amendment Applicant’s submission filed on 02/26/2026 has been entered. Claims 1-20 are pending. 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. The factual inquiries 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. Claims 1, 5, 11, and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki et al. (US 2018/0302935), hereinafter "Kawasaki", in view of Hashmi et al. (US 2023/0015471), hereinafter “Hashmi”. Regarding claims 1, 11, Kawasaki teaches: A method or User Equipment (UE) (see Kawasaki, Fig. 7, par. [0167], lines 2-3: FIG. 7 illustrates a device configuration of the UE 10), comprising: a connection handling circuit (see Kawasaki, Fig. 7, item 700, par. [0169], lines 1-4: The control unit 700 serves as a function unit for controlling the UE 10. The control unit 700 implements various processes by reading out and executing various programs stored in the storage 750) that maintains a multi-access protocol data unit (MA PDU) session and user-plane resources over non-3GPP access for the MA PDU session by a user equipment (UE) (see Kawasaki, par. [0054], lines 1-7: the multi-access PDN connection denotes a PDN connection capable of accommodating, in one PDN connection, a transfer path and/or a bearer over a 3GPP access and/or a WLAN access. In other words, the multi-access PDN connection is capable of accommodating both a transfer path through the 3GPP access and a transfer path through the WLAN access, and see Kawasaki, par. [0052], lines 1-3: the UE 10 is capable of establishing a first PDN connection and/or a second PDN connection; in this case, there is support for accommodating (i.e. maintaining) several PDN connections (corresponding to a MA PDU session) and transfer paths and bearers (i.e. user-plane resources) over WLAN access (corresponding to non-3GPP access)), wherein the MA PDU session has a stored first set of parameters (see Kawasaki, par. [0673], lines 1-8: The PDN connection attribute information may be information indicating that the PDN connection established in the current PDN connectivity procedure is the multi-access PDN connection, and/or information indicating that user data transmitted and/or received by using the PDN connection established in the current PDN connectivity procedure is allowed to be transmitted and/or received through the access network A and the access network B, and see Kawasaki, par. [0118]: The PDN connection ID is identification information for identifying a PDN connection. The UE 10, the TWAG 74, and the PGW 30 may store the same identification information; in this case, PDN connection information corresponds to a stored first set of parameters); a transmitter that transmits (see Kawasaki, Fig. 7, item 740, par. [0171], lines 1-3: The WLAN interface unit 740 serves as a data transmission and/or reception unit configured to transmit and/or receive user data and/or a control message) a Packet Data Network (PDN) CONNECTIVITY REQUEST message to establish a PDN connection as a user-plane resource for the same MA PDU session (see Kawasaki, par. [0401]: The UE 10 first transmits a PDN connectivity request to the MME 40 via the eNB 45 (S2102). The UE 10 first transmits a PDN connectivity request to the MME 40 via the eNB 45 (S2102). The UE 10 may transmit the PDN connectivity request including at least the PDN connectivity request message identity (PDN connectivity request message ID), the Procedure transaction identity (Procedure transaction ID), the Request type, the PDN type, the Protocol discriminator, and EPS bearer identity (EPS bearer ID). Furthermore, the UE 10 may include at least first identification information and/or fifth identification information and/or eighth identification information in the PDN connectivity request, and see par. [0403]: the fifth identification information may be the Mode Indication representing an NBIFOM operation mode for the multi-access PDN connection whose establishment is requested by the UE 10, and see pars. [0406-0408]: the eighth identification information may be information indicating a default access (Default Assess) in the multi-access PDN connection. The eighth identification information may be information indicating the 3GPP access or the WLAN access. The 3GPP access may be an access system that is not the WLAN access. More specifically, the 3GPP access may be information indicating an access network including the E-UTRAN access, the UTRAN access, and the GERAN access. Alternatively, the eighth identification information may include more detailed information. For example, the eighth identification information may be one of the E-UTRAN access, the UTRAN access and the GERAN access. As described above, the UE 10 may transmit the eighth identification information to request a default access for the multi-access PDN connection. In other words, the UE 10 may transmit the eighth identification information to request the establishment of the multi-access PDN connection in which the access network indicated by the eighth identification information is used as the default access, and see Kawasaki, par. [0352], lines 2-5: The EPS bearer context for each PDN connection includes a PDN connection ID, a Network allowed mode, an Operation mode, a User plane connection ID, an MME MAC address, and an NBIFOM Permission, and see Kawasaki, par. [0054], lines 1-7: the multi-access PDN connection denotes a PDN connection capable of accommodating, in one PDN connection, a transfer path and/or a bearer over a 3GPP access and/or a WLAN access. In other words, the multi-access PDN connection is capable of accommodating both a transfer path through the 3GPP access and a transfer path through the WLAN access; in this case, the UE sends a PDN connection request, with information including at least eighth information to request a default access for the multi-access PDN connection (i.e. to establish a PDN connection). Information on a PDN connection includes user-plane information (i.e. a user-plane resource)); a receiver that receives (see Kawasaki, Fig. 7, item 740, par. [0171], lines 1-3: The WLAN interface unit 740 serves as a data transmission and/or reception unit configured to transmit and/or receive user data and/or a control message) an ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message of a default Evolved Packet System (EPS) bearer context activation procedure, wherein the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message contains a second set of parameters (see Kawasaki, par. [0521], lines 1-7: on the basis of the reception of the Activate default EPS bearer context request and/or in accordance with the seventh identification information included in the Activate default EPS bearer context request and/or PDN connection attribute information and/or policy of the UE 10, the UE 10 may transmit an Activate default EPS bearer context reject to the MME 40 via the eNB 45, and see Kawasaki, par. [0484]: the MME 40 may include the PCO and/or the ESM Cause and/or the TFT and/or the bearer identification information identifying the default bearer, and/or the PDN connection ID and/or the PDN connection attribute information, in the Activate default EPS bearer context request; in this case, the UE receives the activate default EPS bearer context request which contains at least seventh identification information, PDN connection ID, PDN connection attribute information, and bearer identification information (corresponding to a second set of parameters)); a control circuit (see Kawasaki, Fig. 7, item 700, par. [0169], lines 1-4: The control unit 700 serves as a function unit for controlling the UE 10. The control unit 700 implements various processes by reading out and executing various programs stored in the storage 750) that determines a condition is not fulfilled when at least one parameter in the second set of parameters does not match to a corresponding parameter in the first set of parameters (see Kawasaki, par. [0520]: in a case where the UE 10 does not support the operation mode allowed based on the operator policy and/or in a case where the operation mode allowed based on the operator policy does not comply with the policy of the UE 10, the UE 10 may reject the establishment of the first PDN connection, and see par. [0521], lines 1-7: on the basis of the reception of the Activate default EPS bearer context request and/or in accordance with the seventh identification information included in the Activate default EPS bearer context request and/or PDN connection attribute information and/or policy of the UE 10, the UE 10 may transmit an Activate default EPS bearer context reject to the MME 40 via the eNB 45, and see Kawasaki, par. [0522], lines 1-6: The UE 10 may transmit at least an Activate default EPS bearer context reject message identity (Activate default EPS bearer context reject message ID), a Procedure transaction ID, a protocol discriminator, an EPS bearer ID, and an ESM Cause included in the Activate default EPS bearer context reject, and see Kawasaki, par. [0525], lines 1-3: The ESM Cause may be information representing a reason why the Activate default EPS bearer context request is rejected, and see Kawasaki, par. [0492], lines 1-4: ESM Cause may be information representing that the PDN type of the PDN address assigned to the UE 10 is different from the PDN type requested by the UE 10 in the PDN connectivity request, and see Kawasaki, par. [0484]: the MME 40 may include the PCO and/or the ESM Cause and/or the TFT and/or the bearer identification information identifying the default bearer, and/or the PDN connection ID and/or the PDN connection attribute information, in the Activate default EPS bearer context request, and see pars. [0237-0238]: the EPS bearer context for each PDN connection will be described. FIG. 10B illustrates an example of the EPS bearer context for each PDN connection. As illustrated in FIG. 10B, the context includes at least a PDN connection ID, an IP address, a PDN type, an APN, a Network allowed mode, and an Operation mode, and see par. [0191]: the UE 10 may store the EPS bearer identification information identifying each of the default bearer for the access network A and the default bearer for the access network B. Here, the default bearer for an access network may be a default bearer for an access system of the access network. Therefore, the UE 10 may store a default bearer for a 3GPP access and a default bearer for a WLAN access in association with a multi-access PDN connection; in this case, sending the Activate default EPS bearer context reject message in accordance with PDN connection attribute information and seventh identification information (i.e. the first and second set of parameters). The sections further teach an ESM cause being the reason for rejecting and an embodiment that the ESM cause is PDN type of the PDN address assigned to the UE is different from the PDN type requested by the UE in the PDN connectivity request (i.e. first set of parameters and second set of parameters do not match). Determining the ESM cause therefore then corresponds to determining a condition that is not fulfilled when there is a mismatch of parameters. The ESM cause being the reason for rejecting corresponds to transmitting the Activate default EPS bearer context reject message in response to the ESM cause, and therefore in response to not fulfilling the condition); and in response to not fulfilling the condition, transmitting an ACTIVATE DEFAULT EPS BEARER CONTEXT REJECT message to the network (see Kawasaki, par. [0521], lines 1-7: on the basis of the reception of the Activate default EPS bearer context request and/or in accordance with the seventh identification information included in the Activate default EPS bearer context request and/or PDN connection attribute information and/or policy of the UE 10, the UE 10 may transmit an Activate default EPS bearer context reject to the MME 40 via the eNB 45, and see Kawasaki, par. [0522], lines 1-6: The UE 10 may transmit at least an Activate default EPS bearer context reject message identity (Activate default EPS bearer context reject message ID), a Procedure transaction ID, a protocol discriminator, an EPS bearer ID, and an ESM Cause included in the Activate default EPS bearer context reject, and see Kawasaki, par. [0525], lines 1-3: The ESM Cause may be information representing a reason why the Activate default EPS bearer context request is rejected, and see Kawasaki, par. [0492], lines 1-4: ESM Cause may be information representing that the PDN type of the PDN address assigned to the UE 10 is different from the PDN type requested by the UE 10 in the PDN connectivity request; in this case, an ESM cause being the reason for rejecting and an embodiment that the ESM cause is PDN type of the PDN address assigned to the UE is different from the PDN type requested by the UE in the PDN connectivity request (i.e. first set of parameters and second set of parameters do not match). Determining the ESM cause therefore then corresponds to determining a condition that is not fulfilled when there is a mismatch of parameters. The ESM cause being the reason for rejecting corresponds to transmitting the Activate default EPS bearer context reject message in response to the ESM cause, and therefore in response to not fulfilling the condition). However, Kawasaki does not teach: wherein the MA PDU session is in a 5G system (5GS) Hashmi, in the same field of endeavor, teaches: wherein the MA PDU session is in a 5G system (5GS) (see Hashmi, pars. [0019-0021]: The UE 104 may reject the Activate Default EPS Bearer Context Request as the corresponding NSSAI is rejected in that PLMN while the UE was on 5G, and b) The UE 104 might accept the Activate Default EPS Bearer Context Request, but session continuity to 5G during handover/reselection from LTE 102 to 5GC 106 is not guaranteed as the corresponding NSSAI for the PDN is stored in the rejected list in the UE 104. Since the corresponding NSSAI is stored in the rejected NSSAI list, the UE 104 will not request for that slice, and that PDN connection will be forced to be released, as that slice will not be received as part of the allowed NSSAI list. c) The UE 104 will not be able to transfer PDN connection from non-3GPP connected to EPC (ePDG) to 5GC 106, if the S-NSSAI provided by the network during the PDN connection establishment via non-3GPP is in the rejected NSSAI list) Hashimi also teaches support for rejecting the Activate Default EPS Bearer Context Request based on a corresponding S-NSSAI being stored in a list of rejected NSSAI at least in Fig. 1 and pars. [0018-0021]. It is also taught that there is a stored list of allowed NSSAI at least in Fig. 4 and par. [0062] and exclusivity between the rejected NSSAI and allowed NSSAI is taught at least in par. [0114]. Therefore, a reject message is sent based on a corresponding S-NSSAI being stored in a list of rejected NSSAI and not being stored in a list of allowed NSSAI, providing further support for the limitations for “determining a condition is not fulfilled” and “in response to not fulfilling the condition, transmitting an ACTIVATE DEFAULT EPS BEARER CONTEXT REJECT message” as claimed. Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the MA PDU session of Kawasaki with the session being in a 5G system of Hashmi with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of enabling real time delivery of more flexible types of network slices (see Hashmi, par. [0010]). Regarding claims 5, 15, the combination of Kawasaki in view of Hashmi teaches the method or UE. Kawasaki further teaches: wherein the condition comprises a PDN type value of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message is the same as a stored PDU session type of the MA PDU session of the first set of parameters (see Kawasaki, par. [0521], lines 1-7: on the basis of the reception of the Activate default EPS bearer context request and/or in accordance with the seventh identification information included in the Activate default EPS bearer context request and/or PDN connection attribute information and/or policy of the UE 10, the UE 10 may transmit an Activate default EPS bearer context reject to the MME 40 via the eNB 45, and see Kawasaki, par. [0522], lines 1-6: The UE 10 may transmit at least an Activate default EPS bearer context reject message identity (Activate default EPS bearer context reject message ID), a Procedure transaction ID, a protocol discriminator, an EPS bearer ID, and an ESM Cause included in the Activate default EPS bearer context reject, and see Kawasaki, par. [0492], lines 1-4: ESM Cause may be information representing that the PDN type of the PDN address assigned to the UE 10 is different from the PDN type requested by the UE 10 in the PDN connectivity request). Claims 2-3 and 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki in view of Hashmi, as applied to claims 1, 5, 11, and 15 above, and further in view of Youn et al. (US 11,528,763), hereinafter "Youn". Regarding claim 2, 12, the combination of Kawasaki in view of Hashmi teaches the method or UE. However, the combination of Kawasaki in view of Hashmi does not teach: wherein the UE locally releases the MA PDU session and performs a registration procedure for mobility and periodic registration update over non-3GPP access. Youn, in the same field of endeavor, teaches: wherein the UE locally releases the MA PDU session (see Youn, col. 11, lines 39-40: a UE is waiting for a response from a network after initiating a PDU session release procedure) and performs a registration procedure for mobility and periodic registration update over non-3GPP access (see Youn, col. 17, lines 47-50: the UE may request user plane allocation through a registration/service request over the access. When the UE is temporarily deregistered from one access and then performs registration, and see Youn, col. 17, lines 59-62: When the UE performs registration or performs a service request procedure, the UE may forward information indicating that the UE wants to activate the MA PDU session, and see Youn, col. 20, lines 62-66: The UE performs a registration procedure or a service request procedure through non-3GPP. Here, the UE may request activation of the MA PDU session by including a list of PDU sessions to be activated in a registration/service request message). Youn also teaches support for the UE maintaining connections over 3GPP and non-3GPP access (see Youn, col. 2, lines 43-47: a terminal (or UE) having an IP capability can access an IP service network (e.g., IMS), provided by a service provider (i.e., an operator), via various elements within an EPC based on non-3GPP access as well as based on 3GPP access). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the method of the combination of Kawasaki in view of Hashmi with the release and registration of Youn with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of efficiently allocating and using resources (see Youn, col. 18, lines 53-59). Regarding claims 3, 13, the combination of Kawasaki in view of Hashmi, and further in view of Youn teaches the method or UE. The combination of Kawasaki in view of Hashmi does not teach, but Youn teaches: wherein a PDU session status information element (IE) is included in the REGISTRATION REQUEST message of the registration procedure for mobility and periodic registration update (see Youn, col. 20, lines 62-66: The UE performs a registration procedure or a service request procedure through non-3GPP. Here, the UE may request activation of the MA PDU session by including a list of PDU sessions to be activated in a registration/service request message; in this case, a list of PDU sessions to be activated corresponds to a PDU session status IE). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the method of the combination of Kawasaki in view of Hashmi with the PDU information included in a registration of Youn with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of efficiently allocating and using resources (see Youn, col. 18, lines 53-59). Claims 4 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki in view of Hashmi, and further in view of Youn, as applied to claims 2-3 and 12-13 above, and further in view of Venkataraman et al. (US 2023/0180169), hereinafter “Venkataraman”. Regarding claims 4, 14, the combination of Kawasaki in view of Hashmi, and further in view of Youn teaches the method or UE. However, the combination of Kawasaki in view of Hashmi, and further in view of Youn does not teach: wherein the PDU session status IE is for indicating to the network that the user-plane resources established over non-3GPP access for the MA PDU session are released. Venkataraman, in the same field of endeavor, teaches: wherein the PDU session status IE is for indicating to the network that the user-plane resources established over non-3GPP access for the MA PDU session are released (see Venkataraman, par. [0076], lines 6-10: The UE can also ensure PDU Sessions associated with incompatible slices are either released implicitly and indicated to the network via a PDU Session status IE in a Registration Request, and see Venkataraman, par. [0099], lines 1-6: various techniques can provide for UE slice support over non-3GPP and 3GPP Access Technologies. If the UE is registered over different AMFs on 3GPP and non-3GPP Access technologies, then it can choose to activate mutually exclusive slices simultaneously independently; in this case, released slices (corresponding to user-plane resources) are indicated to the network). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the PDU session status IE of the combination of Kawasaki in view of Hashmi, and further in view of Youn with the PDU session status IE indicating released resources of Venkataraman with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of ensuring the maximum compatible slices are allowed (see Venkataraman, par. [0082], lines 1-11). Claims 6 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki in view of Hashmi, as applied to claims 1, 5, 11, and 15 above, and further in view of Watfa (US 2023/0199605), hereinafter “Watfa”. Regarding claims 6, 16, the combination of Kawasaki in view of Hashmi teaches the method or UE. However, the combination of Kawasaki in view of Hashmi does not teach: wherein the condition comprises a PDN address of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message is the same as a stored PDU address of the MA PDU session of the first set of parameters. Watfa, in the same field of endeavor, teaches: wherein the condition comprises a PDN address of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message is the same as a stored PDU address of the MA PDU session of the first set of parameters (see Watfa, pars. [0125-0126]: the PDU address of the PDU session shall be mapped to the PDN address of the default EPS bearer context as follows: 1) the PDN address of the default EPS bearer context is set to the PDU address of the PDU session, if the PDU session type is “IPv4”, “IPv6” or “IPv4v6”; in this case, Watfa teaches a scenario for the PDN address being the same as a PDU address for the default EPS bearer context). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the method of the combination of Kawasaki in view of Hashmi with the condition comprising a PDN address matching a stored PDU address of Watfa with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of improving cellular internet of things optimizations (see Watfa, par. [0016], lines 1-4). Claims 7 and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki in view of Hashmi, as applied to claims 1, 5, 11, and 15 above, and further in view of Chiba et al. (US 2020/0053615), hereinafter “Chiba”. Regarding claims 7, 17, the combination of Kawasaki in view of Hashmi teaches the method or UE. However, the combination of Kawasaki in view of Hashmi does not teach: wherein the condition comprises a stored selected Session and Service Continuity (SSC) mode of the MA PDU session of the first set of parameters is set to "SSC mode 1". Chiba, in the same field of endeavor, teaches: wherein the condition comprises a stored selected Session and Service Continuity (SSC) mode of the MA PDU session of the first set of parameters is set to "SSC mode 1" (see Chiba, par. [0172], lines 1-9: SSC mode 1 in the present embodiment is a mode of the session and service continuity in which the same TUPF is continuously maintained regardless of the access technology such as the Radio Access Technology (RAT) and the cell the UE_A 10 uses to connect to a network. To be more specific, SSC mode 1 may be a mode in which even in a case that the mobility of the UE_A 10 occurs, the session and service continuity is achieved without changing the TUPF used by the established PDU session, and see Chiba, par. [0179], lines, 4-5: The Default SSC mode may be information indicating SSC mode 1). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the method of the combination of Kawasaki in view of Hashmi with the condition being a SSC mode set to mode 1 of Chiba with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of enabling simultaneous connection to a core network via multiple access networks (see Chiba, par. [0016], lines 1-7). Claims 8 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki in view of Hashmi, as applied to claims 1, 5, 11, and 15 above, and further in view of Bakker (US 2022/0053447), hereinafter “Bakker”. Regarding claims 8, 18, the combination of Kawasaki in view of Hashmi teaches the method or UE. However, the combination of Kawasaki in view of Hashmi does not teach: wherein the condition comprises an EPS session management (ESM) cause of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message matches to an 5G session management (5GSM) cause of the MA PDU session of the first set of parameters, or EPS session management (ESM) cause is included and set to single address bearers only allowed and no 5GSM cause of the MA PDU session of the first set of parameters is stored, or EPS session management (ESM) cause is not included and no 5GSM cause of the MA PDU session of the first set of parameters is stored. Bakker, in the same field of endeavor, teaches: wherein the condition comprises an EPS session management (ESM) cause of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message matches to an 5G session management (5GSM) cause of the MA PDU session of the first set of parameters, or EPS session management (ESM) cause is included and set to single address bearers only allowed and no 5GSM cause of the MA PDU session of the first set of parameters is stored, or EPS session management (ESM) cause is not included and no 5GSM cause of the MA PDU session of the first set of parameters is stored (see Bakker, par. [0120], lines 1-6: The cause code may contain a session management cause value. The session management cause value may be one of one or more predefined values and transmitting the second registration request message is in response to the UE detecting the session management cause value is set to the one of the one or more predefined values, and see Bakker, par. [0042], lines 1-5: the UE performs the attach (e.g., a normal attach) or the attach for emergency bearer services with the second network if the ESM cause value in the PDN CONNECTIVITY REJECT message from the first network matches one or more predefined ESM cause values, and see Bakker, par. [0052], lines 1-4: the UE performs the registration for emergency services with the second network if the 5GSM cause value matches one or more predefined 5GSM cause values; in this case, the cause code for the rejection message can be based on session management cause matching predefined (i.e. stored) cause values, for ESM and 5GSM). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the condition of the combination of Kawasaki in view of Hashmi with the condition being a comparison between session management causes of Bakker with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of establishing interworking between 5G and EPC networks for maintaining connections during handover (see Bakker, par. [0012], lines 13-21). Claims 9-10 and 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Kawasaki in view of Hashmi, as applied to claims 1, 5, 11, and 15 above, and further in view of Takakura (US 11,375,568), hereinafter “Takakura”. Regarding claims 9, 19, the combination of Kawasaki in view of Hashmi teaches the method or UE. However, the combination of Kawasaki in view of Hashmi does not teach: wherein the condition comprises an S-NSSAI value of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message is the same as a stored S-NSSAI value of the MA PDU session of the first set of parameters. Takakura, in the same field of endeavor, teaches: wherein the condition comprises an S-NSSAI value of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message is the same as a stored S-NSSAI value of the MA PDU session of the first set of parameters (see Takakura, col. 56, lines 29-45: the UE_A 10 may include policies (UE policies) and/or rules, management functions of the policies and/or rules, policy enforcer to cause the UE_A 10 to operate based on the policies and/or rules, one or more applications, and session management instances (session managers) for managing one or more PDU sessions to establish or attempt to establish based on requests from each application in a storage unit and/or controller within the UE_A 10, and congestion management initiated by the UE_A 10 may be implemented by performing any of the 12th to 15th behaviors as the fourth process based on these. The policies and/or rules may include one or more of network slice association rules, and/or priority management rules for backoff timers, and/or Network Slice Selection Policy (NSSP), which may further be configured to the UE_A 10 in advance or received from the network. Here, the policy enforcer may be an NSSP enforcer, and see Takakura, col. 34, lines 38-41: the DNN corresponding to the first congestion management, the third congestion management, and the fourth congestion management may be the S-NSSAI indicated by the 17th identification information, and see Takakura, col. 54, lines 24-34: by transmitting…17th identification information and/or the 18th identification information included in the PDU session establishment reject message, the SMF_A 230 may indicate that a request for establishment of a PDU session belonging to a network slice has been rejected, or may indicate a network slice to which the PDU session is not allowed to belong; in this case, there is support for establishing a set of network slices to which the PDU session is not allowed to belong (i.e. matching S-NSSAI values to a blacklist for a conditional acceptance). Network slice selection is also performed and used for congestion management). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the condition of the combination of Kawasaki in view of Hashmi with the condition being matching a network slice of Takakura with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of performing congestion management in the network (see Takakura, col. 2, lines 37-41). Regarding claim 10, 20, the combination of Kawasaki in view of Hashmi teaches the method or UE. However, the combination of Kawasaki in view of Hashmi does not teach: wherein the condition comprises an APN of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message maps to a same DNN as a stored DNN of the MA PDU session of the first set of parameters. Takakura, in the same field of endeavor, teaches: wherein the condition comprises an APN of the ACTIVATE DEFAULT EPS BEARER CONTEXT REQUEST message maps to a same DNN as a stored DNN of the MA PDU session of the first set of parameters (see Takakura, col. 77, lines 11-16: the UE_A 10 may be configured to be able to perform an ESM procedure by using the APN equivalent to this specific DNN in the S1 mode in the modification of the system. Accordingly, based on this configuration, the UE_10 may transmit a PDN connectivity establishment request message using this specific APN, and see Takakura, col. 16, lines 42-49: The APN may be identification information for identifying the core network and an external network such as the DN. Furthermore, the APN can also be used as information for selecting a gateway such as the PGW_A 30/UPGW_A 130/UPF_A 235 for connecting the core network A_90. Note that the APN may be a Data Network Name (DNN). Therefore, the APN may be represented by a DNN, or the DNN may be represented by the APN; in this case, the UE may perform an ESM procedure and select a gateway based on a comparison between APN and DNN values). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have modified the condition of the combination of Kawasaki in view of Hashmi with the condition being matching an APN and DNN of Takakura with a reasonable expectation of success. One of ordinary skill in the art would have been motivated to make this modification for the benefit of performing congestion management in the network (see Takakura, col. 2, lines 37-41). Response to Arguments Applicant's arguments filed 02/26/2026 have been fully considered but they are not persuasive. Applicant argues that there is “no teaching of ‘determining a condition is not fulfilled when at least one parameter in the second set of parameters does not match to a corresponding parameter in the first set of parameters; and in response to not fulfilling the condition, transmitting an ACTIVATE DEFAULT EPS BEARER CONTEXT REJECT message to the network’ “. Examiner respectfully disagrees and points to Kawasaki in par. [0118] which teaches “The PDN connection ID is identification information for identifying a PDN connection. The UE 10, the TWAG 74, and the PGW 30 may store the same identification information”, par. [0191] which teaches “the UE 10 may store the EPS bearer identification information identifying each of the default bearer for the access network A and the default bearer for the access network B. Here, the default bearer for an access network may be a default bearer for an access system of the access network. Therefore, the UE 10 may store a default bearer for a 3GPP access and a default bearer for a WLAN access in association with a multi-access PDN connection”, pars. [0237-0238] which teach “the EPS bearer context for each PDN connection will be described. FIG. 10B illustrates an example of the EPS bearer context for each PDN connection. As illustrated in FIG. 10B, the context includes at least a PDN connection ID, an IP address, a PDN type, an APN, a Network allowed mode, and an Operation mode”, par. [0484] which teaches “the MME 40 may include the PCO and/or the ESM Cause and/or the TFT and/or the bearer identification information identifying the default bearer, and/or the PDN connection ID and/or the PDN connection attribute information, in the Activate default EPS bearer context request”, par. [0492] which teaches “ESM Cause may be information representing that the PDN type of the PDN address assigned to the UE 10 is different from the PDN type requested by the UE 10 in the PDN connectivity request”, par. [0520] which teaches “in a case where the UE 10 does not support the operation mode allowed based on the operator policy and/or in a case where the operation mode allowed based on the operator policy does not comply with the policy of the UE 10, the UE 10 may reject the establishment of the first PDN connection”, par. [0521] which teaches “on the basis of the reception of the Activate default EPS bearer context request and/or in accordance with the seventh identification information included in the Activate default EPS bearer context request and/or PDN connection attribute information and/or policy of the UE 10, the UE 10 may transmit an Activate default EPS bearer context reject to the MME 40 via the eNB 45”, par. [0522] which teaches “The UE 10 may transmit at least an Activate default EPS bearer context reject message identity (Activate default EPS bearer context reject message ID), a Procedure transaction ID, a protocol discriminator, an EPS bearer ID, and an ESM Cause included in the Activate default EPS bearer context reject”, par. [0525] which teaches “The ESM Cause may be information representing a reason why the Activate default EPS bearer context request is rejected”, and par. [0673] which teaches “The PDN connection attribute information may be information indicating that the PDN connection established in the current PDN connectivity procedure is the multi-access PDN connection, and/or information indicating that user data transmitted and/or received by using the PDN connection established in the current PDN connectivity procedure is allowed to be transmitted and/or received through the access network A and the access network B”. These sections teach that PDN connection attribute information is maintained (i.e. a stored first set of parameters) and the UE receives the activate default EPS bearer context request which contains at least seventh identification information, PDN connection ID, PDN connection attribute information, and bearer identification information (corresponding to a second set of parameters). The sections also teach sending the Activate default EPS bearer context reject message in accordance with PDN connection attribute information and seventh identification information (i.e. the first and second set of parameters). The sections further teach an ESM cause being the reason for rejecting and an embodiment that the ESM cause is PDN type of the PDN address assigned to the UE is different from the PDN type requested by the UE in the PDN connectivity request (i.e. first set of parameters and second set of parameters do not match). Determining the ESM cause therefore then corresponds to determining a condition that is not fulfilled when there is a mismatch of parameters. The ESM cause being the reason for rejecting corresponds to transmitting the Activate default EPS bearer context reject message in response to the ESM cause, and therefore in response to not fulfilling the condition. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Huang-Fu (US 2021/0250409) teaches a method of handling multi-access (MA) Protocol data unit (PDU) session upgrade among 3GPP access networks and non-3GPP access networks. Huang-Fu et al. (US 2020/0404552) teaches a method of handling multi-access (MA) Protocol data unit (PDU) session under inter-system change among 3GPP access networks and non-3GPP access networks. Y. -i. Choi et al. ("Mobility Management in the 5G Network between Various Access Networks") teaches the concept of Multiple Access Protocol Data Unit (MA-PDU) session to control large data transmission in 5G network and a dynamic anchoring mobility management between different access networks Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to CALEB J BALLOWE whose telephone number is (571)270-0410. The examiner can normally be reached MON-FRI 7:30-5. 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, Nishant B. Divecha can be reached at (571) 270-3125. 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. /C.J.B./Examiner, Art Unit 2419 /Nishant Divecha/Supervisory Patent Examiner, Art Unit 2419
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Prosecution Timeline

Show 6 earlier events
Oct 03, 2025
Request for Continued Examination
Oct 07, 2025
Response after Non-Final Action
Nov 26, 2025
Non-Final Rejection mailed — §103
Feb 26, 2026
Response Filed
Apr 16, 2026
Final Rejection mailed — §103
Jun 11, 2026
Interview Requested
Jun 17, 2026
Applicant Interview (Telephonic)
Jun 17, 2026
Examiner Interview Summary

Precedent Cases

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5-6
Expected OA Rounds
18%
Grant Probability
57%
With Interview (+39.2%)
2y 7m (~0m remaining)
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