Prosecution Insights
Last updated: August 17, 2026
Application No. 18/080,019

MA PDU HANDLING OF INTERWORKING FROM 5G TO 2G/3G

Final Rejection §103
Filed
Dec 13, 2022
Priority
Jan 03, 2022 — provisional 63/296,029
Examiner
KASSIM, KHALED M
Art Unit
2400
Tech Center
2400 — Computer Networks
Assignee
MediaTek Inc.
OA Round
2 (Final)
70%
Grant Probability
Favorable
3-4
OA Rounds
11m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allowance Rate
379 granted / 539 resolved
+12.3% vs TC avg
Strong +38% interview lift
Without
With
+38.3%
Interview Lift
resolved cases with interview
Typical timeline
4y 7m
Avg Prosecution
9 currently pending
Career history
554
Total Applications
across all art units

Statute-Specific Performance

§101
8.1%
-31.9% vs TC avg
§103
61.0%
+21.0% vs TC avg
§102
16.1%
-23.9% vs TC avg
§112
8.8%
-31.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 539 resolved cases

Office Action

§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 . Application Status This is in response to the amendment filed 08/11/2025. Claims 1-20 are pending and presented for examination. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-16 and 18-20 are rejected under 35 U.S.C. 103 as being unpatentable over Huang-Fu et al. US 20210105858 A1, hereinafter, “Huang-Fu”) in view of Huang-Fu et al. (US 10257760 B2, hereinafter, “Huang-Fu-1”) Per claim 1, Huang-Fu discloses A method, comprising: maintaining a 5G Multi-Access Protocol Data Unit (MA PDU) session with a User Equipment (UE) by a 5G network entity in a 5G network, Maintaining a 5G Multi-Access PDU (MA PDU) session with a User Equipment (UE). Clearly defines that the 5G network manages an MA PDU session, satisfying the setup of the claimed method. [ie. “Accordingly, 3GPP introduced. Multi-Access (MA) PDU session in 5GS. An MA PDU session can be configured to use one 3GPP access network or one non-3GPP access network at a time, or simultaneously one 3GPP access network and one non-3GPP access network. The 5GS can initiate a PDU session release procedure to release one specific access type or both access types for an MA PDU session”, Huang-Fu, [0005] wherein a 4G Packet Data Network (PDN) connection is established as a user plane resource for the 5G MA PDU session; Establishes that the MA PDU session logically includes the 4G PDN bearer, fulling the structure requirement [ie. “In 5G, a PDU session establishment procedure is a parallel procedure of a PDN connection procedure in 4G. A PDU session defines the association between the UE and the data network that provides a PDU connectivity service. Each PDU session is identified by a POD session ID, and may include multiple QoS flows and QoS rules. In 5G network, QoS flow is the finest granularity for QoS management to enable more QoS control. The concept of QoS flow in 5G is like EPS bearer in 4G”, Huang-Fu, [0029] Hung-Fu does not disclose but Hung-Fu-1 discloses detecting by the 5G network entity in the 5G network that a 2G/3GPDP context is activated using parameters from a default evolved packet system (EPS) bearer context of the 4G PDN connection; Implies EPS bearer parameters are reused during hand-over from 4G to 3G, triggering PDP activation using LTE originated context. Detecting that a 2G/3G PDP context is activated using parameters from the default EPS bearer context. [ie. “It is possible that when a PDP context is activated in the 3G system via bearer change from the 4G system, one or more of the parameters of the LLC SAPI and the radio priority is omitted. A parameter set 113 of the 2G system has all parameters listed as mandatory including the TI, the R99 QoS, the LLC SAPI, and the radio priority”, Huang-Fu-1, (18)] and initiating to release the 5G MA PDU session upon the activation of the 2G/3G PDP context. Directly confirms that session release occurs in response to inter-RAT fallback with reused/missing bearer parameters [ie. “The UE performs bearer termination by releasing the PDP context. In one embodiment, the PDP context is locally released”, Huang-Fu-1, (Abstract)] It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. Huang-Fu-1 provides essential fallback handling logic complements the 5G MA PDU session structure. While Huang-Fu describes maintaining an MA PDU session with a 4G PDN leg, Huang-Fu-1 addresses what happens when the UE transitions to 2G/3G and activates a PDP context using parameters from that 4G leg. This reuse triggers a conflict in session ownership and configuration, motivating the network or UE to release the MA PDU session to preserve system integrity. Per claim 2, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 1, - refer to the indicated claim for reference(s). Huang-Fu further discloses wherein the 5G network entity is a session management (SM) entity, wherein the SM entity contains session management function (SMF). Explicitly identifies SMF as a session management entity in 5G responsible for PDU session management [ie. “In Non-Access Stratum (NAS) layer, the AMF 110 and the SMF 111 communicate with RAN and 5GC for access and mobility management and PDU session management of wireless access devices in the 5G network 100”, Huang-Fu, [0029]] Huang-Fu-1 further discloses at least one of a Serving GPRS Support Node (SGSN), a mobility management entity (MME) Identifies SGSN as the session-handling core in 2G/3G, involved in PDP context management during fallback [ie. “ The RNC of the 3G system connects via the lu interface with a serving GPRS support node (SGSN) 106, which is connected to SAE gateway 106. A 2G system has a base transceiver station (BTS) 104 and a base station controller (BSC). The BSC of the 2G system connects with SGSN 106 via the Gb interface.”, Huang-Fu-1, (17)] It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. The SMF in the 5G core (5GC) manages PDU sessions across multiple access types, including non-3G)) and 3GPP LTE (4G). However, when a user equipment (UE) falls back t a 2G/3G network, the 5GC no longer manages the user plane directly. In this scenario, the Serving GPRS Support Node (SGSN) – the session management entity in the legacy 2/3G packet core--- becomes responsible for managing the session using PDP context. To ensure seamless session continuity and proper session lifecycle management, the SMF must detect that the session has transitioned to SGSN control, and subsequently release the MA PDU session. Per claim 3, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 1, - refer to the indicated claim for reference(s). Huang-Fu-1 further discloses wherein the 2G/3GPDP context is activated based on a configured set of essential 2G/3G PDP parameters of the default EPS bearer context of the PDN connection. The 2G/3G PDP context activation depends on whether the essential parameters (TI, R99 QoS, LLC SAPI, radio priority) are available or preconfigured in the EPS bearer context (or derived from it). [ie. “To transfer the bearer to the 3G system, parameter set 212 for the 3G system requires the TI and the R99 QoS to be mandatory while having the LLC SAPI, and the radio priority as optional. Therefore, in the inter-RAT bearer change procedure, the UE may detect missing parameters/missing IEs if 4G parameter set 211 does not include any one of the optional parameters of the TI and the R99 QoS. If the missing parameter is detected, a bearer preservation procedure is performed to keep the bearer continuity”, Huang-Fu-1, (25)] The UE used a configured set of parameters, whether directly from EPS bearer or retrieved from a pre-set database, to support PDP context activation in 2G/3G. [ie. “ The UE can access preconfigured/predefined database 412 and retrieves the preconfigured value for the LLC SAPI such the new bearer can be established. Similarly, if the radio priority parameter is not presented, the UE retrieves the preconfigured/predefined radio priority value from database 412”, Huang-Fu-1, (30)] Per claim 4, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 3, - refer to the indicated claim for reference(s). Huang-Fu-1 further discloses wherein the set of essential 2GPDP parameters comprises a Logic Link Control (LLC) Service Access Point Identifier (SAPI), a radio priority parameter, a transaction identifier parameter, and a R99 Quality of Service (QoS) parameter. [ie. “To transfer the bearer to the 2G system, parameter set 222 for the 2G system requires all four parameters the TI, the R99 QoS, the LLC SAPI, and the radio priority to be mandatory. Therefore, in the inter-RAT bearer change procedure, the UE may detect missing parameters/missing IEs if 4G parameter set 221 does not include any one of the optional parameters of the TI, the R99 QoS, the LLC SAPI, and the radio priority.”, Huang-Fu-1, (26)] It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. In legacy 2G GPRS networks, the PDP context must be configured with a complete set of mandatory parameters to enable valid session establishment and proper QoS handling. These parameters include: LLC SAPI: Identify the logical link for data transmission between UE and SGSN Radio priority: Control resources scheduling and prioritization for bearer traffic Transaction Identifier (TI): Uniquely identifies the PDO context activation procedure R99 QoS: Defines the end-to-end quality of service required for data session However, these fields are optional or handled differently in EPS bearer context (LTE). Therefore, when the UE reuses the EPS bearer configuration to activate a PDP context in 2G, these parameters must be explicitly present or derived to comply with 2G PDP context requirements. The combination of these 4 parameters is needed to: enable successful PDP context activation during the inter-fallback; ensure compatibility with SGSN and 2G core requirements and prevent session rejection or degraded service due to incomplete PDP configuration. Per claim 5, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 3, - refer to the indicated claim for reference(s). Huang-Fu-1 further discloses wherein the set of essential 3G PDP parameters comprises a transaction identifier parameter and a R99 Quality of Service (QoS) parameter. Directly identifies TI (transaction Identifier) and R99 QoS as the mandatory parameters for 3GPP context activation. These are precisely the parameters claimed as “essential 3G PDP parameters”. [ie. “To transfer the bearer to the 3G system, parameter set 212 for the 3G system requires the TI and the R99 QoS to be mandatory while having the LLC SAPI, and the radio priority as optional.”, Huang-Fu-1, (25)] It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. Without these two parameters, the 3G network cannot activate a PDP context, and the fallback procedure from LTE (EPS) to 3G would fail. Thus, the method must ensure that the default EPS bearer context includes, derives, or maps these two parameters when initiating PDP context activation in the 3G domain. This very important during inter-RAT mobility, where the 5G or LTE session is handed over to legacy systems. If the TI and R99 QoS are not present or mapped correctly, the session cannot continue in 3G, and the UE may lose connectivity. Per claim 6, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 1, - refer to the indicated claim for reference(s). wherein the 5G network entity initiates a network-requested PDU session release procedure over non-3GPP access. Huang-Fu further discloses The below paragraph states that the 5G network (5GS) --- which includes SMF ---initiates the PDU session release. The release is targeted at the non-3GPP access leg, clearly fulfilling the requirement of a network-requested release over non-3GPP access. [ie. “ In step 1041, the 5GS network triggers a PDU session release procedure to release the MA PDU session over the non-3GPP access (e.g., MA PDU session's user plane resource on non-3GPP access), by sending a PDU SESSION RELEASE COMMAND message to UE 1001, with an access type IE set to “non-3GPP” and with PSI=1. Note that, in another embodiment, the MA PDU session may be established over the other access type (e.g., non-3GPP access) and the access type IE in the PDU SESSION RELEASE COMMAND message may be set to “non-3GPP””, Huang-Fu, [0051]] Per claim 7, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 1, - refer to the indicated claim for reference(s). Huang-Fu further discloses wherein the 5G network entity locally releases the 5G MA PDU session. The below paragraph shows that the release of the entire MA PDU session can be performed locally by the UE. While the paragraph focuses on the UE, this behavior is symmetrical in many networks design --- if the UE does not respond or confirm, the SMF (network entity) may perform a local release to clean up the session state. The presence of the optional local release behavior indicates that either the network or UE may initiate such action depending on conditions [ie. “That is, UE 1001 does not diagnose an error for the access type IE, and may further process the release command. Note that, in another embodiment, UE 1001 may release the whole MA PDU session (i.e., UE 1001 may enter PDU SESSION INACTIVE state), instead of keeping the MA PDU session”, Huang-Fu, [0052]] Per claim 8, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 1, - refer to the indicated claim for reference(s). Huang-Fu further discloses wherein the 5G MA PDU also has user plane resources established on 5G non-3GPP access, It confirms that the MA PDU session has user plan resources established on non-3GPP access. [ie. “In another example, the PDU session is an MA PDU session, and the UE further considers/determines the user plane resources of the MA PDU session on the first RAT access indicated in the access”, Huang-Fu, [0055]] and wherein the 5G network entity releases the entire 5G MA PDU session. It confirms that the 5G network entity (e.g.; SMF) initiates a complete MA PDU session release, via PDU SESSION RELEASE COMMAND. [ie. “ In step 1041, the 5GS network triggers a PDU session release procedure to release the MA PDU session over the non-3GPP access (e.g., MA PDU session's user plane resource on non-3GPP access), by sending a PDU SESSION RELEASE COMMAND message to UE 1001”, Huang-Fu, [0051]] Per claim 9, Hung-Fu discloses A method, comprising: maintaining a 5G Multi-Access protocol data unit (MA PDU) session by a User Equipment (UE) in a 5G network, Maintaining a 5G Multi-Access PDU (MA PDU) session with a User Equipment (UE). Clearly defines that the 5G network manages an MA PDU session, satisfying the setup of the claimed method. [ie. “Accordingly, 3GPP introduced. Multi-Access (MA) PDU session in 5GS. An MA PDU session can be configured to use one 3GPP access network or one non-3GPP access network at a time, or simultaneously one 3GPP access network and one non-3GPP access network. The 5GS can initiate a PDU session release procedure to release one specific access type or both access types for an MA PDU session”, Huang-Fu, [0005] wherein a 4G PDN connection is established as a user plane resource for the 5G MA PDU session; Establishes that the MA PDU session logically includes the 4G PDN bearer, fulling the structure requirement [ie. “In 5G, a PDU session establishment procedure is a parallel procedure of a PDN connection procedure in 4G. A PDU session defines the association between the UE and the data network that provides a PDU connectivity service. Each PDU session is identified by a POD session ID, and may include multiple QoS flows and QoS rules. In 5G network, QoS flow is the finest granularity for QoS management to enable more QoS control. The concept of QoS flow in 5G is like EPS bearer in 4G”, Huang-Fu, [0029]] Hung-Fu does not disclose but Hung-Fu-1 discloses performing an intersystem change to 2G or 3G by the UE; The below paragraph describes the UE’s ability to fall back to legacy RATs. Confirming the intersystem change capability required by the claim [ie. “ UE 101 establishes EPS bearer in the 4G system via the S1 interface, or establishes a PDP context in the 3G system via the lu interface, or establishes a PDP context in the 2G system via the Gb interface”, Huang-Fu-1, (18)] activating a PDP context using parameters from a default EPS bearer context of the 4G PDN connection Confirms reuse of EPS bearer parameters during inter-RAT fallback, leading to PDP context activation in 2G/3G [ie. “ It is possible that when a PDP context is activated in the 3G system via bearer change from the 4G system, one or more of the parameters of the LLC SAPI and the radio priority is omitted”, Huang-Fu-1, (18)] upon determining that the default EPS bearer context of the PDN connection is configured with a set of essential 2G or 3G packet data protocol (PDP) parameters; This demonstrates that EPS bearer reuse only succeeds if the required PDP parameters are present to supporting conditional PDP activation [ie. “ A parameter set 113 of the 2G system has all parameters listed as mandatory including the TI, the R99 QoS, the LLC SAPI, and the radio priority”, Huang-Fu-1, (18)] and locally releasing the 5G MA PDU session upon the activation of the PDP context. Indicates that upon successful PDP activation, the UE performs local session release --- aligning precisely with the claimed behavior [ie. “The bearer termination procedure is performed either through local release of the PDP context or through the explicit PDP context deactivation procedure”, Huang-Fu-1, (20)] It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. Huang-Fu’s teachings are to define the initial setup of a 5G MA PDU session which includes a 4G PDN connection as one of its user-plane legs. This configuration enables dual access continuity across 5G and legacy networks. However, to ensure seamless service continuity when the UE moves out of LTE or 5G coverage, the method must support inter-system fallback to legacy 2G/3G networks. Huang-Fu-1’s approach describes the fallback process such as handover, activation of a compatible PDP context, parameter validation, and the clean release of the original 5G session. Per claim 10, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 9, - refer to the indicated claim for reference(s). wherein the PDP context is activated based on the configured set of essential 2G or 3G PDP parameters of a default EPS bearer context of the 4G PDN connection. This below confirms that PDP context activation can be based on a configured set of essential 2G/3G parameter, either (1): predefine in the UE; (2): retrieved from the network; (3): obtained via signaling procedure. [ie. “In one novel aspect, upon detecting missing mandatory parameters during inter-RAT bearer change, the UE performs the bearer preservation procedure. In one embodiment, predefined/preconfigured parameter settings are used. In another embodiment, the missing parameters are obtained from the network. In yet another embodiment, signaling procedures are modified/designed to obtain the missing parameters Huang-Fu-1, (28)] Claim 11 list all the same elements of claim 4. Therefore, the supporting rationale of the rejection to claim 11 applies equally as well to claim 4 Claim 12 list all the same elements of claim 5. Therefore, the supporting rationale of the rejection to claim 12 applies equally as well to claim 5 Claim 13 list all the same elements of claim 8. Therefore, the supporting rationale of the rejection to claim 11 applies equally as well to claim 8 Per claim 14, Huang-Fu discloses A method, comprising: maintaining a 5G Multi-Access protocol data unit (MA PDU) session with a User Equipment (UE) by a 5G network entity in a 5G network, Maintaining a 5G Multi-Access PDU (MA PDU) session with a User Equipment (UE). Clearly defines that the 5G network manages an MA PDU session, satisfying the setup of the claimed method. [ie. “Accordingly, 3GPP introduced. Multi-Access (MA) PDU session in 5GS. An MA PDU session can be configured to use one 3GPP access network or one non-3GPP access network at a time, or simultaneously one 3GPP access network and one non-3GPP access network. The 5GS can initiate a PDU session release procedure to release one specific access type or both access types for an MA PDU session”, Huang-Fu, [0005] wherein a 4G PDN connection is established as a user plane resource for the 5G MA PDU session, Establishes that the MA PDU session logically includes the 4G PDN bearer, fulling the structure requirement [ie. “In 5G, a PDU session establishment procedure is a parallel procedure of a PDN connection procedure in 4G. A PDU session defines the association between the UE and the data network that provides a PDU connectivity service. Each PDU session is identified by a POD session ID, and may include multiple QoS flows and QoS rules. In 5G network, QoS flow is the finest granularity for QoS management to enable more QoS control. The concept of QoS flow in 5G is like EPS bearer in 4G”, Huang-Fu, [0029] and wherein the 5G MA PDU session also has user plane resources established on 5G non-3GPP access; Clearly identifies simultaneously active user [lane paths over both 3GPP and non-3GPP, including Wi-Fi [ie. “the MA PDU session with PSI=1 is established over both 3GPP and non-3GPP access types, and then the user-plane resources are established over both 3GPP and non-3GPP access types”, Huang-Fu, [0038]] Hung-Fu does not disclose but Hung-Fu-1 discloses It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. Huang-Fu’s teachings are to define the initial setup of a 5G MA PDU session which includes a 4G PDN connection as one of its user-plane legs. This configuration enables dual access continuity across 5G and legacy networks. However, to ensure seamless service continuity when the UE moves out of LTE or 5G coverage, the method must support inter-system fallback to legacy 2G/3G networks. Huang-Fu-1’s approach describes the fallback process such as handover, activation of a compatible PDP context, parameter validation, and the clean release of the original 5G session. Claim 15 list all the same elements of claim 4. Therefore, the supporting rationale of the rejection to claim 15 applies equally as well to claim 4. Claim 16 list all the same elements of claim 5. Therefore, the supporting rationale of the rejection to claim 16 applies equally as well to claim 5. Per claim 19, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 14, - refer to the indicated claim for reference(s). Huang-Fu further discloses wherein the 5G network entity initiates a network requested PDU session release procedure over 5G non-3GPP access. The 5G network (5GS) is clearly the entity initiating the PDU session release. The release explicitly targets the non-3GPP leg of the MA PDU session. The procedure involves a network-requested PDU SESSION RELEASE COMMAND, confirms this is not UE-initiated. [ie. “In step 1041, the 5GS network triggers a PDU session release procedure to release the MA PDU session over the non-3GPP access (e.g., MA PDU session's user plane resource on non-3GPP access), by sending a PDU SESSION RELEASE COMMAND message to UE 1001, with an access type IE set to “non-3GPP” and with PSI=1”, Huang-Fu, [0051]] Per claim 20, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 19, - refer to the indicated claim for reference(s). Huang-Fu further discloses wherein a PDU SESSION RELEASE COMMAND message does not include an access type IE, or the access type IE indicates non-3GPP access. The PDU SESSION RELEASE COMMAND message may include an access type IE to “non-3GPP” full filling the second option of the claim [ie. “Note that, in another embodiment, the MA PDU session may be established over the other access type (e.g., non-3GPP access) and the access type IE in the PDU SESSION RELEASE COMMAND message may be set to “non-3GPP””, Huang-Fu, [0051]] The following sentence describes how the command may be considered invalid, implicitly covering the case where the access type IE might be omitted or irrelevant to the MA PDU session [ie. “Specifically, the 5GSM STATUS message includes a 5GSM cause value indicating that the PDU SESSION RELEASE COMMAND message is not valid for the MA PDU session”, Huang-Fu, [0052]] Claims 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Huang-Fu et al. US 20210105858 A1, hereinafter, “Huang-Fu”) and Huang-Fu et al. (US 10257760 B2, hereinafter, “Huang-Fu-1”) in view of Huang-Fu et al. (US 20200404609 A1, hereinafter, “Huang-Fu-2”) Per claim 17, Huang-Fu and Huang-Fu-1 disclose, The method of Claim 14, - refer to the indicated claim for reference(s). Huang-Fu and Huang-Fu-1 do not disclose, but Huang-Fu-2 discloses wherein the 5G network entity initiates a network requested PDU session modification procedure over 5G non-3GPP access. It explicitly states that the 5G network (SMF) sends PDU SESSION MODIFICATION COMMAND, initiating the modification procedure. The procedure’s purpose is to shift data traffic to the non-3GPP leg (e.g., WiFi) of the MA PDU session. [ie. “In step 1042, the network sends a PDU SESSION MODIFICATION COMMAND message to UE 1001. In step 1043, UE 1001 sends a PDU SESSION MODIFICATION COMPLETE message back to the network. Through the PDU session modification procedure, the network can modify the steering mode in the ATSSS rule so that, data traffic of the MA PDU session is moved from 3GPP access to non-3GPP access”, Huang-Fu-2, [0046]] It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu and Huang-Fu-1’s teachings by incorporating Huang-Fu-2’s approach. In a 5G <A PDU session, traffic can be simultaneously routed over both 3GPP (e.g., LTE or NR) and non-3GPP (e.g., WiFi) access networks. However, when the 3GPP leg becomes unavailable --- such as during fallback to legacy 2G/3G or due to degraded radio conditions --- the MA PDU session must be adjusted to ensure continued service through the remaining access leg. This approach by Huang-Fu-2 is handled via network-initiated PDU session modification procedure, where the 5G SMF updates session routing and ATSSS policies to steer traffic exclusively over a non-3GPP leg. Per claim 18, Huang-Fu, Huang-Fu-1 and Huang-Fu-2 disclose, The method of Claim 17, - refer to the indicated claim for reference(s). Huang-Fu-2 further discloses wherein all traffic of the 5G MA PDU session is moved to 5G non-3GPP access. The below quote explicitly confirms that all traffic of the MA PDU session is redirected from the 3GPP access to the non-3GPP access (i.e., WiFi). [ie. “Through the PDU session modification procedure, the network can modify the steering mode in the ATSSS rule so that, data traffic of the MA PDU session is moved from 3GPP access to non-3GPP access”, Huang-Fu-2, [0046]] Response to Argument(s) Applicant's argument(s) filed on August 11, 2025 have been fully considered but they are not persuasive. Therefore, rejection is maintained. In the remarks, the Applicant argues in substance that: The applicant argues that The combination of prior art applied fails to teaches or suggest a " initiating to release the 5G MA PDU session upon the activation of the 2G/3G PDP context.". The applicant argued The architecture of Huang-Fu-1 predates 5G session management; it discusses only EPS bearers and 2 G/3 G PDP contexts. No portion of the reference even mentions an MA-PDU session, let alone any rule for releasing it. In response. Examiner respectively disagrees. Applicant is reminded that claims must be given their broadest reasonable interpretation. First, One cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., Inc., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). The combination of Huang-Fu and Huang-Fu-1 is a logical extension of established session management principles across evolving 3GPP network generations. With that being said, Huang-Fu (¶ 0029) discloses that The 5G core (SMF) manages legacy PDN connections as part of the MA PDU session. When the UE transitions to 2G/3G and the network detects the new context is active, it is routine session hygiene to release the old session to prevent duplication or resource leaks. Also, Huang-Fu-1, (Abstract) discloses directly confirms that session release occurs in response to inter-RAT fallback with reused/missing bearer parameters [ie. “The UE performs bearer termination by releasing the PDP context. In one embodiment, the PDP context is locally released”,]. Thus, as explained in the previous action, It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. Huang-Fu-1 provides essential fallback handling logic complements the 5G MA PDU session structure. While Huang-Fu describes maintaining an MA PDU session with a 4G PDN leg, Huang-Fu-1 addresses what happens when the UE transitions to 2G/3G and activates a PDP context using parameters from that 4G leg. This reuse triggers a conflict in session ownership and configuration, motivating the network or UE to release the MA PDU session to preserve system integrity Both references address the need for clean session transitions during inter-RAT mobility. While Huang-Fu-1 triggers release on failure, it also describes the end of the bearer’s utility in the newer RAT. Thus, the combination of prior art applied meets the scope of the claimed limitation as currently presented. the combination of prior art applied fails to teaches or suggest detecting by the 5G network entity in the 5G network that a 2G/3G PDP context is activated using parameters from a default evolved packet system (EPS) bearer context of the 4G PDN connection" as recited in Applicant's claim 1. IN response: b) Examiner respectively disagrees. Applicant is reminded that claims must be given their broadest reasonable interpretation. First, as explained in the previous action, the above limitation Implies that EPS bearer parameters are reused during hand-over from 4G to 3G, triggering PDP activation using LTE originated context. Detecting that a 2G/3G PDP context is activated using parameters from the default EPS bearer context. With that being said, Huang-Fu-1 [(18), Col. 4, lines 1-20] discloses that It is possible that when a PDP context is activated in the 3G system via bearer change from the 4G system, one or more of the parameters of the LLC SAPI and the radio priority is omitted. A parameter set 113 of the 2G system has all parameters listed as mandatory including the TI, the R99 QoS, the LLC SAPI, and the radio priority. Also, Huang-Fu-1 discloses sending SERVICE REQUEST with additional EPS bearer context-status parameters to hint the network to trigger network initiated allocation of 3G or 2G parameters [See (35), Col. 7, lines 36-55]. In current 3GPP architectures, the 5G core (SMF/AMF) is responsible for tracking session continuity and interworking with legacy systems. When a UE transitions to a legacy RAT, the 5G network is notified of the context activation via standard interworking signaling (see 3GPP TS 23.502, interworking with EPS/UMTS/GPRS). Huang-Fu-1 [see (30), (31); Col 6, lines 30-60] teaches mapping or provisioning of essential parameters from the EPS context to the PDP context during inter-RAT mobility. The network entity (whether SGSN, MME, or SMF) is involved in this parameter handover and can detect when a PDP context is activated using inherited parameters. Thus, the combination of prior art applied meets the scope of the claimed limitation as currently presented. the combination of prior art applied to teaches or suggest " locally releasing the 5G MA PDU session upon the activation of the PDP context" as recited in Applicant's claim 9. In response: Examiner respectively disagrees. Applicant is reminded that claims must be given their broadest reasonable interpretation. First, One cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., Inc., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). The combination of Huang-Fu and Huang-Fu-1 is a logical extension of established session management principles across evolving 3GPP network generations. With that being said, Huang-Fu (¶ 0029) discloses that The 5G core (SMF) manages legacy PDN connections as part of the MA PDU session. When the UE transitions to 2G/3G and the network detects the new context is active, it is routine session hygiene to release the old session to prevent duplication or resource leaks. Also, Huang-Fu-1, (Abstract) discloses directly confirms that session release occurs in response to inter-RAT fallback with reused/missing bearer parameters [ie. “The UE performs bearer termination by releasing the PDP context. In one embodiment, the PDP context is locally released”,]. Thus, as explained in the previous action, It would have been obvious to one of ordinary skill in the art before the effective filling date of the claim invention to modify Huang-Fu’s teachings by incorporating Huang-Fu-1’s approach. Huang-Fu-1 provides essential fallback handling logic complements the 5G MA PDU session structure. While Huang-Fu describes maintaining an MA PDU session with a 4G PDN leg, Huang-Fu-1 addresses what happens when the UE transitions to 2G/3G and activates a PDP context using parameters from that 4G leg. This reuse triggers a conflict in session ownership and configuration, motivating the network or UE to release the MA PDU session to preserve system integrity Both references address the need for clean session transitions during inter-RAT mobility. While Huang-Fu-1 triggers release on failure, it also describes the *end* of the bearer’s utility in the newer RAT. Thus, the combination of prior art applied meets the scope of the claimed limitation as currently presented. the combination of prior art applied fails to teaches or suggest a " detecting that the 4G PDN connection is no longer usable after intersystem change to 2G/3G, wherein the 4G PDN connection is not configured with a set of essential 2G/3G packet data protocol (PDP) parameters; and modifying or releasing the 5G MA PDU session" as now recited in Applicant's amended claim 14. In response: Examiner respectively disagrees. Applicant is reminded that claims must be given their broadest reasonable interpretation. Both Huang-Fu and Huang-Fu-1 teach that when a session leg (e.g., 4G PDN connection) is no longer usable (due to fallback or parameter incompatibility), the corresponding session should be released or modified to maintain proper operation (see Huang-Fu, [0052], [0055]; Huang-Fu-1, [(20), col. 4 lines 20-25. Also, Huang-Fu-1 [(45), Col 9, lines 35-50] discloses detecting that the 4G PDN connection is no longer usable after intersystem change to 2G/3G, Describes the UE moving from 4G to 3G and then 2G and detecting the EPS PDN leg is no longer usable due to missing parameters [ie. “Subsequently, the UE detects missing mandatory parameters during inter-RAT bearer change from 3G to 2G in an idle state. The UE performs bearer termination by releasing the PDP context”, Huang-Fu-1, (45)]. Moreover, Huang-Fu-1 discloses “the EPS bearer established in the 4G system, several parameters are optional as shown in a parameter set 111. The transaction identifier (TI), which is used in both the 2G and the 3G system, is optional for the EPS bearer setup in the 4G/LTE system”, [(18), Col 3, lines 52-62] and also discloses that A bearer termination handler 194 releases a PDP context upon detecting one or more predefined conditions”, [Huang-Fu-1, (24), Col 5, lines 1-20]. Thus, the detection of unusability (e.g., missing parameters, fallback events) is a routine network function, and the session release/modification is a direct consequence, as taught by both references. Conclusion THIS ACTION IS MADE FINAL. 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 KHALED M KASSIM whose telephone number is (571)270-3770. The examiner can normally be reached 9:00 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. /KHALED M KASSIM/supervisory patent examiner, Art Unit 2475
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Prosecution Timeline

Dec 13, 2022
Application Filed
May 09, 2025
Non-Final Rejection mailed — §103
Aug 11, 2025
Response Filed
Aug 05, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
70%
Grant Probability
99%
With Interview (+38.3%)
4y 7m (~11m remaining)
Median Time to Grant
Moderate
PTA Risk
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