Prosecution Insights
Last updated: July 17, 2026
Application No. 18/180,784

WIRELESS PACKET HEADER PROTECTION

Non-Final OA §103
Filed
Mar 08, 2023
Examiner
HEIBER, SHANTELL LAKETA
Art Unit
2645
Tech Center
2600 — Communications
Assignee
Qualcomm Incorporated
OA Round
3 (Non-Final)
77%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 77% — above average
77%
Career Allowance Rate
624 granted / 806 resolved
+15.4% vs TC avg
Strong +20% interview lift
Without
With
+19.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
22 currently pending
Career history
843
Total Applications
across all art units

Statute-Specific Performance

§101
1.5%
-38.5% vs TC avg
§103
84.4%
+44.4% vs TC avg
§102
9.4%
-30.6% vs TC avg
§112
0.6%
-39.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 806 resolved cases

Office Action

§103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 2/20/26 has been entered. Response to Arguments Applicant’s arguments with respect to the claim(s) have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claim(s) 1, 9 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe et al. (Grewe), U.S. Publication No. 2011/0206022 in view of Gage, U.S. Publication No. 2018/0368196. Regarding Claims 1 and 16, Grewe discloses a method for wireless communication performable at a wireless communication device, the method comprising: generating header integrity check information based on one or more fields of one or both of a medium access control (MAC) header (i.e., HIC 102 is a checksum value computed over MAC header 101 to indicate to a receiver that MAC header 101 is received correctly; see paragraph [0022]) or an encryption header that are to be included in a first data packet; wirelessly transmitting: the first data packet including a field having a value in accordance with the header integrity check information (i.e., HIC 102 is a checksum value; see paragraph [0022]… FIG. 1 shows an exemplary format for an IEEE 802.11 frame 100 employing FEC in accordance with an exemplary embodiment of the present invention that a transmitter might send to a receiver.; see paragraph [0021]), or the first data packet, without the field having the value that is based on the header integrity check information, followed by wirelessly transmitting a second data packet, the second data packet including the field having a value in accordance with the header integrity check information generated for the first data packet. Grewe fails to disclose generating message integrity check information, distinct from the header integrity check information, based on a data payload that is to be included in the first data packet. Gage discloses disclose generating message integrity check information, distinct from the header integrity check information, based on a data payload that is to be included in the first data packet (i.e., the PDCP data PDU of FIG. 7B includes a message integrity check value (also known as an integrity message authentication code, MAC-I) 706.; see paragraph [0120]). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Gage’s invention with Grewe’s invention for successfully and safely communicating data messages in the network. Regarding Claim 9, Grewe and Gage disclose the method as described above. Grewe fails to disclose wherein the generation of the message integrity check information is further based on one or more fields of the MAC header. Gage discloses wherein the generation of the message integrity check information is further based on one or more fields of the MAC header (see paragraph [0120]). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Gage’s invention with Grewe’s invention for successfully and safely communicating data messages in the network. Claim(s) 2 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe and Gage in view of Akisada et al. (Akisada), U.S. Publication No. 2014/0192766. Regarding Claim 2, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose wherein the header integrity check information is generated based further on one or both of: a second packet number that is distinct from a first packet number that is included in the MAC header of the first data packet and that is associated with encrypting the payload of the first data packet; or a second encryption key that is distinct from a first encryption key used to encrypt the payload of the first data packet. Akisada discloses wherein the header integrity check information is generated based further on one or both of: a second packet number that is distinct from a first packet number that is included in the MAC header of the first data packet and that is associated with encrypting the payload of the first data packet; or a second encryption key that is distinct from a first encryption key used to encrypt the payload of the first data packet (see paragraph [0063]). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Akisada’s invention with Grewe’s and Gage’s invention for suppressing wasteful power consumption and maintaining security (see paragraph [0027] of Akisada). Claim(s) 3-4 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe and Gage in view of Xu et al. (Xu), U.S. Publication No. 2023/0092744. Regarding Claim 3, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose wherein the first packet number is included in a first range of packet numbers that is allocated to data payload encryption, and wherein the second packet number is included in a second range of packet numbers that is allocated to header integrity. Xu discloses wherein the first packet number is included in a first range of packet numbers that is allocated to data payload encryption, and wherein the second packet number is included in a second range of packet numbers that is allocated to header integrity (see paragraphs [0293] and [0295]). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Xu's invention with Grewe’s and Gage’s invention to reduce transmission resource overheads (see paragraph [0296] of Xu). Regarding Claim 4, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose wherein the second packet number is greater than the first packet number, and wherein the first packet number and the second packet number are included in a range of packet numbers that is allocated to data payload encryption. Xu discloses wherein the second packet number is greater than the first packet number, and wherein the first packet number and the second packet number are included in a range of packet numbers that is allocated to data payload encryption (see paragraph [0295]). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Xu's invention with Grewe’s and Gage’s invention to reduce transmission resource overheads (see paragraph [0296] of Xu). Claim(s) 5-6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe and Gage in view of Roth et al. (Roth), U.S. Patent No. 9,602,482. Regarding Claim 5, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose wherein the second packet number comprises at least a portion of a timestamp associated with transmission of the first data packet. Roth discloses wherein the second packet number comprises at least a portion of a timestamp associated with transmission of the first data packet (see col. 8, lines 48-64). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Roth's invention with Grewe’s and Gage’s invention for providing security precautions to prevent unauthorized devices from accessing the service as described throughout Roth. Regarding Claim 6, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose further comprising: generating a pair of pairwise encryption keys during an association process with another wireless communication device, wherein the pair of pairwise encryption keys includes the first encryption key and the second encryption key. Roth discloses generating a pair of pairwise encryption keys during an association process with another wireless communication device, wherein the pair of pairwise encryption keys includes the first encryption key and the second encryption key (see col. 5, lines 17-33). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Roth's invention with Grewe’s and Gage’s invention for providing security precautions to prevent unauthorized devices from accessing the service as described throughout Roth. Claim(s) 7 and 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe and Gage in view of Mozumdar et al. (Mozumdar), U.S. Publication No. 2021/0314351. Regarding Claim 7, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose wherein the field having the value in accordance with the header integrity check information includes: at least a portion of the second packet number; or at least a portion of the second packet number and an encryption key identifier. Mozumdar discloses wherein the field having the value in accordance with the header integrity check information includes: at least a portion of the second packet number (see figure 1 and paragraph [0038]); or at least a portion of the second packet number and an encryption key identifier. It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Mozumdar's invention with Grewe’s and Gage’s invention to identify and prevent security threats as described in paragraph [0003] of Mozumdar. Regarding Claim 12, Grewe and Gage disclose the method and wireless communication device as described above. Grewe and Gage fail to disclose wherein the field having the value in accordance with the header integrity check information is located between the MAC header and the encryption header or between the encryption header and the data payload. Mozumdar discloses wherein the field having the value in accordance with the header integrity check information is located between the MAC header and the encryption header (see figure 1) or between the encryption header and the data payload. It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Mozumdar's invention with Grewe’s and Gage’s invention to identify and prevent security threats as described in paragraph [0003] of Mozumdar. Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe and Gage in view of Paniconi et al. (Paniconi), U.S. Patent No. 9,490,850. Regarding Claim 8, Grewe and Gage disclose the method as described above. Grewe and Gage fail to disclose further comprising: transmitting one or more dummy frames associated with generation of the header integrity check information, wherein the wireless communication device generates the first data packet based on the header integrity check information and transmits the first data packet after transmission of the one or more dummy frames. Paniconi discloses further comprising: transmitting one or more dummy frames associated with generation of the header integrity check information, wherein the wireless communication device generates the first data packet based on the header integrity check information and transmits the first data packet after transmission of the one or more dummy frames (see col. 16, lines 36-50). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Paniconi's invention with Grewe’s and Gage’s invention for preventing network congestion and degradation in quality of service as described throughout Paniconi. Claim(s) 14-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grewe and Gage in view of Kim et al. (Kim), U.S. Publication No. 2019/0215725. Regarding Claim 14, Grewe and Gage disclose the wireless communication device as described above. Grewe and Gage fail to disclose wherein the field of the second data packet having the value based on the header integrity check information is located in a header of the second data packet. Kim discloses wherein the field of the second data packet having the value based on the header integrity check information is located in a header of the second data packet (see figure 2I). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Kim’s invention with Grewe’s and Gage’s invention for efficiently providing communication in a wireless communication system as described throughout Kim. Regarding Claim 15, Grewe and Gage disclose the wireless communication device as described above. Grewe and Gage fail to disclose wherein: the payload of the first data packet comprises an encrypted data unit; the first data packet comprises a data frame or a management frame; or the payload of the first data packet comprises a null value and the first data packet comprises a null frame. Kim discloses wherein: the payload of the first data packet comprises an encrypted data unit; the first data packet comprises a data frame or a management frame (see figure 2I); or the payload of the first data packet comprises a null value and the first data packet comprises a null frame. It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to consider Kim’s invention with Grewe’s and Gage’s invention for efficiently providing communication in a wireless communication system as described throughout Kim. Allowable Subject Matter Claims 16-23 and 25 are allowed. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SHANTELL LAKETA HEIBER whose telephone number is (571)272-0886. The examiner can normally be reached on M-F from 9am to 5pm. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Anthony Addy, can be reached at telephone number 571-272-7795. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from Patent Center. Status information for published applications may be obtained from Patent Center. Status information for unpublished applications is available through Patent Center for authorized users only. Should you have questions about access to Patent Center, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). 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) Form at https://www.uspto.gov/patents/uspto-automated- interview-request-air-form. /SHANTELL L HEIBER/Primary Examiner, Art Unit 2645 July 7, 2026
Read full office action

Prosecution Timeline

Mar 08, 2023
Application Filed
Jul 15, 2025
Non-Final Rejection mailed — §103
Sep 26, 2025
Response Filed
Dec 11, 2025
Final Rejection mailed — §103
Feb 11, 2026
Response after Non-Final Action
Feb 20, 2026
Request for Continued Examination
Feb 25, 2026
Response after Non-Final Action
Jul 09, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12684358
LAWFUL INTERCEPTION ON NETWORK SLICES
3y 5m to grant Granted Jul 14, 2026
Patent 12672000
UAS AUTHENTICATION AND SECURITY ESTABLISHMENT
3y 4m to grant Granted Jun 30, 2026
Patent 12672001
SYSTEM AND METHOD FOR MANAGEMENT OF SECURED DEVICES
3y 1m to grant Granted Jun 30, 2026
Patent 12672112
VEHICLE-TO-ANYTHING RESOURCE SELECTION
2y 8m to grant Granted Jun 30, 2026
Patent 12659731
PHYSICAL LAYER SECRET-KEY CONFIGURATION AND SIGNALING
3y 5m to grant Granted Jun 16, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

3-4
Expected OA Rounds
77%
Grant Probability
97%
With Interview (+19.7%)
3y 0m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 806 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month