Prosecution Insights
Last updated: April 19, 2026
Application No. 18/189,941

PRECISE POSITIONING USING DIFFERENTIAL CARRIER PHASE (DCP)-BASED MEASUREMENT UPDATES

Non-Final OA §103
Filed
Mar 24, 2023
Examiner
ZHU, NOAH YI MIN
Art Unit
3648
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Qualcomm Incorporated
OA Round
3 (Non-Final)
82%
Grant Probability
Favorable
3-4
OA Rounds
3y 3m
To Grant
98%
With Interview

Examiner Intelligence

Grants 82% — above average
82%
Career Allow Rate
49 granted / 60 resolved
+29.7% vs TC avg
Strong +17% interview lift
Without
With
+16.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
39 currently pending
Career history
99
Total Applications
across all art units

Statute-Specific Performance

§101
4.4%
-35.6% vs TC avg
§103
48.3%
+8.3% vs TC avg
§102
21.6%
-18.4% vs TC avg
§112
23.4%
-16.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 60 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 01/27/2026 has been entered. Response to Amendments The amendment filed 01/27/2026 has been entered. Claims 1, 11, 21, and 28 are amended. Claims 4-6, 14-16, and 24-26 were previously cancelled. Claims 1-3, 7-13, 17-23, and 27-30 are pending. Response to Arguments Applicant’s arguments, filed 09/05/2025, with respect to Claim Rejections under 35 U.S.C. 103 have been considered but they are not persuasive. Applicant appears to argue that while a Kalman filter may use a prior-epoch estimate procedurally, this does not mean that the prior-epoch terms are part of the estimation state itself. Examiner respectfully disagrees and asserts that Lie teaches a position estimator, which may comprise a Kalman filter, that must estimate a set of nine states in order to determine position ([0172]: “To solve or fully utilize the above equations in the determination or estimation of an absolute or relative position estimate, the navigation positioning estimator 57 or the data processor 159 (which may comprise a predictive filter) must estimate various states (e.g., nine states)”). The nine states estimated by the position estimator include a current epoch position term ([0172]: “(1) relative position”) and a previous epoch position term ([0172]: “(4), initial position”). The position estimator uses the nine state to generate a position estimate (i.e., an estimation state). Applicant’s arguments regarding prior art Honma have been considered but are moot because they do not apply to the specific combination of references used in the current rejection. 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 1-2, 8-10, 11-12, 18-22, and 28-29 are rejected under 35 U.S.C. 103 as being unpatentable over Lie (US 2017/0299728) in view of Dai (US 2009/0102708) and Kim (Kim et al., “Performance Improvement of Time-Differenced Carrier Phase Measurement-Based Integrated GPS/INS Considering Noise Correlation,” 2019). Regarding Claim 1, Lie teaches: A positioning method for a mobile device ([0004]), comprising: obtaining a pseudorange observation for a positioning epoch and a carrier phase observation for the positioning epoch based on measurements of global navigation satellite system (GNSS) signals transmitted by one or more space vehicles (SVs) of a GNSS constellation ([0004]: "a real-time kinematic (RTK) mode"; "relative position mode"; [0027]: "pseudo-range and integrated carrier phase"; [0040]: "constellation of satellites"); generating a differential carrier phase observation for the positioning epoch based on the carrier phase observation for the positioning epoch and a determination that real-time kinematic (RTK) correction data associated with the GNSS constellation is unavailable ([0004]: "Upon loss of the RTK correction signal, the navigation positioning estimator or controller switches to a relative position mode"; "The relative position estimator determines an estimated relative position based on time-differenced phase measurements"; [0035]; [0050]: "extended RTK mode"); and generating a position, velocity, … observation of the mobile device for the positioning epoch, according to an … Kalman filter … based positioning model, based on the differential carrier phase observation for the positioning epoch ([0004]: "estimated relative position"; [0044]: "the precise clock solutions or clock biases in the correction data 16 can be used to estimate the precise position, attitude, or velocity (e.g., solution) of the mobile receiver 12."; [0065]; [0171]: “the relative position estimator 124 or any of the bias estimators may comprise a Kalman filter”; [0172]), wherein an estimation state of the … positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term ([0172]: “To solve or fully utilize the above equations in the determination or estimation of an absolute or relative position estimate, the navigation positioning estimator 57 or the data processor 159 (which may comprise a predictive filter) must estimate various states (e.g., nine states)”; “(1) relative position”; “(4), initial position”), or both a current epoch clock term and a previous epoch clock term ([0172]: “(3) current tropospheric delay”; “(5) initial tropospheric delay”). Lie does not explicitly teach – but Dai teaches: generating a position, velocity, and time (PVT) observation (Dai [0012]: “the position, velocity and time (PVT)”). It would have been obvious to modify Lie to generate a position, velocity, and time (PVT) observation, as taught by Dai. PVT measurements are well-known in the art and are beneficial for enhancing position and velocity measurements and enabling additional applications, such as timestamping. Kim teaches: an extended Kalman filter (EKF)-based positioning model (Kim [pg. 5]: “extended KF (EKF)”; [pg. 7]: “relative position”), and wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term (Kim [pg. 7]: Equation (19); 𝛿𝑧𝑘+1 is the estimation state, 𝐻𝑘+1𝛿𝑥𝑘+1 is the current epoch position term, J𝑘+1𝛿𝑥𝑘 is the previous epoch position term.). It would have been obvious to modify Lie and use an EKF-based positioning model, wherein an estimation state of the EKF-based positioning model includes at least one of: both a current epoch position term and a previous epoch position term, as taught by Kim. EKF-based positioning models are well-known for use in GNSS positioning systems. Using an EKF-based positioning model that includes both a current epoch position term and a previous epoch position term is beneficial for improving positioning accuracy (Kim [pg. 1]). Regarding Claim 11, Lie teaches: A positioning apparatus for a mobile device, comprising: a global navigation satellite system (GNSS) receiver ([0004]: “satellite navigation receiver”); a memory ([0026]: “data storage devices”); and one or more processors communicatively coupled with the GNSS receiver and the memory ([0026]: “data processors”), wherein the one or more processors are configured to: obtain a pseudorange observation for a positioning epoch and a carrier phase observation for the positioning epoch based on measurements of GNSS signals transmitted by one or more space vehicles (SVs) of a GNSS constellation ([0004]; [0027]; [0040]); generate a differential carrier phase observation for the positioning epoch based on the carrier phase observation for the positioning epoch and a determination that real-time kinematic (RTK) correction data associated with the GNSS constellation is unavailable ([0004]; [0035]; [0050]); and generate a position, velocity, … observation of the mobile devices, according to an … Kalman filter … based positioning model, for the positioning epoch based on the differential carrier phase observation for the positioning epoch ([0004]; [0044]; [0065]; [0171-0172]), wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term, or both a current epoch clock term and a previous epoch clock term ([0171-0172]). Lie does not explicitly teach – but Dai teaches: generate a position, velocity, and time (PVT) observation (Dai [0012]). The rationale to modify Lie with the teachings of Dai would persist from Claim 1. Kim teaches: an extended Kalman filter (EKF)-based positioning model (Kim [pg. 5]: “extended KF (EKF)”; [pg. 7]: “relative position”), and wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term (Kim [pg. 7]: Equation (19); 𝛿𝑧𝑘+1 is the estimation state, 𝐻𝑘+1𝛿𝑥𝑘+1 is the current epoch position term, J𝑘+1𝛿𝑥𝑘 is the previous epoch position term.). The rationale to modify Lie with the teachings of Kim would persist from Claim 1. Regarding Claim 21, Lie teaches: A non-transitory computer-readable medium storing instructions for positioning for a mobile device ([0004]; [0026]), the instructions comprising code for: obtaining a pseudorange observation for a positioning epoch and a carrier phase observation for the positioning epoch based on measurements of global navigation satellite system (GNSS) signals transmitted by one or more space vehicles (SVs) of a GNSS constellation ([0004]; [0027]; [0040]); generating a differential carrier phase observation for the positioning epoch based on the carrier phase observation for the positioning epoch and a determination that real-time kinematic (RTK) correction data associated with the GNSS constellation is unavailable ([0004]; [0035]; [0050]); and generating a position, velocity, … observation of the mobile device for the positioning epoch, according to an … Kalman filter … based positioning model, based on the differential carrier phase observation for the positioning epoch ([0004]; [0044]; [0065]; [0171-0172]), wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term, or both a current epoch clock term and a previous epoch clock term ([0171-0172]). Lie does not explicitly teach – but Dai teaches: generating a position, velocity, and time (PVT) observation (Dai [0012]). The rationale to modify Lie with the teachings of Dai would persist from Claim 1. Kim teaches: an extended Kalman filter (EKF)-based positioning model (Kim [pg. 5]: “extended KF (EKF)”; [pg. 7]: “relative position”), and wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term (Kim [pg. 7]: Equation (19); 𝛿𝑧𝑘+1 is the estimation state, 𝐻𝑘+1𝛿𝑥𝑘+1 is the current epoch position term, J𝑘+1𝛿𝑥𝑘 is the previous epoch position term.). The rationale to modify Lie with the teachings of Kim would persist from Claim 1. Regarding Claim 28, Lie teaches: A positioning apparatus for a mobile device ([0004]; [0026]), comprising: means for obtaining a pseudorange observation for a positioning epoch and a carrier phase observation for the positioning epoch based on measurements of global navigation satellite system (GNSS) signals transmitted by one or more space vehicles (SVs) of a GNSS constellation ([0004]; [0027]; [0040]); means for generating a differential carrier phase observation for the positioning epoch based on the carrier phase observation for the positioning epoch and a determination that real-time kinematic (RTK) correction data associated with the GNSS constellation is unavailable ([0004]; [0035]; [0050]); and means for generating a position, velocity, … observation of the mobile device for the positioning epoch, according to an … Kalman filter … based positioning model, based on the differential carrier phase observation for the positioning epoch ([0004]; [0044]; [0065]; [0171-0172]), wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term, or both a current epoch clock term and a previous epoch clock term ([0171-0172]). Lie does not explicitly teach – but Dai teaches: generating a position, velocity, and time (PVT) observation (Dai [0012]). The rationale to modify Lie with the teachings of Dai would persist from Claim 1. Kim teaches: an extended Kalman filter (EKF)-based positioning model (Kim [pg. 5]: “extended KF (EKF)”; [pg. 7]: “relative position”), and wherein an estimation state of the EKF-based positioning model of the positioning epoch corresponding to a current epoch includes at least one of: both a current epoch position term and a previous epoch position term (Kim [pg. 7]: Equation (19); 𝛿𝑧𝑘+1 is the estimation state, 𝐻𝑘+1𝛿𝑥𝑘+1 is the current epoch position term, J𝑘+1𝛿𝑥𝑘 is the previous epoch position term.). The rationale to modify Lie with the teachings of Kim would persist from Claim 1. Regarding Claims 2, 12, 22, and 29, Lie teaches: generating the … observation of the mobile device for the positioning epoch based on the differential carrier phase observation for the positioning epoch and a … observation of the mobile device for a preceding positioning epoch ([0004]: "based a last available RTK position."; "time-differenced"; [0073]: "estimate the position of the mobile receiver (or its antenna 17) with respect to an initial reference position (e.g., the last known RTK position)"; [0137]: "Kalman filter"). Lie does not explicitly teach – but Dai teaches: the PVT observation (Dai [0012]). It would have been obvious to modify Lie to generate a position, velocity, and time (PVT) observation, as taught by Dai. PVT measurements are well-known in the art and are beneficial for enhancing position and velocity measurements and enabling additional applications, such as timestamping. Regarding Claims 8, 18, and 27, Lie teaches: obtaining a pseudorange observation for a second positioning epoch and a carrier phase observation for the second positioning epoch based on measurements of GNSS signals transmitted by one or more SVs of a second GNSS constellation ([0027]: "pseudo-range and integrated carrier phase"; [0059]: "one or more GNSS satellite constellations"; [0120]: "a first measurement time and a second measurement time"; [0121]: "receives a real-time kinematic (RTK) signal"; [0124]: "determines a precise position"); determining that RTK correction data associated with the second GNSS constellation is available ([0122]: "received RTK correction data"; [0126]: "if the RTK signal is not lost, interrupted, corrupted"); generating a corrected pseudorange observation and a corrected carrier phase observation based on the pseudorange observation for the second positioning epoch, the carrier phase observation for the second positioning epoch, and the RTK correction data associated with the second GNSS constellation ([0122]: "determines a real-time kinematic position for the first measurement time based on the measured carrier phase of the received satellite signals and the received RTK correction data"; [0127]: "waits an interval prior to returning to step S500 for another iteration";); generating a differential carrier phase observation for the second positioning epoch based on the carrier phase observation for the second positioning epoch ([0120]: "carrier phase"; [0122]: "RTK"; [0124]: "precise position"); and generating a … observation of the mobile device for the second positioning epoch … ([0044]; [0122]: "real-time kinematic position"; "RTK correction data"; [0124]: "precise position"; "precise correction data"). Lie does not explicitly teach – but Dai teaches: generating a PVT observation of the mobile device for the second positioning epoch based on the corrected pseudorange observation, the corrected carrier phase observation, and the differential carrier phase observation for the second positioning epoch (Dai [0006]: "the corrections cancel or significantly mitigate most of the noise sources in the pseudorange and/or carrier phase measurements."; [0009]: "The WADGPS techniques that employ a carrier-phase differential method can also achieve very high navigational accuracy."; [0010]: " combining the use of the standard RTK and the WADGPS navigation techniques"; [0012]: "PVT"). It would have been obvious to modify Lie and generate a PVT observation of the mobile device for the second positioning epoch based on the corrected pseudorange observation, the corrected carrier phase observation, and the differential carrier phase observation for the second positioning epoch, as taught by Dai. Combining the corrected pseudorange observation, the corrected carrier phase observation, and the differential carrier phase observation to generate a PVT observation is beneficial for improving the accuracy of the PVT observations (Dai [0012]). Regarding Claims 9 and 19, Lie does not explicitly teach – but Dai teaches: generating the PVT observation of the mobile device for the second positioning epoch based on the corrected pseudorange observation, the corrected carrier phase observation, the differential carrier phase observation for the second positioning epoch, and a PVT observation of the mobile device for a positioning epoch preceding the second positioning epoch (Dai [0006]; [0009-0010]; [0012]: “After this offset has been determined, the RTK PVT outputs, adjusted by the offset, can be used subsequently to initialize the WADGPS system."). It would have been obvious to modify Lie and generate a PVT observation of the mobile device for the second positioning epoch based on the corrected pseudorange observation, the corrected carrier phase observation, the differential carrier phase observation for the second positioning epoch, and a PVT observation of the mobile device for a positioning epoch preceding the second positioning epoch, as taught by Dai. Combining the corrected pseudorange observation, the corrected carrier phase observation, the differential carrier phase observation, and a previous PVT observation to generate a PVT observation is beneficial for improving the accuracy of the PVT observations (Dai [0012]). Regarding Claims 10 and 20, Lie teaches: obtaining the RTK correction data associated with the second GNSS constellation from one or more base stations ([0048]: "correction data (e.g., local RTK correction data) from a real-time kinematic (RTK) base station 430."). Claims 3, 13, 23, and 30 are rejected under 35 U.S.C. 103 as being unpatentable over Lie (US 2017/0299728) in view of Dai (US 2009/0102708) and Kim (Kim et al., “Performance Improvement of Time-Differenced Carrier Phase Measurement-Based Integrated GPS/INS Considering Noise Correlation,” 2019), as applied to Claims 1, 11, 21, and 28 above, and further in view of Gou (US 2014/0350885). Regarding Claims 3, 13, 23, and 30, Lie teaches: discarding the pseudorange observation for the positioning epoch in response to the determination that the RTK correction data associated with the GNSS constellation is unavailable … ([0004]: "Upon loss…"; "time-differenced phase measurements"). Lie does not explicitly teach – but Gou teaches: discarding the pseudorange observation for the positioning epoch in response to … a determination that a residual error associated with the pseudorange observation for the positioning epoch exceeds a threshold (Gou [0034]: "If an error between the residual pseudo-range error and the first predetermined threshold is beyond a predetermined range, the positioning data can be discarded."). It would have been obvious to modify Lie and discard the pseudorange observation for the positioning epoch in response to a determination that a residual error associated with the pseudorange observation for the positioning epoch exceeds a threshold, as taught by Gou. Discarding the pseudorange observation based on a residual error exceeding a threshold is beneficial for improving the accuracy of positioning measurements (Gou [0006]). Claim 7 and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Lie (US 2017/0299728) in view of Dai (US 2009/0102708), and Kim (Kim et al., “Performance Improvement of Time-Differenced Carrier Phase Measurement-Based Integrated GPS/INS Considering Noise Correlation,” 2019), as applied to Claims 1 and 11 above, and further in view of Averin (US 2024/0219577). Regarding Claims 7 and 17, Lie teaches: wherein generating the … observation of the mobile device for the positioning epoch according to the … positioning model includes conducting a differential carrier phase measurement …, wherein the differential carrier phase measurement … does not include updating a clock term ([0039]: “Single difference”; “double difference”; [0096]; [0137]). Lie does not explicitly teach – but Dai teaches: the PVT observation (Dai [0012]). It would have been obvious to modify Lie to generate a position, velocity, and time (PVT) observation, as taught by Dai. PVT measurements are well-known in the art and are beneficial for enhancing position and velocity measurements and enabling additional applications, such as timestamping. Kim teaches: the EKF-based positioning model (Kim [pg. 5]: “extended KF (EKF)”; [pg. 7]: “relative position”), and The rationale to modify Lie with the teachings of Kim would persist from Claim 1. Lie does not explicitly teach – but Averin teaches: conducting a differential carrier phase measurement update based on a selection of a reference SV, wherein the differential carrier phase measurement update does not include updating a clock term (Averin [0007]: “carrier phase”; [Claim 12]: "(vi) the external processor selects a reference GNSS satellite and computes double differences between the single difference for the reference satellite and the single differences for other satellites;"). It would have been obvious to modify Lie to conduct a differential carrier phase measurement update based on a selection of a reference SV, wherein the differential carrier phase measurement update does not include updating a clock term, as taught by Averin. Updating measurements after selecting a reference SV is well-known and is beneficial for improving the accuracy of satellite receiver position measurements (Averin [0007]). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to NOAH Y. ZHU whose telephone number is (571)270-0170. The examiner can normally be reached Monday-Friday, 8AM-4PM. 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, William J. Kelleher can be reached on (571) 272-7753. 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. /NOAH YI MIN ZHU/Examiner, Art Unit 3648 /William Kelleher/Supervisory Patent Examiner, Art Unit 3648
Read full office action

Prosecution Timeline

Mar 24, 2023
Application Filed
Jun 11, 2025
Non-Final Rejection — §103
Sep 05, 2025
Response Filed
Oct 24, 2025
Final Rejection — §103
Dec 17, 2025
Applicant Interview (Telephonic)
Dec 17, 2025
Response after Non-Final Action
Jan 27, 2026
Request for Continued Examination
Feb 20, 2026
Response after Non-Final Action
Mar 12, 2026
Non-Final Rejection — §103 (current)

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Expected OA Rounds
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3y 3m
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