Prosecution Insights
Last updated: April 19, 2026
Application No. 18/209,112

Modifying PDU Sessions In Underlay Networks

Final Rejection §103§112
Filed
Jun 13, 2023
Examiner
PATIDAR, SUDESH M
Art Unit
2415
Tech Center
2400 — Computer Networks
Assignee
Ofinno LLC
OA Round
2 (Final)
79%
Grant Probability
Favorable
3-4
OA Rounds
2y 11m
To Grant
99%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allow Rate
187 granted / 236 resolved
+21.2% vs TC avg
Strong +42% interview lift
Without
With
+42.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
20 currently pending
Career history
256
Total Applications
across all art units

Statute-Specific Performance

§101
3.6%
-36.4% vs TC avg
§103
56.2%
+16.2% vs TC avg
§102
8.0%
-32.0% vs TC avg
§112
26.7%
-13.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 236 resolved cases

Office Action

§103 §112
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 amendment filed on 12/23/2025 has been entered. Claims 1,9 and 17 have been amended. Claims 2-7,10-15 and 18-20 have been canceled in this amendment. No New Claim has been added in this amendment. Claims 1,8-9 and 16-17 are pending in this application, with claims 1,9 and 17 being independent. Response to Arguments Applicant’s arguments with respect to rejection of Claims 1,3,5-7,10-11,13-15,17,19 and 21-28 under 35 U.S.C. §103 have been considered but are moot because the arguments do not apply to any of the references being used in the current rejection. Specification The disclosure is objected to because of the following informalities: the published disclosure recites acronyms “SNPN” without setting forth what the acronyms stand for at first use. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-20 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention. The claims are not clearly written to define metes and bounds of the claimed invention. In claims 1,9 and 17, the phrase “. . is used to establish . .”is unclear as to what it refers and not providing enough information on how two connection are related to each other. Claim 8 is rejected based upon claim dependency to independent claim 1. Claims 16 is rejected based upon claim dependency to independent claim 9. Claim 17 recites the limitation "the first network" in line 4. There is insufficient antecedent basis for this limitation in the claim as there is no reference to refer back to. 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 1,8-9 and 16-17 are rejected under 35 U.S.C. 103 as being unpatentable over YU et al. (US 2022/0408502 Al, hereinafter referred to as “Yu”) in view of SUH et al. (US 2022/0225438 Al, hereinafter referred to as “Suh”) and further in view of Huawei (S2-2007468, hereinafter referred to as “Huawei”) and further in view of in view of SUH et al. (US 2022/0225438 Al, hereinafter referred to as “Suh”). Regarding claims 1,9 and 17, Yu discloses a method and a SMF (Yu Fig.2 Para [0095] A SMF) comprising: receiving, by a first session management function (SMF) of a first network, an indication that a first connection (Yu Fig.3b,5a,5b,5b-2 and associated paragraphs, The SMF receives a message (i.e. indication) regarding existing links and path identifier for a first network, see Para[0149-156]) of a wireless device (Yu Fig.3b,5a,5b,5b-2 and associated paragraphs, The terminal (i.e. wireless device)) with the first network (Yu Fig.3b,5a,5b,5b-2 and associated paragraphs, The first network is 3GPP or non-3GPP network, See Para[0106]) is used to establish a second connection (Yu Fig.3b,5a,5b,5b-2 and associated paragraphs, The second connection to a non-3GPP or 5G cellular network and the received indication contains second path identifier) of the wireless device with a second network (Yu Fig.3b,5a,5b,5b-2 and associated paragraphs, The 5G network. The SMF informs the UPF to set up two tunnels (i.e. connections) based on the received message from the AMF, see Para[0156]); wherein the first network comprises an underlay network and the second network comprises an overlay network (Yu Para[0106] The first network is Wi-Fi AP network (i.e. underlay) and second network is 5G network (i.e. overlay)). Yu does not explicitly disclose sending, by the first SMF to the wireless device and based on the indication, a first message indicating that the first connection is granted an always-on status. However, Suh from the same field of invention discloses sending, by the first SMF (Suh Fig.6 Para[0121] A SMF) to the wireless device (Suh Fig.6 Para[0118] A UE) and based on the indication (Suh Fig.6 Para[0120-122] The SMF receives session update request (i.e. indication) with multi-access PDU session status information), a first message (Suh Fig.6,7 Table 49,59 Para[0132-138] The SMF sends PDU session modification command (i.e. message)) indicating that the first connection is granted an always-on status (Fig.6,7 Table 49,59 Para[0132-138] The PDU session modification command contains Always-on PDU session indication). Therefore, it would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to modify Yu to have the feature of “sending, by the first SMF to the wireless device and based on the indication, a first message indicating that the first connection is granted an always-on status” as taught by Suh. The motivation would have been to improve performance by efficient mobility and session management (Suh Para[0010]). Yu in view of Suh does not explicitly disclose wherein the first connection comprises a first packet data unit (PDU) session between the wireless device and the first network; the IPSec tunnel is used to establish the second connection comprising a second packet data unit (PDU) session between the wireless device and the second network. However, Huawei from a similar field of invention discloses wherein the first connection comprises a first packet data unit (PDU) session between the wireless device and the first network (Huawei Fig.1 A SNPN PDU session (i.e. first session)); the IPSec tunnel is used to establish the second connection comprising a second packet data unit (PDU) session between the wireless device and the second network (Huawei Fig.1 A PLMN PDU session (i.e. second session) via IKEv2 tunnel (i.e. IPSec) to N3IWF). Therefore, it would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to modify Yu and Suh to have the feature of “wherein the first connection comprises a first packet data unit (PDU) session between the wireless device and the first network; the IPSec tunnel is used to establish the second connection comprising a second packet data unit (PDU) session between the wireless device and the second network” as taught by Huawei. The motivation would have been to provide keep alive the PDU session over N3IWF avoiding deregistration (Huawei Abstract). Yu in view of Suh and Huawei does not explicitly disclose the first PDU session is used to establish an IPSec tunnel with anon-3GPP interworking function (N3IWF) of the second network. However, Youn from a similar field of invention discloses the first PDU session is used to establish an IPSec tunnel with anon-3GPP interworking function (N3IWF) of the second network (Youn Fig.9,10 Para[0187] A N3IWF tunnel is established with non-3GPP network (i.e. second network)). Therefore, it would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to modify Yu, Suh and Youn to have the feature of “the first PDU session is used to establish an IPSec tunnel with anon-3GPP interworking function (N3IWF) of the second network” as taught by Youn. The motivation would have been to efficiently manage multiaccess PDU sessions (Youn Para[0078]). Specifically for claim 9, Yu discloses a device that includes a processor (Yu Fig.8 Para[0223] A processor) and memory (Yu Fig.7 Para[0223] memory). Regarding claims 8 and 16, Yu in view of Suh and Huawei discloses the method and the SMF as explained above for Claim 1. Yu discloses wherein the indication is received from a first access and mobility management function (AMF) of the first network (Yu Fig.3b,5a,5b,5b-2 and associated paragraphs, The SMF receives a message regarding existing links and path identifiers from the AMF). Although specific columns, figures, reference numerals, lines of the reference(s), etc. have been referred to, Applicant should consider the entire applied prior art reference(s). Conclusion 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 Sudesh M. Patidar whose telephone number is (571)272-2768. The examiner can normally be reached M-F:: 10AM-6:30PM ET. 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, Jeffrey Rutkowski can be reached at (571) 270-1215. 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. /Sudesh M. Patidar/Primary Examiner, Art Unit 2415
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Prosecution Timeline

Jun 13, 2023
Application Filed
Aug 23, 2025
Non-Final Rejection — §103, §112
Dec 22, 2025
Applicant Interview (Telephonic)
Dec 22, 2025
Examiner Interview Summary
Dec 23, 2025
Response Filed
Jan 27, 2026
Final Rejection — §103, §112 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
79%
Grant Probability
99%
With Interview (+42.3%)
2y 11m
Median Time to Grant
Moderate
PTA Risk
Based on 236 resolved cases by this examiner. Grant probability derived from career allow rate.

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