Prosecution Insights
Last updated: April 19, 2026
Application No. 18/261,211

DIFFERENTIAL ANGLE OF ARRIVAL (AOA) FOR LOW POWER MOBILE DEVICE POSITIONING

Non-Final OA §103
Filed
Jul 12, 2023
Examiner
KINCAID, LESTER G
Art Unit
2649
Tech Center
2600 — Communications
Assignee
Qualcomm Incorporated
OA Round
3 (Non-Final)
54%
Grant Probability
Moderate
3-4
OA Rounds
2y 9m
To Grant
56%
With Interview

Examiner Intelligence

Grants 54% of resolved cases
54%
Career Allow Rate
30 granted / 55 resolved
-7.5% vs TC avg
Minimal +1% lift
Without
With
+1.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
39 currently pending
Career history
94
Total Applications
across all art units

Statute-Specific Performance

§101
4.1%
-35.9% vs TC avg
§103
60.5%
+20.5% vs TC avg
§102
22.7%
-17.3% vs TC avg
§112
9.8%
-30.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 55 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 2/10/2026 has been entered. Information Disclosure Statement The information disclosure statement (IDS) submitted on 2/10/2026 and 2/27/2026 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. 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. Regarding the confusion as to the proposed combination from the final rejection, the reason that the combination seemed incomplete was that the claim seems incomplete. That is, details as to the combination were left out of the statement commensurate in scope with what is (not) claimed. To advance prosecution, the rejection has been dropped in favor of the instant rejection below. 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, 3, 12-14,18, 20, 29-31, and 34-35 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier (2005/0288037) and Okamura et al. (2003/0114169) hereinafter “Okamura”. As to claim 1, (Original) Marinier discloses A method of enabling low-power positioning of a first mobile device using differential Angle of Arrival (AoA), the method (Fig 2) comprising: obtaining a differential AoA between a first AoA of a first wireless reference signal at a second mobile device and a second AoA of a second wireless reference signal at the second mobile device, (see step 60, [0029]: “The direction of arrival of the signal from the base station acts as a reference for measuring an angle (theta) between the two signals.”, & [0031]:”… each mobile unit measures and reports angle measurement (theta) between the two directions of arrival in step 62”) wherein: the first wireless reference signal is transmitted by a first wireless network node (base station), and the second wireless reference signal is transmitted by the first mobile device (target mobile), see [0027]-[0029]; determining the position of the first mobile device based at least in part on the differential AoA ([0031]: “In step 64 the system compounds all of the reported information and computes a position for the target… ”). Also see [0013]-[0016], [0019]. Marinier fails to explicitly recite yet in an analogous art Okamura discloses wherein after positioning a mobile it was known to provide the position of the first mobile device. See Fig 3. (steps 108-109, after 300). PNG media_image1.png 412 424 media_image1.png Greyscale Before the effective filing date of the instant invention it would have been obvious to one of ordinary skill in the art to modify the method of Marinier to include the additional step of providing the position of the first mobile device, as taught by Okamura for the purpose of providing the mobile with its position as offered in [0004]. As to claim 3, the combination of Marinier and Okamura discloses everything as applied above to claim 1, and Marinier further provides for wherein determining the position of the first mobile device comprises resolving an ambiguity of the position of the first mobile device based on: a second differential AoA indicative of an angle at the second (neighboring mobile units, (see [0029], [0031], etc) mobile device between a second wireless network node and the first mobile device, historical location information or tracking information for the first mobile device, or location information for the first mobile device obtained from the first mobile device, or any combination thereof. As to claim 12, (Original) the combination of Marinier and Okamura discloses the method of claim 1, Marinier is silent on however the examiner takes official notice that it was well known in the art before the effective filing date of the instant invention wherein that the first wireless reference signal comprises: a Positioning Reference Signal (PRS), a Synchronization Signal Block (SSB), a Tracking Reference Signal (TRS), a Channel State Information Reference Signal (CSIRS), or Demodulation Reference Signal (DMRS), or any combination thereof. It would have been obvious to one of ordinary skill in the art to configure Marinier such that the first wireless reference signal comprises: a Positioning Reference Signal (PRS), a Synchronization Signal Block (SSB), a Tracking Reference Signal (TRS), a Channel State Information Reference Signal (CSIRS), or Demodulation Reference Signal (DMRS), or any combination thereof for the purpose of employing known standards. As to claim 13, (Original) the combination of Marinier and Okamura discloses the method of claim 1, Marinier is silent on however the examiner takes official notice that it was well known in the art before the effective filing date of the instant invention wherein the second wireless reference signal comprises: a sidelink PRS (SL-PRS), aDMRS, or a CSIRS, or any combination thereof. It would have been obvious to one of ordinary skill in the art to configure Marinier such that the second wireless reference signal comprises: a sidelink PRS (SL-PRS), aDMRS, or a CSIRS, or any combination thereof for the purpose of employing known standards. As to claim 14, (Original) the combination of Marinier and Okamura discloses the method of claim 1, Marinier is silent on however the examiner takes official notice that it was well known in the art before the effective filing date of the instant invention wherein: the first wireless reference signal is on a first wireless frequency band and the second wireless reference signal is on a second frequency band. It would have been obvious to one of ordinary skill in the art to configure Marinier such that the the first wireless reference signal is on a first wireless frequency band and the second wireless reference signal is on a second frequency band for the purpose of avoiding interference. Claims 18, 20, and 29-31 recite devices corresponding to method claims 1,3, and 12-14 as applied above. In addition see Fig.1 of Marinier which implies transceiver, memory, and processing units. Claims 34 and 35 recite a device and CRM corresponding to claim 18 and are considered similarly. Claim(s) 2 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier and Okamura as applied to claim 1/18 above, and further in view of Yu et al. (U 2021/0022105) hereinafter “Yu”. As to claim 2. The combination of Marinier and Okamura discloses the method of claim 1, is silent but in an analogous art Yu discloses obtaining a Reference Signal Time Difference (RSTD) measurement indicative of a time difference between a time the first wireless reference signal is received at the second mobile device and a time the second wireless reference signal is received at the second mobile device, wherein determining the position of the first mobile device is based on a determination that the time difference is below a threshold. See [0052]. Before the effective filing date of the instant invention it would have been obvious to one of ordinary skill in the art to include the step of “obtaining” and adjusting the determining step accordingly as taught by Yu for the purpose of increasing accuracy as suggested by Yu [0002]. Claim 19 recites a device corresponding to the method of claim 2 and is considered similarly. Claim(s) 4-5 and 21-22 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier and Okamura as applied to claim 1/18 above, and further in view of Shimoda et al. (2023/0422201) hereinafter “Shimoda”. As to claim 4, (Original) The combination of Marinier and Okamura discloses the method of claim 1, is silent but in an analogous art Shimoda discloses wherein the method is performed by the second mobile device (UE#2 performs method for UE#1, see Fig 14, [0233]-[0234]). Before the effective filing date of the instant invention it would have been obvious to one of ordinary skill in the art to perform the method by the second mobile device, as taught by Shimoda for the purposes of distributed processing and/or quickness. As to claim 5, (Original) The combination of Marinier, Okamura, and Shimoda discloses the method of claim 4, and it is considered that the addition of Shimoda would logically result in wherein providing the position of the first mobile device comprises sending the position of the first mobile device from the second mobile device to the first mobile device. Claims 21-22 recite a device corresponding to the method of claims 4-5 and are considered similarly. Claim(s) 6 and 23 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier, Okamura, and Shimoda as applied to claim 4/21 above, and further in view of Arsian (2014/0365488). As to claim 6, (Original) The combination of Marinier, Okamura, and Shimoda discloses the method of claim 4, is silent to yet in an analogous art Arslan disclose wherein providing (S1210) the position of the first mobile device comprises providing the position of the first mobile device to an application executed by the second mobile device [0235]. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to provide the position of the first mobile device to an application executed by the second mobile device for display on a map or other required usage as suggested by Arslan. Claim 23 recites a device corresponding to the method of claim 6 and is considered similarly. Claim(s) 5, 7, 22, and 24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier, Okamura, and Shimoda as applied to claim 4/21 above, and further in view of Khoryaev et al. (US 9713117) hereinafter “Khoryaev” . As to claim 5, the combination of Marinier, Okamura, and Shimoda discloses The method of claim 4, fails to explicitly recite however in an analogous art Khoryaev discloses wherein providing the position of the first mobile device (UE) comprises sending the position of the first mobile device from the second mobile device (location server / entity performing method) to the first mobile device (see col. 2, lines 38-45). See also col 4, lines 39-41 and 65-67. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to send the position of the first mobile device from the second mobile device to the first mobile device as taught by Khoryaev for the purpose of informing the UE of interest. As to claim 7, the combination of Marinier, Okamura, and Shimoda discloses The method of claim 4, fail to explicitly recite however in an analogous art Khoryaev discloses prior to obtaining the differential AoA: obtaining motion data regarding a motion of the second mobile device; and sending information indicative of the motion data to a location server (location server periodically calculates UE location from received data). See col. 7, lines 17-34 and col 4, lines 39-41. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to periodically (and thus prior to obtaining the differential AoA): obtaining motion data regarding a motion of the second mobile device; and sending information indicative of the motion data to a location server as taught by Khoryaev for the purpose of having updated location data. Claims 22 and 24 recite a device corresponding to the method of claims 5 & 7 and are considered similarly. Claim(s) 8 and 25 is/are rejected under 35 U.S.C. 103 as being unpatentable over of Marinier, Okamura, and Shimoda as applied to claim 4 / 21 above, and further in view of KO et al. (US 2022/0236365) hereinafter “KO”. As to claim 8, the combination of of Marinier, Okamura, and Shimoda discloses The method of claim 4, fail to explicitly recite however in an analogous art KO discloses sending, from the second mobile device to a location server, information indicative of a capability of the second mobile device for determining the differential AoA. See [0121],[0126]. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to send, from the second mobile device to a location server, information indicative of a capability of the second mobile device for determining the differential AoA (capability information) as taught by KO for the purpose of enabling the network to function according to 5G NR standards. Claim 25 recites a device corresponding to method claim 8 as applied above. Claim(s) 9 and 26 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier and Okamura as applied to claim 1/18 above, and further in view of Khoryaev. As to claim 9, the combination of Marinier and Okamura, discloses The method of claim 1, fails to explicitly recite however Khoryaev discloses wherein the method is performed by a location server (see col. 2, lines 38-45, col 4, lines 20-41 and col. 7, lines 17-34), and wherein obtaining the differential AoA comprises receiving the differential AoA from the second mobile device. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to perform the method by a location server (see col. 2, lines 38-45, col 4, lines 20-41 and col. 7, lines 17-34), and wherein obtaining the differential AoA comprises receiving the differential AoA from the second mobile device for the purpose of utilizing the system resources. Claim 26 recites a device corresponding to method claim 1 as applied above. Claim(s) 10-11 and 27-28 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier, Okamura, and Khoryaev as applied to claim 9 / 26 above, and further in view of KO. As to claim 10, the combination of Marinier, Okamura, and Khoryaev discloses The method of claim 9, Khoryaev further discloses: receiving motion data regarding a motion of the second mobile device (see col 4, lines 20-41 and col. 7, lines 17-34); determining a time-domain proximity (up-to-date data) for the first wireless reference signal and second wireless reference signal based at least in part on the motion data (see col. 7, lines 17-34). Khoryaev fail however KO discloses configuring the first wireless network node to send the first wireless reference signal, configuring the first mobile device to send the second wireless reference signal, or both, based at least in part on the time-domain proximity. See [0119]. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to perform the steps of Khoryaev and KO for the purpose of taking advantage of 5G NR specifications. As to claim 11, the combination of Marinier, Okamura, and Khoryaev, discloses The method of claim 9, KO further discloses receiving a request at the location server [0125] for the position of the first mobile device from a requesting entity, and wherein providing the position of the first mobile device comprises sending the position of the first mobile device from the location server to the requesting entity [0127]. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to receiving a request and sending the position as taught by Ko for the purpose of utilizing specialized network equipment. Claims 27-28 recite devices corresponding to method claims 10-11 as applied above. Claim(s) 15-17, 32, and 36 is/are rejected under 35 U.S.C. 103 as being unpatentable over Marinier and Okamura as applied to claim 1/18 above, and further in view of Keating et al. (U 2024/0022375) hereinafter “Keating”. As to claim 15, the combination of Marinier and Okamura discloses The method of claim 1, is silent to yet in an analogous art, Keating discloses: determining a first time difference (290), wherein the first time difference comprises a time difference between: a time a third wireless reference signal transmitted by a network entity arrives at the first mobile device, and a time the first mobile device transmits a second wireless reference signal [0095]; and determining a second time difference [0097], wherein the second time difference comprises a time difference between: a time the first wireless reference signal transmitted by the Transmission Reception Point arrives at the second mobile device, and a time the second wireless reference signal arrives at the second mobile device; wherein determining the position of the first mobile device is further based on the first time difference and the second time difference [0099]. Before the effective filing date of the instant application it would have been obvious to one of ordinary skill in the art to perform the steps of determining as taught by Keating for the purpose of estimating the position more accurately without additional signaling. See [0101]-[0105]. As to claim 16, the combination of Marinier, Okamura, and Keating discloses The method of claim 15, Keating discloses wherein the first wireless reference signal and the third wireless reference signal comprise the same signal. See Fig.2 [0099]. As to claim 17, the combination of Marinier, Okamura, and Keating discloses The method of claim 15, Keating discloses wherein the first wireless reference signal and the third wireless reference signal comprise different signals, and determining the position of the first mobile device is further based on a difference in time between the transmission of the first wireless reference signal and the third wireless reference signal. See Fig.2 [0099]. Claim 32 recites a device corresponding to method claim 15 as applied above. As to claim 36, (New) , the combination of Marinier, Okamura, and Keating discloses the method of claim 15, Keating discloses wherein the first wireless reference signal and the third wireless reference signal are transmitted using the same beam. See [0075], Fig.2 [0099]. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Shpak (2023/0017758) provides for [0085] differential AoA between a signal from a mobile and a reference signal from a fixed point to enhance the accuracy of positioning. Any inquiry concerning this communication or earlier communications from the examiner should be directed to LESTER KINCAID whose telephone number is (571)272-7922. The examiner can normally be reached M-Th: 7-5. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Yuwen Pan can be reached at 571-272-7855. 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. LESTER G. KINCAID Primary Patent Examiner Art Unit 2649 /LESTER G KINCAID/ Primary Examiner, Art Unit 2649
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Prosecution Timeline

Jul 12, 2023
Application Filed
Jul 12, 2023
Response after Non-Final Action
Jul 21, 2025
Non-Final Rejection — §103
Oct 15, 2025
Response Filed
Nov 09, 2025
Final Rejection — §103
Jan 09, 2026
Response after Non-Final Action
Feb 10, 2026
Request for Continued Examination
Feb 23, 2026
Response after Non-Final Action
Mar 25, 2026
Non-Final Rejection — §103 (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
54%
Grant Probability
56%
With Interview (+1.2%)
2y 9m
Median Time to Grant
High
PTA Risk
Based on 55 resolved cases by this examiner. Grant probability derived from career allow rate.

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