Prosecution Insights
Last updated: October 01, 2026
Application No. 18/261,477

Managing Pending Data in Inactive State Scenarios

Non-Final OA §103
Filed
Jul 13, 2023
Priority
Jan 13, 2021 — provisional 63/199,634 +2 more
Examiner
ZHANG, ZHENSHENG
Art Unit
2474
Tech Center
2400 — Computer Networks
Assignee
Google LLC
OA Round
2 (Non-Final)
76%
Grant Probability
Favorable
2-3
OA Rounds
0m
Est. Remaining
87%
With Interview

Examiner Intelligence

Grants 76% — above average
76%
Career Allowance Rate
311 granted / 407 resolved
+18.4% vs TC avg
Moderate +11% lift
Without
With
+10.7%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
35 currently pending
Career history
431
Total Applications
across all art units

Statute-Specific Performance

§101
2.2%
-37.8% vs TC avg
§103
76.6%
+36.6% vs TC avg
§102
7.4%
-32.6% vs TC avg
§112
10.3%
-29.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 407 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 . 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 allowance or after an Office action under Ex Parte Quayle, 25 USPQ 74, 453 O.G. 213 (Comm'r Pat. 1935). 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, prosecution in this application has been reopened pursuant to 37 CFR 1.114. Applicant's submission filed on 6/9/2026 has been entered. 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. Claims 1-4, 9, 11-17 are rejected under 35 U.S.C. 103 as being unpatentable over Yerramalli (US 20190014589) in view of Yue (US 20230232442). Regarding claim 1, Yerramalli disclose a method implemented in a UE for communicating with a base station, the method comprising: detecting, when the UE operates in an inactive state associated with a protocol for controlling radio resources (fig. 14, [0191], the UE is in limited power state or inactive state), pending data addressed to the base station (fig. 14, [0192], identify an autonomous UL transmission or a scheduled transmission), the pending data including (i) first data for a first channel for which the UE is configured to use a first procedure that causes the UE to transition to a connected state associated with the protocol (fig. 14, [0192], identify scheduled UL data which can be transmitted in active state), and (ii) second data for a second channel for which the UE is configured to use a second procedure that causes the UE to remain in the inactive state (fig. 14, [0002][0192], identify an autonomous UL data which can be transmitted in inactive state), transmitting at least a portion of the pending data using the selected procedure (fig. 14, [0195], the UE 115 may transmit, to a base station, the autonomous UL transmission or the scheduled UL transmission based at least in part on the identified priority configuration). Yerramalli does not explicitly disclose the limited power state can be an inactive state or active state, the first data (or scheduled UL transmission) uses a first procedure that causes the UE to transition to a connected state associated with the protocol, selecting the first procedure or the second procedure based on comparing a priority of the first channel to a priority of the second channel. Yue discloses the limited power state can be an inactive state or active state (Yue, [0024][0028], saving power in a capacity reduced UE by enabling the UE to be in inactive state or active state based on the data to be transmitted), the first data (or scheduled UL transmission) uses a first procedure that causes the UE to transition to a connected state associated with the protocol (Yue, [0028], in the case that the UE in the RRC_INACTIVE state has data to be transmitted, it has to resume the connection (i.e. move to the RRC_CONNECTED state) for an downlink and uplink data transmission), selecting the first procedure or the second procedure based on comparing a priority of the first channel to a priority of the second channel (Yue, [0031][0033], since the priority of LCH 1 is higher than LCH 2, the data in the LCH 1 should be allocated with the resource of the UL granted firstly for transmission). Yue also teaches transmitting at least a portion of the pending data using the selected procedure (Yue, [0033], only part 1 of the data in the LCH 1 is included in a MAC SDU 1 for transmitting in the UL grant 1). It would have been obvious to a person of ordinary skill in the art before the time of effective filing to combine the teachings of transmitting data in inactive state as given by Yerramalli with the teachings of transition from inactive to active state given by Yue. The motivation for doing so would have been to efficiently transfer between active and inactive state to save energy. Claim 17 is rejected similarly with claim 1 noting that Yerramalli discloses a UE with processor (Yerramalli , [0008]). Regarding claim 2, Yerramalli and Yue disclose the method of claim 1, wherein the selecting includes: if the priority of the second channel is above the priority of the first channel, selecting the second procedure (Yerramalli , [0026], the priority configuration prioritizes the autonomous UL transmissions over the scheduled UL transmissions, Yue, [0033]). Regarding claim 3, Yerramalli and Yue disclose the method of claim 1, wherein the selecting includes: if the priority of the first channel is equal to the priority of the second channel, selecting the second procedure (Yerramalli , [0026], the priority configuration prioritizes the autonomous UL transmissions over the scheduled UL transmissions. Here, since the UE is already in the inactive state, and it makes sense to transmit the second data in the inactive state). Regarding claim 4, Yerramalli and Yue disclose the method of claim 2, wherein the at least a portion of the pending data is the second data (Yerramalli , fig. 14, [0026][0195], the UE 115 may transmit, to a base station, the autonomous UL transmission based at least in part on the identified priority configuration, Yue, [0033]). Regarding claim 9, Yerramalli and Yue disclose the method of claim 1, wherein the selecting includes: if the priority of the first channel is above the priority of the second channel, selecting the first procedure (Yerramalli , [0140], the priority configuration prioritizes the scheduled UL transmission over the autonomous UL transmission; Yue, [0033]). Regarding claim 11, Yerramalli and Yue disclose the method of claim 1, wherein the second procedure is a small data transmission (SDT) procedure (Yue, [0028], To enable the data transmission in the RRC_INACTIVE state, a work item in the NR states that small data transmission in the RRC_INACTIVE state may be implemented through a random access channel). Regarding claim 12, Yerramalli and Yue disclose the method of claim 1, wherein the detecting of the pending data includes detecting the first data in a first data buffer associated with the first channel and detecting the second data in a second data buffer associated with the second channel (Yerramalli , [0087][0111], The UE 115 may schedule a first scheduled transmission and a second autonomous transmission during a subframe on different channels according to the uplink buffer status). Regarding claim 13, Yerramalli and Yue disclose the method of claim 1, further comprising: detecting a medium access control (MAC) control element (CE) addressed to the base station; and transmitting the MAC CE with the at least a portion of the pending data using the selected procedure (Yerramalli , [0121]; Yue, [0030], MAC entity, MAC layer normally includes Control Element). Regarding claim 14, Yerramalli and Yue disclose the method of claim 1, further comprising: receiving, from the base station, a configuration message prior to detecting the pending data (Yerramalli , fig. 15, the base station transmits an indication of the priority configuration). Regarding claim 15, Yerramalli and Yue disclose the method of claim 14, wherein the configuration message includes the priority of the first channel and the priority of the second channel (Yerramalli , fig. 15, the base station transmits an indication of the priority configuration, [0026]). Regarding claim 16, Yerramalli and Yue disclose the method of claim 14, wherein the configuration message includes at least one configured grant (Yerramalli , [0087], the priority configuration for the UE 115 to use to prioritize between autonomous UL transmissions (grantless) and scheduled UL transmissions (grant-based)). Claims 5-8, 10, 18-20 are rejected under 35 U.S.C. 103 as being unpatentable over Yerramalli in view of Yue further in view of Xu (US 20220256484). Regarding claims 5, 18 Yerramalli and Yue disclose the method of claim 2, wherein the transmitting includes: Yerramalli and Yue do not explicitly disclose determining whether to transmit the at least a portion of the pending data using a configured grant procedure or a random access procedure based on whether the UE is configured with a configured grant for a time period corresponding to a next transmission opportunity. Xu discloses determining whether to transmit the at least a portion of the pending data using a configured grant procedure or a random access procedure based on whether the UE is configured with a configured grant for a time period corresponding to a next transmission opportunity (Xu, [0091], for example, pre-configured resources may be indicated as available to the wireless device to perform a configured grant based small data transfer while in RRC inactive mode. These resources may include time- and frequency resources in which the wireless device can transmit up to a certain volume of data according to a configured grant (CG) based small data transfer (SDT) procedure). It would have been obvious to a person of ordinary skill in the art before the time of effective filing to combine the teachings of transmitting data in inactive state as given by Yerramalli with the teachings of small data transfer protocol given by Xu. The motivation for doing so would have been to reduce power requirements in UE device designs while allowing the UE device to maintain good transmit and receive abilities for improved communications (Xu, [0003]). Regarding claims 6, 19, Yerramalli , Yue and Xu disclose the method of claim 5, wherein the transmitting includes: if the UE is configured with the configured grant for the time period, transmitting the at least a portion of the pending data using the configured grant (Xu, [0091], For example, pre-configured resources may be indicated as available to the wireless device to perform a configured grant based small data transfer while in RRC inactive mode. These resources may include time- and frequency resources in which the wireless device can transmit up to a certain volume of data according to a configured grant (CG) based small data transfer (SDT) procedure). Regarding claims 7, 20, Yerramalli , Yue and Xu disclose the method of claim 5, wherein the transmitting includes: if the UE is not configured with the configured grant for the time period, transmitting the at least a portion of the pending data using another configured grant at a later time period after the time period (Xu, [0101], the wireless device may maintain the newly provided TA and may be able to perform subsequent (or another) configured grant based small data transfer procedure while in RRC inactive). Regarding claim 8, Yerramalli , Yue and Xu disclose the method of claim 5, wherein the transmitting includes: if the UE is not configured with the configured grant for the time period: initiating the random access procedure using a random access resource dedicated for use in the inactive state; and transmitting the at least a portion of the pending data during the random access procedure (Xu, [100], it may be the case that the wireless device does not perform a configured grant based small data transfer while in RRC inactive mode, the wireless device may perform a random access channel (RACH) based small data transfer while in the RRC inactive mode). Regarding claim 10, Yerramalli , Yue and Xu disclose the method of claim 9, wherein the transmitting includes: initiating a random access procedure using a random access resource not dedicated for use in the inactive state; and transmitting the pending data during the random access procedure (Xu, [100], it may be the case that the wireless device does not perform a configured grant based small data transfer while in RRC inactive mode, the wireless device may perform a random access channel (RACH) based small data transfer while in the RRC inactive mode). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZHENSHENG ZHANG whose telephone number is (571)270-1985. The examiner can normally be reached Monday-Thursday 8:00am-6:00pm. 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, Michael Thier can be reached at 571-272-2832. 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. /ZHENSHENG ZHANG/Primary Examiner, Art Unit 2474
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Prosecution Timeline

Jul 13, 2023
Application Filed
Oct 16, 2025
Non-Final Rejection mailed — §103
Jan 16, 2026
Response Filed
Jun 09, 2026
Request for Continued Examination
Jun 17, 2026
Response after Non-Final Action
Sep 23, 2026
Non-Final Rejection mailed — §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

2-3
Expected OA Rounds
76%
Grant Probability
87%
With Interview (+10.7%)
2y 8m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 407 resolved cases by this examiner. Grant probability derived from career allowance rate.

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