Prosecution Insights
Last updated: July 17, 2026
Application No. 18/390,859

SELECTIVE PAYLOAD COMPRESSION

Final Rejection §103
Filed
Dec 20, 2023
Examiner
SHIU, HO T
Art Unit
2443
Tech Center
2400 — Computer Networks
Assignee
T-Mobile USA Inc.
OA Round
2 (Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
11m
Est. Remaining
69%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allowance Rate
330 granted / 458 resolved
+14.1% vs TC avg
Minimal -4% lift
Without
With
+-3.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
28 currently pending
Career history
492
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
91.1%
+51.1% vs TC avg
§102
4.3%
-35.7% vs TC avg
§112
1.6%
-38.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 458 resolved cases

Office Action

§103
CTFR 18/390,859 CTFR 84539 Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. DETAILED ACTION Notice of Pre-AIA or AIA Status Claims 1-4, 6-21 are pending in this application. 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 Arguments Applicant’s arguments with respect to claim(s) 1-4, 6-21 have been considered but are moot because the new ground of rejection does not rely on the combination of references applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Claim Rejections - 35 USC § 103 07-20-aia AIA 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. 07-21-aia AIA Claim s 1-4, and 5-8 are rejected under 35 U.S.C. 103 as being Unpatentable over Yang (US 2018/0014225) and in view of Zhao (US 2018/0242192) and in view of Arndt (US 2016/0301582) and in view of Wu (US 2023/0164523) . Re claim 1, Yang discloses a method for dynamic data packet compression comprising: receiving, from a data network, a data packet ([0007], circuitry to receive a packet); compressing the data packet based on the first service flow and a compression policy associated with the first service flow ([0016]-[0018], the header compressor determines the compression scheme based on the header packet for an audio stream); communicating the compressed data packet to a user equipment (UE) ([0015], mobile device 110 transfers packet to the base station 150); and based on the compression policy associated with the first service flow, communicating instructions to the UE to decompress the data packet that is assigned to the first service flow ([0015], mobile device 110 transfers packet to the base station 150. Yang discloses in [0007], parses the header of the packet to obtain header information and determine whether to compress the packet. However, Yang does not disclose assigning the data packet to a first service flow based on what type of data the data packet is. In addition, Zhao discloses assigning the data packet to a first service flow of the plurality of service flows based on what type of data the data packet is ([0099]-[0106] Based on the UL data (or data flow or data flow type) classification above, packet headers may be compressed, e.g. using RoHC, by enabling header compression for the default bearer(s), which may be accomplished in one of several ways. There are various compression method used to indicate the specified level of compression for the various different data flows that maybe chosen based on the profiles.). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang’s compression with Zhao’s compression in order to determine the appropriate compression for the type of files. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used. Yang and Zhao do not disclose , however Arndt discloses receiving, from a policy function, compression policy information indicating compression instructions associated with a plurality of service flows ([0040]-[0042], [0047]-[0048], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria. The utilizing system adjusts policies to the application and can instruct a different codec type, compression function.); determining, based on the compression policy information, a compression policy associated with the first service flow ([0040]-[0042], [0047]-[0048], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria. The utilizing system adjusts policies to the application and can instruct a different codec type, compression function.). In addition, Arndt discloses assigning the data packet to a first service flow of the plurality of service flows based on what type of data the packet is ([0040]-[0042], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria such as a source address, size of the packet of data, the payload protocol, application session information, other criteria, or combinations thereof.). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang and Zhao’s compression with Arndt’s compression in order to select a certain codec with the compression function. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of compression codecs to be used based on low/high quality. While Zhao discloses a base station to communicate over wireless/cellular communications, Yang, Zhao, and Arndt do not disclose , however Wu discloses receiving at a user plane function, data packet ([0104], the base station in the communication network utilizes a user plane function network element.). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Zhao, and Arndt’s communication with Wu’s communication base station which includes a user plane function network elements. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to utilize a user plane function network element for responsible for connecting to an external network. Re claim 2 , Yang discloses wherein the first service flow is determined based on a content type of the data packet ([0016]-[0018], the header compressor determines the compression scheme based on the header packet for an audio stream). Re claim 3 , Yang discloses wherein the content type includes at least one of video streaming, audio streaming, or web browsing data ([0017], the header compressor determines the compression scheme based on the header packet for an audio stream). Re claim 4 , Yang discloses adjusting a compression level based on a current network congestion status ([0020] the compression controller 121 may decide not to perform compression on any received packets for a period of time until resource status improves). Re claim 6 , Yang discloses wherein the UE is a fixed wireless access point ([0015], the base station (UE) in an LTE network. It is well known a base station in a wireless network can be known as a wireless access point). Re claim 7 , one of ordinary level of skill in the art would have been compelled to make the proposed modification to Yang for the same reasons identified in the rejection of claim 1. In addition, Zhao discloses re-compressing the data packet at the UE for uplink communication based on a second service flow instructions ([0102]-[0106], different profiles maybe used for header compression due to data flows). Re claim 8 , Yang discloses wherein the instructions to the UE include an algorithm for decompression that corresponds to a compression protocol used ([0021], the context of the header compressor in the mobile device and the header decompressor of the base station are synchronized/updated in counterpart in order for the base station do decompress the packet efficiently) . 07-21-aia AIA Claim 21 is rejected under 35 U.S.C. 103 as being unpatentable over Yang and in view of Zhao and in view of Arndt and in view of Wu and in view of Peace (US 6,574,272) . Re claim 21, while Arndt discloses assigning to a service flow and Wu discloses user plane function, Yang, Zhao, Arndt, and Wu do not disclose, however Peace discloses abstains from compressing data packets associated with time-sensitive data (abstract, transmission of time critical data is sent on a priority basis bypassing error correction routines and bypassing data compression). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Zhao, Arndt, and Wu’s data transmission with Peace’s data transmission with bypassing compression. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to timely process critical data by removing significant amount of delay bypassing error correcting and data compression . 07-21-aia AIA Claim s 9, 12, and 16-19 are rejected under 35 U.S.C. 103 as being unpatentable over Yang and in view of Huang (US 9,026,505) and in view of Arndt and in view of Wu . Re claim 9, Yang discloses one or more non-transient computer-readable media having computer-executable instructions embodied thereon that, when executed, perform a method for dynamic data packet compression, the method comprising: receiving, from a data network, a data packet ([0007], circuitry to receive a packet); compressing the data packet using second tier compression protocol based on the first service flow ([0016]-[0018], the header compressor determines the compression scheme based on the header packet for an audio stream);; and communicating the data packet to a user equipment (UE) ([0015], mobile device 110 transfers packet to the base station 150). Yang does not disclose, however Huang discloses determining that the data packet is compressed using a first tier compression protocol (col. 4, lines 6-11. A precompressed input file is received); decompressing the data packet (col. 4, lines 18-21, decompress the precompressed input file.); assigning the data packet to a first service flow based a type of data the data packet is (col. 4, lines 24-30 recompress the decompressed file); It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang’s compression with Huang’s compression in order to recompress pre-compressed packets. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used. Yang and Huang do not disclose , however Arndt discloses receiving, from a policy function, compression policy information indicating compression instructions associated with a plurality of service flows ([0040]-[0042], [0047]-[0048], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria. The utilizing system adjusts policies to the application and can instruct a different codec type, compression function.); plurality of service flows ([0040]-[0042], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria.); determining, based on the compression policy information, a compression policy associated with the first service flow ([0040]-[0042], [0047]-[0048], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria. The utilizing system adjusts policies to the application and can instruct a different codec type, compression function.); compressing the data packet using the compression policy associated with the first service flow ([0040]-[0042], [0047]-[0048], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria. The utilizing system adjusts policies to the application and can instruct a different codec type, compression function.). In addition, Arndt discloses assigning the data packet to a first service flow of the plurality of service flows based on what type of data the packet is ([0040]-[0042], policy based routing utilizes routing policies used for routing decisions of data packets based on other criteria such as a source address, size of the packet of data, the payload protocol, application session information, other criteria, or combinations thereof.). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang and Huang’s compression with Arndt’s compression in order to select a certain codec with the compression function. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of compression codecs to be used based on low/high quality. While Zhao discloses a base station to communicate over wireless/cellular communications, Yang, Huang, and Arndt do not disclose , however Wu discloses receiving at a user plane function, data packet ([0104], the base station in the communication network utilizes a user plane function network element.). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Huang, and Arndt’s communication with Wu’s communication base station which includes a user plane function network elements. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to utilize a user plane function network element for responsible for connecting to an external network. Re claim 12 , Yang discloses wherein the determining that the data packet is compressed at a first tier compression protocol comprises using deep packet inspection to identify a compression protocol of the data packet ([0016]-[0018], the header compressor determines the compression scheme based on the header packet for an audio stream). Re claims 16-17, they are similar to claims 9 and 12 and therefore are rejected for the same reasons above. Re claim 18, Yang discloses dynamically selecting the second tier compression protocol based on a current network load and bandwidth availability ([0020] the compression controller 121 may decide not to perform compression on any received packets for a period of time until resource status improves). Re claim 19, Yang discloses wherein the UE is configured to adjust a decompression process based on the first service flow of the plurality of service flows to which the data packet is assigned ([0020] the compression controller 121 may decide not to perform compression on any received packets for a period of time until resource status improves) . 07-21-aia AIA Claim s 10-11 are rejected under 35 U.S.C. 103 as being unpatentable over Yang and in view of Huang and in view of Arndt and in view of Wu and in view of and in view of Schillinger (US 2014/0013006) . Re claim 10, Yang, Huang, Arndt, and Wu do not disclose, however Schillinger discloses wherein the first tier compression protocol is a lossless compression protocol ([00041] the compression algorithm for the file can be a lossless compression algorithms). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Huang, Arndt, and Wu’s compression with Schillinger’s compression in order to utilize lossless compression algorithm. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used. Re claim 11, Arndt discloses different types of codecs have different types of lossy properties. Yang, Huang, Arndt, and Wu do not disclose, however Schillinger discloses wherein the first tier compression protocol is a lossy compression protocol ([00041] the compression algorithm for the file can be a lossy compression algorithms). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Huang, Arndt, and Wu’s compression with Schillinger’s compression in order to utilize lossy compression algorithm. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used . 07-21-aia AIA Claim s 13 are rejected under 35 U.S.C. 103 as being unpatentable over Yang and in view of Huang and in view of Arndt and in view of Wu and in view of Hsu (US 8,942,168) . Re claim 13, Yang, Huang, Arndt, and Wu do not disclose, however Hsu discloses wherein the first service flow is selected based on a quality of service (QoS) requirement associated with the data packet (abstract, the packet flow mapping is based on quality of service of the associated packet flow). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Huang, Arndt, and Wu’s compression with Hsu’s compression mapping in order to determine the compression algorithm. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used . 07-21-aia AIA Claim s 14 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Yang and in view of Huang and in view of Arndt and in view of Wu and in view of Hsu and in view of Dhanabalan (US 2017/0222930) . Re claims 14 and 20, Yang, Huang, and Hsu do not disclose, however Dhanabalan discloses wherein the QoS requirement prioritizes latency-sensitive traffic such as real-time audio or video calls ([0038] determine QoS characteristics of the packets, e.g., whether an application type of the packets is a jitter sensitive application or not. Data characteristics field can indicate whether the packet has realtime or non-realtime characteristics. Data characteristics field can also indicate video or audio characteristics). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Huang and Hsu’s compression with Dhanabalan’s compression QoS in order to determine the compression algorithm. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used . 07-21-aia AIA Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Yang and in view of Huang and in view of Arndt and in view of Wu and in view of Hsu and in view of Zhao . Re claim 15, Yang, Huang, Arndt,, Wu and Hsu do not disclose, however Zhao discloses communicating a request to the UE to provide a confirmation of successful decompression of the data packet ([0092], compressor converts the large overhead while decompressor performs the corresponding inverse operation. The decompressor start in U-mode and transition to o0mode and sends a positive acknowledgement). It would have been obvious for one of ordinary skill in the art before the date the current invention was effectively filed to have modified the teachings of Yang, Huang, Arndt, Wu and Hsu’s compression with Zhao’s compression in order to determine the appropriate compression for the type of files. One of ordinary skill in the art would have been motivated to incorporate the teachings with one another in order to allow for different types of appropriate compression to be used. Conclusion 07-40 AIA 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 HO T SHIU whose telephone number is (571)270-3810. The examiner can normally be reached Mon-Fri (9:00am - 5:00pm). 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, Nicholas Taylor can be reached at 571-272-3089. 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. /HO T SHIU/Examiner, Art Unit 2443 HO T. SHIU Examiner Art Unit 2443 /NICHOLAS R TAYLOR/Supervisory Patent Examiner, Art Unit 2443 Application/Control Number: 18/390,859 Page 2 Art Unit: 2443 Application/Control Number: 18/390,859 Page 3 Art Unit: 2443 Application/Control Number: 18/390,859 Page 4 Art Unit: 2443
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Prosecution Timeline

Dec 20, 2023
Application Filed
Nov 19, 2025
Non-Final Rejection mailed — §103
Mar 19, 2026
Response Filed
Jun 03, 2026
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

3-4
Expected OA Rounds
72%
Grant Probability
69%
With Interview (-3.5%)
3y 6m (~11m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 458 resolved cases by this examiner. Grant probability derived from career allowance rate.

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