Prosecution Insights
Last updated: April 19, 2026
Application No. 18/424,593

LIMITED COMMUNICATION CAPABILITY NOTIFICATIONS

Non-Final OA §103
Filed
Jan 26, 2024
Examiner
WYCHE, MYRON
Art Unit
2644
Tech Center
2600 — Communications
Assignee
T-Mobile Usa Inc.
OA Round
1 (Non-Final)
85%
Grant Probability
Favorable
1-2
OA Rounds
2y 7m
To Grant
98%
With Interview

Examiner Intelligence

Grants 85% — above average
85%
Career Allow Rate
707 granted / 834 resolved
+22.8% vs TC avg
Moderate +13% lift
Without
With
+13.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
12 currently pending
Career history
846
Total Applications
across all art units

Statute-Specific Performance

§101
6.5%
-33.5% vs TC avg
§103
56.1%
+16.1% vs TC avg
§102
23.0%
-17.0% vs TC avg
§112
9.1%
-30.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 834 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 . Information Disclosure Statement The information disclosure statements (IDS) submitted on 27 February 2024 and 09 July 2025 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. 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 1-15 are rejected under 35 U.S.C. 103 as being unpatentable over US Patent Application Publication No. 20230362640 (Edge) in view of US Patent Application Publication No. 20220368411 (Speidel et al.) and US Patent Application Publication No. 20110136428 (Ritter). Regarding claim 1, Edge discloses: “a wireless communication device (FIG. 10: 1000) comprising: at least one hardware processor; and at least one non-transitory, computer-readable storage medium (FIG. 10: 1000; [0232]: “The UE 1000 further includes one or more processors 1004, memory 1016, and non-transitory computer-readable medium 1018”) storing instructions that, when executed by the at least one hardware processor, cause the wireless communication device to (FIG. 10: 1016, 1018; [0234]: “The medium 1018 and/or memory 1016 may store instructions or program code 1020 that contain executable code or software instructions that when executed by the one or more processors 1004 cause the one or more processors 1004to operate”): while connected with the first terrestrial communication network, predict that the wireless communication device is about to leave a cumulative network coverage region provided by one or more terrestrial communication networks with which the wireless communication device is enabled to connect ([0103]: “When coverage data is provided as ephemeris/orbital data, the UE has to perform its own coverage prediction”), wherein the one or more terrestrial communication networks include the first terrestrial communication network ([0103]: “For example, if the UE is at location L at time T, the UE needs to determine whether there will be coverage at this location and time. To determine this, the UE would use the ephemeris (and any radio cell) data and calculate whether there is satellite visibility (for L and T) and possibly radio cell coverage (if known) for L and T. The answer may be a binary yes/no (e.g., maybe with a threshold probability between yes and no)”). However, Edge does not clearly disclose the remaining limitations of the claim. To that end, Speidel et al. discloses: “connect with a first terrestrial communication network ([0031]: “a terrestrial network may deploy various bands on the terrestrial infrastructure used to deploy the services. Specifically, a terrestrial network might use licensed frequency blocks in cellular bands”) such that a wireless communication service ([0031]: “A terrestrial transmitter deploying an LTE service”) is provided to the wireless communication device by the first terrestrial communication network” ([0031]: “The terrestrial transmitters may only enable mobile user equipment to remain connected in certain geographies described by the terrestrial transmitters “coverage map”, or geographical areas of coverage”). It is respectfully submitted that it would have been obvious to one of ordinary skill in the art at the time of the invention to combine Edge with the invention of Speidel et al. in order to provide terrestrial network wireless communication services (e.g., see Speidel et al. @ [0031]). However, the combination of Edge and Speidel et al. does not clearly disclose the remaining limitations of the claim. To that end, Ritter discloses: “the wireless communication device is about to leave the cumulative network coverage region, display a message indicating that the wireless communication device is about to connect to a satellite communication network” ([ABSTRACT]: “An enhanced communication device comprises a terrestrial wireless communication device and a satellite modem. The terrestrial wireless communication device may be used when terrestrial communications are permitted. Otherwise, messages may be generated at the terrestrial wireless communication device and transmitted to the satellite modem (such as through a wireless communications interface). The satellite modem may send the message via a satellite communication network or system. The satellite modem may also receive messages and provide them to the terrestrial wireless communication device for display”). It is respectfully submitted that it would have been obvious to one of ordinary skill in the art at the time of the invention to further modify the combination of Edge and Speidel et al. with the invention of Ritter in order to provide an interface to a satellite communication system (e.g., see Ritter @ [ABSTRACT]). With respect to claim 8, Edge discloses: “predicting that the wireless communication device is about to leave a cumulative network coverage region provided by one or more terrestrial communication networks with which the wireless communication device is enabled to connect ([0103]: “When coverage data is provided as ephemeris/orbital data, the UE has to perform its own coverage prediction”), wherein the one or more terrestrial communication networks include the first terrestrial communication network ([0103]: “For example, if the UE is at location L at time T, the UE needs to determine whether there will be coverage at this location and time. To determine this, the UE would use the ephemeris (and any radio cell) data and calculate whether there is satellite visibility (for L and T) and possibly radio cell coverage (if known) for L and T. The answer may be a binary yes/no (e.g., maybe with a threshold probability between yes and no)”). In addition, , Speidel et al. discloses: “a method comprising: connecting a wireless communication device with a first terrestrial communication network ([0031]: “a terrestrial network may deploy various bands on the terrestrial infrastructure used to deploy the services. Specifically, a terrestrial network might use licensed frequency blocks in cellular bands”) such that a wireless communication service ([0031]: “A terrestrial transmitter deploying an LTE service”) is provided to the wireless communication device by the first terrestrial communication network; while connected with the first terrestrial communication network” ([0031]: “The terrestrial transmitters may only enable mobile user equipment to remain connected in certain geographies described by the terrestrial transmitters “coverage map”, or geographical areas of coverage”). Further, , Ritter discloses: “that the wireless communication device is about to leave the cumulative network coverage region, displaying a message indicating that the wireless communication device is about to connect to a satellite communication network” ([ABSTRACT]: “An enhanced communication device comprises a terrestrial wireless communication device and a satellite modem. The terrestrial wireless communication device may be used when terrestrial communications are permitted. Otherwise, messages may be generated at the terrestrial wireless communication device and transmitted to the satellite modem (such as through a wireless communications interface). The satellite modem may send the message via a satellite communication network or system. The satellite modem may also receive messages and provide them to the terrestrial wireless communication device for display”). With respect to claims 2/9, Edge discloses: “to determine/determining that the wireless communication device is moving to a location within a first network coverage region provided by a satellite network ([Claim 2]: “the coverage data includes a spatial coverage map that indicates whether the access to the serving PLMN can be possible at the one or more locations in a geographical area, the one or more locations comprising a plurality of locations on a grid”), wherein displaying the message indicating that the wireless communication device is about to connect to the satellite network is in response to determining that the wireless communication device is moving to the location within the first network coverage region” ([Claim 4]: “indicate whether the access to the serving PLMN can be possible at the one or more locations, the spatial coverage map comprises a plurality of grid points, wherein each grid point of the plurality of grid points is associated with a Boolean Coverage Availability Indication or a Numeric Signal Power Indication”). In addition, Speidel et al. discloses: ([0060]: “A process for computing and evaluating three-dimensional (3D) and dynamic coverage extension of existing terrestrial mobile networks by introducing orbital, or moving, base stations is provided. These techniques could also be used for 2D mapping”). Regarding claims 3/10. Edge discloses: “determine/determining that the wireless communication device is about to leave the cumulative network coverage region based on one or more coverage maps of the one or more terrestrial communication networks” (FIG. 7C, [0117]: “When coverage data is provided as ephemeris/orbital data, the UE has to perform its own coverage prediction. For example, if the UE is at location L at time T, the UE needs to determine whether there will be coverage at this location and time T”). With respect to claims 4/11, Edge discloses: receive/receiving, from the first terrestrial communication network, a coverage map of the first terrestrial communication network; and determine that the wireless communication device is about to leave the cumulative network coverage region based on the coverage map” ([0117]: “When coverage data is provided as ephemeris/orbital data, the UE has to perform its own coverage prediction. For example, if the UE is at location L at time T, the UE needs to determine whether there will be coverage at this location and time. To determine this, the UE would use the ephemeris (and any radio cell) data and calculate whether there is satellite visibility (for L and T) and possibly radio cell coverage (if known) for L and T. The answer may be a binary yes/no (e.g., maybe with a threshold probability between yes and no)”). Regarding claims 5/12, Edge discloses: determine/determining that the wireless communication device is proximate to a cumulative network coverage boundary of the one or more terrestrial communication networks, wherein the cumulative network coverage boundary comprises a perimeter of the cumulative network coverage region ([0106]: “coverage map” which may reference, indicate or comprise a number of separate locations, designated L1, L2, L3, Ln here, and/or a sequence of consecutive times, designated T1, T2, T3, Tm here”; “A UE 115 can be assumed to be at a location Li if Li corresponds to an area and the UE 115 is inside the area or if Li corresponds to a point and is the closest point to UE 115”); and predict that the wireless communication device is moving closer to the cumulative network coverage boundary, wherein predicting that the wireless communication device is about to leave the cumulative network coverage region ([0117]: “When coverage data is provided as ephemeris/orbital data, the UE has to perform its own coverage prediction”) is in response to determining that the wireless communication device is proximate to the cumulative network coverage boundary and predicting that the wireless communication device is moving closer to the cumulative network coverage boundary” [0227]: “a UE near a boundary of a radio cell might receive coverage from satellites not included in the SIB32 or that a satellite included in the SIB32 that should be visible to a UE does not provide coverage to the UE due to restrictions on PLMN or country support or because radio cells are not configured for the entire area of visibility of the satellite”). Regarding claims 6 and 13, Edge discloses: “the message indicates ([0038]: “the satellite coverage data may indicate a discontinuous service coverage pattern of the UE (e.g., may indicate coverage area(s) of the satellite(s) with respect to the UE”). that a first wireless communication service is available on the satellite communication network ([0038]: “The UE may identify or otherwise determine … a second time (T2) of satellite availability (e.g., a time when the UE is able to resume communication with the serving PLMN wirelessly via a satellite”) and a second wireless communication service is not available on the satellite communication network” ([0038]: “The UE may identify or otherwise determine a first time (T1) of satellite unavailability (e.g., a time when the UE is initially not able to communicate with the serving PLMN wirelessly via a satellite)”). Regarding claims 7/14, Edge discloses: “predict/predicting an amount of time ([0103]: “When coverage data is provided as ephemeris/orbital data, the UE has to perform its own coverage prediction”) until the wireless communication device leaves the cumulative network coverage region; and the message indicates that the wireless communication device is going to connect to the satellite communication network in the amount of time” ([0103]: “For example, if the UE is at location L at time T, the UE needs to determine whether there will be coverage at this location and time. To determine this, the UE would use the ephemeris (and any radio cell) data and calculate whether there is satellite visibility (for L and T) and possibly radio cell coverage (if known) for L and T. The answer may be a binary yes/no (e.g., maybe with a threshold probability between yes and no)”). Claims 15-18 are rejected under 35 U.S.C. 103 as being unpatentable over. US Patent Application Publication No. 20240163708 (Kumar et al.) in view of US Patent Application Publication No. 2023/0066232 (Caro et al). With respect to claim 15, Kumar et al. discloses: “a non-transitory, computer-readable storage medium comprising instructions recorded thereon, wherein the instructions, when executed by at least one processor of a system, cause the system ([0031]: “any form of non-transitory computer-readable storage medium having stored therein a corresponding set of computer instructions that, upon execution, would cause or instruct an associated processor of a device to perform the functionality described herein”) to: transmit, from a non-terrestrial communication network to a wireless communication device, network information associated with the non-terrestrial communication network ([0097]: “assist information regarding communication between the at least one other wireless communication device and a non-terrestrial network (NTN)”); in response to transmitting the network information, receive, at the non-terrestrial network and from the wireless communication device, a request to connect to the non-terrestrial communication network such that a wireless communication service is provided to the wireless communication device by the non-terrestrial communication network ([0097]: “establishing a connection with the NTN based on the assist information”). However, Kumar et al. does not clearly disclose the remaining limitations of the claim. To that end, Caro et al. discloses: determine a set of wireless communication services available on the non-terrestrial communication network (FIG. 7: 706; [0333]: “ displaying (706) a respective selectable communication option”); and in response to receiving the request to connect to the non-terrestrial communication network, transmit, from the non-terrestrial communication network to the wireless communication device, a message indicating that the wireless communication device is connected to the non-terrestrial network and that the set of wireless communication services is available on the non-terrestrial communication network” ([0333]: “selected via the one or more input devices, initiates a process for communicating (e.g., via phone call, text message, and/or video conference) (in some embodiments, the communication is a real-time (e.g., full duplex real time) communication) via a non-terrestrial wireless communication network”). It is respectfully submitted that it would have been obvious to one of ordinary skill in the art at the time of the invention to combine Kumar et al. with the invention of Caro et al. in order to provide wireless communication via a non-terrestrial wireless communication network option (e.g., see [0333]). With respect to claim 16, Kumar et al. discloses: “the non-transitory, computer-readable storage medium of claim 15, wherein the instructions, when executed by the at least one processor ([0031]: “any form of non-transitory computer-readable storage medium having stored therein a corresponding set of computer instructions that, upon execution, would cause or instruct an associated processor of a device to perform the functionality described herein”), further cause the system to: in response to receiving the request to connect to the non-terrestrial communication network, determine one or more wireless communication services available to the wireless communication device on the non-terrestrial communication network based on a wireless subscription plan of the wireless communication device ([0102]: “subscription or charging information regarding accessing the NTN by the wireless communication device”). In addition, Caro et al. determine the one or more wireless communication services available to the wireless communication device on the non-terrestrial communication network as the set of wireless communication services” (FIG. 7: 706; [0333]: “displaying (706) a respective selectable communication option”). Regarding claim 17, Kumar et al. discloses: “the non-transitory, computer-readable storage medium of claim 15 ([0031]: “any form of non-transitory computer-readable storage medium”), wherein the message comprises a short message service (SMS) message ([0066]: “short message service (SMS) messages”). With respect to claim18, Kumar et al. discloses: “the non-transitory, computer-readable storage medium of claim 15 ([0031]: “any form of non-transitory computer-readable storage medium”). In addition, Caro et al. discloses: “the message indicates that a first wireless communication service is available on the non-terrestrial communication network and a second wireless communication service is not available on the non-terrestrial communication network” (FIG. 7: 706; [0333]: “displaying (706) a respective selectable communication option”). Claims 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Kumar et al. in view of Caro et al. and Official Notice. Claims 19-20 are dependent upon claim 15. As discussed above, claim 15 is disclosed by the combination of Kumar et al. and Caro et al. Thus, those limitations of the claims 15 that are recited in claims 19 and 20 are also disclosed by the combination of Kumar et al. and Caro et al. However, the combination of Kumar et al. and Caro et al. does not clearly disclose the remaining limitations of the claims. To that end, with respect to claims 19 and 20, the Examiner takes Official Notice that the limitations of: “the message indicates that messaging services are available on the non-terrestrial communication network and that voice calling services or data services are not available on the non-terrestrial communication network”; and “the message indicates a cost for providing a first wireless communication service that is available on the non-terrestrial communication network” are well known in the art. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MYRON K WYCHE whose telephone number is (571)272-3390. The examiner can normally be reached 7:30 am - 3:30 pm. 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, Kathy Wang-Hurst can be reached at 571-270-5371. 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. /Myron Wyche/ 03 January 2026 Primary Examiner AU2644
Read full office action

Prosecution Timeline

Jan 26, 2024
Application Filed
Jan 03, 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

1-2
Expected OA Rounds
85%
Grant Probability
98%
With Interview (+13.1%)
2y 7m
Median Time to Grant
Low
PTA Risk
Based on 834 resolved cases by this examiner. Grant probability derived from career allow rate.

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