Prosecution Insights
Last updated: April 19, 2026
Application No. 18/431,419

Selecting Resources for Mobile Terminated Small Data Transmission (MT-SDT) in a Wireless Network

Non-Final OA §102§103
Filed
Feb 02, 2024
Examiner
LEE, JUSTIN YE
Art Unit
2644
Tech Center
2600 — Communications
Assignee
Apple Inc.
OA Round
1 (Non-Final)
80%
Grant Probability
Favorable
1-2
OA Rounds
3y 3m
To Grant
91%
With Interview

Examiner Intelligence

Grants 80% — above average
80%
Career Allow Rate
563 granted / 703 resolved
+18.1% vs TC avg
Moderate +11% lift
Without
With
+10.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
13 currently pending
Career history
716
Total Applications
across all art units

Statute-Specific Performance

§101
4.4%
-35.6% vs TC avg
§103
52.6%
+12.6% vs TC avg
§102
18.0%
-22.0% vs TC avg
§112
14.6%
-25.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 703 resolved cases

Office Action

§102 §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 statement (IDS) submitted on 2/16/24 and 5/16/24 are being considered by the examiner. Claim Rejections - 35 USC § 102 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 the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 62-63, 66, 68-69, 85-86, 89 and 91-93 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Huang et al. (US 2023/0309081 A1). Consider claim 62, Huang teaches a method comprising: receiving a Mobile Terminated Small Data Transmission (MT SDT) paging message from a base station of a wireless network (paragraph 382); determining a resource for transmitting an uplink (UL) response message to the base station, based on at least one of: a Configured Grant resource specific to Small Data Transmission (CG-SDT), a legacy Random Access Channel (RACH) resource, or a Random Access Small Data Transmission (RA-SDT) resource; and transmitting the UL response message to the base station using the determined resource (paragraph 382, the UE receives a MT-SDT from the NW then determining a UL response using RA-SDT or CG-SDT. In paragraph 31, 385 and 432 also teaches legacy RA procedure). Consider claim 85, Huang teaches a non-transitory computer storage medium encoded with instructions that, when executed by one or more processors, cause the one or more processors to perform operations comprising: transmitting a MT SDT paging message to a user equipment (UE) (paragraph 382); receiving, from the UE, an uplink (UL) response message using a resource, wherein the resource is determined based on at least one of: a Configured Grant resource specific to Small Data Transmission (CG-SDT), a legacy Random Access Channel (RACH) resource, or a Random Access Small Data Transmission (RA-SDT) resource; and transmitting data to the UE based on the UL response message (Fig. 15 and paragraph 382, the UE receives a MT-SDT from the NW then determining a UL response using RA-SDT or CG-SDT. In paragraph 31, 385 and 432 also teaches legacy RA procedure). Consider claims 63 and 86, Huang also teaches wherein determining the resource comprises: determining that the CG-SDT resource is configured; and prioritizing the CG-SDT resource over the RACH resource as the resource (paragraph 378, the UE maybe configured to use CG-SDT resource). Consider claims 66 and 89, Huang also teaches receiving, from the base station, configuration information comprising in indication of the CG-SDT resource via RRC dedicated signaling (paragraph 378, the UE is configured with the CG-SDT resource in a RRC release message form the network). Consider claims 68 and 91, Huang also teaches wherein the method is performed by a user equipment (UE) (Fig. 15). Consider claims 69 and 92, Huang also teaches wherein the method is performed by at least one baseband processor (Fig. 3). Consider claim 93, Huang teaches an apparatus comprising one or more processors and one or more storage devices on which are stored instructions that are operable, when executed by the one or more processors (abstract and Fig. 3 and 15), to cause the one or more processors to perform operations comprising: receiving, from a base station of a wireless network, configuration information for selecting a resource for transmitting an uplink (UL) response message to the base station (paragraph 382); receiving, in an RRC_INACTIVE state, a Mobile Terminated Small Data Transmission (MT-SDT) paging message from the base station (paragraph 382); determining whether the MT-SDT paging message includes an indication of at least one of a first resource or a first resource type for transmitting the UL response message (paragraph 382-387, the NW provides type 1 configuration UL grant eg, CG-SDT resources); and performing at least one of: (i) upon determining that the MT-SDT paging message includes the indication and that one or more conditions have been satisfied, transmitting the UL response message to the base station using at least one of the first resource or the first resource type (paragraph 382-387, the NW may send a page to indicate MT-SDT. The UE would transmit UL response using RA-SDT or CG-SDT), (ii) upon determining that the MT-SDT paging message includes the indication and that one or more conditions for using the first resource have not been satisfied, transmitting the UL response message to the base station using a second resource that is selected based on configuration information, or (iii) upon determining that the MT-SDT paging message does not include the indication, transmitting the UL response message to the base station using the second resource selected based on the configuration information. 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. Claim(s) 64-65, 67, 87-88 and 90 is/are rejected under 35 U.S.C. 103 as being unpatentable over Huang et al. (US 2023/0309081 A1) in view of Ericsson, 3GPP TSG-RAN WG2 Meeting #120 R2-2211471 (hereinafter, Ericsson). Consider claims 64 and 87, Huang does not teach wherein determining the resource comprises: responsive to determining that MT-SDT paging message triggers MT-SDT only and that the CG-SDT resource is not configured, determining that the RACH resource is the resource. Ericsson further teaches wherein determining the resource comprises: responsive to determining that MT-SDT paging message triggers MT-SDT only and that the CG-SDT resource is not configured, determining that the RACH resource is the resource (page 2/10-3/10, section 2.1, for point 2, a local page message can reach the UE, but a random access (SDT or legacy) is necessary for the UE to response to the page if no valid CG-SDT is configured). Therefore, it would have been obvious to one of ordinary skill in the art before the effective date of the claimed invention was made to modify and utilize the above teachings for the purposes of effectively performing uplink transmission under all conditions. Consider claims 65 and 88, Ericsson father teaches wherein determining the resource comprises: responsive to determining that MT-SDT paging message triggers MT-SDT, determining that the CG-SDT resource or the RA-SDT resource is the resource (page 2/10-3/10, section 2.1, paging of the UE). Therefore, it would have been obvious to one of ordinary skill in the art before the effective date of the claimed invention was made to modify and utilize the above teachings for the purposes of effectively performing uplink transmission under all conditions. Consider claims 67 and 90, Ericsson further teaches receiving, from the base station, configuration information comprising in indication of the RACH configuration via RRC broadcast signaling (page 2/10, section 2, proposal 1, an SDT-indication for the UE). Therefore, it would have been obvious to one of ordinary skill in the art before the effective date of the claimed invention was made to modify and utilize the above teachings for the purposes of effectively performing uplink transmission under all conditions. Claim(s) 94-96 is/are rejected under 35 U.S.C. 103 as being unpatentable over Huang et al. (US 2023/0309081 A1) in view of Chen (US 2025/0193959 A1). Consider claims 94-96, Huang does not teach wherein the configuration information comprises: an indication that the UE select the resource for transmitting the UL response message based on a priority of resource types, and wherein according to the priority of resource types, a Configured Grant resource specific to Small Data Transmission (CG-SDT) is prioritized over a legacy Random Access Channel (RACH) resource or an indication that the UE select the resource for transmitting the UL response message based on a priority of resource types, and wherein according to the priority of resource types, when the MT-SDT paging message triggers MT-SDT only, the UE selects a legacy Random Access Channel (RACH) resource or wherein the configuration information comprises: an indication that the UE select the resource for transmitting the UL response message based on a priority of resource types, and wherein according to the priority of resource types, when the MT-SDT paging message triggers MT-SDT, a selection is made from among a Configured Grant resource specific to Small Data Transmission (CG-SDT) or a Random Access Small Data Transmission (RA-SDT) resource. Chen further teaches wherein the configuration information comprises: an indication that the UE select the resource for transmitting the UL response message based on a priority of resource types, and wherein according to the priority of resource types, a Configured Grant resource specific to Small Data Transmission (CG-SDT) is prioritized over a legacy Random Access Channel (RACH) resource or an indication that the UE select the resource for transmitting the UL response message based on a priority of resource types, and wherein according to the priority of resource types, when the MT-SDT paging message triggers MT-SDT only, the UE selects a legacy Random Access Channel (RACH) resource or wherein the configuration information comprises: an indication that the UE select the resource for transmitting the UL response message based on a priority of resource types, and wherein according to the priority of resource types, when the MT-SDT paging message triggers MT-SDT, a selection is made from among a Configured Grant resource specific to Small Data Transmission (CG-SDT) or a Random Access Small Data Transmission (RA-SDT) resource (paragraph 49 and 80, priority is indicated for RA-SDT and CG-SDT). Therefore, it would have been obvious to one of ordinary skill in the art before the effective date of the claimed invention was made to modify and utilize the above teachings for the purposes of effectively performing uplink transmission under all conditions. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JUSTIN YE LEE whose telephone number is (571)272-5258. The examiner can normally be reached 9:30-8:00. 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 5712705371. 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. /JUSTIN Y LEE/ Primary Examiner, Art Unit 2644 3/3/26
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Prosecution Timeline

Feb 02, 2024
Application Filed
Mar 03, 2026
Non-Final Rejection — §102, §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
80%
Grant Probability
91%
With Interview (+10.9%)
3y 3m
Median Time to Grant
Low
PTA Risk
Based on 703 resolved cases by this examiner. Grant probability derived from career allow rate.

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