Prosecution Insights
Last updated: April 19, 2026
Application No. 18/433,148

MESSAGE TRANSMISSION METHOD AND COMMUNICATION APPARATUS

Non-Final OA §102§103
Filed
Feb 05, 2024
Examiner
AJIBADE AKONAI, OLUMIDE
Art Unit
3648
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Huawei Technologies Co., Ltd.
OA Round
1 (Non-Final)
84%
Grant Probability
Favorable
1-2
OA Rounds
3y 2m
To Grant
93%
With Interview

Examiner Intelligence

Grants 84% — above average
84%
Career Allow Rate
989 granted / 1172 resolved
+32.4% vs TC avg
Moderate +9% lift
Without
With
+8.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
29 currently pending
Career history
1201
Total Applications
across all art units

Statute-Specific Performance

§101
6.3%
-33.7% vs TC avg
§103
44.9%
+4.9% vs TC avg
§102
26.0%
-14.0% vs TC avg
§112
14.8%
-25.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1172 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 . Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitations uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitations are: first network device and second network device in claims 1, 2, 5, 7-11. Because these claim limitations are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, they are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have these limitations interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitations recite sufficient structure to perform the claimed function so as to avoid them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. 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. Claims 1, 7, and 12 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Han et al US 12,156,276 (hereinafter Han). Regarding claim 1, Han discloses a message transmission method for message transmission, comprising: receiving, by a first network device (gNB1 112, see fig. 2, col. 3, line 12), a first message (RCCResumeRequest, see fig. 2, col. 3, lines 9-10) from a terminal device (UE 110, see fig. 2, col. 3, lines 9-10), wherein the first message comprises a resume cause value and an integrity check code (RRCResumeRequest message are sent with a RNA update/ma-Update, and include a resumeMAC-I, see fig. 2, col. 3, line 9 – col. 4, line 9), the integrity check code is generated based on the resume cause value (since the ResumeCause is RNA update/ma-Update, a resumeMAC-I is generated, see fig. 2, col. 3, line 9 – col. 4, line 9, Table 1), the terminal device is in an inactive state (UE in RRC_INACTIVE, see fig. 2), and the resume cause value is a resume cause indicated by a higher layer or a radio resource control (RRC layer) (RRC layer signaling is used for sending and processing the RRCResumeRequest see table 1, figs. 2 and 3, col. 7, lines 55-67, col. 13, lines 55-57 and 64-67, col. 14, lines 1-3); and sending, by the first network device, a second message (Retrieve UE Context Request, see fig. 2, col. 4, lines 10-12, col. 14, lines 1-4) to a second network device (last serving gNB 114, see fig. 2, col. 4, lines 10-12, col. 14, lines 1-4), wherein the second message comprises the resume cause value and the integrity check code (see fig. 2, col. 3, line 9 – col. 4, line 14, col. 14, lines 1-4, Table 1), and the second network device is a network device that stores a context of the terminal device (context retrieval to the last serving gNB because it stores UE context, see col. 4, lines 16-19, col. 5, lines, Table 1, col. 13, line 64 – col. 15, line 11). Regarding claim 7, Han discloses a message transmission method for message transmission (see fig. 2), comprising: receiving, by a second network device (last serving gNB 114, see fig. 2, col. 4, lines 10-12, col. 14, lines 1-4), a second message (Retrieve UE Context Request, see fig. 2, col. 4, lines 10-12, col. 14, lines 1-4) from a first network device (gNB1 112, see fig. 2, col. 3, line 12), wherein the second message is sent by the first network device when the first network device receives a resume cause value and an integrity check code (RRCResumeRequest message are sent with a RNA update/ma-Update, and include a resumeMAC-I, see fig. 2, col. 3, line 9 – col. 4, line 9) that are sent by a terminal device (UE 110, see fig. 2, col. 3, lines 9-10), the second message comprises the resume cause value and the integrity check code (see Table 1), the terminal device is in an inactive state (UE in RRC_INACTIVE, see fig. 2), and the resume cause value is a resume cause indicated by a higher layer or a radio resource control (RRC) layer (RRC layer signaling is used for sending and processing the RRCResumeRequest see table 1, figs. 2 and 3, col. 7, lines 55-67, col. 13, lines 55-57 and 64-67, col. 14, lines 1-3); and checking, by the second network device, the integrity check code by using the resume cause value (since the ResumeCause is RNA update/ma-Update, a resumeMAC-I is generated, see fig. 2, col. 3, line 9 – col. 4, line 9, Table 1). Regarding claim 12, Han discloses an apparatus (see figs. 3 and 4), comprising: one or more processors (see fig. 4, col. 9, lines 55-67); and one or more memories coupled to the one or more processors and storing programming instructions for execution by the one or more processors (see fig. 4, col. 9, lines 55-67) to cause the apparatus to perform operations comprising: receiving, by a first network device (gNB1 112, see fig. 2, col. 3, line 12), a first message (RCCResumeRequest, see fig. 2, col. 3, lines 9-10) from a terminal device (UE 110, see fig. 2, col. 3, lines 9-10), wherein the first message comprises a resume cause value and an integrity check code (RRCResumeRequest message are sent with a RNA update/ma-Update, and include a resumeMAC-I, see fig. 2, col. 3, line 9 – col. 4, line 9), the integrity check code is generated based on the resume cause value (since the ResumeCause is RNA update/ma-Update, a resumeMAC-I is generated, see fig. 2, col. 3, line 9 – col. 4, line 9, Table 1), the terminal device is in an inactive state (UE in RRC_INACTIVE, see fig. 2), and the resume cause value is a resume cause indicated by a higher layer or a radio resource control (RRC) layer (RRC layer signaling is used for sending and processing the RRCResumeRequest see table 1, figs. 2 and 3, col. 7, lines 55-67, col. 13, lines 55-57 and 64-67, col. 14, lines 1-3); and sending, by the first network device, a second message (Retrieve UE Context Request, see fig. 2, col. 4, lines 10-12, col. 14, lines 1-4) to a second network device (last serving gNB 114, see fig. 2, col. 4, lines 10-12, col. 14, lines 1-4), wherein the second message comprises the resume cause value and the integrity check code (see fig. 2, col. 3, line 9 – col. 4, line 14, col. 14, lines 1-4, Table 1), and the second network device is a network device that stores a context of the terminal device (context retrieval to the last serving gNB because it stores UE context, see col. 4, lines 16-19, col. 5, lines, Table 1, col. 13, line 64 – col. 15, line 11). 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 2, 8, and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Han et al US 12,156,276 (hereinafter Han) in view of Cheng US 12,089,274. Regarding claims 2 and 13 as applied to claims 1 and 12, Han discloses the claimed invention except sending, by the first network device, a third message to the terminal device based on the resume cause value when the first network device receives the context of the terminal device from the second network device, wherein the third message is a response message to the first message. In the same field of endeavor, Cheng discloses sending, by a first network device (505-a, see fig. 6), a third message (RRCResume 635, see fig. 6, col. 19, lines 19-24) to a terminal device (UE 115-c, see fig. 6) based on the resume cause value (resume request including cause value, 625, see fig. 6, col. 19, lines 9-16) when the first network device receives the context of the terminal device (630, see col. 19, lines 16-19) from a second network device (510-a, see fig. 6), wherein the third message is a response message to a first message (620, see fig. 6, col. 19, lines 7-8). It would therefore have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the teaching of Cheng with Han with a reasonable expectation of success by sending a RRCResume to the UE in response to receiving the UE context, as taught by Cheng, for the benefit of efficiently supporting resumption of connectivity with a node in a cell after transitioning from an inactive state to a connected state. Regarding claim 8 as applied to claim 7, Han discloses the claimed invention except wherein the second message comprises data indicative of a request to obtain a context of the terminal device, and the method further comprises: sending, by the second network device, the context of the terminal device to the first network device when the checking of the integrity check code succeeds. In the same field of endeavor, Cheng discloses wherein a second message (625, see fig. 6, col. 19, lines 14-10) from a first network device (505-a, see fig. 6) to a second network device (510-a, see fig. 6) comprises data indicative of a request to obtain a context of the terminal device (UE context retrieval request 625, see fig. 6, col. 19, lines 14-10), and the method further comprises: sending, by the second network device, the context of the terminal device to the first network device when the checking of the integrity check code succeeds (630, see col. 19, lines 9-19). It would therefore have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine the teaching of Cheng with Han with a reasonable expectation of success by sending a RRCResume to the UE in response to receiving the UE context, the UE context being transmitted in response to verifying the MAC-I value in the context retrieval request, as taught by Cheng, for the benefit of efficiently supporting resumption of connectivity with a node in a cell after transitioning from an inactive state to a connected state. Allowable Subject Matter Claims 3-6, 9-11, and 14-17 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Orsino et al US 20240314558 discloses a method comprising obtaining a first connection resume request message that comprises: i) a first field containing a cause value, ii) a second field containing an identity value, and iii) a third field containing a pre-defined token value. The method further includes using the first connection resume request message to generate an authentication token. Wang et al US 12,089,046 discloses connection resume request message carrying the following information: a resume ID, a resume cause, and a short resume MAC-I. The resume ID is used to identify a suspended terminal, that is, used to identify the terminal sending the RRC connection resume request message. The resume cause is used to indicate a reason why the terminal resumes a connection. For example, a value of the resume cause is mobile terminating-access (mt-Access) or a newly added value. The newly added value is used to indicate that the reason for resuming the connection is transmitting single downlink data. The short resume MAC-I is used to perform integrity protection on the Msg3 to prevent the Msg3 from being tampered with. Torabian Esfahani et al US 20240015503 discloses a method performed by a source network node, for preventing agents from illegitimately identifying the source network node when resuming a wireless terminal in a target network node in a wireless communications network is provided. Zhang et al US 11,240,866 discloses sending, by a terminal in a radio resource control RRC inactive state, first information to a first access network device, where the first information is used to indicate that the terminal is located in a wireless network area in which the terminal is in the RRC inactive state, and the first access network device is an access network device to which a cell in which the terminal is currently located belongs. Lindheimer et al US 20200120741 discloses a wireless device determines, while in an RRC Inactive state, that a Radio Access Network Notification Area Update, RNAU, is needed. The wireless device further evaluates whether there is any other cause for resuming an RRC connected state, in addition to the need for the RNAU. The wireless device transmits an RRC Resume Request message to the network, in response to the determining. The RRC Resume Request message includes a cause indicator indicating an RNAU as a cause for resuming a RRC Connected state in the event that said evaluating identifies no other cause for resuming the RRC connected state. Mildh et al US 10,555,168 discloses security handling for RRC Resume from inactive state. Any inquiry concerning this communication or earlier communications from the examiner should be directed to OLUMIDE T AJIBADE AKONAI whose telephone number is (571)272-6496. The examiner can normally be reached Monday-Friday 8AM-4PM. 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, CHARLES N APPIAH can be reached at 571-272-7904. 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. /OLUMIDE AJIBADE AKONAI/ Primary Examiner, Art Unit 3648
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Prosecution Timeline

Feb 05, 2024
Application Filed
Mar 14, 2026
Non-Final Rejection — §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
84%
Grant Probability
93%
With Interview (+8.8%)
3y 2m
Median Time to Grant
Low
PTA Risk
Based on 1172 resolved cases by this examiner. Grant probability derived from career allow rate.

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