Prosecution Insights
Last updated: October 02, 2026
Application No. 18/456,024

OPTIMIZING SMS MESSAGE FLOWS WITH OPTIMIZED UDM MESSAGING

Non-Final OA §103
Filed
Aug 25, 2023
Examiner
SUGDEN, NOAH JAMES
Art Unit
2475
Tech Center
2400 — Computer Networks
Assignee
T-Mobile USA Inc.
OA Round
3 (Non-Final)
85%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
98%
With Interview

Examiner Intelligence

Grants 85% — above average
85%
Career Allowance Rate
28 granted / 33 resolved
+26.8% vs TC avg
Moderate +13% lift
Without
With
+13.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
28 currently pending
Career history
68
Total Applications
across all art units

Statute-Specific Performance

§101
1.4%
-38.6% vs TC avg
§103
73.1%
+33.1% vs TC avg
§102
20.1%
-19.9% vs TC avg
§112
5.0%
-35.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 33 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 final rejection. 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 07/22/2026 has been entered. Information Disclosure Statement The information disclosure statement (IDS) submitted on 07/22/2026 is 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 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 text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. 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. Claims 1-3, 7-10, 14-17 are rejected under 35 U.S.C. 103 as being unpatentable over Dharmadhikari; Neeraj (EP 4184962 A1), hereinafter Dharmadhikari in view of Liu et al. (WO 202318490 A1), hereinafter Liu and Mariyani et al. (US 11689915 B1), hereinafter Mariyani. Re. Claims 1, 8, and 15, Dharmadhikari teaches a system comprising: one or more processors (Pg. 3, Line 40 - Apparatus comprising: one or more processors, and memory storing instructions that, when executed by the one or more processors, cause the apparatus to perform); and one or more non-transitory computer-readable media storing instructions executable by one or more processors, wherein the instructions (Pg. 4, Line 40 - there is provided a computer program product comprising a set of instructions which, when executed on an apparatus, is configured to cause the apparatus to carry out the method according to any of the third and fourth aspects), when executed, cause the one or more processors to perform operations comprising: receiving, by a home subscriber server (HSS), a query from a short message service center (SMSC) to send a short message service (SMS) message to a user equipment (UE) (Pg. 2, Line 19 - SMSC queries the HSS(HLR) over MAP-C/S6c SRI_SM/SRR to get the registered domain address); sending, by the HSS and to a unified data repository (UDR), a request for UE network status information (Pg. 2, Line 31 - The HSS queries the EPS-UDR via Ud to read the registered MME/MSC, the registered SGSN, and the UE-not-reachable flags for SMS in MME/MSC, SGSN and UDM); receiving, by the HSS and from the UDR, short message service function (SMSF) registration status data and access and mobility function (AMF) registration status data (Fig. 3, step 1 & Pg. 3, Line 25 - The UDM receives a Notification from the AMF/SMSF Registration); and based on the SMSF registration status data and the AMF registration status data, sending, to the SMSC, at least one of: first location data associated with a mobility management entity (MME) (Fig. 3, steps 2-3 and fig. 4, steps 4-5 & Pg. 6, Line 19 - UDM queries 5G-UDR to fetch UE reachability information and reachability info for SMS including SMSF address and/or SMS subscription. Additionally, Examiner interprets that only one of the claimed features needs to be mapped because of the presence of “Or”); OR second location data associated with the SMSF Yet, Dharmadhikari does not expressly teach determining, based on the SMSF registration status data and the AMF registration status data, whether the UE is active in a fourth generation (4G) radio network or a fifth generation (5G) radio network. However, Liu explicitly teaches determining, based on the SMSF registration status data and the AMF registration status data, whether the UE is active in a fourth generation (4G) radio network or a fifth generation (5G) radio network (Pg. 7, Line 23 - When the user terminal 60 is turned on and off, moved, or switched between networks (for example, 4G network/5G network switching), the terminal registration/deregistration process will be triggered and reach the SMSF network element via the AMF network element 50 . During the terminal registration process, the SMSF network element will record the AMF network element 50 where the user terminal 60 is located; when receiving a short message from the SMS-SC network element calling the user terminal 60, the SMSF network element can correctly forward it to The nearest AMF network element where the user terminal 60 is located). Yet, the combination of Dharmadhikari and Liu do not expressly teach the SMSF suppresses sending a deregistration message and an unsubscribe message to a unified data management function node (UDM) in response to receiving, at the SMSF, a deregistration notification from the AMF during a handover by the UE from the 5G radio network to the 4G radio network. However, Mariyani explicitly teaches wherein the SMSF suppresses sending a deregistration message and an unsubscribe message to a unified data management function node (UDM) in response to receiving, at the SMSF, a deregistration notification from the AMF during a handover by the UE from the 5G radio network to the 4G radio network (Fig. 1, Column 6, Line 50 - the one or more network functions in method 400 can include at least one of access and mobility management function (AMF), short message service function (SMSF), session management function (SMF), and authentication server function (AUSF). Furthermore, communication from the one or more network functions can be associated with a UE accessing a different network slice, a handover operation of the UE, roaming of the UE in a home network, or roaming of the UE in a partner network. The communication from the one or more network functions in method 400 can additionally or alternatively include one of the following call events: register, subscribe, deregister, unsubscribe, update, or notify). Therefore, it would have been obvious to one of the ordinary skill in the art before the effective filing date of the claimed invention to add the teaching of Mariyani to the teaching of Dharmadhikari and Liu. The motivation for such would be as Liu provides determining whether the UE is active in 4G or 5G based on the SMSF and AMF status (Liu, Pg. 7, Line 23) and Mariyani teaches that a deregistration message does not need to be sent when handoff occurs (Mariyani, Column 6, Line 50). All of the claimed elements were known in the prior art and one skilled in the art could have combined the elements, as claimed by known methods, and the combination would have yielded predictable results to one having ordinary skill in the art at the time of invention. Re. Claims 2, 9, and 16, Dharmadhikari and Liu 1, 8, and 15. Additionally, Dharmadhikari wherein the SMSC causes the SMS message to be sent to the UE based at least in part on the first location data or the second location data (Pg. 2, Line 16 - The SMs are served by a SMSC, e.g. (but not limiting) by a GW-SMSC at the edge of a network receiving SMS from another network than the home network. For the delivery of SM, SMSC needs to know the domain on which the subscriber is currently available). Re. Claims 3, 10, and 17, Dharmadhikari and Liu teach Claim 1, 8, and 15. Additionally, Dharmadhikari further teaches receiving, in response to the request for UE status information, SMSF location data indicating at the UE is registered in the 5G radio network and the AMF registration status data indicating that the UE is active in the 4G radio network; and based on the AMF registration status data, sending the first location data to the SMSC (Pg. 2, Line 24 - if HSS needs to know the availability/reachability of the UE in 5G SMSF (which may be combined with AMF to AMF/SMSF), HSS needs to fetch the SMSF address from UDM, and then HSS sends it to SMSC). Re. Claims 7, and 14, Dharmadhikari and Liu teach Claim 1, 8, and 15. Additionally, Dharmadhikari further teaches wherein determining that the UE is registered in the 4G radio network comprises determining that the SMSF registration status data is set to not active and the AMF registration status data is set to not active (Pg. 3, Line 13 - The UDM checks that the UE is registered in an AMF and SMSF. The UDM then queries the 5GS-UDR to see whether the UE-Reachability event has already been subscribed at the registered AMF(s) (i.e. whether URRP-AMF flag is set). Additionally, examiner interprets that by performing this check to see if the AMF and SMSF are registered, the check is implicitly checking whether they are active or not active, and as such if the AMF and SMSF are not active then the UE is likely registered in 4G rather than 5G). Re. Claims 5, 10, and 19, Dharmadhikari, Liu, and Mariyani teach Claim 4, 9, and 18. Additionally, Dharmadhikari teaches wherein the second location data of the SMSF associated with the UE is maintained at the UDR while the UE is connected to the 4G radio network (Pg. 2, Line 13 - dynamic information of 5G is managed and stored independently from the storage for the 2G/3G/4G subscription and some dynamic information of 2G/3G/4G (UDM .fwdarw. 5G-UDR, HSS.fwdarw. EPS-UDR)). Re. Claims 6, 11, and 20, Dharmadhikari, Liu, and Mariyani teach Claim 4, 9, and 18. Yet, the combination of Dharmadhikari and Liu do not expressly teach wherein the second location data of the SMSF associated with the UE is maintained at the UDR for a configurable period of time after the UE performs the handover from the 5G radio network to the 4G radio network However, Mariyani explicitly teaches wherein the second location data of the SMSF associated with the UE is maintained at the UDR for a configurable period of time after the UE performs the handover from the 5G radio network to the 4G radio network (Column 4, Line 63 - The UDM 110 can be configured to communicate, for example, a message to the UDR 112, with the message comprising a timestamp indicating to the UDR 112 a time that the message was transmitted by the UDM 110. The UDM 110 and the UDR 112 are configured for sending and receiving of messages between each other. The UDM 110 is configured to communicate a first message 120 to the UDR 112 in response to receiving a second message 122 from one of the network functions 102-108. For example, the second message 122 can be any communication the UDM 110 receives from the AMF 102, the SMSF 104, the SMF 106, or the AUSF 108. Upon receipt of the first message 120 from the UDM 110, the UDR 112 is configured to write the first message, including the timestamp, into memory or a database of the UDR 112). Therefore, it would have been obvious to one of the ordinary skill in the art before the effective filing date of the claimed invention to add the teaching of Mariyani to the teaching of Dharmadhikari and Liu. The motivation for such would be as Mariyani teaches that a deregistration message does not need to be sent when handoff occurs (Mariyani, Column 4, Line 63). All of the claimed elements were known in the prior art and one skilled in the art could have combined the elements, as claimed by known methods, and the combination would have yielded predictable results to one having ordinary skill in the art at the time of invention. Response to Arguments Applicant's arguments filed 07/22/2026 have been fully considered but they are not persuasive. Examiner upholds the previously provided argument regarding Mariyani and respectfully disagrees with Applicant’s interpretation of the reference. Applicant has changed the verb phrase “refrain from sending” to “suppress sending” to which Examiner interprets the two phrases perform functionally the same role. Again, Examiner interprets the claim language of “suppress” to act as a form of negative claim, as the core of the claimed language implies the Applicant is seeking to claim the absence of an action rather that the performance of an action. In their response, on page 10, Applicant acknowledges the stance of the Examiner interpreting the claim language as such and has attempted to amend the language to provide an active element rather than the absence of action. This amendment however has not materially altered the claim as to avoid the claim limitation being pointed to the non-performance of the sending a deregistration notification. Examiner would also like to address that the final clause in the claim limitation (“in response to receiving… 4G radio network.”) may also be subject to this interpretation, as the limitation is only performed if the deregistration notification is received at the SMSF. Should the deregistration notification not be received as such, the limitation would likewise would be claiming the absence or non-performance of an action and would be subject to a similar argument as upheld herein. Since Examiner has presented an argument to this claim limitation previously under the same grounds and Applicant’s argument affirms this, Examiner finds that the grounds of the previous rejection still meet the limitation as presented. As such, Examiner upholds that the negative claim language has been satisfied regarding Claims 1, 8, and 15 as well as all claims depending therein and maintains the rejection under 35 U.S.C. § 103. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Sridharan et al. (2022/0201462) - ¶0002-0006, ¶0015-0026 Any inquiry concerning this communication or earlier communications from the examiner should be directed to NOAH JAMES SUGDEN whose telephone number is (571)270-7406. The examiner can normally be reached Mon-Thurs 9:00-6:00 ET, Fri 9:00-1:00 ET. 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, Khaled Kassim can be reached at (571) 270-3770. 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. /N.J.S./Examiner, Art Unit 2475 /KHALED M KASSIM/supervisory patent examiner, Art Unit 2475
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Prosecution Timeline

Aug 25, 2023
Application Filed
Oct 01, 2025
Non-Final Rejection mailed — §103
Jan 30, 2026
Response Filed
Apr 24, 2026
Final Rejection mailed — §103
Jul 22, 2026
Request for Continued Examination
Jul 25, 2026
Response after Non-Final Action
Sep 04, 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

3-4
Expected OA Rounds
85%
Grant Probability
98%
With Interview (+13.0%)
3y 0m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 33 resolved cases by this examiner. Grant probability derived from career allowance rate.

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