Prosecution Insights
Last updated: April 19, 2026
Application No. 18/471,235

FILTER-BASED TIME-AVERAGED RADIO FREQUENCY EXPOSURE EVALUATION

Final Rejection §103
Filed
Sep 20, 2023
Examiner
RACHEDINE, MOHAMMED
Art Unit
2646
Tech Center
2600 — Communications
Assignee
Qualcomm Incorporated
OA Round
2 (Final)
87%
Grant Probability
Favorable
3-4
OA Rounds
2y 4m
To Grant
98%
With Interview

Examiner Intelligence

Grants 87% — above average
87%
Career Allow Rate
663 granted / 763 resolved
+24.9% vs TC avg
Moderate +11% lift
Without
With
+11.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
15 currently pending
Career history
778
Total Applications
across all art units

Statute-Specific Performance

§101
4.4%
-35.6% vs TC avg
§103
62.3%
+22.3% vs TC avg
§102
11.9%
-28.1% vs TC avg
§112
7.4%
-32.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 763 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 . This action is in response to applicant’s amendment/arguments filed on 01/26/2026. This action is made FINAL. Response to Arguments Applicant's arguments filed 01/26/2026 have been fully considered but they are not persuasive. The applicant argues: With regard to claim 1, Applicant submits that the Non-Final Office Action has failed to adequately show that Lu teaches or suggests at least "determining an effective time-averaged transmit power associated with one or more past transmissions using a filter," as recited in claim 1. Furthermore, the Non-Final Office Action has failed to show that any such alleged transmit power "associated with one or more past transmissions" is determined "using a filter," as recited in claim 1. The Non-Final Office appears to map the BBF 312 in the TX path 302 of the RF transceiver circuit 300 in Lu to the "filter" in claim 1 (and Applicant does not concede this mapping is correct), but has failed to explain how the BBF 312 is used to determine "an effective time- averaged transmit power associated with one or more past transmissions," as recited in claim 1. The examiner respectfully disagrees: Lu et al. disclose: FIG. 5C is a graph 500C of a transmit power over time (P(t)) illustrating a time-average mode that provides a reserve power margin to enable a continuous transmission within the time window (T), in accordance with certain aspects of the present disclosure… In the time-average mode, Pmax and Preserve time durations may be controlled by a processor or control logic to ensure the time-averaged power does not exceed Plimit in the time window. In some aspects, the UE may transmit at a power that is higher than the average power level, but less than Pmax in the time-average mode illustrated in FIG. 5C. The idea of determining a time-averaged transmit power is clearly disclosed by Lu et al. The instant application recites “an effective time-averaged transmit power”. However, this term is not explicitly defined in the claim. Consequently, the time-averaged transmit power disclosed by Lu et al. can be interpreted as such. The term “using a filter” as recited in the instant application is not explicitly defined and is too broad to include any type of filter. The claim does not explicitly show how this filter is configured to produce “an effective time-averaged transmit power”. Similar analysis applies to claims 13 and 25. The limitations in questions have all been addressed as stated above Allowable Subject Matter Claims 6, 18 and 28 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. 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. 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, 5, 7-13, 17, 19-25, 27 and 29-30 are rejected under 35 U.S.C. 103 as being unpatentable over Lu et al. (US 2022/0159582 A1). Claim 1. Lu et al. disclose A method of wireless communication by a wireless device (FIG. 1-12), comprising: determining an effective time-averaged transmit power associated with one (read as UE may transmit, to the receiving entity, a signal indicative of the data at a transmit power based at least in part on the determined transmit time and an RF exposure limit… he UE may determine the amount of transmit time that will be used to transmit the data to the receiving entity in order to select the transmission mode (e.g., time-average mode or peak mode) [0161-0162]. FIG. 5-10) or more past transmissions using a filter (read as TX path 302 may include a baseband filter (BBF) 312 [0057]); and transmitting a signal in a time interval at a transmit power determined based at least in part on the effective time-averaged transmit power in compliance with a radio frequency (RF) exposure limit (read as the transmitter may ensure RF exposure compliance by operating under one of the following example schemes: (a) “a reserve-less time-average mode” without a reserve margin that allows for dropped connections during the time window, (b) “a peak mode” as described herein with respect to FIG. 5B, or (c) “a time-average mode,” as described herein with respect to FIG. 5C [0091]. FIG. 5-10). The rejection is based on the combined teaching of multiple embodiments (FIG. 1-12) disclosed by Lu et al. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to use the teaching of Lu et al. in order to realize all the limitations of the claimed invention and more particularly, to determining a transmit power while maintaining radio frequency (RF) exposure compliance (Lu et al. [0002]). Claim 5. The method of claim 1, Lu et al. disclose, wherein the effective time-averaged transmit power is determined based at least in part on a time-averaged transmit power for one or more past time intervals (read as a time-average mode,” as described herein with respect to FIG. 5C [0091]), a scaling factor (read as burst transmit time of P(t) at Pmax calculated for a given Pmax, Plimit, Preserve and T, can be scaled depending on a duty cycle of the transmission to a receiving entity. For example, the burst transmit time may be adjusted by a factor associated with the duty cycle (1/duty_cycle), where duty_cycle is between [0, 1] [0097]), and a filter value associated with one or more past time intervals (read as TX path 302 may include a baseband filter (BBF) 312 [0057]). Claim 7. The method of claim 5, Lu et al. disclose, further comprising: determining a normalized transmit power budget based at least in part on a reserve level and the effective time-averaged transmit power (read as the normalized average transmit power over X seconds [0110]); and converting the normalized transmit power budget to a maximum allowed transmit power for the time interval, wherein the transmit power is less than or equal to the maximum allowed transmit power (read as determining the capped transmit power in a single transmission scenario is as follows: Equation 9 [0110]). Claim 8. The method of claim 7, Lu et al. disclose, wherein the normalized transmit power budget is converted to the maximum allowed transmit power using a duty cycle associated with one or more transmissions (read as the average transmit power as described herein may account for changes in network duty_cycle over time [0109]). Claim 9. The method of claim 1, Lu et al. disclose, further comprising determining no past transmissions have occurred in a time-averaging time window for RF exposure compliance, wherein determining the effective time-averaged transmit power comprises setting the effective time-averaged transmit power to a particular value in response to determining no past transmissions have occurred in the time-averaging time window (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power). Claim 10. The method of claim 1, Lu et al. disclose, further comprising determining no past transmissions have occurred in one or more past time intervals, wherein the effective time-averaged transmit power is determined using a default transmit power for the one or more past time intervals in response to determining no past transmissions have occurred in the one or more past time intervals (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power). Claim 11. The method of claim 1, Lu et al. disclose, wherein the wireless device lacks sufficient resources to store a rolling transmit power history having a series of transmit powers over a time-averaging time window (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power). Claim 12. The method of claim 1, Lu et al. disclose, wherein the wireless device is an Internet of things (IoT) device (read as Internet-of-Things (IoT) devices [0305]). Claim 13. Lu et al. disclose An apparatus for wireless communication (FIG. 1-3), comprising: one or more memories collectively storing computer-executable instructions (read as The memory 338 may store data and program codes for operating the RF transceiver circuit 300 [0061]); one or more processors coupled to the one or more memories, the one or more processors being collectively configured to implement a filter and to execute the computer-executable instructions to cause the apparatus to perform an operation (read as The software modules include instructions that, when executed by an apparatus such as a processor, cause the processing system to perform various functions [0315]) comprising: determining an effective time-averaged transmit power associated with one (read as UE may transmit, to the receiving entity, a signal indicative of the data at a transmit power based at least in part on the determined transmit time and an RF exposure limit… the UE may determine the amount of transmit time that will be used to transmit the data to the receiving entity in order to select the transmission mode (e.g., time-average mode or peak mode) [0161-0162]. FIG. 5-10) or more past transmissions using the filter (read as TX path 302 may include a baseband filter (BBF) 312 [0057]); determining a transmit power based at least in part on the effective time-averaged transmit power in compliance with a radio frequency (RF) exposure limit (read as the transmitter may ensure RF exposure compliance by operating under one of the following example schemes: (a) “a reserve-less time-average mode” without a reserve margin that allows for dropped connections during the time window, (b) “a peak mode” as described herein with respect to FIG. 5B, or (c) “a time-average mode,” as described herein with respect to FIG. 5C [0091]. FIG. 5-10); and transmitting a signal in a time interval at the determined transmit power (FIGs. 5, 7 and 8-11). The rejection is based on the combined teaching of multiple embodiments (FIG. 1-12) disclosed by Lu et al. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to use the teaching of Lu et al. in order to realize all the limitations of the claimed invention and more particularly, to determining a transmit power while maintaining radio frequency (RF) exposure compliance (Lu et al. [0002]). Claim 17. The apparatus of claim 13, Lu et al. disclose, wherein the effective time-averaged transmit power is determined based at least in part on a time-averaged transmit power for one or more past time intervals (read as a time-average mode,” as described herein with respect to FIG. 5C [0091]), a scaling factor (read as burst transmit time of P(t) at Pmax calculated for a given Pmax, Plimit, Preserve and T, can be scaled depending on a duty cycle of the transmission to a receiving entity. For example, the burst transmit time may be adjusted by a factor associated with the duty cycle (1/duty_cycle), where duty_cycle is between [0, 1] [0097]), and a filter value associated with one or more past time intervals (read as TX path 302 may include a baseband filter (BBF) 312 [0057]). Claim 19. The apparatus of claim 17, Lu et al. disclose, wherein the operation further comprises: determining a normalized transmit power budget based at least in part on a reserve level and the effective time-averaged transmit power (read as the normalized average transmit power over X seconds [0110]); and converting the normalized transmit power budget to a maximum allowed transmit power for the time interval, wherein the transmit power is less than or equal to the maximum allowed transmit power (read as determining the capped transmit power in a single transmission scenario is as follows: Equation 9 [0110]). Claim 20. The apparatus of claim 19, Lu et al. disclose, wherein the normalized transmit power budget is converted to the maximum allowed transmit power using a duty cycle associated with one or more transmissions (read as the average transmit power as described herein may account for changes in network duty_cycle over time [0109]). Claim 21. The apparatus of claim 13, Lu et al. disclose, wherein: the operation further comprises determining no past transmissions have occurred in a time-averaging time window for RF exposure compliance (read as various transmission modes (e.g., as described herein) based on a transmit time associated with data and/or radio conditions while ensuring RF exposure compliance [0036]); and determining the effective time-averaged transmit power comprises setting the effective time-averaged transmit power to a particular value in response to determining no past transmissions have occurred in the time-averaging time window (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power). Claim 22. The apparatus of claim 13, Lu et al. disclose, wherein: the operation further comprises determining no past transmissions have occurred in one or more past time intervals (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power); and determining the effective time-averaged transmit power comprises using a default transmit power for the one or more past time intervals in response to determining no past transmissions have occurred in the one or more past time intervals (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power). Claim 23. The apparatus of claim 13, Lu et al. disclose, wherein the apparatus lacks sufficient resources to store a rolling transmit power history having a series of transmit powers over a time-averaging time window (FIGs. 5, 7-9 and 11 shown different scenarios for calculating the average transmit power). Claim 24. The apparatus of claim 13, Lu et al. disclose, wherein the apparatus is an Internet of things (IoT) device (read as Internet-of-Things (IoT) devices [0305]). Claim 25. Lu et al. disclose A non-transitory computer-readable medium storing code that (read as The memories 242 and 282 may store data and program codes for BS 110a and UE 120a [0052]), when collectively executed by one or more processors of an apparatus, cause the apparatus to perform a method (read as software components that are executed and run on one or more processors (e.g., controller/processor 280 of FIG. 2) [0102]), the method comprising: determining an effective time-averaged transmit power associated with one (read as UE may transmit, to the receiving entity, a signal indicative of the data at a transmit power based at least in part on the determined transmit time and an RF exposure limit… he UE may determine the amount of transmit time that will be used to transmit the data to the receiving entity in order to select the transmission mode (e.g., time-average mode or peak mode) [0161-0162]. FIG. 5-10) or more past transmissions using a filter (read as TX path 302 may include a baseband filter (BBF) 312 [0057]); and transmitting a signal in a time interval at a transmit power determined based at least in part on the effective time-averaged transmit power in compliance with a radio frequency (RF) exposure limit (read as the transmitter may ensure RF exposure compliance by operating under one of the following example schemes: (a) “a reserve-less time-average mode” without a reserve margin that allows for dropped connections during the time window, (b) “a peak mode” as described herein with respect to FIG. 5B, or (c) “a time-average mode,” as described herein with respect to FIG. 5C [0091]. FIG. 5-10). The rejection is based on the combined teaching of multiple embodiments (FIG. 1-12) disclosed by Lu et al. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to use the teaching of Lu et al. in order to realize all the limitations of the claimed invention and more particularly, to determining a transmit power while maintaining radio frequency (RF) exposure compliance (Lu et al. [0002]). Claim 27. The non-transitory computer-readable medium of claim 25, Lu et al. disclose, wherein the effective time-averaged transmit power is determined based at least in part on a time-averaged transmit power for one or more past time intervals (read as a time-average mode,” as described herein with respect to FIG. 5C [0091]), a scaling factor (read as burst transmit time of P(t) at Pmax calculated for a given Pmax, Plimit, Preserve and T, can be scaled depending on a duty cycle of the transmission to a receiving entity. For example, the burst transmit time may be adjusted by a factor associated with the duty cycle (1/duty_cycle), where duty_cycle is between [0, 1] [0097]), and a filter value associated with one or more past time intervals (read as TX path 302 may include a baseband filter (BBF) 312 [0057]). Claim 29. The non-transitory computer-readable medium of claim 27, Lu et al. disclose, further comprising: determining a normalized transmit power budget based at least in part on a reserve level and the effective time-averaged transmit power (read as the normalized average transmit power over X seconds [0110]); and converting the normalized transmit power budget to a maximum allowed transmit power for the time interval, wherein the transmit power is less than or equal to the maximum allowed transmit power (read as determining the capped transmit power in a single transmission scenario is as follows: Equation 9 [0110]). Claim 30. The non-transitory computer-readable medium of claim 29, Lu et al. disclose, wherein the normalized transmit power budget is converted to the maximum allowed transmit power using a duty cycle associated with one or more transmissions (read as the average transmit power as described herein may account for changes in network duty_cycle over time [0109]). Claims 2-4, 14-16 and 26 are rejected under 35 U.S.C. 103 as being unpatentable over (US 2022/0159582 A1) in view of Meylan et al. (US 20220191730 A1). Claim 2. The method of claim 1, Lu et al. do not explicitly disclose, wherein the filter is based on an nth order infinite impulse response filter, where n> 0. However, in the related field of endeavor Meylan et al. disclose: the UE may filter the energy per byte samples using an infinite impulse response (IIR) filter [0187]. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Claim 3. The method of claim 1, Lu et al. do not explicitly disclose, wherein the filter is based on an integrating filter. However, in the related field of endeavor Meylan et al. disclose: UE can use an instantaneous transmit power that exceeds the average power limit for a period of time provided that the average power over the moving integration window is under the average power limit at which the MPE limit is satisfied. For example, the UE may transmit at a maximum transmit power at the start of the moving integration window, [0091]. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Claim 4. The method of claim 1, Lu et al. do not explicitly disclose, wherein the filter includes a recursive averaging filter. However, in the related field of endeavor Meylan et al. disclose: the UE may filter the energy per byte samples using an infinite impulse response (IIR) filter [0187]. IIR filters are also known as recursive filters (… recursive filters may also be known as infinite impulse response filters (IIR filters) – Sethuraman (US 2012/0207200 A1) [0005]) Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Claim 14. The apparatus of claim 13, Lu et al. do not explicitly disclose, wherein the filter is based on an nth order infinite impulse response filter, where n> 0. However, in the related field of endeavor Meylan et al. disclose: the UE may filter the energy per byte samples using an infinite impulse response (IIR) filter [0187]. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Claim 15. The apparatus of claim 13, Lu et al. do not explicitly disclose, wherein the filter is based on an integrating filter. However, in the related field of endeavor Meylan et al. disclose: UE can use an instantaneous transmit power that exceeds the average power limit for a period of time provided that the average power over the moving integration window is under the average power limit at which the MPE limit is satisfied. For example, the UE may transmit at a maximum transmit power at the start of the moving integration window, [0091]. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Claim 16. The apparatus of claim 13, Lu et al. do not explicitly disclose, wherein the filter includes a recursive averaging filter. However, in the related field of endeavor Meylan et al. disclose: the UE may filter the energy per byte samples using an infinite impulse response (IIR) filter [0187]. IIR filters are also known as recursive filters (… recursive filters may also be known as infinite impulse response filters (IIR filters) – Sethuraman (US 2012/0207200 A1) [0005]) Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Claim 26. The non-transitory computer-readable medium of claim 25, Lu et al. do not explicitly disclose, wherein the filter is based on an nth order infinite impulse response filter, where n> 0. However, in the related field of endeavor Meylan et al. disclose: the UE may filter the energy per byte samples using an infinite impulse response (IIR) filter [0187]. Therefore, it would have been obvious to a person of ordinary skill in the art, at the time the invention was filed, to modify the teaching of Lu et al. with the teaching of Meylan et al. in order to provide uplink quality of service (QoS) management for shared channel transmission (Meylan et al. [0002]). Conclusion THIS ACTION IS MADE FINAL. 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 MOHAMMED RACHEDINE whose telephone number is (571)272-9249. The examiner can normally be reached Mon-Fri 8-5. 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, Matthew D. Anderson can be reached at (571)272-4177. 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. MOHAMMED . RACHEDINE Examiner Art Unit 2649 /MOHAMMED RACHEDINE/Primary Examiner, Art Unit 2646
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Prosecution Timeline

Sep 20, 2023
Application Filed
Oct 22, 2025
Non-Final Rejection — §103
Jan 26, 2026
Response Filed
Mar 07, 2026
Final Rejection — §103 (current)

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