Prosecution Insights
Last updated: April 19, 2026
Application No. 18/509,598

Uplink Spatial Relation Indication and Power Control

Final Rejection §102
Filed
Nov 15, 2023
Examiner
FANG, PAKEE
Art Unit
2409
Tech Center
2400 — Computer Networks
Assignee
Apple Inc.
OA Round
2 (Final)
67%
Grant Probability
Favorable
3-4
OA Rounds
3y 0m
To Grant
99%
With Interview

Examiner Intelligence

Grants 67% — above average
67%
Career Allow Rate
358 granted / 532 resolved
+9.3% vs TC avg
Strong +36% interview lift
Without
With
+36.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
35 currently pending
Career history
567
Total Applications
across all art units

Statute-Specific Performance

§101
3.7%
-36.3% vs TC avg
§103
59.2%
+19.2% vs TC avg
§102
19.1%
-20.9% vs TC avg
§112
11.6%
-28.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 532 resolved cases

Office Action

§102
DETAILED ACTION Response to Amendment The amendment filed on 01/16/2026 has been entered and considered by Examiner. Claims 21-40 are presented for examination. This Action is made FINAL. Claim Rejections - 35 USC § 102 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)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale or otherwise available to the public before the effective filing date of the claimed invention. Claims 21-40 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Applicant’s Admitted Prior Art (AAPA) “Enhancements on Multi-beam Operation” (R1-1909273). For claims 21, 28, and 35, AAPA discloses a method, comprising: determining that a spatial relation between a reference signal and an uplink signal is not configured by a cellular network for a user equipment (UE) (Proposal 12-16, if no PL RS is configured and no spatial relationship for ul transmission is configured, no downlink RS for pathloss is provided and establishing a connection with the cellular network); determining that downlink reference signals for pathloss are not provided by the cellular network for the UE (see Proposal 12-16, from which it derives that if PL RS is not configured and spatial relation for UL transmission is not configured, no downlink RS for pathloss is provided); selecting a particular spatial filter for the uplink signal based at least in part on the determination that the spatial relation between the reference signal and the uplink signal is not configured and the determination that downlink reference signals for pathloss are not provided (see Proposal 12-16), wherein the particular spatial filter is associated with a spatial filter used for a downlink communication (see Proposal 12-16); and transmitting the uplink signal using the particular spatial filter (see Proposal 12-16). For claim 28, AAPA discloses a method, comprising: at a cellular network: communicating with a user equipment (UE) (Page 2-3); receiving, from the UE, an uplink signal using a particular spatial filter associated with a spatial filter used for a downlink communication (see Proposal 12-16), wherein: a spatial relation between a reference signal and an uplink signal is not configured for the UE (Proposal 15 and 16, if no PL RS is configured and no spatial relationship for ul transmission is configured, no downlink RS for pathloss is provided and establishing a connection with the cellular network); and downlink reference signals for pathloss are not provided by the cellular network for the UE (see Proposal 12-15, from which it derives that if PL RS is not configured and spatial relation for UL transmission is not configured, no downlink RS for pathloss is provided). Claim 35 differs from claim 1 only by the additional recitation of the following limitation, which is also taught by the cited prior art. The cited prior art further discloses an apparatus, comprising: a processor configured to, when executing instructions stored in a memory, to perform operations comprising (Page 2-3, a UE that’s connected to Base Station in a cell, must have a processor and a cellular transceiver): All other identical limitations are rejected based on the same rationale as shown above. For claims 22, 29, and 36, AAPA discloses the uplink signal comprises sounding reference signal (SRS) (Page 14, section 7.4, Proposal 16). For claims 23, 30, and 37, AAPA discloses the uplink signal comprises physical uplink control channel (PUCCH) (Page 14, section 7.4, Proposal 16). For claims 24, 31, and 38, AAPA discloses the downlink communication comprises physical downlink shared channel (PDSCH) (Page 14 section 7.4, and Page 16 section 9) For claims 25, 32, and 39, AAPA discloses the downlink communication comprises physical downlink control channel (PDCCH) (Page 8 section 3, Proposal 7). For claims 26, and 33, AAPA discloses the downlink communication comprises a communication in a recent slot (page. 16 section 9). For claims 27, and 34, AAPA discloses the recent slot is offset by K slots from a current slot (page. 16 section 9) and wherein K is configured by higher layer signaling (Page 10 Fig. 6, and Page 14 Proposal 14). For claim 40, AAPA discloses a radio communicatively coupled to the processor (Page 2-3, a UE that’s connected to Base Station in a cell, must have a processor and a cellular transceiver). Response to Arguments Applicant's latest filed arguments have been fully considered but they are not persuasive. With regard to the references failing to teach every element recited in the independent claims; the Examiner respectfully disagrees with the arguments by the Applicant. Even though, the Examiner acknowledges Applicant's invention may possess some novel features, the claims are written too broad that can be read on the current cited prior art(s). Further actions must be taken to explicitly claim those novel features of the current application. 1. With regards to the argument for the limitation “…determining that a spatial relation between a reference signal and an uplink signal is not configured by a cellular network for a user equipment (UE)”, the Examiner asserts that AAPA discloses, on Proposal 15 and 16, if no PL RS is configured and no spatial relationship for ul transmission is configured, no downlink RS for pathloss is provided and establishing a connection with the cellular network. AAPA addresses the scenario where “If spatial relation of PUCCH/SRS is not configured in FR2, we support the default PUCCH/SRS transmit beam to follow the defaulted PDSCH beam on same CC as PUCCH/SRS.” See Section 7.4 - Default PUCCH/SRS Spatial Relation. AAPA specifically proposes behavior for when the UE determines there is a lack of configuration/ Proposal 16: “For PUCCH/SRS without configured spatial relation, corresponding Tx beam follows the default PDSCH beam on same CC as PUCCH/SRS.” AAPA further notes, "If spatial relation of PUCCH/SRS is not configured in FR2, we support the default PUCCH/SRS transmit beam to follow the defaulted PDSCH beam...".These passages explicitly disclose determining that a spatial relation for an uplink signal (PUCCH/SRS) is not configured. Furthermore, AAPA treats beam management and power control (pathloss) as an integrated update process. Integrated Activation: "When the spatial relation of AP-SRS for CB/NCB UL is activated by MAC-CE, UL power control parameters for PUSCH can be activated via the MAC-CE." Unified Problem Solving: The document identifies that the current specification for when a "UE is not provided pathloss RS" is "not adequate". Proposals 15 and 16 are presented as the solution to provide these missing references for UL signals like PUCCH and SRS. By establishing that the "Tx beam follows the default PDSCH beam" when a spatial relation is not configured, Proposal 16 provides the specific "selected" reference signal that fulfills the requirement of the claim when the determinations of missing configurations are made. 2 . With regards to the argument for the limitation “…determining that downlink reference signals for pathloss are not provided by the cellular network for the UE”, the Examiner asserts that AAPA discloses, on Proposal 15, from which it derives that if PL RS is not configured and spatial relation for UL transmission is not configured, no downlink RS for pathloss is provided. The AAPA explicitly ties the pathloss reference signal (PL RS) to the spatial relation of the uplink (UL) transmission. Evidence of the PL-Spatial Relation Link: “If the UE is not provided path loss RS, the UE must calculate PL using a RS resource from the SS/PBCH block index that the UE obtains higher layer parameter MIB.” Same section, continued "if PL RS is not explicitly configured and a DL RS is configured in the spatial relation parameter, then PL for power control should be calculated from the DL RS." The proposal contains two separate determinations: First, PL RS is not configured, second DL RS is configured in spatial relation The claim does not require that no spatial relation exists for any RS; it requires that a spatial relation between a reference signal and an uplink signal is not configured for the claimed selection step. Proposal 15 explicitly handles the case where the pathloss RS is missing, which is exactly the scenario claimed. Proposal 15: If PL RS is not configured and downlink RS is configured in spatial relation for UL transmission associated with this PL RS, support the PL RS to follow the downlink RS in spatial relation". This confirms that the proposal is not just about a measurement, but a rule for the UE to follow a specific downlink reference signal for its uplink transmission parameters when a dedicated pathloss configuration is missing. 3. With regards to the argument Proposals 15 and 16 as unrelated, AAPA shows that proposals are explicitly designed to operate together. “Enhancements on UL and/or DL transmit beam selection specified in Rel-15 to reduce latency and overhead.” Both Proposal 15 (pathloss RS following DL RS) and Proposal 16 (default uplink beam following PDSCH beam) are part of the same beam-selection framework, addressing different missing-configuration conditions. When: no PL RS is configured → Proposal 15 governs how DL RS is used for UL power control; no UL spatial relation is configured → Proposal 16 governs which beam the UL transmission follows. Together, they disclose the conditional logic and resulting selection recited in claim 21. Moreover, Applicant only argues Proposal 15 is “only about pathloss measurement.” That argument is flatly contradicted by Proposals 12-14, which show pathloss RS, spatial relation, and UL transmission are interdependent. Proposal 12 cites: “MAC-CE based spatial relation update is per resource level for A-SRS …” This confirms spatial relation directly governs UL reference signals. Proposal 14 cites: “Support using MAC-CE to update path loss RS for power control.” This explicitly ties pathloss RS selection to UL power control, which is inseparable from UL transmission behavior. Supporting explanation immediately preceding Proposal 15: “If the UE is not provided path loss RS, the UE must calculate PL using a RS resource from the SS/PBCH block… This is not adequate… thus, we support that if PL RS is not explicitly configured… PL for power control should be calculated from the DL RS.” This passage expressly teaches a determination that PL RS is not provided, followed by selection of a DL RS affecting UL transmission. The disclosure and teachings by the AAPA should be view in its entirety, instead of narrowly analyzing one or two of its teachings. ARGUMENT DOES NOT REPLACE EVIDENCE WHERE EVIDENCE IS NECESSARY The arguments made by the counsel cannot take the place of evidence in the record. The Applicant representative’s arguments for the obvious reason to combine the implicit and explicit teaching of the cited reference(s) failed to provide factual support to sustain the ground of arguments. The mere statement of disagreement of the prior art made by the Applicant’s representative cannot be served as evidence for support. Please see the following case law for detail: As discussed above, it is apparent that the Applicant's cited limitations, elements, and arguments have already been disclosed by the relevant prior art(s) or were thoroughly addressed by the Examiner. Additionally, the current Office Action provides further elaboration on the explicit and implicit teachings of the aforementioned disclosed reference(s). It is important to note that any justifications and citations utilized in the preceding Office Action which were not contested by the Applicant shall be regarded as an implicit admission by the Applicant on the matter at hand. 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 extension fee 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. Inquiries Any inquiry concerning this communication or earlier communications from the Examiner should be directed to PAKEE FANG whose telephone number is (571)270-3633. The Examiner can normally be reached on Mon-Fri 9:00AM-5:00PM. 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, Armouche, Hadi can be reached on 571-270-3618. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /PAKEE FANG/ Primary Examiner, Art Unit 2409
Read full office action

Prosecution Timeline

Nov 15, 2023
Application Filed
Nov 17, 2025
Non-Final Rejection — §102
Jan 16, 2026
Response Filed
Jan 30, 2026
Final Rejection — §102 (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
67%
Grant Probability
99%
With Interview (+36.4%)
3y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 532 resolved cases by this examiner. Grant probability derived from career allow rate.

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