Prosecution Insights
Last updated: April 19, 2026
Application No. 18/556,035

SELECTION OF DEFAULT PATH LOSS REFERENCE SIGNAL OR DEFAULT SPATIAL RELATION

Non-Final OA §102§103
Filed
Oct 18, 2023
Examiner
THOMAS, WILFRED
Art Unit
2416
Tech Center
2400 — Computer Networks
Assignee
Qualcomm Incorporated
OA Round
1 (Non-Final)
77%
Grant Probability
Favorable
1-2
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 77% — above average
77%
Career Allow Rate
212 granted / 275 resolved
+19.1% vs TC avg
Strong +30% interview lift
Without
With
+29.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
41 currently pending
Career history
316
Total Applications
across all art units

Statute-Specific Performance

§101
1.7%
-38.3% vs TC avg
§103
66.8%
+26.8% vs TC avg
§102
17.8%
-22.2% vs TC avg
§112
7.8%
-32.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 275 resolved cases

Office Action

§102 §103
DETAILED ACTION The office action is a response to an application filed on October 18, 2023, wherein claims 1-22 are pending and ready for examination. 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 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, 4, 6, and 13-17 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Li Guo (Guo hereafter) (US 20220086769 A1). Regarding claim 1 Guo teaches, A user equipment (UE) for wireless communication, comprising: a memory (Guo; Fig. 2); and one or more processors, coupled to the memory (Guo; Fig. 2), configured to: select, as a default path loss reference signal (PLRS) (Guo; [0014] When the UE applies default spatial relation info on a PUCCH resource, which pathloss RS shall be used by the UE is to be specified), a reference signal (RS) resource that corresponds to an active physical downlink shared channel (PDSCH) (the UE may determine an RS resource index providing a periodic RS resource with QCL-type D in an active Physical Downlink Shared Channel) transmission configuration indicator (TCI) state (Transmission Configuration Indicator (PDSCH TCI) state) of an active downlink (DL) bandwidth part (BWP) (in an active Downlink Bandwidth Part (DL BWP)) if the UE does not receive an indication of a PLRS and if a control resource set (CORESET) is not provided in the active DL BWP (if COntrol REsource SET (CORESET) is not provided in the active DL BWP of a serving cell of the UE)) (Guo; [0068] a UE determines a Reference Signal (RS) resource index providing a periodic RS resource; calculates a downlink pathloss estimate using the RS resource index; and determines the transmission power of the uplink transmission based on the downlink pathloss estimate [0069] When the uplink transmission is an SRS transmission, and if the UE is not provided a pathloss reference configuration or an SRS pathloss reference configuration and is not provided spatial relation information for the SRS transmission, the UE may determine an RS resource index providing a periodic RS resource with QCL-type D in an active Physical Downlink Shared Channel Transmission Configuration Indicator (PDSCH TCI) state with a lowest index in an active Downlink Bandwidth Part (DL BWP), if COntrol REsource SET (CORESET) is not provided in the active DL BWP of a serving cell of the UE); and receive the default PLRS in association with a physical uplink control channel (PUCCH) (Guo; [0102] 25. The method of any one of clauses 20 to 24, wherein the PUCCH spatial relation information is a Radio Recourse Control (RRC) parameter PUCCH-SpatialRelationInfo used to provide a reference signal that provides spatial relation information and a downlink reference signal that provides a path loss reference signal for the PUCCH resource). Regarding claim 13 Guo teaches, A user equipment (UE) for wireless communication, comprising: a memory (Guo; Fig. 2); and one or more processors, coupled to the memory (Guo; Fig. 2), configured to: select, as a default spatial relation for a physical uplink control channel (PUCCH) communication (Guo; [0014] When the UE applies default spatial relation info on a PUCCH resource, which pathloss RS shall be used by the UE is to be specified) (Guo; [0035] the UE may use a default spatial relation info, which may also be called as spatial setting for SRS transmission or SRS resource, to determine the spatial domain transmit filter for the transmission of the first SRS resource), a spatial relation that corresponds to an active physical downlink shared channel (PDSCH) transmission configuration indicator (TCI) state of an active downlink (DL) bandwidth part (BWP) ( [0035] The default spatial relation info may be determined [0038] The reference signal configured as QCL-type D in the TCI-state configured to the CORESET with a largest ID in the active DL BWP) if the UE does not receive spatial relation information and if a control resource set (CORESET) is not provided in the active DL BWP (if a first SRS resource is not configured with spatial relation info) (Guo; [0035] if a first SRS resource is not configured with spatial relation info, that is, if a UE is not configured or provided spatialRelationInfo for SRS resource… The default spatial relation info may be determined as at least one of the follows: [0036] The reference signal configured for QCL-type D in the TCI-state configured to the CORESET with a lowest ID in a most recent monitored DL slot, with respect to the transmission in the first SRS resource. [0037] The reference signal configured as QCL-type D in the TCI-state configured to the CORESET with a lowest ID in the active DL BWP. [0038] The reference signal configured as QCL-type D in the TCI-state configured to the CORESET with a largest ID in the active DL BWP. [0039] The lowest TCI-state ID among all the TCI-states activated by MAC CE for the PDSCH transmission in the active BWP.); and transmit the PUCCH communication using the spatial relation (Guo; [0016] the UE may use a default spatial relation info, which may also be called as a spatial setting for the PUCCH transmission, to determine the spatial domain transmit filter for the PUCCH transmission on the first PUCCH resource). Regarding claim 4 Guo teaches, the claim 1 wherein the one or more processors are configured to select the default PLRS further if spatial relation information is not received for the PUCCH (Guo; [0023] If the UE is not provided with PUCCH-SpatialRelationInfo and the UE is provided with pathlossReferenceRSs, the UE may obtain the referenceSignal value in PUCCH-PathlossReferenceRS from the pucch-PathlossReferenceRS-Id with index 0 in PUCCH-PathlossReferenceRS where the RS resource is either on a same serving cell or, if provided, on a serving cell indicated by a value of pathlossReferenceLinking). Regarding claims 6, and 17 Guo teaches, the claims 1, and 13, wherein the one or more processors are configured to switch carriers for the PUCCH (Guo; [0061] For a PUCCH resource: if a default spatial relation info is applied and the reference signal contained in the default spatial relation info is a periodic CSI-RS or SS/PBCH block, the UE may use that periodic CSI-RS resource or SS/PBCH block as the pathloss RS for that PUCCH resource [0063] For an SRS resource: if spatial relation info is not configured, the pathloss RS configured to the SRS set, the pathloss RSs configured for SRS resource is used as the default spatial relation info for the SRS resource). Regarding claim 14 Guo teaches, the claim13, wherein the one or more processors, to select the spatial relation as the default spatial relation, are configured to select a spatial relation that corresponds to an active PDSCH TCI state with a lowest identifier in the active DL BWP (Guo; [0035-39] the UE may use a default spatial relation info, … The default spatial relation info may be determined, [0039] the lowest TCI-state ID among all the TCI-states activated by MAC CE for the PDSCH transmission in the active BWP.). Regarding claim 15 Guo teaches, the claims 13, wherein the one or more processors are configured to select the default spatial relation further if the UE is configured to determine a default beam (Guo; [0015] the spatial relation info is configured per SRS resource while pathloss RS is configured per SRS resource set. When an SRS resource is not configured with spatial relation info, the UE may apply a default spatial relation info on that SRS resource, where the pathloss RS used by the UE is to be specified). Regarding claim 16 Guo teaches, the claim 15, wherein the one or more processors are configured to select the default spatial relation further if the UE does not receive an indication of a path loss reference signal (PLRS) in a PUCCH power control field (Guo; [0028] If the UE is not provided with a pathloss reference configuration, e.g., a list of pathloss RSs for PUCCH, the UE may use the CSI-RS resource contained in the default spatial relation info to measure the pathloss used for calculating transmit power of PUCCH). 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. Claims 2, 7, 8, 10, 12, and 18-22 are rejected under 35 U.S.C. 103 as being unpatentable over Guo as applied to claim 1 and 17 above, and further in view of Liu et al. (Liu903 hereafter) (US 20220345903 A1). Regarding claim 7 Guo teaches, A base station for wireless communication (Guo; [0011] pathlossReferenceRS configures a CSI-RS resource index or SS/PBCH block index that provides the downlink reference signal resource index for pathloss estimate), comprising: select, as a default path loss reference signal (PLRS) for a user equipment (UE) (Guo; [0014] When the UE applies default spatial relation info on a PUCCH resource, which pathloss RS shall be used by the UE is to be specified), a reference signal (RS) resource that corresponds to an active physical downlink shared channel (PDSCH) (the UE may determine an RS resource index providing a periodic RS resource with QCL-type D in an active Physical Downlink Shared Channel) transmission configuration indicator (TCI) state (Transmission Configuration Indicator (PDSCH TCI) state) of an active downlink (DL) bandwidth part (BWP) for the UE (in an active Downlink Bandwidth Part (DL BWP)) if the base station does not provide an indication of a PLRS to the UE and if the base station does not provide the UE a control resource set (CORESET) in the active DL BWP (if COntrol REsource SET (CORESET) is not provided in the active DL BWP of a serving cell of the UE)) (Guo; [0068] a UE determines a Reference Signal (RS) resource index providing a periodic RS resource; calculates a downlink pathloss estimate using the RS resource index; and determines the transmission power of the uplink transmission based on the downlink pathloss estimate [0069] When the uplink transmission is an SRS transmission, and if the UE is not provided a pathloss reference configuration or an SRS pathloss reference configuration and is not provided spatial relation information for the SRS transmission, the UE may determine an RS resource index providing a periodic RS resource with QCL-type D in an active Physical Downlink Shared Channel Transmission Configuration Indicator (PDSCH TCI) state with a lowest index in an active Downlink Bandwidth Part (DL BWP), if COntrol REsource SET (CORESET) is not provided in the active DL BWP of a serving cell of the UE); and transmit the RS resource to the UE as the default PLRS (Guo; [0102] 25. The method of any one of clauses 20 to 24, wherein the PUCCH spatial relation information is a Radio Recourse Control (RRC) parameter PUCCH-SpatialRelationInfo used to provide a reference signal that provides spatial relation information and a downlink reference signal that provides a path loss reference signal for the PUCCH resource). Guo fails to explicitly teach a base station for wireless communication a memory; and one or more processors, coupled to the memory However, in the same field of endeavor Liu903 teaches, a memory (Liu903; fig.7); and one or more processors, coupled to the memory (Liu903; fig.7 The eNB (i.e. base unit) includes a processor, a memory) It would have been obvious to one of ordinary skilled in the art before the effective filing date to create the invention of Guo to include the above recited limitations as taught by Liu903 in order to transmit the uplink signal using the determined default spatial relation (Liu903; [0081]) Regarding claim 18 Guo teaches, A base station for wireless communication (Guo; [0011] pathlossReferenceRS configures a CSI-RS resource index or SS/PBCH block index that provides the downlink reference signal resource index for pathloss estimate), comprising: select, as a default spatial relation for a physical uplink control channel (PUCCH) communication (Guo; [0014] When the UE applies default spatial relation info on a PUCCH resource, which pathloss RS shall be used by the UE is to be specified) (Guo; [0035] the UE may use a default spatial relation info, which may also be called as spatial setting for SRS transmission or SRS resource, to determine the spatial domain transmit filter for the transmission of the first SRS resource), a spatial relation that corresponds to an active physical downlink shared channel (PDSCH) transmission configuration indicator (TCI) state of an active downlink (DL) bandwidth part (BWP) ( [0035] The default spatial relation info may be determined [0038] The reference signal configured as QCL-type D in the TCI-state configured to the CORESET with a largest ID in the active DL BWP) if the base station does not provide spatial relation information for the PUCCH and if the base station does not provide a control resource set (CORESET) in the active DL BWP (if a first SRS resource is not configured with spatial relation info) (Guo; [0035] if a first SRS resource is not configured with spatial relation info, that is, if a UE is not configured or provided spatialRelationInfo for SRS resource… The default spatial relation info may be determined as at least one of the follows: [0036] The reference signal configured for QCL-type D in the TCI-state configured to the CORESET with a lowest ID in a most recent monitored DL slot, with respect to the transmission in the first SRS resource. [0037] The reference signal configured as QCL-type D in the TCI-state configured to the CORESET with a lowest ID in the active DL BWP. [0038] The reference signal configured as QCL-type D in the TCI-state configured to the CORESET with a largest ID in the active DL BWP. [0039] The lowest TCI-state ID among all the TCI-states activated by MAC CE for the PDSCH transmission in the active BWP); receive the PUCCH communication using a TCI state that corresponds to the default spatial relation (Guo; [0017] A reference signal configured for QCL-type D in the Transmission Configuration Indicator (TCI)-state configured to the COntrol REsource SET (CORESET) with the lowest ID in a most recent monitored downlink (DL) slot, with respect to the transmission in the first PUCCH resource.). Guo fails to explicitly teach a base station for wireless communication a memory; and one or more processors, coupled to the memory However, in the same field of endeavor Liu903 teaches, a memory (Liu903; fig.7); and one or more processors, coupled to the memory (Liu903; fig.7 The eNB (i.e. base unit) includes a processor, a memory) It would have been obvious to one of ordinary skilled in the art before the effective filing date to create the invention of Guo to include the above recited limitations as taught by Liu903 in order to transmit the uplink signal using the determined default spatial relation (Liu903; [0081]). Regarding claims 2 and 8 Guo teaches, The claims 1 and 7, Guo fail to explicitly teach, wherein the one or more processors, to select the RS resource as the default PLRS, are configured to select an RS resource index that provides a periodic RS resource that is configured with a quasi-co-location (QCL) Type D in the active PDSCH TCI state Liu903 further teaches, wherein the one or more processors, to select the RS resource as the default PLRS, are configured to select an RS resource index that provides a periodic RS resource that is configured with a quasi-co-location (QCL) Type D in the active PDSCH TCI state (Liu903; [0053] If higher layer parameter usage set to ‘antennaSwitching’ for the SRS, the UE transmits the second periodic SRS using the same spatial domain filter as that for a reception of PDSCH transmission#2. [0055] For periodic SRS transmission, the default spatial relation may be alternatively determined by referring to the pathloss reference RS for SRS resource configured by a higher layer parameter pathlossReferenceRS. As described above, each SRS resource set may be configured with one higher layer index for TRP distinguish. The SRS resource sets used for the same TRP may be configured with the same index value.). It would have been obvious to one of ordinary skilled in the art before the effective filing date to create the invention of Guo to include the above recited limitations as taught by Liu903 in order to transmit the uplink signal using the determined default spatial relation (Liu903; [0081]). Regarding claim 10 Guo-Liu903 teaches, the claim 7, Guo further teaches, wherein the one or more processors are configured to select the default PLRS further if spatial relation information is not received for the PUCCH (Guo; [0023] If the UE is not provided with PUCCH-SpatialRelationInfo and the UE is provided with pathlossReferenceRSs, the UE may obtain the referenceSignal value in PUCCH-PathlossReferenceRS from the pucch-PathlossReferenceRS-Id with index 0 in PUCCH-PathlossReferenceRS where the RS resource is either on a same serving cell or, if provided, on a serving cell indicated by a value of pathlossReferenceLinking). Regarding claims 12 and 22 Guo-Liu903 teaches, the claims 7, and 18, Guo further teaches, wherein the one or more processors are configured to switch carriers for the PUCCH (Guo; [0061] For a PUCCH resource: if a default spatial relation info is applied and the reference signal contained in the default spatial relation info is a periodic CSI-RS or SS/PBCH block, the UE may use that periodic CSI-RS resource or SS/PBCH block as the pathloss RS for that PUCCH resource [0063] For an SRS resource: if spatial relation info is not configured, the pathloss RS configured to the SRS set, the pathloss RSs configured for SRS resource is used as the default spatial relation info for the SRS resource). Regarding claim 19 Guo-Liu903 teaches, the claim 18, Guo further teaches, wherein the one or more processors, to select the spatial relation as the default spatial relation, are configured to select a spatial relation that corresponds to an active PDSCH TCI state with a lowest identifier in the active DL BWP (Guo; [0035-39] the UE may use a default spatial relation info, … The default spatial relation info may be determined, [0039] the lowest TCI-state ID among all the TCI-states activated by MAC CE for the PDSCH transmission in the active BWP.). Regarding claim 20 Guo-Liu903 teaches, the claim 18, Guo further teaches, wherein the one or more processors are configured to select the default spatial relation further if the UE is configured to determine a default beam (Guo; [0015] the spatial relation info is configured per SRS resource while pathloss RS is configured per SRS resource set. When an SRS resource is not configured with spatial relation info, the UE may apply a default spatial relation info on that SRS resource, where the pathloss RS used by the UE is to be specified). Regarding claim 21 Guo-Liu903 teaches, the claim 20 Guo further teaches, wherein the one or more processors are configured to select the default spatial relation further if the UE does not receive an indication of a path loss reference signal (PLRS) in a PUCCH power control field (Guo; [0028] If the UE is not provided with a pathloss reference configuration, e.g., a list of pathloss RSs for PUCCH, the UE may use the CSI-RS resource contained in the default spatial relation info to measure the pathloss used for calculating transmit power of PUCCH). Claims 3 and 9 are rejected under 35 U.S.C. 103 as being unpatentable over Guo as applied to claim 1 and 7 above, and further in view of Xiao et al. (Xiao740 hereafter) (US 20240015740 A1). Regarding claims 3 and 9 Guo teaches, the claims 1 and 7 wherein the one or more processors, to select the RS resource as the default PLRS, are configured to select an RS resource that corresponds to an active PDSCH TCI state with a lowest identifier in the active downlink BWP Xiao740 teaches, wherein the one or more processors, to select the RS resource as the default PLRS, are configured to select an RS resource that corresponds to an active PDSCH TCI state with a lowest identifier in the active downlink BWP (Xiao740; [0033] the UE 101 may determine a specific TCI state with lowest identity number (e.g., TCI-StateId defined in 3GPP specifications) from a plurality of TCI states which is activated for a specific CORESET, which is associated with a monitored search space, with lowest identify number (e.g., controlResourceSetId) in latest slot within the active BWP of the serving cell monitored by the UE 101. Then, the UE 101 may receive the PDSCH according to reference signals corresponding to the specific TCI state). It would have been obvious to one of ordinary skilled in the art before the effective filing date to create the invention of Guo to include the above recited limitations as taught by Xiao740 in order to receive the PDSCH according to reference signals corresponding to the specific TCI state. (Xiao740; [0033]). Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Guo as applied to claim 4 above, and further in view of Matsumura et al. (Matsumura175 hereafter) (US 20240267175 A1). Regarding claim 5 Guo teaches, the claim 4, Guo fails to explicitly teach, wherein the one or more processors are configured to select the default PLRS further if the UE is configured to determine a default beam However, in the same field of endeavor Matsumura175 teaches, wherein the one or more processors are configured to select the default PLRS further if the UE is configured to determine a default beam. (Matsumura175; [0057] A condition for application of the default spatial relation/default PL-RS for the SRS may include a case that an information element for enabling a default beam pathloss for the SRS (higher layer parameter enableDefaultBeamPlForSRS) is set to “enabled.”). It would have been obvious to one of ordinary skilled in the art before the effective filing date to create the invention of Guo to include the above recited limitations as taught by Matsumura175 in order to have a QCL relationship with the channel (Matsumura175; [0043]). Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over Guo-Liu903 as applied to claim 10 above, and further in view of Matsumura et al. (Matsumura175 hereafter) (US 20240267175 A1). Regarding claim 11 Guo teaches, the claim 10, Guo-Liu903 fails to explicitly teach, wherein the one or more processors are configured to select the default PLRS further if the UE is configured to determine a default beam However, in the same field of endeavor Matsumura175 teaches, wherein the one or more processors are configured to select the default PLRS further if the UE is configured to determine a default beam. (Matsumura175; [0057] A condition for application of the default spatial relation/default PL-RS for the SRS may include a case that an information element for enabling a default beam pathloss for the SRS (higher layer parameter enableDefaultBeamPlForSRS) is set to “enabled.”). It would have been obvious to one of ordinary skilled in the art before the effective filing date to create the invention of Guo-Liu903 to include the above recited limitations as taught by Matsumura175 in order to have a QCL relationship with the channel (Matsumura175; [0043]). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to WILFRED THOMAS whose telephone number is (571)270-0353. The examiner can normally be reached Mon -Thurs 9:00 am-4:00 pm. 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, Noel R Beharry can be reached at 571-270-5630. 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. /W. T/ Examiner, Art Unit 2416 /NOEL R BEHARRY/ Supervisory Patent Examiner, Art Unit 2416
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Prosecution Timeline

Oct 18, 2023
Application Filed
Dec 11, 2025
Non-Final Rejection — §102, §103
Feb 09, 2026
Interview Requested
Feb 13, 2026
Applicant Interview (Telephonic)
Feb 13, 2026
Examiner Interview Summary

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