Prosecution Insights
Last updated: April 19, 2026
Application No. 18/557,455

THERMAL MITIGATION FOR CELLULAR DEVICES

Non-Final OA §102§103
Filed
Oct 26, 2023
Examiner
LEE, CHI HO A
Art Unit
2475
Tech Center
2400 — Computer Networks
Assignee
Google LLC
OA Round
2 (Non-Final)
92%
Grant Probability
Favorable
2-3
OA Rounds
2y 6m
To Grant
96%
With Interview

Examiner Intelligence

Grants 92% — above average
92%
Career Allow Rate
1244 granted / 1353 resolved
+33.9% vs TC avg
Minimal +4% lift
Without
With
+3.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
42 currently pending
Career history
1395
Total Applications
across all art units

Statute-Specific Performance

§101
3.4%
-36.6% vs TC avg
§103
41.6%
+1.6% vs TC avg
§102
23.2%
-16.8% vs TC avg
§112
13.8%
-26.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1353 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 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 13-15 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by CHEN et al PG PUB 2016/0255639. Re Claim 13, CHEN et al teaches in figure 1, a UE 22 determining whether a frequency measurement exceeds a measurement threshold value (a thermal trigger event) [0020]; the UE includes 1st RAT schedule 30 and 2nd RAT schedule 32 for indicating/determining a first and second activity schedules (a data measurement) for the respective RATs (at least one RAT) of the UE [0085-0087]; based on the scheduled activity (the data measurement), selecting a first or second interference mitigation based on the scheduling activity of 1st or 2nd RAT and performing the interference mitigation. Re Claims 14, 15, CHEN et al teaches each of 1st or 2nd RAT (each of plurality of Scells) activity (associated data measurement) are associated with a priority value (a thermal mitigation priority) [0014] wherein based on the priority value, RAT activity schedule can be terminated (dropping the selected at least one Scell). 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 1-3, 7, 20-23 are rejected under 35 U.S.C. 103 as being unpatentable over Gupta et al PG PUB 2019/0021115 in view of Arora et al PG PUB 2017/0347313. Re Claims 1, Gupta et al teaches in figure 5, 505, a device 110 (RF modem, processor, memory) supports data aggregation on concurrent LTE-U (a first RAT) and WiFI (a second RAT) [0030]; steps 550, 585 teaches the device performing a CQI on the LTE-U (a first level of thermal mitigation) and WLAN PER (a second level of thermal mitigation) wherein the CQI and WLAN PER being different [0035 0036] wherein the CQI/PER can be associated with thermal/power measurements. Gutpa et al fails to explicitly teach “responsive to a trigger event, determining a first data measurement …a first RAT and a second data measurement …a second RAT of the UE;”. However, Arora et al teaches a power controller for varying a configuration parameter based on estimated data throughput used per data communicated in carrier aggregation [0080-0083] wherein with a certain threshold (a thermal triggering event), the power can be increased or reduced to improve throughput gains or mitigate for interference. By combining the teachings, the power controller in Arora et al can be implemented in the device of Gupta et al to improve throughput gain and mitigate for interference. One skilled in the art would have been motivated to improve throughput and mitigate for interference in CA operation in Gutpa et al. Therefore, it would have been obvious to one skilled to have combined the teachings. Re Claims 2, 21, Gutpa et al teaches in figure 5, 585, a CQI threshold (the triggering event) for determining a CQI (one thermal parameter) associated with the device satisfies at the CQI threshold [0036]. Re Claims 3, 23, Arora et al teaches data estimate throughput in the carrier aggregation (multiple downlink CCs) wherein in view of Gutpa et al, the data aggregation is the data estimate throughput per connection from the LTE-U and WLAN (the first and second RAT). Re Claims 7 and 23, Gupta et al in view of Arora et al teaches responsive to the certain threshold, in this case, the thresholds for the LTE-U and WLAN connections, the device of Arora et al, the device of Gupta can be modified to perform the first and second thermal mitigations based on the certain thresholds wherein if the certain thresholds are satisfied, the first and second thermal mitigations would have been halted and thermal trigger event has ended; responsive to the certain threshold is not satisfied and varying the power is not feasible for interference/thermal mitigation, Gupta et al teaches [0036] disabling the LTE-U or WLAN connectivity (a more aggressive level of thermal mitigation). Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Gupta et al PG PUB 2019/0021115 in view of Arora et al PG PUB 2017/0347313 as applied to Claim 1 above and further in view of Lohr et al PG PUB 2018/0310202. Re Claim 4, Gupta et al in view of Arora et al teaches estimating data throughput per data communicated in CA wherein in Gupta, estimated data throughputs are determined in LTE-U (the first RAT) and WLAN (the second RAT) supporting CA. Gupta et al in view of Arora et al fails a first and a second portion of a Split-Bearer configured for the first and second RATs. However, Lohr et al teaches a NB can configure a split bearer operation as defined or 5G for throughput enhancement [0033]. By combining the teaching, device in Gupta et al can be configured with the split-bearer operation for throughput enhancement as defined in 5G. One skilled in the art would have been motivated to support throughput enhancement via the split-bearer operation as defined in 5G. Therefore, it would have been obvious to one skilled to have combined the teachings. Claims 8, 10 and 24 rejected under 35 U.S.C. 103 as being unpatentable over Gupta et al PG PUB 2019/0021115 in view of Arora et al PG PUB 2017/0347313 as applied to Claims 1, above and further in view SAHU et al PG PUB 2014/0247729. Re Claims 8, 10 and 24, Gupta et al in view of Arora et al fails to explicitly teach “selecting a relaxed level of thermal mitigation” associated “the first level of thermal mitigation” and “a aggressive level of of thermal mitigation" associated with "the second level of thermal mitigation. However, SAHU et al teaches when the mobile station temperature rises over a first threshold (a relaxed level of thermal mitigation), the mobile station back-off transmission gradually to reduce the thermal temperature of the mobile device [0026] and has a less negative impact on the data throughput. SAHU et al further teaches when the mobile station temperature rises over a second threshold (a aggressive level of thermal mitigation), the mobile station consequently triggers a transmission shutdown of the mobile station [0027] that absolutely impacts (increased negative impact) the data throughput. By combining the teachings, one skilled in the art would have been motivated to have adaptively select different thermal mitigation based on different thermal temperature conditions of the mobile station. Therefore, it would have been obvious to one skilled in the art to have combined the teachings. Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over WEI et al PG PUB 2022/0286191 in view of SAKHNINI et al PG PUB 2021/0368529. Re Claim 16, WEI et al teaches a UE within a communication network, the UE reporting (informing) to the network of reduced bandwidth capability of UE; the UE receiving from the network UE-specific RRC (a reduced bandwidth part configuration) configured BWP having a narrow bandwidth; the UE implementing the reduce bandwidth part configuration [0107]. WEI et al fails to explicitly teach “responsive to a thermal trigger event having occurred, informing the cellular network…”. However, SAKHNINI et al teaches a reduced capability UE may communicate on a narrow BWP in order to reduce or mitigate for interference to improve transmission data [0008]. By combining the teachings, the reduced bandwidth capability information of the UE can be triggered when interference exceeds its threshold. One skilled in the art would have been motivated to have switched to the reduced bandwidth configuration to mitigate for the interference. Therefore, it would have been obvious to one skilled in the art to have combined the teachings. Claim 17 is rejected under 35 U.S.C. 103 as being unpatentable over WEI et al PG PUB 2022/0286191 in view of SAKHNINI et al PG PUB 2021/0368529 as applied to Claim 16 above and further in view of KUBOTA et al PG PUB 2021/0044408 Re Claim 17, in view of WEI et al in view of SAKHNINI, one skilled in the art would have realized that based on a threshold for the interference, the mobile would have determined that the thermal triggering event has ended. WEI et al in view of SAKHNINI fails to explicitly teach “based on the thermal event ending to the network, receiving an increased bandwidth part configuration…”. However, KUBOTA et al teaches the UE can be configured with increased bandwidth capability or reduced bandwidth capability [0084]. By combining the teachings, the UE can be configured with the increased bandwidth when the thermal event has ended to improve throughput. One skilled in the at would have been motivated to have configured the UE to operating in increased bandwidth when interference has ended to improve throughput. Therefore, it would have been obvious to one skilled to have combined the teachings. Claims 18, 19 are rejected under 35 U.S.C. 103 as being unpatentable over WEI et al PG PUB 2022/0286191 in view of SAKHNINI et al PG PUB 2021/0368529 as applied to Claim 16 above and further in view of Zeira et al PG PUB 2012/0243486. Re Claim 18, WEI et al in view of SALHNINI et al fails to explicitly teach “selecting a lower CQI based on the current channel quality indicator and sending the…to the cellular network.”. However Zeira et al teaches the UE can be configured to report/feedback based on high or low CQI thresholds [0114]. By combining the teachings, the CQI for the current channel condition can be configured to report/feedback based on the lower CQI threshold. One skilled in the art would have been motivated to have configured the UE to be adaptive to different CQI thresholds. Therefore, it would have been obvious to one skilled to have combined the teachings. Re Claims 19, in view of Zeira et al, based on the CQI threshold, the UE determines that the interferences has ended and feedback the CQI accordingly. Allowable Subject Matter Claim 25 is 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. The following is a statement of reasons for the indication of allowable subject matter: Re Claim 25, prior art fails to teach the first level of thermal mitigation is further selected based on the first data measurement being lower than the second data measurement, and wherein the second level of thermal mitigation is further selected based on the second data measurement being higher than the first data measurement as claimed. Response to Arguments Applicant’s arguments with respect to claim(s) 1-4, 7-10, 13-24 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANDREW LEE whose telephone number is (571)272-3130. The examiner can normally be reached Monday-Friday 8:30AM-5PM 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, KASSIM KHALAD can be reached at 5712703370. 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. /ANDREW LEE/ Primary Examiner, Art Unit 2475
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Prosecution Timeline

Oct 26, 2023
Application Filed
Oct 28, 2025
Non-Final Rejection — §102, §103
Jan 12, 2026
Applicant Interview (Telephonic)
Jan 12, 2026
Examiner Interview Summary
Jan 28, 2026
Response Filed
Mar 23, 2026
Non-Final Rejection — §102, §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

2-3
Expected OA Rounds
92%
Grant Probability
96%
With Interview (+3.9%)
2y 6m
Median Time to Grant
Moderate
PTA Risk
Based on 1353 resolved cases by this examiner. Grant probability derived from career allow rate.

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