Prosecution Insights
Last updated: April 19, 2026
Application No. 18/574,201

SMALL DATA TRANSMISSION

Non-Final OA §103
Filed
Dec 26, 2023
Examiner
ABBATINE JR., MICHAEL WILLIAM
Art Unit
2419
Tech Center
2400 — Computer Networks
Assignee
Nokia Technologies Oy
OA Round
1 (Non-Final)
25%
Grant Probability
At Risk
1-2
OA Rounds
3y 1m
To Grant
-8%
With Interview

Examiner Intelligence

Grants only 25% of cases
25%
Career Allow Rate
1 granted / 4 resolved
-33.0% vs TC avg
Minimal -33% lift
Without
With
+-33.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
61 currently pending
Career history
65
Total Applications
across all art units

Statute-Specific Performance

§101
2.4%
-37.6% vs TC avg
§103
78.1%
+38.1% vs TC avg
§102
9.4%
-30.6% vs TC avg
§112
9.1%
-30.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 4 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 . The Office Action is in response to the preliminary amendment correspondence filed on 12/26/2023. Claims 1-18, 22, & 40 are pending and rejected. Information Disclosure Statement The information disclosure statement (IDS) submitted on 07/26/2024 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 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 1-18, & 22 are rejected under 35 U.S.C. 103 as being unpatentable over Phuyal et al (US20180324854A1) in view of 3GPP TSG-WG2 Meeting #111 electronic R2-2007433 (08-2020) (hereinafter "CMCC") in further view of 3GPP TS 38.331 v16.4.1 (hererinafter "3GPP"). Regarding claim 1, Phuyal teaches a first device comprising: at least one processor ([0056], Fig 6, UE, controller/processor, memory program with instructions); and at least one memory including computer program codes ([0056], Fig 6, UE, controller/processor, memory program with instructions); the at least one memory and the computer program codes are configured to, with the at least one processor ([0056], Fig 6, UE, controller/processor, memory program with instructions), cause the first device at least to: But Phuyal fails to teach in accordance with a determination that a first condition related to Small Data Transmission (SDT) is met, determine a target identifier associated with an inactive state of the first device; and transmit, to the second device, a first message for the SDT comprising the target identifier in the inactive state. However, CMCC teaches in accordance with a determination that a first condition related to Small Data Transmission (SDT) is met, determine a target identifier associated with an inactive state of the first device (Introduction, and Section 2 Discussion pg. 1-4, specifically, the document is explicit about data/small data transmission from RRC_INACTIVE, and it ties the triggering condition (need to transmit small data while inactive), to the use of an inactive-state identifier; explanation that a UE in RRC_INACTIVE has UL data to transmit and that small data transmission from RRC_INACTIVE is the scenario being addressed; this directly corresponds to “a first condition related to SDT is met”; for data transmission from RRC_INACTIVE, the UE uses an RRC Resume-based procedure and explicitly references the use of resumeIdentity/resume-related identifiers as part of the resume request); It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. A POSITA would have been motivated to apply the hardware mechanism of Phuyal with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. But CMCC fails to teach transmit, to the second device, a first message for the SDT comprising the target identifier in the inactive state. However, 3GPP teaches transmit, to the second device, a first message for the SDT comprising the target identifier in the inactive state (clause 5.3.13.3 normative NR RRC behavior that specifies exactly what the UE transmits and what it includes when operating from RRC_INACTIVE—when the UE initiates an RRC resume procedure, the UE prepares an RRCResumeRequest/RRCResumeRequest1, and sets resumeIdentity to the stores I-RNTI/fullI-RNTI, which is the identifier associated with the inactive (suspended) state; UE transmits this RRCResumeRequest;). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 2, Phuyal fails to teach the first device wherein the first condition comprises a type of the SDT to be performed being a predetermined type of the SDT. However, CMCC teaches the first device wherein the first condition comprises a type of the SDT to be performed being a predetermined type of the SDT (Introduction, and Section 2 Discussion pg. 1-4, explicitly frames small data in RRC inactive and discusses amon 2-step RA/4-step RA/configured grant procedures (type of SDT)). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 3, Phuyal fails to teach the first device wherein the first condition comprises a type of the SDT to be performed being a configured grant (CG) based SDT. However, CMCC teaches the first device wherein the first condition comprises a type of the SDT to be performed being a configured grant (CG) based SDT (Introduction, and Section 2 Discussion pg. 1-4, explicitly lists configured grant procedure as a procedure for small data in RRC inactive state). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 4, Phuyal fails to teach the first device wherein the first condition comprises the SDT to be performed on a cell provided by a last serving network device for the first device with a CG configuration. However, CMCC teaches the first device wherein the first condition comprises the SDT to be performed on a cell provided by a last serving network device for the first device with a CG configuration ((Introduction, and Section 2 Discussion pg. 1-4, it discusses service cell unchanged since suspension vs. changed, which is the closest “last serving hook). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 5, Phuyal and CMCC fails to teach the first device wherein the first condition comprises the SDT to be performed on a cell which provides for the first device with a RRC Release with suspend. However, 3GPP teaches the first device wherein the first condition comprises the SDT to be performed on a cell which provides for the first device with a RRC Release with suspend (clause 5.3.1, 6.3.2, 6.3.2.3, clean place where RRCRelease and suspendConfig/RRC_INACTIVE configuration live (i.e. the “release with suspend” mechanism). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 6, Phuyal and CMCC fails to teach the first device wherein the first condition comprises the SDTto be performed on a cell which commands the first device to transition to the inactive state. However, 3GPP teaches the first device wherein the first condition comprises the SDTto be performed on a cell which commands the first device to transition to the inactive state (clauses 5.3.1, 6.3.2, 5.3.13, cell commands transition to inactive, normatively defines the network command/procedure that places a UE into RRC_INACTIVE via release/suspend signaling). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 7, Phuyal and CMCC fails to teach the first device wherein the target identifier is determined to be one of a short Inactive Radio Network Temporary Identifier (I-RNTI), or an I-RNTI shorter than the short I-RNTI. However, 3GPP teaches the first device wherein the target identifier is determined to be one of a short Inactive Radio Network Temporary Identifier (I-RNTI), or an I-RNTI shorter than the short I-RNTI (clauses 6.2.3.2, 5.3.13.3, explicitly supports shortI-RNTI as the resume identity in the “useFullResumeID not signaled” branch). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 8, Phuyal and CMCC fail to teach the first device wherein the first condition comprises one of the following: the SDT to be performed on a first cell other than a second cell commands the first device to transition to the inactive state, or a type of the SDT to be performed being different from a configured grant (CG) based SDT, and wherein the target identifier is determined to be a full Inactive Radio Network Temporary Identifier (I-RNTI). However, 3GPP teaches the first device wherein the first condition comprises one of the following: the SDT to be performed on a first cell other than a second cell commands the first device to transition to the inactive state, or a type of the SDT to be performed being different from a configured grant (CG) based SDT, and wherein the target identifier is determined to be a full Inactive Radio Network Temporary Identifier (I-RNTI) (clauses 5.3.13.3, 6.3.2.3, actions related to transmission of RRCResumeRequest/RRCResumeRequest1, SuspendConfig; if useFULLResumeID is signaled in SIB1, UE selects RRCResumeRequest1 and sets resumeIdentity to stored fullI-RNTI). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 9, Phuyal fails to teach the first device wherein the first condition comprises a type of the SDT to be performed being one of the following: a 4-step Random Access Channel (RACH) based SDT, and the first message comprising a MSG3, or a 2-step Random Access Channel (RACH) based SDT, and the first message comprising a MSGA. However, CMCC teaches the first device wherein the first condition comprises a type of the SDT to be performed being one of the following: a 4-step Random Access Channel (RACH) based SDT, and the first message comprising a MSG3, or a 2-step Random Access Channel (RACH) based SDT, and the first message comprising a MSGA (Introduction, and Section 2 Discussion pg. 1-4, SDT in inactive state via 2-step RA (MSGA/MSGB) and 4-step RA (MSGA/MSGB) with the RRC message concatenated with UL data). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 10, Phuyal and CMCC fails to teach the first device wherein the first condition further comprises the SDT to be performed on one of the following: a cell provided by a last serving network device for the first device, or a radio access network notification area (RNA) associated with the inactive state of the first device. However, 3GPP teaches the first device wherein the first condition further comprises the SDT to be performed on one of the following: a cell provided by a last serving network device for the first device, or a radio access network notification area (RNA) associated with the inactive state of the first device (clauses 6.3.2.3, 5.3.13, 5.3.13.2, SuspendConfig includes RAN Notification Area (RNA) information used in RRC_INACTIVE, Resume procedures are anchored to the last serving cell/RNA). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 11, Phuyal and CMCC fails to teach the first device wherein the at least one memory and the computer program codes are configured to, with the at least one processor, further cause the first device to:prior to determining the target identifier, receive, from the second device, an indication of a first identifier associated with an inactive state of the first device to be used. However, 3GPP teaches the first device wherein the at least one memory and the computer program codes are configured to, with the at least one processor, further cause the first device to:prior to determining the target identifier, receive, from the second device, an indication of a first identifier associated with an inactive state of the first device to be used (clauses 5.3.13.3, 6.2.2 Actions related to transmission of RRCResumeRequest/RRCResumeRequest1, SystemInformationBlockType1 (SIB1); UE behavior depends on network-provided indication (e.g. whether to use full or short resume identity; indication is received before determining which identifier to transmit). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 12, Phuyal and CMCC fails to teach the first device wherein the indication comprises a field in a system information block (SIB) from the second device, the field indicates the first identifier to be used by the first device in the inactive state. However, 3GPP teaches the first device wherein the indication comprises a field in a system information block (SIB) from the second device, the field indicates the first identifier to be used by the first device in the inactive state (clauses 6.2.2, 5.3.13.3, SIB1, Actions related to transmission of RRCResumeRequest/RRCResumeRequest1; SIB1 includes the field (e.g. useFullResumeID) that instructs the UE which inactive identifier to use). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 13, Phuyal and CMCC fails to teach the first device wherein the target identifier comprises one of a full Inactive Radio Network Temporary Identifier (I-RNTI), a short I-RNTI or an I-RNTI shorter than the short I-RNTI. However 3GPP teaches teach the first device wherein the target identifier comprises one of a full Inactive Radio Network Temporary Identifier (I-RNTI), a short I-RNTI or an I-RNTI shorter than the short I-RNTI (clauses 6.3.2.3, 5.3.13.3, SuspendConfig, Actions related to transmission of RRCResumeRequest/RRCResumeRequest1; supports fullI-RNTI and shortI-RNTI; alternative sizes such as smaller I-RNTI—reduced size conceptually). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 14, Phuyal and CMCC fails to teach the first device wherein the at least one memory and the computer program codes are configured to, with the at least one processor, further cause the first device to determine the target identifier by: receiving, from the second device, a second message comprising information for determining the target identifier. However, 3GPP teaches the first device wherein the at least one memory and the computer program codes are configured to, with the at least one processor, further cause the first device to determine the target identifier by: receiving, from the second device, a second message comprising information for determining the target identifier (clauses 6.3.2, 6.3.2.3, 5.3.13, RRCRelease, SuspendConfig, RRC connection resume; RRCRelease carries SuspendConfig which includes identifier information used later to determine the resume identity). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 15, Phuyal and CMCC fails to teach the first device wherein information for determining the target identifier indicates a first identifier based on which the target identifier is determined. However, 3GPP teaches the first device wherein information for determining the target identifier indicates a first identifier based on which the target identifier is determined (clauses 6.3.2.3 SuspendConfig explcitily includes fullI-RNTI and shortI-RNTI, which serves as the first identifier(s)). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 16, Phuyal and CMCC fails to teach the first device wherein information for determining the target identifier further indicates a rule for determining the target identifier from the first identifier. However, 3GPP teaches the first device wherein information for determining the target identifier further indicates a rule for determining the target identifier from the first identifier (clauses 5.3.13.3, 6.2.2, Actions related to transmission of RRCResumeRequest/RRCResumeRequest1; SystemInformationBlockType1 (SIB1); Rule based selection—if useFullResumeID is signaled[Wingdings font/0xE0]use fullI-RNTI, otherwise use shortI-RNTI). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 17, Phuyal and CMCC fails to teach the first device wherein information for determining the target identifier indicates a configuration of the target identifier. However, 3GPP teaches the first device wherein information for determining the target identifier indicates a configuration of the target identifier (clauses 6.3.2.3 SuspendConfig, SuspendConfig is explicitly defines as the configuration for the RRC_INACTIVE state, including identifier configuration). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 18, Phuyal and CMCC fails to teach the first device wherein the first condition further comprises a third message received from the second device indicating the target identifier other than a full Inactive Radio Network Temporary Identifier (I-RNTI) configured for the SDT, and the third message comprises one of a Radio Resource Control (RRC) message or a system information block (SIB). However, 3GPP teaches the first device wherein the first condition further comprises a third message received from the second device indicating the target identifier other than a full Inactive Radio Network Temporary Identifier (I-RNTI) configured for the SDT, and the third message comprises one of a Radio Resource Control (RRC) message or a system information block (SIB) (clauses 6.2.2, 5.3.13.3, SIB1, Actions related to transmission of RRCResumeRequest/RRCResumeRequest1; SIB1 signaling (e.g. usefuLLResumeID = false) indicates that the UE shall use short I-RNTI instead of full I-RNTI which satisfies “message indicating a target identifier other than a full I_RNTI). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Regarding claim 22, Phuyal teaches a second device comprising: at least one processor ([0056], Fig 6, UE, controller/processor, memory program with instructions); and at least one memory including computer program codes ([0056], Fig 6, UE, controller/processor, memory program with instructions); the at least one memory and the computer program codes are configured to, with the at least one processor ([0056], Fig 6, UE, controller/processor, memory program with instructions), cause the second device at least to: But Phuyal fails to teach receive, from a first device, a first message for Small Data Transmission (SDT) comprising a target identifier associated with an inactive state of the first device, the target identifier determined by the first device in accordance with a first condition related to SDT being met; and identify the first device based on the target identifier. However, CMCC teaches receive, from a first device, a first message for Small Data Transmission (SDT) comprising a target identifier associated with an inactive state of the first device, the target identifier determined by the first device in accordance with a first condition related to SDT being met (Introduction, and Section 2 Discussion pg. 1-4, specifically, the document is explicit about data/small data transmission from RRC_INACTIVE, and it ties the triggering condition (need to transmit small data while inactive), to the use of an inactive-state identifier; explanation that a UE in RRC_INACTIVE has UL data to transmit and that small data transmission from RRC_INACTIVE is the scenario being addressed; this directly corresponds to “a first condition related to SDT is met”; for data transmission from RRC_INACTIVE, the UE uses an RRC Resume-based procedure and explicitly references the use of resumeIdentity/resume-related identifiers as part of the resume request); and It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. A POSITA would have been motivated to apply the hardware mechanism of Phuyal with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. But CMCC fails to teach identify the first device based on the target identifier. However, 3GPP teaches identify the first device based on the target identifier (clause 5.3.13.3 normative NR RRC behavior that specifies exactly what the UE transmits and what it includes when operating from RRC_INACTIVE—when the UE initiates an RRC resume procedure, the UE prepares an RRCResumeRequest/RRCResumeRequest1, and sets resumeIdentity to the stores I-RNTI/fullI-RNTI, which is the identifier associated with the inactive (suspended) state; UE transmits this RRCResumeRequest;). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Claim 40 is rejected under 35 U.S.C. 103 as being unpatentable over 3GPP TSG-WG2 Meeting #111 electronic R2-2007433 (08-2020) (hereinafter "CMCC") in view of 3GPP TS 38.331 v16.4.1 (hererinafter "3GPP") Regarding claim 40, CMCC teaches a method comprising: in accordance with a determination that a first condition related to Small Data Transmission (SDT) is met, determining, at a first device, a target identifier associated with an inactive state of the first device (Introduction, and Section 2 Discussion pg. 1-4, specifically, the document is explicit about data/small data transmission from RRC_INACTIVE, and it ties the triggering condition (need to transmit small data while inactive), to the use of an inactive-state identifier; explanation that a UE in RRC_INACTIVE has UL data to transmit and that small data transmission from RRC_INACTIVE is the scenario being addressed; this directly corresponds to “a first condition related to SDT is met”; for data transmission from RRC_INACTIVE, the UE uses an RRC Resume-based procedure and explicitly references the use of resumeIdentity/resume-related identifiers as part of the resume request); and But CMCC fails to teach transmitting, to the second device, a first message for the SDT comprising the target identifier in the inactive state. However, 3GPP teaches transmitting, to the second device, a first message for the SDT comprising the target identifier in the inactive state (clause 5.3.13.3 normative NR RRC behavior that specifies exactly what the UE transmits and what it includes when operating from RRC_INACTIVE—when the UE initiates an RRC resume procedure, the UE prepares an RRCResumeRequest/RRCResumeRequest1, and sets resumeIdentity to the stores I-RNTI/fullI-RNTI, which is the identifier associated with the inactive (suspended) state; UE transmits this RRCResumeRequest;). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the invention to combine Phuyal with CMCC to achieve the subject matter in question because both references address reducing signaling overhead and latency for UL transmissions by a UE that is not in an active RRC-connected state. Phuyal teaches the hardware mechanism that when a condition related to small data transmission is met, a UE transmits a first UL message carrying small data together with UE identification information without establishing a full RRC connection, thereby enabling efficient small data transmission. CMCC expressly addresses small data transmission from a UE in the RRC_INACTIVE state, explaining that when a UE has small data to transmit while inactive (when an SDT-related condition is met), the UE employs a resume-based procedure and relies on an identifier associated with the suspended/inactive context, such as a resume identity, to enable context retrieval. 3GPP provides the normative specification for this resume-based operation defining that a UE in RRC_INACTIVE prepares and transmits an RRCResumeRequest message and explicitly sets an includes the resumeIdentity derived from the stored inactive-state identifier (I-RNTI, for fullI-RNTI) in that first UL message. A POSITA would have been motivated to apply the hardware mechanism of Phuyal and 3GPP’s resume-based operations with the SDT scenario described in CMCC because both references seek to enable efficient UL data transmission from an inactive UE with minimal signaling overhead. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Ingale et al (US20200214070A1) discloses method and user equipment for reconnecting RRC connection with radio access network (RAN) node. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL WILLIAM ABBATINE whose telephone number is (571)272-0192. The examiner can normally be reached Monday-Friday 0830-1700 EST. 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, Nishant Divecha can be reached at (571) 270-3125. 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 CA /MICHAEL WILLIAM ABBATINE JR./Examiner, Art Unit 2419 /Nishant Divecha/Supervisory Patent Examiner, Art Unit 2419
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Prosecution Timeline

Dec 26, 2023
Application Filed
Jan 08, 2026
Non-Final Rejection — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
25%
Grant Probability
-8%
With Interview (-33.3%)
3y 1m
Median Time to Grant
Low
PTA Risk
Based on 4 resolved cases by this examiner. Grant probability derived from career allow rate.

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