Prosecution Insights
Last updated: April 19, 2026
Application No. 18/616,748

Wireless Device Location

Non-Final OA §103
Filed
Mar 26, 2024
Examiner
CRAVER, CHARLES R
Art Unit
3992
Tech Center
3900
Assignee
Ofinno LLC
OA Round
1 (Non-Final)
60%
Grant Probability
Moderate
1-2
OA Rounds
4y 1m
To Grant
83%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allow Rate
53 granted / 88 resolved
At TC average
Strong +23% interview lift
Without
With
+22.7%
Interview Lift
resolved cases with interview
Typical timeline
4y 1m
Avg Prosecution
22 currently pending
Career history
110
Total Applications
across all art units

Statute-Specific Performance

§101
4.2%
-35.8% vs TC avg
§103
30.8%
-9.2% vs TC avg
§102
11.3%
-28.7% vs TC avg
§112
32.0%
-8.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 88 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 . Specification The following guidelines illustrate the preferred layout for the specification of a utility application. These guidelines are suggested for the applicant’s use. Arrangement of the Specification As provided in 37 CFR 1.77(b), the specification of a utility application should include the following sections in order. Each of the lettered items should appear in upper case, without underlining or bold type, as a section heading. If no text follows the section heading, the phrase “Not Applicable” should follow the section heading: (a) TITLE OF THE INVENTION. (b) CROSS-REFERENCE TO RELATED APPLICATIONS. (c) STATEMENT REGARDING FEDERALLY SPONSORED RESEARCH OR DEVELOPMENT. (d) THE NAMES OF THE PARTIES TO A JOINT RESEARCH AGREEMENT. (e) INCORPORATION-BY-REFERENCE OF MATERIAL SUBMITTED ON A READ-ONLY OPTICAL DISC, AS A TEXT FILE OR AN XML FILE VIA THE PATENT ELECTRONIC SYSTEM. (f) STATEMENT REGARDING PRIOR DISCLOSURES BY THE INVENTOR OR A JOINT INVENTOR. (g) BACKGROUND OF THE INVENTION. (1) Field of the Invention. (2) Description of Related Art including information disclosed under 37 CFR 1.97 and 1.98. (h) BRIEF SUMMARY OF THE INVENTION. (i) BRIEF DESCRIPTION OF THE SEVERAL VIEWS OF THE DRAWING(S). (j) DETAILED DESCRIPTION OF THE INVENTION. (k) CLAIM OR CLAIMS (commencing on a separate sheet). (l) ABSTRACT OF THE DISCLOSURE (commencing on a separate sheet). (m) SEQUENCE LISTING. (See MPEP § 2422.03 and 37 CFR 1.821 - 1.825). A “Sequence Listing” is required on paper if the application discloses a nucleotide or amino acid sequence as defined in 37 CFR 1.821(a) and if the required “Sequence Listing” is not submitted as an electronic document either on read-only optical disc or as a text file via the patent electronic system. 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 1-4, 7-11, and 14-18 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pat. PGPUB 2022/0321674A1 to Sung et al. (“Sung”) in view of U.S. Pat. 9,491,620 B2 to Edge et al. (“Edge”). As to claim 1, Sung discloses: A method comprising: sending, by a wireless device to an overlay network, via a user plane connection of an underlay network, an indication of a location of the wireless device determined based on location […] information […]. Sung discloses a method in a wireless device 100. Sung at ¶42. The wireless device sends to an overlay network 300, via a user plane connection of an underlay network 200, an indication of the location of the wireless device. Sung at FIG 2: PNG media_image1.png 476 746 media_image1.png Greyscale …and FIG 3 and at ¶¶74-82 and 87 “[w]hen the terminal is camping on the access network of the underlay network, the terminal may obtain access to the service of the overlay network. The terminal may establish a PDU session with the underlay network using the 3GPP access and may establish another PDU session through the N3IWF of the overlay network using the non-3GPP access”, “[i]n an embodiment, the AF or NF of the overlay network 300 may input QoS requirements and the location information of the terminal to a service operation for the underlay network 200 to request the QoS related information”, “The AF or NF of the overlay network 300 may obtain the location information of the terminal from the underlay network 200 based on the SLA agreed between the overlay network 300 and the underlay network 200”. Sung fails to disclose that the location information is determined based on location assistance information received by the wireless device from the underlay network. To that end, Edge discloses an analogous invention, namely a wireless device 116 connected via a local network 130 which is connected to a further network 140, similar to the underlay/overlay network system of Sung. Edge at Abstract, FIG 1B and at 7:31-43. In Edge, similarly to Sung, location information is obtained by the further network from the UE, and Edge specifies that the location information is obtained by the UE by way of location assistance information received by the UE from the local (“underlay”) network using the user plane. Id. at 7:54-67 “[i]n the case that SET 116 and SET 122 are accessing serving network 130 which is different to home network 140, better location services may be provided using SUPL by D-SLP 132 and D-SLP 134 than by H-SLP 142. This may arise because D-SLPs 132 and 134 have better knowledge of serving network 130 than does H-SLP 142 (e.g. better knowledge of the locations and transmission characteristics of access points 100) and thus may be better able to (i) provide location assistance data related to acquiring and measuring radio signals from serving network 130, (ii) compute an accurate location using such measurements and/or (iii) provide assistance data to SETs 116 and 122 enabling these SETs to compute such a location by themselves”, as well as at FIG 5C and at 24:9-66. Therefore, it would have been obvious to one of ordinary skill in the art at the time of applicant’s filing to modify Sung in the manner taught by Edge, namely as to utilizing location assistance information in the UE obtained from the underlay network. One of ordinary skill in the art would have understood such to merely be an example of combining prior art elements according to known methods, obtaining predictable results. MPEP § 2143 I. A., citing KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Further as to claim 2: The method of claim 1, wherein the sending via the user plane connection is via a packet data unit session of the underlay network. Sung discloses that the sending via the user plane connection is via a packet data unit session of the underlay network. Sung at ¶80 “the terminal 100 according to an embodiment may establish a PDU session with the underlay network 200 using the 3GPP access (S110)”. Further as to claim 3: The method of claim 1, wherein the sending via the user plane connection is via an internet protocol security (IPsec) connection. Sung further discloses that the sending via the user plane connection is via an internet protocol security (IPsec) connection. Sung at ¶78 “the notification that the overlay network receives from the underlay network may relate to a connectivity status related to IPsec of the overlay network” Further as to claim 4: The method of claim 1, wherein a packet data unit session of the overlay network is between the wireless device a non-3GPP interworking function (N3IWF) of the overlay network. Sung further discloses that a packet data unit session of the overlay network is between the wireless device a non-3GPP interworking function (N3IWF) of the overlay network. Sung at ¶¶75-78 and 81 “The terminal may establish a PDU session with the underlay network using the 3GPP access and may establish another PDU session through the N3IWF of the overlay network using the non-3GPP access”, “The terminal 100 that has activated the non-3GPP access may register information of the terminal 100 to the overlay network 300 through the non-3GPP interworking function (N3IWF) of the overlay network 300 using the non-3GPP access”. Further as to claim 7: The method of claim 1, wherein the location assistance information comprises an identifier of a cell of a base station of the underlay network. Edge further discloses that the location assistance information comprises an identifier of a cell of a base station of the underlay network. Edge at Abstract “the UE may include the Cell ID of a LTE neighbor cell or information regarding a 5G NR serving cell, such as a portion of the 5G NR Cell ID or a reserved value or sequence identifying the 5G NR serving cell”. As to claim 8, Sung discloses: A wireless device comprising: one or more processors; and memory storing instructions that, when executed by the one or more processors, cause the wireless device to: Sung discloses a wireless device 100. Sung at ¶42. The UE contains one or more processors and memory storing instructions. Id. at ¶179. send, to an overlay network, via a user plane connection of an underlay network, an indication of a location of the wireless device determined based on location […] information […] In Sung, the wireless device sends to an overlay network 300, via a user plane connection of an underlay network 200, an indication of the location of the wireless device. Sung at FIG 2: PNG media_image1.png 476 746 media_image1.png Greyscale …and FIG 3 and at ¶¶74-82 and 87 “[w]hen the terminal is camping on the access network of the underlay network, the terminal may obtain access to the service of the overlay network. The terminal may establish a PDU session with the underlay network using the 3GPP access and may establish another PDU session through the N3IWF of the overlay network using the non-3GPP access”, “[i]n an embodiment, the AF or NF of the overlay network 300 may input QoS requirements and the location information of the terminal to a service operation for the underlay network 200 to request the QoS related information”, “The AF or NF of the overlay network 300 may obtain the location information of the terminal from the underlay network 200 based on the SLA agreed between the overlay network 300 and the underlay network 200”. Sung fails to disclose that the location information is determined based on location assistance information received by the wireless device from the underlay network. To that end, Edge discloses an analogous invention, namely a wireless device 116 connected via a local network 130 which is connected to a further network 140, similar to the underlay/overlay network system of Sung. Edge at Abstract, FIG 1B and at 7:31-43. In Edge, similarly to Sung, location information is obtained by the further network from the UE, and Edge specifies that the location information is obtained by the UE by way of location assistance information received by the UE from the local (“underlay”) network using the user plane. Id. at 7:54-67 “[i]n the case that SET 116 and SET 122 are accessing serving network 130 which is different to home network 140, better location services may be provided using SUPL by D-SLP 132 and D-SLP 134 than by H-SLP 142. This may arise because D-SLPs 132 and 134 have better knowledge of serving network 130 than does H-SLP 142 (e.g. better knowledge of the locations and transmission characteristics of access points 100) and thus may be better able to (i) provide location assistance data related to acquiring and measuring radio signals from serving network 130, (ii) compute an accurate location using such measurements and/or (iii) provide assistance data to SETs 116 and 122 enabling these SETs to compute such a location by themselves”, as well as at FIG 5C and at 24:9-66. Therefore, it would have been obvious to one of ordinary skill in the art at the time of applicant’s filing to modify Sung in the manner taught by Edge, namely as to utilizing location assistance information in the UE obtained from the underlay network. One of ordinary skill in the art would have understood such to merely be an example of combining prior art elements according to known methods, obtaining predictable results. MPEP § 2143 I. A., citing KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Further as to claim 9: The wireless device of claim 8, wherein the sending via the user plane connection is via a packet data unit session of the underlay network. Sung discloses that the sending via the user plane connection is via a packet data unit session of the underlay network. Sung at ¶80 “the terminal 100 according to an embodiment may establish a PDU session with the underlay network 200 using the 3GPP access (S110)”. Further as to claim 10: The wireless device of claim 8, wherein the sending via the user plane connection is via an internet protocol security (IPsec) connection. Sung further discloses that the sending via the user plane connection is via an internet protocol security (IPsec) connection. Sung at ¶78 “the notification that the overlay network receives from the underlay network may relate to a connectivity status related to IPsec of the overlay network” Further as to claim 11: The wireless device of claim 8, wherein a packet data unit session of the overlay network is between the wireless device a non-3GPP interworking function (N3IWF) of the overlay network. Sung further discloses that a packet data unit session of the overlay network is between the wireless device a non-3GPP interworking function (N3IWF) of the overlay network. Sung at ¶¶75-78 and 81 “The terminal may establish a PDU session with the underlay network using the 3GPP access and may establish another PDU session through the N3IWF of the overlay network using the non-3GPP access”, “The terminal 100 that has activated the non-3GPP access may register information of the terminal 100 to the overlay network 300 through the non-3GPP interworking function (N3IWF) of the overlay network 300 using the non-3GPP access”. Further as to claim 14: The wireless device of claim 8, wherein the location assistance information comprises an identifier of a cell of a base station of the underlay network. Edge further discloses that the location assistance information comprises an identifier of a cell of a base station of the underlay network. Edge at Abstract “the UE may include the Cell ID of a LTE neighbor cell or information regarding a 5G NR serving cell, such as a portion of the 5G NR Cell ID or a reserved value or sequence identifying the 5G NR serving cell”. As to claim 15, Sung discloses: A non-transitory computer-readable medium comprising instructions that, when executed by one or more processors of a wireless device, cause the wireless device to: Sung discloses a wireless device 100. Sung at ¶42. The UE contains one or more processors and memory storing instructions. Id. at ¶179. send, to an overlay network, via a user plane connection of an underlay network, an indication of a location of the wireless device determined based on location […] information […] In Sung, the wireless device sends to an overlay network 300, via a user plane connection of an underlay network 200, an indication of the location of the wireless device. Sung at FIG 2: PNG media_image1.png 476 746 media_image1.png Greyscale …and FIG 3 and at ¶¶74-82 and 87 “[w]hen the terminal is camping on the access network of the underlay network, the terminal may obtain access to the service of the overlay network. The terminal may establish a PDU session with the underlay network using the 3GPP access and may establish another PDU session through the N3IWF of the overlay network using the non-3GPP access”, “[i]n an embodiment, the AF or NF of the overlay network 300 may input QoS requirements and the location information of the terminal to a service operation for the underlay network 200 to request the QoS related information”, “The AF or NF of the overlay network 300 may obtain the location information of the terminal from the underlay network 200 based on the SLA agreed between the overlay network 300 and the underlay network 200”. Sung fails to disclose that the location information is determined based on location assistance information received by the wireless device from the underlay network. To that end, Edge discloses an analogous invention, namely a wireless device 116 connected via a local network 130 which is connected to a further network 140, similar to the underlay/overlay network system of Sung. Edge at Abstract, FIG 1B and at 7:31-43. In Edge, similarly to Sung, location information is obtained by the further network from the UE, and Edge specifies that the location information is obtained by the UE by way of location assistance information received by the UE from the local (“underlay”) network using the user plane. Id. at 7:54-67 “[i]n the case that SET 116 and SET 122 are accessing serving network 130 which is different to home network 140, better location services may be provided using SUPL by D-SLP 132 and D-SLP 134 than by H-SLP 142. This may arise because D-SLPs 132 and 134 have better knowledge of serving network 130 than does H-SLP 142 (e.g. better knowledge of the locations and transmission characteristics of access points 100) and thus may be better able to (i) provide location assistance data related to acquiring and measuring radio signals from serving network 130, (ii) compute an accurate location using such measurements and/or (iii) provide assistance data to SETs 116 and 122 enabling these SETs to compute such a location by themselves”, as well as at FIG 5C and at 24:9-66. Therefore, it would have been obvious to one of ordinary skill in the art at the time of applicant’s filing to modify Sung in the manner taught by Edge, namely as to utilizing location assistance information in the UE obtained from the underlay network. One of ordinary skill in the art would have understood such to merely be an example of combining prior art elements according to known methods, obtaining predictable results. MPEP § 2143 I. A., citing KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Further as to claim 16: The non-transitory computer-readable medium of claim 15, wherein the sending via the user plane connection is via a packet data unit session of the underlay network. Sung discloses that the sending via the user plane connection is via a packet data unit session of the underlay network. Sung at ¶80 “the terminal 100 according to an embodiment may establish a PDU session with the underlay network 200 using the 3GPP access (S110)”. Further as to claim 17: The non-transitory computer-readable medium of claim 15, wherein the sending via the user plane connection is via an internet protocol security (IPsec) connection. Sung further discloses that the sending via the user plane connection is via an internet protocol security (IPsec) connection. Sung at ¶78 “the notification that the overlay network receives from the underlay network may relate to a connectivity status related to IPsec of the overlay network” Further as to claim 18: The non-transitory computer-readable medium of claim 15, wherein a packet data unit session of the overlay network is between the wireless device a non-3GPP interworking function (N3IWF) of the overlay network. Sung further discloses that a packet data unit session of the overlay network is between the wireless device a non-3GPP interworking function (N3IWF) of the overlay network. Sung at ¶¶75-78 and 81 “The terminal may establish a PDU session with the underlay network using the 3GPP access and may establish another PDU session through the N3IWF of the overlay network using the non-3GPP access”, “The terminal 100 that has activated the non-3GPP access may register information of the terminal 100 to the overlay network 300 through the non-3GPP interworking function (N3IWF) of the overlay network 300 using the non-3GPP access”. Claims 5 and 6 are rejected under 35 U.S.C. 103 as being unpatentable over Sung in view of Edge as applied to claim 1 above and further in view of U.S. Pat. PGPUB 2018/0302877A1 to Bosch et al. (“Bosch”). As to claim 5: The method of claim 1, wherein the location assistance information comprises user location information, ULI. Sung in view of Edge discloses claim 1 from which claim 5 depends, but fails to disclose that the location assistance information comprises ULI. Bosch discloses an analogous invention, namely providing location information in a wireless system, and states that 3GPP systems at the time provided location indicators which identified ULI. Bosch at FIG 1 and at ¶¶19 and 69. Therefore, it would have been obvious to one of ordinary skill in the art at the time of applicant’s filing to modify Sung in view of Edge in the manner taught by Bosch, namely as to utilizing ULI in the location assistance information in the UE obtained from the underlay network. Sung in view of Edge discloses 3GPP systems and Bosch discloses that such systems at the time included ULI. Further, one of ordinary skill in the art would have understood such to merely be an example of combining prior art elements according to known methods, obtaining predictable results. MPEP § 2143 I. A., citing KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Further as to claim 6: The method of claim 5, wherein the ULI comprises at least one or more of: a geographic location field comprising a cell global identification (CGI); a geographic location field comprising a service area identification (SAI); and a geographic location field comprising a routing area identification (RAI). Bosch discloses the ULI may comprise CGI, SAI, or RAI. Bosch at ¶69. Claims 12 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Sung in view of Edge as applied to claim 8 above and further in view of Bosch. As to claim 12: The wireless device of claim 8, wherein the location assistance information comprises user location information, ULI. Sung in view of Edge discloses claim 8 from which claim 12 depends, but fails to disclose that the location assistance information comprises ULI. Bosch discloses an analogous invention, namely providing location information in a wireless system, and states that 3GPP systems at the time provided location indicators which identified ULI. Bosch at FIG 1 and at ¶¶19 and 69. Therefore, it would have been obvious to one of ordinary skill in the art at the time of applicant’s filing to modify Sung in view of Edge in the manner taught by Bosch, namely as to utilizing ULI in the location assistance information in the UE obtained from the underlay network. Sung in view of Edge discloses 3GPP systems and Bosch discloses that such systems at the time included ULI. Further, one of ordinary skill in the art would have understood such to merely be an example of combining prior art elements according to known methods, obtaining predictable results. MPEP § 2143 I. A., citing KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Further as to claim 13: The wireless device of claim 12, wherein the ULI comprises at least one or more of: a geographic location field comprising a cell global identification (CGI); a geographic location field comprising a service area identification (SAI); and a geographic location field comprising a routing area identification (RAI). Bosch discloses the ULI may comprise CGI, SAI, or RAI. Bosch at ¶69. Claims 19 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Sung in view of Edge as applied to claim 15 above and further in view of Bosch. As to claim 19: The non-transitory computer-readable medium of claim 15, wherein the location assistance information comprises user location information, ULI. Sung in view of Edge discloses claim 8 from which claim 12 depends, but fails to disclose that the location assistance information comprises ULI. Bosch discloses an analogous invention, namely providing location information in a wireless system, and states that 3GPP systems at the time provided location indicators which identified ULI. Bosch at FIG 1 and at ¶¶19 and 69. Therefore, it would have been obvious to one of ordinary skill in the art at the time of applicant’s filing to modify Sung in view of Edge in the manner taught by Bosch, namely as to utilizing ULI in the location assistance information in the UE obtained from the underlay network. Sung in view of Edge discloses 3GPP systems and Bosch discloses that such systems at the time included ULI. Further, one of ordinary skill in the art would have understood such to merely be an example of combining prior art elements according to known methods, obtaining predictable results. MPEP § 2143 I. A., citing KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Further as to claim 20: The non-transitory computer-readable medium of claim 19, wherein the ULI comprises at least one or more of: a geographic location field comprising a cell global identification (CGI); a geographic location field comprising a service area identification (SAI); and a geographic location field comprising a routing area identification (RAI). Bosch discloses the ULI may comprise CGI, SAI, or RAI. Bosch at ¶69. Conclusion Any inquiry concerning this communication or earlier communications from the Examiner should be directed to Charles Craver whose telephone number is (571) 272- 7849. The Examiner can normally be reached on Monday - Friday 8:30-5:30 PT Pacific Time. If attempts to reach the Examiner by telephone are unsuccessful, the Examiner’s supervisor, Andrew J. Fischer can be reached on 571-272-6779. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272- 1000. Signed, /CHARLES R CRAVER/ Primary Examiner, Art Unit 3992
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Prosecution Timeline

Mar 26, 2024
Application Filed
Feb 26, 2026
Non-Final Rejection — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
60%
Grant Probability
83%
With Interview (+22.7%)
4y 1m
Median Time to Grant
Low
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