Prosecution Insights
Last updated: July 17, 2026
Application No. 18/655,418

Apparatus and Method for Establishing a Direct Communication Connection to a Network Via an Access Point of a Different Network Type

Final Rejection §103
Filed
May 06, 2024
Examiner
IQBAL, KHAWAR
Art Unit
2643
Tech Center
2600 — Communications
Assignee
Lenovo (United States) Inc.
OA Round
2 (Final)
73%
Grant Probability
Favorable
3-4
OA Rounds
1y 3m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
477 granted / 654 resolved
+10.9% vs TC avg
Strong +29% interview lift
Without
With
+29.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
22 currently pending
Career history
679
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
76.2%
+36.2% vs TC avg
§102
21.0%
-19.0% vs TC avg
§112
0.6%
-39.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 654 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 . 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. 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. Claim(s) 1, 3, 5-8, 10, 12-15, 17, 19-26 are rejected under 35 U.S.C. 103 as being unpatentable over TONESI et al (20250318002) in view of Vaidya et al (20250106803). Regarding claim 1, TONESI et al discloses, a user equipment (UE, 120, fig. 2) for wireless communication (abstract, fig. 2-14), comprising: at least one memory (282, fig. 2); and at least one processor (280, fig. 2) coupled with the at least one memory and configured to cause the device to (¶ 0080): independently derive an encryption key for communications via a direct communication connection to a user plane function (UPF, fig. 7-9) of the cellular network (¶ 0134, 0139, 0162-0165, generating the token may include generating the token based at least in part on the ATSSS key, such as by using an HMAC associated with the ATSSS key, the multipath protocol proxy IP address, and PDU session information e.g., a connection ID, an IP address and the ATSSS key may have an ATSSS key ID and an associated lifetime); receive, from the cellular network, a request response message including an address of the UPF (0141, 0146, the SMF 445 may transmit an IP address associated with the UPF 450, which may be used by the UE 120 to establish a connection with the UPF 450 via the 3GPPA UP and/or via the NIN3A); establish the direct communication connection with the UPF using the address and the encryption key (0141-0143, 0166, 0170, 0172, the UE 120 may use the token and the associated connection ID to establish a connection with the UPF 450 e.g., the MPQUIC proxy 820 of the UPF 450 via the NIN3A); and communicate with the UPF via the direct communication connection (0141, 0170, 0177-0178, the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access (e.g., an NIN3A) of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may conserve computing, power, network, and/or communication resources that may have otherwise been consumed traditional ATSSS architectures and/or traditional multi-access session establishment procedures. For example, based at least in part on the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access e.g., an NIN3A of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may communicate using fewer entities and/or less overhead than associated with full-featured ATSSS architectures and/or may communicate with enhanced security as compared to certain ATSSS-lite architectures). TONESI et al does not specifically disclose a registration request message indicating that the UE supports non-integrated non-cellular access. In the same field of endeavor, Vaidya et al discloses, a registration request message indicating that the UE supports non-integrated non-cellular access (¶ 0251, 0256-0257, 0311, a method of operating a Non-3GPP InterWorking Function to support user equipment (UE) communications, the method comprising: performing a QUIC connection setup with a first UE to establish a first QUIC connection between the first UE and the N3IWF; and communicating authentication request and response messages via the first QUIC connection between the first UE and the N3IWF as part of a UE registration procedure.). Therefore, before the effective filing date of the claim invention, it would have been obvious to one of ordinary skill in the art at the time the invention was made to modify the device of TONESI et al by specifically adding feature in order to enhance system performance to independent pre-defined connection ID range to allow routing user plane information to the user plane function and communicating authentication request and response messages via the first QUIC connection between the first UE and the TNGF as part of a UE registration procedure as taught by Vaidya et al. Regarding claims 3, 10, 17, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the direct communication connection includes an Internet Protocol (IP) communication connection between the UE and the cellular network, which is protected utilizing an encryption key (¶ 0139, 0154-0155, 0175, the token and/or a related connection ID may be generated by the SMF 445 and/or the UPF 450. For example, in some aspects, the SMF 445 may generate the token and/or the connection ID. More particularly, in some aspects the SMF 445 may generate the token randomly. In some other aspects, the SMF 445 may generate the token using the connection ID and/or an ATSSS key and the SMF 445 may generate the token based at least in part on using a hash-based message authentication code (HMAC) using the ATSSS key and a connection ID associated with the UE 120 and, more particularly, a connection ID associated with the connection between the UE 120 and the UPF 450 over the NIN3A and WIFI/IP access). Regarding claims 5, 12, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the access point of the network of the different type is an untrusted access point (¶ 0036, 0122, 0138, the ATSSS architecture may include an NWu interface between the UE and the N3IWF for establishing secure tunnels between the UE and the N3IWF so that control-plane and user-plane traffic between the UE and the 5G core network is transferred securely over untrusted non-3GPP access). Regarding claims 6, 13, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the access point of the network of the different type is a trusted access point (¶ 0037, 0121, downlink and/or uplink traffic that is served over one or more concurrent accesses e.g., the 3GPP access, a trusted non-3GPP access). Regarding claims 7, 14, 19, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the network is a cellular network (¶ 0130, the 3GPP access provides an N1 interface to enable communication between the UE and an AMF and the 3GPP access) and the access point of the network of the different type is part of a WIFI network (¶ 0129, a non-integrated IP network (e.g., a generic IP access, such as Wi-Fi or another IP access). Regarding claim 8, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, a processor for wireless communication (abstract, fig. 2-14), comprising: at least one controller coupled with at least one memory and configured to cause the processor to (¶ 0080): send, to a cellular network via a non-cellular access point, a registration request message indicating that the processor supports non- integrated non-cellular access; independently derive an encryption key for communications via a direct communication connection to a receive, from the cellular network, a request response message including an address of the UPF (¶ 0134, 0139, 0141, 0162-0165, generating the token may include generating the token based at least in part on the ATSSS key, such as by using an HMAC associated with the ATSSS key, the multipath protocol proxy IP address, and PDU session information e.g., a connection ID, an IP address and the ATSSS key may have an ATSSS key ID and an associated lifetime); establish the direct communication connection with the UPF using the address and the encryption key (0141, 0146, the SMF 445 may transmit an IP address associated with the UPF 450, which may be used by the UE 120 to establish a connection with the UPF 450 via the 3GPPA UP and/or via the NIN3A, 0141-0143, 0166, 0170, 0172, the UE 120 may use the token and the associated connection ID to establish a connection with the UPF 450 e.g., the MPQUIC proxy 820 of the UPF 450 via the NIN3A); and communicate with the UPF via the direct communication connection (0141, 0170, 0177-0178, the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access (e.g., an NIN3A) of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may conserve computing, power, network, and/or communication resources that may have otherwise been consumed traditional ATSSS architectures and/or traditional multi-access session establishment procedures. For example, based at least in part on the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access e.g., an NIN3A of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may communicate using fewer entities and/or less overhead than associated with full-featured ATSSS architectures and/or may communicate with enhanced security as compared to certain ATSSS-lite architectures). TONESI et al does not specifically disclose a registration request message indicating that the UE supports non-integrated non-cellular access. In the same field of endeavor, Vaidya et al discloses, a registration request message indicating that the UE supports non-integrated non-cellular access (¶ 0251, 0256-0257, 0311, a method of operating a Non-3GPP InterWorking Function to support user equipment (UE) communications, the method comprising: performing a QUIC connection setup with a first UE to establish a first QUIC connection between the first UE and the N3IWF; and communicating authentication request and response messages via the first QUIC connection between the first UE and the N3IWF as part of a UE registration procedure.). Therefore, before the effective filing date of the claim invention, it would have been obvious to one of ordinary skill in the art at the time the invention was made to modify the device of TONESI et al by specifically adding feature in order to enhance system performance to independent pre-defined connection ID range to allow routing user plane information to the user plane function and communicating authentication request and response messages via the first QUIC connection between the first UE and the TNGF as part of a UE registration procedure as taught by Vaidya et al. Regarding claim 15, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, method performed by a user equipment (abstract, fig. 2-14), the method comprising: independently deriving an encryption key for communications via a direct communication connection to a user plane function (UPF) of the cellular network; receiving, from the cellular network, a request response message including an address of the UPF (¶ 0134, 0139, 0162-0165, generating the token may include generating the token based at least in part on the ATSSS key, such as by using an HMAC associated with the ATSSS key, the multipath protocol proxy IP address, and PDU session information e.g., a connection ID, an IP address and the ATSSS key may have an ATSSS key ID and an associated lifetime); establishing the direct communication connection with the UPF using the address and the encryption key (0141, 0146, the SMF 445 may transmit an IP address associated with the UPF 450, which may be used by the UE 120 to establish a connection with the UPF 450 via the 3GPPA UP and/or via the NIN3A, 0141-0143, 0166, 0170, 0172, the UE 120 may use the token and the associated connection ID to establish a connection with the UPF 450 e.g., the MPQUIC proxy 820 of the UPF 450 via the NIN3A); and communicating with the UPF via the direct communication connection (0141, 0170, 0177-0178, the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access (e.g., an NIN3A) of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may conserve computing, power, network, and/or communication resources that may have otherwise been consumed traditional ATSSS architectures and/or traditional multi-access session establishment procedures. For example, based at least in part on the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access e.g., an NIN3A of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may communicate using fewer entities and/or less overhead than associated with full-featured ATSSS architectures and/or may communicate with enhanced security as compared to certain ATSSS-lite architectures). TONESI et al does not specifically disclose sending, to a cellular network via anon-cellular access point, a registration request message indicating that the UE supports non-integrated non-cellular access. In the same field of endeavor, Vaidya et al discloses, sending, to a cellular network via anon-cellular access point, a registration request message indicating that the UE supports non-integrated non-cellular access (¶ 0251, 0256-0257, 0311, a method of operating a Non-3GPP InterWorking Function to support user equipment (UE) communications, the method comprising: performing a QUIC connection setup with a first UE to establish a first QUIC connection between the first UE and the N3IWF; and communicating authentication request and response messages via the first QUIC connection between the first UE and the N3IWF as part of a UE registration procedure.). Therefore, before the effective filing date of the claim invention, it would have been obvious to one of ordinary skill in the art at the time the invention was made to modify the device of TONESI et al by specifically adding feature in order to enhance system performance to independent pre-defined connection ID range to allow routing user plane information to the user plane function and communicating authentication request and response messages via the first QUIC connection between the first UE and the TNGF as part of a UE registration procedure as taught by Vaidya et al. Regarding claim 20, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, a network entity (NE) for wireless communication, comprising: at least one memory; and at least one processor coupled with the at least one memory and configured to cause the device to (¶ 0048): independently derive an encryption key for communications via a direct communication connection between the UE and a user plane function (UPF) of a cellular network (¶ 0134, 0139, 0162-0165, generating the token may include generating the token based at least in part on the ATSSS key, such as by using an HMAC associated with the ATSSS key, the multipath protocol proxy IP address, and PDU session information e.g., a connection ID, an IP address and the ATSSS key may have an ATSSS key ID and an associated lifetime); send the encryption key to the UPF (0141, 0146, the SMF 445 may transmit an IP address associated with the UPF 450, which may be used by the UE 120 to establish a connection with the UPF 450 via the 3GPPA UP and/or via the NIN3A, 0141-0143, 0166, 0170, 0172, the UE 120 may use the token and the associated connection ID to establish a connection with the UPF 450 e.g., the MPQUIC proxy 820 of the UPF 450 via the NIN3A); and send a request response message to the UE, including an address of the UPF (0141, 0170, 0177-0178, the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access (e.g., an NIN3A) of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may conserve computing, power, network, and/or communication resources that may have otherwise been consumed traditional ATSSS architectures and/or traditional multi-access session establishment procedures. For example, based at least in part on the UE 120 and the UPF 450 using a token-based connection request to establish a connection via a non-3GPP access e.g., an NIN3A of a multi-access session, the UE 120, the SMF 445, and/or the UPF 450 may communicate using fewer entities and/or less overhead than associated with full-featured ATSSS architectures and/or may communicate with enhanced security as compared to certain ATSSS-lite architectures). TONESI et al does not specifically disclose receive, from a user equipment (UE) via anon-cellular access point a registration request indicating that the UE supports non- integrated non-cellular access. In the same field of endeavor, Vaidya et al discloses, receive, from a user equipment (UE) via anon-cellular access point a registration request indicating that the UE supports non- integrated non-cellular access (¶ 0251, 0256-0257, 0311, a method of operating a Non-3GPP InterWorking Function to support user equipment (UE) communications, the method comprising: performing a QUIC connection setup with a first UE to establish a first QUIC connection between the first UE and the N3IWF; and communicating authentication request and response messages via the first QUIC connection between the first UE and the N3IWF as part of a UE registration procedure.). Therefore, before the effective filing date of the claim invention, it would have been obvious to one of ordinary skill in the art at the time the invention was made to modify the device of TONESI et al by specifically adding feature in order to enhance system performance to independent pre-defined connection ID range to allow routing user plane information to the user plane function and communicating authentication request and response messages via the first QUIC connection between the first UE and the TNGF as part of a UE registration procedure as taught by Vaidya et al. Regarding claims 21, 24, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the encryption key is derived based at least in part on a non-access stratum (NAS) count value associated with an authentication procedure performed via the non-cellular access point (¶ 0126, 0151, session that includes a first connection via a 3GPP access (e.g., the 3GPPA 980 described below in connection with FIG. 9C) and a second connection via a non-3GPP access (e.g., the NIN3A 990 described below in connection with FIG. 9C). More particularly, the UE 120 may transmit, and the AMF 440 may receive, a NAS message that includes a session establishment request). Regarding claims 22, 25, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the direct communication connection comprises a Multipath QUIC (MPQUIC) connection (¶ 0154-0158, 0162, session establishment, the SMF 445 may generate the token sometimes referred to as an NIN3A authorization token, which may be a one-time NIN3A authorization token and the SMF 445 may allocate the token to the UE 120. In some aspects, the SMF 445 may generate the token using an ATSSS key, such as an ATSSS key that is specific to a multipath protocol proxy e.g., an MPQUIC proxy, an MPTCP proxy, and a similar proxy associated with the UPF 450, which may enable stateless filtering e.g., filtering based solely on the content of individual packets, without requiring consideration of the context and/or the state of the communication session at the UPF 450 e.g., by the filter component 825 of the UPF). Regarding claims 23, 26, TONESI et al and Vaidya et al disclose in claim 1 further, TONESI et al discloses, wherein the encryption key is used for mutual authentication and transport layer security (TLS) session setup with the UPF (¶ 0132, 0167, 0172, the connection request transmitted via the non-3GPP access (e.g., the NIN3A 990 and/or the Nx interface) may be a first uplink traffic transmitted by the UE 120 to the UPF 450 via the non-3GPP access. For example, the connection request may be associated with a first IP packet sent to the UPF 450 via the non-3GPP access (e.g., the token and/or the connection ID may be included inside a first IP packet sent to UPF 450 via the non-3GPP access), the connection request may be associated with a TLS HELLO packet (e.g., the token and/or the connection ID may be included inside a TLS HELLO packet), and/or the connection request may be associated with a zero-round-trip-time (0-RTT) packet (e.g., the token and/or the connection ID may be included inside a 0-RTT packet), among other examples). Response to Arguments Applicant’s arguments with respect to claim(s) 1, 3, 5-8, 10, 12-15, 17, 19-20 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. Examiner’s Note: the Examiner has pointed out particular references contained in the prior art of record within the body of this action for the convenience of the Applicant. Although the specified citations are representative of the teachings in the art and are applied to the specific limitations within the individual claim, other passages and figures may apply. "The use of patents as references is not limited to what the patentees describe as their own inventions or to the problems with which they are concerned. They are part of the literature of the art, relevant for all they contain." In re Heck, 699 F.2d 1331, 1332-33,216 USPQ 1038, 1039 (Fed. Cir. 1983) (quoting In re Lemelson, 397 F.2d 1006, 1009, 158 USPQ 275,277 (CCPA 1968)). A reference may be relied upon for all that it would have reasonably suggested to one having ordinary skill the art, including nonpreferred embodiments (see MPEP 2123). Therefore, Applicant, in preparing the response, must fully consider the entire disclosure of the cited references as potentially teaching all or part of the claimed invention, including the context of the cited passages as taught by the prior art disclosed by the Examiner. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to KHAWAR IQBAL whose telephone number is (571)272-7909. The examiner can normally be reached M-F. 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, Jinsong Hu can be reached at 5712723965. 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. /KHAWAR IQBAL/ Primary Examiner, Art Unit 2643
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Prosecution Timeline

May 06, 2024
Application Filed
Apr 02, 2026
Non-Final Rejection mailed — §103
Jun 23, 2026
Response Filed
Jul 07, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
73%
Grant Probability
99%
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