Prosecution Insights
Last updated: August 17, 2026
Application No. 18/671,815

PREVENTING FRAUD DURING SMSF REGISTRATION

Non-Final OA §101
Filed
May 22, 2024
Examiner
MIZRAHI, DIANE D
Art Unit
2647
Tech Center
2600 — Communications
Assignee
T-Mobile USA Inc.
OA Round
1 (Non-Final)
92%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
98%
With Interview

Examiner Intelligence

Grants 92% — above average
92%
Career Allowance Rate
1262 granted / 1368 resolved
+30.3% vs TC avg
Moderate +5% lift
Without
With
+5.3%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 1m
Avg Prosecution
34 currently pending
Career history
1398
Total Applications
across all art units

Statute-Specific Performance

§101
23.0%
-17.0% vs TC avg
§103
12.8%
-27.2% vs TC avg
§102
32.0%
-8.0% vs TC avg
§112
20.9%
-19.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1368 resolved cases

Office Action

§101
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 . Restriction Remarks Claims 1-20 are pending. Claims 1-5 and 12-20 are withdrawn as of June 15, 2026 with traverse. Claims 6-11 are examined. This application contains 1-5 and 12-20 are drawn to an invention nonelected without traverse in the reply filed on June 15, 2026. A complete reply to the final rejection must include cancellation of nonelected claims or other appropriate action (37 CFR 1.144) See MPEP § 821.01. Applicant is reminded that upon the cancellation of claims to a non-elected invention, the inventorship must be amended in compliance with 37 CFR 1.48(b) if one or more of the currently named inventors is no longer an inventor of at least one claim remaining in the application. Any amendment of inventorship must be accompanied by a request under 37 CFR 1.48(b) and by the fee required under 37 CFR 1.17(i). Applicant is reminded that upon the cancellation of claims to a non-elected invention with Applicant’s amendment and response to this Non-final office action. The requirement is still deemed proper and is therefore made FINAL. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 6-11 are rejected under 35 U.S.C. 101 because the claimed invention is directed to an abstract idea without significantly more. Claims 6-11 are directed to abstract idea such as an idea standing alone such as an instantiated concept, pan or scheme, as well as a mental process (thinking) that “can be performed in the human mind, or by a human using a pen and paper”, for example, “receiving a permanent identifier, receiving a second permanent identifier, determining whether the second permanent identifier; allowing the SMF registration, denying the SMSF registration.” This judicial exception is not integrated into a practical application because the generically recited computer elements do not add a meaningful limitation to the abstract idea because they amount to simply implementing the abstract idea on a computer. The claim(s) does/do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the steps of the claimed invention can be done mentally and no additional features in the claims would preclude them from being performed as such. The method claim 6 recites limitations, “ receiving, by a unified data management node (UDM), a first permanent equipment identifier (PEI) during a network registration; receiving, by the UDM, a second PEI from a short message service function (SMSF); determining, by the UDM, whether the second PEI matches the first PEI; in response to determining that the second PEI matches the first PEI, allowing, by the UDM, the SMSF registration; and in response to determining that the second PEI does not match the first PEI, denying, by the UDM, the SMSF registration”. Since the claim is directed to a method, which is one of the statutory categories of the invention (Step 1: YES). The claim is then analyzed to determine whether it is directed to any judicial exception. The claim recites, “receiving a permanent identifier, receiving a second permanent identifier, determining whether the second permanent identifier; allowing the SMF registration, denying the SMSF registration”.... These limitations without showing steps or functions recited in the claim is no more than an abstract idea i.e., mental process of “receiving, receiving, determining allowing, denying”, etc. (Step 2A: Prong One Abstract Idea = YES). The claim is then analyzed if it requires an additional elements or a combination of additional elements in the claim to apply, reply on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the exception – i.e., limitation that are indicative of integration into a practical application; improving the functioning of a computer or to any other technology or technical field. In the current claims, there is no additional elements that would integrate the abstract idea into a practical application (Step 2A: Prong Two Abstract Idea = YES). Next the claim as a whole is analyzed to determine if there are additional limitation recited in the claim such that the claim amount to significantly more than an abstract idea. In the current scenario there are no additional elements that would amount to significantly more than the abstract idea. Therefore, the claim does not amount to significantly more than the abstract idea itself (Step 2B: NO). Accordingly, the claim is not patent eligible and recites an abstract idea. Further, dependent claims 7-11 do not add any positive limitation or step that recite within the scope of the claim and does not carry patentable weight they are also rejected for the same reasons as independent claims. This judicial exception is not integrated into a practical application as recited in Claims 6-11. Allowable Subject Matter Claims 6-11 would be allowable if rewritten and/or amending to remedy the 101 rejections and the objection to the specification presented in this Office Action. The prior art made of record and not relied upon is considered pertinent to applicant’s disclosure [see USPTO Notice of References Cited Form 892]: The following is an examiner's statement of reasons for allowance: Interpreting the claims in light of the specification, Examiner finds the claimed invention is patentably distinct from the prior art of record, which sets forth in the following: The prior art of record does not teach the combination of claimed elements including and under the broadest reasonable interpretation of the claimed limitation consistence with the Applicant's Specification. The prior art cited above fails to teach all of the Applicant’s claimed limitation. In particularly, the claimed invention advantageously provides a finer level of detail that includes “receiving, by a unified data management node (UDM), a first permanent equipment identifier (PEI) during a network registration; receiving, by the UDM, a second PEI from a short message service function (SMSF); determining, by the UDM, whether the second PEI matches the first PEI; in response to determining that the second PEI matches the first PEI, allowing, by the UDM, the SMSF registration; and in response to determining that the second PEI does not match the first PEI, denying, by the UDM, the SMSF registration” in combination with the other limitations of the claims, was not disclosed by, would not have been obvious over, nor would have been fairly suggested by the prior art of record in context to the claims and the specification. The closes prior art, MT Rahman discloses dynamically controlling network registrations and replacing a stringent error message with a lenient cause message in responding to a registration request from a user equipment but does not disclose Applicant’s, particular, “receiving, by a unified data management node (UDM), a first permanent equipment identifier (PEI) during a network registration; receiving, by the UDM, a second PEI from a short message service function (SMSF); determining, by the UDM, whether the second PEI matches the first PEI; in response to determining that the second PEI matches the first PEI, allowing, by the UDM, the SMSF registration; and in response to determining that the second PEI does not match the first PEI, denying, by the UDM, the SMSF registration. Pertinent Prior Art The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. M. T. Rahman (US Patent No. 10911500 B1), “Registration control for wireless networks, such as IMS networks” (February 2, 2021) discloses dynamically controlling network registrations and replacing a stringent error message with a lenient cause message in responding to a registration request from a user equipment . Communication Any inquiry concerning this communication or earlier communications from the examiner should be directed to DIANE D MIZRAHI whose telephone number is 571- 272-4079. The examiner can normally be reached on 7:30-3:30 PM (7:30 - 4:30 p.m.). If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Alison T. Slater can be reached on (571) 270-0375. The fax phone numbers for the organization where this application or proceeding is assigned are (703) 872-9306 for regular communications and for After Final communication. Any inquiry of a general nature or relating to the status of this application or proceeding should be directed to the receptionist whose telephone number is (571) 272-2600. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.qov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll free). /DIANE D MIZRAHI/Primary Examiner, Art Unit 2647 Diane.Mizrahi@USPTO.gov
Read full office action

Prosecution Timeline

May 22, 2024
Application Filed
Jul 22, 2026
Applicant Interview (Telephonic)
Jul 22, 2026
Examiner Interview Summary
Jul 29, 2026
Non-Final Rejection mailed — §101 (current)

Precedent Cases

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
92%
Grant Probability
98%
With Interview (+5.3%)
2y 1m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 1368 resolved cases by this examiner. Grant probability derived from career allowance rate.

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