Prosecution Insights
Last updated: August 17, 2026
Application No. 18/693,199

Method for Detecting GNSS Spoofing in a GNSS Receiver of a Localization System

Final Rejection §101§103§112
Filed
May 29, 2024
Priority
Sep 23, 2021 — DE 10 2021 210 599.8 +1 more
Examiner
LE, HAILEY R
Art Unit
3648
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Robert Bosch GmbH
OA Round
2 (Final)
80%
Grant Probability
Favorable
3-4
OA Rounds
6m
Est. Remaining
90%
With Interview

Examiner Intelligence

Grants 80% — above average
80%
Career Allowance Rate
138 granted / 172 resolved
+28.2% vs TC avg
Moderate +10% lift
Without
With
+10.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
30 currently pending
Career history
211
Total Applications
across all art units

Statute-Specific Performance

§101
6.9%
-33.1% vs TC avg
§103
58.7%
+18.7% vs TC avg
§102
15.9%
-24.1% vs TC avg
§112
17.8%
-22.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 172 resolved cases

Office Action

§101 §103 §112
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 . Examiner’s Note For applicant’s benefit, portions of the cited reference(s) have been cited to aid in the review of the rejection(s). While every attempt has been made to be thorough and consistent within the rejection it is noted that the PRIOR ART MUST BE CONSIDERED IN ITS ENTIRETY, including disclosures that teach away from the claims. See MPEP 2141.02 VI. “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 in the art, including non-preferred embodiments. Merck & Co. v.Biocraft Laboratories, 874 F.2d 804, 10 USPQ2d 1843 (Fed. Cir.), cert. denied, 493 U.S. 975 (1989). See also Upsher-Smith Labs. v. Pamlab, LLC, 412 F.3d 1319, 1323, 75 USPQ2d 1213, 1215 (Fed. Cir. 2005) See MPEP 2123. Response to Amendment Applicant’s amendment filed 18 May, 2026 is acknowledged and has been entered. Claim objection(s) regarding claim(s) 5, 9, and 12 have been overcome in view of the amendment. Claim rejection(s) under 35 USC 112(b) regarding claim(s) 2 has been overcome in view of the amendment. Response to Arguments Applicant’s argument filed 18 May, 2026 has been fully considered but is moot in view of a new ground of rejection necessitated by Applicant’s amendment. However, the Examiner noted the following argument: Applicant’s argument: “The claimed invention provides a solution to this technological problem in the technical field of accurately localizing an autonomous vehicle for safe operation. Particularly, as recited in the claims, when first and second ephemeris/almanac data have matching timestamps, they are compared and spoof is detected if the data deviate from one another (par. 0008-0009). Thus, the position can be determined more accurately and the autonomous vehicle can be operated more safely, thereby integrating any recited abstract ideas into a practical application.” Examiner’s response: With respect to Applicant’s argument that the claimed invention provides a solution to a technological problem, the Examiner respectfully disagrees. As recited as a contingent step, and as Applicant alleged (i.e., spoof is detected if the data deviate from one another), the claim does not require the operation of the vehicle if the contingent condition is not met. Evidently, Applicant’s disclosure states that “Checking the match of the time stamps is preferably an additional condition for detecting a spoofing situation. This condition must be satisfied for a spoofing situation to be detected. In design variants of the method, the matching of the time stamps is a prerequisite for the comparison of the ephemeris data or the almanac data in step c) to occur at all.” [0011]. Therefore, under broadest reasonable interpretation, claim 1 merely requires the step of comparing first and second timestamps, which is simply selection and mathematical manipulation of data. The Examiner maintains that claim 1 is rejected under 35 USC 101. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claim(s) 1 and 3-12 is/are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 1 recites “detecting first ephemeris data or first almanac data of a GNSS satellite at a time step, a first timestamp being included in the first ephemeris data or the first almanac data; detecting second ephemeris data or second almanac data of the GNSS satellite at a subsequent time step, a second timestamp being included in the first ephemeris data or the first almanac data” which renders the claim indefinite, because the scope of the claim would not be reasonably ascertainable by one of ordinary skill in the art. As recited, both the first and second timestamps are taken from the first ephemeris data or the first almanac data. Claim 4 recites “wherein in step c)” which renders the claim indefinite, because the scope of the claim would not be reasonably ascertainable by one of ordinary skill in the art. Claim 5 recites “a validity period of the ephemeris or almanac data of the GNSS satellite” which renders the claim indefinite, because the scope of the claim would not be reasonably ascertainable by one of ordinary skill in the art. It is unclear if the first or second or both first and second of the ephemeris and/or almanac data are referred to. Claim(s) 3-12 are additionally rejected by virtue of their dependence on claim 1. 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 1-12 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception without significantly more. The claim(s) are directed to a system and a method and recite(s) judicial exceptions as explained in the Step 2A, Prong 1 analysis below. The judicial exceptions are not integrated into a practical application as explained in the Step 2A, Prong 2 analysis below. The claim(s) do not include additional elements that are sufficient to amount to significantly more than the judicial exception as explained in the Step 2B analysis below. Independent claim 1: Claim 1: A method for operating a vehicle having a localization system including global navigation satellite system ("GNSS") receiver, the method comprising: detecting first ephemeris data or first almanac data of a GNSS satellite at a time step, a first timestamp being included in the first ephemeris data or the first almanac data; detecting second ephemeris data or second almanac data of the GNSS satellite at a subsequent time step, a second timestamp being included in the first ephemeris data or the first almanac data; checking whether the first timestamp matches the second time stamp; in response to the first timestamp matching the second time stamp, (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position. Step Analysis 1: Statutory Category? Yes. Claim 1 recites a series of steps and therefore, is a process. As such, the claim is directed to one of the four categories of patent eligible subject matter, and is eligible for further analysis. 2A - Prong 1: Judicial Exception Recited (i.e., mathematical concepts, certain methods of organizing human activities such as a fundamental economic practice, or mental processes)? Yes. The focus of the claim (i.e., “checking whether the first timestamp matches the second time stamp; in response to the first timestamp matching the second time stamp, (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position”) is on selecting certain information and analyzing it. These observations or evaluations are simply mathematical concepts (e.g., algorithms, spatial relationships, geometry, etc.). When given its broadest reasonable interpretation in light of the disclosure, “checking whether the first timestamp matches the second time stamp; in response to the first timestamp matching the second time stamp, (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position” are simply selection and mathematical manipulation of data. Merely selecting information for collection and analysis does nothing significant to differentiate a process from an abstract idea. The limitation “in response to the first timestamp matching the second time stamp, (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position” contains contingent claim language. If the condition for performing a contingent step is not satisfied, the performance recited by the step need not be carried out in order for the claimed method to be performed. See Ex parte Schulhauser, Appeal 2013-007847 (PTAB April 28, 2016) for an analysis of contingent claim limitations in the context of a method claim. Thus, the claim recites an abstract idea. 2A - Prong 2: Integrated into a Practical Application? No. The claim does not recite any additional elements that would integrate the judicial exception into a practical application. The additional limitation(s) of “detecting first ephemeris data or first almanac data of a GNSS satellite at a time step, a first timestamp being included in the first ephemeris data or the first almanac data; detecting second ephemeris data or second almanac data of the GNSS satellite at a subsequent time step, a second timestamp being included in the first ephemeris data or the first almanac data” are recited at a high level of generality. The additional limitation(s) merely are used to perform the abstract idea, and are merely invoked as tools of performing generic functions. The further limitation(s) are considered insignificant extra-solution activities to the judicial exception. The limitation(s) of “global navigation satellite system ("GNSS") receiver; a GNSS satellite” represent no more than mere instructions to apply the judicial exception on generic devices, and can be viewed as nothing more than an attempt to link the use of the judicial exception to the technological environment. It should be noted that because the courts have made it clear that mere physicality or tangibility of an additional element or elements is not a relevant consideration in the eligibility analysis, the physical nature of these components does not affect this analysis. See MPEP 2106.05(I) for more information on this point, including explanations from judicial decisions including Alice Corp. Pty. Ltd. V. CLS Bank Int’l, 573 U.S. 208, 224-26 (2014). The additional limitation(s) represent no more than mere attempt to recite a field in which the device is intended to be applied. Accordingly, the claim as a whole does not integrate the recited judicial exception into a practical application. 2B: Claim provides an Inventive Concept? No. Step 2 considers whether the claim provides limitations which amount to “significantly more” than the recited judicial exception. The claim as a whole does not provide any meaningful limitations which amount to significantly more than the mathematical concept of claim 1. The additional limitation(s) of “detecting first ephemeris data or first almanac data of a GNSS satellite at a time step, a first timestamp being included in the first ephemeris data or the first almanac data; detecting second ephemeris data or second almanac data of the GNSS satellite at a subsequent time step, a second timestamp being included in the first ephemeris data or the first almanac data” do not impose a meaningful limit on the judicial exception. The limitation(s) are at a high level of generality and are just a nominal or tangential addition to the claim. The limitation(s) are at best the equivalent of merely adding the words “apply it” to the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. Therefore, the claim as a whole does not provide meaningful limitations which amount to significantly more than the mathematical concept of claim 1 and does not state an inventive concept. The limitation(s) are just a nominal or tangential addition to the claim. Looking at the elements as a combination does not add anything more than the elements analyzed individually. Applicant’s disclosure does not provide evidence that the additional element(s) recited in claim 1 (i.e., the claim element(s) in addition to the abstract idea) is sufficient to amount to significantly more than the abstract idea itself. This issue is explained by the Federal Circuit, as follows: It has been clear since Alice that a claimed invention’s use of the ineligible concept to which it is directed cannot supply the inventive concept that renders the invention “significantly more” than that ineligible concept. In Alice, the Supreme Court held that claims directed to a computer-implemented scheme for mitigating settlement risks claimed a patent-ineligible abstract idea. 134 S.Ct. at 2352, 2355—56. Some of the claims at issue covered computer systems configured to mitigate risks through various financial transactions. Id. After determining that those claims were directed to the abstract idea of intermediated settlement, the Court considered whether the recitation of a generic computer added “significantly more” to the claims. Id. at 2357. Critically, the Court did not consider whether it was well-understood, routine, and conventional to execute the claimed intermediated settlement method on a generic computer. Instead, the Court only assessed whether the claim limitations other than the invention’s use of the ineligible concept to which it was directed were well-understood, routine and conventional. Id. at 2359-60. BSG Tech LLC v. Buyseasons, Inc., 899 F.3d 1281, 1290 (2018) (emphases added). Therefore, independent claim 1 is ineligible. Dependent claims 3-12: Step Analysis 1: Statutory Category? Yes. Claims 3-12 recite a series of steps and therefore, fall under a process. As such, the claim(s) are directed to one of the four categories of patent eligible subject matter, and are eligible for further analysis. Claim(s) 4-12 will not be evaluated separately because the claim(s) contain the same or sufficiently similar defects as those noted for claim 3 below. 2A - Prong 1: Judicial Exception Recited? Yes. The claim is directed to the method of claim 1 which recites a mathematical concept (see analysis above). Merely selecting information for collection and analysis does nothing significant to differentiate a process from the abstract idea. 2A - Prong 2: Integrated into a Practical Application? No. The claim is considered an insignificant extra-solution activity to the judicial exception. The additional limitation(s) merely are used to perform the abstract idea. The claimed limitations are recited at a high level of generality, and are merely invoked as tools of performing generic functions. The claim(s) in this case specifies what information it is desirable to gather and analyze; but it does not include any requirement for performing the claimed function(s) by use of anything not entirely conventional and generic. 2B: Claim provides an Inventive Concept? No. The claim fails to impose a meaningful limit on the judicial exception. The limitation therefore remains insignificant extra-solution activity even upon reconsideration, and does not amount to significantly more. The type of information being manipulated does not impose meaningful limitations or render the idea less abstract. Therefore, dependent claim(s) 3-12 are ineligible. 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. Claim(s) 1, 3-4, and 6-11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Chen et al. (US 6,611,756 B1 newly cited “CHEN”), in view of Sickle (Sickle, J. V. (2007, July 24). Lesson 1: The GPS signal, newly cited “SICKLE”). Regarding claim 1, CHEN discloses (Examiner’s note: What CHEN does not disclose is strike-through) a method for operating a vehicle having a localization system including global navigation satellite system ("GNSS") receiver, the method comprising: detecting first ephemeris data or first almanac data of a GNSS satellite at a time step, a first timestamp being included in the first ephemeris data or the first almanac data; detecting second ephemeris data or second almanac data of the GNSS satellite at a subsequent time step, a second timestamp being included in the first ephemeris data or the first almanac data (navigation data includes navigation data bits and parity bits, wherein navigation data bits comprise a satellite identifier, timing information, satellite health indicators and orbital data, such as ephemeris and almanac information [col. 5, lines 61-65]); (subframes two 42-2 and three 42-3 include parity bits and navigation data bits corresponding to ephemeris parameters [col. 6, lines 16-18]); the Issue of Data for Ephemeris (IODE) parameter in subframe three 42-3 of a current frame can be compared to the IODE parameter in subframe three 42-3 of an immediate preceding frame. If the IODE parameter in subframe three 42-3 of the current frame is not equal to the IODE parameter in subframe three 42-3 of the immediate preceding frame, then the current frame is a part of a new data set [col. 8, lines 55-61]). Examiner’s note: The limitation “first ephemeris data or first almanac data” and limitation “second ephemeris data or second almanac data” are in alternative form; therefore, only one alternative from each limitation was given patentable weight. in response to the first timestamp matching the second time stamp, (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position. Examiner’s note: Claim 1 recites a method. Limitation “in response to the first timestamp matching the second time stamp, (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position” contains contingent claim language. See MPEP 2111.04. The broadest reasonable interpretation of a method (or process) claim having contingent limitations requires only those steps that must be performed and does not include steps that are not required to be performed because the condition(s) precedent are not met. In this case, the method claim requires step A (i.e. (i) comparing the first ephemeris data or the first almanac data with the second ephemeris data or the second almanac data, and (ii) detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other; determining a position of the vehicle taking into account the GNSS spoofing; and operating the vehicle depending on the position”) if a first condition (i.e. “in response to the first timestamp matching the second time stamp”) happens. If the condition for performing a contingent step is not satisfied, the performance recited by the step need not be carried out in order for the claimed method to be performed. See Ex parte Schulhauser, Appeal 2013-007847 (PTAB April 28, 2016) for an analysis of contingent claim limitations in the context of a method claim. Similarly, limitation “detecting GNSS spoofing in response to the first ephemeris data or the first almanac data and the second ephemeris or the second almanac data deviating from each other” also contains contingent claim language. CHEN discloses that the Issue of Data for Ephemeris (IODE) parameter in subframe three 42-3 of a current frame can be compared to the IODE parameter in subframe three 42-3 of an immediate preceding frame. If the IODE parameter in subframe three 42-3 of the current frame is not equal to the IODE parameter in subframe three 42-3 of the immediate preceding frame, then the current frame is a part of a new data set [col. 8, lines 55-61]. However, CHEN does not explicitly disclose the first timestamp and the second timestamp. In a same or similar field of endeavor, SICKLE teaches that one of the most important parts of this portion of the NAV message is called IODE. IODE is an acronym that stands for Issue of Data Ephemeris, sort of a time stamp on the ephemeris that the receiver gets from the navigation message, and it appears in both subframes 2 and 3 [Ephemerides, pg. 15]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of CHEN to include the teachings of SICKLE, because it is simply combining prior art elements according to known methods to yield predictable result of verifying the navigation data, as recognized by SICKLE. Additionally, doing so would account for ephemeris accuracy deteriorating, as recognized by SICKLE. Regarding claim 3, CHEN/ SICKLE discloses the method according to claim 1, wherein the first ephemeris data are stored in a memory for comparison with the second ephemeris data of the GNSS satellite detected in the subsequent time step (stored previously received navigation data [CHEN col. 9, lines 9-10]). Regarding claim 4, CHEN/ SICKLE discloses the method according to claim 1, wherein in step c) the first ephemeris data or the first almanac data and the second ephemeris data or the second almanac data are compared with each other (the Issue of Data for Ephemeris (IODE) parameter in subframe three 42-3 of a current frame can be compared to the IODE parameter in subframe three 42-3 of an immediate preceding frame. If the IODE parameter in subframe three 42-3 of the current frame is not equal to the IODE parameter in subframe three 42-3 of the immediate preceding frame, then the current frame is a part of a new data set [CHEN col. 8, lines 55-61], cited and incorporated in the rejection of claim 1); (one of the most important parts of this portion of the NAV message is called IODE. IODE is an acronym that stands for Issue of Data Ephemeris, sort of a time stamp on the ephemeris that the receiver gets from the navigation message, and it appears in both subframes 2 and 3 [SICKLE Ephemerides, pg. 15], cited and incorporated in the rejection of claim 1) bit by bit (the specific bits being compared are the eight least significant bits of the ten bits corresponding to the IODC parameter in subframe one 42-1, the eight bits corresponding to the IODE parameter in subframe two 42-2 and/or the eight bits corresponding to the IODE parameter in subframe three 42-3. A change in any one of the aforementioned bits signifies a new data set period [CHEN col. 8, lines 35-41]). Regarding claim 6, CHEN/ SICKLE discloses the method according to claim 1, the determining the position of the vehicle taking into account the GNSS spoofing further comprising: ceasing tracking of the GNSS satellite in response to detecting the GNSS spoofing. Examiner’s note: Claim 6 recites a method. Limitation “ceasing tracking of the GNSS satellite in response to detecting the GNSS spoofing” contains contingent claim language. See MPEP 2111.04. The broadest reasonable interpretation of a method (or process) claim having contingent limitations requires only those steps that must be performed and does not include steps that are not required to be performed because the condition(s) precedent are not met. In this case, the method claim requires step A (i.e. “ceasing tracking of the GNSS satellite”) if a first condition (i.e. “in response to detecting the GNSS spoofing”) happens. If the condition for performing a contingent step is not satisfied, the performance recited by the step need not be carried out in order for the claimed method to be performed. See Ex parte Schulhauser, Appeal 2013-007847 (PTAB April 28, 2016) for an analysis of contingent claim limitations in the context of a method claim. Regarding claim 7, CHEN/ SICKLE discloses the method according to claim 1, the determining the position of the vehicle taking into account the GNSS spoofing further comprising: removing the first ephemeris data or the first almanac data and/or the second ephemeris data or the second almanac data from current localization calculations in response to detecting the GNSS spoofing. Examiner’s note: Claim 7 recites a method. Limitation “removing the first ephemeris data or the first almanac data and/or the second ephemeris data or the second almanac data from current localization calculations in response to detecting the GNSS spoofing” contains contingent claim language. See MPEP 2111.04. The broadest reasonable interpretation of a method (or process) claim having contingent limitations requires only those steps that must be performed and does not include steps that are not required to be performed because the condition(s) precedent are not met. In this case, the method claim requires step A (i.e. “removing the first ephemeris data or the first almanac data and/or the second ephemeris data or the second almanac data from current localization calculations”) if a first condition (i.e. “in response to detecting the GNSS spoofing”) happens. If the condition for performing a contingent step is not satisfied, the performance recited by the step need not be carried out in order for the claimed method to be performed. See Ex parte Schulhauser, Appeal 2013-007847 (PTAB April 28, 2016) for an analysis of contingent claim limitations in the context of a method claim. Regarding claim 8, CHEN/ SICKLE discloses the method according to claim 1, the determining the position of the vehicle taking into account the GNSS spoofing further comprising: restarting localization calculations in response to detecting the GNSS spoofing. Examiner’s note: Claim 8 recites a method. Limitation “restarting localization calculations in response to detecting the GNSS spoofing” contains contingent claim language. See MPEP 2111.04. The broadest reasonable interpretation of a method (or process) claim having contingent limitations requires only those steps that must be performed and does not include steps that are not required to be performed because the condition(s) precedent are not met. In this case, the method claim requires step A (i.e. “restarting localization calculations”) if a first condition (i.e. “in response to detecting the GNSS spoofing”) happens. If the condition for performing a contingent step is not satisfied, the performance recited by the step need not be carried out in order for the claimed method to be performed. See Ex parte Schulhauser, Appeal 2013-007847 (PTAB April 28, 2016) for an analysis of contingent claim limitations in the context of a method claim. Regarding claim 9, CHEN/ SICKLE discloses a control unit for the GNSS receiver (receiving navigation data ND-j transmitted from a plurality of satellites 12-j [CHEN col. 9, lines 16-17]) configured to perform the method according to claim 1 (Examiner’s note: see rejection of claim 1). Regarding claim 10, CHEN/ SICKLE discloses the method according to claim 1, wherein a computer program is configured to perform the method (computer memory [CHEN col. 10, line 54]). Regarding claim 11, CHEN/ SICKLE discloses a non-transitory machine-readable storage medium on which the computer program according to claim 10 is stored (computer memory [CHEN col. 10, line 54], cited and incorporated in the rejection of claim 10). Claim(s) 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over CHEN, in view of SICKLE, and further in view of Syrjarinne et al. (US 2021/0109226 A1 previously cited “SYRJARINNE”). Regarding claim 5, CHEN/ SICKLE discloses the method according to claim 1, In a same or similar field of endeavor, SYRJARINNE teaches that the first time period may define a temporal validity of the first GNSS navigation data, the extension time period may define a temporal validity of the extended first GNSS navigation data, and the second time period may define a temporal validity of the second GNSS navigation data [0021]. It is assumed that the respective GNSS navigation data contain ephemeris data that enable determining an orbital position of the respective GNSS satellite at any given time within a limited time period and clock data that enable determining a deviation of a clock of the respective GNSS satellite from a GNSS system time at any given time within a limited time period [0110]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of CHEN to include the teachings of SYRJARINNE, because doing so would improve detection accuracy, as recognized by SYRJARINNE. Claim(s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over CHEN, in view of SICKLE, and further in view of Garin (US 2007/0247354 A1 previously cited “GARIN”). Regarding claim 12, CHEN/ SICKLE discloses Examiner’s note: see rejection of claim 1). In a same or similar field of endeavor, GARIN teaches a vehicle with a PND (Portable Navigation Device) or GPS receiver mounted [0010]. GARIN teaches a method for improving the accuracy of a receiver position, comprising applying a correction to almanac data [0012]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of CHEN to include the teachings of GARIN, because doing so would apply the method to improve accuracy of GPS positioning system used in vehicle navigation, as recognized by GARIN. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Rao (US 2018/0081066 A1 previously cited) is considered pertinent art for the disclosure overall, and in particular the details of satellite navigation receiver (SNR) extracting ephemeris data from sub-frames of navigation data of each of the navigation signals. The SNR compares the ephemeris data of each navigation signal with the ephemeris data of another navigation signal. The SNR detects cross correlation when the code comparison results in a mismatch and discards the navigation signal with the mismatched ranging code. Gaal (US 2002/0049536 A1 newly cited) is considered pertinent art for the disclosure of an apparatus, method, and system for predicting subframes of GPS signals. 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 HAILEY R LE whose telephone number is (571)272-4910. The examiner can normally be reached 9:00 AM - 5:00 PM 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, VLADIMIR MAGLOIRE can be reached at (571) 270-5144. 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. /Hailey R Le/Examiner, Art Unit 3648 July 12, 2026 /VLADIMIR MAGLOIRE/Supervisory Patent Examiner, Art Unit 3648
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Prosecution Timeline

May 29, 2024
Application Filed
Feb 24, 2026
Non-Final Rejection mailed — §101, §103, §112
May 18, 2026
Response Filed
Jul 15, 2026
Final Rejection mailed — §101, §103, §112 (current)

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

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Prosecution Projections

3-4
Expected OA Rounds
80%
Grant Probability
90%
With Interview (+10.3%)
2y 9m (~6m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 172 resolved cases by this examiner. Grant probability derived from career allowance rate.

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