Prosecution Insights
Last updated: April 19, 2026
Application No. 18/756,966

Systems and Methods for Providing a Push-To-Talk Session Using Web Real-Time Communication

Final Rejection §101§103
Filed
Jun 27, 2024
Examiner
TURRIATE GASTULO, JUAN CARLOS
Art Unit
2446
Tech Center
2400 — Computer Networks
Assignee
Zabra Technologies Corporation
OA Round
2 (Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
3y 2m
To Grant
99%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
270 granted / 376 resolved
+13.8% vs TC avg
Strong +36% interview lift
Without
With
+35.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
28 currently pending
Career history
404
Total Applications
across all art units

Statute-Specific Performance

§101
13.8%
-26.2% vs TC avg
§103
55.4%
+15.4% vs TC avg
§102
14.3%
-25.7% vs TC avg
§112
8.4%
-31.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 376 resolved cases

Office Action

§101 §103
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 . DETAILED ACTION This action is in response to application filed 02/19/2026. Claims 1-20 are pending in this application. Response to Arguments Applicant's arguments have been fully considered but they are not persuasive. Applicant assets that the prior art of record fails to disclose “responsive to receiving a response accepting the invite request from at least one additional PTT session participant…providing the at least one additional PTT session participant access to the PTT session, and designating the at least one additional PTT session participant as a receiver of the communications unable to transmit any communication to any PTT session participants” Examiner respectfully disagrees. Patel discloses an MBCP Connect message is used for connecting the calling party to the call when at least one of the called parties accepts and/or would auto-answer the call ([0368]). In other words, Patel discloses the options to accept the call (i.e. accept invite). Furthermore, Narayanaswamy discloses reference is made to PTT sessions, where floor control policies are applied. A barge request (e.g. invite request) is made by a barging user for an online user. In some embodiments, a barging user and an online user are PoC client users. The method may be configured to handle a barge request like a simple call request or call invitation ([0026]-[0027]). Furthermore, Narayanaswamy discloses a stealth barge request is made by a stealth barging user for an online user. In some embodiments, a stealth barging user and an online user are PoC client users. In general, a stealth barge request, to be permitted, must be made by a stealth barging user having appropriate stealth barge privileges. Once a call is joined, a stealth barge user may continue to monitor the call for a desired time period. In some embodiments, a stealth barge time limit may be utilized to limit the duration of a stealth barge ([0031]-[0032]). In other words, Narayanaswamy discloses accepting a call invitation request (e.g. stealth barge request), and once the barging user is joined (e.g. access session), the barging user monitors the call for a time period (i.e. receiving and not transmitting communications). Claim Rejections - 35 USC § 101 The 35 USC § 101 rejection presented on previous office action (11/19/2025) is withdrawn in view of applicant’s response. More specifically, applicant has amended 19-20 to recite non-transitory. 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 of this title, 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claims 1, 3, 5-6, 8-10, 12, 14-15, 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Patel et al. (US 2017/0295475 A1) in view of Narayanaswamy et al. (US 2009/0117887 A1). Regarding claim 1, Patel discloses a method for providing a push-to-talk (PTT) session including half-duplex communications ([0042]: wherein the advanced voice services include a two-way half-duplex voice call within a group of the user devices comprising a PTT call session) using a Web Real-Time Communication (WebRTC) protocol ([0042]: At least one of the user devices communicates with at least one of the servers during the PTT call session using a WebRTC connection, and at least the media streams for the PTT call session are transmitted between the server and the user device using the WebRTC connection), the method comprising: receiving, from a computing device of a PTT session initiator, a session request to initiate the PTT session including the half-duplex communications using the WebRTC protocol ([0216]: a Client 136, 148 in a NULL state, i.e., the start of the logic. A transition out of this state is triggered by a user making a request to originate a PoC/PTT call. A request to originate a PoC/PTT call is normally made by pressing a PoC/PTT button), wherein the session request includes information of one or more additional PTT session participants ([0137]: The PoC Server 112 instructs the Media Server 114 to associate the media ports of various subscribers dynamically into a session when a PoC/PTT call is originated and this session is maintained for the duration of the call. The PoC Server 112 also controls the floor states of the various participants in a PoC/PTT call session by receiving indications from the Media Servers 114 and sending appropriate requests back to the Media Servers 114 to send MBCP messages to the participants in the PoC/PTT call); responsive to receiving the session request, initiating the PTT session including the PTT session initiator as an initial PTT session participant, providing the PTT session initiator control of the PTT session by designating the PTT session initiator as a transmitter of communications of the PTT session able to transmit the communications to all other PTT session participants ([0137]: Media ports are assigned and tracked by the PoC Server 112 at the time of setting up pre-established sessions. The PoC Server 112 instructs the Media Server 114 to associate the media ports of various subscribers dynamically into a session when a PoC/PTT call is originated and this session is maintained for the duration of the call. [0142]: The Media Server 114 is completely controlled by the PoC Server 112. As noted above, even the media ports of the Media Server 114 are allocated by the PoC Server 112 and then communicated to the Media Server 114. Likewise, floor control requests received by the Media Server 114 from Clients 136, 148 are sent to the PoC Server 112, and the PoC Server 112 instructs the Media Server 114 appropriately. Based on these instructions, the Media Server 114 sends floor control messages to the Clients 136, 148 and sends the RTP packets received from the talker to all the listeners), generating an invite request to join the PTT session, and transmitting the invite request to one or more computing devices of the respective one or more additional PTT session participants ([0334]-[0335]: call flow for initiating a 1-to-1 call from a PoC Client 136 to a WebRTC PTT Client 148. When initiating a 1-to-1 call from a PoC Client 136 to a WebRTC PTT Client 148, there is a small change in the call flow. Once the WebRTC PTT Client 148 receives an INVITE request, then the WebRTC PTT Client 148 receives the offer from the STUN/TURN/ICE Server 304, and initiates allocation and create permission requests to the STUN/TURN/ICE Server 304. The descriptions of these messages provided above in the 1-to-1 call between the WebRTC PTT Client 148 and the PoC Client 136 are valid for this scenario as well); and responsive to receiving a response accepting the invite request from at least one additional PTT session participant of the one or more additional PTT session participants via a respective at least one computing device, providing the at least one additional PTT session participant access to the PTT session ([0368]: An MBCP Connect message is used for terminating an incoming PTT call session to an invited party when the invited party has auto-answer enabled. This is also used for connecting the calling party to the call when at least one of the called parties accepts and/or would auto-answer the call). However, Patel does not disclose designating the at least one additional PTT session participant as a receiver of the communications unable to transmit any communications to any PTT session participants. In an analogous art, Narayanaswamy discloses designating the at least one additional PTT session participant as a receiver of the communications unable to transmit any communications to any PTT session participants ([0031-[0032]: stealth barge request is made by a stealth barging user for an online user. In some embodiments, a stealth barging user and an online user are PoC client users. In general, a stealth barge request, to be permitted, must be made by a stealth barging user having appropriate stealth barge privileges. Once a call is joined, a stealth barge user may continue to monitor the call for a desired time period). Therefore, it would have been obvious before the effective filed date of the claimed invention to a person having ordinary skill in the art to modify Patel to comprise “designating the at least one additional PTT session participant as a receiver of the communications unable to transmit any communications to any PTT session participants” taught by Narayanaswamy. One of ordinary skilled in the art would have been motivated because it would have enabled denying the barging user from the joining the number of online users with the barge call (Narayanaswamy, [0007]). Regarding claim 3, Patel-Narayanaswamy discloses the method of claim 1, wherein one or more of a request or a response associated with the PTT session is transmitted using a Websocket protocol (Patel, [0229]: WebRTC PTT Clients 148 require persistent connection for signaling, which are provided by WebSockets. Since modern browsers support both WebRTC and WebSockets, SIP over WebSockets was chosen for signaling. This combination makes realization of WebRTC PTT Clients 148 on these browsers highly viable). Regarding claim 5, Patel-Narayanaswamy discloses the method of claim 1, wherein the communications include audio (Patel, [0228]: WebRTC defines and provides ways to create an audio path through RTP, and leaves the choice of using signaling out of band, free to the implementer to define it). Regarding claim 6, Patel-Narayanaswamy discloses the method of claim 1, further comprising: determining the at least one additional PTT session participant is unavailable to join the PTT session (Narayanaswamy, [0026]: when a barge time limit is exceeded, the floor control granted to a barging user may be revoked); and responsive to determining the at least one additional PTT session participant is unavailable (Narayanaswamy, [0027]: Restrictions may be individually configurable for each user in some embodiments. If the method determines at a step 316 that any of the online users are busy or the barging user is restricted, the method continues to a step 318 to deny the call, whereupon the method ends), one or more of: refraining from transmitting the invite request to the at least one computing device of the respective at least one additional PTT session participant, transmitting the invite request to the at least one computing device of the respective at least one additional PTT session participant responsive to determining the at least one additional PTT session participant becomes available to join the PTT session (Narayanaswamy, [0027]: online users are not busy or the barging user is not restricted, the method joins the barging user to the call at a step 320. In some embodiments, joining a call without barge privileges may include joining an on-going call when an online user is in an on-going call. In some embodiments, joining a call without barge privileges may include creating a new call when an online user is not in an on-going call), providing a notification to the computing device of the PTT session initiator indicating the at least one additional PTT session participant is unavailable, or terminating the PTT session. The same rationale applies as in claim 1. Regarding claim 8, Patel-Narayanaswamy discloses the method of claim 1, wherein the PTT session further includes one or more of: full-duplex video communications or file sharing (Patel, [0227]: WebRTC is a standard drafted by the World Wide Web Consortium (W3C) that supports browser-based applications for real-time communication, such as voice calling, video chat, and peer-to-peer file sharing. Generally, SIP over WebSockets is used as the signaling protocol, although it is not mandated). Regarding claim 9, Patel-Narayanaswamy discloses the method of claim 1, further comprising terminating the PTT session based on one or more of: expiration of a timeout period during which the transmitter does not provide the communications, or all PTT session participants leaving the PTT session (Patel, [0224]: all terminating legs being released from the call when no user makes a request for the within a specified time period, or after all users have ended their respective call legs). Regarding claims 10 and 19; the claims are interpreted and rejected for the same reason as set forth in claim 1. Regarding claim 12; the claim is interpreted and rejected for the same reason as set forth in claim 3. Regarding claim 14; the claim is interpreted and rejected for the same reason as set forth in claim 5. Regarding claim 15; the claim is interpreted and rejected for the same reason as set forth in claim 6. Regarding claim 17; the claim is interpreted and rejected for the same reason as set forth in claim 8. Regarding claim 18; the claim is interpreted and rejected for the same reason as set forth in claim 9. Claims 2, 11, 20 are rejected under 35 U.S.C. 103 as being unpatentable over Patel in view of Narayanaswamy, as applied to claims 1, 10, 19, in further view of Minami et al. (US 2009/0124237 A1). Regarding claim 2, Patel-Narayanaswamy discloses the method of claim 1. Patel discloses further comprising: receiving, from the computing device of a PTT session participant of a plurality of PTT session participants of the PTT session, a control request to provide the PTT session participant associated with the control request control of the PTT session by designating the PTT session participant associated with the control request as the transmitter of communications of the PTT session (Patel, [0137]: Media ports are assigned and tracked by the PoC Server 112 at the time of setting up pre-established sessions. The PoC Server 112 instructs the Media Server 114 to associate the media ports of various subscribers dynamically into a session when a PoC/PTT call is originated and this session is maintained for the duration of the call. [0142]: The Media Server 114 is completely controlled by the PoC Server 112. As noted above, even the media ports of the Media Server 114 are allocated by the PoC Server 112 and then communicated to the Media Server 114. Likewise, floor control requests received by the Media Server 114 from Clients 136, 148 are sent to the PoC Server 112, and the PoC Server 112 instructs the Media Server 114 appropriately. Based on these instructions, the Media Server 114 sends floor control messages to the Clients 136, 148 and sends the RTP packets received from the talker to all the listeners) However, Patel does not disclose designating remaining PTT session participants as receivers of the communications unable to transmit any communications to any PTT session participants. In an analogous art, Narayanaswamy discloses designating remaining PTT session participants as receivers of the communications unable to transmit any communications to any PTT session participants ([0026]-[0027]: when a barge time limit is exceeded, the floor control granted to a barging user may be revoked. A barging user may be restricted by an online user to prevent that barging user from contacting the online user. Restrictions may be individually configurable for each user in some embodiments. If the method determines at a step 316 that any of the online users are busy or the barging user is restricted, the method continues to a step 318 to deny the call). Therefore, it would have been obvious before the effective filed date of the claimed invention to a person having ordinary skill in the art to modify Patel to comprise “designating remaining PTT session participants as receivers of the communications unable to transmit any communications to any PTT session participants” taught by Narayanaswamy. One of ordinary skilled in the art would have been motivated because it would have enabled denying the barging user from the joining the number of online users with the barge call (Narayanaswamy, [0007]). However, Patel-Narayanaswamy does not disclose approving the control request when the PTT session does not include the transmitter of the communications when the control request is received; and denying the control request when the PTT session includes the transmitter of communications when the control request is received. In an analogous art, Minami discloses approving the control request when the PTT session does not include the transmitter of the communications when the control request is received ([0074]: the cellular phone B 10b requests a server 20 to grant the floor (step S21). Then, when the server 20 is informed by the cellular phone B that the PoC talking is started between the cellular phone A 10a and the cellular phone B 10b, such server decides a current status of the floor (step S22). At this time, since the cellular phones A, B that do the PoC talking are in a status "Floor Idle" in which the floor is not granted, the server transmits a signal to grant the floor to the cellular phone B 10b (step S23), and then the server updates a status of the floor to the "Floor Grant". When the cellular phone B 10b succeeded in getting the floor from the server 20, the user B can start the talking and can continue to talk while such user pushes the particular button); and denying the control request when the PTT session includes the transmitter of communications when the control request is received ([0075]: the server 20 also decides a current status of the floor (step S25). When the server 20 is requested by the cellular phone A 10a to grant the floor during a period of time a status of the floor is the "Floor Grant", such server transmits a signal to the cellular phone A 10a to inform that the floor cannot be granted (step S26). Therefore, it would have been obvious before the effective filed date of the claimed invention to a person having ordinary skill in the art to modify Patel-Narayanaswamy to comprise “approving the control request when the PTT session does not include the transmitter of the communications when the control request is received; and denying the control request when the PTT session includes the transmitter of communications when the control request is received” taught by Minami. One of ordinary skilled in the art would have been motivated because it would have enabled the server to manage the right that grants the floor to a particular cellular phone to talk (Minami, [0005]). Regarding claims 11 and 20; the claims are interpreted and rejected for the same reason as set forth in claim 2. Claims 4, 13 are rejected under 35 U.S.C. 103 as being unpatentable over Patel in view of Narayanaswamy, as applied to claims 1, 10, in further view of Macdonald et al. (US 2022/0232048 A1). Regarding claim 4, Patel-Narayanaswamy discloses the method of claim 1. However, Patel-Narayanaswamy does not disclose wherein the WebRTC protocol includes Secure Real-time Transport. In an analogous art, Macdonald discloses wherein the WebRTC protocol includes Secure Real-time Transport ([0040]: The system 200 includes at least one browser-based dispatch console 10 a communicating over Internet 20 with at least one radio device 12 a via at least one RoIP gateway device 11 a. It should be understood that the Internet 20 provides a mechanism for signaling using WebSocket and session initiation protocol (SIP) while real-time communications are provided via WebRTC and Secure Real-Time Transport Protocol or Secure RTP (SRTP). Therefore, it would have been obvious before the effective filed date of the claimed invention to a person having ordinary skill in the art to modify Patel-Narayanaswamy to comprise “wherein the WebRTC protocol includes Secure Real-time Transport” taught by Macdonald. One of ordinary skilled in the art would have been motivated because it would have enabled to provide secure real-time communications over the Internet by utilizing WebRTC secured with Secure Sockets (Macdonald, [0012]). Regarding claim 13; the claim is interpreted and rejected for the same reason as set forth in claim 4. Claims 7 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Patel in view of Narayanaswamy, as applied to claims 1, 10, in further view of Shaffer et al. (US 2007/0104121 A1). Regarding claim 7, Patel-Narayanaswamy discloses the method of claim 1. However, Patel-Narayanaswamy does not disclose further comprising: designating the transmitter of the communications as a receiver of the communications based upon one or more of: expiration of a timeout period during which the transmitter does not provide the communications, receiving a relinquish request from the computing device of the transmitter to relinquish a designation as the transmitter; or receiving the control request to control the PTT session from the computing device of a receiver of the communications of the PTT session. In an analogous art, Shaffer discloses further comprising: designating the transmitter of the communications as a receiver of the communications based upon one or more of: expiration of a timeout period during which the transmitter does not provide the communications, receiving a relinquish request from the computing device of the transmitter to relinquish a designation as the transmitter; or receiving the control request to control the PTT session from the computing device of a receiver of the communications of the PTT session ([0058]: This floor control may be provided to endpoint 80 by IS 50 through a mute function. For example, when endpoint 80 is not muted, it controls the floor such that its communications are transmitted to PTT endpoints 90 of the VTG. IS 100 will prevent users of half duplex endpoints 90 from gaining control of the floor at this time. However, when endpoint 80 is muted, then one of PTT endpoints 90 may be able to control the floor to communicate to the rest of the VTG, including to endpoint 80. The mute function may be activated and deactivated by the user of endpoint 80 through any suitable method, such as through a DTMF button of the endpoint which transmits a DTMF signal in the communication channel through which endpoint 80 communicates with IS 50. In some embodiments, IS 50 may force full duplex endpoint 80 into mute whenever a half-duplex endpoint gains floor control). Therefore, it would have been obvious before the effective filed date of the claimed invention to a person having ordinary skill in the art to modify Patel-Narayanaswamy to comprise “further comprising: designating the transmitter of the communications as a receiver of the communications based upon one or more of: expiration of a timeout period during which the transmitter does not provide the communications, receiving a relinquish request from the computing device of the transmitter to relinquish a designation as the transmitter; or receiving the control request to control the PTT session from the computing device of a receiver of the communications of the PTT session” taught by Shaffer. One of ordinary skilled in the art would have been motivated because it would have enabled for providing a push-to-talk communication session facilitating a push-to-talk communication session among a full duplex endpoint supporting simultaneous two-way communication and a plurality of half duplex endpoints (Shaffer, [0006]). Regarding claim 16; the claim is interpreted and rejected for the same reason as set forth in claim 7. Additional References The prior art made of record and not relied upon is considered pertinent to applicants disclosure. Lee et al., US 2023/0103410 A1: Method for Group Call Floor Control and Electronic Device Therefor. Walker, US 10,959,062 B1: System and Method for Push-to-Talk Over Cellular Integration with Software Defined Radio. Khartabil et al., US 2006/0056440 A1: Managing Conference Communication in a Communication System. Conclusion THIS ACTION IS MADE FINAL. 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 JUAN C TURRIATE GASTULO whose telephone number is (571)272-6707. The examiner can normally be reached Monday - Friday 8 am-4 pm. 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, Brian J Gillis can be reached at 571-272-7952. 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. /J.C.T/Examiner, Art Unit 2446 /BRIAN J. GILLIS/Supervisory Patent Examiner, Art Unit 2446
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Prosecution Timeline

Jun 27, 2024
Application Filed
Nov 15, 2025
Non-Final Rejection — §101, §103
Feb 19, 2026
Response Filed
Mar 19, 2026
Final Rejection — §101, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
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Grant Probability
99%
With Interview (+35.9%)
3y 2m
Median Time to Grant
Moderate
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