Prosecution Insights
Last updated: July 17, 2026
Application No. 18/839,596

MANAGING RESOURCES FOR DATA TRANSMISSION IN AN INACTIVE STATE

Non-Final OA §103
Filed
Aug 19, 2024
Priority
Feb 22, 2022 — provisional 63/312,795 +3 more
Examiner
KIM, WON TAE C
Art Unit
Tech Center
Assignee
Google LLC
OA Round
1 (Non-Final)
88%
Grant Probability
Favorable
1-2
OA Rounds
7m
Est. Remaining
86%
With Interview

Examiner Intelligence

Grants 88% — above average
88%
Career Allowance Rate
253 granted / 286 resolved
+28.5% vs TC avg
Minimal -3% lift
Without
With
+-2.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
24 currently pending
Career history
307
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
78.4%
+38.4% vs TC avg
§102
2.5%
-37.5% vs TC avg
§112
14.3%
-25.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 286 resolved cases

Office Action

§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 . The preliminary amendment filed 8/19/24 has been entered. Claims 1-3, 5-14, and 31-37 are pending. Information Disclosure Statement The IDS statements filed to date have been considered by the examiner. 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, 7, 8-9, 13, 31, and 36-37 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al., US 2023/0120096, (“Kim”), in view of Kim et al., US 2023/0102937, (“Ofinno”), and Tsai et al., US 2023/0122869, (“Tsai”). Independent Claims Regarding claim 1, Kim teaches “A method for resource management, the method implemented in a user equipment (UE) and comprising: receiving, from a radio access network (RAN) and in a first cell, a resource for an uplink transmission to the RAN when a radio connection between the UE and the RAN is suspended (paragraph no. 0330, “Based on receiving the RRC release message comprising the first suspend configuration parameters, the UE may perform the suspending RRC connection based on the first suspend configuration parameters. The UE may transition to an RRC idle state or an RRC inactive state. The UE may receive PUR configuration parameters via previous RRC release message. The previous RRC release message may be the RRC release message. In response to receiving the PUR configuration parameters, the UE in an RRC idle state or an RRC inactive state”); activating a small data transmission (SDT) alignment timer in response to the receiving (paragraph no. 0330, “In response to receiving the PUR configuration parameters, the UE in an RRC idle state or an RRC inactive state may start a time alignment timer for PUR with the value of time alignment timer for PUR and configure the PUR configuration parameters”; the disclosed time alignment timer teaches the claimed “SDT alignment timer”); initiating, in a second cell and while the radio connection is suspended, a procedure to resume the radio connection with the RAN (paragraph no. 0330, “Based on the RRC release message, the UE in an RRC idle state or an RRC inactive state may perform a cell (re)selection procedure. Based on the cell (re)selection procedure, the UE in an RRC idle state or an RRC inactive state may select a cell 2 of a second base station (a target base station)”; see also, paragraph no. 0387, “Based on the detecting, the UE in the RRC inactive or idle state perform cell (re)selection and suspend one or more bearers. Based on the cell (re)selection, the UE in the RRC inactive or idle state may select the second cell (e.g., change a serving cell of the UE from the first cell to the second cell). Based on the selecting, the UE in the RRC inactive or idle state may resume the one or more bearers … the UE in the RRC inactive or idle state may resume the communicating via the second cell”); and in response to the initiating; releasing the resource” (paragraph no. 0387, “Based on the detecting, the UE in the RRC inactive or idle state perform cell (re)selection and suspend one or more bearers”; see also, paragraph no. 0335, “the UE in an RRC inactive state … release all radio resources”; see also, paragraph nos. 0292 and 0304; it appears that at least the suspending of one or more bearers upon cell re-selection teaches the claimed “releasing the resource” – however, see below for an explicit teaching). Ofinno teaches explicitly the limitation “in response to the initiating: releasing the resource” (paragraph no. 0416, “A wireless device may select a second cell. The wireless device may initiate an RRC procedure to establish or resume an RRC connection via the second cell. Based on the initiating, the wireless device may determine to release one or more configurations of at least one preconfigured uplink resource (configured uplink grant) of a first cell”) as recited in claim 1. It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim by incorporating the teachings of Ofinno to enable the network to reuse the released resource for a different uplink transmission. Kim does not teach but Tsai teaches “stopping the SDT alignment timer” (paragraph no. 0289, “The SDT TA timer and/or TA timer may be stopped upon a cell selection or a cell re-selection … The SDT TA timer and/or TA timer may be stopped when the UE changes the serving cell to another cell or when the UE camps on a new (suitable/acceptable) cell. For example, the timer may be stopped when/after the UE establishes/resumes an RRC connection from the RRC_INACTIVE state on a cell different from the cell where the CG configuration was provided”) as recited in claim 1. It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim by incorporating the teachings of Tsai to enable the SDT timer to be stopped upon cell reselection by the UE, as suggested by Tsai in paragraph no. 0289. Regarding independent claim 31, this independent claim is a corresponding apparatus claim of the method claim 1 and recites similar subject matter. As such, the rationale behind the above rejection of claim 1 applies with equal force to this independent claim and as further amplified below to highlight the minor differences between the claims. Regarding claim 31, see Fig. 15 of Kim for the claimed structural elements of the claim. Dependent Claims Regarding claims 7 and 36, Kim teaches “wherein receiving the resource in the first cell includes: receiving a command to release the radio connection, the command indicating the resource” (paragraph no. 0330, “The UE may receive PUR configuration parameters via previous RRC release message. The previous RRC release message may be the RRC release message”). Regarding claim 9, Kim teaches “wherein the initiating of the procedure to resume the radio connection includes: transmitting, in the second cell, a request to resume the radio connection” (paragraph no. 0387). Regarding claim 13, Kim teaches “wherein the initiating of the procedure to resume the radio connection is in response to receiving a paging message” (paragraph no. 0225). Regarding claims 8 and 37, Kim does not teach but Ofinno teaches “wherein the releasing is further in response to determining that the procedure to resume the radio connection is initiated in the second cell and not the first cell” (paragraph no. 0416). It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, and Tsai by incorporating the additional teachings of Ofinno to enable the network to reuse the released resource for a different uplink transmission in the first cell when the UE resumes a RRC connection in a second cell. Claim(s) 2, 32 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim, Ofinno, and Tsai as applied to claims 1, 31 above, and further in view of Lei et al., US 2025/0133561, (“Lei”). Kim does not teach but Lei teaches “wherein the resource includes a configured grant for small data transmission (CG-SDT)” (paragraph no. 0104). It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, and Tsai by incorporating the teachings of Lei to enable small data transmission over configured grant type 1 resources while the UE is in an inactive state, as suggested by Lei in paragraph no. 0104. Claim(s) 3, 33 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim, Ofinno, and Tsai as applied to claims 1, 31 above, and further in view of the 3GPP document, R3-215894, entitled “SoD of CB: # SDT1_CGbased” by LG Electronics, (“LG Electronics”). Kim does not teach but LG Electronics teaches “wherein the resource includes an sdt-MAC- PHY-CG-Config information element” (page 7, Question 3 discloses SDT-MACPHY-Config information element which appears to be the same as the claimed term). It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, and Tsai by incorporating the teachings of LG Electronics to enable the use of a known information element in the small data transmission while the UE is in the inactive state. However, assuming arguendo that LG Electronics’ disclosure of SDT-MACPHY-Config information element is not an equivalent of the claimed “sdt-MAC- PHY-CG-Config information element”, then it would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, and Tsai by incorporating the teachings of LG Electronics as modified to include the sdt-MAC- PHY-CG-Config information element since this is nothing more than the use of new emerging information elements developed by the standard organizations such as 3GPP to support certain technologies such as small data transmission. Examiner’s note: According to a google search of the term “sdt-MAC- PHY-CG-Config information element,” (Google search result: “The SDT-MAC-PHY-CG-Config is a 3GPP Information Element (IE) introduced in Release 17 for 5G New Radio (NR). It provides dedicated MAC and Physical layer configurations that allow IoT and low-power devices to transmit small amounts of data (Small Data Transmission, or SDT) while staying in the highly efficient RRC_INACTIVE state”) it appears that this term is standardized in the 3GPP release 17 for 5G NR specification. The publication of release 17 would appear to be prior to the effective filing date (2/22/22) of this patent application, and therefore, the release 17 would constitute prior art against claims 3 and 33. Claim(s) 5-6, 34-35 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim, Ofinno, Tsai, and Lei as applied to claims 2, 32 above, and further in view of Mao et al., US 2024/0357698, (“Mao”). Regarding claims 5 and 34, Kim does not teach but Mao teaches “wherein the SDT alignment timer is a CG SDT alignment timer” (paragraph no. 0264 discloses a CG-SDT timer). It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, Tsai and Lei by incorporating the teachings of Mao to enable the UE to use a known timer such as the CG-SDT timer to improve the small data transmission by the UE while in the inactive state. Regarding claims 6 and 35, Kim does not teach but Mao teaches “wherein the SDT alignment timer is a CG-SDT-TimeAlignmentTimer timer” (see paragraph no. 0264 which discloses a CG-SDT-TAT timer). It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, and Tsai by incorporating the teachings of Mao to enable the UE to use a known timer such as the CG-SDT TAT timer to improve the small data transmission by the UE while in the inactive state. Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim, Ofinno, and Tsai as applied to claim 1 above, and further in view of Laselva et al., US 12581563, (“Laselva”). Kim does not teach but Laselva teaches “wherein the initiating of the procedure to resume the radio connection is in response to determining that the UE has non-SDT data to transmit to the RAN” (col. 11, lines 5-8). It would have been obvious to one of ordinary skill in the art before the effective filing date of this claimed invention to modify Kim, Ofinno, and Tsai by incorporating the teachings of Laselva to enable the UE to terminate the small data transmission when non-SDT data is available for transmission to the base station. Allowable Subject Matter Claims 10-12 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Regarding claim 10, the prior art of record does not teach or fairly suggest “receiving, subsequently to the transmitting of the request to resume the radio connection, a rejection of the request; and in response to the rejection, restarting the SDT alignment timer.” Regarding claim 11, the prior art of record does not teach or fairly suggest “receiving, subsequently to the transmitting of the request to resume the radio connection, a rejection of the request; and in response to the rejection, resetting a Medium Access Control (MAC) entity.” Regarding claim 12, the prior art of record does not teach or fairly suggest “receiving, subsequently to the transmitting of the request to resume the radio connection, a rejection of the request; and in response to the rejection, (i) resetting a MAC entity and (ii) restarting the SDT alignment timer after resetting the MAC entity.” Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to WON TAE C. KIM whose telephone number is (571)270-1812. The examiner can normally be reached Monday-Friday 8:00 am - 5:00 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, Edan Orgad can be reached at (571)272-7884. 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. /WON TAE C KIM/Primary Examiner, Art Unit 2414
Read full office action

Prosecution Timeline

Aug 19, 2024
Application Filed
Jun 17, 2026
Non-Final Rejection mailed — §103 (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

1-2
Expected OA Rounds
88%
Grant Probability
86%
With Interview (-2.9%)
2y 6m (~7m remaining)
Median Time to Grant
Low
PTA Risk
Based on 286 resolved cases by this examiner. Grant probability derived from career allowance rate.

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