Prosecution Insights
Last updated: October 01, 2026
Application No. 18/860,065

SYSTEMS, METHODS, AND DEVICES FOR ENHANCED SHORT DATA TRANSMISSION (SDT)

Non-Final OA §103
Filed
Oct 25, 2024
Priority
Apr 25, 2022 — nonprovisional of PCTCN2022089041
Examiner
PARK, JUNG H
Art Unit
Tech Center
Assignee
Apple Inc.
OA Round
1 (Non-Final)
88%
Grant Probability
Favorable
1-2
OA Rounds
10m
Est. Remaining
93%
With Interview

Examiner Intelligence

Grants 88% — above average
88%
Career Allowance Rate
873 granted / 992 resolved
+28.0% vs TC avg
Moderate +5% lift
Without
With
+5.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
42 currently pending
Career history
1031
Total Applications
across all art units

Statute-Specific Performance

§101
6.9%
-33.1% vs TC avg
§103
60.0%
+20.0% vs TC avg
§102
20.8%
-19.2% vs TC avg
§112
7.5%
-32.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 992 resolved cases

Office Action

§103
DETAILED ACTION 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. Claims 1, 3, 5-9, 11, 13-17, and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Shih et al. (US 2023/0209463, “Shih”) in view of Laselva et al. (US 2022/0225257, “Laselva”). Regarding claim 1, Shih discloses a baseband processor, configured to, when executing instructions stored in a memory, perform operations comprising: - entering an inactive mode of operation (See ¶.86, when the UE enters RRC_INACTIVE state); - determining that a user equipment (UE) is configured for small data transmission (SDT) during the inactive mode (See ¶.162, the UE may determine whether to switch to the power saving mode based on a specific criterion; See ¶.86, the UE may start the timer with the timer initial value when the UE performs a small data transmission (SDT) in RRC RRC_INACTIVE state); and - in response to the determination, performing radio resource management (RRM) relaxation based on the SDT configuration (See ¶.115, the UE in the power saving mode may configure grant (CG) for small data transmission, and may perform the radio resource measurement (RRM) relaxation; Examiner’s Note: Laselva discloses the method of “performing RRM relaxation based on the SDT configuration”, i.e. in RRC_INACTIVE state). Shih discloses that “the UE in the power saving mode may configure grant (CG) for small data transmission, and may perform the radio resource measurement (RRM) relaxation (Shih, See ¶.115), but does not explicitly disclose what Laselva discloses “in response to the determination, performing radio resource management (RRM) relaxation based on the SDT configuration” (Laselva, See ¶.26, configuration of the configured grant type 1 resources for SDT in UL for INACTIVE state; See ¶.41, In NR, RRM measurements relaxation of the neighbor cells measurements based on serving cell level may be performed based on thresholds in RRC idle/inactive state).” Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date to apply the method of “performing radio resource management (RRM) relaxation based on the SDT configuration” as taught by Laselva into the system of Shih, so that it provides a way of performing RRM measurements relaxation based on thresholds in RRC inactive state (Laselva, See ¶.41). Regarding claim 3, Shih does not explicitly disclose what Laselva discloses “wherein performing the RRM relaxation comprises refraining from performing RRM relaxation during SDT transmissions (Laselva, See ¶.51, the measurement type used for TA validation may include RSRP. In certain example embodiments, UEs in RRC idle/inactive state may relax intra-/inter-frequency neighbor measurements at the cell center where CG-based SDT is assumed to operate (RSRP threshold to be defined for resource validity check of CG-based SDT). Thus, there may be an increase of UE power from measuring additional neighbor cells, at times when the UE is allowed to otherwise omit RRM measurements of neighbor cells).” Therefore, this claim is rejected with the similar reasons and motivation set forth in the rejection of claim 1. Regarding claim 5, Shih discloses “wherein performing the RRM relaxation comprises refraining from performing RRM relaxation when one or more relaxation conditions are satisfied (See ¶.274, if the UE determines that the signal quality of the UE does not satisfy the low mobility criterion during the RRM measurement relaxation, the UE immediately switches to the normal measurement state, stops using the expansion factor K at the same time, that is, performing RRM measurement according to the measurement period in the normal measurement state, and reports the state that the UE does not satisfy, the measurement relaxation criteria to the base station or does not report the state that the UE does not satisfy the measurement relaxation criteria to the base station; See ¶.278, the UE receiving the measurement relaxation instruction stops performing RRM measurement for up to 24 hours according to the protocol specification that satisfies the stationary criterion).” Regarding claim 6, Shih discloses “wherein the one or more relaxation conditions comprises at least one of: a location of the UE with respect to a cell perimeter; a stationary status of the UE; or a mobility status of the UE (See ¶.54, the relaxation criteria may include a low mobility criterion, a non-cell edge criterion, and a stationary criterion; See ¶.274, if the UE determines that the signal quality of the UE does not satisfy the low mobility criterion during the RRM measurement relaxation).” Regarding claim 7, Shih discloses “wherein performing the RRM relaxation comprises refraining from performing RRM relaxation with 1-hour or more than 1-hour measurement interval (See ¶.92, the measurement suspending duration received by the UE is one hour, the UE may suspend the measurement for one hour).” Regarding claim 8, Shih does not explicitly disclose what Laselva discloses “wherein timing advance (TA) validation for SDT is satisfied when the UE is performing the RRM relaxation in a low mobility mode (Laselva, See ¶.26, for the RRC_INACTIVE state, transmission of UL data on pre-configured PUSCH resources (i.e., reusing the configured grant type 1) when timing advance (TA) is valid may involve general procedure for SDT over configured grant type 1 resources from INACTIVE state; See ¶.31, data volume threshold may be used for the UE to decide whether to perform SDT. In determining data volume, an additional SDT specific reference signal received power (RSRP) threshold may be used to determine whether the UE should perform SDT. The agreements also include a new TA timer for TA maintenance specified for configured grant based small data transfer in RRC_INACTIVE state. Procedures may also be provided for the validity of TA and how to handle expiration of a TA timer which may be configured together with the CG configuration in the RRCRelease message. In other cases, the UE may use CG-based SDT if the user data is smaller than the data volume threshold, if CG resource is configured and valid, and/or when the UE has a valid TA; See ¶.41, RRM measurement relaxation framework may be extended for not-at-cell-edge and low mobility conditions; See ¶.39, a time variant TDOA may indicate mobility, while a time invariant TDOA may indicate low or no mobility; See ¶.42, Certain example embodiments may provide a network controlled method that allows the UE to determine whether its current TA is still valid. According to certain example embodiments, use of TA validation conditions may be based on measurements obtained on a serving cell and one or more neighbor cells based on network control/assistance. For instance, in certain example embodiments, evaluation of TA conditions for more than one serving-neighbor cell pairs may provide robustness against situations in which the measurements related to a single pair of cells are unable to detect whether the UE has moved; See ¶.45, if the set of neighbor cells currently detected is not at least partially overlapping with the reference set, it may be determined that the UE has moved significantly from the UE's previous location and, thus, its current TA cannot be valid). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date to apply the method of “timing advance (TA) validation for SDT being satisfied when the UE is performing the RRM relaxation in a low mobility mode” as taught by Laselva into the system of Shih, so that it provides a way of determining whether the current TA is valid or not (Laselva, See ¶.45). Regarding claim 9, it is a user equipment claim corresponding to the claim 1, except the limitations “radio frequency circuitry, one or more processors, and a memory (See Fig.2)” and is therefore rejected for the similar reasons set forth in the rejection of the claim. Regarding claims 11 and 13-16, they are claims corresponding to claims 3 & 5-8, respectively and are therefore rejected for the similar reasons set forth in the rejection of the claims. Regarding claim 17, it is a method claim corresponding to the claim 1 and is therefore rejected for the similar reasons set forth in the rejection of the claim. Regarding claim 19, it is a claim corresponding to the claim 3 and is therefore rejected for the similar reasons set forth in the rejection of the claim. Claims 2, 10, and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Shih in view of Laselva and further in view of Koskinen et al. (US 2025/0126566, “Koskinen”). Regarding claim 2, Shih and Laselva do not explicitly disclose what Koskinen discloses “wherein performing the RRM relaxation comprises refraining from performing RRM relaxation when the UE is configured for SDT (Koskinen, See ¶.67, there may be radio resource management (RRM) relaxations for neighbouring cells for RedCap devices for RRC_INACTIVE/RRC_IDLE and/or RRC_CONNECTED. Enabling and disabling of RRM relaxation may be under the network's control, and signaled by broadcasting or dedicated signaling; See ¶.71, wherein the network explicitly indicates how RedCap devices should adjust the condition(s) for SDT. Referring to FIG. 2, a network element of a wireless communication network transmits 201, to one or more UEs, an indication for adjusting one or more conditions for SDT, wherein the indication is specific to RedCap devices (i.e., non-RedCap UEs may ignore the indication); See ¶.99, the RSRP threshold may be adjusted by increasing the RSRP threshold, such that the RSRP threshold for the first device type (e.g., RedCap device) is higher than for the second device type (e.g., non-RedCap UEs) for allowing the SDT procedure to be initiated. The rule and/or the value used for adjusting the RSRP threshold may be pre-defined (e.g., statically specified in 3GPP specification), or they may be indicated from the network).” Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date to apply the method of “performing the RRM relaxation comprises refraining from performing RRM relaxation when the UE is configured for SDT” as taught by Koskinen into the system of Shih and Laselva, so that it provides a way of ignoring the adjusting indication for non-RedCaP UEs, i.e. standard and/or legacy UE’s small data transmission (Koskinen, See ¶.71). Regarding claims 10 and 18, they are claims corresponding to claims 2 & 2, respectively and are therefore rejected for the similar reasons set forth in the rejection of the claims. Claims 4, 12, and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Shih in view of Laselva and further in view of Shi (US 2024/0381149, “Shi”). Regarding claim 4, Shih and Laselva do not explicitly disclose what Shi discloses “wherein performing the RRM relaxation comprises refraining from performing RRM relaxation for one or more pre-selected frequency carriers (Shi, See ¶.96, the UE performing measurement only for the measurement identifier that includes the dedicated frequency; See ¶.97, it is assumed that the dedicated measurement frequency is 3 GHZ (gigahertz), the UE may perform measurement only for the measurement identifier including the 3 GHZ frequency band, and not perform measurement for the measurement identifiers including other frequency bands, so as to realize relaxation measurement; See further ¶.74-77, a predefined measurement relaxation parameter may include a measurement suspending duration and/or one or more dedicated measurement frequency band).” Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date to apply the method of “performing the RRM relaxation comprises refraining from performing RRM relaxation for one or more pre-selected frequency carriers” as taught by Shi into the system of Shih and Laselva, so that it provides a way of not perform measurement for the measurement identifiers including other frequency bands, so as to realize relaxation measurement (Shi, See ¶.97). Regarding claims 12 and 20, they are claims corresponding to claims 4 & 4, respectively and are therefore rejected for the similar reasons set forth in the rejection of the claims. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. HE (US 2022/0312243, filed on 02/15/2022, Fig.4, ¶.86, and ¶.87) discloses the method of receiving, from a network entity, a configuration associated with RRM measurement relaxation based at least in part on the UE being stationary (block 410). For example, the UE may receive, from a network entity, a configuration associated with RRM measurement relaxation based at least in part on the UE being stationary, as described above. HE further discloses the method of performing RRM measurements based at least in part on the configuration associated with RRM measurement relaxation (block 420). For example, the UE may perform RRM measurements based at least in part on the configuration associated with RRM measurement relaxation. PNG media_image1.png 170 556 media_image1.png Greyscale Contact Information Any inquiry concerning this communication or earlier communications from the examiner should be directed to Jung H Park whose telephone number is 571-272-8565. The examiner can normally be reached M-F: 7:00 AM-3:00 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, Derrick Ferris can be reached on 571-272-3123. 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. /JUNG H PARK/ Primary Examiner, Art Unit 2411
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Prosecution Timeline

Oct 25, 2024
Application Filed
Sep 02, 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
93%
With Interview (+5.2%)
2y 9m (~10m remaining)
Median Time to Grant
Low
PTA Risk
Based on 992 resolved cases by this examiner. Grant probability derived from career allowance rate.

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