Prosecution Insights
Last updated: October 27, 2026
Application No. 18/895,752

SIGNALING ASSOCIATED WITH CELLULAR POSITIONING PROTOCOL FOR LIGHT-BASED POSITIONING

Non-Final OA §103
Filed
Sep 25, 2024
Examiner
PAYNE, DAVID C
Art Unit
2635
Tech Center
2600 — Communications
Assignee
Qualcomm Incorporated
OA Round
2 (Non-Final)
52%
Grant Probability
Moderate
2-3
OA Rounds
5m
Est. Remaining
82%
With Interview

Examiner Intelligence

Grants 52% of resolved cases
52%
Career Allowance Rate
13 granted / 25 resolved
-10.0% vs TC avg
Strong +30% interview lift
Without
With
+29.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
2 currently pending
Career history
27
Total Applications
across all art units

Statute-Specific Performance

§101
1.8%
-38.2% vs TC avg
§103
58.2%
+18.2% vs TC avg
§102
29.1%
-10.9% vs TC avg
§112
7.3%
-32.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 25 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 . DETAILED OFFICE ACTION Information Disclosure Statement The information disclosure statement (IDS) submitted on September 25, 2024 and May 09, 2026 in compliance with the provisions of 37 CFR 1.97 has been considered by the examiner and made of record in the application file. Claim Status Claims 1-70 are pending in this application and are under examination in this Office Action. No claims have been allowed. Double Patenting The non-statutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the "right to exclude" granted by a patent and to prevent possible harassment by multiple assignees. A non-statutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); and In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on non-statutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a non-statutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional, the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration, while not provided for in 37 CFR 1.113(c), may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. The instant application and the reference patents identified below have a common applicant/assignee, QUALCOMM Incorporated, and share at least one common inventor. Accordingly, the reference patents are proper non-statutory double patenting references under MPEP § 804. Claims 1-9, 17, 20, 36-44, 52 and 55 are rejected on the ground of non-statutory obviousness-type double patenting as being unpatentable over claims 1-3, 7, 10-13 and 16 of U.S. Patent No. 11,849,371 B2 in view of Jovicic (US20150373503A1). Claims 5-7, 20, 40-42 and 55 are further supported by Huang et al. (US 2024/0243809 A1) and/or U.S. Patent No. 11,044,693 B1, and claims 8-9 and 43-44 are further supported by Yang et al., “A 3D Visible Light Positioning and Orienteering Scheme Using Two LEDs and a Pair of Photo-detectors” (2021). Although the claims at issue are not identical, they are not patentably distinct from each other because of the following: With respect to claim 1, claims 1-3 and 7 of U.S. Patent No. 11,849,371 B2 contain the similar limitations as underlined below: Instant application U.S. Patent No. 11,849,371 B2 As per claim 1, A method performed by a first entity supporting light-based positioning (LBP) of a user equipment (UE), comprising: receiving, from a second entity, a request for location information of the UE, the request for location information defined and transferred using a positioning protocol for at least one of 4G, 5G or 6G cellular communication; obtaining at least one measurement of a light-based signal based on the light-based signal received from a third entity; and sending the location information to the second entity, wherein the location information is based on the at least one measurement, and wherein the location information is sent using the positioning protocol. As per claims 1-3 and 7, a method performed by a user equipment (UE) for supporting location services for the UE, comprising: receiving a request for location information from a location server; receiving an uplink grant from a base station before the UE is ready to send the location information to the location server; and sending the location information to the location server. Claim 2 recites that the uplink grant is received before the UE has completed positioning measurements; claim 3 recites that the location information comprises the positioning measurements; and claim 7 recites that the request for location information is received via Long Term Evolution (LTE) Positioning Protocol (LPP) and the location information is sent via LPP. The principal features of claim 1 of the current application that are not expressly required by claims 1-3 and 7 of U.S. Patent No. 11,849,371 B2 are: “obtaining at least one measurement of a light-based signal based on the light-based signal received from a third entity.” However, in an analogous positioning art, Jovicic teaches a mobile device that “receives a visible light communication (VLC) signal”, determines a position relative to the VLC signal source, and sends the identifier and position to a server [Jovicic, Abstract; [0006]; Figs. 2-3]. Jovicic therefore teaches using a light-source signal as the positioning signal measured/processed by the mobile device and reporting resulting position information to a server. Huang further teaches a plurality of LED light sources used for positioning and teaches that the light-source distances may be obtained using received-signal-strength positioning, expressly explaining that RSS may be understood as “received signal strength indication (RSSI)” [Huang, ¶¶ [0057]-[0058], Figs. 4-7]. Huang also teaches receiving optical signals from multiple LEDs, converting the optical signals through a photodetector/TIA, and calculating UE location from the resulting signal measurements [Huang, ¶¶ [0155]-[0156], Fig. 18]. Accordingly, the secondary references teach the missing light-based positioning feature while U.S. Patent No. 11,849,371 B2 already claims the location-server request, positioning measurements, location-information response, and LPP signaling framework. The combination merely uses a known optical/VLC positioning measurement modality within a claimed cellular positioning-protocol request/response procedure. Each element would continue to perform its established positioning function, and the result obtaining a position measurement from a light-based signal and returning location information using LPP would have been predictable to one of ordinary skill in the art. Based on the above findings, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to employ the VLC/light-based positioning measurements taught by Jovicic and Huang in the LPP location-information procedure claimed in U.S. Patent No. 11,849,371 B2 as no more than the predictable use of prior-art positioning elements according to their established functions. With respect to claim 36, claims 10-13 and 16 of U.S. Patent No. 11,849,371 B2 contain the similar limitations as underlined below: Instant application U.S. Patent No. 11,849,371 B2 As per claim 36, A first entity supporting light-based positioning (LBP) of a UE, comprising one or more memories; one or more transceivers; and one or more processors communicatively coupled to the one or more memories and the one or more transceivers, configured to: receive, via the one or more transceivers, from a second entity, a request for location information of the UE, the request defined and transferred using a positioning protocol for at least one of 4G, 5G or 6G cellular communication; obtain at least one measurement of a light-based signal received from a third entity; and send, via the one or more transceivers, the location information to the second entity, wherein the location information is based on the measurement and is sent using the positioning protocol. As per claims 10-13 and 16, a UE comprises a wireless transceiver, at least one memory, and at least one processor coupled to the wireless transceiver and memory and configured to receive a request for location information from a location server and send the location information to the location server. Claim 11 recites positioning measurements, claim 12 recites that the location information comprises the positioning measurements, claim 13 recites a position estimate based on the measurements, and claim 16 recites that the request for location information is received via LPP and the location information is sent via LPP. The difference is again the expressly light-based nature of the positioning signal and the recitation that the light-based signal is received from a third entity. Jovicic and Huang teach that difference for the reasons discussed above. It would therefore have been obvious to implement the claimed UE/location-server/LPP architecture of claims 10-13 and 16 of U.S. Patent No. 11,849,371 B2 with the known VLC/LED positioning modality taught by Jovicic and Huang, with predictable results. With respect to claims 2-9, 17, 20, 37-44, 52 and 55: Claims 2 and 37 recite alternatives in which the location information comprises the measurement or an absolute/relative location, or the light-based signal is Li-Fi. U.S. Patent No. 11,849,371 B2 claims positioning measurements and position estimates (claims 3, 12 and 13), while Jovicic teaches VLC positioning and reporting position information to a server. Thus, at least one recited alternative is taught. Claims 3, 17, 38 and 52 recite alternatives identifying the first/second/third entities and/or the second entity as a network component, UE, another UE, or location server. U.S. Patent No. 11,849,371 B2 expressly claims a UE, location server, and base station participating in the positioning procedure; a location server and base station are wireless-network components. Thus, the recited entity alternatives are met. Claims 4 and 39 recite visible, infrared/ultraviolet, or X-ray spectrum alternatives. Jovicic expressly teaches visible-light communication; therefore the visible-light alternative is met. Claims 5-6 and 40-41 recite one or more light sensors including a photodiode and/or camera. Huang teaches optical positioning using photodetectors and ambient-light sensors, including conversion of received LED optical signals through a photodetector/TIA before positioning processing [Huang, ¶¶ [0058], [0155], Figs. 5-7 and 18]. Claims 7 and 42 recite, in the alternative, light intensity, RSSI, AoA, AoD, ToA, TDoA, or combinations thereof. Huang expressly teaches RSS/RSSI-based positioning ([0058]), and U.S. Patent No. 11,044,693 B1 claim 5 likewise claims positioning measurements including TOA and RSSI. Thus, at least one claimed measurement alternative is taught. Claims 8-9 and 43-44 recite device-state information including orientation information. Yang expressly teaches a 3D visible-light-positioning system using two LEDs and two photodetectors that provides terminal orientation information [Yang, Abstract; pp. 1-3]. Incorporating known orientation information into the reported VLC positioning information would have predictably improved or supplemented the location solution. Claims 20 and 55 recite that the light-based signal is a reference signal. U.S. Patent No. 11,044,693 B1 claims positioning reference signals (PRSs) used to obtain location measurements (claims 1, 5 and 11, 15), while Jovicic/Huang teach the optical positioning modality. Using a known positioning reference signal as the optical positioning signal would have been a predictable choice of signaling format. Claims 10-14 and 45-49 are rejected on the ground of non-statutory obviousness-type double patenting as being unpatentable over claims 36-37 and 69-70 of U.S. Patent No. 12,726,934 B2 in view of Barbu (WO 2023/033784 A1) and Jovicic, and, for the expressly optical implementation, Huang et al. Although the claims at issue are not identical, they are not patentably distinct from each other because of the following: With respect to claims 10 and 13, claims 36-37 of U.S. Patent No. 12,726,934 B2 contain the similar limitations as underlined below: Instant application U.S. Patent No. 12,726,934 B2 As per claim 10, the method of claim 1 further comprises receiving assistance data (AD) from the second entity, the AD defined and transferred using the positioning protocol; and obtaining the measurement of the light-based signal based at least in part on the AD. As per claim 13, the method further comprises sending light-based capability information associated with the first entity to the second entity, the capability information defined and sent using the positioning protocol, wherein the request for location information is based on the capability information. As per claims 36-37, a second UE receives a Request Capabilities message, sends a Provide Capabilities message, and receives a Provide Assistance Data message including an SL-PRS configuration for the UE, the configuration being based at least in part on capability information; the UE further receives a Request Location Information message, performs one or more SL-PRS measurements according to the configuration, and sends a Provide Location Information message based on the measurements. The features not expressly present in claims 36-37 of the reference patent are that the assistance data and capability information are specifically light-based. However, Barbu teaches capability information indicating an apparatus capability for transmitting and/or receiving positioning reference signals and teaches that reference-signal configuration information is generated/received based on that capability information [Barbu, ¶¶ [0022]-[0024], ¶¶ [0112]-[0114], claims 5-7 and 25-26]. Jovicic and Huang teach replacing the radio/UWB positioning modality with a VLC/LED positioning modality. Accordingly, the combination supplies the expressly light-based implementation without changing the established capability, assistance-data, measurement, and location-reporting functions. The combination would have been predictable because the primary patent already claims capability-driven PRS configuration and measurement, Barbu teaches transmit/receive capability information and capability-based reference-signal configuration, and Jovicic/Huang teaches a known optical positioning signal. A person of ordinary skill would have had reason to apply the known protocol and assistance-data framework to the known VLC positioning modality to support cellular-assisted indoor positioning. With respect to claims 11-12 and 46-47, Barbu teaches that positioning-reference-signal configuration information may include timing information, bandwidth, periodicity and center frequency ([0020]) and that the positioning signal is measured based on the received configuration [Barbu, ¶¶ [0117]]. Because claims 11 and 46 require only at least one listed AD parameter, the disclosure of bandwidth, timing, periodicity, and frequency satisfies the recited alternatives. The location information in the reference claim is based on measurements performed according to the configured positioning signal, thereby satisfying the alternative in claims 12 and 47 that the location information is based at least in part on the AD. With respect to claims 14 and 49, Barbu expressly teaches capability information indicating whether the apparatus is capable of transmitting and/or receiving the positioning reference signal [Barbu, ¶¶ [0022]-[0024]]. In view of Jovicic/Huang’s VLC implementation, these transmit/receive positioning capabilities become the claimed light-transmission/light-reception capabilities. Because claims 14 and 49 are drafted in the alternative, this teaching is sufficient for at least the first capability alternative. Claims 21, 23-32, 56 and 58-67 are rejected on the ground of non-statutory obviousness-type double patenting as being unpatentable over claims 19-26 and 55-70 of U.S. Patent No. 12,726,934 B2 in view of Barbu and Jovicic. Claims 24-26, 59-61 are further supported by Huang et al., and claims 27 and 62 are further supported by Yang et al. (2021). Although the claims at issue are not identical, they are not patentably distinct from each other because of the following: With respect to claim 21, claims 19-20 of U.S. Patent No. 12,726,934 B2 contain the similar limitations as underlined below:. Instant application U.S. Patent No. 12,726,934 B2 As per claim 21, A method performed by a second entity supporting LBP of a UE, comprising: transmitting, to a first entity, a request for location information of the UE, the request defined and transferred using a positioning protocol for at least one of 4G, 5G or 6G cellular communication; transmitting, to a third entity, a request to transmit a light-based signal from the third entity to the first entity; and receiving, from the first entity, the location information, wherein the location information is based on at least one measurement of the light-based signal and is received using the positioning protocol. As per claims 19-20, a first UE sends Request Capabilities messages, receives Provide Capabilities messages, obtains SL-PRS configurations, and sends Provide Assistance Data including the SL-PRS configurations to one or more additional UEs; the first UE further sends one or more Request Location Information messages to the additional UE(s) requesting positioning measurement data and receives one or more Provide Location Information messages in which the additional UE(s) provide the positioning measurement data. The features of claim 21 not expressly required by claims 19-20 are the separate request to a third entity to cause transmission of the positioning signal and the expressly light-based nature of that signal. However, Barbu teaches a location server causing transmission of positioning-reference-signal triggering information, where the triggering information “comprises information for triggering a transmission of the UWB RS” and the signal is transmitted based on the received triggering information [Barbu, ¶ [0026], ¶ [0115], claim 28]. This provides the claimed second-entity-to-third-entity request/trigger relationship. Jovicic then teaches the known optical substitution: a mobile device “receives a visible light communication (VLC) signal”, determines its position relative to the VLC source, and reports position information to a server [Jovicic, Abstract; ¶ [0006]; Fig. 3]. Huang likewise teaches LED-based RSS/RSSI positioning [Huang, ¶¶ [0057]-[0058]]. Accordingly, one of ordinary skill would have found it obvious to use the known network-controlled positioning-signal triggering taught by Barbu with the positioning-protocol request/report framework claimed in U.S. Patent No. 12,726,934 B2, and to implement the triggered positioning signal using the known VLC/LED positioning modality of Jovicic/Huang. The combination changes only the known physical positioning-signal modality while retaining the same request-trigger-measure-report functions, yielding predictable results. With respect to claim 56, claims 55-56 and 69-70 of U.S. Patent No. 12,726,934 B2 contain the corresponding apparatus limitations as underlined below: Instant application U.S. Patent No. 12,726,934 B2 As per claim 56, A second entity supporting LBP of a UE comprises one or more memories, one or more transceivers, and one or more processors configured to transmit to a first entity a request for location information; transmit to a third entity a request to transmit a light-based signal from the third entity to the first entity; and receive from the first entity the location information, wherein the location information is based on a measurement of the light-based signal and is received using the positioning protocol. As per claims 55-56, a first UE comprises transceivers, memories, and processors configured to send Request Capabilities messages, receive Provide Capabilities messages, obtain SL-PRS configurations, and send Provide Assistance Data; claim 56 further configures the processors to send Request Location Information messages requesting positioning measurement data and receive Provide Location Information messages containing that data. As per claims 69-70, a second UE likewise comprises transceivers, memories and processors configured to receive positioning-protocol messages, perform SL-PRS measurements, and send Provide Location Information based on the measurements. Barbu and Jovicic/Huang supply the same missing trigger-to-third-entity and light-based-signal limitations discussed for claim 21. Therefore, the apparatus form is likewise an obvious variation of the reference patent claims. With respect to claims 23-32 and 58-67: Claims 23 and 58 recite alternatives concerning measurement/location information, Li-Fi, and entity identities. U.S. Patent No. 12,726,934 B2 claims positioning measurement data and location-information messages, while Jovicic supplies the VLC/Li-Fi-type optical modality; at least one alternative is therefore taught. Claims 24 and 59 recite visible/IR/UV/X-ray alternatives. Jovicic and Huang expressly teach visible-light positioning; thus, the visible-light alternative is met. Claims 25-26 and 60-61 recite light sensors and measurement types. Huang teaches optical positioning using photodetectors/ambient-light sensors and RSS/RSSI-based measurements [Huang, ¶ [0058], ¶ [0155]]. U.S. Patent No. 11,044,693 B1 claim 5 additionally confirms known positioning measurements including TOA and RSSI. Claims 27 and 62 recite device-state information. Yang teaches a VLC positioning receiver that obtains both position and terminal orientation information; the orientation information constitutes device-state information associated with the receiving entity. Claims 28-30 and 63-65 recite positioning-protocol assistance data and measurement based on the AD. U.S. Patent No. 12,726,934 B2 claims Provide Assistance Data including SL-PRS configurations and measurements performed according to the configurations; Barbu additionally teaches configuration parameters including timing, bandwidth, periodicity and center frequency. Claims 31-32 and 66-67 recite capability information and capability types. U.S. Patent No. 12,726,934 B2 claims Request/Provide Capabilities messages used to determine positioning-reference-signal configurations, and Barbu teaches transmit/receive reference-signal capability information with configuration based on the capability. In view of Jovicic/Huang, implementing those known capabilities for optical positioning is a predictable substitution. It is noted that the above non-statutory double-patenting rejections are based on claim-to-claim comparisons with the cited reference patents. The secondary references are relied upon only for the expressly identified differences between the examined claims and the reference patent claims. See MPEP § 804. Response to Arguments Because this Office action introduces new grounds of rejection based on newly cited art that were not necessitated by an amendment of the claims, this action is made NON-FINAL. See MPEP § 706.07(a). Applicant further notes that the prior Office action identified claims 14, 22, 32, 49, 57, and 67 as containing allowable subject matter if rewritten in independent form. That prior indication is withdrawn in view of the newly cited prior art and the new grounds of rejection set forth below. Each of those claims is expressly addressed in this Office action. The new grounds below address the deficiencies identified by Applicant. In particular, Gummadi (U.S. Patent No. 11,849,371 B2) expressly teaches the location-server request for location information and LPP request/response signaling; Barbu (WO 2023/033784 A1) expressly teaches network/location-server control and triggering of a separate positioning-reference-signal transmitter; and Huang supplies the known light-based/VLC positioning modality and optical measurements. The dependent claims are separately addressed with additional references where necessary. Applicant’s arguments are persuasive with respect to anticipation by Huang alone. Accordingly, the prior 35 U.S.C. § 102 rejection based on Huang is withdrawn. The withdrawal of that rejection does not indicate that the pending claims are otherwise patentable. Applicant also traverses the prior anticipation rejection over Huang and argues, among other things, that Huang does not disclose: (1) a request for location information transmitted from the second entity to the first entity; (2) defining and transferring the request/location information using a positioning protocol for 4G, 5G, or 6G cellular communication; or (3) for claims 21, 34, 56, and 69, a request transmitted to a separate third entity that causes the third entity to transmit the light-based positioning signal. Applicant first points out that the prior Office action incorrectly stated that the application was examined under the pre-AIA first-to-invent provisions. Applicant is correct. The present application was filed on September 25, 2024 and is subject to the first-inventor-to-file provisions of the AIA . The status statement in this Office action has been corrected accordingly. Applicant’s September 3, 2026 remarks have been fully considered. Claim Rejections – 35 U.S.C. § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for the 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. As reiterated by the Supreme Court in KSR, and as set forth in MPEP 2141 (R-01.2024), II, the factual inquiries of Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), applied for establishing a background for determining obviousness under 35 U.S.C. §103, are summarized as follows: Determining the scope and content of the prior art; Ascertaining the differences between the prior art and the claims at issue; Resolving the level of ordinary skill in the pertinent art; and Considering objective evidence indicative of obviousness or non-obviousness, if present. The key to supporting a rejection under 35 U.S.C. § 103 is a clear articulation of the reason or reasons why the claimed invention would have been obvious, with an articulated reasoning having a rational underpinning. The analysis below identifies the teachings relied upon for each limitation and states a claim-specific reason for the proposed combination. This application currently names joint inventors. In considering patentability of the claims, the examiner presumes that the subject matter disclosed in the prior art was created by another (i.e., not by the inventive entity) unless proven otherwise. Applicant is advised of the obligation under 37 C.F.R. § 1.56 to point out the inventor and effective filing dates of each claim, and any evidence relevant to an exception under 35 U.S.C. § 102(b), so that the examiner may properly consider the applicability of the cited prior art. The primary cellular-positioning reference, Gummadi et al. (US 11,849,371 B2), teaches an LPP/SUPL location-service transaction in which a UE receives a request for location information from a location server and returns location information. The optical-positioning reference, Huang et al. (US 2024/0243809 A1), teaches high-precision positioning from optical signals transmitted by multiple LEDs, including RSS/RSSI/ALS measurements and Li-Fi/VLC implementations. The integrated non-RAT-positioning reference, Barbu et al. (WO 2023/033784 A1), teaches 5G NR/LPP/NRPP positioning that configures and triggers a separate apparatus to transmit a positioning reference signal, receives measurements at network/UE entities, and uses an LMF/location server to coordinate the positioning procedure. These references are in the same field of positioning and wireless/optical communications and expressly address complementary portions of the claimed signaling architecture. Claims 1-4, 7, 17, 20-24, 26, 34-39, 42, 52, 55-59, 61, and 69-70 are rejected under 35 U.S.C. § 103 as being unpatentable over Gummadi et al. (US 11,849,371 B2) in view of Huang et al., further in view of Barbu et al., and, with respect to the server-apparatus form, further in view of Wachter et al. (US 9,900,860 B2). Claim 1 Gummadi teaches the first-entity cellular positioning-protocol transaction. In particular, the UE is the claimed first entity and the location server is the claimed second entity. Gummadi expressly claims: “receiving a request for location information from a location server” [Gummadi, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 further expressly claims: “wherein the request for location information is received via Long Term Evolution (LTE) Positioning Protocol (LPP) and the location information is sent via LPP” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Thus, the request for location information is both defined and transferred using LPP, a standardized LTE/4G positioning protocol, which satisfies the claimed “at least one of 4G, 5G or 6G” alternative. Gummadi also teaches sending the resulting location information back to the location server using that protocol. Gummadi’371 expressly claims: “sending the location information to the location server using the uplink grant” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 does not expressly require the positioning measurement to be optical. Huang supplies that limitation in the same positioning context. Huang teaches: “a plurality of light sources (for example, an LED 1, an LED 2, and an LED 3 ... ) may be placed around a target device ... horizontal distances ... between the light sources and the target device may be obtained through measurement, and current location information (x, y) of the target device may be obtained by positioning with reference to the horizontal distances ... and location information of the light sources” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Huang further teaches the actual optical measurement and derived UE location: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Huang therefore teaches a third entity in the form of an LED/light source that transmits a light-based signal to the UE, the UE obtaining a measurement of that signal and determining location information from the measurement. Barbu independently confirms that adding a non-cellular positioning signal to a cellular positioning framework was a known architecture. Barbu teaches: “The conventional framework for positioning in 5th Generation, 5G, NR ... involves the transmission of ... Position Reference Signals, PRS, transmitted by gNBs for DL positioning ... Such OFDM-based RSs are received, detected and measured by the gNBs ... or UE ... A Location Management Function, LMF, receives the measurements ... A NR Positioning Protocol A, NRPPa, carries positioning information between the NG-RAN nodes and the LMF” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Gummadi already provides the standardized LPP request-and-report framework, while Huang expressly identifies VLC/Li-Fi as a high-precision indoor positioning technique and obtains UE location from measured optical signals. A skilled artisan seeking improved indoor positioning accuracy in the Gummadi framework would have had a reason to use the known Huang optical positioning measurement as an additional positioning modality. Barbu further demonstrates that integrating a non-RAT positioning signal into a 5G positioning framework and reporting its measurements to an LMF was already known and technically compatible. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 2 For completeness, the inherited first-entity limitations of claim 2 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 2 is addressed below with exact text from the cited art. Gummadi’371 expressly teaches measurement or position-estimate forms of location information: “wherein the location information comprises positioning measurements by the UE; wherein the location information comprises a position estimate generated by the UE” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’906 further explains absolute and relative location alternatives: “A location estimate may ... be defined relative to some other known location or defined in absolute terms” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Huang expressly identifies Li-Fi/VLC as the optical positioning technology: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because the added limitation merely specifies known forms of the location result (measurement, absolute/relative estimate) or expressly identifies the optical technique as Li-Fi. These are expressly disclosed alternatives in the cited positioning references and do not alter the underlying request/measurement/report architecture. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 3 For completeness, the inherited first-entity limitations of claim 3 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 3 is addressed below with exact text from the cited art. Gummadi’371 maps the UE and location-server entities: “receiving a request for location information from a location server” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Barbu expressly teaches that the non-RAT positioning apparatus may be a UE or gNB/RAN node within the 5G architecture: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Thus, the claimed alternatives in which the first/second/third entities are UEs, location servers, or wireless-network components correspond to the ordinary UE/location-server/RAN-node roles already used by the cited positioning systems. Because the claim is written in the disjunctive, disclosure of any one recited entity alternative is sufficient; the cited art in fact supplies several of them. One of ordinary skill in the art would have been motivated to combine the cited teachings because the entity labels merely assign the already-known signaling and measurement functions to ordinary UE, location-server, and RAN-node components. The cited references expressly use those components for the same positioning functions, so selecting one of those known entities for the recited role would have been a routine allocation of function. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 4 For completeness, the inherited first-entity limitations of claim 4 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 4 is addressed below with exact text from the cited art. Huang expressly teaches Li-Fi/VLC optical spectra: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Huang expressly identifies the spectrum categories: “the electromagnetic spectrum may be divided into ... an infrared ray, visible light, an ultraviolet ray, an X-ray ...” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Maricic independently teaches IR/UV light emitters for positioning: “the beacon transmitters may be any suitable light sources configured to emit modulated light (e.g., light fixture based, infrared or IR based, ultraviolet or UV based)” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. The claim is disjunctive. The cited art directly teaches the visible-light, infrared, and ultraviolet alternatives. The rejection does not depend on treating Huang’s mere identification of X-rays as an enabled positioning embodiment; the expressly taught visible/IR/UV alternatives are sufficient to meet the claim as drafted. One of ordinary skill in the art would have been motivated to combine the cited teachings because choosing visible, IR, or UV for an optical positioning signal was a known wavelength-selection design choice dictated by illumination requirements, ambient light, detector responsivity, human visibility, and link budget. Huang and Maricic expressly teach those alternatives in optical positioning/communication systems, so applying one to the core positioning architecture would have been predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 7 For completeness, the inherited first-entity limitations of claim 7 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 7 is addressed below with exact text from the cited art. Huang expressly teaches RSS/RSSI optical positioning: “the horizontal distances ... may be obtained through measurement according to a received signal strength (RSS) positioning principle, ambient light sensor (ALS)-based wireless optical RSS positioning ... It should be understood that the RSS ... may be further understood as a received signal strength indication (RSSI)” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu independently teaches AoA, AoD, TOA, and TDOA positioning measurements: “Such Radio Access Technology, RAT, based positioning techniques may utilise one of the following methods: Uplink Angle of Arrival (UL-AoA), Downlink Angle of Departure (DL-AoD), Variance of Time of Arrival (TOA)-based ranging, Uplink Time Difference of Arrival (UL-TDOA), Downlink Time Difference of Arrival (DL-TDOA), and Multi-cell Round Trip Time (Multi-RTT)” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Accordingly, multiple expressly recited alternatives of the claim are taught. In particular, RSSI satisfies the optical-measurement branch directly, and the 5G/non-RAT positioning art independently confirms that AoA/AoD/TOA/TDOA were known measurement types. One of ordinary skill in the art would have been motivated to combine the cited teachings because selecting among RSSI, time-based, and angle-based measurements is a routine positioning design choice based on available sensors, synchronization, geometry, and desired accuracy. The references expressly identify these known measurement families and use them for the same purpose deriving UE position so no inventive modification is required. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 17 For completeness, the inherited first-entity limitations of claim 17 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 17 is addressed below with exact text from the cited art. Gummadi’371 expressly identifies the second entity as a location server in the LPP positioning transaction: “receiving a request for location information from a location server” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. A location server is a network component of the wireless communications network, satisfying the recited alternative. The claim is disjunctive and does not require every listed alternative to be present simultaneously. One of ordinary skill in the art would have been motivated to combine the cited teachings because assigning the second-entity functions to the network location server is not a modification at all; it is the role already expressly used by Gummadi for requesting and receiving UE location information. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 20 For completeness, the inherited first-entity limitations of claim 20 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 20 is addressed below with exact text from the cited art. Barbu expressly identifies the transmitted/received positioning waveform as a “Reference Signal” (RS/PRS) used for positioning: “The conventional framework for positioning in 5th Generation, 5G, NR ... involves the transmission of ... Position Reference Signals, PRS, transmitted by gNBs for DL positioning ... Such OFDM-based RSs are received, detected and measured by the gNBs ... or UE ... A Location Management Function, LMF, receives the measurements ... A NR Positioning Protocol A, NRPPa, carries positioning information between the NG-RAN nodes and the LMF” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang teaches the optical positioning signal transmitted by LEDs and measured by the UE: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because a reference signal is a known positioning waveform whose properties are known/configured so that the receiver can measure it. Barbu expressly uses PRS/RS for positioning, and Huang uses known LED optical waveforms for the same measurement function. Designating/configuring the known light-based positioning waveform as the positioning reference signal is therefore the predictable application of the established reference-signal concept to the optical modality. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 21 As per claim 21, the second entity is most directly mapped to the location server/LMF. Gummadi’371 expressly teaches transmitting a location-information request to the first entity and receiving the response using LPP. Gummadi’371 expressly claims: “A method performed by a location server for supporting location services for a user equipment (UE), comprising: sending a request to the UE for information related to the location services; sending a message to a base station to instigate an uplink grant for the UE to respond to the request; and receiving a response to the request from the UE sent by the UE using the uplink grant” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 further narrows the request and response to location information: “wherein the request for information related to the location services comprises a request for location information and the response to the request comprises the location information” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 further expressly requires the positioning protocol: “wherein the request for information related to the location services is sent via Long Term Evolution (LTE) Positioning Protocol (LPP) and the response to the request is received via LPP” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 does not expressly teach that this same second entity also requests a separate third entity to transmit a light-based signal to the first entity. Barbu teaches the missing separate-signal-source triggering relationship in an LMF/5G positioning architecture. Barbu teaches: “causing transmission of UWB RS triggering information, wherein the UWB RS triggering information comprises information for triggering a transmission of the UWB RS to the at least one node of the RAN; wherein the UWB RS is transmitted based at least in part on the received UWB RS triggering information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Barbu further teaches selection of one or more separate RAN nodes for positioning-signal configuration/triggering: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang supplies the optical implementation of the triggered positioning signal. Huang teaches: “When the UE accesses the nine LEDs, the nine LEDs independently transmit fixed bit streams ... After receiving a group of optical signals transmitted by the LEDs, the UE calculates location information of the UE by referring to an ALS-based positioning principle” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because the claimed second-entity architecture merely combines Gummadi’s standardized location-server LPP request/report transaction with Barbu’s known LMF-controlled triggering of a separate positioning-signal source and Huang’s known LED/VLC positioning signal. Barbu provides an express technical reason for central coordination of a separate reference-signal transmitter, while Huang provides a known optical signal source that improves indoor/high-precision positioning. Substituting the optical positioning signal for the non-cellular UWB reference signal while retaining the known LMF/LPP control relationship would have been a predictable use of known positioning modalities. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 22 For completeness, the inherited second-entity limitations of claim 22 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 22 is addressed below. Barbu teaches selecting “one or more nodes of the RAN” to receive positioning-signal configuration/triggering information: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang independently teaches a plurality of LED transmitters whose optical signals are jointly received for positioning: “When the UE accesses the nine LEDs, the nine LEDs independently transmit fixed bit streams ... After receiving a group of optical signals transmitted by the LEDs, the UE calculates location information of the UE by referring to an ALS-based positioning principle” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. This directly maps the first disjunctive branch of the claim: sending additional request(s) to additional third entities so that additional positioning signals are available. Because the claim recites the crowdsourced-device branch with “or,” it is unnecessary to rely on that separate branch to establish obviousness; the cited art expressly teaches the additional-third-entity branch. One of ordinary skill in the art would have been motivated to combine the cited teachings because multi-source positioning improves geometry, redundancy, and accuracy. Both Barbu and Huang expressly employ multiple signal sources/nodes. Once the second entity is already controlling one positioning-signal source, extending the same request/trigger to additional known sources is a routine scale-out of the same protocol and yields the predictable benefit of more measurements. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 23 For completeness, the inherited second-entity limitations of claim 23 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 23 is addressed below. Gummadi’371 teaches measurement/position-estimate location information: “wherein the location information comprises positioning measurements by the UE; wherein the location information comprises a position estimate generated by the UE” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Huang teaches Li-Fi/VLC positioning: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu teaches UE/location-server/RAN-node roles in cellular positioning: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because claim 23 merely selects known result forms, a known Li-Fi optical modality, and known UE/location-server/RAN-node roles. These alternatives are expressly present in the cited references and are used for the same positioning functions. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 24 For completeness, the inherited second-entity limitations of claim 24 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 24 is addressed below. Huang expressly teaches Li-Fi/VLC optical spectra: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Huang expressly identifies the spectrum categories: “the electromagnetic spectrum may be divided into ... an infrared ray, visible light, an ultraviolet ray, an X-ray ...” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Maricic independently teaches IR/UV light emitters for positioning: “the beacon transmitters may be any suitable light sources configured to emit modulated light (e.g., light fixture based, infrared or IR based, ultraviolet or UV based)” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. The claim is disjunctive. The cited art directly teaches the visible-light, infrared, and ultraviolet alternatives. The rejection does not depend on treating Huang’s mere identification of X-rays as an enabled positioning embodiment; the expressly taught visible/IR/UV alternatives are sufficient to meet the claim as drafted. One of ordinary skill in the art would have been motivated to combine the cited teachings because choosing visible, IR, or UV for an optical positioning signal was a known wavelength-selection design choice dictated by illumination requirements, ambient light, detector responsivity, human visibility, and link budget. Huang and Maricic expressly teach those alternatives in optical positioning/communication systems, so applying one to the core positioning architecture would have been predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 26 For completeness, the inherited second-entity limitations of claim 26 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 26 is addressed below. Huang expressly teaches RSS/RSSI optical positioning: “the horizontal distances ... may be obtained through measurement according to a received signal strength (RSS) positioning principle, ambient light sensor (ALS)-based wireless optical RSS positioning ... It should be understood that the RSS ... may be further understood as a received signal strength indication (RSSI)” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu independently teaches AoA, AoD, TOA, and TDOA positioning measurements: “Such Radio Access Technology, RAT, based positioning techniques may utilise one of the following methods: Uplink Angle of Arrival (UL-AoA), Downlink Angle of Departure (DL-AoD), Variance of Time of Arrival (TOA)-based ranging, Uplink Time Difference of Arrival (UL-TDOA), Downlink Time Difference of Arrival (DL-TDOA), and Multi-cell Round Trip Time (Multi-RTT)” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Accordingly, multiple expressly recited alternatives of the claim are taught. In particular, RSSI satisfies the optical-measurement branch directly, and the 5G/non-RAT positioning art independently confirms that AoA/AoD/TOA/TDOA were known measurement types. One of ordinary skill in the art would have been motivated to combine the cited teachings because selecting among RSSI, time-based, and angle-based measurements is a routine positioning design choice based on available sensors, synchronization, geometry, and desired accuracy. The references expressly identify these known measurement families and use them for the same purpose deriving UE position so no inventive modification is required. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 34 As per claim 34, Barbu is the strongest reference for the third-entity “receive request/trigger and transmit positioning signal” sequence. Barbu places that sequence inside a 5G NR positioning framework using LPP/NRPP. Barbu teaches the cellular positioning-protocol context: “The position of a UE within a RAN can be determined by an LMF by various network-based positioning techniques (such as using LTE Positioning Protocol, LPP, or New Radio Positioning Protocol, NRPP)” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Barbu expressly teaches the trigger-to-transmit relationship: “receiving UWB RS triggering information, wherein the UWB RS triggering information comprises information for triggering the transmission of the UWB RS to the at least one node of the RAN; and wherein the UWB RS is transmitted based at least in part on the received UWB RS triggering information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Barbu additionally provides an express positioning-request example: “A serving gNB 1201 sends a positioning request 401 to a UE 110. The sending of such a request may be directed by a LMF 140. Responsive to the request, the UE 110 transmits, via its UWB transceiver 301, a UWB RS 402” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Barbu uses UWB rather than light. Huang teaches the predictable optical implementation: multiple LEDs transmit optical positioning signals to a UE, and those signals are measured to determine UE location. Huang teaches: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Barbu expressly teaches a cellular-positioning-controlled apparatus that transmits a positioning reference signal in response to trigger/request information. Huang expressly teaches that LED/VLC signals are used for high-precision positioning and are received and measured by the target UE. A skilled artisan implementing Barbu’s non-RAT positioning signal would have recognized Huang’s optical signal as a known alternative positioning waveform for indoor use; changing the physical signal from UWB to optical light does not change the control sequence receive the positioning request/trigger, transmit the positioning signal, and permit the receiver to measure it. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 35 For completeness, the inherited third-entity limitations of claim 35 are mapped to the same references as claim 34: Barbu teaches reception of positioning-signal triggering/request information and transmission of the positioning reference signal in response, while Huang teaches implementation of that positioning signal as an optical/light-based signal and Gummadi/Barbu supplies the 4G/5G positioning-protocol context. Barbu teaches that the positioning apparatus can be a UE/RAN node in the 5G framework and that the signal is a positioning RS: “A serving gNB 1201 sends a positioning request 401 to a UE 110. The sending of such a request may be directed by a LMF 140. Responsive to the request, the UE 110 transmits, via its UWB transceiver 301, a UWB RS 402” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang teaches visible/IR/UV Li-Fi/VLC positioning signals: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Maricic teaches IR/UV beacon transmitters: “the beacon transmitters may be any suitable light sources configured to emit modulated light (e.g., light fixture based, infrared or IR based, ultraviolet or UV based)” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. The claim is written as a series of “or” alternatives. The references expressly satisfy multiple branches: the second entity may be a location-server/network function; the third entity may be a UE/RAN component; the light signal may be visible/IR/UV; and Barbu’s positioning waveform is a reference signal. These express alternatives are sufficient without relying on the X-ray branch. One of ordinary skill in the art would have been motivated to combine the cited teachings because the added alternatives identify ordinary implementation choices already taught by the references. Selecting a UE/RAN component as transmitter, selecting visible/IR/UV as the optical band, or treating the transmitted positioning waveform as a reference signal does not alter the request-trigger-transmit sequence and would have been chosen according to deployment and detector requirements. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 36 Claim 36 recites the apparatus counterpart of claim 1. Gummadi expressly supplies the claimed memory/transceiver/processor architecture and the LPP request/report functions. Gummadi’371 expressly claims the UE apparatus: “a wireless transceiver configured to communicate with other entities in a wireless network; at least one memory; and at least one processor coupled to the wireless transceiver and the at least one memory and configured to: receive, via the wireless transceiver, a request for location information from a location server” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 further claims: “wherein the request for location information is received via Long Term Evolution (LTE) Positioning Protocol (LPP) and the location information is sent via LPP” [Gummadi’371 claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Huang supplies the processor-obtained measurement of a light-based signal from a separate LED/light source and the location information based on that measurement. Huang teaches: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu independently confirms processor/memory implementation of the non-RAT positioning-signal apparatus: “an apparatus comprising: at least one processor; and at least one memory including computer program instructions; the at least one memory and the computer program instructions configured to, with the at least one processor, cause the apparatus at least to perform: receiving Ultra-Wideband, UWB, Reference Signal, RS, configuration information ... and ... causing transmission or reception of the UWB RS” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because the apparatus claim merely places the same known functions of claim 1 into conventional processor/memory/transceiver hardware that Gummadi’371 already expressly claims. Huang’s optical measurement and Barbu’s integrated reference-signal positioning are software/receiver functions readily executed by that known hardware. No new hardware principle is required; the modification is a predictable configuration of known wireless-positioning processors and transceivers. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 37 For completeness, the inherited apparatus limitations of claim 37 are mapped to the same references as claim 36: Gummadi’371 expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’371 expressly teaches measurement or position-estimate forms of location information: “wherein the location information comprises positioning measurements by the UE; wherein the location information comprises a position estimate generated by the UE” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’906 further explains absolute and relative location alternatives: “A location estimate may ... be defined relative to some other known location or defined in absolute terms” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Huang expressly identifies Li-Fi/VLC as the optical positioning technology: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because the added limitation merely specifies known forms of the location result (measurement, absolute/relative estimate) or expressly identifies the optical technique as Li-Fi. These are expressly disclosed alternatives in the cited positioning references and do not alter the underlying request/measurement/report architecture. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 38 For completeness, the inherited apparatus limitations of claim 38 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’371 maps the UE and location-server entities: “receiving a request for location information from a location server” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Barbu expressly teaches that the non-RAT positioning apparatus may be a UE or gNB/RAN node within the 5G architecture: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Thus, the claimed alternatives in which the first/second/third entities are UEs, location servers, or wireless-network components correspond to the ordinary UE/location-server/RAN-node roles already used by the cited positioning systems. Because the claim is written in the disjunctive, disclosure of any one recited entity alternative is sufficient; the cited art in fact supplies several of them. One of ordinary skill in the art would have been motivated to combine the cited teachings because the entity labels merely assign the already-known signaling and measurement functions to ordinary UE, location-server, and RAN-node components. The cited references expressly use those components for the same positioning functions, so selecting one of those known entities for the recited role would have been a routine allocation of function. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 39 For completeness, the inherited apparatus limitations of claim 39 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Huang expressly teaches Li-Fi/VLC optical spectra: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Huang expressly identifies the spectrum categories: “the electromagnetic spectrum may be divided into ... an infrared ray, visible light, an ultraviolet ray, an X-ray ...” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Maricic independently teaches IR/UV light emitters for positioning: “the beacon transmitters may be any suitable light sources configured to emit modulated light (e.g., light fixture based, infrared or IR based, ultraviolet or UV based)” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. The claim is disjunctive. The cited art directly teaches the visible-light, infrared, and ultraviolet alternatives. The rejection does not depend on treating Huang’s mere identification of X-rays as an enabled positioning embodiment; the expressly taught visible/IR/UV alternatives are sufficient to meet the claim as drafted. One of ordinary skill in the art would have been motivated to combine the cited teachings because choosing visible, IR, or UV for an optical positioning signal was a known wavelength-selection design choice dictated by illumination requirements, ambient light, detector responsivity, human visibility, and link budget. Huang and Maricic expressly teach those alternatives in optical positioning/communication systems, so applying one to the core positioning architecture would have been predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 42 For completeness, the inherited apparatus limitations of claim 42 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Huang expressly teaches RSS/RSSI optical positioning: “the horizontal distances ... may be obtained through measurement according to a received signal strength (RSS) positioning principle, ambient light sensor (ALS)-based wireless optical RSS positioning ... It should be understood that the RSS ... may be further understood as a received signal strength indication (RSSI)” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu independently teaches AoA, AoD, TOA, and TDOA positioning measurements: “Such Radio Access Technology, RAT, based positioning techniques may utilise one of the following methods: Uplink Angle of Arrival (UL-AoA), Downlink Angle of Departure (DL-AoD), Variance of Time of Arrival (TOA)-based ranging, Uplink Time Difference of Arrival (UL-TDOA), Downlink Time Difference of Arrival (DL-TDOA), and Multi-cell Round Trip Time (Multi-RTT)” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Accordingly, multiple expressly recited alternatives of the claim are taught. In particular, RSSI satisfies the optical-measurement branch directly, and the 5G/non-RAT positioning art independently confirms that AoA/AoD/TOA/TDOA were known measurement types. One of ordinary skill in the art would have been motivated to combine the cited teachings because selecting among RSSI, time-based, and angle-based measurements is a routine positioning design choice based on available sensors, synchronization, geometry, and desired accuracy. The references expressly identify these known measurement families and use them for the same purpose—deriving UE position—so no inventive modification is required The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 52 For completeness, the inherited apparatus limitations of claim 52 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’371 expressly identifies the second entity as a location server in the LPP positioning transaction: “receiving a request for location information from a location server” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. A location server is a network component of the wireless communications network, satisfying the recited alternative. The claim is disjunctive and does not require every listed alternative to be present simultaneously. One of ordinary skill in the art would have been motivated to combine the cited teachings because assigning the second-entity functions to the network location server is not a modification at all; it is the role already expressly used by Gummadi for requesting and receiving UE location information. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 55 For completeness, the inherited apparatus limitations of claim 55 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Barbu expressly identifies the transmitted/received positioning waveform as a “Reference Signal” (RS/PRS) used for positioning: “The conventional framework for positioning in 5th Generation, 5G, NR ... involves the transmission of ... Position Reference Signals, PRS, transmitted by gNBs for DL positioning ... Such OFDM-based RSs are received, detected and measured by the gNBs ... or UE ... A Location Management Function, LMF, receives the measurements ... A NR Positioning Protocol A, NRPPa, carries positioning information between the NG-RAN nodes and the LMF” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang teaches the optical positioning signal transmitted by LEDs and measured by the UE: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because a reference signal is a known positioning waveform whose properties are known/configured so that the receiver can measure it. Barbu expressly uses PRS/RS for positioning, and Huang uses known LED optical waveforms for the same measurement function. Designating/configuring the known light-based positioning waveform as the positioning reference signal is therefore the predictable application of the established reference-signal concept to the optical modality. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 56 Claim 56 is the apparatus counterpart of claim 21. Wachter expressly supplies a positioning-server transceiver/processor structure that sends positioning-protocol messages to a terminal, while Gummadi supplies the request-for-location-information and response flow and Barbu supplies the third-entity trigger. Wachter expressly claims: “A server comprising: a transceiver configured to send messages to a Secure User Plane Location (SUPL) Enabled Terminal (SET) and to receive messages from the SET; and a processor communicatively coupled to the transceiver and configured to send a positioning method SUPL message to the SET via the transceiver using a SUPL User Plane Location Protocol (ULP)” [Wachter, claim 1, cols. 29-30, pp. 23-24; FIGS. 4-7]. Gummadi’371 expressly teaches the location-server request/response: “A method performed by a location server for supporting location services for a user equipment (UE), comprising: sending a request to the UE for information related to the location services; sending a message to a base station to instigate an uplink grant for the UE to respond to the request; and receiving a response to the request from the UE sent by the UE using the uplink grant” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Gummadi’371 expressly teaches the LPP protocol: “wherein the request for information related to the location services is sent via Long Term Evolution (LTE) Positioning Protocol (LPP) and the response to the request is received via LPP” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Barbu teaches the separate positioning-signal trigger: “causing transmission of UWB RS triggering information, wherein the UWB RS triggering information comprises information for triggering a transmission of the UWB RS to the at least one node of the RAN; wherein the UWB RS is transmitted based at least in part on the received UWB RS triggering information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang supplies the light-based signal measured for location: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Wachter demonstrates that a positioning server routinely contains the claimed transceiver and processor for protocol messaging; Gummadi provides the exact location-request/location-response purpose; Barbu provides the second communication to a separate reference-signal source; and Huang provides the optical signal. Combining those known functions in the server hardware would have been a straightforward implementation of a centrally coordinated multi-modal positioning service. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 57 For completeness, the inherited apparatus limitations of claim 57 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Barbu teaches selecting “one or more nodes of the RAN” to receive positioning-signal configuration/triggering information: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang independently teaches a plurality of LED transmitters whose optical signals are jointly received for positioning: “When the UE accesses the nine LEDs, the nine LEDs independently transmit fixed bit streams ... After receiving a group of optical signals transmitted by the LEDs, the UE calculates location information of the UE by referring to an ALS-based positioning principle” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. This directly maps the first disjunctive branch of the claim: sending additional request(s) to additional third entities so that additional positioning signals are available. Because the claim recites the crowdsourced-device branch with “or,” it is unnecessary to rely on that separate branch to establish obviousness; the cited art expressly teaches the additional-third-entity branch. One of ordinary skill in the art would have been motivated to combine the cited teachings because multi-source positioning improves geometry, redundancy, and accuracy. Both Barbu and Huang expressly employ multiple signal sources/nodes. Once the second entity is already controlling one positioning-signal source, extending the same request/trigger to additional known sources is a routine scale-out of the same protocol and yields the predictable benefit of more measurements. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 58 For completeness, the inherited apparatus limitations of claim 58 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Gummadi’371 teaches measurement/position-estimate location information: “wherein the location information comprises positioning measurements by the UE; wherein the location information comprises a position estimate generated by the UE” [Gummadi’371, claims 1, 7, 10, 16, 19, 22-24, 27, 30, 32-37, cols. 51-54, pp. 37-38; FIGS. 2-3, pp. 4-5]. Huang teaches Li-Fi/VLC positioning: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu the relevant UE/location-server/RAN-node entity roles: “the LS selects/identifies, based at least in part on the first position, one or more nodes of the RAN to receive at least one selected from the group of: UWB RS configuration information, UWB RS triggering information, and UWB RS measurement information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because claim 58 recites the apparatus-side counterparts of the already-known alternatives in claim 23. Implementing those known result forms, Li-Fi modality, and entity roles in the server/processor architecture of claim 56 would have been routine. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 59 For completeness, the inherited apparatus limitations of claim 59 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Huang expressly teaches Li-Fi/VLC optical spectra: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Huang expressly identifies the spectrum categories: “the electromagnetic spectrum may be divided into ... an infrared ray, visible light, an ultraviolet ray, an X-ray ...” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Maricic independently teaches IR/UV light emitters for positioning: “the beacon transmitters may be any suitable light sources configured to emit modulated light (e.g., light fixture based, infrared or IR based, ultraviolet or UV based)” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. The claim is disjunctive. The cited art directly teaches the visible-light, infrared, and ultraviolet alternatives. The rejection does not depend on treating Huang’s mere identification of X-rays as an enabled positioning embodiment; the expressly taught visible/IR/UV alternatives are sufficient to meet the claim as drafted. One of ordinary skill in the art would have been motivated to combine the cited teachings because choosing visible, IR, or UV for an optical positioning signal was a known wavelength-selection design choice dictated by illumination requirements, ambient light, detector responsivity, human visibility, and link budget. Huang and Maricic expressly teach those alternatives in optical positioning/communication systems, so applying one to the core positioning architecture would have been predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 61 For completeness, the inherited apparatus limitations of claim 61 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Huang expressly teaches RSS/RSSI optical positioning: “the horizontal distances ... may be obtained through measurement according to a received signal strength (RSS) positioning principle, ambient light sensor (ALS)-based wireless optical RSS positioning ... It should be understood that the RSS ... may be further understood as a received signal strength indication (RSSI)” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Barbu independently teaches AoA, AoD, TOA, and TDOA positioning measurements: “Such Radio Access Technology, RAT, based positioning techniques may utilise one of the following methods: Uplink Angle of Arrival (UL-AoA), Downlink Angle of Departure (DL-AoD), Variance of Time of Arrival (TOA)-based ranging, Uplink Time Difference of Arrival (UL-TDOA), Downlink Time Difference of Arrival (DL-TDOA), and Multi-cell Round Trip Time (Multi-RTT)” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Accordingly, multiple expressly recited alternatives of the claim are taught. In particular, RSSI satisfies the optical-measurement branch directly, and the 5G/non-RAT positioning art independently confirms that AoA/AoD/TOA/TDOA were known measurement types. One of ordinary skill in the art would have been motivated to combine the cited teachings because selecting among RSSI, time-based, and angle-based measurements is a routine positioning design choice based on available sensors, synchronization, geometry, and desired accuracy. The references expressly identify these known measurement families and use them for the same purpose—deriving UE position—so no inventive modification is required. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 69 Claim 69 is the apparatus counterpart of claim 34. Barbu expressly teaches processor/memory implementation of a positioning-signal apparatus and receipt of triggering information that causes transmission of the positioning reference signal. Barbu teaches the processor/memory apparatus: “an apparatus comprising: at least one processor; and at least one memory including computer program instructions; the at least one memory and the computer program instructions configured to, with the at least one processor, cause the apparatus at least to perform: receiving Ultra-Wideband, UWB, Reference Signal, RS, configuration information ... and ... causing transmission or reception of the UWB RS” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Barbu teaches the NR/UWB transceiver context: “the apparatus comprises each of a UWB modem and a NR modem which share a common reference clock that is locked to NR” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Barbu teaches the trigger-response operation: “receiving UWB RS triggering information, wherein the UWB RS triggering information comprises information for triggering the transmission of the UWB RS to the at least one node of the RAN; and wherein the UWB RS is transmitted based at least in part on the received UWB RS triggering information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang teaches replacing/implementing the positioning reference signal as a light-based optical signal transmitted by an LED/light source to the first entity. Huang et al. teaches: “the UE receives optical signals ... transmitted by the four LEDs, and the optical signals are converted into voltage signals after passing through a corresponding PD and TIA ... determines which LED signals exist, obtains location information of these LEDs ... calculates a horizontal distance between the UE and each LED ... and then calculates the location information of the UE” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. One of ordinary skill in the art would have been motivated to combine the cited teachings because the claimed processor/memory/transceiver apparatus performs no function beyond the known Barbu trigger-controlled reference-signal transmitter, except that the transmitted positioning signal is optical. Huang teaches that exact optical positioning modality. A skilled artisan would have expected the same request/trigger logic to control an LED/VLC positioning transmitter just as it controls a UWB positioning transmitter, with predictable results. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 70 For completeness, the inherited third-entity limitations of claim 70 are mapped to the same references as claim 34: Barbu teaches reception of positioning-signal triggering/request information and transmission of the positioning reference signal in response, while Huang teaches implementation of that positioning signal as an optical/light-based signal and Gummadi/Barbu supplies the 4G/5G positioning-protocol context. Barbu teaches that the positioning apparatus can be a UE/RAN node in the 5G framework and that the signal is a positioning RS: “A serving gNB 1201 sends a positioning request 401 to a UE 110. The sending of such a request may be directed by a LMF 140. Responsive to the request, the UE 110 transmits, via its UWB transceiver 301, a UWB RS 402” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Huang teaches visible/IR/UV Li-Fi/VLC positioning signals: “These advantages of the Li-Fi technology (or referred to as the VLC technology) enable wireless optical communication ... to have one or more of the following features: an ultra high frequency optical spectrum (for example, visible, infrared, and ultraviolet) ... high-precision positioning ... [and] a location service” [Huang, ¶¶ [0050], [0055], [0057]-[0058], [0154]-[0156], pp. 21-22, 32; FIGS. 4-5, 18]. Maricic teaches IR/UV beacon transmitters: “the beacon transmitters may be any suitable light sources configured to emit modulated light (e.g., light fixture based, infrared or IR based, ultraviolet or UV based)” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. The claim is written as a series of “or” alternatives. The references expressly satisfy multiple branches: the second entity may be a location-server/network function; the third entity may be aUE/RAN component; the light signal may be visible/IR/UV; and Barbu’s positioning waveform is a reference signal. These express alternatives are sufficient without relying on the X-ray branch. One of ordinary skill in the art would have been motivated to combine the cited teachings because the added alternatives identify ordinary implementation choices already taught by the references. Selecting a UE/RAN component as transmitter, selecting visible/IR/UV as the optical band, or treating the transmitted positioning waveform as a reference signal does not alter the request-trigger-transmit sequence and would have been chosen according to deployment and detector requirements. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claims 5, 6, 25, 40, 41, and 60 are rejected under 35 U.S.C. § 103 as being unpatentable over the combination applied above, further in view of Maricic et al. (US 2018/0262270 A1) and, as corroborating optical-detector art, Jovicic. Claim 5 For completeness, the inherited first-entity limitations of claim 5 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 5 is addressed below with exact text from the cited art. Maricic expressly teaches the light-sensor/photodiode receiver: “the beacon receivers may each include one or more photodetectors (e.g., light sensors, infrared or IR sensors, photodiodes, beacon sensors) configured to receive signals emitted from one or more beacon transmitters” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. One of ordinary skill in the art would have been motivated to combine the cited teachings because photodiodes and image sensors/cameras are conventional optical detectors for VLC/VLP. Maricic and Jovicic use them for the same function recited here receiving modulated light and deriving positioning information so incorporating them into the core optical-positioning receiver would have been routine and predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 6 For completeness, the inherited first-entity limitations of claim 6 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 6 is addressed below with exact text from the cited art. Maricic expressly teaches the light-sensor/photodiode receiver: “the beacon receivers may each include one or more photodetectors (e.g., light sensors, infrared or IR sensors, photodiodes, beacon sensors) configured to receive signals emitted from one or more beacon transmitters” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Thus the “at least one photodiode” alternative is expressly disclosed. Because the claim uses “photodiode, camera, or a combination thereof,” an express photodiode implementation is sufficient. Jovicic additionally teaches a camera/image sensor receiving VLC signals, providing independent support for the camera alternative. Jovicic further expressly teaches the camera/image-sensor alternative: “A camera/image sensor (e.g., camera 570) on a mobile device (e.g., the mobile device 115) may capture the VLC signal (e.g., light data) to determine the relative position from the device to the VLC signal source (e.g., the emitter or fixture).” [Jovicic, ¶ [0033], p. 11; FIG. 2]. One of ordinary skill in the art would have been motivated to combine the cited teachings because photodiodes and image sensors/cameras are conventional optical detectors for VLC/VLP. Maricic and Jovicic use them for the same function recited here—receiving modulated light and deriving positioning information—so incorporating them into the core optical-positioning receiver would have been routine and predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 25 For completeness, the inherited second-entity limitations of claim 25 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 25 is addressed below. Maricic expressly teaches the light-sensor/photodiode receiver: “the beacon receivers may each include one or more photodetectors (e.g., light sensors, infrared or IR sensors, photodiodes, beacon sensors) configured to receive signals emitted from one or more beacon transmitters” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. One of ordinary skill in the art would have been motivated to combine the cited teachings because photodiodes and image sensors/cameras are conventional optical detectors for VLC/VLP. Maricic and Jovicic use them for the same function recited here receiving modulated light and deriving positioning information so incorporating them into the core optical-positioning receiver would have been routine and predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 40 For completeness, the inherited apparatus limitations of claim 40 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Maricic expressly teaches the light-sensor/photodiode receiver: “the beacon receivers may each include one or more photodetectors (e.g., light sensors, infrared or IR sensors, photodiodes, beacon sensors) configured to receive signals emitted from one or more beacon transmitters” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. One of ordinary skill in the art would have been motivated to combine the cited teachings because photodiodes and image sensors/cameras are conventional optical detectors for VLC/VLP. Maricic and Jovicic use them for the same function recited here receiving modulated light and deriving positioning information—so incorporating them into the core optical-positioning receiver would have been routine and predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 41 For completeness, the inherited apparatus limitations of claim 41 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Maricic expressly teaches the light-sensor/photodiode receiver: “the beacon receivers may each include one or more photodetectors (e.g., light sensors, infrared or IR sensors, photodiodes, beacon sensors) configured to receive signals emitted from one or more beacon transmitters” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Thus the “at least one photodiode” alternative is expressly disclosed. Because the claim uses “photodiode, camera, or a combination thereof,” an express photodiode implementation is sufficient. Jovicic additionally teaches a camera/image sensor receiving VLC signals, providing independent support for the camera alternative. Jovicic further expressly teaches the camera/image-sensor alternative: “A camera/image sensor (e.g., camera 570) on a mobile device (e.g., the mobile device 115) may capture the VLC signal (e.g., light data) to determine the relative position from the device to the VLC signal source (e.g., the emitter or fixture).” [Jovicic, ¶ [0033], p. 11; FIG. 2]. One of ordinary skill in the art would have been motivated to combine the cited teachings because photodiodes and image sensors/cameras are conventional optical detectors for VLC/VLP. Maricic and Jovicic use them for the same function recited here—receiving modulated light and deriving positioning information—so incorporating them into the core optical-positioning receiver would have been routine and predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 60 For completeness, the inherited apparatus limitations of claim 60 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Maricic expressly teaches the light-sensor/photodiode receiver: “the beacon receivers may each include one or more photodetectors (e.g., light sensors, infrared or IR sensors, photodiodes, beacon sensors) configured to receive signals emitted from one or more beacon transmitters” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. One of ordinary skill in the art would have been motivated to combine the cited teachings because photodiodes and image sensors/cameras are conventional optical detectors for VLC/VLP. Maricic and Jovicic use them for the same function recited here receiving modulated light and deriving positioning information so incorporating them into the core optical-positioning receiver would have been routine and predictable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claims 8, 9, 27, 43, 44, and 62 are rejected under 35 U.S.C. § 103 as being unpatentable over the combination applied above, further in view of Maricic et al. and Yang. Claim 8 For completeness, the inherited first-entity limitations of claim 8 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 8 is addressed below with exact text from the cited art. Maricic teaches positions and orientations and device-state sensors used with VLC positioning: “The location tracking system may determine the locations (e.g., positions and/or orientations) of the objects using the beacon data or signals collected by the beacon receivers ... the beacon receivers may each include any suitable sensors, such as gyros, accelerometers, magnetometers, and inertial measurement units (IMUs) used in combination with the VLC system to improve location accuracy” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Yang independently teaches terminal orientation together with VLP/TOA: “A 3D visible light positioning (VLP) scheme is proposed by referring to the distances between two luminaires and a pair of photo-detectors. VLP accuracy < 10 cm can be achieved while offering terminal orientation information ... With time-of-arrival (TOA) distance estimation ... the proposed scheme can achieve both high-accurate 3D positioning and terminal orienteering” [Yang, Abstract and Introduction; pp. 1-3]. Orientation is expressly identified by the dependent claim itself as a form of device-state information. Maricic’s location information includes position and/or orientation and uses gyros/accelerometers/IMUs with VLC positioning; Yang independently confirms terminal orientation as positioning output. One of ordinary skill in the art would have been motivated to combine the cited teachings because device orientation directly affects optical incidence angle, field of view, received power, and angle-based positioning. A skilled artisan therefore had an express technical reason to include orientation/device-state information with the location information to improve optical positioning accuracy, exactly as Maricic and Yang teach. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 9 For completeness, the inherited first-entity limitations of claim 9 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 9 is addressed below with exact text from the cited art. Maricic teaches positions and orientations and device-state sensors used with VLC positioning: “The location tracking system may determine the locations (e.g., positions and/or orientations) of the objects using the beacon data or signals collected by the beacon receivers ... the beacon receivers may each include any suitable sensors, such as gyros, accelerometers, magnetometers, and inertial measurement units (IMUs) used in combination with the VLC system to improve location accuracy” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Yang independently teaches terminal orientation together with VLP/TOA: “A 3D visible light positioning (VLP) scheme is proposed by referring to the distances between two luminaires and a pair of photo-detectors. VLP accuracy < 10 cm can be achieved while offering terminal orientation information ... With time-of-arrival (TOA) distance estimation ... the proposed scheme can achieve both high-accurate 3D positioning and terminal orienteering” [Yang, Abstract and Introduction; pp. 1-3]. The claim recites “orientation information, calibrated delay information, or a combination thereof.” The references expressly teach the orientation-information alternative; therefore, the disjunctive limitation is met without relying on calibrated delay. One of ordinary skill in the art would have been motivated to combine the cited teachings because device orientation directly affects optical incidence angle, field of view, received power, and angle-based positioning. A skilled artisan therefore had an express technical reason to include orientation/device-state information with the location information to improve optical positioning accuracy, exactly as Maricic and Yang teach. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 27 For completeness, the inherited second-entity limitations of claim 27 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 27 is addressed below. Maricic teaches positions and orientations and device-state sensors used with VLC positioning: “The location tracking system may determine the locations (e.g., positions and/or orientations) of the objects using the beacon data or signals collected by the beacon receivers ... the beacon receivers may each include any suitable sensors, such as gyros, accelerometers, magnetometers, and inertial measurement units (IMUs) used in combination with the VLC system to improve location accuracy” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Yang independently teaches terminal orientation together with VLP/TOA: “A 3D visible light positioning (VLP) scheme is proposed by referring to the distances between two luminaires and a pair of photo-detectors. VLP accuracy < 10 cm can be achieved while offering terminal orientation information ... With time-of-arrival (TOA) distance estimation ... the proposed scheme can achieve both high-accurate 3D positioning and terminal orienteering” [Yang, Abstract and Introduction; pp. 1-3]. Orientation is expressly identified by the dependent claim itself as a form of device-state information. Maricic’s location information includes position and/or orientation and uses gyros/accelerometers/IMUs with VLC positioning; Yang independently confirms terminal orientation as positioning output. One of ordinary skill in the art would have been motivated to combine the cited teachings because device orientation directly affects optical incidence angle, field of view, received power, and angle-based positioning. A skilled artisan therefore had an express technical reason to include orientation/device-state information with the location information to improve optical positioning accuracy, exactly as Maricic and Yang teach. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 43 For completeness, the inherited apparatus limitations of claim 43 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Maricic teaches positions and orientations and device-state sensors used with VLC positioning: “The location tracking system may determine the locations (e.g., positions and/or orientations) of the objects using the beacon data or signals collected by the beacon receivers ... the beacon receivers may each include any suitable sensors, such as gyros, accelerometers, magnetometers, and inertial measurement units (IMUs) used in combination with the VLC system to improve location accuracy” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Yang independently teaches terminal orientation together with VLP/TOA: “A 3D visible light positioning (VLP) scheme is proposed by referring to the distances between two luminaires and a pair of photo-detectors. VLP accuracy < 10 cm can be achieved while offering terminal orientation information ... With time-of-arrival (TOA) distance estimation ... the proposed scheme can achieve both high-accurate 3D positioning and terminal orienteering” [Yang, Abstract and Introduction; pp. 1-3]. Orientation is expressly identified by the dependent claim itself as a form of device-state information. Maricic’s location information includes position and/or orientation and uses gyros/accelerometers/IMUs with VLC positioning; Yang independently confirms terminal orientation as positioning output. One of ordinary skill in the art would have been motivated to combine the cited teachings because device orientation directly affects optical incidence angle, field of view, received power, and angle-based positioning. A skilled artisan therefore had an express technical reason to include orientation/device-state information with the location information to improve optical positioning accuracy, exactly as Maricic and Yang teach. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 44 For completeness, the inherited apparatus limitations of claim 44 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Maricic teaches positions and orientations and device-state sensors used with VLC positioning: “The location tracking system may determine the locations (e.g., positions and/or orientations) of the objects using the beacon data or signals collected by the beacon receivers ... the beacon receivers may each include any suitable sensors, such as gyros, accelerometers, magnetometers, and inertial measurement units (IMUs) used in combination with the VLC system to improve location accuracy” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Yang independently teaches terminal orientation together with VLP/TOA: “A 3D visible light positioning (VLP) scheme is proposed by referring to the distances between two luminaires and a pair of photo-detectors. VLP accuracy < 10 cm can be achieved while offering terminal orientation information ... With time-of-arrival (TOA) distance estimation ... the proposed scheme can achieve both high-accurate 3D positioning and terminal orienteering” [Yang, Abstract and Introduction; pp. 1-3]. The claim recites “orientation information, calibrated delay information, or a combination thereof.” The references expressly teach the orientation-information alternative; therefore, the disjunctive limitation is met without relying on calibrated delay. One of ordinary skill in the art would have been motivated to combine the cited teachings because device orientation directly affects optical incidence angle, field of view, received power, and angle-based positioning. A skilled artisan therefore had an express technical reason to include orientation/device-state information with the location information to improve optical positioning accuracy, exactly as Maricic and Yang teach. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 62 For completeness, the inherited apparatus limitations of claim 62 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Maricic teaches positions and orientations and device-state sensors used with VLC positioning: “The location tracking system may determine the locations (e.g., positions and/or orientations) of the objects using the beacon data or signals collected by the beacon receivers ... the beacon receivers may each include any suitable sensors, such as gyros, accelerometers, magnetometers, and inertial measurement units (IMUs) used in combination with the VLC system to improve location accuracy” [Maricic, ¶¶ [0015]-[0019], [0039], pp. 7-8, 11; FIGS. 1-2]. Yang independently teaches terminal orientation together with VLP/TOA: “A 3D visible light positioning (VLP) scheme is proposed by referring to the distances between two luminaires and a pair of photo-detectors. VLP accuracy < 10 cm can be achieved while offering terminal orientation information ... With time-of-arrival (TOA) distance estimation ... the proposed scheme can achieve both high-accurate 3D positioning and terminal orienteering” [Yang, Abstract and Introduction; pp. 1-3]. Orientation is expressly identified by the dependent claim itself as a form of device-state information. Maricic’s location information includes position and/or orientation and uses gyros/accelerometers/IMUs with VLC positioning; Yang independently confirms terminal orientation as positioning output. One of ordinary skill in the art would have been motivated to combine the cited teachings because device orientation directly affects optical incidence angle, field of view, received power, and angle-based positioning. A skilled artisan therefore had an express technical reason to include orientation/device-state information with the location information to improve optical positioning accuracy, exactly as Maricic and Yang teach. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claims 10-14, 28-32, 45-49, and 63-67 are rejected under 35 U.S.C. § 103 as being unpatentable over the combination applied above, further in view of Gummadi et al. (US 2022/0116906 A1) and Rajagopal et al. (US 2010/0215378 A1). Claim 10 For completeness, the inherited first-entity limitations of claim 10 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 10 is addressed below with exact text from the cited art. Gummadi’906 teaches LPP capability exchange and measurement configuration: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 expressly teaches the assistance-data/request/measurement sequence: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 confirms that reference-signal configuration is provided as positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because assistance data is the conventional mechanism by which a positioning server tells the measuring entity what signal, bandwidth, timing, source, or method to measure. Applying that known LPP assistance-data mechanism to Huang’s optical positioning signal would have reduced search/measurement burden and ensured that the receiver measures the intended light source at the intended configuration. This is the same technical role assistance data performs in the cited cellular positioning art. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 11 For completeness, the inherited first-entity limitations of claim 11 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 11 is addressed below with exact text from the cited art. Gummadi’906 expressly lists frequency-hopping, bandwidth, periodicity, slot/timing and related reference-signal configuration parameters in positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu independently lists timing, bandwidth, periodicity, and centre frequency of the non-RAT positioning reference signal: “the UWB RS configuration information comprises an indication of at least one selected from the group of: information for enabling the apparatus to determine a structure of the UWB RS; a pulse width of the UWB RS; a pulse type of the UWB RS; timing information of the UWB RS; a transmission power of the UWB RS; a bandwidth of the UWB RS; a periodicity of the UWB RS; and a centre frequency of the UWB RS” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. The claim requires the assistance data to include “at least one of” the listed parameters. The cited art expressly teaches several of the listed alternatives, including frequency/frequency-related information, bandwidth, timing, periodicity, and frequency hopping. One of ordinary skill in the art would have been motivated to combine the cited teachings because these parameters are ordinary configuration fields required for a receiver to know when and where in frequency to observe a positioning reference signal. Using the same known configuration fields for an optical positioning signal is a direct application of their established function and predictably enables efficient signal acquisition and measurement. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 12 For completeness, the inherited first-entity limitations of claim 12 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 12 is addressed below with exact text from the cited art. Gummadi’906 expressly teaches obtaining location information based on the position measurement configuration and assistance data: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. This directly teaches the first disjunctive alternative—location information based at least in part on the assistance data/configuration. Because the claim uses “or,” that express teaching is sufficient. Barbu additionally teaches that the configuration is generated from capabilities and includes characteristics of the transmitted positioning signal. Barbu teaches: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because if assistance data specifies the signal/source parameters used to obtain the measurement, the resulting location information is necessarily based at least in part on that assistance data. The cited references expressly use assistance/configuration data for precisely this purpose, making the limitation a predictable consequence of the known positioning procedure. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 13 For completeness, the inherited first-entity limitations of claim 13 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 13 is addressed below with exact text from the cited art. Gummadi’906 teaches that the location server requests and obtains UE capabilities through an LPP session: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu teaches that signal configuration is based on transmitted capability information: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Gummadi’906 then teaches that the server determines the position measurement configuration from the obtained information and sends the measurement request/location-assistance procedure: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because a location server cannot reliably request a measurement mode that the UE cannot support. The cited art therefore performs capability exchange before configuring/requesting the positioning measurement, and Barbu expressly bases reference-signal configuration on capability information. Applying the same capability-driven request logic to light-based positioning would have been an expected interoperability step, particularly where the UE may or may not support optical transmission/reception. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 14 For completeness, the inherited first-entity limitations of claim 14 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu et al. The additional limitation of claim 14 is addressed below with exact text from the cited art. Barbu expressly defines capability information as transmit/receive support for the positioning reference signal: “causing transmission of UWB capability information, wherein the UWB capability information comprises information indicative of capability of the apparatus for transmitting, and/or receiving, UWB RSs” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Rajagopal expressly teaches optical-device capability exchange including supported light/color channels: “The MAC may also report the number of supported channels and the associated guard colors for each channel for the device during device discovery ... Device 1002 also provides its supported channels, guard channels and application requirements as part of its capabilities information exchange” [Rajagopal, ¶¶ 0025-0030, 0057-0062, 0069-0071, pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. These disclosures map directly to the recited capability alternatives: whether the entity supports transmission and/or reception, and which optical channels/spectra it supports. The claim is disjunctive and requires only one of the listed capability types; the art teaches multiple such types. One of ordinary skill in the art would have been motivated to combine the cited teachings because capability signaling is used to prevent configuration of unsupported transmit/receive modes and unsupported optical channels. Combining Barbu’s standardized positioning capability exchange with Rajagopal’s optical-channel capability exchange would have predictably produced light-based capability information suitable for selecting an optical positioning mode. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 28 For completeness, the inherited second-entity limitations of claim 28 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 28 is addressed below. Gummadi’906 teaches LPP capability exchange and measurement configuration: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 expressly teaches the assistance-data/request/measurement sequence: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 confirms that reference-signal configuration is provided as positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because assistance data is the conventional mechanism by which a positioning server tells the measuring entity what signal, bandwidth, timing, source, or method to measure. Applying that known LPP assistance-data mechanism to Huang’s optical positioning signal would have reduced search/measurement burden and ensured that the receiver measures the intended light source at the intended configuration. This is the same technical role assistance data performs in the cited cellular positioning art. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 29 For completeness, the inherited second-entity limitations of claim 29 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 29 is addressed below. Gummadi’906 expressly lists frequency-hopping, bandwidth, periodicity, slot/timing and related reference-signal configuration parameters in positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu independently lists timing, bandwidth, periodicity, and centre frequency of the non-RAT positioning reference signal: “the UWB RS configuration information comprises an indication of at least one selected from the group of: information for enabling the apparatus to determine a structure of the UWB RS; a pulse width of the UWB RS; a pulse type of the UWB RS; timing information of the UWB RS; a transmission power of the UWB RS; a bandwidth of the UWB RS; a periodicity of the UWB RS; and a centre frequency of the UWB RS” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. The claim requires the assistance data to include “at least one of” the listed parameters. The cited art expressly teaches several of the listed alternatives, including frequency/frequency-related information, bandwidth, timing, periodicity, and frequency hopping. One of ordinary skill in the art would have been motivated to combine the cited teachings because these parameters are ordinary configuration fields required for a receiver to know when and where in frequency to observe a positioning reference signal. Using the same known configuration fields for an optical positioning signal is a direct application of their established function and predictably enables efficient signal acquisition and measurement. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 30 For completeness, the inherited second-entity limitations of claim 30 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 30 is addressed below. Gummadi’906 expressly teaches obtaining location information based on the position measurement configuration and assistance data: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. This directly teaches the first disjunctive alternative location information based at least in part on the assistance data/configuration. Because the claim uses “or,” that express teaching is sufficient. Barbu additionally teaches that the configuration is generated from capabilities and includes characteristics of the transmitted positioning signal. Barbu teaches: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because if assistance data specifies the signal/source parameters used to obtain the measurement, the resulting location information is necessarily based at least in part on that assistance data. The cited references expressly use assistance/configuration data for precisely this purpose, making the limitation a predictable consequence of the known positioning procedure. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 31 For completeness, the inherited second-entity limitations of claim 31 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 31 is addressed below. Gummadi’906 teaches that the location server requests and obtains UE capabilities through an LPP session: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu teaches that signal configuration is based on transmitted capability information: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Gummadi’906 then teaches that the server determines the position measurement configuration from the obtained information and sends the measurement request/location-assistance procedure: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because a location server cannot reliably request a measurement mode that the UE cannot support. The cited art therefore performs capability exchange before configuring/requesting the positioning measurement, and Barbu expressly bases reference-signal configuration on capability information. Applying the same capability-driven request logic to light-based positioning would have been an expected interoperability step, particularly where the UE may or may not support optical transmission/reception. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 32 For completeness, the inherited second-entity limitations of claim 32 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 32 is addressed below. Barbu expressly defines capability information as transmit/receive support for the positioning reference signal: “causing transmission of UWB capability information, wherein the UWB capability information comprises information indicative of capability of the apparatus for transmitting, and/or receiving, UWB RSs” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Rajagopal expressly teaches optical-device capability exchange including supported light/color channels: “The MAC may also report the number of supported channels and the associated guard colors for each channel for the device during device discovery ... Device 1002 also provides its supported channels, guard channels and application requirements as part of its capabilities information exchange” [Rajagopal, ¶¶ 0025-0030, 0057-0062, 0069-0071, pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. These disclosures map directly to the recited capability alternatives: whether the entity supports transmission and/or reception, and which optical channels/spectra it supports. The claim is disjunctive and requires only one of the listed capability types; the art teaches multiple such types. One of ordinary skill in the art would have been motivated to combine the cited teachings because capability signaling is used to prevent configuration of unsupported transmit/receive modes and unsupported optical channels. Combining Barbu’s standardized positioning capability exchange with Rajagopal’s optical-channel capability exchange would have predictably produced light-based capability information suitable for selecting an optical positioning mode. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 45 For completeness, the inherited apparatus limitations of claim 45 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’906 teaches LPP capability exchange and measurement configuration: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 expressly teaches the assistance-data/request/measurement sequence: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 confirms that reference-signal configuration is provided as positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because assistance data is the conventional mechanism by which a positioning server tells the measuring entity what signal, bandwidth, timing, source, or method to measure. Applying that known LPP assistance-data mechanism to Huang’s optical positioning signal would have reduced search/measurement burden and ensured that the receiver measures the intended light source at the intended configuration. This is the same technical role assistance data performs in the cited cellular positioning art. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 46 For completeness, the inherited apparatus limitations of claim 46 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’906 expressly lists frequency-hopping, bandwidth, periodicity, slot/timing and related reference-signal configuration parameters in positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu independently lists timing, bandwidth, periodicity, and centre frequency of the non-RAT positioning reference signal: “the UWB RS configuration information comprises an indication of at least one selected from the group of: information for enabling the apparatus to determine a structure of the UWB RS; a pulse width of the UWB RS; a pulse type of the UWB RS; timing information of the UWB RS; a transmission power of the UWB RS; a bandwidth of the UWB RS; a periodicity of the UWB RS; and a centre frequency of the UWB RS” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. The claim requires the assistance data to include “at least one of” the listed parameters. The cited art expressly teaches several of the listed alternatives, including frequency/frequency-related information, bandwidth, timing, periodicity, and frequency hopping. One of ordinary skill in the art would have been motivated to combine the cited teachings because these parameters are ordinary configuration fields required for a receiver to know when and where in frequency to observe a positioning reference signal. Using the same known configuration fields for an optical positioning signal is a direct application of their established function and predictably enables efficient signal acquisition and measurement. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 47 For completeness, the inherited apparatus limitations of claim 47 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’906 expressly teaches obtaining location information based on the position measurement configuration and assistance data: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. This directly teaches the first disjunctive alternative location information based at least in part on the assistance data/configuration. Because the claim uses “or,” that express teaching is sufficient. Barbu additionally teaches that the configuration is generated from capabilities and includes characteristics of the transmitted positioning signal. Barbu teaches: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because if assistance data specifies the signal/source parameters used to obtain the measurement, the resulting location information is necessarily based at least in part on that assistance data. The cited references expressly use assistance/configuration data for precisely this purpose, making the limitation a predictable consequence of the known positioning procedure. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 48 For completeness, the inherited apparatus limitations of claim 48 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Gummadi’906 teaches that the location server requests and obtains UE capabilities through an LPP session: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu teaches that signal configuration is based on transmitted capability information: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Gummadi’906 then teaches that the server determines the position measurement configuration from the obtained information and sends the measurement request/location-assistance procedure: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because a location server cannot reliably request a measurement mode that the UE cannot support. The cited art therefore performs capability exchange before configuring/requesting the positioning measurement, and Barbu expressly bases reference-signal configuration on capability information. Applying the same capability-driven request logic to light-based positioning would have been an expected interoperability step, particularly where the UE may or may not support optical transmission/reception. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 49 For completeness, the inherited apparatus limitations of claim 49 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Barbu expressly defines capability information as transmit/receive support for the positioning reference signal: “causing transmission of UWB capability information, wherein the UWB capability information comprises information indicative of capability of the apparatus for transmitting, and/or receiving, UWB RSs” [Barbu, [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Rajagopal expressly teaches optical-device capability exchange including supported light/color channels: “The MAC may also report the number of supported channels and the associated guard colors for each channel for the device during device discovery ... Device 1002 also provides its supported channels, guard channels and application requirements as part of its capabilities information exchange” [Rajagopal, ¶¶ 0025-0030, 0057-0062, 0069-0071, pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. These disclosures map directly to the recited capability alternatives: whether the entity supports transmission and/or reception, and which optical channels/spectra it supports. The claim is disjunctive and requires only one of the listed capability types; the art teaches multiple such types. One of ordinary skill in the art would have been motivated to combine the cited teachings because capability signaling is used to prevent configuration of unsupported transmit/receive modes and unsupported optical channels. Combining Barbu’s standardized positioning capability exchange with Rajagopal’s optical-channel capability exchange would have predictably produced light-based capability information suitable for selecting an optical positioning mode. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 63 For completeness, the inherited apparatus limitations of claim 63 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Gummadi’906 teaches LPP capability exchange and measurement configuration: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 expressly teaches the assistance-data/request/measurement sequence: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Gummadi’906 confirms that reference-signal configuration is provided as positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because assistance data is the conventional mechanism by which a positioning server tells the measuring entity what signal, bandwidth, timing, source, or method to measure. Applying that known LPP assistance-data mechanism to Huang’s optical positioning signal would have reduced search/measurement burden and ensured that the receiver measures the intended light source at the intended configuration. This is the same technical role assistance data performs in the cited cellular positioning art. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 64 For completeness, the inherited apparatus limitations of claim 64 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Gummadi’906 expressly lists frequency-hopping, bandwidth, periodicity, slot/timing and related reference-signal configuration parameters in positioning assistance data: “the assistance data may include identifiers of the base stations ... from which to measure reference signals, the reference signal configuration parameters (e.g., the number of consecutive positioning slots, periodicity of positioning slots, muting sequence, frequency hopping sequence, reference signal identifier (ID), reference signal bandwidth, slot offset, etc.)” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu independently lists timing, bandwidth, periodicity, and centre frequency of the non-RAT positioning reference signal: “the UWB RS configuration information comprises an indication of at least one selected from the group of: information for enabling the apparatus to determine a structure of the UWB RS; a pulse width of the UWB RS; a pulse type of the UWB RS; timing information of the UWB RS; a transmission power of the UWB RS; a bandwidth of the UWB RS; a periodicity of the UWB RS; and a centre frequency of the UWB RS” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. The claim requires the assistance data to include “at least one of” the listed parameters. The cited art expressly teaches several of the listed alternatives, including frequency/frequency-related information, bandwidth, timing, periodicity, and frequency hopping. One of ordinary skill in the art would have been motivated to combine the cited teachings because these parameters are ordinary configuration fields required for a receiver to know when and where in frequency to observe a positioning reference signal. Using the same known configuration fields for an optical positioning signal is a direct application of their established function and predictably enables efficient signal acquisition and measurement. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 65 For completeness, the inherited apparatus limitations of claim 65 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Gummadi’906 expressly teaches obtaining location information based on the position measurement configuration and assistance data: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. This directly teaches the first disjunctive alternative location information based at least in part on the assistance data/configuration. Because the claim uses “or,” that express teaching is sufficient. Barbu additionally teaches that the configuration is generated from capabilities and includes characteristics of the transmitted positioning signal. Barbu teaches: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. One of ordinary skill in the art would have been motivated to combine the cited teachings because if assistance data specifies the signal/source parameters used to obtain the measurement, the resulting location information is necessarily based at least in part on that assistance data. The cited references expressly use assistance/configuration data for precisely this purpose, making the limitation a predictable consequence of the known positioning procedure. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 66 For completeness, the inherited apparatus limitations of claim 66 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Gummadi’906 teaches that the location server requests and obtains UE capabilities through an LPP session: “the LS 112 may request and obtains the capabilities of the UE 104 via the base station (BS) 102, e.g., via an LPP session with the UE 104 through the BS 102” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Barbu teaches that signal configuration is based on transmitted capability information: “the apparatus receives the UWB RS configuration information based at least in part on the UWB capability information” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Gummadi’906 then teaches that the server determines the position measurement configuration from the obtained information and sends the measurement request/location-assistance procedure: “obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906,¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because a location server cannot reliably request a measurement mode that the UE cannot support. The cited art therefore performs capability exchange before configuring/requesting the positioning measurement, and Barbu expressly bases reference-signal configuration on capability information. Applying the same capability-driven request logic to light-based positioning would have been an expected interoperability step, particularly where the UE may or may not support optical transmission/reception. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 67 For completeness, the inherited apparatus limitations of claim 67 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Barbu expressly defines capability information as transmit/receive support for the positioning reference signal: “causing transmission of UWB capability information, wherein the UWB capability information comprises information indicative of capability of the apparatus for transmitting, and/or receiving, UWB RSs” [Barbu, ¶¶ [0003], [0020], [0022]-[0026], [0087], [0113]-[0115], [0122]-[0126], pp. 2, 6-7, 14, 21-23; claims 5-9 and 20-32, pp. 46-50]. Rajagopal expressly teaches optical-device capability exchange including supported light/color channels: “The MAC may also report the number of supported channels and the associated guard colors for each channel for the device during device discovery ... Device 1002 also provides its supported channels, guard channels and application requirements as part of its capabilities information exchange” [Rajagopal, ¶¶ 0025-0030, 0057-0062, 0069-0071, pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. These disclosures map directly to the recited capability alternatives: whether the entity supports transmission and/or reception, and which optical channels/spectra it supports. The claim is disjunctive and requires only one of the listed capability types; the art teaches multiple such types. One of ordinary skill in the art would have been motivated to combine the cited teachings because capability signaling is used to prevent configuration of unsupported transmit/receive modes and unsupported optical channels. Combining Barbu’s standardized positioning capability exchange with Rajagopal’s optical-channel capability exchange would have predictably produced light-based capability information suitable for selecting an optical positioning mode. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claims 15, 16, 50, and 51 are rejected under 35 U.S.C. § 103 as being unpatentable over the combination applied above, further in view of Jovicic and Gummadi et al. (Gummadi’906). Claim 15 For completeness, the inherited first-entity limitations of claim 15 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 15 is addressed below with exact text from the cited art. Jovicic expressly teaches detection of one or more VLC light sources, decoding their identifiers, and notifying a server: “the mobile device ... detects and decodes a VLC signal ... The VLC signals source may be one or more light fixtures/emitters ... The VLC signals may carry identification (ID) messages for the particular source ... In response to detecting a VLC signal, the mobile device may notify a server of receipt of the VLC signal” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. Jovicic further teaches transmitting the identified source/status information to the server: “the mobile device ... sends a status signal to a server ... the status signal includes one or more of the decoded identifier from the VLC signal, the relative position of the mobile device to the VLC signal source, and external field measurements” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. One of ordinary skill in the art would have been motivated to combine the cited teachings because detecting and reporting available light transmitters is a straightforward discovery step for optical positioning: the server needs to know which emitters are visible to the UE before selecting a source or measurement. Jovicic expressly performs that discovery and reports source identifiers, so the claimed step is a predictable use of known VLC positioning information. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 16 For completeness, the inherited first-entity limitations of claim 16 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 16 is addressed below with exact text from the cited art. Jovicic expressly teaches detection of one or more VLC light sources, decoding their identifiers, and notifying a server: “the mobile device ... detects and decodes a VLC signal ... The VLC signals source may be one or more light fixtures/emitters ... The VLC signals may carry identification (ID) messages for the particular source ... In response to detecting a VLC signal, the mobile device may notify a server of receipt of the VLC signal” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. Jovicic further teaches transmitting the identified source/status information to the server: “the mobile device ... sends a status signal to a server ... the status signal includes one or more of the decoded identifier from the VLC signal, the relative position of the mobile device to the VLC signal source, and external field measurements” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. Jovicic then teaches a server request generated after the reported VLC/status information: “the server ... sends request for updated signal(s) ... the server may ... send out a request for a device to obtain new VLC and associated external field(s)” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. Gummadi’906 independently teaches that a location server uses received condition/source information to select a positioning configuration and then sends the measurement request: “the LS 112 obtains information relating to channel conditions of the UE 104 ... [and] determines a position measurement configuration for the UE 104 ... based on the channel conditions of the UE 104 ... The position measurement configuration may comprise ... a plurality of signal sources ... a plurality of signals ... and/or ... one or more position methods obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Jovicic expressly reports detected light-source identities to the server and then has the server request updated VLC information. Gummadi independently teaches the general cellular-positioning control rule that the server uses received source/channel information to select the positioning configuration and request the measurement. A skilled artisan would therefore have had a direct reason to base the location request on the reported set of available light transmitters so that the requested measurement targets a source that is actually detectable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 50 For completeness, the inherited apparatus limitations of claim 50 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Jovicic expressly teaches detection of one or more VLC light sources, decoding their identifiers, and notifying a server: “the mobile device ... detects and decodes a VLC signal ... The VLC signals source may be one or more light fixtures/emitters ... The VLC signals may carry identification (ID) messages for the particular source ... In response to detecting a VLC signal, the mobile device may notify a server of receipt of the VLC signal” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. Jovicic further teaches transmitting the identified source/status information to the server: “the mobile device ... sends a status signal to a server ... the status signal includes one or more of the decoded identifier from the VLC signal, the relative position of the mobile device to the VLC signal source, and external field measurements” [Jovicic, ¶¶ [0033]-[0037], [0045]-[0048], pp. 11-13; FIGS. 2-3]. One of ordinary skill in the art would have been motivated to combine the cited teachings because detecting and reporting available light transmitters is a straightforward discovery step for optical positioning: the server needs to know which emitters are visible to the UE before selecting a source or measurement. Jovicic expressly performs that discovery and reports source identifiers, so the claimed step is a predictable use of known VLC positioning information. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 51 For completeness, the inherited apparatus limitations of claim 51 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Jovicic expressly teaches detection of one or more VLC light sources, decoding their identifiers, and notifying a server: “the mobile device ... detects and decodes a VLC signal ... The VLC signals source may be one or more light fixtures/emitters ... The VLC signals may carry identification (ID) messages for the particular source ... In response to detecting a VLC signal, the mobile device may notify a server of receipt of the VLC signal” [Jovicic, ¶¶ [0033]-[0037], [0045]-[0048], pp. 11-13; FIGS. 2-3]. Jovicic further teaches transmitting the identified source/status information to the server: “the mobile device ... sends a status signal to a server ... the status signal includes one or more of the decoded identifier from the VLC signal, the relative position of the mobile device to the VLC signal source, and external field measurements” [Jovicic, ¶¶ [0033]-[0037], [0045]-[0048], pp. 11-13; FIGS. 2-3]. Jovicic then teaches a server request generated after the reported VLC/status information: “the server ... sends request for updated signal(s) ... the server may ... send out a request for a device to obtain new VLC and associated external field(s)” [Jovicic, ¶¶ 0033-0037, 0045-0048, pp. 11-13; FIGS. 2-3]. Gummadi’906 independently teaches that a location server uses received condition/source information to select a positioning configuration and then sends the measurement request: “the LS 112 obtains information relating to channel conditions of the UE 104 ... [and] determines a position measurement configuration for the UE 104 ... based on the channel conditions of the UE 104 ... The position measurement configuration may comprise ... a plurality of signal sources ... a plurality of signals ... and/or ... one or more position methods obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Jovicic expressly reports detected light-source identities to the server and then has the server request updated VLC information. Gummadi independently teaches the general cellular-positioning control rule that the server uses received source/channel information to select the positioning configuration and request the measurement. A skilled artisan would therefore have had a direct reason to base the location request on the reported set of available light transmitters so that the requested measurement targets a source that is actually detectable. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claims 18, 33, 53, and 68 are rejected under 35 U.S.C. § 103 as being unpatentable over the combination applied above, further in view of Rajagopal et al. and Gummadi et al. (Gummadi’906). Claim 18 For completeness, the inherited first-entity limitations of claim 18 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 18 is addressed below with exact text from the cited art. Rajagopal expressly teaches determining ambient-light interference on optical/color channels and reporting channel quality/selection information to another device: “transmitting on every one of a plurality of supported color channels of a first device to estimate an ambient interference on each supported color channel ... calculating a channel quality index (CQI) for each of the receiving color channels; selecting at least one ... communication channel; and reporting the at least one communication channel to a second device in the VLC network” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Rajagopal explains why the interference is spectrum-dependent: “One of the major challenges with visible light communication is interference from ambient lighting ... VLC that transmits on a channel (band of wavelengths) ... may be subject to interference ... Therefore, it would be desirable to select a VLC channel that has minimal interference from ambient light” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Gummadi’906 teaches the corresponding cellular-positioning control consequence: the server determines a preferred signal source/frequency/configuration based on received channel-condition information and then sends location assistance data and a measurement request: “determining the position measurement configuration for the UE comprises determining at least one of a position method, a preferred frequency band or bandwidth part, or a preferred positioning signal source ... [and] determining a positioning reference signal (PRS) configuration obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Rajagopal supplies the specifically optical interference measurement/report, while Gummadi supplies the known positioning-server rule of using channel-condition information to determine the positioning configuration and request. A skilled artisan would have used the reported light-spectrum interference to choose the optical positioning source/frequency and formulate the subsequent location request, because requesting a measurement in a heavily interfered optical band would predictably reduce positioning reliability. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 33 For completeness, the inherited second-entity limitations of claim 33 are mapped to the same references as claim 21: Gummadi teaches the location-server request/response over LPP; Barbu teaches location-server/LMF control and triggering of a separate positioning-signal transmitting apparatus; and Huang teaches the optical/light-based positioning signal measured by the first entity. The additional limitation of claim 33 is addressed below. Rajagopal expressly teaches determining ambient-light interference on optical/color channels and reporting channel quality/selection information to another device: “transmitting on every one of a plurality of supported color channels of a first device to estimate an ambient interference on each supported color channel ... calculating a channel quality index (CQI) for each of the receiving color channels; selecting at least one ... communication channel; and reporting the at least one communication channel to a second device in the VLC network” [Rajagopal, US 2010/0215378 A1, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Rajagopal explains why the interference is spectrum-dependent: “One of the major challenges with visible light communication is interference from ambient lighting ... VLC that transmits on a channel (band of wavelengths) ... may be subject to interference ... Therefore, it would be desirable to select a VLC channel that has minimal interference from ambient light” [Rajagopal, ¶¶ 0025-0030, 0057-0062, 0069-0071, pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Gummadi’906 teaches the corresponding cellular-positioning control consequence: the server determines a preferred signal source/frequency/configuration based on received channel-condition information and then sends location assistance data and a measurement request: “determining the position measurement configuration for the UE comprises determining at least one of a position method, a preferred frequency band or bandwidth part, or a preferred positioning signal source ... [and] determining a positioning reference signal (PRS) configuration obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Rajagopal supplies the specifically optical interference measurement/report, while Gummadi supplies the known positioning-server rule of using channel-condition information to determine the positioning configuration and request. A skilled artisan would have used the reported light-spectrum interference to choose the optical positioning source/frequency and formulate the subsequent location request, because requesting a measurement in a heavily interfered optical band would predictably reduce positioning reliability. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 53 For completeness, the inherited apparatus limitations of claim 53 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Rajagopal expressly teaches determining ambient-light interference on optical/color channels and reporting channel quality/selection information to another device: “transmitting on every one of a plurality of supported color channels of a first device to estimate an ambient interference on each supported color channel ... calculating a channel quality index (CQI) for each of the receiving color channels; selecting at least one ... communication channel; and reporting the at least one communication channel to a second device in the VLC network” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Rajagopal explains why the interference is spectrum-dependent: “One of the major challenges with visible light communication is interference from ambient lighting ... VLC that transmits on a channel (band of wavelengths) ... may be subject to interference ... Therefore, it would be desirable to select a VLC channel that has minimal interference from ambient light” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Gummadi’906 teaches the corresponding cellular-positioning control consequence: the server determines a preferred signal source/frequency/configuration based on received channel-condition information and then sends location assistance data and a measurement request: “determining the position measurement configuration for the UE comprises determining at least one of a position method, a preferred frequency band or bandwidth part, or a preferred positioning signal source ... [and] determining a positioning reference signal (PRS) configuration obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Rajagopal supplies the specifically optical interference measurement/report, while Gummadi supplies the known positioning-server rule of using channel-condition information to determine the positioning configuration and request. A skilled artisan would have used the reported light-spectrum interference to choose the optical positioning source/frequency and formulate the subsequent location request, because requesting a measurement in a heavily interfered optical band would predictably reduce positioning reliability. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 68 For completeness, the inherited apparatus limitations of claim 68 are mapped to the same references as claim 56: Wachter and Gummadi teach a location-server/positioning-server transceiver and processor that sends positioning-protocol messages and receives location responses; Barbu teaches transmission of triggering information to a separate signal source; and Huang supplies the light-based positioning signal. The additional limitation is addressed below. Rajagopal expressly teaches determining ambient-light interference on optical/color channels and reporting channel quality/selection information to another device: “transmitting on every one of a plurality of supported color channels of a first device to estimate an ambient interference on each supported color channel ... calculating a channel quality index (CQI) for each of the receiving color channels; selecting at least one ... communication channel; and reporting the at least one communication channel to a second device in the VLC network” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Rajagopal explains why the interference is spectrum-dependent: “One of the major challenges with visible light communication is interference from ambient lighting ... VLC that transmits on a channel (band of wavelengths) ... may be subject to interference ... Therefore, it would be desirable to select a VLC channel that has minimal interference from ambient light” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Gummadi’906 teaches the corresponding cellular-positioning control consequence: the server determines a preferred signal source/frequency/configuration based on received channel-condition information and then sends location assistance data and a measurement request: “determining the position measurement configuration for the UE comprises determining at least one of a position method, a preferred frequency band or bandwidth part, or a preferred positioning signal source ... [and] determining a positioning reference signal (PRS) configuration obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. One of ordinary skill in the art would have been motivated to combine the cited teachings because Rajagopal supplies the specifically optical interference measurement/report, while Gummadi supplies the known positioning-server rule of using channel-condition information to determine the positioning configuration and request. A skilled artisan would have used the reported light-spectrum interference to choose the optical positioning source/frequency and formulate the subsequent location request, because requesting a measurement in a heavily interfered optical band would predictably reduce positioning reliability. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claims 19 and 54 are rejected under 35 U.S.C. § 103 as being unpatentable over the combination applied above, further in view of Rajagopal et al., Van Wageningen et al. (US 2023/0308176 A1), Carraro et al. (US 2022/0166506 A1), and Gummadi et al. (Gummadi’906). Claim 19 For completeness, the inherited first-entity limitations of claim 19 are mapped to the same references as claim 1: the cellular positioning-protocol request and return path are taught by Gummadi; the received light-based positioning signal and optical measurement are taught by Huang; and the use of a separately controlled positioning-signal source within a 5G positioning framework is taught by Barbu. The additional limitation of claim 19 is addressed below with exact text from the cited art. Rajagopal teaches visible-light interference measurement and selection of a lower-interference optical channel: “One of the major challenges with visible light communication is interference from ambient lighting ... VLC that transmits on a channel (band of wavelengths) ... may be subject to interference ... Therefore, it would be desirable to select a VLC channel that has minimal interference from ambient light” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Van Wageningen expressly teaches an optical interference threshold: “selection ... may be determined based on a cross-over point which defines a threshold based on the shared determined link qualities ... the threshold is preferably set such that it defines a threshold where an interference power has a first predetermined relation to a noise power and a second predetermined relation to a desired signal power” [Van Wageningen, ¶¶ [0027]-[0032], [0191]-[0209], pp. 14-15, 23-24; claims 1 and 7, pp. 29-30]. Carraro expressly teaches visible and infrared signaling and controller selection between modes/frequencies: “A typical OWC system is a LiFi system ... the AP may be incorporated into a luminaire and may use the visible light of the luminaire for the downlink. The STA may be incorporated into a mobile device ... and may use infrared (IR) for the uplink The light of the first frequency may comprise visible light. The light of the second frequency may comprise infrared light. The light of the third frequency may comprise infrared light” [Carraro, ¶¶ [0005]-[0009], [0014], [0035], [0040], [0060], pp. 8-11; FIGS. 1-2, 8-10]. Gummadi’906 teaches that the positioning server chooses a preferred frequency band/source based on channel conditions and sends a measurement request: “determining the position measurement configuration for the UE comprises determining at least one of a position method, a preferred frequency band or bandwidth part, or a preferred positioning signal source ... [and] determining a positioning reference signal (PRS) configuration obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Taken together, the references teach the complete conditional relationship: measure optical/visible interference; compare interference to a threshold; when the visible channel is unsuitable, select an alternative optical band such as IR outside the visible spectrum; and communicate the selected configuration/request to obtain the positioning measurement. One of ordinary skill in the art would have been motivated to combine the cited teachings because optical interference is wavelength dependent. Rajagopal teaches measuring and avoiding interfered visible channels; Van Wageningen expressly converts optical interference quality into a threshold decision; Carraro teaches using infrared as the non-visible alternative; and Gummadi teaches basing the positioning configuration/request on channel conditions. A skilled artisan would have combined these teachings to avoid an above-threshold visible-light interferer by requesting the positioning signal in IR, thereby predictably improving SNR and measurement reliability. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. Claim 54 For completeness, the inherited apparatus limitations of claim 54 are mapped to the same references as claim 36: Gummadi expressly teaches the memory/transceiver/processor UE architecture and LPP location request/report functions; Huang supplies the light-based positioning measurement; and Barbu supplies the integrated positioning-reference-signal control framework. The additional limitation is addressed below. Rajagopal teaches visible-light interference measurement and selection of a lower-interference optical channel: “One of the major challenges with visible light communication is interference from ambient lighting ... VLC that transmits on a channel (band of wavelengths) ... may be subject to interference ... Therefore, it would be desirable to select a VLC channel that has minimal interference from ambient light” [Rajagopal, ¶¶ [0025]-[0030], [0057]-[0062], [0069]-[0071], pp. 13, 16-17; claims 1-6 and 16-21, pp. 17-18; FIGS. 11-13]. Van Wageningen expressly teaches an optical interference threshold: “selection ... may be determined based on a cross-over point which defines a threshold based on the shared determined link qualities ... the threshold is preferably set such that it defines a threshold where an interference power has a first predetermined relation to a noise power and a second predetermined relation to a desired signal power” [Van Wageningen, ¶¶ [0027]-[0032], [0191]-[0209], pp. 14-15, 23-24; claims 1 and 7, pp. 29-30]. Carraro expressly teaches visible and infrared signaling and controller selection between modes/frequencies: “A typical OWC system is a LiFi system ... the AP may be incorporated into a luminaire and may use the visible light of the luminaire for the downlink. The STA may be incorporated into a mobile device ... and may use infrared (IR) for the uplink The light of the first frequency may comprise visible light. The light of the second frequency may comprise infrared light. The light of the third frequency may comprise infrared light” [Carraro, ¶¶ [0005]-[0009], [0014], [0035], [0040], [0060], pp. 8-11; FIGS. 1-2, 8-10]. Gummadi’906 teaches that the positioning server chooses a preferred frequency band/source based on channel conditions and sends a measurement request: “determining the position measurement configuration for the UE comprises determining at least one of a position method, a preferred frequency band or bandwidth part, or a preferred positioning signal source ... [and] determining a positioning reference signal (PRS) configuration obtaining location information from the UE based on the position measurement configuration comprises sending, to the UE, location assistance data, sending, to the UE, a request to perform a location measurement, and receiving, from the UE, the location information” [Gummadi’906, ¶¶ [0010], [0094]-[0095], [0122]-[0123], [0144]-[0145], [0193]-[0194], [0224], pp. 18, 29, 32, 34, 37-38; FIGS. 6 and 10A]. Taken together, the references teach the complete conditional relationship: measure optical/visible interference; compare interference to a threshold; when the visible channel is unsuitable, select an alternative optical band such as IR outside the visible spectrum; and communicate the selected configuration/request to obtain the positioning measurement. One of ordinary skill in the art would have been motivated to combine the cited teachings because optical interference is wavelength dependent. Rajagopal teaches measuring and avoiding interfered visible channels; Van Wageningen expressly converts optical interference quality into a threshold decision; Carraro teaches using infrared as the non-visible alternative; and Gummadi teaches basing the positioning configuration/request on channel conditions. A skilled artisan would have combined these teachings to avoid an above-threshold visible-light interferer by requesting the positioning signal in IR, thereby predictably improving SNR and measurement reliability. The modification would have used each reference for its established function, would not have required a change in the basic principle of operation of any reference, and would have produced the predictable result of a cellular positioning session that uses a known optical positioning modality and known positioning-protocol signaling. It is noted that any citations to specific pages, columns, lines, or figures in the prior art references and any interpretation of the reference should not be considered to be limiting in any way. A reference is relevant for all it contains and may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art. See MPEP § 2123. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to David C Payne whose telephone number is (571)272-3024. The examiner can normally be reached M-W Teleworking 6:30a -2:30p. 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. 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. /DAVID C PAYNE/ Supervisory Patent Examiner, Art Unit 2635
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Prosecution Timeline

Sep 25, 2024
Application Filed
Jun 04, 2026
Non-Final Rejection mailed — §103
Sep 03, 2026
Response Filed
Sep 30, 2026
Non-Final Rejection mailed — §103 (current)

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