Prosecution Insights
Last updated: August 17, 2026
Application No. 18/946,748

PREVENTION OF BRUTE FORCE ATTACKS ON VOICEMAIL ACCOUNTS

Non-Final OA §103
Filed
Nov 13, 2024
Examiner
KIM, WESLEY LEO
Art Unit
2648
Tech Center
2600 — Communications
Assignee
T-Mobile USA Inc.
OA Round
1 (Non-Final)
61%
Grant Probability
Moderate
1-2
OA Rounds
2y 5m
Est. Remaining
93%
With Interview

Examiner Intelligence

Grants 61% of resolved cases
61%
Career Allowance Rate
211 granted / 347 resolved
-1.2% vs TC avg
Strong +32% interview lift
Without
With
+32.5%
Interview Lift
resolved cases with interview
Typical timeline
4y 3m
Avg Prosecution
15 currently pending
Career history
362
Total Applications
across all art units

Statute-Specific Performance

§101
5.6%
-34.4% vs TC avg
§103
53.7%
+13.7% vs TC avg
§102
19.7%
-20.3% vs TC avg
§112
14.6%
-25.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 347 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 . Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1, 8, 14-16, and 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Shaw (US 9204302) in view of Ishihara (JP 11008702 A) Regarding Claims 1, 15-16, and 19-20, Shaw teaches receiving, by a voicemail server device associated with the network service provider (Col.7:lines 15-19 and Col.7:lines 48-50, call voicemail of UE. UE associated with network provider), a voice call attempting to access a voicemail account associated with a subscriber of the network service provider, wherein the voice call is originated from an originating device associated with an originating mobile station international subscriber directory number (MSISDN) (Col.7:lines 15-19 and Col.8:lines 40-43, phone number is msisdn), and wherein accessing the voicemail account requires providing, by the originating device, a personal identification number (PIN) predefined for the voicemail account (Col.9:lines 47-62, 4 digit passcode); determining, by the voicemail server device, whether the originating device is associated with the subscriber by determining whether the originating MSISDN corresponds to an MSISDN associated with a device of the subscriber (Col.8:lines 40-46 and Col.9:10-22 and lines32-46, the UE receiving input to dial phone number associated with the UE with a secure key. Phone number is msisdn and if secure key from network entity matches, it is “on-network”); responsive to determining that the originating device is not associated with the subscriber (Fig.6:step 608->step 612; Col.9:lines 32-38 and Col.11:lines 8-19, mismatch key and wrong passcode, no association/”not on-network”): automatically activating, by the voicemail server device a request for passcode (Col.11:lines 8-19, additional security measure activated). Ishihara teaches a voicemail system (Par.2 and Par.12) to prevent brute force attacks on a voicemail account associated with a telecommunications network service provider (Par.19-26, Par.29). Responsive to determining that the originating device is not associated with the subscriber (Par.12-15, incorrect pin/passcode): automatically activating, by the voicemail server device, an attempt limit for the voicemail account (Par.12-15, sets 3 attempts, the first failed attempt is counted), wherein the attempt limit corresponds to a predefined number of failed attempts to access the voicemail account by providing an incorrect PIN (Par.15, NG counter=”3”); receiving, by the voicemail server device from the originating device during the voice call, an incorrect PIN that is different from the PIN predefined for the voicemail account (Par.12-16, mismatch); receiving, by the voicemail server device, additional attempts to access the voicemail account by incorrect PINs (Par.16, mismatch occurs three times); and responsive to determining that a number of the additional attempts has reached the attempt limit, automatically redefining, by the voicemail server device, the PIN (Par.29 and Par.34, change to a secondary password) and providing an indication of the redefined PIN to the subscriber (Par.39, Par.33 and Par.49, password change is sent to subscriber B). Therefore, to one of ordinary skill in the art it would have been obvious before the effective filing date of the invention to modify Shaw with the teachings of Ishihara. Shaw’s system determining the originating device is not associated with the subscriber and then using additional security measures can obviously be modified with Ishihara’s teachings of limiting the number of failed attempts to enter a PIN and changing the PIN when the failed attempts exceed a predefined number. The combination would obviously provide a more secure system which makes it harder for someone to continuously try different combinations to gain unauthorized access to voicemail systems. Regarding Claim 8, Shaw and Ishihara teach responsive to determining that the originating device is associated with the subscriber, allowing access to the voicemail account and forgoing activating the attempt limit (Shaw: Col.6:lines 48-62 and Col.9:lines 39-46 and Ishihara: Par.8). Regarding Claim 14, Ishihara teaches wherein the additional attempts are received during additional voice calls from one or more additional originating devices (Par.20-22, additional attempts-10yen per use and from another D (i.e. a different device)), and wherein the one or more additional originating devices are associated with respective MSISDNs that are different from the originating MSISDN (Par.14, D is another device, subscriber B is the originating MSISND). Claims 2 and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Shaw (US 9,204,302) and Ishihara (JP 11008702 A) in further view of Brown (US 8,688,080) Regarding Claims 2 and 17, Ishihara already teaches providing the indication of the redefined PIN to the subscriber (Par.39, Par.33 and Par.49, password change is sent to subscriber B) however Shaw and Ishihara does not teach transmitting, by the voicemail server device via a short message server (SMS), a short message to an MSISDN associated with the subscriber, wherein the short message includes the redefined PIN. Brown teaches transmitting, by the voicemail server device via a short message server (SMS), a short message to an MSISDN associated with the subscriber, wherein the short message includes a PIN/password (Col.4:lines 28-45). A skilled artisan immediately recognizes that Shaw and Ishihara notifies the subscriber of the new pin and by the teachings of Brown, it is obvious that the voicemail server would send the new pin to the subscribers MSISND/phone number via SMS. This would provide an efficient way of providing secure and reliable message transmissions at low cost. Claims 3 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Shaw (US 9204302) and Ishihara (JP 11008702 A) in further view of Brown (8688080) and Cronin (US 20150319169) Regarding Claims 3 and 18, Ishihara already teaches providing the indication of the redefined PIN to the subscriber (Par.39, Par.33 and Par.49, password change is sent to subscriber B) however Shaw and Ishihara do not teach transmitting, by the voicemail server device via a short message server (SMS), a short message to an MSISDN associated with the subscriber, wherein the short message includes the redefined PIN. Brown teaches transmitting, by the voicemail server device via a short message server (SMS), a short message to an MSISDN associated with the subscriber, wherein the short message includes a PIN/password (Col.4:lines 28-45). A skilled artisan immediately recognizes that Shaw and Ishihara notifies the subscriber of the new pin and by the teachings of Brown, it is obvious that the voicemail server would send the new pin to the subscribers MSISND/phone number via SMS. This would provide an efficient way of providing secure and reliable message transmissions at low cost. Shaw, Ishihara, and Brown do not expressly teach the SMS message biometrics protected, requiring the subscriber to provide biometric information prior to providing the subscriber with the indication of the redefined PIN. Cronin teaches that it is well known in the art for a sender of a message to protect the message via biometrics required from the recipient before allowing access to the communication (Par.23). Therefore, to one of ordinary skill in the art it would have been obvious to modify Shaw, Ishihara, and Brown with the teachings of Cronin such that an enhanced system is provided where messages can only be accessed after biometric verification. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Shaw (US 9204302) and Ishihara (JP 11008702 A) in further view of Brown (8688080) and Weaver (US 7,769,146) Regarding Claim 4, Ishihara already teaches providing the indication of the redefined PIN to the subscriber (Par.39, Par.33 and Par.49, password change is sent to subscriber B) however Shaw and Ishihara does not teach transmitting, by the voicemail server device via a short message server (SMS), a short message to an MSISDN associated with the subscriber, wherein the short message includes the redefined PIN. Brown teaches transmitting, by the voicemail server device via a short message server (SMS), a short message to an MSISDN associated with the subscriber, wherein the short message includes a PIN/password (Col.4:lines 28-45). A skilled artisan immediately recognizes that Shaw and Ishihara notifies the subscriber of the new pin and by the teachings of Brown, it is obvious that the voicemail server would send the new pin to the subscribers MSISND/phone number via SMS. This would provide an efficient way of providing secure and reliable message transmissions at low cost. Shaw, Ishihara, and Brown does not expressly teach transmitting, by the voicemail server device, an email message to an email address associated with the subscriber, wherein the email message includes the redefined PIN. Weaver teaches that it is well known concept in the art for a voicemail server to send SMS or Email notification message (Col.4:lines 10-21). Therefore, to one of ordinary skill in the art before the effective filing date of the invention it would have been obvious to modify Shaw, Ishihara, and Brown with the teachings of Weaver such that an enhanced system is provided where the redefined PIN can be sent via email to provide a secure and reliable messaging. Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Shaw (US 9,204,302) and Ishihara (JP 11008702 A) in further view of Cronin (US 20150319169) Regarding Claim 5, Ishihara already teaches providing by the voicemail server device, the indication of the redefined PIN to the subscriber (Par.39, Par.33 and Par.49, password change is sent to subscriber B) however Shaw and Ishihara do not teach causing an authenticator mobile application on the subscriber’s device to provide a notification indicating that the PIN is redefined, and causing the authenticator mobile application to request a two-factor authentication from the subscriber prior to providing the predefined PIN to the subscriber. Cronin teaches, in response to an incoming message, causing an authenticator mobile application on the subscriber’s device (Fig.2, Receivers smartphone 240) to provide a notification indicating that a message has received (Fig.2, “Bob@bob.com has sent a locked message.” Is provided by an authenticator app. Fig.4 and Par.51), and causing the authenticator mobile application to request a two-factor authentication from the subscriber prior to providing the predefined PIN to the subscriber (Fig.2, “Please unlock with your fingerprint”, app requests authentication. Fig.4 and Par.51 combination of biometrics may be used and Par.59, “allows a sender of a first communication to request a first biometric verification and optionally allowing the sender to request additional biometrics and a passcode before the first communication can be interpreted”. This reads on 2-factor). Therefore, to one of ordinary skill in the art before the effective filing date of the invention it would have been obvious to modify Shaw and Ishihara with the teachings of Cronin such that an enhanced system is provided where the redefined PIN can be sent via Text message/email requiring multi-factor authentication to provide a secure and reliable messaging. Claims 6 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Shaw (US 9,204,302) and Ishihara (JP 11008702 A) in further view of OFFICIAL NOTICE. Regarding Claim 6, Ishihara already teaches providing the indication of the redefined PIN to the subscriber (Par.39, Par.33 and Par.49, password change is sent to subscriber B), Shaw and Ishihara do not expressly teach the indication including a link for redefining the PIN using a voicemail administration access portal associated with the voicemail server device. The examiner takes OFFICIAL NOTICE that it is well known in the art to have a message include a link for changing settings of the voicemail box using a voicemail administration access portal associated with the voicemail server device. Therefore, to one of ordinary skill in the art it would have been obvious before the effective filing date of the invention to modify the combined teachings of Shaw and Ishihara with the subject matter of the OFFICIAL notice to provide a system which allows a user to conveniently click a link to redefine/change the PIN as desired for security purposes. Regarding Claim 13, While Ishihara teaches it is known for additional attempts is known (Par.19-20), Shaw and Ishihara do not expressly teach the additional attempts are received during the voice call. The examiner takes OFFICIAL NOTICE that it is well known in the art to have additional attempts received during a voice call. Therefore, to one of ordinary skill in the art it would have been obvious before the effective filing date of the invention to modify the combined teachings of Shaw and Ishihara with the subject matter of the OFFICIAL notice to provide a system which allows a user to conveniently attempt access to their voicemail without having to disconnect and re-establish connection due to accidentally inputting a pin/passcode incorrectly. Allowable Subject Matter Claims 7 and 9-12 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to WESLEY LEO KIM whose telephone number is (571)272-7867. The examiner can normally be reached 9-5:30 M-F. 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. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /WESLEY L KIM/Supervisory Patent Examiner, Art Unit 2648
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Prosecution Timeline

Nov 13, 2024
Application Filed
Jul 21, 2026
Non-Final Rejection mailed — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
61%
Grant Probability
93%
With Interview (+32.5%)
4y 3m (~2y 5m remaining)
Median Time to Grant
Low
PTA Risk
Based on 347 resolved cases by this examiner. Grant probability derived from career allowance rate.

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