Prosecution Insights
Last updated: October 25, 2026
Application No. 19/010,912

ELECTRONIC DEVICE FOR ALLOCATING TRANSMIT POWER BASED ON HOUSING STATE

Non-Final OA §103
Filed
Jan 06, 2025
Priority
Jul 10, 2024 — RE 10-2024-0091329
Examiner
HUANG, WEN WU
Art Unit
2648
Tech Center
2600 — Communications
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
73%
Grant Probability
Favorable
1-2
OA Rounds
1y 4m
Est. Remaining
89%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
605 granted / 828 resolved
+11.1% vs TC avg
Strong +16% interview lift
Without
With
+15.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
39 currently pending
Career history
888
Total Applications
across all art units

Statute-Specific Performance

§101
2.6%
-37.4% vs TC avg
§103
67.8%
+27.8% vs TC avg
§102
18.9%
-21.1% vs TC avg
§112
4.6%
-35.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 828 resolved cases

Office Action

§103
DETAILED ACTION 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 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim(s) 1 and 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koshy (US 20190036563 A1) in view of Zhou (US 20250106785 A1). Regarding claim 1, Koshy teaches an electronic device (Koshy discloses a convertible information handling system 100/600, para. 001,70-72) comprising: a first housing (Koshy discloses a "tablet head portion with a display screen" (display screen portion 605)); a second housing connected to the first housing (Koshy discloses a "keyboard base portion 610 connected via hinge 615"); a transmitter comprising a plurality of antennas, the transmitter configured to control the plurality of antennas to transmit signals (Koshy discloses a wireless interface adapter (transmitter) and a plurality of co-located antennas (WLAN/WWAN) configured to transmit signals, para. 0050-52,113-15, fig. 5, antennas 520,522,524,526), the plurality of antennas being respectively in the first housing or the second housing (Antennas are located in different hinged portions (tablet display head portion vs. keyboard base portion), para. 0098-102); and a communication processor configured to allocate transmit power of each of the plurality of antennas, the communication processor comprising a controller configured to: detect a housing state between the first housing and the second housing (Koshy uses sensors to detect the relative hinge angle or physical "orientation mode" between the first housing and the second housing, which corresponds to the "housing state." This is used to adjust maximum SAR transmit power limits dynamically); and allocate transmit power to one or more transmit antennas from among the plurality of antennas based on the detected housing state (Koshy's processor dynamically prioritizes and apportions transmit power among active wireless links). Koshy is silent to teaching that configured to calculate a consumed total exposure ratio (TER) value of each of the plurality of antennas based on a housing state; and allocate transmit power to one or more transmit antennas from among the plurality of antennas based on the consumed TER value. In the same field of endeavor, Zhou teaches a device configured to calculate a consumed total exposure ratio (TER) value of each of the plurality of antennas based on a housing state (Zhou's calculation module calculates a "consumed total exposure ratio (TER) value" representing the sum of exposure ratios across the plurality of active antennas using a time average algorithm, para.0112. It determines co-located antenna proximity ("first distance") using pre-configured antenna location relationship tables as the housing state); and allocate transmit power to one or more transmit antennas from among the plurality of antennas based on the consumed TER value (Zhou determines and allocates transmit power to the active antennas based on the calculated exposure ratio/TER (even allocation, preferential, service type, signal strength) to maintain TER ≤ 1, para. 0016,35). Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention would have been highly motivated to combine the teachings of Koshy and Zhou. Koshy teaches that convertible, 2-in-1 devices (changing between laptop, tablet, tent, and easel modes) present highly variable user exposure profiles. The physical orientation of the housings directly dictates which surfaces contact the user's body. Consequently, Koshy dynamically adjusts overall regulatory maximum power limits based on the detected physical housing mode (e.g., restricting transmission power to a lower 14 dBm in tablet mode where body contact is likely, while allowing up to 18 dBm in laptop mode where contact risks are reduced). Zhou teaches that to prevent dangerous radiation superposition during simultaneous multi-antenna transmissions, the device must monitor and maintain a cumulative Total Exposure Ratio (TER) such that the sum of the individual antennas' exposure ratios remains less than or equal to 1 (TER≤1). Because folding or unfolding the housings of a convertible device physically changes the distance between antennas and the user's body, it directly alters the regulatory safety limits of the active antennas. Combining the references allows the communication processor to dynamically update the TER limits and exposure denominators in real-time based on the physical configuration of the housings, ensuring continuous, adaptive regulatory safety in all operating modes. Regarding claim 12, Koshy teaches an operation method of an electronic device, the electronic device comprising a first housing, a second housing connected to the first housing (Koshy discloses a "tablet head portion with a display screen" (display screen portion 605), a "keyboard base portion 610 connected via hinge 615"), a transmitter comprising a plurality of antennas respectively in the first housing or the second housing and the transmitter configured to control the plurality of antennas to transmit signals, and a communication processor configured to allocate transmit power of each of the plurality of antennas (Koshy discloses a wireless interface adapter (transmitter) and a plurality of co-located antennas (WLAN/WWAN) configured to transmit signals, para. 0050-52,113-15, fig. 5, antennas 520,522,524,526), the operation method comprising: detecting, via the communication processor, a housing state between the first housing and the second housing (Koshy uses sensors to detect the relative hinge angle or physical "orientation mode" between the first housing and the second housing, which corresponds to the "housing state." This is used to adjust maximum SAR transmit power limits dynamically); and allocating, via the communication processor, transmit power to one or more transmit antennas from among the plurality of antennas based on the detected housing state (Koshy's processor dynamically prioritizes and apportions transmit power among active wireless links). Koshy is silent to teaching that configured to calculating a consumed total exposure ratio (TER) value of each of the plurality of antennas based on a housing state; and allocating transmit power to one or more transmit antennas from among the plurality of antennas based on the consumed TER value. In the same field of endeavor, Zhou teaches a method comprising calculating a consumed total exposure ratio (TER) value of each of the plurality of antennas based on a housing state (Zhou's calculation module calculates a "consumed total exposure ratio (TER) value" representing the sum of exposure ratios across the plurality of active antennas using a time average algorithm, para.0112. It determines co-located antenna proximity ("first distance") using pre-configured antenna location relationship tables as the housing state); and allocating transmit power to one or more transmit antennas from among the plurality of antennas based on the consumed TER value (Zhou determines and allocates transmit power to the active antennas based on the calculated exposure ratio/TER (even allocation, preferential, service type, signal strength) to maintain TER ≤ 1, para. 0016,35). Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention would have been highly motivated to combine the teachings of Koshy and Zhou. Koshy teaches that convertible, 2-in-1 devices (changing between laptop, tablet, tent, and easel modes) present highly variable user exposure profiles. The physical orientation of the housings directly dictates which surfaces contact the user's body. Consequently, Koshy dynamically adjusts overall regulatory maximum power limits based on the detected physical housing mode (e.g., restricting transmission power to a lower 14 dBm in tablet mode where body contact is likely, while allowing up to 18 dBm in laptop mode where contact risks are reduced). Zhou teaches that to prevent dangerous radiation superposition during simultaneous multi-antenna transmissions, the device must monitor and maintain a cumulative Total Exposure Ratio (TER) such that the sum of the individual antennas' exposure ratios remains less than or equal to 1 (TER≤1). Because folding or unfolding the housings of a convertible device physically changes the distance between antennas and the user's body, it directly alters the regulatory safety limits of the active antennas. Combining the references allows the communication processor to dynamically update the TER limits and exposure denominators in real-time based on the physical configuration of the housings, ensuring continuous, adaptive regulatory safety in all operating modes. Claim(s) 2, 7, 13, 18 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koshy and Zhou as applied to claims 1 and 12 above, and further in view of Sambhwani (US 20220408378 A1). Regarding claim 2, the combination of Koshy and Zhou teaches the electronic device of claim 1. The combination of Koshy and Zhou is silent to teaching that wherein the controller is further configured to: determine a device state based on the housing state at a consumption time point and the housing state at a current time point; calculate a window TER value at the consumption time point based on the device state; and calculate the consumed TER value based on window TER values at time points that are included in a TER measurement interval. In the same field of endeavor, Sambhwani teaches a device wherein the controller is further configured to: determine a device state based on the housing state at a consumption time point and the housing state at a current time point (Sambhwani’s controller tracks changes in the physical operating environment of the device—defined as the "device position" or "device state" (e.g., spending the first 30 seconds of an averaging period adjacent to a user's head, and the subsequent 30 seconds on the user's body). It uses sensors to detect these transitions over time, para. 0049,73); calculate a window TER value at the consumption time point based on the device state (Sambhwani divides the rolling averaging period into finite, smaller subperiods (consumption time points). For each subperiod, the calculator computes an "instantaneous RFE metric value" (window TER value) by multiplying the conducted transmit power by the antenna coefficient (C) that is mapped to that specific device position/state. Under BRI, this instantaneous RFE metric includes a Total Exposure Ratio (TER) combining SAR and MPE, para. 0028,36,50-53); and calculate the consumed TER value based on window TER values at time points that are included in a TER measurement interval (Sambhwani teaches calculating a cumulative "consumed RFE metric value" (consumed TER value) by averaging the instantaneous window TER values gathered across the elapsed subperiods included in the larger rolling averaging window, i.e., "TER measurement interval"), para. 0053-55). Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention would have been motivated to combine the teachings of Koshy and Sambhwani. To prevent exceeding Specific Absorption Rate (SAR) limits, Koshy's system relies on hardware trigger sensors (accelerometers/gyroscopes) to detect when the device enters a high-exposure configuration (like tablet mode) and dynamically restricts transmission to a lower, static "cutback" power limit. Sambhwani teaches that instead of relying on rigid, static power caps, a device can implement time-domain averaging of RF exposure metrics. A PHOSITA would be highly motivated to apply Sambhwani's time-domain averaging to Koshy's convertible computer. Rather than permanently throttling the co-located antennas to a conservative, low-power state the moment Koshy's sensors detect tablet mode, the combined system can leverage Sambhwani's remaining exposure budget. This allows the device to deliver high-speed bursts of data in tablet mode when the historical exposure budget is low, maximizing wireless throughput without ever compromising user safety. Regarding claim 7, the combination of Koshy and Zhou teaches the electronic device of claim 1. The combination of Koshy and Zhou is silent to teaching that wherein the controller is further configured to: calculate a residual TER value based on the consumed TER value and a limit TER value; and allocate the transmit power to the one or more transmit antennas, based on the residual TER value. In the same field of endeavor, Sambhwani teaches a device wherein the controller is further configured to: calculate a residual TER value based on the consumed TER value and a limit TER value; and allocate the transmit power to the one or more transmit antennas, based on the residual TER value (Sambhwani's remaining RFE budget calculator 66 explicitly calculates a "remaining RFE budget" (residual TER value) for the averaging window based on the difference between the assigned RFE budget (limit TER) and the cumulative "consumed average exposure value". RFE budget conversion circuitry 36 uses this remaining/residual budget to calculate a revised maximum transmit power level. The transmitter then restricts or scales subsequent signal transmissions during the next subperiod to remain subject to this P LIMIT​, para. 0055-58,79) Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention would have been motivated to combine the teachings of Koshy and Sambhwani. To prevent exceeding Specific Absorption Rate (SAR) limits, Koshy's system relies on hardware trigger sensors (accelerometers/gyroscopes) to detect when the device enters a high-exposure configuration (like tablet mode) and dynamically restricts transmission to a lower, static "cutback" power limit. Sambhwani teaches that instead of relying on rigid, static power caps, a device can implement time-domain averaging of RF exposure metrics. A PHOSITA would be highly motivated to apply Sambhwani's time-domain averaging to Koshy's convertible computer. Rather than permanently throttling the co-located antennas to a conservative, low-power state the moment Koshy's sensors detect tablet mode, the combined system can leverage Sambhwani's remaining exposure budget. This allows the device to deliver high-speed bursts of data in tablet mode when the historical exposure budget is low, maximizing wireless throughput without ever compromising user safety. Regarding claims 13 and 18, the dependent claims are interpreted and rejected for the same reasons as set forth above in claims 2 and 7, respectively. Regarding claim 19, Koshy teaches an electronic device comprising: a first housing (Koshy discloses a "tablet head portion with a display screen" (display screen portion 605)); a second housing connected to the first housing (Koshy discloses a "keyboard base portion 610 connected via hinge 615"); a transmitter comprising a plurality of antennas and the transmitter configured to control the plurality of antennas to transmit signals (Koshy discloses a wireless interface adapter (transmitter) and a plurality of co-located antennas (WLAN/WWAN) configured to transmit signals, para. 0050-52,113-15, fig. 5, antennas 520,522,524,526), the plurality of antennas being respectively in the first housing or the second housing (Antennas are located in different hinged portions (tablet display head portion vs. keyboard base portion), para. 0098-102); and a communication processor configured to allocate transmit power of each of the plurality of antennas, the communication processor comprising a controller configured to: determine a device state based on a housing state between the first housing and the second housing at a current time point (Koshy uses sensors to detect the relative hinge angle or physical "orientation mode" between the first housing and the second housing, which corresponds to the "housing state." This is used to adjust maximum SAR transmit power limits dynamically); and allocate transmit power to one or more transmit antennas from among the plurality of antennas (Koshy's processor dynamically prioritizes and apportions transmit power among active wireless links). Koshy is silent to teaching that configured to determine a device state at a consumption time point; calculate a consumed total exposure ratio (TER) value of each of the plurality of antennas based on the device state; and allocate transmit power to one or more transmit antennas from among the plurality of antennas based on the consumed TER value. In the same field of endeavor, Zhou teaches a device configured to calculate a consumed total exposure ratio (TER) value of each of the plurality of antennas based on the device state (Zhou's calculation module calculates a "consumed total exposure ratio (TER) value" representing the sum of exposure ratios across the plurality of active antennas using a time average algorithm, para.0112. It determines co-located antenna proximity ("first distance") using pre-configured antenna location relationship tables as the housing state); and allocate transmit power to one or more transmit antennas from among the plurality of antennas based on the consumed TER value (Zhou determines and allocates transmit power to the active antennas based on the calculated exposure ratio/TER (even allocation, preferential, service type, signal strength) to maintain TER ≤ 1, para. 0016,35). Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention would have been highly motivated to combine the teachings of Koshy and Zhou. Koshy teaches that convertible, 2-in-1 devices (changing between laptop, tablet, tent, and easel modes) present highly variable user exposure profiles. The physical orientation of the housings directly dictates which surfaces contact the user's body. Consequently, Koshy dynamically adjusts overall regulatory maximum power limits based on the detected physical housing mode (e.g., restricting transmission power to a lower 14 dBm in tablet mode where body contact is likely, while allowing up to 18 dBm in laptop mode where contact risks are reduced). Zhou teaches that to prevent dangerous radiation superposition during simultaneous multi-antenna transmissions, the device must monitor and maintain a cumulative Total Exposure Ratio (TER) such that the sum of the individual antennas' exposure ratios remains less than or equal to 1 (TER≤1). Because folding or unfolding the housings of a convertible device physically changes the distance between antennas and the user's body, it directly alters the regulatory safety limits of the active antennas. Combining the references allows the communication processor to dynamically update the TER limits and exposure denominators in real-time based on the physical configuration of the housings, ensuring continuous, adaptive regulatory safety in all operating modes. The combination of Koshy and Zhou is silent to teaching that configured to determine a device state at a consumption time point. In the same field of endeavor, Sambhwani teaches a device wherein the controller is further configured to: determine a device state based on the housing state at a consumption time point and the housing state at a current time point (Sambhwani’s controller tracks changes in the physical operating environment of the device—defined as the "device position" or "device state" (e.g., spending the first 30 seconds of an averaging period adjacent to a user's head, and the subsequent 30 seconds on the user's body). It uses sensors to detect these transitions over time, para. 0049,73); Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention would have been motivated to combine the teachings of Koshy and Sambhwani. To prevent exceeding Specific Absorption Rate (SAR) limits, Koshy's system relies on hardware trigger sensors (accelerometers/gyroscopes) to detect when the device enters a high-exposure configuration (like tablet mode) and dynamically restricts transmission to a lower, static "cutback" power limit. Sambhwani teaches that instead of relying on rigid, static power caps, a device can implement time-domain averaging of RF exposure metrics. A PHOSITA would be highly motivated to apply Sambhwani's time-domain averaging to Koshy's convertible computer. Rather than permanently throttling the co-located antennas to a conservative, low-power state the moment Koshy's sensors detect tablet mode, the combined system can leverage Sambhwani's remaining exposure budget. This allows the device to deliver high-speed bursts of data in tablet mode when the historical exposure budget is low, maximizing wireless throughput without ever compromising user safety. Claim(s) 8-10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koshy and Zhou as applied to claim 1 above, and further in view of CURTISS (US 20220086770 A1). Regarding claim 8, the combination of Koshy and Zhou teaches the electronic device of claim 1. The combination of Koshy and Zhou is silent to teaching that wherein the communication processor further comprises a memory comprising: an antenna index buffer storing a used-antenna index indicating one or more used-antennas that are used in each window; and a used-power buffer storing used power of an antenna that corresponds to the used-antenna index. In the same field of endeavor, CURTISS teaches a device wherein the communication processor further comprises a memory (CURTISS teaches an apparatus for wireless communication comprising a processor 608 and a memory 610 (which can be static memory or non-volatile memory separate from a general file system) that stores RF exposure information associated with a rolling time window, para. 0078,94) comprising: an antenna index buffer storing a used-antenna index indicating one or more used-antennas that are used in each window (Curtiss teaches that the stored RF exposure info includes "an antenna parameter indicating one or more antennas used for transmission (i.e., active antennas)", which is recorded for the respective transmit scenario. Under BRI, a parameter or index identifying active, transmitting antennas corresponds directly to a "used-antenna index", and the static/non-volatile memory registers storing this parameter over time function as an "antenna index buffer", para. 0072,94-96); and a used-power buffer storing used power of an antenna that corresponds to the used-antenna index (Curtiss teaches that the memory stores the "history of transmission powers" or "transmission powers within the time window". Under BRI, storing raw or conducted transmit powers corresponding to the active transmit scenario/antennas represents a "used-power buffer"). Therefore, a Person Having Ordinary Skill in the Art (PHOSITA) would have been highly motivated to combine the folding, multi-housing physical design of Koshy with the exception-robust memory buffer architecture of CURTISS at the time of the invention. By combining the references, the device can use Curtiss’s non-volatile memory and PMIC counter to preserve and recover the time-averaged exposure history. This ensures that the device remains continuously safe and compliant across reboot boundaries, even if the physical "housing state" (antenna distance) is changed mid-reset. Regarding claim 9, the combination of Koshy, Zhou and CURTISS teaches the electronic device of claim 8, wherein the controller is further configured to: read the used-antenna index from the antenna index buffer; read, from the used-power buffer, the used power of the antenna corresponding to the used- antenna index; and calculate a window TER value based on the used-antenna index and the used power (Under simultaneous transmission (such as MIMO), Curtiss's processor calculates a combined normalized SAR/PD distribution (which represents a Total Exposure Ratio [TER] combining active antenna exposure ratios relative to safety limits). This calculation is performed by reading the active antenna identifier (index i) and scaling the stored SAR distribution by the actual conducted transmit power level (Tx i), para. 0065,86-92). Regarding claim 10, the combination of Koshy, Zhou and CURTISS teaches the electronic device of claim 8, wherein the memory further comprises a housing state buffer storing the housing state at a time point corresponding to each window (CURTISS teaches that normalized SAR/PD distributions are stored in memory for different "transmit scenarios". Each scenario is defined in part by an "antenna parameter indicating one or more antennas used for transmission (i.e., active antennas)". In a multi-antenna device, activating a specific combination of co-located antennas inherently establishes a specific three-dimensional spatial separation or physical distance between the active radiating elements. Because Curtiss periodically logs these transmit scenario parameters (including the active antenna parameters) to memory alongside timestamps corresponding to each sub-window interval, it is storing a historical record of the active antenna arrangement (the active "antenna distance"). Under BRI, this scenario registry functions as a "housing state buffer", para. 0055,72-86,92). Allowable Subject Matter Claims 3-4, 14-17 and 20 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 The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Black: US 20240364376 A1; Klomsdorf: US 20220182473 A1; NADAKUDUTI: US 20250097858 A1; Sahoo: US 20200106468 A1; Wu: US 20200120616 A1 Any inquiry concerning this communication or earlier communications from the examiner should be directed to WEN WU HUANG whose telephone number is (571)272-7852. The examiner can normally be reached Mon-Fri 10-6. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Wesley Kim can be reached at (571) 272-7867. 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. /WEN W HUANG/Primary Examiner, Art Unit 2648
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Prosecution Timeline

Jan 06, 2025
Application Filed
Aug 10, 2026
Non-Final Rejection mailed — §103
Oct 15, 2026
Applicant Interview (Telephonic)
Oct 15, 2026
Examiner Interview Summary

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