Applicant: InterDigital Patent Holdings, Inc.
`Application N0.: 15/413,072
`
`REMARKS/ARGUMENTS
`
`After the foregoing Amendment, claims 1-2, 8-12, 14-17, and 19-20 are
`
`currently pending in this application with claims 1, 11 and 16 being independent.
`
`Claims 6 and 7 have been canceled without prejudice. Claims 3-5, 13 and 18 were
`
`previously canceled. Claims 1, 11, and 16 are amended.
`
`Claim Reiections - 35 U.S.C. § 103
`
`Claims 1, 2, 11, 12, 16, and 17 are rejected under pre-AlA 35 U.S.C. 103(a) as
`
`being unpatentable over to Yu et al. (US 2011/0098043) (hereinafter Yu) in view of
`
`Pirzada et al. (US 2006/007 3847) (hereinafter Pirzada).
`
`Claims 8, 15, and 20, are rejected under pre-AlA 35 U.S.C. 103(a) as being
`
`unpatentable over Yu and Pirzada as applied to claims 1, 11, and 16 above, and
`
`further in view of Hakola et al. (US 2013/0013926) (hereinafter Hakola).
`
`Claim 9 is rejected under pre-AlA 35 U.S.C. 103(a) as being unpatentable
`
`over Yu as applied to claim 1 above, and further in view of Van Phan et al.
`
`(US 2015/0065154) (hereinafter Van Phan).
`
`Claims 10, 14, and 19, are rejected under pre-AlA 35 U.S.C. 103(a) as being
`
`unpatentable over Yu and Pirzada as applied to claims 1, 11, and 16 above, and
`
`further in view of Fodor et al. (US 2014/0122607) (hereinafter Fodor).
`
`Applicant respectively traverses the rejection and submits that independent
`
`claims 1, 11, and 16 recite features not taught, suggested, or otherwise yielded by
`
`the cited reference.
`
`
`Application N0.: 15/413,072
`
`REMARKS/ARGUMENTS
`
`After the foregoing Amendment, claims 1-2, 8-12, 14-17, and 19-20 are
`
`currently pending in this application with claims 1, 11 and 16 being independent.
`
`Claims 6 and 7 have been canceled without prejudice. Claims 3-5, 13 and 18 were
`
`previously canceled. Claims 1, 11, and 16 are amended.
`
`Claim Reiections - 35 U.S.C. § 103
`
`Claims 1, 2, 11, 12, 16, and 17 are rejected under pre-AlA 35 U.S.C. 103(a) as
`
`being unpatentable over to Yu et al. (US 2011/0098043) (hereinafter Yu) in view of
`
`Pirzada et al. (US 2006/007 3847) (hereinafter Pirzada).
`
`Claims 8, 15, and 20, are rejected under pre-AlA 35 U.S.C. 103(a) as being
`
`unpatentable over Yu and Pirzada as applied to claims 1, 11, and 16 above, and
`
`further in view of Hakola et al. (US 2013/0013926) (hereinafter Hakola).
`
`Claim 9 is rejected under pre-AlA 35 U.S.C. 103(a) as being unpatentable
`
`over Yu as applied to claim 1 above, and further in view of Van Phan et al.
`
`(US 2015/0065154) (hereinafter Van Phan).
`
`Claims 10, 14, and 19, are rejected under pre-AlA 35 U.S.C. 103(a) as being
`
`unpatentable over Yu and Pirzada as applied to claims 1, 11, and 16 above, and
`
`further in view of Fodor et al. (US 2014/0122607) (hereinafter Fodor).
`
`Applicant respectively traverses the rejection and submits that independent
`
`claims 1, 11, and 16 recite features not taught, suggested, or otherwise yielded by
`
`the cited reference.
`
`
`
`Applicant: InterDigital Patent Holdings, Inc.
`Application N0.: 15/413,072
`
`Claim 1, as amended herein, recites in part:
`
`A method for establishing a wireless local area network .
`
`.
`
`. comprising:
`
`transmitting a configuration message with configuration information
`
`associated with the second WLAN ProSe capable WTRU
`
`wherein the configuration message with configuration information
`
`associated with the second WLAN ProSe capable WTRU is an
`
`indication to establish the WLAN ProSe connection.
`
`Claims 11 and 16, as amended herein, recite similar language.
`
`None of the cited references, alone or in combination, teach or suggest that
`
`transmitting the configuration message is an indication to establish the WLAN
`
`ProSe connection. Yu teaches a method in which the DRSF supplies parameters
`
`such as allocated channel, data rate, and maximum allocated transmit power by
`
`generating a resource allocation token, which the “DRSF .
`
`.
`
`. provides to at least one
`
`of the terminal apparatuses that is party to the D2D connection.” In paragraph
`
`[0074], the DRSF “includlesl [the] resource allocation token in a D2D connection
`
`establishment response that may be sent .
`
`.
`
`. in response to a D2D connection
`
`establishment request.” (emphasis added).
`
`Nothing in Yu indicates implicitly or explicitly that the resource allocation
`
`token directs initiation of the D2D connection. To the contrary, paragraph [0074]
`
`explains that the role of the resource allocation token is “to limit the possibility of
`
`-8-
`
`
`
`Applicant: InterDigital Patent Holdings, Inc.
`Application N0.: 15/413,072
`
`the D2D connection interfering with in-band cellular communications.” As
`
`Paragraphs [0083],
`
`[0091], and [0107] thus further support, resource allocation
`
`merely facilitates establishment of the D2D connection by designating the necessary
`
`parameters. Yu does not mention any additional contents or purposes of the
`
`connection establishment response along with which the resource allocation token is
`
`sent and, therefore, is silent with respect to any indicative role of such message.
`
`Neither Pirzada nor Hakola correct this deficiency. Pirzada teaches a method
`
`for switching between infrastructure and ad-hoc modes of communication in an
`
`access point station without assistance from a cellular network. It does not teach a
`
`network transmitting a configuration message as any indication to establish a
`
`WLAN ProSe connection.
`
`While Hakola does discuss methods for facilitating transition from a cellular
`
`connection to
`
`a D2D connection,
`
`the reference
`
`teaches
`
`away from any
`
`implementation wherein the configuration message indicates to establish a
`
`connection. Paragraphs [0039] describes the MME generating a D2D security key
`
`combination value and “sending the D2D security key combination value to each of
`
`the mobile terminals separately, via individualized, secured connections to each
`
`respective mobile terminal.” Paragraph [0040] describes the mobile terminals
`
`deconstructing the D2D security key combination value to determine a peer device’s
`
`D2D security key.
`
`Finally, Paragraph [0041]
`
`then explains that
`
`the mobile
`
`terminal uses the security key combination to cipher and decipher outgoing and
`
`
`
`Applicant: InterDigital Patent Holdings, Inc.
`Application N0.: 15/413,072
`
`incoming communications. Nowhere does Hakola discuss the security configuration
`
`information triggering a D2D connection.
`
`Rather, Hakola teaches the network transmitting an indication to start the
`
`D2D connection that is independent of the configuration information. For instance,
`
`paragraph [0036] describes the “eNB send[ing] a communications node change
`
`command to the mobile terminals .
`
`.
`
`. to t_riggg the mobile terminals to transition to
`
`a D2D communications session.” (emphasis added). As in Yu, paragraphs [0042]-
`
`[0043] make clear that the D2D security key combination is merely included
`
`alongside the command change command, and itself does not serve as an indication
`
`to establish a D2D connection.
`
`Therefore, amended claims 1, 11, and 16 are not obvious over Yu in view of
`
`Pirzada, and further in view of Hakola, and the Applicant believes these claims are
`
`allowable over all cited references of record.
`
`Claims 2, 8-10, 12, 14-15, 17, 19, and 20 are ultimately dependent on one of
`
`claims 1, 11 and 16, which the Applicant believes are patentable as set forth above.
`
`As claims 2, 8-10, 12, 14-15, 17, 19, and 20 each depend from an allowable claim,
`
`Applicant respectfully submits that claims 2, 8-10, 12, 14-15, 17, 19, and 20 are
`
`similarly allowable.
`
`Based on the arguments presented above, withdrawal of the 35 U.S.C. 103
`
`rejections is respectfully requested.
`
`-10-
`
`
`
`Applicant: InterDigital Patent Holdings, Inc.
`Application N0.: 15/413,072
`
`Conclusion
`
`If the Examiner believes that any additional minor formal matters need to be
`
`addressed in order to place this application in condition for allowance, or that a
`
`telephonic interview will help to materially advance the prosecution of this
`
`application, the Examiner is invited to contact the undersigned by telephone at the
`
`Examiner's convenience.
`
`In view of the foregoing, Applicant respectfully submits that the present
`
`application,
`
`including claims 1, 2, 8-12, 14-17, 19 and 20,
`
`is in condition for
`
`allowance and a notice to that effect is respectfully requested.
`
`Respectfully submitted,
`
`InterDigital Patent Holdings, Inc.
`
`By /Wesley T. McMichael/
`Wesley T. McMichael
`Registration No. 56,982
`
`Volpe and Koenig, PC.
`30 South 17th Street, 18th Fl.
`
`Philadelphia, PA 19103-4009
`Telephone: (215) 568-6400
`Facsimile:
`(215) 568-6499
`
`WTM/srp
`
`-11-
`
`
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