US 12395899

US Patent 12395899: Negotiation of Quality of Service (QoS) Information for Network Management Traffic in a Wireless Local Area Network (WLAN)

Assignee: Malikie Innovations Ltd
Inventors: Stephen McCann, Michael Peter Montemurro
Filing Date: 2024-03-27
Issue Date: 2025-08-19
Abstract: An access point advertises a management frame quality of service (MFQ) policy that defines an access category used for transmitting a first type of management frame. Each mobile station associated with the access point is to prioritize transmission of management frames according to the MFQ policy advertised by the access point, unless a policy configuration request for the mobile station to prioritize transmission of management frames according to a different MFQ policy has been accepted.

Plain-Language Overview of Independent Claims:

Claim 1 (Method for a Wireless Station): This claim describes a method for a wireless station (mobile station) to handle management frame prioritization. It involves three main steps:

1. Receiving an "extended capabilities element" from an access point (AP), which indicates that the AP supports prioritizing management frames.
2. Receiving a "management frame quality of service (MFQ) policy" from the AP. This policy specifies an "access category" for transmitting a particular type of management frame. The key here is that management frames are separate from data frames.
3. Transmitting a "policy configuration request" to the AP to ask for a change to the received MFQ policy.

Claim 10 (Mobile Station): This claim describes a mobile station (STA) that performs the method outlined in Claim 1. It specifies that the mobile station includes a processor and memory. The memory stores instructions that, when executed by the processor, cause the mobile station to:

1. Receive an extended capabilities element from an AP indicating support for management frame prioritization.
2. Receive an MFQ policy from the AP that defines an access category for a specific type of management frame, where management frames are distinct from data frames.
3. Transmit a policy configuration request to ask for a change to the MFQ policy.

Claim 15 (Method for an Access Point): This claim describes a method for an access point (AP) to manage management frame prioritization. It also involves three main steps:

1. Transmitting an extended capabilities element to a mobile station, indicating that the AP supports prioritizing management frames.
2. Transmitting an MFQ policy to the mobile station that defines an access category for a particular type of management frame, emphasizing that management frames are distinct from data frames.
3. Receiving a policy configuration request from the mobile station, asking for a change to the MFQ policy.

Claim 18 (Access Point): This claim describes an access point (AP) that performs the method outlined in Claim 15. It specifies that the access point includes a processor and memory. The memory stores instructions that, when executed by the processor, cause the access point to:

1. Transmit an extended capabilities element to a mobile station, indicating support for management frame prioritization.
2. Transmit an MFQ policy to the mobile station that defines an access category for a specific type of management frame, where management frames are distinct from data frames.
3. Receive a policy configuration request from the mobile station, asking for a change to the MFQ policy.

Uncertainty Regarding CAFC Dockets:
A search of CAFC 2026 dockets for patent number US12395899 did not return any direct results indicating ongoing litigation or challenges related to this specific patent. Therefore, there is no authoritative information from the performed search to suggest any current legal status beyond "Active" as indicated by Google Patents.

As of April 26, 2026, a search for litigation involving US patent 12395899 did not return any direct results from the specified patent litigation search sites or general web searches.

Therefore, there is no known litigation involving US patent 12395899 at this time, based on the performed search.

To comprehensively search for federal court records, including patent litigation, one would typically use the Public Access to Court Electronic Records (PACER) service. PACER allows users with an account to search for appellate, district, and bankruptcy court case and docket information nationwide. Case information on PACER is updated daily, and specific court records are updated in real-time. Records for cases filed on or after March 1, 2012, are generally available through PACER. The U.S. Court of Appeals for the Federal Circuit (CAFC) also provides case information and documents through PACER for cases filed after March 1, 2012.

Proceedings overview

There are no AIA trial proceedings (Inter Partes Review, Post-Grant Review, or Covered Business Method) on file for US Patent 12395899 as of 2026-07-23. The USPTO Open Data Portal API returns no results, and web searches for "PTAB US12395899", "IPR US12395899", "PGR US12395899", and "CBM US12395899" did not surface any specific proceedings. This means the patent has not been challenged in an AIA trial before the Patent Trial and Appeal Board.

Strategic summary

Currently, all claims (1-20) of US Patent 12395899 remain untested by any AIA trial proceeding. There are no canceled or sustained claims from PTAB decisions, meaning the patent's validity has not been adjudicated by the Board. This implies that all claims are currently considered patentable as issued.

The estoppel landscape is entirely open. Since no PTAB proceedings have occurred, there are no prior-art grounds that would be barred under 35 U.S.C. § 315(e)(2) for a future petitioner. Any prior-art grounds that could have been raised in an IPR or PGR are still available for a potential challenger. There is no pattern of filings by any specific petitioner, nor is there any indication of aggressive PTAB appeals by the patent owner or involvement of defensive aggregators.

Recommended next steps

If you are a defendant facing assertion of US Patent 12395899, the absence of PTAB activity suggests that the patent has not yet undergone the rigorous scrutiny of an AIA trial. This can be both an advantage and a disadvantage:

• Advantage: All prior art grounds are potentially available for a challenge. An IPR or PGR petition could be filed against the patent, presenting a fresh opportunity to invalidate the claims.
• Disadvantage: Without prior PTAB decisions, there's no existing roadmap of what arguments or prior art the Board might find compelling, and the patent owner has not had to defend its claims against such challenges.

Given the current situation, recommended next steps include:

1. Conduct a comprehensive prior art search: Since the patent has not been tested, a thorough search for prior art relevant to claims 1-20 (the independent claims are 1, 10, 15, and 18) could reveal strong grounds for an IPR or PGR.
2. Evaluate the claims for patentability challenges: Assess claims 1-20 against relevant prior art under 35 U.S.C. § 102 (novelty) and § 103 (obviousness), and potentially § 112 (written description, enablement, definiteness) if applicable.
3. Consider filing an AIA trial petition: If strong prior art is identified, filing an IPR or PGR petition could be a viable defense strategy. This would force the patent owner to defend the validity of its claims before the PTAB.

Inventors

• Stephen McCann: Employer at time of filing is not explicitly stated in the patent document.
• Michael Peter Montemurro: Employer at time of filing is not explicitly stated in the patent document.

The patent US12395899 is a continuation of a family of patents tracing priority back to a Canadian application filed March 15, 2010. The current patent's filing date is March 27, 2024. The named inventors' employment at the time of the original priority filing (2010) or the current patent's filing (2024) is not detailed. However, the original assignee for the earliest related application (US13/045,658) was Research In Motion Limited (now BlackBerry Limited).

Original assignee

The entity named on the issued patent US12395899 is Malikie Innovations Ltd.

Information regarding whether Malikie Innovations Ltd ships products embodying the claims, its primary line of business, or its current operating status is not readily available through public search results. The company's name "Malikie Innovations Ltd" suggests a focus on intellectual property or innovation, but this alone is not definitive.

Assignment timeline

A search of the USPTO Patent Assignment Search database for patent number US12395899 (as of 2026-07-23) returned no recorded assignments for this specific patent.

However, public information from other sources indicates a significant transfer of patents involving the original priority holder, BlackBerry Limited, to Malikie Innovations Ltd.

Specifically:

• In March 2023, Malikie Innovations Ltd. (a subsidiary of Irish patent monetization firm Key Patent Innovations Limited (KPI)) acquired a large portfolio of approximately 32,000 patents from BlackBerry Limited. This deal involved the sale of "substantially all of [BlackBerry's] non-core patents and patent applications" related to mobile devices, messaging, and wireless networking.
• Malikie Innovations is described as a patent assertion entity focused on licensing these patents.

While the direct assignment record for US12395899 is not found on the USPTO Assignment Center search, the ownership chain is established through the larger portfolio acquisition. The current patent (US12395899B2) is a continuation of earlier applications originally filed by Research In Motion Limited (which became BlackBerry Limited). The fact that this specific patent application (filed March 27, 2024, and issued August 19, 2025) names Malikie Innovations Ltd as the original assignee means that the patent was issued directly to Malikie, presumably as a result of the earlier portfolio transfer agreement with BlackBerry. Therefore, there are no post-issuance assignment records to list for this patent in the USPTO database.

Timeline diagram

timeline
    title Ownership of US 12395899
    2010 : Priority date (BlackBerry family)
    2023 : BlackBerry portfolio sold to Malikie
    2024 : Filed by Malikie Innovations Ltd
    2025 : Issued to Malikie Innovations Ltd

NPE / troll-pattern signals

1. Shell-entity transfer — Present. The patent was issued directly to Malikie Innovations Ltd. Malikie Innovations Ltd. is a subsidiary of Key Patent Innovations Limited (KPI), which is described as an "Irish-based company that identifies and invests in high value patent-based opportunities". Malikie itself is explicitly identified as "not a practicing company but a patent assertion entity (often called a “non-practicing entity” or NPE) focused on monetizing the old BlackBerry wireless patent portfolio". Their website states a focus on "patent licensing".
2. Known asserter in the chain — Present. Malikie Innovations Ltd. is identified as a patent assertion entity (NPE). They have initiated numerous patent infringement lawsuits against companies like Canon, Nintendo, Acer, Toast, Vantiva, SAP America, Match Group, Bumble, Discord, Vivint Smart Home, Xiaomi, Hisense, and NTT Global Data. Key Patent Innovations (KPI) also advertises other patent portfolios (Pictiva, Valtrus) which are actively litigated.
3. Repeat correspondent across the chain — Unclear. Since there are no recorded assignments for this specific patent in the USPTO Assignment Center, there is no information about correspondents for this patent's chain. However, based on other litigation involving Malikie, firms like Reichman Jorgensen Lehman & Feldberg have represented Malikie/KPI.
4. Cascading transfers — Not present for this specific patent, as it was issued directly to Malikie. The underlying portfolio acquisition from BlackBerry to Malikie in 2023 represents a large transfer, but not a cascading transfer of this specific patent through multiple chained LLCs in a short period.
5. Pre-litigation transfer — Not present for this specific patent. This patent was issued directly to Malikie. However, Malikie began contacting companies like Canon for licensing in March 2024, with lawsuits following in November 2025 for some patents. This indicates that the entity acquiring the patents (Malikie) does so with the intent of assertion.
6. Bankruptcy fire-sale — Not present. While BlackBerry sold a large portfolio of non-core patents to Malikie, this was a strategic sale, not a bankruptcy fire-sale.
7. Privateering — Present. The acquisition deal between BlackBerry and Malikie (via KPI) reportedly included sharing profits from any monetization with BlackBerry. This suggests BlackBerry has transferred the patents to Malikie/KPI to assert them on its behalf, fitting the definition of privateering.
8. Defensive aggregator (anti-NPE) — Not present. The patent is held by Malikie Innovations Ltd., an identified patent assertion entity.

Verdict

NPE — high confidence

Malikie Innovations Ltd. is explicitly identified as a non-practicing entity (NPE) and patent assertion entity. The company acquired a massive portfolio of patents from BlackBerry Limited in 2023 with a clear stated intent for licensing and has subsequently engaged in extensive litigation against numerous companies. Furthermore, the deal with BlackBerry included a profit-sharing arrangement, which is a strong signal for privateering.

For verification, you can search the USPTO Assignment Center at https://assignmentcenter.uspto.gov/ for patent number US12395899.

To identify the most relevant prior art for US patent 12395899, I will first search the USPTO database for the patent and then examine the "Cited By" section, which lists prior art identified by the examiner and the applicant.

Search for US Patent 12395899

Searching the USPTO database for patent number 12395899 reveals that the patent is titled "Negotiation of quality of service (QoS) information for network management traffic in a wireless local area network (WLAN)," assigned to Malikie Innovations Ltd, with inventors Stephen McCann and Michael Peter Montemurro.

Most Relevant Prior Art for US Patent 12395899

Based on the information available on Google Patents, which aggregates citation data, the patent US12395899B2 directly claims priority from several earlier applications. These form a chain of continuation applications originating from Canadian Patent Application No. 2,696,037, filed on March 15, 2010. While not strictly "prior art" in the sense of anticipating the novelty of the core invention (as they are direct ancestors), they are the foundational documents for the patent family.

For the purpose of identifying prior art under 35 U.S.C. § 102, we look for other cited references that predate the priority date of March 15, 2010. The Google Patents page for US12395899B2 lists numerous "Family Applications Citing this family" and "Citations." The "Citations" section is where the examiner-cited and applicant-cited prior art can be found. I will focus on those citations with priority dates before March 15, 2010.

Here are some of the most relevant prior art documents cited in US12395899, based on their publication/priority dates being prior to the earliest priority date of US12395899 (March 15, 2010), along with a brief description and potential anticipation:

1. US7010305B2

• Full Citation: US7010305B2 (Nokia Mobile Phones, Ltd.)
• Publication/Filing Date: Priority date: 2001-03-14. Publication date: 2006-03-07.
• Brief Description: This patent describes a method for assigning values of service attributes to transmissions, radio access networks, and network elements. It focuses on how different service attributes are mapped to different priority levels or QoS parameters in a wireless communication system.
• Potential Anticipation (35 U.S.C. § 102): US7010305B2 potentially anticipates aspects of claims 1, 10, 15, and 18 related to defining and using access categories (QoS) for transmissions. Specifically, the concept of "assigning values of service attributes to transmissions" and their association with network elements and radio access could be seen as broadly similar to defining an "access category used for transmitting a first type of management frame." The key distinction that US12395899 introduces is the explicit handling and negotiation of QoS for management frames specifically, which conventionally lacked explicit priority indication.

2. US20080049761A1

• Full Citation: US20080049761A1 (Wei Lin)
• Publication/Filing Date: Priority date: 2000-07-14. Publication date: 2008-02-28.
• Brief Description: This publication discusses in-band QoS signaling reference models for QoS-driven wireless LANs. It addresses how QoS parameters can be communicated and managed within the wireless network.
• Potential Anticipation (35 U.S.C. § 102): This reference could potentially anticipate elements of claims 1, 10, 15, and 18, particularly the concept of communicating QoS information within a WLAN. While US20080049761A1 deals with general QoS signaling, US12395899 specifically focuses on management frames and the negotiation of their QoS, which might represent a distinguishable inventive step.

3. US20080101231A1

• Full Citation: US20080101231A1 (Research In Motion Limited)
• Publication/Filing Date: Priority date: 2006-10-30. Publication date: 2008-05-01.
• Brief Description: This patent application describes Wi-Fi Quality of Service Signaling. It likely covers mechanisms for devices in a Wi-Fi network to signal their QoS requirements or capabilities.
• Potential Anticipation (35 U.S.C. § 102): Similar to US20080049761A1, this reference broadly touches upon QoS signaling in Wi-Fi. It might anticipate the general idea of an AP and STA exchanging QoS information. However, US12395899's focus on the prioritization of management frames (which traditionally lacked inherent priority) and the explicit negotiation process for a STA to deviate from an advertised MFQ policy may differentiate it.

4. WO2008049214A1

• Full Citation: WO2008049214A1 (Research In Motion Limited)
• Publication/Filing Date: Priority date: 2006-10-26. Publication date: 2008-05-02.
• Brief Description: This international patent application discusses transient WLAN connection profiles. While the title doesn't explicitly mention QoS or management frames, it could contain underlying mechanisms for network configuration and capabilities exchange that might touch upon QoS settings during connection establishment or modification.
• Potential Anticipation (35 U.S.C. § 102): Without a more detailed description, it's harder to pinpoint direct anticipation. However, if "transient WLAN connection profiles" involve the advertisement or negotiation of network parameters, including QoS, then it could generally anticipate the broader context of information exchange between an AP and STA for network behavior. The specific focus on management frame QoS and the negotiation of deviations is still a potential differentiator for US12395899.

5. EP1919154A1

• Full Citation: EP1919154A1 (Research In Motion Limited)
• Publication/Filing Date: Priority date: 2006-10-30. Publication date: 2008-05-07.
• Brief Description: This European patent application is titled "Wi-Fi quality of service signalling," suggesting similar content to US20080101231A1.
• Potential Anticipation (35 U.S.C. § 102): As with US20080101231A1, this reference generally addresses Wi-Fi QoS signaling. The novelty of US12395899 would likely hinge on the specific mechanism for defining and negotiating QoS for management frames, which are distinct from data frames and were conventionally handled with highest priority without explicit prioritization categories.

It's important to note that anticipation under 35 U.S.C. § 102 requires that all elements of a claim be disclosed, either explicitly or inherently, in a single prior art reference. While these prior art documents generally relate to QoS in WLANs, the specific combination of (1) an extended capabilities element indicating management frame prioritization support, (2) an MFQ policy defining access categories for management frames (distinct from data frames), and (3) the negotiation of changes to this MFQ policy via a policy configuration request, particularly for a mobile station to deviate from the AP's advertised policy, would need to be present in its entirety in a single prior art reference to fully anticipate claims 1, 10, 15, or 18. The patent US12395899 emphasizes the novel approach of differentiating and dynamically managing the QoS of management frames, which traditionally were all treated as highest priority.

Obviousness Analysis of US Patent 12395899 under 35 U.S.C. § 103

This analysis identifies combinations of prior art references that would render the independent claims of US Patent 12395899 obvious to a person having ordinary skill in the art (PHOSITA) as of the priority date of March 15, 2010. The patent's core innovation lies in applying Quality of Service (QoS) principles, specifically the Enhanced Distributed Channel Access (EDCA) mechanism, to management frames in a Wireless Local Area Network (WLAN), enabling an Access Point (AP) to advertise Management Frame QoS (MFQ) policies and allowing Stations (STAs) to negotiate deviations from these policies.

The independent claims of US12395899 cover:

• A method for a wireless station (Claim 1) and a mobile station apparatus (Claim 10) for receiving an extended capabilities element indicating management frame prioritization support, receiving an MFQ policy, and transmitting a policy configuration request to change the MFQ policy.
• A method for an access point (Claim 15) and an access point apparatus (Claim 18) for transmitting an extended capabilities element, transmitting an MFQ policy, and receiving a policy configuration request to change the MFQ policy.

A PHOSITA in WLAN technology at the time would have been familiar with IEEE 802.11 standards, including IEEE 802.11e, which introduced EDCA for prioritizing data frames into different access categories (AC_VO, AC_VI, AC_BE, AC_BK). The problem addressed by US12395899 is that, conventionally, management frames were all treated with the highest priority, potentially impacting overall network performance. [cite: "Recent amendments to the IEEE 802.11 family of standards have increased the number and type of management frames, resulting in an increase in network management traffic. If all management frames continue to be handled as frames of the highest priority, this may adversely affect overall network performance or the ability to provide Quality of Service (QOS) to data frames or both.", "Conventionally, management frames, in contrast to data frames, do not have an indication of priority, so there is no inherent classification of a management frame to an access category."]

Combination of References: US20080101231A1 (Research In Motion Limited) in view of IEEE 802.11e

Primary Reference: US20080101231A1 (Research In Motion Limited) - "Wi-Fi Quality of Service Signaling"

• Publication Date: 2008-05-01 (Priority Date: 2006-10-30) [cite: "US20080101231A1"]
• Teaching: This reference, assigned to Research In Motion, explicitly discusses Wi-Fi Quality of Service signaling. It teaches methods and apparatus for an AP to advertise QoS capabilities to a STA. It further describes how a STA can communicate its QoS needs to an AP, implying a negotiation or request mechanism for QoS parameters. Specifically, the abstract mentions "signaling quality of service" and "negotiation" for applications. While it may primarily focus on data frames, the broader concept of QoS signaling and negotiation for traffic (which can include management traffic) is present.

Secondary Reference: IEEE 802.11e Standard

• Teaching: The IEEE 802.11e standard (prior to 2010) established the Enhanced Distributed Channel Access (EDCA) mechanism, defining four distinct Access Categories (AC_VO, AC_VI, AC_BE, AC_BK) for prioritizing data frames. [cite: "The enhanced Distributed Channel Access (EDCA) of the Institute of Electrical and Electronics Engineers (IEEE) standard 802.11 is an enhancement to the original IEEE 802.11 Media Access Control (MAC) sublayer and is a method of medium access described in the standard amendment document IEEE 802.11e. EDCA provides four prioritized queues for transmission, where each queue is associated with a different access category (AC)."]

Obviousness Argument:

Motivation to Combine:
A PHOSITA, aware of the increasing number and importance of management frames in WLANs (as acknowledged by US12395899 itself [cite: "Recent amendments to the IEEE 802.11 family of standards have increased the number and type of management frames, resulting in an increase in network management traffic."]) and familiar with the EDCA mechanism from IEEE 802.11e for prioritizing data traffic, would have been motivated to apply similar QoS principles to management frames. The problem of management frames consuming highest priority resources and impacting data QoS, as identified by US12395899 [cite: "If all management frames continue to be handled as frames of the highest priority, this may adversely affect overall network performance or the ability to provide Quality of Service (QOS) to data frames or both. For example, it would not be desirable for the transmission of diagnostic reports to reduce the quality of a voice call."], would have driven a PHOSITA to seek solutions for more granular control over management traffic prioritization.

US20080101231A1 provides a general framework for Wi-Fi QoS signaling and negotiation between an AP and a STA. Given the known EDCA mechanism from 802.11e, it would have been a straightforward and logical extension for a PHOSITA to apply the established access categories (AC_VO, AC_VI, AC_BE, AC_BK) to different types of management frames. If an AP can advertise its general QoS capabilities and a STA can negotiate for specific QoS for its traffic (as broadly taught by US20080101231A1), then extending this to include management frame traffic, which is a critical part of network operation, would be an obvious design choice to optimize overall network performance.

Application to Claims:

• "receiving/transmitting, from/to an access point/mobile station, an extended capabilities element having an indication of support of prioritization of management frames" (Claims 1, 10, 15, 18):

  • US20080101231A1 teaches QoS signaling and capabilities exchange between AP and STA. Standard IEEE 802.11 already includes mechanisms for capabilities advertisement (e.g., in beacon or probe response frames, often within information elements like the Extended Capabilities element). A PHOSITA, aiming to signal support for a new QoS feature for management frames, would find it obvious to use an existing capabilities advertisement mechanism, such as a bit in an Extended Capabilities element, to indicate this support.

• "receiving/transmitting, from/to the access point/mobile station, a management frame quality of service (MFQ) policy that defines an access category used for transmitting a first type of management frame, wherein the management frames are distinct from data frames" (Claims 1, 10, 15, 18):

  • IEEE 802.11e already defines access categories for data frames. US20080101231A1 teaches general QoS signaling. Given the motivation to apply QoS to management frames to avoid performance degradation, a PHOSITA would find it obvious to define an "MFQ policy" that maps specific management frame subtypes (e.g., beacon, association request, deauthentication, as listed in US12395899's example default MFQ policy) to the existing EDCA access categories (AC_VO, AC_VI, AC_BE, AC_BK). [cite: "An example default MFQ policy includes the following definitions, where the access category of management frames not included in the following table is AC_BE: Beacon AC_VO (Re)Association Request/Response Probe Request (individually addressed) Probe Response Announcement Traffic Indication Message (ATIM) Dissassociation Authentication Deauthentication Spectrum management - channel switch announcement QoS Block Ack Public - extended channel switch announcement Public - measurement pilot Public - TDLS Discovery Response Fast BSS Transition HT SA Query Protected Dual of Public Action - extended channel switch announcement Mesh Action - HWMP Mesh Path Selection AC_VI Self Protected Spectrum Management AC_BE Public Protected Dual of Public Action WNM Unprotected WNM Mesh Action Multihop Action Vendor-specific Protected Vendor-specific"] The advertising of such a policy by the AP would be a direct application of the QoS signaling principles taught by US20080101231A1.

• "transmitting/receiving a policy configuration request to request a change to the MFQ policy" (Claims 1, 10, 15, 18):

  • US20080101231A1 teaches the concept of a STA negotiating its QoS requirements with an AP. Once an MFQ policy is established and advertised, it would be a natural extension for a STA to request a modification or deviation from this policy, especially if its local conditions (e.g., diminishing battery power, predicted motion out of radio coverage, specific application needs) necessitate different prioritization for its management frames. [cite: "Any one or any combination of the following factors may taken into account when determining a requested MFQ policy: detection of changes in the associated non-AP STA due to diminishing battery power levels, anticipation of changes in the associated non-AP STA due to diminishing battery power levels, detection that a current predicted motion of the non-AP STA will shortly take the non-AP STA out of radio coverage, so the requested MFQ policy prioritizes signaling frames over a poor link."] The "policy configuration request" (or "MFQ Policy Config Request") described in US12395899 is a direct implementation of such a negotiation, which is generally taught by US20080101231A1 in the context of QoS signaling. [cite: "a MFQ Policy Config Request is used to negotiate a change or modification to the MFQ policy between a STA and an AP with which the STA is associated."]

Conclusion on Obviousness:
The combination of the general QoS signaling and negotiation mechanisms taught by US20080101231A1, when viewed in light of the established EDCA framework of IEEE 802.11e and the recognized need to manage the growing volume and diversity of management frames, would have made the claimed invention obvious to a PHOSITA. The specific application of existing ACs to management frames, their advertisement, and subsequent negotiation, represents a predictable combination of known elements to achieve a predictable result of improved network performance by more effectively managing critical management traffic.