of the handset, or is unable to connect to the device, the push notification will be encoded and sent as an SMS.

Connection Oriented Push is used less frequently than Connectionless Push for several reasons including:
* Devices while registered to the network, may not have a data session (PDP Context in the GSM world) established.
* A separate IP->MSISDN table has to be maintained in Connection Oriented Push.
* Typically, the PPG or another part of the gateway has to receive