Systems, methods and apparatus for wireless communication are provided. In one aspect, the method comprises receiving at least one downlink packet. The method further comprises generating an acknowledge message in response to receiving the at least one downlink packet. The method further comprises prioritizing the acknowledge message in a buffer according to a probability, the probability based at least in part on a current utilization level of the buffer. The method may further comprise one or more of the following: setting the probability to a first value when the utilization level is below a first level, setting the probability to a second value when the utilization level is above the first level and below a second level, and setting the probability to a third value when the utilization level is above the second level. The second value may be adjusted based on feedback corresponding to a downlink throughput.