Since it means the dialogue is not being updated (UPDATE is for early dialogue). Update would be used for updated an SDP offer, etc., and must be responded to very promptly.

If the session is established it's not recommended...

Although UPDATE can be used on confirmed
dialogs, it is RECOMMENDED that a re-INVITE be used instead. This is
because an UPDATE needs to be answered immediately, ruling out the
possibility of user approval. Such approval will frequently be
needed, and is possible with a re-INVITE.

http://www.rfc-editor.org/rfc/rfc3311.txt

On Fri, Jul 23, 2010 at 3:26 PM, Sergey Okhapkin <sos@sokhapkin.dyndns.org> wrote:
Is it possible to use SIP UPDATE method to check session activity instead of
re-INVITE?

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