Prosecution Insights
Last updated: April 19, 2026
Application No. 16/901,783

CUSHIONED COVERS FOR CUSHIONS

Non-Final OA §103
Filed
Jun 15, 2020
Examiner
WEYDEMEYER, ALICIA JANE
Art Unit
1781
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Purple Innovation LLC
OA Round
5 (Non-Final)
46%
Grant Probability
Moderate
5-6
OA Rounds
3y 6m
To Grant
72%
With Interview

Examiner Intelligence

Grants 46% of resolved cases
46%
Career Allow Rate
178 granted / 386 resolved
-18.9% vs TC avg
Strong +26% interview lift
Without
With
+26.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
57 currently pending
Career history
443
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
57.5%
+17.5% vs TC avg
§102
14.0%
-26.0% vs TC avg
§112
24.0%
-16.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 386 resolved cases

Office Action

§103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114 was filed in this application after a decision by the Patent Trial and Appeal Board, but before the filing of a Notice of Appeal to the Court of Appeals for the Federal Circuit or the commencement of a civil action. Since this application is eligible for continued examination under 37 CFR 1.114 and the fee set forth in 37 CFR 1.17(e) has been timely paid, the appeal has been withdrawn pursuant to 37 CFR 1.114 and prosecution in this application has been reopened pursuant to 37 CFR 1.114. Applicant’s submission filed on 12/05/2025 has been entered. Information Disclosure Statement The information disclosure statement(s) (IDS) submitted on 09/27/2024 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the IDS is being considered by the examiner. Examiner Notes Claims 13-22, 26-39, and 41 are currently pending of which claims 20 and 30 are withdrawn. Claims 13, 16, 18-19, 37, and 39 are currently amended. Claim Objections Claim 26 is objected to under 37 CFR 1.75 as being a substantial duplicate of claim 15. When two claims in an application are duplicates or else are so close in content that they both cover the same thing, despite a slight difference in wording, it is proper after allowing one claim to object to the other as being a substantial duplicate of the allowed claim. See MPEP § 608.01(m). Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claim 13-14 are rejected under 35 U.S.C. 103 as being unpatentable over Poppe (US 2008/0271250) in view of Blazar (US 2014/0082846). Regarding claim 13, Poppe discloses a pillow comprising a sleeve (11) and non-woven material (4), instant “first panel”. Where the top layer of the sleeve and non-woven material are the instant outer and inner layers, respectively. A comfort layer (5; instant secondary cushioning element) formed of a compressible resilient temperature-sensitive elastic material (instant elastomeric material; 0014 and 0022). The comfort material defining a plurality of interconnected walls (Fig. 2). The bottom layer of the sleeve and non-woven material are the instant “second panel” superimposed with the “first panel.” A primary receptacle defined between the first and second panel with a primary cushioning element positioned in between (0032, Fig. 1). The peripheral edges of the panels secured together (Fig. 1). Poppe does not teach where the plurality of interconnected walls are fixed to the outer layer or inner layer of the first panel. Regarding the fixing of the comfort material, Blazar, in the analogous field of pillows (0004), teaches a fabric cover firmly fixed to at least one surface of a cushion element (0026, 0031-0035). A person of ordinary skill in the art before the effective filing date of the claimed invention would have found it obvious for the comfort layer of Poppe to be fixed to a surface of the fabric, as taught by Blazar, to afford more stability to allow the pillow to be washed more frequently without deterioration thereby extending the life and its overall value to a consumer (0026). Regarding claim 14, Poppe teaches the core comprising foam springs (3), instant pillow. Claims 16-19 and 21 are rejected under 35 U.S.C. 103 as being unpatentable over Poppe in view of Blazar as applied to claim 13 and further in view of Alletto (US 2014/0096323). Regarding claim 16, modified Poppe discloses the limitations of claim 13 as discussed above. While Poppe teaches the plurality of interconnected walls defining an array of cells (Fig. 2, 3), Poppe does not teach a central region of the array of cells being taller than an outer periphery of the array of cells. Alletto, in the analogous field of pillows (0006), teaches an embodiment in which fill material is located both outside of an inner cover (48) and inside of an outer cover (12), where the fill material (52) has a shape which gradually tapers from a central region toward an outer periphery of the edge of the pillow (Fig. 6 and 7, 0031). A person of ordinary skill in the art before the effective filing date of the claimed invention would have found it obvious to have adapted the shape of Alletto’s fill material, for the shape of the comfort layer of Poppe, to impart the overall shape of a pillow which supports the head and neck of a person (0005 and 0031). Due to the taper from the central region, the height of the interconnected walls at the center will be taller than at the outer periphery. Regarding claim 17, Poppe teaches the comfort material comprising formed of a compressible resilient temperature-sensitive elastic material which assumes the shape of the body pressing down on it and then reassumes its original shape (buckling walls/cells), the material comprising interconnected walls (Fig. 2, 0022). Regarding claim 18, Poppe discloses a pillow comprising a sleeve (11) and non-woven material (4). Where the bottom layer of the sleeve and non-woven material are the instant outer and inner layers, respectively. The comfort layer (5; instant secondary cushioning element) formed of a compressible resilient temperature-sensitive elastic material (instant elastomeric material; 0014 and 0022). The comfort material defining a plurality of interconnected walls (Fig. 2). Poppe does not teach where the plurality of interconnected walls are fixed to the outer layer or inner layer of the second panel. Regarding the fixing of the comfort material, Blazar, in the analogous field of pillows (0004), teaches a fabric cover firmly fixed to at least one surface of a cushion element (0026, 0031-0035). A person of ordinary skill in the art before the effective filing date of the claimed invention would have found it obvious for the comfort layer of Poppe to be fixed to a surface of the fabric, as taught by Blazar, to afford more stability to allow the pillow to be washed more frequently without deterioration thereby extending the life and its overall value to a consumer (0026). Regarding claim 19, Poppe teaches the plurality of interconnected walls defining an array of cells (Fig. 2, 3). Regarding claim 21, Poppe teaches the inner layer comprising a non-woven e.g., fabric (0032) with the comfort material adhered to the inner layer as discussed above. Poppe does not teach the comfort material formed on the inner layer however, this includes product by process language with regards to the recitation of “formed on”. The above arguments establish a rationale tending to show the claimed product is the same as what is taught by the prior art. “[E]ven though product-by-process claims are limited by and defined by the process, determination of patentability is based on the product itself. The patentability of a product does not depend on its method of production. If the product in the product-by-process claim is the same as or obvious from a product of the prior art, the claim is unpatentable even though the prior product was made by a different process.” (In re Thorpe, 227 USPQ 964,966). Once the Examiner provides a rationale tending to show that the claimed product appears to be the same or similar to that of the prior art, although produced by a different process, the burden shifts to applicant to come forward with evidence establishing an unobvious different between the claimed product and the prior art product. In re Marosi, 710 F.2d 798, 802, 218 USPQ 289, 292 (Fed. Cir. 1983), MPEP 2113. Claim 22 is rejected under 35 U.S.C. 103 as being unpatentable over Poppe in view of Blazar as applied to claim 18 above, and further in view of Landi et al. (US 5,039,567). Regarding claim 22, modified Poppe discloses the limitations of claim 18 as discussed above. Poppe does not disclose the plurality of interconnected walls and array of cells of the secondary cushioning element of the first panel being laterally offset from a plurality of interconnected walls and array of cells of the secondary cushioning element of the second panel. Landi, in the analogous field of elastomeric cushioning structures (column 1, lines 5-10), discloses a honeycombed panel structure comprising two wall core segments having a first and second interconnected array of cells (column 6, lines 50-55; Fig. 13), wherein the second plurality of interconnected walls and cells are laterally offset from the first plurality of interconnected walls and cells (Fig. 13). A person of ordinary skill in the art before the effective filing date of the claimed invention would have found it obvious to for the interconnected walls and array of cells of the first panel of Poppe to be laterally offset from interconnected walls and array of cells of the second panel, as taught by Landi, achieving a unique energy absorbing structure that does not degrade with repeated impact (column 2, lines 10-15). Allowable Subject Matter Claims 15, 26-29, 31-39 and 41 are allowed. The following is a statement of reasons for the indication of allowable subject matter: Poppe teaches the comfort layer being connected by gluing to surround the core (0036). Thus, it would not have been obvious for the material of the core to be removable from and replaceable within the core as gluing closes the comfort layer around the core. Response to Arguments Applicant’s arguments have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Contact Information Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALICIA WEYDEMEYER whose telephone number is (571)270-1727. The examiner can normally be reached M-Th 9-4. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Frank Vineis can be reached at 571-270-1547. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /ALICIA J WEYDEMEYER/Primary Examiner, Art Unit 1781
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Prosecution Timeline

Jun 15, 2020
Application Filed
Sep 01, 2020
Response after Non-Final Action
Sep 30, 2021
Response after Non-Final Action
Aug 18, 2022
Non-Final Rejection — §103
Nov 23, 2022
Response Filed
Feb 16, 2023
Final Rejection — §103
Apr 24, 2023
Response after Non-Final Action
May 02, 2023
Response after Non-Final Action
May 22, 2023
Request for Continued Examination
Jun 01, 2023
Response after Non-Final Action
Oct 17, 2023
Non-Final Rejection — §103
Jan 22, 2024
Response Filed
Feb 23, 2024
Final Rejection — §103
Apr 29, 2024
Response after Non-Final Action
May 28, 2024
Notice of Allowance
May 28, 2024
Response after Non-Final Action
Jun 21, 2024
Response after Non-Final Action
Jul 29, 2024
Response after Non-Final Action
Aug 08, 2024
Response after Non-Final Action
Sep 12, 2024
Response after Non-Final Action
Nov 20, 2024
Response after Non-Final Action
Nov 22, 2024
Response after Non-Final Action
Nov 25, 2024
Response after Non-Final Action
Nov 25, 2024
Response after Non-Final Action
Oct 07, 2025
Response after Non-Final Action
Dec 05, 2025
Request for Continued Examination
Dec 08, 2025
Response after Non-Final Action
Feb 19, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12600827
METHOD FOR THE SYNTHESIS OF A TWO-DIMENSIONAL OR QUASI-TWO-DIMENSIONAL POLYMER FILM, THE TWO-DIMENSIONAL OR QUASI-TWO-DIMENSIONAL POLYMER FILM AND THE USE
2y 5m to grant Granted Apr 14, 2026
Patent 12584249
Tearable Cloth
2y 5m to grant Granted Mar 24, 2026
Patent 12575041
DISPLAY MODULE
2y 5m to grant Granted Mar 10, 2026
Patent 12570571
GLASS
2y 5m to grant Granted Mar 10, 2026
Patent 12553189
ABSORBENT STRUCTURES WITH HIGH STRENGTH AND LOW MD STRETCH
2y 5m to grant Granted Feb 17, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
46%
Grant Probability
72%
With Interview (+26.4%)
3y 6m
Median Time to Grant
High
PTA Risk
Based on 386 resolved cases by this examiner. Grant probability derived from career allow rate.

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