Prosecution Insights
Last updated: April 19, 2026
Application No. 17/097,644

SHAPE MEMORY ALLOY VALVE AND METHOD FOR FABRICATION THEREOF

Non-Final OA §103
Filed
Nov 13, 2020
Examiner
WADDY, JONATHAN J
Art Unit
3753
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Smarter Alloys Inc.
OA Round
8 (Non-Final)
71%
Grant Probability
Favorable
8-9
OA Rounds
2y 10m
To Grant
99%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allow Rate
472 granted / 662 resolved
+1.3% vs TC avg
Strong +37% interview lift
Without
With
+37.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
26 currently pending
Career history
688
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
40.5%
+0.5% vs TC avg
§102
24.9%
-15.1% vs TC avg
§112
29.6%
-10.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 662 resolved cases

Office Action

§103
DETAILED ACTION The RCE filed 20 February 2026 has been entered. Claims 1-2, 4-9, and 11 remain pending. Claims 3, 10, and 12 have been cancelled. 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, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 20 February 2026 has been entered. Response to Arguments Applicant's arguments filed 20 February 2026 have been fully considered but they are not persuasive for the following reasons. The applicant argues with respect to independent claims 1 and 2 on pg. 4 of the Response that “Barth teaches movement in a single axis which may be seen as the ‘irrotational’ movement along an axis that is perpendicular to the valve seat. While Barth also teaches the subject matter of rotational movement, it is respectfully submitted that there is no suggestion that this includes movement in a horizontal plane or axis (or a second axis)…It is submitted that the rotational movement of the valve seat does not necessarily equate to movement of the valve seat along the horizontal plane or an axis different from the axis perpendicular to the valve seat.” However, as the applicant points out, the SMA actuator segments can move the stage in translational/”irrotational” movement from the valve seat, which is shown in Fig. 3C as being vertical relative to the page (col. 7, lines 47-51), and the SMA actuator can move the stage in rotational movement, which is shown in Figs. 4A-E and 5 (col. 8, lines 33-39) as being along an axis that is horizontal and into the page. These are two movements about two different axes. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 1-2, 4, and 6-11 are rejected under 35 U.S.C. 103 as being unpatentable over Barth et al. (US 5,954,079) in view of Tomonari et al. (US 2003/0160538) and Allston et al. (US 6,019,113). Regarding claim 1, Barth discloses in Figs. 1-5 a valve formed from a monolithic sheet 20, the valve comprising: a stage (comprising the center of sheet 20, below which the central boss 13 is located) formed from the monolithic sheet 20; and one or more actuator segments (comprising the serpentine heating elements 32, 33 shown in Fig. 3B and/or the portions of the legs 26, 27 with the heating elements 32, 33), formed from the monolithic sheet, connected to the stage via spring-like actuation patterns (comprising the remaining rectangular portion of the legs 26, 27 connecting the portion with heater elements 32, 33 to the stage, and wherein “spring-like” is broad and subject, and the rectangular actuation patterns are like leaf springs that bend according to actuation/deactivation) and configured to move the stage to seal or open a flow of gas or liquid (indirectly via the boss 13 fixed to the monolithic sheet 20) when the shape memory effect is activated (wherein the heat-responsive movement of the bimetallic sheet 22, of which monolithic sheet 20 is a part, is seen as being a shape memory effect); and a biasing spring section (comprising portion 34 shown in Fig. 3B around slots 38, 40, as disclosed col. 7, lines 31-45, or the “flexible suspension 38” disclosed in col. 6, lines 39 and shown in Fig. 3A, which is understood as referring to the same portion as portion 34 in Fig. 3B) for pulling the stage to seal the flow of gas or liquid (because the valve is disclosed as having a “normally closed position of Fig. 3A,” as disclosed in col. 7, lines 17-30, and portions 34 at least make up a portion of the biasing structure(s)); wherein the two or more SMA actuator segments can move the stage in more than one axis (because the SMA actuator segments can move the stage in translational/”irrotational” movement from the valve seat, which is shown in Fig. 3C as being vertical relative to the page (col. 7, lines 47-51), and the SMA actuator can move the stage in rotational movement, which is shown in Figs. 4A-E and 5 (col. 8, lines 33-39) as being along an axis that is horizontal and into the page). [AltContent: arrow][AltContent: arrow][AltContent: arrow][AltContent: arrow] PNG media_image1.png 191 441 media_image1.png Greyscale [AltContent: textbox (Biasing spring section or biasing component)][AltContent: textbox (actuator segment/component)][AltContent: textbox (stage)][AltContent: arrow][AltContent: arrow][AltContent: arrow] PNG media_image2.png 312 433 media_image2.png Greyscale Barth lacks teaching that the valve is a shape memory alloy (SMA) valve with the sheet being of a SMA and the actuator segments being of a SMA, and a resistance monitor for monitoring a resistance of the valve. With regard to the SMA, Tomonari teaches a bimetallic sheet (comprising moving element 5 and flexible areas 2) similar to the bimetallic sheet 22 disclosed by Barth, wherein the sheet has actuator segments 2 that may alternatively be of an SMA (paragraph 180). The actuator segments 2 also comprise spring-like actuation patterns in the form of rectangular portions connecting the actuator segments 2 to the central stage (like stage 5 in Figs. 1-3), and that change shape by bending according to actuation/deactivation, similar to the spring-like actuation patterns disclosed by Barth, which are like leaf springs. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the conductive sheet 20, or at least the actuator segments, disclosed by Barth to be of an SMA (such that the valve is a SMA valve) as a functionally equivalent alternative, as Tomonari teaches (paragraph 180), and as Barth suggests (col. 5, line 63 – col. 6, line 10 and col. 6, lines 40-49). With regard to the resistance monitor, Allston teaches a SMA valve comprising a resistance monitor for monitoring a resistance of the valve (col. 1, lines 13-30). Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the SMA valve in the combination of Barth and Tomonari to include a resistance monitor to provide feedback to the user/operator of the position of the valve, as Allston teaches (col. 1, lines 26-30). Regarding claim 2, Barth discloses in Figs. 1-5 a valve formed from a monolithic sheet 20, the valve comprising: a sealing stage (comprising the center of sheet 20, below which the central boss 13 is located) formed from the monolithic sheet 20; a biasing component (comprising portion 34 shown in Fig. 3B around slots 38, 40, as disclosed col. 7, lines 31-45, or the “flexible suspension 38” disclosed in col. 6, lines 39 and shown in Fig. 3A, which is understood as referring to the same portion as portion 34 in Fig. 3B) formed from the monolithic sheet 20 configured to pull the sealing stage toward a predetermined position to seal a flow of gas or liquid (because the valve is disclosed as having a “normally closed position of Fig. 3A,” as disclosed in col. 7, lines 17-30, and portions 34 at least make up a portion of the biasing structure(s)); and an actuator component (comprising the serpentine heating elements 32, 33 shown in Fig. 3B and/or the portions of the legs 26, 27 with the heating elements 32, 33) formed from the monolithic sheet 20 connected to the sealing stage via a spring-like actuation pattern (comprising the remaining rectangular portion of the legs 26, 27 connecting the portion with heater elements 32, 33 to the stage, and wherein “spring-like” is broad and subject, and the rectangular actuation patterns are like leaf springs that bend according to actuation/deactivation) and configured to move the sealing stage against the bias when the shape memory effect is activated (wherein the heat-responsive movement of the bimetallic sheet 22, of which monolithic sheet 20 is a part, is seen as being a shape memory effect); wherein the SMA actuator component can move the sealing stage in more than one axis (because the SMA actuator segments can move the stage in translational/”irrotational” movement from the valve seat, which is shown in Fig. 3C as being vertical relative to the page (col. 7, lines 47-51), and the SMA actuator can move the stage in rotational movement, which is shown in Figs. 4A-E and 5 (col. 8, lines 33-39) as being along an axis that is horizontal and into the page). Barth lacks teaching that the valve is a shape memory alloy (SMA) valve with the sheet being of a SMA and the actuator component being of a SMA, and a resistance monitor for monitoring a resistance of the valve. With regard to the SMA, Tomonari teaches a bimetallic sheet (comprising moving element 5 and flexible areas 2) similar to the bimetallic sheet 22 disclosed by Barth, wherein the sheet has actuator segments 2 that may alternatively be of an SMA (paragraph 180). The actuator segments 2 also comprise spring-like actuation patterns in the form of rectangular portions connecting the actuator segments 2 to the central stage (like stage 5 in Figs. 1-3), and that change shape by bending according to actuation/deactivation, similar to the spring-like actuation patterns disclosed by Barth, which are like leaf springs. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the conductive sheet 20, or at least the actuator segments, disclosed by Barth to be of an SMA (such that the valve is a SMA valve) as a functionally equivalent alternative, as Tomonari teaches (paragraph 180), and as Barth suggests (col. 5, line 63 – col. 6, line 10 and col. 6, lines 40-49). With regard to the resistance monitor, Allston teaches a SMA valve comprising a resistance monitor for monitoring a resistance of the valve (col. 1, lines 13-30). Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the SMA valve in the combination of Barth and Tomonari to include a resistance monitor to provide feedback to the user/operator of the position of the valve, as Allston teaches (col. 1, lines 26-30). Regarding claim 4, Barth discloses in Figs. 1-5 that there is a heat sink (comprising the outer periphery of the sheet 20 exposed to ambient temperatures outside of the valve assembly and/or abutting the adjacent substrate) provided to cool the one or more SMA actuator segments (because said heat sink/outer periphery of the sheet 20 can dissipate heat to the ambient environment and/or the abutting substrate). Regarding claim 6, Barth discloses in Figs. 1-5 that there is a heat sink (comprising the outer periphery of the sheet 20 exposed to ambient temperatures outside of the valve assembly and/or abutting the adjacent substrate) provided to cool theSMA actuator component.Gowling WLG (Canada) LLP Page 2Appin No. 17/097,644Response dated December 15, 2021In reply to Office Action issued June 16, 2021 SMA actuator component (because said heat sink/outer periphery of the sheet 20 can dissipate heat to the ambient environment and/or the abutting substrate). Regarding claim 7, Barth and Tomonari teach an SMA valve, as previously discussed, but the recitation that “the actuation patterns are formed by one of stamping or laser cutting” is interpreted as a “product-by-process” limitation that isn’t seen as defining over the prior art structure. Regarding claim 8, Barth discloses in Figs. 1-5 that the actuation patterns (comprising the portion of the legs 26, 27 with the heating elements 32, 33) are designed to achieve force and displacement requirements of the valve (col. 6, lines 57-67). Tomonari teaches a similar heat-responsive actuator that uses actuation patterns a part of SMA actuator segments. Regarding claim 9, Barth (in view of Tomonari) discloses in Figs. 1-5 that the actuation patterns (comprising the portion of the legs 26, 27 with heating elements 32, 33) comprises at least one electrically isolated segment (comprising the at least one leg that isn’t actuated in certain actuation modes, because the legs 26, 27 can be separately actuated for different actuation modes as disclosed in col. 6, lines 61-67 and col. 8, lines 23-38, such that said unactuated leg doesn’t have electricity flowing through it, like the electrically isolated segment(s) disclosed by the applicant in paragraph 43, which is understood as referring to a segment that electricity bypasses and/or doesn’t pass through during activation of the SMA). Regarding claim 10, Barth (in view of Tomonari) discloses in Figs. 1-5 that there are at least two SMA actuator segments (comprising the serpentine heating elements 32, 33 shown in Fig. 3B and/or the portions of the legs 26, 27 with the heating elements 32, 33), the at least two SMA actuator segments enabling the stage to move along at least two different axes (comprising the vertical axis to move the seating element 13 up and down, and the horizontal axis to move the side-to-side due to separate actuation of the heating elements 32, 33, as disclosed in col. 6, lines 61-67 and col. 8, lines 23-38, and shown in Figs. 4-5). Regarding claim 11, Barth discloses in Figs. 1-5 that at least two of the two different axes are perpendicular to each other (comprising the vertical axis to move the seating element 13 up and down, and the horizontal axis to move the side-to-side due to separate actuation of the heating elements 32, 33, as disclosed in col. 6, lines 61-67 and col. 8, lines 23-38, and shown in Figs. 4-5). Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Barth in view of Tomonari and Allston, as applied to claim 1 above, and further in view of Schramm et al. (US 2010/0122735). Regarding claim 5, Barth discloses in Figs. 1-5 that the valve is configured to operate between the temperatures of -400C and 800C (because the unheated temperature is 25oC, as disclosed in col. 8, lines 62-66, and the typical temperature ranger is less than 30oC, as disclosed in col. 9, lines 27-35). The combination of Barth and Tomonari teaches an SMA sheet as previously discussed, but lacks teaching that the temperatures in which the SMA sheet is configured to operate is between -40oC and 80oC. Schramm teaches in paragraph 45 that nickel-titanium types of SMA, like the SMA disclosed by Tomonari (paragraph 180), operate (i.e. actuate) between the temperatures of -400C and 800C. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have the valve in the combination of Barth and Tomonari to operate between -40oC and 80oC to sufficiently heat the SMA to its actuating temperature, as Schramm teaches (paragraph 45). Claims 1-2, 4, and 6-11 (alternatively: all) are rejected under 35 U.S.C. 103 as being unpatentable over Barth in view of Johnson et al. (US 5,325,880) and Allston. Regarding claim 1, Barth discloses in Figs. 1-5 a valve formed from a sheet 20, the valve comprising: a stage (comprising the center of sheet 20, below which the central boss 13 is located) formed from the sheet 20; and one or more actuator segments (comprising the serpentine heating elements 32, 33 shown in Fig. 3B and/or the portions of the legs 26, 27 with the heating elements 32, 33), formed from the sheet 20, connected to the stage via spring-like actuation patterns (comprising the remaining rectangular portion of the legs 26, 27 connecting the portion with heater elements 32, 33 to the central stage portion, and wherein “spring-like” is broad and subject, and the rectangular actuation patterns are like leaf springs that bend according to actuation/deactivation) and configured to move the stage to seal or open a flow of gas or liquid (indirectly via the boss 13 fixed to the monolithic sheet 20) when the shape memory effect is activated (wherein the heat-responsive movement of the bimetallic sheet 22, of which monolithic sheet 20 is a part, is seen as being a shape memory effect); and a biasing spring section (comprising portion 34 shown in Fig. 3B around slots 38, 40, as disclosed col. 7, lines 31-45, or the “flexible suspension 38” disclosed in col. 6, lines 39 and shown in Fig. 3A, which is understood as referring to the same portion as portion 34 in Fig. 3B) for pulling the stage to seal the flow of gas or liquid (because the valve is disclosed as having a “normally closed position of Fig. 3A,” as disclosed in col. 7, lines 17-30, and portions 34 at least make up a portion of the biasing structure(s)); wherein the two or more SMA actuator segments can move the stage in more than one axis (because the SMA actuator segments can move the stage in translational/”irrotational” movement from the valve seat, which is shown in Fig. 3C as being vertical relative to the page (col. 7, lines 47-51), and the SMA actuator can move the stage in rotational movement, which is shown in Figs. 4A-E and 5 (col. 8, lines 33-39) as being along an axis that is horizontal and into the page). Barth lacks teaching that the valve is a shape memory alloy (SMA) valve with the sheet being a monolithic sheet of SMA, wherein the stage and one or more actuators are formed from the monolithic SMA sheet, and a resistance monitor for monitoring a resistance of the valve. With regard to the SMA and monolithic sheet of SMA, Johnson teaches in Figs. 1A-B a monolithic sheet of SMA 30 comprising a stage that selectively seats on seat 20 and a one or more actuator segments comprising any other portions of the sheet 30 that conduct electricity/heat between terminals 31, 32 like the conductive sheet 20 disclosed by Barth. The actuator segments also comprise spring-like actuation patterns in the form of sheet portions connecting the actuator segments to the central stage, and that change shape by bending according to actuation/deactivation, similar to the spring-like actuation patterns disclosed by Barth, which are like leaf springs. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the bimetallic sheet disclosed by Barth to be a monolithic SMA sheet, like Johnson teaches, because it provides a simpler assembly than having to use the two layered materials forming the bimetallic sheet disclosed by Barth. With regard to the resistance monitor, Allston teaches a SMA valve comprising a resistance monitor for monitoring a resistance of the valve (col. 1, lines 13-30). Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the SMA valve in the combination of Barth and Johnson to include a resistance monitor to provide feedback to the user/operator of the position of the valve, as Allston teaches (col. 1, lines 26-30). Regarding claim 2, Barth discloses in Figs. 1-5 a valve formed from a monolithic sheet 20, the valve comprising: a sealing stage (comprising the center of sheet 20, below which the central boss 13 is located) formed from the monolithic sheet 20; a biasing component (comprising portion 34 shown in Fig. 3B around slots 38, 40, as disclosed col. 7, lines 31-45, or the “flexible suspension 38” disclosed in col. 6, lines 39 and shown in Fig. 3A, which is understood as referring to the same portion as portion 34 in Fig. 3B) formed from the monolithic sheet 20 configured to pull the sealing stage toward a predetermined position to seal a flow of gas or liquid (because the valve is disclosed as having a “normally closed position of Fig. 3A,” as disclosed in col. 7, lines 17-30, and portions 34 at least make up a portion of the biasing structure(s)); and an SMA actuator component (comprising the serpentine heating elements 32, 33 shown in Fig. 3B and/or the portions of the legs 26, 27 with the heating elements 32, 33) formed from the monolithic sheet 20 connected to the sealing stage via a spring-like actuation pattern (comprising the remaining rectangular portion of the legs 26, 27 connecting the portion with heater elements 32, 33 to the stage, and wherein “spring-like” is broad and subject, and the rectangular actuation patterns are like leaf springs that bend according to actuation/deactivation) and configured to move the sealing stage against the bias when the shape memory effect is activated (wherein the heat-responsive movement of the bimetallic sheet 22, of which monolithic sheet 20 is a part, is seen as being a shape memory effect); wherein the SMA actuator component can move the sealing stage in more than one axis (because the SMA actuator segments can move the stage in translational/”irrotational” movement from the valve seat, which is shown in Fig. 3C as being vertical relative to the page (col. 7, lines 47-51), and the SMA actuator can move the stage in rotational movement, which is shown in Figs. 4A-E and 5 (col. 8, lines 33-39) as being along an axis that is horizontal and into the page). Barth lacks teaching that the valve is a shape memory alloy (SMA) valve with the monolithic sheet being a monolithic sheet of SMA, wherein the stage and one or more actuators are formed from the monolithic SMA sheet, and a resistance monitoring for monitoring a resistance of the valve. With regard to the SMA and monolithic sheet of SMA, Johnson teaches in Figs. 1A-B a monolithic sheet of SMA 30 comprising a stage that selective seats on seat 20 and a one or more actuator segments comprising any other portions of the sheet 30 that conduct electricity/heat between terminals 31, 32 like the conductive sheet 20 disclosed by Barth. The actuator segments also comprise spring-like actuation patterns in the form of sheet portions connecting the actuator segments to the central stage, and that change shape by bending according to actuation/deactivation, similar to the spring-like actuation patterns disclosed by Barth, which are like leaf springs. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the bimetallic sheet disclosed by Barth to be a monolithic SMA sheet, as Johnson teaches, because it provides a simpler assembly than having to use the two layered materials forming the bimetallic sheet disclosed by Barth. With regard to the resistance monitor, Allston teaches a SMA valve comprising a resistance monitor for monitoring a resistance of the valve (col. 1, lines 13-30). Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the SMA valve in the combination of Barth and Johnson to include a resistance monitor to provide feedback to the user/operator of the position of the valve, as Allston teaches (col. 1, lines 26-30). Regarding claim 4, Barth discloses in Figs. 1-5 that there is a heat sink (comprising the outer periphery of the sheet 20 exposed to ambient temperatures outside of the valve assembly and/or abutting the adjacent substrate) provided to cool the one or more SMA actuator segments (because said heat sink/outer periphery of the sheet 20 can dissipate heat to the ambient environment and/or the abutting substrate). Regarding claim 6, Barth discloses in Figs. 1-5 that there is a heat sink (comprising the outer periphery of the sheet 20 exposed to ambient temperatures outside of the valve assembly and/or abutting the adjacent substrate) provided to cool theSMA actuator component.Gowling WLG (Canada) LLP Page 2Appin No. 17/097,644Response dated December 15, 2021In reply to Office Action issued June 16, 2021 SMA actuator component (because said heat sink/outer periphery of the sheet 20 can dissipate heat to the ambient environment and/or the abutting substrate). Regarding claim 7, Barth and Johnson teach an SMA valve, as previously discussed, but the recitation that “the actuation patterns are formed by one of stamping or laser cutting” is interpreted as a “product-by-process” limitation that isn’t seen as defining over the prior art structure. Regarding claim 8, Barth discloses in Figs. 1-5 that the actuation patterns (comprising the portion of the legs 26, 27 with the heating elements 32, 33) are designed to achieve force and displacement requirements of the valve (col. 6, lines 57-67). Regarding claim 9, Barth (in view of Johnson) discloses in Figs. 1-5 that the actuation patterns (comprising the portion of the legs 26, 27 with heating elements 32, 33) comprises at least one electrically isolated segment (comprising the at least one leg that isn’t actuated in certain actuation modes, because the legs 26, 27 can be separately actuated for different actuation modes as disclosed in col. 6, lines 61-67 and col. 8, lines 23-38, such that said unactuated leg doesn’t have electricity flowing through it, like the electrically isolated segment(s) disclosed by the applicant in paragraph 43, which is understood as referring to a segment that electricity bypasses and/or doesn’t pass through during activation of the SMA). Regarding claim 10, Barth (in view of Johnson) discloses in Figs. 1-5 that there are at least two SMA actuator segments (comprising the serpentine heating elements 32, 33 shown in Fig. 3B and/or the portions of the legs 26, 27 with the heating elements 32, 33), the at least two SMA actuator segments enabling the stage to move along at least two different axes (comprising the vertical axis to move the seating element 13 up and down, and the horizontal axis to move the sealing element 13 side-to-side due to separate actuation of the heating elements 32, 33, as disclosed in col. 6, lines 61-67 and col. 8, lines 23-38, and shown in Figs. 4-5). Regarding claim 11, Barth discloses in Figs. 1-5 that at least two of the two different axes are perpendicular to each other (comprising the vertical axis to move the seating element 13 up and down, and the horizontal axis to move the side-to-side due to separate actuation of the heating elements 32, 33, as disclosed in col. 6, lines 61-67 and col. 8, lines 23-38, and shown in Figs. 4-5). Claim 5 (alternatively) is rejected under 35 U.S.C. 103 as being unpatentable over Barth in view of Johnson and Allston, as applied to claim 1 above, and further in view of Schramm. Regarding claim 5, Barth discloses in Figs. 1-5 that the SMA valve is configured to operate between the temperatures of -400C and 800C (because the unheated temperature is 25oC, as disclosed in col. 8, lines 62-66, and the typical temperature ranger is less than 30oC, as disclosed in col. 9, lines 27-35). The combination of Barth and Johnson teaches an SMA sheet as previously discussed, but lack teaching that the temperatures in which the SMA sheet is configured to operate is between -40oC and 80oC. Schramm teaches in paragraph 45 that nickel-titanium types of SMA, like the SMA disclosed by Johnson (col. 4, lines 26-33), operate (i.e. actuate) between the temperatures of -400C and 800C. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have the valve in the combination of Barth and Johnson to operate between -40oC and 80oC to sufficiently heat the SMA to its actuating temperature, as Schramm teaches (paragraph 45). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Ossmer et al. (US 2019/0353269) discloses a SMA valve formed from a monolithic sheet 1 of SMA, the SMA valve comprising: a central stage portion that selectively controls flow via a valve ball 8; one or more SMA actuator segments at two opposite ends of the sheet 1 (like the two longitudinal ends of the sheet 1 shown in Fig. 1); and a biasing component comprising the patterns with openings therethrough and connecting the SMA actuator segments at the ends to the central stage portion, wherein the patterns are “spring-like” actuation patterns because they inherently provide a biasing force when the central stage moves from its neutral position. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Examiner Jonathan Waddy, whose telephone number is 571-270-3146. The examiner can normally be reached on Monday-Friday (10:00AM-6:00PM EST). If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisors can be reached by phone. Kenneth Rinehart can be reached at 571-272-4881 or Craig Schneider can be reached at 571-272-3607. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from Patent Center. Status information for published applications may be obtained from Patent Center. Status information for unpublished applications is available through Patent Center for authorized users only. Should you have questions about access to Patent Center, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). 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) Form at https://www.uspto.gov/patents/uspto-automated- interview-request-air-form. /J. W./ Examiner, Art Unit 3753 /KENNETH RINEHART/Supervisory Patent Examiner, Art Unit 3753
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Prosecution Timeline

Nov 13, 2020
Application Filed
Jun 10, 2021
Non-Final Rejection — §103
Dec 15, 2021
Response Filed
Apr 01, 2022
Final Rejection — §103
Oct 03, 2022
Request for Continued Examination
Oct 06, 2022
Response after Non-Final Action
Oct 12, 2022
Non-Final Rejection — §103
Apr 12, 2023
Response Filed
Jul 07, 2023
Non-Final Rejection — §103
Jan 12, 2024
Response Filed
Apr 18, 2024
Final Rejection — §103
Oct 23, 2024
Request for Continued Examination
Oct 24, 2024
Response after Non-Final Action
Nov 14, 2024
Non-Final Rejection — §103
May 15, 2025
Response Filed
Aug 15, 2025
Final Rejection — §103
Feb 20, 2026
Request for Continued Examination
Mar 12, 2026
Response after Non-Final Action
Mar 27, 2026
Non-Final Rejection — §103 (current)

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Prosecution Projections

8-9
Expected OA Rounds
71%
Grant Probability
99%
With Interview (+37.1%)
2y 10m
Median Time to Grant
High
PTA Risk
Based on 662 resolved cases by this examiner. Grant probability derived from career allow rate.

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