Office Action Predictor
Application No. 17/319,264

PTC Heating Cell and Method for Manufacturing the Same

Non-Final OA §103
Filed
May 13, 2021
Examiner
THONG, YEONG JUEN
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Eberspächer Catem Hermsdorf GMBH & CO. Kg
OA Round
5 (Non-Final)
48%
Grant Probability
Moderate
5-6
OA Rounds
3y 5m
To Grant
99%
With Interview

Examiner Intelligence

48%
Career Allow Rate
71 granted / 149 resolved
Without
With
+51.9%
Interview Lift
avg trend
3y 5m
Avg Prosecution
43 pending
192
Total Applications
career history

Statute-Specific Performance

§101
0.9%
-39.1% vs TC avg
§103
44.7%
+4.7% vs TC avg
§102
23.1%
-16.9% vs TC avg
§112
27.9%
-12.1% vs TC avg
Black line = Tech Center average estimate • Based on career data

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, 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 October 23th 2025 has been entered. Claims Status: Claims 1 and 4-9 are pending. Claims 2-3 are cancelled. Claims 1 and 7 are amended. Claims 1 and 4-9 are examined as follow: 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claims 1 and 8 are rejected under 35 U.S.C. 103 as being unpatentable over Bohlender et al (US2016/0360573A1 Previously cited) herein set forth as Bohlender, in view of Nikkhoo et al (US2013/0186941A1 previously cited) herein set forth as Nikkhoo, and further in view of GEISHECKER (US3955170 newly cited) herein set forth as GEISHECKER. Regarding claim 1, Bohlender discloses a method for manufacturing a positive temperature coefficient(PTC) heating cell (PTC heating element #2, fig.1) with at least one PTC element (PTC element #4, fig.1) and contact elements (contact plate #6, fig.1) which are made of an electrically conductive material (Examiner note: contact element is electrically conductive, because the intended invention of the prior is to conduct electricity to generate heat), which are electrically conductively abutted against opposed main side surfaces (refer to the surface between each #6.1 and #4 in fig.1) of the PTC element (PTC element #4, fig.1), and which are connected to the PTC element (PTC element #4, fig.1), the method comprising: providing the contact elements (contact plate #6, fig.1) and the PTC element (PTC element #4, fig.1); and disposing a solder (refer as “adhesive” in Paragraph 0036 cited: “…The contact plate is connected for the formation of a PTC heating element to the PTC element 4 by way of an adhesive, preferably an electrically conductive adhesive…”) between each of the opposed main side surfaces (refer to the surface between each #6.1 and #4 in fig.1) of the PTC ceramic material of the PTC element (PTC element #4, fig.1) and the contact elements (contact plate #6, fig.1) such that the solder (refer as “adhesive” in Paragraph 0036 cited: “…The contact plate is connected for the formation of a PTC heating element to the PTC element 4 by way of an adhesive, preferably an electrically conductive adhesive…”) is the only material disposed between the PTC ceramic material of the PTC element (PTC element #4, fig.1) and a contact surface (refer to the surface between each #6.1 and #4 in fig.1) of a respective one of the contact elements (contact plate #6, fig.1), and such that the solder (refer as “adhesive” in Paragraph 0036 cited: “…The contact plate is connected for the formation of a PTC heating element to the PTC element 4 by way of an adhesive, preferably an electrically conductive adhesive…”) is exclusively (refer to fig.1, Examiner note: figure show that there is adhesive outside of the connection) disposed between the PTC material of the PTC element (PTC element #4, fig.1) and the contact element (contact plate #6, fig.1), PNG media_image1.png 403 677 media_image1.png Greyscale However, Bohlender only discloses adhesive the contact elements to the PTC element, Bohlender does not explicitly disclose the use of induction soldering as adhesive; Wherein a contact surface of each of the contact elements is sized smaller than the respective main side surface of the PTC element. In the field of soldering and bonding, Nikkhoo discloses the use of induction soldering as adhesive (refer to abstract: “…an inductive heater designed for use in assembling electronics is disclosed…”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bohlender’s method with the use of induction soldering, as taught by Nikkhoo, in order to prevent harm to unshielded adjacent electrical components (refer to abstract: “…A number of methods for shaping a magnetic field are disclosed for the purpose of completing an inductive bonding process without causing harm to unshielded adjacent electrical components…”). Nikkhoo too does not discloses Wherein a contact surface of each of the contact elements is sized smaller than the respective main side surface of the PTC element. In the field of making a PTC electrode component, Geishecker discloses Wherein a contact surface of each of the contact elements (#36 and #38, fig.3-5) is sized smaller than the respective main side surface of the PTC element (#26, fig.5). PNG media_image2.png 778 523 media_image2.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filing date to substitute the Bohlender’s contact element with Geishecker’s contact element, because the substitution of one known element for another would have yielded predictable results. Regarding claim 8, the modification of Bohlender, Nikkhoo and GEISHECKER discloses substantially all features set forth in claim 1, Bohlender or Nikkhoo does not discloses wherein the contact surface of each contact element is annular in shape. In the field of making a PTC electrode component, GEISHECKER further discloses wherein the contact surface of each contact element (#36 and #38, fig.3-5) is annular in shape (refer to the shape of #36 and #38 in fig.3 and 4). It would have been obvious to one of ordinary skill in the art before the effective filing date to substitute the Bohlender’s contact element with GEISHECKER’s contact element, because the substitution of one known element for another would have yielded predictable results. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Bohlender et al (US2016/0360573A1 Previously cited) herein set forth as Bohlender, in view of Nikkhoo et al (US2013/0186941A1 previously cited) herein set forth as Nikkhoo, further in view of GEISHECKER et al (US3955170 newly cited) herein set forth as GEISHECKER, and further in view of REUL (US2021/0291286A1 previously cited) herein set forth as REUL. Regarding claim 4, the modification of Bohlender, Nikkhoo and GEISHECKER discloses substantially all features set forth in claim 1, Bohlender does not explicitly disclose wherein at least one of the contact elements is first applied to the PTC element, and inductive heating is then carried out. In the field of electrical connection of contact elements, REUL discloses wherein at least one of the contact elements (contact element #14, fig. 1) is first applied to the PTC element, and inductive heating (soldering tool #13, fig.1 and refer to Paragraph 0076 cited: “…The soldering tool 13 contains (at least) one induction loop 13I or one induction coil that is supplied with an alternating voltage with adjustable frequency and power by a commercial generator …”) is then carried out. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bohlender invention with wherein at least one of the contact elements is first applied to the PTC element, and inductive heating is then carried out, as taught by REUL, in order to provide a more secure connection and reduce damage and detachment (Refer to Page 3 Paragraph 0053 cited: “…his has the particular advantage that although the contact element, the solder deposit adjacent the second solder connection surface, and thus indirectly also the first solder connection surface of the conductor surface are reliably heated, the conductor structure in the vicinity of the first solder connection surface is heated only slightly. Thus, damage to the conductor structure and detachment of the conductor structure from the plate can be reliably avoided. …”), such that would reduce defect, and improved operational life span of the invention. Claims 5-6 are rejected under 35 U.S.C. 103 as being unpatentable over Bohlender et al (US2016/0360573A1 Previously cited) herein set forth as Bohlender, in view of Nikkhoo et al (US2013/0186941A1 previously cited) herein set forth as Nikkhoo, further in view of GEISHECKER et al (US3955170 newly cited) herein set forth as GEISHECKER, further in view of REUL (US2021/0291286A1 previously cited) herein set forth as REUL, and further in view of WANTANABE (US2022/0320811A1 previously cited) herein set forth as WANT. Regarding claim 5, the modification of Bohlender, Nikkhoo and GEISHECKER discloses substantially all features set forth in claim 1, Bohlender does not explicitly disclose wherein at least one of the contact elements is first inductively heated, and then the contact element is applied to the PTC element and soldered thereto. In the field of electrical connection of contact elements, REUL further discloses wherein at least one of the contact elements (contact element #14, fig.1) is inductively heated (soldering tool #13, fig.1 and refer to Paragraph 0076 cited: “…The soldering tool 13 contains (at least) one induction loop 13I or one induction coil that is supplied with an alternating voltage with adjustable frequency and power by a commercial generator …”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bohlender’s invention with heating the contact element inductively, as taught by REUL, in order to provide a specific heating and also control vicinity of the heating area (refer to Paragraph 0018 cited: “…The method according to the invention has the particular advantage that the contact element and the adjacent solder deposit are heated specifically and the vicinity of the conductor structure around the first solder connection surface is, in contrast, heated only slightly…”), such that would produce lesser defect by reducing over heating unnecessary area, and increase in energy efficiency by only heating necessary area. However, REUL does not explicitly disclose wherein at least one of the contact elements is preheated, and then the contact element is applied to the PTC element and soldered thereto. In the field of soldering component, WANT discloses wherein at least one of the contact elements (refer to “the lead” cited in Paragraph 0011 below) is first pre-heated, and then the contact element (refer to “the lead” cited in Paragraph 0011 below) is applied to the PTC element (refer to “the land” cited in Paragraph 0011 below) and soldered thereto (refer to Paragraph 0011 cited: “…it is necessary to preheat the land and the lead at the soldering point to a temperature close to the melting temperature of the solder, in advance of soldering …”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bohlender’s method with wherein at least one of the contact elements is preheated, and then the contact element is applied to the PTC element and soldered thereto, as taught by WANT, in order to provide a better adhesion in the soldering (refer to Paragraph 0011 cited: “…In a state in which the land and the lead of the electronic component are not preheated and thus have a low temperature, when the solder melted by the laser beam contacts with the lead or the land in the low-temperature state, the solder immediately solidifies, so that adhesion thereof is lost, leading to soldering fault …”), such that would reduce defect and soldering fault being produce. Regarding claim 6, the modification of Bohlender, Nikkhoo and GEISHECKER discloses substantially all features set forth in claim 1, Bohlender does not explicitly disclose wherein at least one of the contact elements is first inductively heated, and then the contact element is applied to the PTC element and soldered thereto at a phase boundary between the contact elements and the PTC element during continued inductive heating. In the field of electrical connection of contact elements, REUL discloses wherein at least one of the contact elements (contact element #14, fig.1) is inductively heated (soldering tool #13, fig.1 and refer to Paragraph 0076 cited: “…The soldering tool 13 contains (at least) one induction loop 13I or one induction coil that is supplied with an alternating voltage with adjustable frequency and power by a commercial generator …”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bohlender’s method with heating the contact element inductively, as taught by REUL, in order to provide a specific heating and also control vicinity of the heating area (refer to Paragraph 0018 cited: “…The method according to the invention has the particular advantage that the contact element and the adjacent solder deposit are heated specifically and the vicinity of the conductor structure around the first solder connection surface is, in contrast, heated only slightly…”), such that would produce lesser defect by reducing over heating unnecessary area, and increase in energy efficiency by only heating necessary area. However, REUL does not explicitly disclose wherein at least one of the contact elements is preheated, and then the contact element is applied to the PTC element and soldered thereto at a phase boundary between the contact elements and the PTC element during continued inductive heating. In the field of soldering component, WANT discloses wherein at least one of the contact elements (refer to “the lead” cited in Paragraph 0011 below) is first pre-heated, and then the contact element (refer to “the lead” cited in Paragraph 0011 below) is applied to the PTC element (refer to “the land” cited in Paragraph 0011 below) and soldered thereto at a phase boundary (refer to Examiner’s assumption in 112b rejection above, and “adhesion” cited in Paragraph 0011 below) between the contact elements (refer to “the lead” cited in Paragraph 0011 below) and the PTC element (refer to “the lead” cited in Paragraph 0011 below) during continued inductive heating (refer to Paragraph 0011 cited: “…it is necessary to preheat the land and the lead at the soldering point to a temperature close to the melting temperature of the solder, in advance of soldering, In a state in which the land and the lead of the electronic component are not preheated and thus have a low temperature, when the solder melted by the laser beam contacts with the lead or the land in the low-temperature state, the solder immediately solidifies, so that adhesion thereof is lost, leading to soldering fault …”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bohlender’s method with wherein at least one of the contact elements is preheated, and then the contact element is applied to the PTC element and soldered thereto, as taught by WANT, in order to provide a better adhesion in the soldering (refer to Paragraph 0011 cited: “…In a state in which the land and the lead of the electronic component are not preheated and thus have a low temperature, when the solder melted by the laser beam contacts with the lead or the land in the low-temperature state, the solder immediately solidifies, so that adhesion thereof is lost, leading to soldering fault …”), such that would reduce defect and soldering fault being produce. Claims 7 and 9 are rejected under 35 U.S.C. 103 as being unpatentable over Bohlender et al (US2016/0360573A1 Previously cited) herein set forth as Bohlender, in view of GEISHECKER et al (US3955170 newly cited) herein set forth as GEISHECKER. Regarding claim 7, Bohlender discloses a positive temperature coefficient (PTC) heating cell (PTC heating element #2, fig.1) comprising: at least one PTC element (PTC element #4, fig.1); and contact elements (contact plate #6, fig.1) which are made of an electrically conductive material (refer to Paragraph 0036 cited: “…which is arranged between two strip conductors 6 formed as contact plates of sheet metal…”) and which are electrically conductively abutted (refer to fig.1) against the PTC element (PTC element #4, fig.1), wherein the contact elements (contact plate #6, fig.1) are soldered (refer as “adhesive” in Paragraph 0036 cited: “…The contact plate is connected for the formation of a PTC heating element to the PTC element 4 by way of an adhesive, preferably an electrically conductive adhesive…”) to the PTC element (PTC element #4, fig.1) such that only a solder of a solder connection (refer as “electrically conductive adhesive” in Paragraph 0036 cited: “…The contact plate is connected for the formation of a PTC heating element to the PTC element 4 by way of an adhesive, preferably an electrically conductive adhesive…”) is provided between a PTC material of the PTC element (PTC element #4, fig.1) and the contact element (#3 and #4, fig.1-4), and wherein the solder of the solder connection (refer as “electrically conductive adhesive” in Paragraph 0036 cited: “…The contact plate is connected for the formation of a PTC heating element to the PTC element 4 by way of an adhesive, preferably an electrically conductive adhesive…”) is exclusively (refer to fig.1, Examiner note: figure show that there is adhesive outside of the connection) disposed between the PTC material of the PTC element (PTC element #4, fig.1) and the contact element (contact plate #6, fig.1), Wherein a contact surface (refer to the contact surface of #6.1 in fig.1) of each of the contact elements (contact plate #6, fig.1) is sized same than a surface area (refer to the surface area of the whole #4 in fig.1) of the PTC element (PTC element #4, fig.1). PNG media_image1.png 403 677 media_image1.png Greyscale Bohlender does not explicitly disclose Wherein a contact surface of each of the contact elements is sized smaller than the respective main side surface of the PTC element. In the field of making a PTC electrode component, GEISHECKER discloses Wherein a contact surface of each of the contact elements (#36 and #38, fig.3-5) is sized smaller than the respective main side surface of the PTC element (#26, fig.5). PNG media_image2.png 778 523 media_image2.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filing date to substitute the Bohlender’s contact element with GEISHECKER’s contact element, because the substitution of one known element for another would have yielded predictable results. Regarding claim 9, the modification of Bohlender and GEISHECKER discloses substantially all features set forth in claim 7, Bohlender does not discloses wherein the contact surface of each contact element is annular in shape. In the field of making a PTC electrode component, GEISHECKER further discloses wherein the contact surface of each contact element (#36 and #38, fig.3-5) is annular in shape (refer to the shape of #36 and #38 in fig.3 and 4). It would have been obvious to one of ordinary skill in the art before the effective filing date to substitute the Bohlender’s contact element with GEISHECKER’s contact element, because the substitution of one known element for another would have yielded predictable results. Response to Argument Applicant's arguments filed August 27th 2025 have been fully considered but most of the arguments moot in view of the new ground(s) of rejection in the new 103 combination rejection with a new secondary prior art of GEISHECKER et al (US3955170 newly cited). Applicant argued: “…Any such reduction in the size of the contact plates 6 would necessitate the addition of more insulating mass 10 to fill the resultant gap between the PTC element 4 and the hybrid film 8. That is, any gap created between the PTC element 4 and the hybrid film 8 would comprise the structural integrity of the PTC heating element 2 and need to be filled…” in Remark page 3. Examiner response: It is noted that one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. The newly cited GEISHECKER clearly show in fig. 5 #24 as gap, and the structure of #36 and #38 in fig.5 show how contact elements support and maintain the integrity of the PTC element. Therefore, the argument is not persuasive. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to YEONG JUEN THONG whose telephone number is (571)272-6930. The examiner can normally be reached Monday - Friday. 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, Helena Kosanovic can be reached at (571) 272-9059. 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. /YEONG JUEN THONG/Examiner, Art Unit 3761 December 22th 2025 /HELENA KOSANOVIC/Supervisory Patent Examiner, Art Unit 3761
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Prosecution Timeline

May 13, 2021
Application Filed
Jan 11, 2024
Non-Final Rejection — §103
Jun 26, 2024
Response Filed
Aug 17, 2024
Final Rejection — §103
Oct 28, 2024
Response after Non-Final Action
Oct 31, 2024
Response after Non-Final Action
Dec 04, 2024
Request for Continued Examination
Dec 05, 2024
Response after Non-Final Action
Jan 09, 2025
Non-Final Rejection — §103
Apr 02, 2025
Examiner Interview Summary
Apr 02, 2025
Applicant Interview (Telephonic)
May 13, 2025
Response Filed
May 22, 2025
Final Rejection — §103
Aug 27, 2025
Response after Non-Final Action
Oct 23, 2025
Request for Continued Examination
Oct 31, 2025
Response after Non-Final Action
Dec 22, 2025
Non-Final Rejection — §103
Mar 30, 2026
Response Filed

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Prosecution Projections

5-6
Expected OA Rounds
48%
Grant Probability
99%
With Interview (+51.9%)
3y 5m
Median Time to Grant
High
PTA Risk
Based on 149 resolved cases by this examiner