Prosecution Insights
Last updated: April 17, 2026
Application No. 17/365,087

ITEM-CONTAINING PILLOW

Final Rejection §103
Filed
Jul 01, 2021
Examiner
MCCLURE, MORGAN J
Art Unit
3673
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
unknown
OA Round
6 (Final)
47%
Grant Probability
Moderate
7-8
OA Rounds
3y 2m
To Grant
79%
With Interview

Examiner Intelligence

Grants 47% of resolved cases
47%
Career Allow Rate
216 granted / 459 resolved
-4.9% vs TC avg
Strong +32% interview lift
Without
With
+32.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
32 currently pending
Career history
491
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
58.9%
+18.9% vs TC avg
§102
17.6%
-22.4% vs TC avg
§112
18.7%
-21.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 459 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 . Response to Arguments Applicant’s arguments with respect to claim(s) 1-15, 17-18, and 20-21 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. A new rejection is set forth in response to the amendments. 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(s) 1-6, 17, 18, and 21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Theis (US Patent 10251808) in view of England (US Patent 6918146). Regarding claim 1, Theis teaches a pillow comprising: a core (Figure 3; 100) that provides a plurality of spaced-apart cavities (Figure 2; 182a and 182b and 184a and 184b), wherein the pillow comprises a perimeter (Figure 5; as shown) when closed, said perimeter having a side, wherein the pillow comprises a hinge (Figure 5; at 112) on said side, wherein the pillow is openable along the hinge to access the cavities in the core, wherein when the core is closed the cavities are contained by the core (Figure 5; as shown), wherein the core comes into direct contact with itself when pivoted along the core hinge into the closed position (Figure 5; 104, 106 as shown), wherein the core comprises a first portion having a plurality of first recesses (Figure 2; 104 and 182a and 182b) and second portion having a plurality of second recesses (Figure 2; 106 and 184a and 184b), wherein the first portion and second portion of the core come together to form said cavities when said core is closed along the core hinge (Figure 10; 180), wherein the cavities comprise the first recesses and the second recesses in direct communication with each other (Figure 10; 180 as shown). Theis does not teach wherein the core comprises a core hinge, wherein the core comprises a single piece which is pivotable into a closed position along the core hinge. England teaches the core comprises a core hinge, wherein the core comprises a single piece which is pivotable into a closed position along the core hinge (Figure 4b shows a core with two hinged pieces at 46 and 48 which are hinged by the piece itself). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and arrived at a foam cushion with a hinge formed from the foam piece itself . One of ordinary skill in the art would have been motivated to make such a combination because it “allows each seat cushion to be individually customized by a user of that seat cushion” as taught in England (Column 1; lines 55-57). Regarding claim 2, Theis teaches the pillow is configured to contain items in the cavities, wherein the items are accessible by opening the pillow along the hinge (Figure 9; 200, see also Figure 20). Regarding claim 3, Theis teaches the pillow comprises an outer surface, wherein a covering is on the outer surface of the pillow (Figure 1; 101). Regarding claim 4, Theis teaches at least one closure mechanism is on the covering (Figure 1; Z). Regarding claim 5, Theis teaches a tether on the at least one closure mechanism (Figure 1; Z, Examiner note that zippers contain tethers). Regarding claim 6, Theis teaches the at least one closure mechanism is provided along the perimeter of the pillow but not along at least a majority of a length of the hinge (Figure 1; z is provided at a perimeter of the pillow which is not the hinge, as shown). Regarding claim 17, Theis teaches the pillow comprises an outer surface, wherein a covering is on the outer surface of the pillow, wherein the covering has either a decorative appearance (Figure 1; 101, any cover would naturally have a decorative appearance in some way) and/or relates to one or more brands. Regarding claim 18, Theis teaches the core goes along the whole perimeter of the pillow (Column 9; lines 26-45 describe how the hinge connections may be removable which would allow a configuration without cushions 102 and 108 in which case the core would go along the whole perimeter). Regarding claim 21, Theis teaches the first recesses are shaped like the second recesses (Figure 2; 182a and 182b and 184a and 184b, as shown). Claim(s) 7-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Theis (US Patent 10251808) in view of England (US Patent 6918146) further in view of in view of The DIY Mommy NPL (https://www.youtube.com/watch ?v=aFGbWzNFKaA). Regarding claim 7, Theis does not teach piping on the covering. The DIY Mommy NPL teaches piping on the covering (at 11:40). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and The DIY Mommy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 8, Theis teaches at least one closure mechanism is on the covering (Figure 1; z). Theis does not teach wherein the piping is provided along the perimeter of the pillow, proximate a travel path of the at least one closure mechanism. The DIY Mommy NPL teaches wherein the piping is provided along the perimeter of the pillow, proximate a travel path of the at least one closure mechanism (At 11:40 the piping on the left side is attached to the flap which together hide the teeth of the zipper at different viewing angles). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and The DIY Mommy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 9, Theis teaches at least one closure mechanism is on the covering (Figure 1; z). Theis does not teach wherein the piping hides teeth of the at least one closure mechanism. The DIY Mommy NPL teaches the piping hides teeth of the at least one closure mechanism (At 11:40 the piping on the left side is attached to the flap which together hide the teeth of the zipper and closure mechanism at different viewing angles). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and The DIY Mommy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Claim(s) 10-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Theis (US Patent 10251808) in view of England (US Patent 6918146) further in view of Sweet Red Poppy NPL (ittys://sweetrednonny.com/Halloween-make- palooza-diy-pillows-cricut-maker/). Regarding claim 10, Theis does not teach a flap on the covering. Sweet Red Poppy teaches a flap on the covering (Figure 10 shows a flap, covering the zipper shown in Figure 9, with tassels coming off the edge of the flap). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and Sweet Red Poppy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 11, Theis teaches at least one closure mechanism is on the covering (Figure 1; Z). Theis does not teach wherein the flap is provided along the perimeter of the pillow, proximate a travel path of the at least one closure mechanism. Sweet Red Poppy teaches wherein the flap is provided along the perimeter of the pillow, proximate a travel path of the at least one closure mechanism (Figures 9 and 10 show that the flap is proved on the perimeter of the pillow along the zipper track). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and Sweet Red Poppy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 12, Theis teaches at least one closure mechanism is on the covering (Figure 1; Z). Theis does not teach wherein the flap hides teeth of the at least one closure mechanism. Sweet Red Poppy teaches the flap hides teeth of the at least one closure mechanism (Figures 9 and 10 show the flap covers the zipper pull, at least partially). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and Sweet Red Poppy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 13, Theis does not teach at least one tassel connected to the flap. Sweet Red Poppy teaches at least one tassel connected to the flap (Figure 10 shows a flap, covering the zipper shown in Figure 9, with tassels coming off the edge of the flap). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and Sweet Red Poppy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 14, Theis does not teach at least one tassel connected to the flap. Sweet Red Poppy teaches at least one tassel connected to the flap (Figure 10 shows a flap, covering the zipper shown in Figure 9, with tassels coming off the edge of the flap). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and Sweet Red Poppy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Regarding claim 15, Theis does not teach at least one tassel connected to the flap. Sweet Red Poppy teaches at least one tassel connected to the flap (Figure 10 shows a flap, covering the zipper shown in Figure 9, with tassels coming off the edge of the flap). Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined combined Theis (directed to a foam cushion with a hinge) and England (directed to a foam cushion with a hinge formed from the foam piece itself) and Sweet Red Poppy NPL (directed to a pillow with a hidden zipper) and arrived at a hinged pillow with a hinge formed from the foam piece itself, with a hidden zipper. One of ordinary skill in the art would have been motivated to make such a combination in order to improve the overall appearance of the pillow and make it more aesthetically pleasing to the user. Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Theis (US Patent 10251808) in view of England (US Patent 6918146) further in view of Murray (US Patent 8245339). Regarding claim 20, Theis does not teach the closure mechanism starts and ends along the hinge of the pillow such that the closure mechanism can be opened, and the pillow pivoted open along the hinge of the pillow. Murray teaches the closure mechanism starts and ends along the hinge of the pillow such that the closure mechanism can be opened, and the pillow pivoted open along the hinge of the pillow (Figure 1; 38 and hinge 28/30, see also Figure 2, 38 and 30) . Accordingly, it would have been obvious to one of ordinary skill in the art before the invention was effectively filed to have combined Theis (directed to hinged pillow with an outer cover) and England (directed to a core hinge formed from the single piece core) and Murray (directed to a hinged pillow with an outer covering to hold the pillow in the closed hinged position) and arrived at a hinged pillow with a core hinge with an outer covering to hold the pillow in the closed hinged position. One of ordinary skill in the art would have been motivated to make such a combination to provide “a cushioning device that is adaptable for easy adjustment in comfort” as taught in Murray (Column 1; lines 5-6). Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MORGAN J MCCLURE whose telephone number is (571)270-0362. The examiner can normally be reached Tuesdays 12pm-10pm and Thursdays 12pm-10pm. 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, Justin Mikowski can be reached at 5712728525. 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. /MORGAN J MCCLURE/Examiner, Art Unit 3673 /Matthew Troutman/Supervisory Patent Examiner, Art Unit 3679
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Prosecution Timeline

Jul 01, 2021
Application Filed
Oct 21, 2023
Non-Final Rejection — §103
Mar 27, 2024
Response Filed
Apr 07, 2024
Final Rejection — §103
Sep 16, 2024
Request for Continued Examination
Oct 02, 2024
Response after Non-Final Action
Oct 09, 2024
Non-Final Rejection — §103
Oct 21, 2024
Response Filed
Jan 10, 2025
Final Rejection — §103
Apr 17, 2025
Response after Non-Final Action
May 07, 2025
Request for Continued Examination
May 13, 2025
Response after Non-Final Action
May 22, 2025
Non-Final Rejection — §103
Jun 26, 2025
Response Filed
Oct 23, 2025
Final Rejection — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

7-8
Expected OA Rounds
47%
Grant Probability
79%
With Interview (+32.2%)
3y 2m
Median Time to Grant
High
PTA Risk
Based on 459 resolved cases by this examiner. Grant probability derived from career allow rate.

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