Prosecution Insights
Last updated: April 19, 2026
Application No. 17/448,198

COMPOSITE ELECTRONIC DEVICE COMPONENTS

Non-Final OA §103§112
Filed
Sep 20, 2021
Examiner
LA VILLA, MICHAEL EUGENE
Art Unit
1784
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Apple Inc.
OA Round
5 (Non-Final)
75%
Grant Probability
Favorable
5-6
OA Rounds
2y 9m
To Grant
94%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allow Rate
693 granted / 921 resolved
+10.2% vs TC avg
Strong +19% interview lift
Without
With
+18.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
30 currently pending
Career history
951
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
34.2%
-5.8% vs TC avg
§102
17.3%
-22.7% vs TC avg
§112
36.6%
-3.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 921 resolved cases

Office Action

§103 §112
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 3 March 2026 has been entered. Specification The specification is objected to as failing to provide proper antecedent basis for the claimed subject matter. See 37 CFR 1.75(d)(1) and MPEP § 608.01(o). Correction of the following is required: It is unclear where Specification refers to “engagement surface,” and it is unclear where the Specification refers to a feature comprising a combination of aperture and engagement surface wherein exterior portion defines first part of engagement surface and interior portion defines second part of engagement surface. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the claimed “engagement surface,” and a feature being a combination of aperture and engagement surface wherein exterior portion defines first part of engagement surface and interior portion defines second part of engagement surface. must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1 and 3-7 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. It is unclear where Specification provides written description support for “engagement surface,” and for a feature comprising a combination of aperture and engagement surface wherein exterior portion defines first part of engagement surface and interior portion defines second part of engagement surface. It is noted that the Specification refers to “engagement features” (e.g., Specification at paragraph 49). However, these, as best understood, constitute alternatives to the already claimed diffusion bonding that is claimed. None of the citations to the Specification or Figures of the Response at page 7 appear to relate to this specific language. To the extent that “engagement surface” is something other than “engagement features”, it is unclear how there is support unless it is merely a restatement of “faces” that are inherently present when aperture is formed where there are exterior and interior portions. To the extent that “engagement surface” relates to “engagement features” it is unclear how the citations provided by applicant are relevant. It is further unclear how this language does or does not relate to the aperture of the type depicted in Figure 5b in terms of written description support. The following is a quotation of 35 U.S.C. 112(b): CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1 and 3-7 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Regarding Claim 1, it is unclear what is meant by “engagement surface”. There is no apparent description in the Specification or apparent definition in the prior art. The arguments appear to characterize it as the “face” of the aperture, but it is unclear how this would constitute an engagement, particularly since the Specification appears to relate the term engagement to means of joining exterior and interior portions. 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: Determining the scope and contents of the prior art. Ascertaining the differences between the prior art and the claims at issue. Resolving the level of ordinary skill in the pertinent art. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim(s) 1, 3-5, and 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hsu et al. USPA 2012/0244385 in view of Ganchrow USPA 2016/0164186. Hsu teaches housing (paragraph 2) for electronic device (paragraphs 4 and 19) of first metal or exterior portion (paragraphs 21 and 23) and second metal (Figure 3; and paragraph 32) of interior portion that defines interior volume (Figure 3) wherein the thickness of first metal can be more than 25 microns (paragraph 24) and wherein first and second metal are diffused into each other by diffusion bonding (paragraph 23). As mentioned, Hsu teaches that the diffusion layer is an outer surface of housing, from which it follows that the second metal is present at the interior portion defining interior volume. Hsu teaches that the titanium nitride diffusion layer forms at the outer surface. Thus, this titanium is the first metal, by itself or in combination with the metal of the blank that forms the metal material in Hsu. Hsu teaches that this diffused layer has much higher hardness than the base metal, meeting the hardness relationship being claimed (paragraph 26), Hsu teaches that diffusion layer can be up to 125 microns, rendering obvious this thickness (paragraph 24). Thus, the innermost portion of the diffusion layer may be identified with the claimed “diffused bonded” feature of Claim 1 and the remainder of at least 25 microns thickness, on exterior surface portion, may be identified with the claimed “exterior portion comprising a first metal”. Hsu does not teach “a feature”. Ganchrow teaches provision of aperture in phone housing for antennas (Figures 5a and 5b; and paragraphs 31). It would have been obvious to one of ordinary skill in the art before the time of filing to prepare article with such a feature suggested by Ganchrow in order to provide effective housing for intended electronic device. In doing so, aperture defined by both first and second metal would be expected to be obtained (i.e., one comparable to what is shown in Figure 5b of the Specification). Hsu teaches that titanium nitride forms by diffusion bonding (paragraphs 23 and 31). Regarding Claim 3, Hsu, as mentioned above, suggests effective thickness of diffusion layer in total is 125 microns (paragraph 24). Thus, in doing so, the interface zone necessarily would be less than ca. 1 mm. Regarding Claim 4, Hsu teaches titanium in the titanium nitride. As well, this diffusion layer forms on material that can also contain stainless steel, titanium, or aluminum (alloy) (paragraph 32), rendering obvious titanium, aluminum, or steel. Regarding Claim 5, as mentioned above, Hsu suggests the blank can be aluminum (alloy) (paragraph 32), rendering obvious claimed second metal. Regarding Claim 7, as mentioned above, Hsu suggests the blank can be aluminum (alloy) (paragraph 32). Upon treatment with titanium nitride, the outermost material would be a different titanium concentrated aluminum alloy from that of the untreated blank, the composition of which would be what is now that of the interior metal material. Thus, there would be expected to be two different aluminum alloys as required. Response to Amendment In view of applicant’s amendments and arguments, applicant traverses the section 103 rejection over Hsu in view of Ganchrow of the Office Action mailed on 3 December 2025. Applicant argues that Ganchrow fails to teach or suggest an aperture having a face defined by interior and exterior portion as claimed. However, as acknowledged by applicant, Ganchrow teaches forming aperture (“slots”) in the housing (Figure 7: 710, 720). For the reasons of the rejection, it would have been obvious to form such aperture in the housing of Hsu. Noting that the housing of Hsu has structure of exterior and interior portion, the resulting slit aperture rendered obvious by Ganchrow can be characterized as having claimed aperture with a face defined by “first part” being in the exterior portion of housing of Hsu and claimed “second part” being in the interior portion of the housing of Hsu. Thus, in Hsu’s Figure 4 the aperture with engagement face could be present as a slit in the thickness direction with the first part/exterior portion being in 14 and the second part /interior portion being in 12. Thus, while Ganchrow does not show claimed aperture engagement surface of two separate metals, the slit of Ganchrow when introduced into Hsu’s housing does and it would be obvious to do so for the reasons of the rejection. It is further remarked that it is unclear how the introduction of “engagement surface” limitation in view of arguments relating to “face” is to be thought as changing or narrowing claim scope if it is supposed to. Rejection is maintained. Allowable Subject Matter Regarding Claim 6, the reviewed prior art does not teach or suggest the subject matter of this claim. Particularly, the reviewed prior art does not teach or suggest the claimed combination of materials in the claimed context. For example, Hsu USPA 2012/0244385 fails to teach or suggest this combination of materials. See Hsu (entire document). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL E. LA VILLA whose telephone number is (571)272-1539. The examiner can normally be reached Mon. through Fri. from 9:00 a.m. ET to 5:30 p.m. ET. 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, Humera N. Sheikh can be reached on (571) 272-0604. 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. /MICHAEL E. LA VILLA/Primary Examiner, Art Unit 1784 3 April 2026
Read full office action

Prosecution Timeline

Sep 20, 2021
Application Filed
May 02, 2024
Non-Final Rejection — §103, §112
Jul 31, 2024
Applicant Interview (Telephonic)
Jul 31, 2024
Examiner Interview Summary
Aug 07, 2024
Response Filed
Jan 10, 2025
Final Rejection — §103, §112
Feb 13, 2025
Examiner Interview Summary
Feb 13, 2025
Applicant Interview (Telephonic)
Feb 17, 2025
Response after Non-Final Action
Apr 15, 2025
Request for Continued Examination
Apr 16, 2025
Response after Non-Final Action
May 21, 2025
Non-Final Rejection — §103, §112
Aug 12, 2025
Applicant Interview (Telephonic)
Aug 12, 2025
Examiner Interview Summary
Aug 22, 2025
Response Filed
Nov 29, 2025
Final Rejection — §103, §112
Jan 20, 2026
Response after Non-Final Action
Mar 03, 2026
Request for Continued Examination
Mar 06, 2026
Response after Non-Final Action
Apr 03, 2026
Non-Final Rejection — §103, §112 (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

5-6
Expected OA Rounds
75%
Grant Probability
94%
With Interview (+18.8%)
2y 9m
Median Time to Grant
High
PTA Risk
Based on 921 resolved cases by this examiner. Grant probability derived from career allow rate.

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