Prosecution Insights
Last updated: April 19, 2026
Application No. 17/616,114

COLD ROLLED AND COATED STEEL SHEET AND A METHOD OF MANUFACTURING THEREOF

Non-Final OA §103
Filed
Dec 02, 2021
Examiner
JOHNSON, JONATHAN J
Art Unit
1734
Tech Center
1700 — Chemical & Materials Engineering
Assignee
ArcelorMittal
OA Round
3 (Non-Final)
25%
Grant Probability
At Risk
3-4
OA Rounds
3y 8m
To Grant
22%
With Interview

Examiner Intelligence

Grants only 25% of cases
25%
Career Allow Rate
23 granted / 93 resolved
-40.3% vs TC avg
Minimal -3% lift
Without
With
+-3.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
14 currently pending
Career history
107
Total Applications
across all art units

Statute-Specific Performance

§101
1.2%
-38.8% vs TC avg
§103
57.1%
+17.1% vs TC avg
§102
8.6%
-31.4% vs TC avg
§112
23.2%
-16.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 93 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 . 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. Claim(s) 28-44 and 58-60 are rejected under 35 U.S.C. 103 as being unpatentable over Ennis et al. (US-20160017472-A1), hereinafter Ennis, in view of Hidekazu et al. (WO-2018043473-A1), hereinafter Hidekazu, where an English machine translation is used and cited herein. Regarding claims 28-35. 41-42, and 60, Ennis teaches a galvanized steel strip ([0001]) produced by cold rolling ([0040]) which constitutes the claimed cold rolled and coated steel sheet. Ennis further teaches the steel including the elements and microstructure as shown in Table 1. Table 1 Element Claim Range Ennis Citation Relationship C 28 30 35 0.12-0.2 0.12-0.19 0.14-0.18 0.13-0.19 [0008] Within Within Encompassing Si 28 29 0.1-0.5 0.1-0.4 0.15 or less [0010] Overlapping Overlapping Al 28 31 0.1-0.8 0.2-0.8 0.4-1 [0011] Overlapping Overlapping Cr 28 33 0.1-0.5 0.1-0.4 0.05-0.25 [0012] Overlapping Overlapping P 28 0-0.09 0.1 or less [0014] Overlapping S 28 0-0.09 0.05 or less [0016] Overlapping N 28 0-0.09 0.007 or less [0017] Within Ni 28 0-3 0.5 or less [0022] Within Ti 28 0-0.1 0.5 or less [0019] Overlapping Cu 28 0-2 0.5 or less [0023] Within Mo 28 0-0.5 0.5 or less [0021] Within V 28 0-0.1 0.4 or less [0020] Overlapping B 28 0-0.003 0.005 or less [0024] Overlapping Bainite 28 41 10-60 20-60 20-50 [0026] Within Within Ferrite 28 25-55 Remainder (38-62) [0026] Overlapping Residual Austenite 28 5-15 8-12 [0026] Within Martensite 28 42 60 11.2-18 11.2-15 11.2-13.6 10 or less [0026] close close Bainite + Ferrite 28 At least 70 58-92 By amounts above Overlapping In the case where the claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists (see In re Wertheim and MPEP § 2144.05). In the case where the claimed ranges are “close”, typically, "[a] prima facie case of obviousness exists when the claimed range and the prior art range do not overlap but are close enough such that one skilled in the art would have expected them to have the same properties." In re Peterson, 315 F.3d 1325, 1329 (Fed. Cir. 2003) (emphasis omitted); see also Titanium Metals v. Banner, 778 F.2d 775, 783 (Fed. Cir. 1985). In the instant case, where the claimed martensite is very close to the lower portion of Ennis’ range, absent evidence to the contrary, one of ordinary skill would have expected a martensite of less than 10% to have the same properties as a martensite of 11.2%. Given that reasonable expectation, it would have been obvious to one of ordinary skill to employ a Ennis’ martensite to be within the claimed range. See Peterson, 315 F.3d at 1329; see also Titanium, 778 F.2d at 783. Ennis further teaches the steel including 1.7-2.5% Mn ([0032]) with examples having 1.73-2.054% Mn (Table 1) which is within the claimed 1.7-2.1% Mn of claim 28, within the claimed 1.7-2.08% Mn of claim 32, and overlapping the claimed 1.8-2.08% Mn of claim 34. Ennis does not disclose a particular carbon content of the retained austenite. Hidekazu teaches a steel sheet ([0001]) and teaches that the carbon content of austenite may be adjusted to obtain a good balance between strength and ductility ([0060]). In order to obtain a good balance between strength and ductility as taught by Hidekazu, a person having ordinary skill in the art may through routine experimentation have come to a value overlapping the claimed carbon content in the residual austenite is 0.7% to 1% in the steel according to Ennis. Regarding claim 36, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. As discussed above, Ennis teaches a C content of 0.13-0.19 and a Mn content of 1.73-2.054 which results in a cumulative amount of C and Mn of 1.86-2.2404 which encompasses the claimed a cumulated amount of carbon and manganese is between 2.1% and 2.25%. Regarding claim 37, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. As discussed above, Ennis teaches a Si content of 0.15 or less and an Al content of 0.4-1 which results in a cumulative amount of Si and Al of 0.4-1.15 which encompasses the claimed a cumulated amount of Si and Al is between 0.5 and 0.9%. Regarding claim 38, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. As discussed above, Ennis teaches a Ferrite content of 38-62% and a Bainite content of 20-50% which results in a cumulative amount of Ferrite and Bainite of 58-82% which overlaps the claimed a cumulated amount of Ferrite and Bainite is more than or equal to 74% and is within the claimed the percentage of Ferrite is at least 30%. Regarding claim 39, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. As discussed above, In order to obtain a good balance between strength and ductility as taught by Hidekazu, a person having ordinary skill in the art may through routine experimentation have come to a value overlapping the claimed carbon content in the residual austenite is between 0.7% and 0.9% in the steel according to Ennis. Regarding claim 40, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. As discussed above, In order to obtain a good balance between strength and ductility as taught by Hidekazu, a person having ordinary skill in the art may through routine experimentation have come to a value overlapping the claimed carbon content in the residual austenite is between 0.7% and 0.8% in the steel according to Ennis. Regarding claim 43, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. Ennis further teaches the steel having an ultimate tensile strength of at least 780 MPa ([0050]) and a total elongation of at least 16% ([0052]) which is within the claimed ultimate tensile strength of 780 MPa or more and overlaps the claimed total elongation of 18% or more. Regarding claim 44, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. Ennis further teaches the steel having an ultimate tensile strength of at least 780 MPa ([0050]) and a total elongation of at least 16% ([0052]) as well as examples having a uniform elongation of 0.18 (Table 2, C5, [0074]) which is less than the total elongation which overlaps the claimed ultimate tensile strength of 800 MPa or more and overlaps the claimed total elongation of greater than or equal to 20%. Regarding claim 58, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. Ennis does not explicitly disclose 0.25 to 0.4% Si. However, Ennis teaches having “no objection to the presence of some Si in the steel, since Si ensures a better retardation of carbides during averaging which is advantageous for the formability of the steel” (para. 46). Ennis further teaches maintaining between 0.4 and 1.05% of aluminum and silicon. (para. 42). In other words, Ennis teaches that aluminum and silicon are result effective variables. As such, it would have been within the skill of one of ordinary skill in the art to optimize amount of aluminum and silicon in the combined invention of Ennis and Hidekazu to arrive at a composition within the claimed ranges of aluminum and silicon in order to ensure the formability of the steel (see Ennis, para. 46). Regarding claim 59, Ennis as modified by Hidekazu teaches the claim elements as discussed above regarding claim 28. Although Ennis teaches a preferred embodiment of Nb fin an amount of 0.01 to 0.04% (para 49) but warns that it is costly (para 49). Ennis also teaches Nb is an “optional element” (see paras 38-40). Thus, it would have been within the skill in the art to omit Nb in order to make the ultimate steel more cost-effective (Ennis, para. 49). Response to Arguments Applicants state that limiting the martensite content in claim 28 “may overcome the current rejection.” The examiner agrees. The examiner notes, however, that a new basis for rejection is provided in this office action involving Titanium metals, which was not the basis of the previous rejection. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JONATHAN J JOHNSON whose telephone number is (571)272-1177. The examiner can normally be reached Monday-Friday, 6:30 AM - 3 PM. 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, Alexa Neckel can be reached at 571-272-2450. 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. JONATHAN JOHNSON Primary Examiner Art Unit 1734 /JONATHAN JOHNSON/ Primary Examiner, Art Unit 1734
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Prosecution Timeline

Dec 02, 2021
Application Filed
Oct 17, 2024
Non-Final Rejection — §103
Feb 21, 2025
Response Filed
May 29, 2025
Final Rejection — §103
Sep 29, 2025
Applicant Interview (Telephonic)
Oct 01, 2025
Examiner Interview Summary
Nov 03, 2025
Request for Continued Examination
Nov 04, 2025
Response after Non-Final Action
Mar 05, 2026
Non-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

3-4
Expected OA Rounds
25%
Grant Probability
22%
With Interview (-3.2%)
3y 8m
Median Time to Grant
High
PTA Risk
Based on 93 resolved cases by this examiner. Grant probability derived from career allow rate.

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