Prosecution Insights
Last updated: April 19, 2026
Application No. 17/764,174

VEHICLE COCKPIT COMPONENT PROVIDED WITH AN IMPROVED HEATING DEVICE

Non-Final OA §103
Filed
Mar 26, 2022
Examiner
CHOU, JIMMY
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Martur Italy S R L
OA Round
3 (Non-Final)
71%
Grant Probability
Favorable
3-4
OA Rounds
3y 4m
To Grant
87%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allow Rate
594 granted / 836 resolved
+1.1% vs TC avg
Strong +16% interview lift
Without
With
+15.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
40 currently pending
Career history
876
Total Applications
across all art units

Statute-Specific Performance

§101
0.8%
-39.2% vs TC avg
§103
44.0%
+4.0% vs TC avg
§102
16.2%
-23.8% vs TC avg
§112
34.4%
-5.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 836 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 . 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 12/29/2025 has been entered. 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, 8-9, 12, 20, 22-23, 27-30 and 32 is/are rejected under 35 U.S.C. 103 as being unpatentable over Diemer et al. (US 2010/0000981) in view of Kiziltas et al. (US 2021/0363317 A1) and Blake et al. (US 2008/0142494). Regarding claim 1, Diemer discloses “a vehicle cockpit component” (abstract and fig.7a-b), comprising “a supporting frame” (annotated fig.7b, a supporting frame); and “a padding” (5, 6, 7 and 8) fitted on “the supporting frame” (annotated fig.7b), the padding (5, 6, 7 and 8) comprising a polyurethane-based foam includes “an electrically conductive filler” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler) wherein “a concentration of electrically conductive filler in the polyurethane-based foam to trigger a first conductive pathway in the polyurethane-based foam ” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler in the polyurethane-based foam) includes mechanical properties required of a cushioning material and that includes an electrically conductive filler” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Examiner noted that polyurethane is generally an electrical insulator, but its conductivity can be enhanced by adding conductive additives during manufacturing); wherein “the polyurethane-based foam with the electrically conductive filler” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is directly connected to “means for generating a voltage difference” ([0102] After hardening of the electrically conductive polyurethane foam, it is flexible and in electrically conductive contact with the contact ends 9 and 10 of the power supply wires 11 and 12 and forms the heating layer 7. [0122], i.e., the heating layer 7 containing the electrically conductive plastic material to a power supply (not shown)), whereby “heat is generated by Joule effect in the padding when the voltage difference is applied” ([0122], i.e., Since the electrical resistance of the heating layer 7 is constant, the heating temperature can be determined or regulated by the supplied electric power. Examiner noted that when voltage pass through resister or heating layer, it creates the voltage difference), and wherein “one or more portions of the padding provide both a cushioning material and a heating device of the vehicle cockpit component” (fig.7a shows padding 5, 6, 7 and 8 can be used to provide a cushioning material and heating device of the vehicle component). Diemer is silent regarding a polyurethane-based foam matrix. Kiziltas et al. teaches “a polyurethane-based foam matrix” ([0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Examiner noted that rigid foam matrix is considered as non-collapsed when no force acting on it). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Kiziltas et al., by replacing Diemer’s polyurethane-based foam material with Kiziltas et al.’s non-collapsed polyurethane-based foam matrix material to provide a rigid foam for vehicle components (para.0028-0029) as taught by Kiziltas et al. One skilled in the art would have found it obvious to substitute Diemer’s polyurethane-based foam material with Kiziltas et al.’s non-collapsed polyurethane-based foam matrix material are both recognized by the art for the same purpose of supporting component for a vehicle. MPEP 2144.06. Diemer is silent regarding a concentration of electrically conductive filler is in a range between a minimum threshold, corresponding to a quantity of electrically conductive filler needed to trigger a first conductive pathway and a maximum threshold, corresponding to a saturation of conductive pathways without reaching the maximum threshold and remaining within 50% of said range closer to the maximum threshold so that the polyurethane-based foam matrix is non-collapsed. Blake et al. teaches “a concentration of electrically conductive filler is in a range between a minimum threshold, corresponding to a quantity of electrically conductive filler needed to trigger a first conductive pathway and a maximum threshold, corresponding to a saturation of conductive pathways without reaching the maximum threshold and remaining within 50% of said range closer to the maximum threshold so that the polyurethane-based foam matrix is non-collapsed” ([0046], i.e., In one embodiment, the electrically conducting fillers are used in an amount of 40 to 90 wt %, based on the total weight of the polymeric PTC composition. Examiner noted that minimum threshold can be 40% and maximum range can be 90%. The filler can be in 80% which is in the range of 40 to 90 wt%). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Blake et al., by modifying Diemer’s electrically conductive filler quantity according to Blake et al.’s electrically conductive filler quantity filling amount in term of weight percentage, to control the electrical resistivity and establish a continuous, percolated network for, or against, electron flow to achieve efficient Joule heating. One skilled in the art would have found it obvious to substitute Diemer’s the filler amount with Blake et al. filler amount are both recognized by the art for the same purpose of achieving efficient Joule heating. Regarding claim 8, modified Diemer discloses “the polyurethane-based foam matrix with the electrically conductive filler” (Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Examiner noted that Dimer is used to teach PU material with conductive filler. Kiziltas et al. is used to teach the rigid type of PU material) is provided with “the pair of metal electrodes” (Diemer, fig.7a, 9 and 10) which is embedded in “the polyurethane-based foam matrix with the electrically conductive filler” (Diemer, 7) and is connected to “a control and power generation circuit” (Diemer, 13 and 14). Regarding claim 9, modified Diemer discloses “the polyurethane-based foam matrix with the electrically conductive filler is a polyurethane foam charged with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler). Regarding claim 12, modified Diemer discloses the vehicle cockpit component is selected from the group consisting of “a vehicle seat” (Diemer, fig.7b), a vehicle seat cushion, a vehicle seat backrest, a vehicle seat armrest, a vehicle seat headrest, an inner panel of a vehicle door, and a cockpit headliner. Regarding claim 22, modified Diemer discloses “the polyurethane-based foam matrix with the electrically conductive filler is a polyurethane foam impregnated with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. The foam is electrically conductive polyurethane which suggest that the foam is impregnated with electrically conductive filler). Regarding claim 23, modified Diemer discloses “a vehicle cockpit component”, (Diemer, abstract and fig.7a-b) comprising; “a supporting frame” (Diemer, annotated fig.7b); and “an upholstery” (Diemer, 5, 6, 7 and 8) fitted on “the supporting frame” (Diemer, annotated fig.7b), “the upholstery” (5, 6, 7 and 8) including “a polyurethane-based foam Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Examiner noted that polyurethane is generally an electrical insulator, but its conductivity can be enhanced by adding conductive additives during manufacturing),” (Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Examiner noted that polyurethane is generally an electrical insulator, but its conductivity can be enhanced by adding conductive additives during manufacturing): wherein “a concentration of electrically conductive filler in the polyurethane-based foam to trigger a first conductive pathway in the polyurethane-based foam ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler in the polyurethane-based foam) wherein “the polyurethane- based foam with the electrically conductive filler” (Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is directly connected to “means for generating a voltage difference” (Diemer, [0102] After hardening of the electrically conductive polyurethane foam, it is flexible and in electrically conductive contact with the contact ends 9 and 10 of the power supply wires 11 and 12 and forms the heating layer 7. [0122], i.e., the heating layer 7 containing the electrically conductive plastic material to a power supply (not shown)), whereby “heat is generated by Joule effect in the upholstery when the voltage difference is applied” (Diemer, [0122], i.e., Since the electrical resistance of the heating layer 7 is constant, the heating temperature can be determined or regulated by the supplied electric power), and wherein “one or more portions of the upholstery provide both a cushioning material and a heating device of the vehicle cockpit component” (Diemer, [0036], i.e., seat upholstery of the seat surface part or the back of a seat, or a mattress). Diemer is silent regarding a polyurethane-based foam matrix. Kiziltas et al. teaches “a polyurethane-based foam matrix” ([0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Examiner noted that rigid foam matrix is considered as non-collapsed when no force acting on it). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Kiziltas et al., by replacing Diemer’s polyurethane-based foam material with Kiziltas et al.’s non-collapsed polyurethane-based foam matrix material to provide a rigid foam for vehicle components (para.0028-0029) as taught by Kiziltas et al. One skilled in the art would have found it obvious to substitute Diemer’s polyurethane-based foam material with Kiziltas et al.’s non-collapsed polyurethane-based foam matrix material are both recognized by the art for the same purpose of supporting component for a vehicle. MPEP 2144.06. Diemer is silent regarding a concentration of electrically conductive filler is in a range between a minimum threshold, corresponding to a quantity of electrically conductive filler needed to trigger a first conductive pathway and a maximum threshold, corresponding to a saturation of conductive pathways without reaching the maximum threshold and remaining within 50% of said range closer to the maximum threshold so that the polyurethane-based foam matrix is non-collapsed. Blake et al. teaches “a concentration of electrically conductive filler is in a range between a minimum threshold, corresponding to a quantity of electrically conductive filler needed to trigger a first conductive pathway and a maximum threshold, corresponding to a saturation of conductive pathways without reaching the maximum threshold and remaining within 50% of said range closer to the maximum threshold so that the polyurethane-based foam matrix is non-collapsed” ([0046], i.e., In one embodiment, the electrically conducting fillers are used in an amount of 40 to 90 wt %, based on the total weight of the polymeric PTC composition. Examiner noted that minimum threshold can be 40% and maximum range can be 90%. The filler can be in 80% which is in the range of 40 to 90 wt%). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Blake et al., by modifying Diemer’s electrically conductive filler quantity according to Blake et al.’s electrically conductive filler quantity filling amount in term of weight percentage, to control the electrical resistivity and establish a continuous, percolated network for, or against, electron flow to achieve efficient Joule heating. One skilled in the art would have found it obvious to substitute Diemer’s the filler amount with Blake et al. filler amount are both recognized by the art for the same purpose of achieving efficient Joule heating. Regarding claim 27, modified Diemer discloses “the polyurethane-based foam matrix with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Diemer, fig.7a, 7) is provided with “the pair of metal electrodes” (Diemer, 9 and 10) which is embedded in “the polyurethane-based foam matrix with the electrically conductive filler” (Diemer, fig.7a, 7) and connected to “a control and power generation circuit” (Diemer, 13 and 14). Regarding claim 28, modified Diemer discloses “the polyurethane-based foam matrix with the electrically conductive filler is a polyurethane foam charged with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Examiner noted that polyurethane is generally an electrical insulator, but its conductivity can be enhanced by adding conductive additives during manufacturing). Regarding claim 29, modified Diemer discloses “the polyurethane-based foam matrix with the electrically conductive filler is a polyurethane foam impregnated with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Examiner noted that polyurethane is generally an electrical insulator, but its conductivity can be enhanced by adding conductive additives during manufacturing. Fig.7a, 7). Regarding claims 20 and 30, Diemer discloses “the electrically conductive fillers is dispersed in the polyurethane-based foam matrix” (Diemer, i.e., [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler. Examiner noted that “polyurethane matrix” means the use of polyurethane as main material. Diemer teaches the foam material is electrically conductive polyurethane which suggest that it is polyurethane based material), and wherein “the minimum threshold corresponds a percolation threshold of the polyurethane-based foam matrix and the maximum threshold corresponds to a saturation threshold of the polyurethane-based foam matrix” (Blake et al., [0046], i.e., In one embodiment, the electrically conducting fillers are used in an amount of 40 to 90 wt %, based on the total weight of the polymeric PTC composition. Examiner noted that minimum threshold can be 40% and maximum range can be 90%. The filler can be in 80% which is in the range of 40 to 90 wt%). Regarding claim 32, modified Diemer discloses the vehicle cockpit component is selected from the group consisting of “a vehicle seat” (Diemer, fig.7b), a vehicle seat cushion, a vehicle seat backrest, a vehicle seat armrest, a vehicle seat headrest an inner panel of a vehicle door, and a cockpit headliner. PNG media_image1.png 984 1134 media_image1.png Greyscale Claim(s) 5 and 24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Diemer et al. (US 2010/0000981) in view of Kiziltas et al. (US 2021/0363317 A1) as applied in claims 1, 8-9, 12, 22-23, 27-29 and 32 above, and further in view of Howick (US 20050242081). Regarding claim 5, Diemer discloses wherein “the means for generating a voltage difference includes a pair of metal electrodes” (Diemer, fig.7a, 9 and 10. Examiner noted that it is inherently and necessarily that the heating elements (i.e., electrodes) will generate a voltage difference), “the polyurethane-based foam matrix with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is arranged close to “the pair of metal electrodes” (9 and 10), and “coupled to the pair of metal electrodes” ([0102] After hardening of the electrically conductive polyurethane foam, it is flexible and in electrically conductive contact with the contact ends 9 and 10 of the power supply wires 11 and 12 and forms the heating layer 7), and wherein “the pair of metal electrodes” (9 and 10) is bonded to “the polyurethane-based foam matrix with the electrically conductive filler” ([0102] After hardening of the electrically conductive polyurethane foam, it is flexible and in electrically conductive contact with the contact ends 9 and 10 of the power supply wires 11 and 12 and forms the heating layer 7) and is connected to “a control and power generation circuit” (13 and 14). Diemer is silent regarding the polyurethane-based foam matrix with the electrically conductive filler comprising the electrically conductive device is arranged between a pair of metal electrodes. Howick teaches “the electrically conductive device is arranged between a pair of metal electrodes” (fig.8 shows the electrically conductive device 444 is arranged between a pair of metal electrodes 420 and 422). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Howick, by modifying Diemer’s electrically conductive device configuration according to Howick’s electrically conductive device configuration to form a boundary of the heater (para.0104 and fig.8) as taught by Howick. Regarding claim 24, modified Diemer discloses wherein “the means for generating a voltage difference includes a pair of metal electrodes” (Diemer, fig.7a, 9 and 10. Examiner noted that it is inherently and necessarily that the heating elements (i.e., electrodes) will generate a voltage difference) “the polyurethane-based foam matrix with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is arranged close to “a pair of metal electrodes” (9 and 10), and “coupled to the pair of metal electrodes” ([0102] After hardening of the electrically conductive polyurethane foam, it is flexible and in electrically conductive contact with the contact ends 9 and 10 of the power supply wires 11 and 12 and forms the heating layer 7), and wherein “the metal electrodes of the pair of metal electrodes” (9 and 10) are bonded to “the polyurethane-based foam matrix with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). [0102] After hardening of the electrically conductive polyurethane foam, it is flexible and in electrically conductive contact with the contact ends 9 and 10 of the power supply wires 11 and 12 and forms the heating layer 7) and are connected to “a control and power generation circuit” (13 and 14). Diemer is silent regarding the polyurethane-based foam matrix with the electrically conductive filler comprising the electrically conductive device is arranged between a pair of metal electrodes. Howick teaches “the electrically conductive device is arranged between a pair of metal electrodes” (fig.8 shows the electrically conductive device 444 is arranged between a pair of metal electrodes 420 and 422). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Howick, by modifying Diemer’s electrically conductive device configuration according to Howick’s electrically conductive device configuration to form a boundary of the heater (para.0104 and fig.8) as taught by Howick. Claims 6 and 25 are rejected under 35 U.S.C. 103 as being unpatentable over Diemer et al. (US 2010/0000981) in view of Kiziltas et al. (US 2021/0363317 A1) and Howick (US 20050242081) as applied in claims 5 and 24 and Ogata (US 5,834,734). Regarding claim 6, modified Diemer discloses wherein “the means for generating a voltage difference includes a pair of metal electrodes” (Diemer, fig.7a, 9 and 10. Examiner noted that it is inherently and necessarily that the heating elements (i.e., electrodes) will generate a voltage difference), “the polyurethane-based foam matrix with the electrically conductive filler” (Kiziltas et al., [0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is arranged close to a pair of electrodes” (9 and 10) and coupled to “the pair of electrodes” (9 and 10); wherein “the pair of electrodes” (9 and 10) is connected to “a control and power generation circuit” (13 and 14). Diemer is silent regarding the polyurethane-based foam matrix with the electrically conductive filler comprising the electrically conductive device is arranged between a pair of metal electrodes and wherein the electrodes of the pair of electrodes are obtained by means of flexible printed circuit boards. Howick teaches “the electrically conductive device is arranged between a pair of metal electrodes” (fig.8 shows the electrically conductive device 444 is arranged between a pair of metal electrodes 420 and 422). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Howick, by modifying Diemer’s electrically conductive device configuration according to Howick’s electrically conductive device configuration to form a boundary of the heater (para.0104 and fig.8) as taught by Howick. Diemer is silent regarding wherein the electrodes of the pair of electrodes are obtained by means of flexible printed circuit boards. Ogata teaches wherein “the electrodes of the pair of electrodes” (fig.3, item P pointed at the electrodes such as copper foil strip pattern. Examiner noted that the handgrip of motorcycle have two sides (right side (fig.1) and left side (not shown)). Examiner takes official notice that a motorcycle having right side and left side of handgrips) are obtained by “means of flexible printed circuit boards” (a flexible printed circuit board heater circuit (hereinafter, referred to as "FPC heater") 20. Examiner noted 20 is implemented on the left side and right side of the handgrips). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Ogata, by modifying Diemer’s heating circuit with Ogata’s heating circuit with flexible circuit boards, to create a flexible, adaptable and functional electronics (fig.1 and fig.3) as taught by Ogata. Regarding claim 25, modified Diemer discloses wherein “the means for generating a voltage difference includes a pair of metal electrodes” (Diemer, fig.7a, 9 and 10. Examiner noted that it is inherently and necessarily that the heating elements (i.e., electrodes) will generate a voltage difference), “the non-collapsed polyurethane-based foam matrix with the electrically conductive filler” (Diemer, [0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is arranged close to Diemer,9 and 10) and coupled to “the pair of electrodes” (Diemer,9 and 10); wherein “the pair of electrodes” (Diemer,9 and 10) is connected to “a control and power generation circuit” (Diemer,13 and 14). Diemer is silent regarding the polyurethane-based foam matrix with the electrically conductive filler comprising the electrically conductive device is arranged between a pair of metal electrodes and wherein the electrodes of the pair of electrodes are obtained by means of flexible printed circuit boards. Howick teaches “the electrically conductive device is arranged between a pair of metal electrodes” (fig.8 shows the electrically conductive device 444 is arranged between a pair of metal electrodes 420 and 422). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Howick, by modifying Diemer’s electrically conductive device configuration according to Howick’s electrically conductive device configuration to form a boundary of the heater (para.0104 and fig.8) as taught by Howick. Diemer is silent regarding wherein the electrodes of the pair of electrodes are obtained by means of flexible printed circuit boards. Ogata teaches wherein “the electrodes of the pair of electrodes” (fig.3, item P pointed at the electrodes such as copper foil strip pattern. Examiner noted that the handgrip of motorcycle have two sides (right side (fig.1) and left side (not shown)). Examiner takes official notice that a motorcycle having right side and left side of handgrips) are obtained by “means of flexible printed circuit boards” (a flexible printed circuit board heater circuit (hereinafter, referred to as "FPC heater") 20. Examiner noted 20 is implemented on the left side and right side of the handgrips). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Ogata, by modifying Diemer’s heating circuit with Ogata’s heating circuit with flexible circuit boards, to create a flexible, adaptable and functional electronics (fig.1 and fig.3) as taught by Ogata. Claims 7 and 26 is/are rejected under 35 U.S.C. 103 as being unpatentable over Diemer et al. (US 2010/0000981) in view of Kiziltas et al. (US 2021/0363317 A1) as applied in claims 1, 8-9, 12, 22-23, 27-29 and 32 above, and further in view of Howick (US 20050242081) and Philip et al. (US 2015/0382403). Regarding claim 7, Diemer discloses wherein “the means for generating a voltage difference includes a pair of metal electrodes” (Diemer, fig.7a, 9 and 10. Examiner noted that it is inherently and necessarily that the heating elements (i.e., electrodes) will generate a voltage difference), “the polyurethane-based foam matrix with the electrically conductive filler” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is arranged close to a pair of metal electrodes” (9 and 10) and coupled to “the pair of electrodes” (9 and 10); wherein “the electrodes of the pair of electrodes” (9 and 10) are connected to “a control and power generation circuit” (13 and 14). Diemer is silent regarding the polyurethane-based foam with the electrically conductive filler comprising the electrically conductive device is arranged between a pair of metal electrodes and wherein the electrodes of the pair of electrodes are obtained by means of printed conductive inks. Howick teaches “the electrically conductive device is arranged between a pair of metal electrodes” (fig.8 shows the electrically conductive device 444 is arranged between a pair of metal electrodes 420 and 422). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Howick, by modifying Diemer’s electrically conductive device configuration according to Howick’s electrically conductive device configuration to form a boundary of the heater (para.0104 and fig.8) as taught by Howick. Diemer is silent regarding wherein the electrodes of the pair of electrodes are obtained by means of printed conductive inks. Philip et al. teaches “the electrodes of the pair of electrodes are obtained by means of printed conductive inks” ([0052], i.e., The busbars may also be a printed conductive ink). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Philip et al., by modifying Diemer’s heating circuit with Ogata’s heating circuit with flexible circuit boards, to create a flexible, adaptable and functional electronics (para.0052) as taught by Philip. Regarding claim 26, Diemer discloses wherein “the means for generating a voltage difference includes a pair of metal electrodes” (Diemer, fig.7a, 9 and 10. Examiner noted that it is inherently and necessarily that the heating elements (i.e., electrodes) will generate a voltage difference), “the polyurethane-based foam with the electrically conductive filler” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane) is arranged close to a pair of electrodes” (9 and 10) and coupled to “the pair of electrodes” (9 and 10); wherein “the electrodes of the pair of electrodes” (9 and 10) is connected to “a control and power generation circuit” (13 and 14). Diemer is silent regarding the polyurethane-based foam with the electrically conductive filler comprising the electrically conductive device is arranged between a pair of metal electrodes and wherein the electrodes of the pair of electrodes is obtained by means of printed conductive inks. Howick teaches “the electrically conductive device is arranged between a pair of metal electrodes” (fig.8 shows the electrically conductive device 444 is arranged between a pair of metal electrodes 420 and 422). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Howick, by modifying Diemer’s electrically conductive device configuration according to Howick’s electrically conductive device configuration to form a boundary of the heater (para.0104 and fig.8) as taught by Howick. Diemer is silent regarding wherein the electrodes of the pair of electrodes are obtained by means of printed conductive inks. Philip et al. teaches “the electrodes of the pair of electrodes are obtained by means of printed conductive inks” ([0052], i.e., The busbars may also be a printed conductive ink). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Diemer with Philip et al., by modifying Diemer’s heating circuit with Ogata’s heating circuit with flexible circuit boards, to create a flexible, adaptable and functional electronics (para.0052) as taught by Philip. Claims 21 and 31 are rejected under 35 U.S.C. 103 as being unpatentable over Diemer et al. (US 2010/0000981) in view of Kiziltas et al. (US 2021/0363317 A1) as applied in claims 1, 8-9, 12, 22-23, 27-29 and 32 above, and further in view of Howick (US 20050242081) and Howick et al. (US 2004/0100131). Regarding claims 21 and 31, modified Diemer discloses the electrically conductive filler. Howick et al. teaches “the filler is are selected from the group consisting of metal particles” (Howick, conductive metal powder), carbon black particles, graphite particles, graphene particles, graphene oxide, graphene nanoplatelets, carbon fibres, and carbon nanotubes. One skilled in the art would have found it obvious to substitute Diemer with Howick et al. are both recognized by the art for the same purpose of providing electrical conductivity materials for conducting electricity. MPEP 2144.06. Response to Arguments Applicant's arguments filed on 12/29/2025 have been fully considered but they are not persuasive. (1) Applicant argues “objection to specification …35 USC 112 …” on pages 10-12. In response, the amendment to claims overcome the 35 USC 112 and specification objection. Thus, the 35 USC 112 and specification objection have been withdrawn. (2) Applicant argues “35 USC 103 … Diemer et al. disclose a heating device with a layer containing electrically conductive plastic. As explicitly mentioned in Diemer et al., the heating device has adhesive properties at least in some sections of at least one side (see Paragraph Nos. 0013-0023 of Diemer et al.) so that it can be applied to a component of an object, thus obtaining a heatable object (see Paragraph No. 0026 of Diemer et al.). The above referenced "component of an object" refers to a completely conventional padding or upholstery that has no intrinsic heating properties and acts as a support for the heating device. The heating device itself of Diemer et al. does not provide a cushioning material or padding and does not include a conductive filler dispersed within a foam matrix that provides mechanical properties consistent with a cushioning material (i.e., Diemer et al. fails to disclose a composite cushioning/heating material). Thus, in Diemer et al., the heating function is performed by the heating device and the support/cushioning function is performed by a separate component (i.e., the padding or upholstery). Conversely, in the claimed invention, the heating device is made in the form of padding and/or upholstery that integrate(s) both the heating function and the support function (i.e., it is a single composite material (matrix with filler dispersed therein)). In the claimed invention, the heating device has intrinsic support characteristics which make it suitable for use directly as padding and/or upholstery, without the need for an additional component. This is possible because the heating device consists of a polyurethane-based foam matrix with an electrically conductive filler dispersed therein. This material has mechanical properties of a cushioning material (i.e., the foam is not collapsed or unstable under the effects of gravity and will conform to the person sitting on the padding and then will return to its original shape after the person exits the seat)” on pages 13-14 of remark. In response, examiner respectfully disagrees because claims 1 and 23 only require “the padding comprising a polyurethane-based foam matrix that includes an electrically conductive filler”. Claims 1 and 23 do not require additional composite cushioning/heating material. In this case, Dimer et al. teaches the padding (5, 6, 7 and 8) comprising a polyurethane-based foam includes “an electrically conductive filler” ([0099], i.e., The heating layer 7 is made of a flexible, electrically conducting synthetic foam, such as electrically conductive polyurethane. The polyurethane is plastic and for it to be electrically conductive it would require electric conductive filler). Kiziltas et al. teaches “a polyurethane-based foam matrix” ([0029] Non-limiting examples of polymers used to form the foam matrix 100 (i.e., a soft and/or rigid foam matrix) include polyurethane (PU). Examiner noted that rigid foam matrix is considered as non-collapsed when no force acting on it). (3) With respect to Kiziltas et al. arguments, Kiziltas et al. teach the polyurethane based foam matrix. However, the claim does not require specific flexibility for the cushioning material. And the cushioning material does not suggest any degree of flexibility. In other words, rigid materials can be used as cushioning. (4) With respect to arguments on pages 16-18, the arguments are moot due to newly introduced reference in current rejection. In particular, Blake et al. teaches the filler ranges (Blake et al., [0046], i.e., In one embodiment, the electrically conducting fillers are used in an amount of 40 to 90 wt %, based on the total weight of the polymeric PTC composition. Examiner noted that minimum threshold can be 40% and maximum range can be 90%. The filler can be in 80% which is in the range of 40 to 90 wt%). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JIMMY CHOU whose telephone number is (571)270-7107. The examiner can normally be reached Mon-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. /JIMMY CHOU/Primary Examiner, Art Unit 3761
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Prosecution Timeline

Mar 26, 2022
Application Filed
Apr 01, 2025
Non-Final Rejection — §103
Jul 02, 2025
Response Filed
Sep 24, 2025
Final Rejection — §103
Dec 29, 2025
Request for Continued Examination
Feb 11, 2026
Response after Non-Final Action
Mar 12, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

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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
71%
Grant Probability
87%
With Interview (+15.6%)
3y 4m
Median Time to Grant
High
PTA Risk
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