Prosecution Insights
Last updated: October 02, 2026
Application No. 17/787,093

FLUID-HEATING DEVICE, IN PARTICULAR INTENDED FOR A VEHICLE

Final Rejection §103
Filed
Jun 17, 2022
Priority
Dec 18, 2019 — FR FR1914697 +1 more
Examiner
MILLS JR., JOE E
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Valeo S.A.
OA Round
4 (Final)
72%
Grant Probability
Favorable
5-6
OA Rounds
0m
Est. Remaining
88%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allowance Rate
291 granted / 402 resolved
+2.4% vs TC avg
Strong +16% interview lift
Without
With
+15.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
50 currently pending
Career history
463
Total Applications
across all art units

Statute-Specific Performance

§101
0.8%
-39.2% vs TC avg
§103
48.7%
+8.7% vs TC avg
§102
23.6%
-16.4% vs TC avg
§112
24.4%
-15.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 402 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 Amendment This office action is responsive to the amendment filed on 04/23/2026. As directed by the amendment: claim(s) 1 has/have been amended; no claim(s) has/have been cancelled and no new claim(s) has/have been added. Thus, claims 1-9 are presently pending in this application. 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: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 1-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yamiyama et al (JP2013230021) in view of Kominami et al (US 2013/0092744), Seger et al (US 2007/0194009), and Adachi et al (US 2019/0135079). Regarding claim 1, Yamiyama discloses an electric fluid heating device for a motor vehicle, comprising: at least one electric heating element (Fig. 4 #3 electric heater) configured to heat the fluid, a temperature sensor (Fig. 4 #36 temperature sensor) configured to provide information on the temperature of the fluid, an inrush current switch (Fig. 4 #50 IGBT), configured to create an inrush current in a power supply circuit for the at least one heating element (Fig. 4 #3 electric heater), an opening means (Fig. 4 #20 fuse) configured to open the power supply circuit when an inrush current occurs, wherein the temperature sensor (Fig. 4 #36 temperature sensor) and the inrush current switch (Fig. 4 #50 IGBT) are positioned independently of one another (Shown in Fig. 4), and wherein the heating device is configured to transmit a signal from the temperature sensor to the inrush current switch (The temperature sensor, the amplifier, the switch, and the controller communicate through connecting wires indicated by dotted lines between the various elements.). PNG media_image1.png 270 376 media_image1.png Greyscale However, Yamiyama does not disclose a first chamber configured to accommodate the at least one heating element; and further configured to contain the fluid, a control circuit board configured to control an electric current flowing through the at least one electric heating element; a separating wall disposed between the first chamber and a second chamber, the separating wall separating the first chamber from the second chamber; a heat sink disposed in a second chamber between the control circuit board and the first chamber, wherein the temperature sensor is mounted on the control circuit board. Nonetheless, Kominami is recognized in the field of endeavor of electric heating in vehicles. Kominami teaches a first chamber (Fig. 3(B) # 11b casing) configured to accommodate the at least one heating element (Fig. 3(B) #17 heat-exchange tubes), and further configured to contain the fluid, a control circuit board (Fig. 3(A) #13 control board) configured to control an electric current flowing through the at least one electric heating element (Fig. 3(B) #17 heat-exchange tubes), a heat sink (Fig. 3(A) #16 heat-exchange pressing member) disposed in a second chamber (Examiner considers the second chamber to be the space where the heat sink occupies.) between the control circuit board (Fig. 3 (A) #13 control board) and the first chamber (Fig. 3(B) #11b casing). PNG media_image2.png 470 428 media_image2.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the heating device of Yamiyama by incorporating the chamber of Kominami for the benefit of protect the control board and heaters from outside , the controller of Kominami for the benefit of automated control of the heaters, and the heat sink of Kominami for the benefit of dissipating access heat away from the circuit board. Furthermore, Seger is recognized in the field of endeavor of electronic control of temperature. Seger teaches wherein the temperature sensor is mounted on the control circuit board ([0072] lines 1-5 ---" Referring now to FIG. 10, an implementation is shown of the temperature sensing circuit. The temperature sensing circuit includes a temperature sensor, such as a thermistor TH1 that senses the temperature of power module 26.” and lines 11-13 ---" For example, thermistor TH1 can be mounted on PCB 52 between transistors Q2 and Q3 (see FIG. 5.)”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the heating device of Yamiyama by incorporating the temperature sensor mounted on a control circuit board as taught by Seger for the benefit of simplifying heating device construction. Furthermore, Adachi in the same field of endeavor being fluid heating devices teaches a separating wall (Fig 7 #30a electronic component cooling wall) disposed between the first chamber (Fig. 7 #20 first heating medium distribution box) and a second chamber (Fig. 7 #50 second heating medium distribution box), the separating wall (Fig 7 #30a electronic component cooling wall) separating the first chamber (Fig. 7 #20 first heating medium distribution box) from the second chamber (Fig. 7 #50 second heating medium distribution box). PNG media_image3.png 370 494 media_image3.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the heating device of Yamiyama by incorporating the separating wall as taught by Adachi for the benefit of removing access heat from the control board. Regarding claim 2, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 1), and Yamiyama teaches comprising a means for transmitting the signal between the temperature sensor and the inrush current switch (The temperature sensor, the amplifier, the switch, and the controller communicate through connecting wires indicated by dotted lines between the various elements. Shown in Fig. 4.). Regarding claim 3, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 2), and Yamiyama teaches wherein the means for transmitting the signal comprises an electrical conductor (The temperature sensor, the amplifier, the switch, and the controller communicate through connecting wires indicated by dotted lines between the various elements. Shown in Fig. 4.). Regarding claim 4, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 3), and Yamiyama teaches wherein the controller (Fig. 4 #33 controller) comprises a microcontroller (The controller implies the inclusion of a microcontroller due to its function.) able to control the inrush current switch ([0058]), and wherein the means for transmitting the signal provides the connection between the temperature sensor and said microcontroller (The temperature sensor, the amplifier, the switch, and the controller communicate through connecting wires indicated by dotted lines between the various elements. Shown in Fig. 4.). Regarding claim 5, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 1), and Yamiyama teaches wherein the inrush current switch (Fig. 4 #50 IGBT) is connected on a short-circuit line (Fig. 4 #10 short-circuit current line) parallel with the electric heating element (Fig. 4 #3 electric heater), said short-circuit line (Fig. 4 #10 short-circuit current line) comprising a first end (Fig. 4 #10a end) and a second end (Fig. 4 #10b end). Regarding claim 6, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 5), and Yamiyama teaches further comprising an upstream switch (Fig. 4 #30 IGBT at the top of the circuit) and a downstream switch (Fig. 4 #30 IGBT at the bottom of the circuit) connected in series with the electric heating element (Fig. 4 #3 electric heater), said electric heating element (Fig. 4 #3 electric heater) being positioned between said upstream switch (Fig. 4 #30 IGBT at the top of the circuit) and said downstream switch (Fig. 4 #30 IGBT at the bottom of the circuit), at least one of said upstream and downstream switches being configured to regulate the current flowing through said electric heating element. Regarding claim 7, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 6), and Yamiyama teaches wherein the first end (Fig. 4 #10a end) of the short-circuit line (Fig. 4 #10 short-circuit current line) is positioned directly upstream of the electric heating element (Fig. 4 #3 electric heater), and/or the second end (Fig. 4 #10b end) of the short-circuit line (Fig. 4 #10 short-circuit current line) is positioned directly downstream of said electric heating element (Fig. 4 #3 electric heater). Regarding claim 8, Yamiyama in view of Kominami, Seger, and Adachi Yamiyama teaches wherein the first end (Fig. 4 #10a end) of the short-circuit line (Fig. 4 #10 short-circuit current line) is positioned upstream of the upstream switch (Fig. 4 #30 IGBT at the top of the circuit) and/or the second end (Fig. 4 #10b end) of the short-circuit line (Fig. 4 #10 short-circuit current line) is positioned downstream of the downstream switch (Fig. 4 #30 IGBT at the bottom of the circuit). Regarding claim 9, Yamiyama in view of Kominami, Seger, and Adachi teaches the heating device as appears above (see the rejection of claim 6), and Yamiyama teaches wherein the means for opening the circuit comprises at least one fuse (Fig. 4 #20 fuse) mounted upstream of the first end of the short-circuit line (Fig. 4 #10 short-circuit current line) or downstream of the second end of the short-circuit line, said fuse being configured to protect the electric heating element (Fig. 4 #3 electric heater) in the event of simultaneous failure of the upstream switch (Fig. 4 #30 IGBT at the top of the circuit) and of the downstream switch (Fig. 4 #30 IGBT at the bottom of the circuit). Response to Arguments Applicant’s arguments, see pages 4-8, filed 04/23/2026, with respect to the rejection(s) of claim(s) 1-9 under 35 U.S.C. 103 have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of Adachi et al (US 2019/0135079). Applicant argues that the cited prior art does not teach a separating wall disposed between the first chamber and a second chamber, the separating wall separating the first chamber from the second chamber. Examiner respectfully agrees. However, newly cited prior art Adachi teaches a separating wall disposed between the first chamber and a second chamber, the separating wall separating the first chamber from the second chamber. See the rejection of claim 1. Applicant's arguments filed 04/23/2026 have been fully considered but they are not persuasive. Applicant argues that the heat exchange pressing member of Kominami fails to render a heat sink. Examiner respectfully disagrees. The heat exchange pressing member functions as a heat sink. [0077] “These semiconductor switching 12, which are heat-generating devices that generate heat when activated, are screwed on the upper surface of the heat-exchange pressing member 16 and in the vicinity of the inlet header 22 of the upper flat heat-exchange tube 17a with connecting screws 12a and are cooled using the heat-exchange pressing member 16 as a heat sink.” 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 JOE E MILLS JR. whose telephone number is (571)272-8449. The examiner can normally be reached M-F 8-5. 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, Ibrahime Abraham can be reached at (571) 270-5569. 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. /JOE E MILLS JR./Examiner, Art Unit 3761 /CHRIS Q LIU/Primary Examiner, Art Unit 3761
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Prosecution Timeline

Show 2 earlier events
Jun 03, 2025
Response Filed
Aug 06, 2025
Final Rejection mailed — §103
Oct 06, 2025
Response after Non-Final Action
Dec 03, 2025
Request for Continued Examination
Dec 21, 2025
Response after Non-Final Action
Jan 23, 2026
Non-Final Rejection mailed — §103
Apr 23, 2026
Response Filed
Aug 20, 2026
Final Rejection mailed — §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

5-6
Expected OA Rounds
72%
Grant Probability
88%
With Interview (+15.5%)
3y 2m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 402 resolved cases by this examiner. Grant probability derived from career allowance rate.

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