Prosecution Insights
Last updated: April 19, 2026
Application No. 17/789,582

METHOD FOR PRODUCING AN IMPLANTABLE ELECTRODE DEVICE

Final Rejection §102§103
Filed
Jun 28, 2022
Examiner
MCNALLY, DANIEL
Art Unit
1746
Tech Center
1700 — Chemical & Materials Engineering
Assignee
BIOTRONIK SE & Co. KG
OA Round
2 (Final)
68%
Grant Probability
Favorable
3-4
OA Rounds
3y 0m
To Grant
81%
With Interview

Examiner Intelligence

Grants 68% — above average
68%
Career Allow Rate
683 granted / 1007 resolved
+2.8% vs TC avg
Moderate +13% lift
Without
With
+13.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
24 currently pending
Career history
1031
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
51.9%
+11.9% vs TC avg
§102
19.7%
-20.3% vs TC avg
§112
23.1%
-16.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1007 resolved cases

Office Action

§102 §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 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. Claims 1-9 are rejected under 35 U.S.C. 103 as being unpatentable over Fukushima [JP2015-181777, of record, previously cited] in view of Erickson et al. [US2002/0022873, newly cited, “Erickson”]. Fukushima discloses a method for producing an implantable electrode device (10) comprising: providing an electrically insulating support (4, 34) (paragraph 0025, 0052), providing a plurality of electrically conductive electrode elements (1) (paragraph 0030, 0033, 0053), and attaching the electrode elements to the support (paragraph 0053-56), wherein for attaching the electrode elements to the support, the electrode elements and/or the support are heated and the electrode elements are pressed against the support (paragraphs 0053-56). Fukushima discloses a plurality of electrode elements (for example Figure 3), but does not disclose an arrangement with the elements arranged in rows next to each other and are placed in relation to each other. Erickson discloses a method of making an implantable electrode device. Erickson discloses alternative configurations of the device including a device as shown in Figure 3, where the electrodes (20/40) are arranged in an arrangement similar to the disclosure of Fukushima, and an alternative arrangement as shown in Figure 4 wherein the electrode elements (20/40) are arranged in rows next to each other and are placed in relation to each other. It would have been obvious to one of ordinary skill in the art at the time of invention to modify the method of Fukushima by substituting the electrode element arrangement with the arrangement as taught by Erickson with the electrode elements in rows next to each other as a substation of known alternatives is within the ability of one of ordinary skill. With respect to claim 2, Fukushima discloses the support is made of a thermoplastic (paragraph 0025). With respect to claim 3, Fukushima discloses the support is made of a material comprising polyurethane (paragraph 0025). With respect to claim 4, Fukushima discloses attaching the at least on electrode elements to the support ,the electrode elements and/or the support are heated to a temperature greater than 100°C (paragraph 0056), it is noted the language “preferably” is considered to be described a preferred but not required feature and is therefore considered to be optional. With respect to claim 5, Fukushima discloses the electrode elements are placed on an upper side of the support (Figure 7). With respect to claim 6, Fukushima discloses the electrode elements are pressed against the support in such a way that an upper side of the electrode elements are flush with the upper side of the support (Figures 8 and 9). With respect to claim 7, Fukushima discloses an electrical supply line (2) is connected to the electrode elements before the electrode elements are attached to the support (Figures 6, 7). With respect to claim 8, Fukushima discloses the supply line (2) connected to the electrode elements (1) is attached to the support together with the electrode elements (Figures 7-9). With respect to claim 9, the electrode elements have at least one fastening element (1c) which is pressed into the support when the at least one electrode element is attached to the support (paragraphs 0030, 0033, 0048). Claims 10-11 are rejected under 35 U.S.C. 103 as being unpatentable over Fukushima, Erickson and further in view of Kobayashi [JP2001-299713, of record, previously cited]. Fukushima as modified discloses a method for producing an implantable electrode device. Applicant is referred to paragraph 3 for a detailed discussion of Fukushima as modified. Fukushima discloses an electrode element but fails to disclose a pin such that the pin penetrates an underside of the support. Kobayashi discloses an electrode that includes a pin such that when the electrode is attached to the support the pin penetrades an underside of the support (paragraph 0078-82; Figure 3). It would have been obvious to one of ordinary skill in the art at the time of invention to modify the method of Fukushima by including a pin that penetrates the underside of the support as taught by Kobayashi in order to secure the electrode and the improve the connection between the electrode and support and thereby improve the quality of the final product. With respect to claim 11, Fukushima discloses the electrode element is attached to the support and supply line, it would have been within the ability of one of ordinary skill to select the order in which the components are combined as there are a limited number of options. Claims 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over Fukushima, Erickson, and further in view of JP Publication ‘922 [JP2000-502922, of record, previously cited]. Fukushima as modified discloses a method for producing an implantable electrode device. Applicant is referred to paragraph 3 for a detailed discussion of Fukushima as modified. Fukushima discloses the electrode is connected to the support but fails to disclose an encasement. JP Publication ‘922 discloses an enclosure made of silicone material is applied to surround a support after an electrode is attached to the support (Figure 2E). It would have been obvious to one of ordinary skill in the art at the time of invention to modify the method of Fukushima by applying an encasement to surround the support as taught by JP Publication ‘922 in order to provide protection to the electrode. With respect to claim 13, JP Publication ‘922 discloses the encasement is silicone materials (page 10, lines 15-18). Response to Arguments Applicant’s arguments, filed 12/9/2025, with respect to the rejection under 35 USC 102 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 newly cited Erickson. Applicant asserts previously cited Fukushima does not disclose the arrangement of electrode elements as required by the claims. Newly cited Erickson discloses electrode elements arranged in rows next to each other as required by the claims. 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 DANIEL MCNALLY whose telephone number is (571)272-2685. The examiner can normally be reached M-F 9-5. 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, Michael Orlando can be reached at 571-270-5038. 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. /DANIEL MCNALLY/Primary Examiner, Art Unit 1746 DPM February 21, 2026
Read full office action

Prosecution Timeline

Jun 28, 2022
Application Filed
Sep 18, 2025
Non-Final Rejection — §102, §103
Dec 09, 2025
Response Filed
Feb 21, 2026
Final Rejection — §102, §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
68%
Grant Probability
81%
With Interview (+13.4%)
3y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 1007 resolved cases by this examiner. Grant probability derived from career allow rate.

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