Prosecution Insights
Last updated: April 19, 2026
Application No. 17/795,323

GAS DIFFUSION MEMBER, GAS DIFFUSION UNIT, AND FUEL CELL

Non-Final OA §103§112
Filed
Jul 26, 2022
Examiner
CONLEY, OI K
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Enomoto Co. Ltd.
OA Round
4 (Non-Final)
70%
Grant Probability
Favorable
4-5
OA Rounds
3y 7m
To Grant
77%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
597 granted / 858 resolved
+4.6% vs TC avg
Moderate +8% lift
Without
With
+7.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
38 currently pending
Career history
896
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
37.2%
-2.8% vs TC avg
§102
34.5%
-5.5% vs TC avg
§112
21.5%
-18.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 858 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 . The Applicant’s arguements on 11/24/25. The text of those sections of Title 35, U.S.C. code not included in this action can be found in the prior Office Action. 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 8/6/25 has been entered. Drawings The drawing objection has been withdrawn because the Applicant amended the claims Claim Rejections - 35 USC § 112 The 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre- AIA ), second paragraph, as being indefinite, on claims 1-5, 7, 8, 10 are withdrawn. Claims Analysis It is noted that claim disclosure, “adhered” is product-by-process claim limitation. “Even though product-by-process claims are limited by and defined by the process, determination of patentability is based on the product itself. The patentability of a product does not depend on its method of production. If the product in the product-by-process claim is the same as or obvious from a product of the prior art, the claim is unpatentable even though the prior product was made by a different process.” In re Thorpe, 777 F. 2d 695, 698, 227 USPQ 964, 966 (Fed. Cir. 1985). Since the laminated structure is the same as to that of the Applicant’s, Applicant’s process is not given patentable weight in this claim. Claim Rejections - 35 USC § 103 The 35 U.S.C. 103 as being unpatentable over by Shuichi et al. (JP2004-185905) in view Nobata, on claims 1-5, 7, 8, 10 are amended in view of the Applicant’s arguements. 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) 1-4, 7, 8, 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over by Shuichi et al. (JP2004-185905) as evidence by Shimamune reference (JP08-283980). Regarding claim 1, the Shuichi et al. reference discloses a gas diffusion member (32, Abstract) arranged between a separator (40, 50) and a catalyst layer (31; Abstract) of a fuel cell. The diffusion layer comprising a porous material layer (carbon paper); and a conductive material layer (carbon paste). The porous material layer is formed of a conductive porous material (carbon paper) and the conductive material layer is formed of a conductive material (carbon paste). The conductive material layer is arranged throughout (Fig. 3 and 4) and on a surface of the porous material layer (“applied on the surface of the carbon paper”). The Shuichi et al. dislcsoes the conductive material is made of PTFE and carbon powder to form a carbon paste. As evidence by the Shimamune et al. reference, PTFE is a binder resin. The Shuichi et al. reference further ddiscloses the diffusion layer are known to be laminated between the plate and the catalyst layer, specifically examples in which the catalyst layer and the diffusion layer were tightly formed via carbon paste by hot-pressing were disclsoed. The Shuichi et al. reference does not specify the other surface of the diffusion layer contacting the separator are connected via carbon paste, however, it would have been obvious to one of ordinary skill in the art that the other surface of the diffusion layer contacting the separator plates functions the same via hot pressing with the carbon paste that comprises binder PTFE (binder lamination). In addition, since the Shuichi et al. reference teaches that it is known to laminate the diffusion plates in between the catalyst layer and separator plate, it would indeed obvious and teaches the claimed invention. A patent claim can be proved obvious merely by showing that the combination of elements was obvious to try. When there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely the product is not of innovation but of ordinary skill and common sense. KSR v. Teleflex Regarding claim 2, the Shuichi et al. reference discloses wherein the porous material layer (22, 33) comprises a groove (41, 51) on the surface on the side of the separator (40, 50) as a gas flow path. Regarding claim 3, the Shuichi reference discloses a microporous layer is provided on a surface of the pours material layer on a side of the catalyst layer (33; Fig. 5). Regarding claim 4, the Shuichi et al. reference discloses the conductive material is formed of a PTFE resin in which conductive particles are dispersed (See Figures). Regard claim 7, the Shuichi et al. reference discloses a gasket (60,70) arranged to surround the gas diffusion member is fixed to the separator. Regarding claim 8, the Shuichi reference discloses a fuel cell, comprising a cathode-side separator; a cathode gas diffusion member, a catalyst membrane; an anode gas diffusion member; and an anode-side separator in this order; wherein: the catalyst membrane comprises a cathode catalyst layer, an electrolyte membrane and an anode catalyst layer in order from a side of the cathode gas diffusion member; and the cathode gas diffusion member and the anode gas diffusion member are each the gas diffusion member of claim 1 (Fig 1-5). The limitation “catalyst-coated” appears to be a product-by-process limitation. . “Even though product-by-process claims are limited by and defined by the process, determination of patentability is based on the product itself. The patentability of a product does not depend on its method of production. If the product in the product-by-process claim is the same as or obvious from a product of the prior art, the claim is unpatentable even though the prior product was made by a different process.” In re Thorpe, 777 F. 2d 695, 698, 227 USPQ 964, 966 (Fed. Cir. 1985). Since the catalyst membrane is the same as to that of the Applicant’s, Applicant’s process is not given patentable weight in this claim. Regarding claim 10, the Shuichi reference discloses a cathode gasket arranged to surround the cathode gas diffusion member is fixed to the cathode-side separator; and an anode gasket arranged to surround the anode gas diffusion member is fixed to the anode-side separator (60, 70; Fig. 2). Claim(s) 5 is/are rejected under 35 U.S.C. 103(a) as being unpatentable by JP2004-185905) as evidence by Shimamune reference (JP08-283980) in further view of Koyama et al. (US Publication 2005/0238932) Regarding claim 5, the Shuichi in view of Nobata reference discloses the claimed invention above and further incorporated herein. The modified Shuichi reference is silent in disclosing wherein a thickness of the conductive material layer is 1 to 100 µm, however, the Koyama reference discloses carbon paste on carbon paper is conductive and is about 20 microns (P93, P97). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to incorporate about 20 micron for the carbon paste on carbon paper disclosed by the Koyama et al. reference for the carbon paste on carbon paper taught by the modified Shuichi reference to maintain conductivity. Response to Arguments Applicant's arguments filed 11/24/25 have been fully considered but they are not persuasive. Regarding clamed rejected under 35 U.S.C 112, second paragraph, is withdrawn. Therefore, these arguments are moot. The Applicnat’s argue, “ PNG media_image1.png 452 978 media_image1.png Greyscale ” This has been rectified. Please see the rejections above. The Applicants argue, “ PNG media_image2.png 508 960 media_image2.png Greyscale ” However, In response to applicant's argument that the prior art is nonanalogous art, it has been held that a prior art reference must either be in the field of the inventor’s endeavor or, if not, then be reasonably pertinent to the particular problem with which the inventor was concerned, in order to be relied upon as a basis for rejection of the claimed invention. See In re Oetiker, 977 F.2d 1443, 24 USPQ2d 1443 (Fed. Cir. 1992). The Applicants argue, “ PNG media_image3.png 294 974 media_image3.png Greyscale ” However, these arguments have been considered but moot since the rejection is withdrawn. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to HELEN OI CONLEY whose telephone number is (571)272-5162. The examiner can normally be reached 8:30 am - 5:00 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, Nicholas Smith can be reached on 5712728760. 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. /Helen Oi K CONLEY/Primary Examiner, Art Unit 1752
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Prosecution Timeline

Jul 26, 2022
Application Filed
Nov 27, 2024
Non-Final Rejection — §103, §112
Feb 25, 2025
Response Filed
May 09, 2025
Final Rejection — §103, §112
Jul 09, 2025
Response after Non-Final Action
Aug 06, 2025
Request for Continued Examination
Aug 12, 2025
Response after Non-Final Action
Sep 27, 2025
Non-Final Rejection — §103, §112
Nov 24, 2025
Response Filed
Jan 27, 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

4-5
Expected OA Rounds
70%
Grant Probability
77%
With Interview (+7.8%)
3y 7m
Median Time to Grant
High
PTA Risk
Based on 858 resolved cases by this examiner. Grant probability derived from career allow rate.

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