Prosecution Insights
Last updated: April 19, 2026
Application No. 17/951,075

Phone Case with Thermal Ground Plane

Final Rejection §103
Filed
Sep 22, 2022
Examiner
MUIR, MATTHEW SINCLAIR
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Kelvin Thermal Technologies Inc.
OA Round
4 (Final)
68%
Grant Probability
Favorable
5-6
OA Rounds
2y 8m
To Grant
99%
With Interview

Examiner Intelligence

Grants 68% — above average
68%
Career Allow Rate
73 granted / 108 resolved
At TC average
Strong +39% interview lift
Without
With
+39.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
29 currently pending
Career history
137
Total Applications
across all art units

Statute-Specific Performance

§103
50.9%
+10.9% vs TC avg
§102
22.5%
-17.5% vs TC avg
§112
17.0%
-23.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 108 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 Objections Claims 1 and 18 are objected to because of the following informalities: Claim 1, Line 12: “a hole in middle portion” should be amended to recite “a hole in a middle portion”. Claim 1, Line 13: “the the cutout” should be amended to recite “the cutout”. Claim 18, Lines 11-12: “a hole in middle portion” should be amended to recite “a hole in a middle portion”. Claim 18, Line 12: “the the cutout” should be amended to recite “the cutout”. Appropriate correction is required. The numbering of claims is not in accordance with 37 CFR 1.126 which requires the original numbering of the claims to be preserved throughout the prosecution. When claims are canceled, the remaining claims must not be renumbered. When new claims are presented, they must be numbered consecutively beginning with the number next following the highest numbered claims previously presented (whether entered or not). Misnumbered claims 1, 2, 3, 4, 5 and 78 have been renumbered 2, 4, 5, 8, 9 and 18. 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 1 is rejected under 35 U.S.C. 103 as being unpatentable over Kawakatsu (JP 2019016883 A) in view of She (CN 209930339 U). As to Claim 1, Kawakatsu discloses: A phone case (protective case 1a; see Fig. 1) comprising: a phone case body (case body 5); and a thermal ground plane (combination of vapor chamber 20 and protective sheet 7) embedded within the phone case body 5 (Par. 0026 “the heat spreader 6 may be a vapor chamber”; vapor chamber 20 of Fig. 3 is embedded within mounting portion 2), the thermal ground plane 20/7 comprising: a first casing (first sheet 22; see Fig. 3); a liquid transport layer comprising a mesh (inherent that a vapor chamber has a liquid transport layer located opposite the heat source; Par. 0040 “The working medium is not particularly limited as long as it can cause a gas-liquid phase change under the environment in the housing”; Par. 0038 “The wick 27 is not particularly limited as long as it has a structure capable of moving the working medium by a capillary force. The capillary structure that exerts a capillary force to move the working medium is not particularly limited, and may be a known structure used in a conventional vapor chamber. Examples of the capillary structure include a fine structure having irregularities such as pores, grooves, and protrusions, for example, a fiber structure, a groove structure, and a network structure”; definition of mesh “an interwoven or intertwined structure; network” – Dictionary.com; wick 27 is at least indirectly connected to inner side of second sheet 23 defined as liquid transport layer); a vapor transport layer comprising an array of pillars (inherent that a vapor chamber has a vapor transport layer located adjacent to the heat source; Par. 0040 “The working medium is not particularly limited as long as it can cause a gas-liquid phase change under the environment in the housing”; Par. 0033 “One or both of the first sheet and the second sheet has a plurality of protrusions 30 or columns 25, or protrusions 30 and columns 25, on the main surface on the internal space side”; columns 25 pass through inner side of first sheet 22 defined as vapor transport layer); and a second casing (second sheet 23), an outer periphery of the first casing 22 and an outer periphery of the second casing 23 are sealed together encasing the liquid transport layer, the vapor transport layer, and a heat transfer fluid (Par. 0029 “a first sheet 22 and a second sheet 23 which are opposed to each other and whose outer edges 21 are joined to each other”; Par. 0028 “An example of the vapor chamber is a vapor chamber including a planar housing having a sealed space, a wick disposed in the sealed space, and a working medium sealed in the sealed space”). Kawakatsu does not disclose: wherein the thermal ground plane includes a cutout comprising a hole in a middle portion of the thermal ground plane that comprises a dielectric, the cutout does not include a metal, and the cutout is aligned with a wireless charging area of a mobile phone. However, She discloses: wherein the thermal ground plane (heat dissipation film 23; corresponds to 20/7 of Kawakatsu) includes a cutout comprising a hole (hole 231) in a middle portion of the thermal ground plane (Par. 0029 “a hole 231 is provided in the center of the nano-carbon heat dissipation film 23”) that comprises a dielectric (Par. 0032 “The middle filling layer 232 is any one of thermal conductive paste, thermal conductive silicone, or thermal conductive cloth”; at least silicone is a dielectric material), the cutout does not include a metal (hole is filled with non-metal filling layer 232), and the cutout is aligned with a wireless charging area of a mobile phone (Par. 0029 “a hole 231 is provided in the center of the nano-carbon heat dissipation film 23 for facilitating wireless charging, and the hole 231 is filled with a middle filling layer 232 with a heat-conducting effect”; “the wireless charger directly connects to the electronic product through the middle filling layer 232”); in order to prevent the nano-carbon heat dissipation film 23 from affecting the wireless charging, and ensuring the normal operation of the wireless charging (Par. 0029). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Kawakatsu as further suggested by She e.g., providing: wherein the thermal ground plane includes a cutout comprising a hole in a middle portion of the thermal ground plane that comprises a dielectric, the cutout does not include a metal, and the cutout is aligned with a wireless charging area of a mobile phone; in order to prevent the thermal ground plane from affecting the wireless charging, and ensuring the normal operation of the wireless charging. Examiner note: see translations of Kawakatsu and She in PTO-892 of 06/04/2024. Additionally, all claimed elements were known in the prior art and one skilled in the art could have combined/modified the elements as claimed by known methods with no change in their respective functions, and the combination/modification would have yielded predictable results to one of ordinary skill in the art before the effective filing date of the claimed invention. See KSR International Co. v. Teleflex Inc., 550 U.S.___, 82 USPQ2d 1385 (2007). Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over Kawakatsu (JP 2019016883 A) in view of She (CN 209930339 U) as applied to claim 1 above, and further in view of Ady (US 9600041 B2). As to Claim 2, the obvious modification of Kawakatsu in view of She does not disclose: further comprising a fin that folds or bends outward from the phone case body. However, Ady discloses: further comprising a fin (second portion 34) that folds or bends outward from the phone case body (heat management apparatus 10; see Figs. 1-2, 4 and 5B-5C; col. 5, Lines 9-12 “The heat spreader acts much like a fin to direct heat away from the inner heat generating elements as well as away from the outer body of the electronic device”; col. 6, Lines 9-11 “With reference to FIG. 5(b), the second portion of the heat spreader can be rotated away from the top surface and moved from the side surface”; col. 6, Lines 18-23 “With reference to FIG. 5(c), the second portion 34 of the heat spreader can be further rotated such that it is in a downward direction again away from the electronic device but at an angle (such as, for example 90°) relative to the first portion 32 of the heat spreader that overlies the bottom surface”); in order to direct heat away from the inner heat generating elements as well as away from the outer body of the electronic device (col. 5, Lines 9-12). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Kawakatsu in view of She as further suggested by Ady e.g., providing: further comprising a fin that folds or bends outward from the phone case body; in order to direct heat away from the inner heat generating elements of the phone as well as away from the outer body of the electronic device/phone. Claims 3-5 are rejected under 35 U.S.C. 103 as being unpatentable over Kawakatsu (JP 2019016883 A) in view of She (CN 209930339 U) as applied to claim 1 above, and further in view of Li (US 20220294485 A1). As to Claim 3, the obvious modification of Kawakatsu in view of She does not disclose: further comprising a magnetic area that comprises a toroid or donut shape. However, Li discloses: further comprising a magnetic area (magnetic coil 30; see Fig. 1) that comprises a toroid or donut shape (coil 30 is circular; Par. 0020 “the magnetic housing for mobile device comprises a housing body 10, an outer sleeve 20, a magnetic coil 30”); in order to provide a magnetic coil to cooperate with wireless charging modules of a mobile device (Par. 0003) and to prevent an increase in thickness of the housing body when magnetic coils are disposed (Par. 0029). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Kawakatsu in view of She as further suggested by Li e.g., providing: further comprising a magnetic area that comprises a toroid or donut shape; in order to provide a magnetic coil/area to cooperate with wireless charging modules of a mobile device/phone and to prevent an increase in thickness of the housing body/phone case when magnetic coils are disposed. As to Claim 4, the obvious modification of Kawakatsu in view of She and Li discloses: wherein the magnetic area (30 of Li) is configured to couple with a magnetic coupler within a phone (magnetic coil 30 of Li is capable of coupling to a magnetic member of a mobile device; Par. 0003 “In order to increase the charging efficiency, when the wireless charging module is placed on the charging board for charging, the coils of the two wireless charging modules would be correspondingly aligned, and the wireless charging module of the mobile device would be equipped with a magnetic member, to cooperate with the magnetic members of the charging board to perform mutual alignment. Besides, it can also be combined with a magnetic bracket for positioning by a magnetic member. To cooperate with wireless charging modules of the conventional mobile devices, the housing for conventional mobile devices (protective case) would also be equipped with magnetic coil members”; Li). As to Claim 5, the obvious modification of Kawakatsu in view of She does not disclose: further comprising one or more wireless charging antennas. However, Li discloses: further comprising one or more wireless charging antennas (magnetic coil 30; see Fig. 1; Par. 0022 “In some embodiments, the coil is a protocol recognition coil or a charging coil”); in order to provide a charging coil within a magnetic housing for a mobile device 100 (Par. 0022) and to prevent an increase in thickness of the housing body when magnetic coils are disposed (Par. 0029). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Kawakatsu in view of She as further suggested by Li e.g., providing: further comprising one or more wireless charging antennas; in order to provide a charging coil within a magnetic housing for a mobile device/phone case and to prevent an increase in thickness of the housing body/phone case when magnetic coils are disposed. Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Kawakatsu (JP 2019016883 A) in view of She (CN 209930339 U) as applied to claim 1 above, and further in view of Barnett (US 8560031 B2). As to Claim 9, the obvious modification of Kawakatsu in view of She does not disclose: further comprising a handle extending from a back of the phone case. However, Barnett discloses: further comprising a handle (combination of sockets 24, buttons 1, and accordions 2) extending from a back of the phone case 100 (col. 3-4, Lines 66-67 and 1 “FIG. 1B shows case 100 with accordions 2 of sockets 24 extended. The user pulls buttons 1 out from case body 4, and accordions 2 unfold and extend outward”); in order to provide comfortable grips for gaming, data entry and searching the internet (col. 1, Lines 61-62) and allowing the user to securely hold and manipulate the player with one hand (col. 1, Lines 43-44). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Kawakatsu in view of She as further suggested by Barnett e.g., providing: further comprising a handle extending from a back of the phone case; in order to allow the user of a phone to securely hold and manipulate the phone with one hand and provide a comfortable grip while using the phone. Claim 18 is rejected under 35 U.S.C. 103 as being unpatentable over Kawakatsu (JP 2019016883 A) in view of She (CN 209930339 U). As to Claim 18, Kawakatsu discloses: A phone case (protective case 1a; see Fig. 1) comprising: a phone case body (case body 5); a thermal ground plane (combination of vapor chamber 20 and protective sheet 7) embedded within the phone case body 5 (see Fig. 3, vapor chamber 20 is embedded in mounting portion 2 of case body 5), the thermal ground plane 20/7 comprising: a first casing (first sheet 22; see Fig. 3); a liquid transport layer comprising an array of pillars 30 (inherent that a vapor chamber has a liquid transport layer located opposite the heat source; Par. 0040 “The working medium is not particularly limited as long as it can cause a gas-liquid phase change under the environment in the housing”; Par. 0033 “One or both of the first sheet and the second sheet has a plurality of protrusions 30 or columns 25, or protrusions 30 and columns 25, on the main surface on the internal space side”; inner side of second sheet 23 has protrusions 30, wherein inner side of 23 is defined as liquid transport layer); a vapor transport layer comprising a mesh 27 (inherent that a vapor chamber has a vapor transport layer located adjacent to the heat source; Par. 0040 “The working medium is not particularly limited as long as it can cause a gas-liquid phase change under the environment in the housing”; Par. 0038 “The wick 27 is not particularly limited as long as it has a structure capable of moving the working medium by a capillary force. The capillary structure that exerts a capillary force to move the working medium is not particularly limited, and may be a known structure used in a conventional vapor chamber. Examples of the capillary structure include a fine structure having irregularities such as pores, grooves, and protrusions, for example, a fiber structure, a groove structure, and a network structure”; definition of mesh “an interwoven or intertwined structure; network” – Dictionary.com; wick 27 is at least indirectly connected to inner side of first sheet 22 defined as vapor transport layer); and a second casing (second sheet 23), an outer periphery of the first casing 22 and an outer periphery of the second casing 23 are sealed together encasing the liquid transport layer, the vapor transport layer, and a heat transfer fluid (Par. 0029 “a first sheet 22 and a second sheet 23 which are opposed to each other and whose outer edges 21 are joined to each other”; Par. 0028 “An example of the vapor chamber is a vapor chamber including a planar housing having a sealed space, a wick disposed in the sealed space, and a working medium sealed in the sealed space”). Kawakatsu does not disclose: wherein the thermal ground plane includes a cutout comprising a hole in a middle portion of the thermal ground plane that comprises a dielectric, the cutout does not include a metal, and the cutout is aligned with a wireless charging area of a mobile phone. However, She discloses: wherein the thermal ground plane (heat dissipation film 23; corresponds to 20/7 of Kawakatsu) includes a cutout comprising a hole (hole 231) in a middle portion of the thermal ground plane (Par. 0029 “a hole 231 is provided in the center of the nano-carbon heat dissipation film 23”) that comprises a dielectric (Par. 0032 “The middle filling layer 232 is any one of thermal conductive paste, thermal conductive silicone, or thermal conductive cloth”; at least silicone is a dielectric material), the cutout does not include a metal, and the cutout is aligned with a wireless charging area of a mobile phone (Par. 0029 “a hole 231 is provided in the center of the nano-carbon heat dissipation film 23 for facilitating wireless charging, and the hole 231 is filled with a middle filling layer 232 with a heat-conducting effect”; “the wireless charger directly connects to the electronic product through the middle filling layer 232”); in order to prevent the nano-carbon heat dissipation film 23 from affecting the wireless charging, and ensuring the normal operation of the wireless charging (Par. 0029). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Kawakatsu as further suggested by She e.g., providing: wherein the thermal ground plane includes a cutout comprising a hole in a middle portion of the thermal ground plane that comprises a dielectric, the cutout does not include a metal, and the cutout is aligned with a wireless charging area of a mobile phone; in order to prevent the thermal ground plane from affecting the wireless charging, and ensuring the normal operation of the wireless charging. Additionally, all claimed elements were known in the prior art and one skilled in the art could have combined/modified the elements as claimed by known methods with no change in their respective functions, and the combination/modification would have yielded predictable results to one of ordinary skill in the art before the effective filing date of the claimed invention. See KSR International Co. v. Teleflex Inc., 550 U.S.___, 82 USPQ2d 1385 (2007). Examiner note: see translation of Kawakatsu in previous PTO-892 of 06/04/2024. Response to Arguments Applicant's arguments filed 07/07/2025 have been fully considered but they are not persuasive. Applicant suggests “Because the reference states that protrusions can replace the wick, then either the vapor transport layer or the liquid transport layer are not necessary. Thus, the reference shows it is not inherent that vapor chamber has a liquid transport layer and a vapor transport layer as alleged. It can have on or the other…Thus, Kawakatsu shows that either or both the liquid transport layer or the vapor transport layer are not inherent” (Remarks, Pg. 2). In response, Examiner notes that when a vapor chamber functions, vapor is produced when the working fluid is heated by a heat source. The vapor is then condensed back to liquid and travels backs to the region near the heat source. Therefore, there must be a liquid transport region where liquid travels, and a vapor transport region where vapor travels. Applicant also suggests “the wick 27 is not necessarily a mesh” (Remarks, Pg. 2). In response, Examiner notes that the definition of “mesh”, provided in the rejections of claims 1 and 18 above, states that a mesh is a network. Kawakatsu discloses that the wick 27 may include a network structure. 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 MATTHEW S MUIR whose telephone number is (571)270-1329. The examiner can normally be reached Monday - Friday 8 am - 5 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, Jayprakash Gandhi can be reached at (571)272-3740. 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. /MATTHEW SINCLAIR MUIR/ Examiner, Art Unit 2835 /Jayprakash N Gandhi/ Supervisory Patent Examiner, Art Unit 2835
Read full office action

Prosecution Timeline

Sep 22, 2022
Application Filed
May 29, 2024
Non-Final Rejection — §103
Sep 04, 2024
Response Filed
Nov 15, 2024
Final Rejection — §103
Jan 21, 2025
Response after Non-Final Action
Feb 19, 2025
Request for Continued Examination
Feb 20, 2025
Response after Non-Final Action
Feb 25, 2025
Non-Final Rejection — §103
Jul 07, 2025
Response Filed
Oct 01, 2025
Final Rejection — §103 (current)

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Prosecution Projections

5-6
Expected OA Rounds
68%
Grant Probability
99%
With Interview (+39.1%)
2y 8m
Median Time to Grant
High
PTA Risk
Based on 108 resolved cases by this examiner. Grant probability derived from career allow rate.

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