Prosecution Insights
Last updated: April 19, 2026
Application No. 17/991,779

ELECTRONIC DEVICE

Non-Final OA §103
Filed
Nov 21, 2022
Examiner
IQBAL, HAMNA FATHIMA
Art Unit
2817
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Innolux Corporation
OA Round
3 (Non-Final)
91%
Grant Probability
Favorable
3-4
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 91% — above average
91%
Career Allow Rate
10 granted / 11 resolved
+22.9% vs TC avg
Moderate +12% lift
Without
With
+12.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
37 currently pending
Career history
48
Total Applications
across all art units

Statute-Specific Performance

§103
59.8%
+19.8% vs TC avg
§102
24.2%
-15.8% vs TC avg
§112
16.0%
-24.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 11 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 01/05/2025 has been entered. Information Disclosure Statement The information disclosure statement (IDS) submitted on 01/26/2026 is being considered by the examiner. Response to Amendment An Amendment filed on 01/05/2026, responding to the Office Action mailed on 11/06/2025, has been acknowledged and entered into the record. The present Non-final Rejection is made with all the suggested amendments being fully considered. Response to Arguments On page 8 of the remarks filed on 01/05/2026, with regards to the amended independent claim 1, Applicant argues that Hsu only discloses one conductive composite structure and therefore fails to disclose the feature about the first conductive composite structure and the second conductive composite structure. This argument is fully considered but is not persuasive. Figure 3N of Hsu illustrates only one conductive composite structure for clarity and simplicity but includes a plurality of conductive composite structure not shown in the Fig. 3N (see paragraph 0036). Furthermore, the wavy edges of the electronic device showing in Fig. 3N implicitly teaches that the structure is repeated and continues beyond the illustrated region. Therefore, a person of ordinary skill in the art would have recognized that the electronic device of Hsu would include a first conductive composite structures and a second conductive composite structure even though only one structure is explicitly shown in Fig 3N. Therefore, the rejection of Claim 1 and all dependent claims in view of Hsu is maintained. On pages 8-9 of the remarks filed on 01/05/2026, with regards to the amended independent claim 1, Applicant argues that Yugawa only discloses one conductive composite structure and therefore fails to disclose the first conductive structure comprises a first metal layer, a second metal layer, and a third metal layer, the second conductive structure comprises an another first metal layer, an another second metal layer, and an another third metal layer. This argument is fully considered but is not persuasive. Fig. 2 of Yugawa illustrates a plurality of conductive composite structures 5a and the detailed structure of only one of the structures is shown in Fig. 3 for clarity and simplicity. Thus, a person of ordinary skill in the art would have recognized that the electronic device of Yugawa comprises a first conductive composite structure and a second conductive composite structure, the first conductive structure comprises a first metal layer, a second metal layer, and a third metal layer, the second conductive structure comprises an another first metal layer, an another second metal layer, and an another third metal layer. Therefore, the rejection of Claim 1 and all dependent claims in view of Yugawa is maintained. 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 and 9 are rejected under 35 U.S.C. 103 as being unpatentable over Hsu (US 20090020322 A1), in view of Yugawa (US 20210227691 A1). Regarding Claim 1, Hsu teaches an electronic device, comprising: a substrate 30 (Fig. 3N: 30, paragraph 0050); a first conductive composite structure and a second conductive composite structure 332, 34, 35 disposed on the substrate 30 (Fig. 3N: 30, 332, 34, 35, paragraph 0050, 0006, 0036), Note that according to paragraph 0036 of Hsu, the electronic device of Hsu has a plurality of conductive structures but only one structure is shown in Fig. 3N for simplicity, and two of these structures are interpreted as the first and second conductive structures. wherein the first conductive composite structure 332, 34, 35 comprises a first metal layer 332, a second metal layer 34, and a third metal layer 35, the second conductive composite structure 332, 34, 35 comprises an another first metal layer 332, an another second metal layer 34, and an another third metal layer 35 (Fig. 3N: 332, 34, 35, paragraph 0050, 0036), Note that according to paragraph 0036 of Hsu, the electronic device of Hsu has a plurality of conductive structures but only one structure is shown in Fig. 3N for simplicity. Each conductive compositive structure will inherently have its own three metal layers. wherein the second metal layer 34 is located between the first metal layer 332 and the third metal layer 35 (Fig. 3N: 332, 34, 35), and an electronic element disposed on the first conductive composite structure and the second conductive composite structure 332, 34, 35 and coupled to the first conductive composite structure and the second conductive composite structure 332, 34, 35 (electronic component not shown in figures, see paragraph 0048). Hsu fails to explicitly teach that the thickness of the second metal layer 34 ranges from 0.5 µm to 12 µm, wherein a thickness of the third metal layer 35 ranges from 10 nm to 0.5 um. However, Yugawa teaches an electronic device, comprising at least one conductive composite structure 5a including a first metal layer 9, a second metal layer 10, and a third metal layer 11, and a thickness of the second metal layer 10 ranges from ranges from 5 µm to 30 µm, wherein a thickness of the third metal layer 11 ranges from 1000 nm to 3 um. (Fig. 2: 5a, Fig. 3: 9, 10, 11, paragraphs 0019, 0022, 0026). While Yugawa fails to explicitly teach the thickness of the second metal layer 10 ranges from 0.5 µm to 12 µm, the disclosed range of Yugawa overlaps the claimed range. According to MPEP § 2144.05 (I), “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists”. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). Furthermore, while Yugawa fails to explicitly teach the thickness of the third metal layer 11 ranges from 10 nm to 0.05 µm, differences in thickness will not support the patentability of subject matter encompassed by the prior art unless there is evidence indicating such thickness is critical. See MPEP § 2144.05 (II-A), "[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation." In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955). Since the applicant has not provided any experimental evidence to demonstrate that the claimed thickness range renders unexpected results, 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 thickness range of Yugawa through routine optimization to 10 nm to 0.05 µm. Examiner Note: The specification contains no disclosure of either the criticality of the claimed thickness ranges or any unexpected results arising from them. According to MPEP § 716.02 (d), to establish unexpected results over a claimed range, applicants should compare a sufficient number of tests both inside and outside the claimed range to show the criticality of the claimed range. In re Hill, 284 F.2d 955, 128 USPQ 197 (CCPA 1960). Therefore, it would have been obvious to a person of ordinary skill in the art, before the effective filing date of the claimed invention, to have combined the teachings of Hsu with the teachings of Yugawa in order to have the thickness of the second metal layer range from 0.5 µm to 12 µm and the thickness of the third metal layer range from 10 nm to 0.5 µm through routine optimization. Doing so would lower the electrical resistance between the electronic device and the electronic device components, as recognized by Yugawa (paragraph 0022). Regarding Claim 9, Hsu teaches the electronic device according to claim 1, wherein a width of the first metal layer 332 is less than or equal to a width of the second metal layer 34 (See Fig. 3N). Claims 12 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Hsu (US 20090020322 A1), in view of Yugawa (US 20210227691 A1), as applied to Claim 1 above, further in view of Onaka et al. (US 20210149259 A1). Regarding Claim 12, Hsu teaches the electronic device according to claim 1, wherein a material of the second metal layer 34 comprises copper or aluminum (paragraph 0038). Hsu fails to teach wherein a material of the first metal layer and a material of the third metal layer each comprise titanium, titanium alloy, molybdenum, molybdenum alloy, indium tin oxide, or oxide Indium zinc. However, Yugawa teaches wherein a material of the first metal layer 9 comprises titanium, titanium alloy, molybdenum, molybdenum alloy, indium tin oxide, or oxide Indium zinc (paragraph 0020). Therefore, a person of ordinary skill in the art would have combined the teachings of Hsu with the teachings of Yugawa in order to have a material of the first metal layer to comprise titanium, titanium alloy, molybdenum, molybdenum alloy, indium tin oxide, or oxide Indium zinc. Doing so would improve the adhesion with adjacent layers, as recognized by Yugawa (paragraph 0020). Further, Onaka et al. teaches an electronic device comprising a conductive composite structure 7, wherein a material of the third metal 4 layer comprises titanium, titanium alloy, molybdenum, molybdenum alloy, indium tin oxide, or oxide Indium zinc (Fig. 6: 7, 4, paragraphs 0075, 0126). Therefore, a person of ordinary skill in the art would have combined the teachings of Hsu with the teachings of Onaka et al. in order to have a material of the third metal layer to comprise titanium, titanium alloy, molybdenum, molybdenum alloy, indium tin oxide, or oxide Indium zinc. Doing so would improve the adhesion with adjacent layers, thereby minimizing the likelihood of peeling or chipping of the metal layers due to electrostatic breakdown, as recognized by Onaka et al. (paragraph 0066). Regarding Claim 13, the combination of Hsu and Yugawa fails to teach the electronic device according to claim 1, wherein one of the first metal layer and the third metal layer comprises oxide. However, Onaka et al. teaches an electronic device, comprising at least one conductive composite structure 7, wherein one of the first metal layer 4 and the third metal layer 4 comprises oxide (Fig. 6: 7, 4, paragraphs 0075, 0126). Therefore, a person of ordinary skill in the art would have combined the teachings of Hsu, Yugawa and Onaka et al. in order to have one of the first metal layer and the third metal layer comprise an oxide. Doing so would improve the adhesion with adjacent layers, thereby minimizing the likelihood of peeling or chipping of the second metal layer due to electrostatic breakdown, as recognized by Onaka et al. (paragraph 0066). Claims 1, 3, 4, 6-8, 11, and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Chen et al. (US 20210327861 A1), in view of Yugawa (US 20210227691 A1). Regarding Claim 1, Chen et al. teaches an electronic device, comprising: a substrate 10 (Fig. 1F: 10, paragraph 0046); a first conductive structure 112a-1 and a second conductive structure 112a-2 disposed on the substrate 10 (Fig. 1F: 10, 112a-1, 112a-2, paragraph 0048), wherein the first conductive structure 112a-1 and the second conductive structure 112a-2 are disposed at intervals (see annotated Fig. 1F of Chen et al: 112a-1, 112a-2) and an electronic element 130a disposed on the first conductive structure 112a-1 and a second conductive structure 112a-2 and coupled to the first conductive structure 112a-1 and the second conductive structure 112a-2 (Fig. 1F: 130a, 112a-1, 112a-2, paragraph 0051). Chen et al. fails to explicitly teach that the first conductive structure 112a-1 and a second conductive structure 112a-2 is a composite structure, the first conductive structure 112a-1 comprises a first metal layer, a second metal layer, and a third metal layer, the second conductive structure 112a-2 comprises an another first metal layer, an another second metal layer, and an another third metal layer, wherein the second metal layer is located between the first metal layer and the third metal layer, a thickness of the second metal layer ranges from 0.5 µm to 12 µm, wherein a thickness of the third metal layer ranges from 10 nm to 0.5 um However, Yugawa teaches an electronic device, comprising first conductive composite structure and a second conductive composite structure 5a, the first conductive structure 5a comprises a first metal layer 9, a second metal layer 10, and a third metal layer 11, the second conductive structure 5a comprises an another first metal layer 9, an another second metal layer 10, and an another third metal layer 11, wherein the second metal layer 10 is located between the first metal layer 9 and the third metal layer 11, and a thickness of the second metal layer 10 ranges from ranges from 5 µm to 30 µm, wherein a thickness of the third metal layer 11 ranges from 10 nm to 0.5 um (Fig. 2: 5a, Fig. 3: 9, 10, 11, paragraphs 0019, 0022, 0026). Note that while Yugawa does not explicitly teach a thickness of the second metal layer ranges from 0.5 µm to 12 µm, according to MPEP § 2144.05 (I), “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists”. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). Further note that while Yugawa fails to explicitly teach the thickness of the third metal layer 11 ranges from 10 nm to 0.05 µm, differences in thickness will not support the patentability of subject matter encompassed by the prior art unless there is evidence indicating such thickness is critical. See MPEP § 2144.05 (II-A), "[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation." In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955). Since the applicant has not provided any experimental evidence to demonstrate that the claimed thickness range renders unexpected results, 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 thickness range of Yugawa through routine optimization to 10 nm to 0.05 µm. Examiner Note: The specification contains no disclosure of either the criticality of the claimed thickness ranges or any unexpected results arising from them. According to MPEP § 716.02 (d), to establish unexpected results over a claimed range, applicants should compare a sufficient number of tests both inside and outside the claimed range to show the criticality of the claimed range. In re Hill, 284 F.2d 955, 128 USPQ 197 (CCPA 1960). Therefore, it would have been obvious to a person of ordinary skill in the art, before the effective filing date of the claimed invention, to combine the teachings of Chen et al. with the teachings of Yugawa in order to come up with the claimed invention by incorporating the conductive composite structure of Yugawa into the electronic device of Chen et al. Doing so would lower the electrical resistance between the electronic device and the electronic device components, improve adhesion between the metal layers and insulating layers of the electronic device, and suppress metal diffusion, as recognized by Yugawa (paragraphs 0021, 0022, 0024). Regarding Claim 3, the combination of Chen et al. and Yugawa teaches the electronic device according to claim 2, further comprising: a first solder and a second solder disposed between the electronic element 130a and the substrate 10, wherein the electronic element 130a is electrically connected to the first conductive composite structure 112a-1 through the first solder and to the second conductive composite structure 112a-2 through the second solder (see annotated Fig. 1F of Chen et al: first solder, second solder, 112a-1, 112a-2). PNG media_image1.png 596 1418 media_image1.png Greyscale Annotated Fig. 1F of Chen et al. (US 20210327861 A1) Regarding Claim 4, the combination of Chen et al. and Yugawa teaches the electronic device according to claim 1, further comprising a third conductive composite structure 112a-3, the first conductive composite structure 112a-1 is located between the second conductive composite structure 112a-2 and the third conductive composite structure 112a-3, and the first conductive composite structure 112a-1, the second conductive composite structure 112a-2, and the third conductive composite structure 112a-3 are separated from one another in a discontinuous manner (see annotated Fig. 1F of Chen et al: 112a-1, 112a-2, 112a-3). Regarding Claim 6, Chen et al. teaches wherein the electronic element 130a comprises an active electronic component, a passive electronic component, an integrated circuit or combination thereof (paragraph 0051). Regarding Claim 7, the combination of Chen et al. and Yugawa teaches the electronic device according to claim 1, further comprising: a switching element 120a and a redistribution layer 110a disposed on the substrate 10, wherein the switching element 120a is electrically connected to the first conductive composite structure 112a-1 or second conductive composite structure 112a-2 through the redistribution layer 110a (Fig. 1F of Chen et al.: 120a, 110a, 10, 112a, paragraph 0051 of Chen et al.). Regarding Claim 8, Yugawa teaches the electronic device according to claim 1, wherein the third metal layer 11 is at least partially in contact with a side surface of the second metal layer 10 (See Fig. 3 of Yugawa). Regarding Claim 11, Yugawa teaches the electronic device according to claim 1, wherein the third metal layer 11 (included in the conductive composite structure 5a of Fig. 2) is separated from the substrate 2 by a distance, and the third metal layer 11 covers a side surface of the second metal layer 10 and part of the side surface of the first metal layer 9 (see Fig. 3: 9, 10, 11, Fig. 2: 2, 5a of Yugawa). Regarding Claim 14, Yugawa teaches the electronic device according to claim 1, wherein a thickness of the first metal layer 9 ranges from 10 nm to 0.5 µm (paragraph 0020). Yugawa in paragraph 0020 teaches a thickness of the first metal layer 9 ranges from 10 nm to 0.1 µm. According to MPEP § 2144.05 (I), “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists”. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to choose the thickness of the first metal layer 9 to be in the range from 10 nm to 0.5 µm. Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Chen et al. (US 20210327861 A1), in view of Yugawa (US 20210227691 A1), as applied to Claim 4 above, further in view of Wu (US 20130277099 A1). The combination of Chen et al. and Yugawa fails to explicitly teach the electronic device according to claim 4, wherein a horizontal distance between the first conductive composite structure and the second conductive composite structure and a horizontal distance between the first conductive composite structure and the third conductive composite structure range from 10 µm to 100 µm. However, Wu teaches an electronic device comprising at least one conductive structure, wherein a horizontal distance 230 between the first conductive structure 220 and the second conductive structure 215 and a horizontal distance 230 between the first conductive structure 220 and the third conductive structure 225 range from 10 µm to 100 µm (paragraph 0056). Note that Wu teaches the horizontal distance 230 is around 100 µm or 180-200 µm (paragraph 0056). According to MPEP § 2144.05 (I), “In the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists”. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). Therefore, a person of ordinary skill in the art would have combined the teachings of Chen et al., Yugawa and Wu in order to have a horizontal distance between the first conductive composite structure and the second conductive composite structure and a horizontal distance between the first conductive composite structure and the third conductive composite structure range from 10 µm to 100 µm. Doing so would facilitate the fabrication of smaller devices with finer spacing between conductive structures, as recognized by Wu (paragraph 0002). Claims 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Chen et al. (US 20210327861 A1), in view of Yugawa (US 20210227691 A1), as applied to Claim 1 above, further in view of Tseng et al. (US 20090314650 A1). Regarding Claim 17, Chen et al. fails to teach the electronic device according to claim 1, an insulating layer disposed on the third metal layer, wherein the third metal layer comprises a first opening, and the insulating layer comprises a second opening, wherein the first opening exposes part of the second metal layer; and a solder filled in the first opening and the second opening and electrically connected to the first conductive composite structure or the second conductive composite structure. However, Yugawa teaches an insulating layer 6 disposed on the third metal layer 11 (included in the conductive composite structure 5a of Fig. 2), wherein the third metal layer 11 comprises a first opening (see opening in conductive composite structure 5a of Fig. 2), and the insulating layer 6 comprises a second opening 6a (see Fig. 2 and paragraph 0033). Therefore, a person of ordinary skill in the art would have combined the teachings of Chen et al. and Yugawa together in order to have an insulating layer disposed on the third metal layer, wherein the third metal layer comprises a first opening, and the insulating layer comprises a second opening. Doing so would enable the insulating layer to serve as a solder resist layer and also expose the metal layers through the openings in order to establish electrical connection to the electronic component, as recognized by the Yugawa et al. (paragraph 0033). The combination of Chen et al. and Yugawa fails to explicitly teach: wherein the first opening exposes part of the second metal layer; and a solder filled in the first opening and the second opening and electrically connected to the first conductive composite structure or the second conductive composite structure. However, Yugawa does teach that the electronic components S, M are electrically connected to the conductive composite structure 5a via a solder (Fig. 2: S, M, 5a, paragraph 0019). Therefore, a person of ordinary skill in the art, using the combined teachings of Chen et al. and Yugawa, would have recognized that the above solder will be filled in the first opening and the second opening in order to be electrically connected to the first conductive composite structure or the second conductive composite structure. Further, Tseng et al. teaches an electronic device comprising a conductive composite structure 106, 104, 102, the third metal layer 102A comprises a first opening, wherein the first opening exposes part of the second metal layer 104 (Fig. 1A: 106, 104, 102, Fig 1B: 102A, paragraph 0024). Therefore, a person or ordinary skill in the art would have combined the teachings of Chen et al., Yugawa, and Tseng et al. in order to have the first opening of the third metal layer expose part of the second metal layer. Doing so would enable electrical connection to be established between the electronic component and the metal layers. Regarding Claim 18, Yugawa teaches the electronic device according to claim 17, wherein a material of the insulating layer 6 comprises silicon nitride, silicon oxide, epoxy resin, silicon material, or a combination thereof (paragraph 0033). Pertinent Prior Art of Record The following prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Sugiura (US 20040247840 A1) Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to HAMNA F IQBAL whose telephone number is 571-272-1587. The examiner can normally be reached M-F: 8.30 am - 5.30 pm EST. 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, Kretelia Graham can be reached at 571-272-5055. 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. /HAMNA FATHIMA IQBAL/Examiner, Art Unit 2817 03/16/2026 /Kretelia Graham/Supervisory Patent Examiner, Art Unit 2817 March 20, 2026
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Prosecution Timeline

Nov 21, 2022
Application Filed
Jul 09, 2025
Non-Final Rejection — §103
Oct 09, 2025
Response Filed
Oct 21, 2025
Final Rejection — §103
Jan 05, 2026
Request for Continued Examination
Jan 23, 2026
Response after Non-Final Action
Mar 17, 2026
Non-Final Rejection — §103 (current)

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