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 Arguments
Applicant's arguments filed 01/23/2026 have been fully considered but they are not persuasive. On pp. 6 of the remarks the applicant argues that:
Element 68 is not an inlet fitting of Bullard's water tank receptacle 16, as recited in independent claim 1. Rather, it is an outlet of the receptacle 16 that delivers steam from the boiling compartment 50 of the water tank receptacle 16 to the oven chamber (see Col. 5, 11. 10-13).
Bullard's inlet fitting 68 (as construed) is not positioned above the reservoir 48, as recited in independent claim 1. Rather, it is horizontally offset from the reservoir 48 and located below the reservoir's upper opening 49 (see FIG. 3).
Bullard's outlet fitting 45 does not fluidly connect to the inlet fitting 68 (as construed) upon positioning the water tank 14 on the water tank receptacle 16, as recited in independent claim 1. Rather, Bullard's fittings 45, 68 do not engage each other whatsoever when the water tank 14 is positioned on the receptacle 16.
The examiner respectfully disagrees with the applicant’s remarks for the following reasons:
With regards to “a.” the claims require that the water tank receptacle comprises “an inlet fitting positioned above the reservoir” but does not require that the inlet fitting is an inlet fitting to the water receptacle. Reference character 68 of Bullard delivers steam from the boiling compartment to the oven chamber and is therefore an inlet to the oven chamber.
With regards to “b.” Bullard disclose that “[a]s air enters the water tank 14, water is forced to flow from the water tank 14 into the receiving compartment 48…[w]hen the water level in the receiving compartment 48 reaches the bottom 65 of the discharge valve assembly 45, the flow of air into the water tank 14 is interrupted and the water flow from the water tank 14 thereby ceases” [column 4 lines 64-column 6 line 4 of Bullard]; because the water level is never higher than the bottom of 65 the inlet 68 is always higher than the water level, therefore 68 is fairly above the reservoir.
With regards to “c.” in Bullard water flows out of the discharge valve assembly 45, into the reservoir 48, boiling compartment 50 and exits as steam through 68, therefore there is a fluidic connection between 45 and 68 via water and steam. The claim does not require direct engagement between the water tank outlet and the inlet fitting.
With regards to the combination of Bullard and Yang the applicant argues that “…none of the cited references teaches or suggests that Yang's false bottom (as construed) should be applied to Bullard for this purpose” [pp. 7 of the remarks], the cited purpose being “in order to isolate the water in the reservoir from contacting the bottom of the tank, thereby preventing inadvertent contamination” [pp. 3 of the Non-Final rejection dated 09/23/2025]. The MPEP states that “[t]he rationale to modify or combine the prior art does not have to be expressly stated in the prior art; the rationale may be expressly or impliedly contained in the prior art or it may be reasoned from knowledge generally available to one of ordinary skill in the art, established scientific principles, or legal precedent established by prior case law” (emphasis added) [MPEP §2144]; a person having ordinary skill in the art at the time of the filing date of the invention would recognize the challenge in maintaining cleanliness in a humidifier or steam generator. Therefore, providing a false bottom as a barrier between the reservoir and the exterior of the tank prevents contamination because the false bottom taught by Yang would be easier to clean and sanitize than the bottom of the tank, since it can easily be dishwashed. For these reasons the rejections are maintained.
The applicant’s amendments to claim 11 overcome the rejection presented in the Non-Final rejection dated 01/23/2026, therefore the rejections are withdrawn.
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.
Claim(s) 1-4 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bullard (US 5,515,773) in view of Yang et. al (US 2020/0284451 A1).
With respect to claim 1 Bullard discloses that a steam oven comprising: a housing [reference character 10]; a cooking chamber [reference character 28] located within the housing; a water tank receptacle [reference character 16] connected to the housing, the water tank receptacle comprising: a reservoir [reference character 48], an inlet fitting [reference character 68] positioned above the reservoir; a reservoir outlet [reference character 56] extending though a bottom of the reservoir; and a water tank [reference character 14] selectively positionable on the water tank receptacle above water tank receptacle, the water tank having an outlet fitting [reference character 45] configured to fluidily connect to the inlet fitting upon positioning the water tank on the water tank receptacle.
Bullard does not disclose a false bottom positioned above the reservoir, and a reservoir outlet extending through a bottom of the reservoir.
Yang discloses a humidifier that includes a housing [reference character 20] a water tank receptacle [reference character 10] having a reservoir [reference character 112] and a water tank [reference character 21], where there is a false bottom [see annotated Fig. below] between the water tank receptacle and the water tank.
It would have been obvious to one of ordinary skill in the art at the time of the filing date of the invention to modify the system taught by Bullard by including a false bottom above the reservoir, as taught by Yang, in order to isolate the water in the reservoir from contacting the bottom of the tank, thereby preventing inadvertent contamination.
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With respect to claim 2 the combination of Bullard and Yang disclose that the false bottom comprises an opening [see annotated Fig. above] through which at least one of the inlet fitting and outlet fitting passes when the water tank is positioned on the water tank receptacle.
With respect to claim 3 the combination of Bullard and Yang disclose that the reservoir extends from a first end at a back of the housing to a second end at the front of the housing, the inlet fitting is adjacent the first end, and the reservoir outlet is adjacent the second end [see annotated Fig. below].
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With respect to claim 4 the combination of Bullard and Yang discloses drip tray [reference character 40] positioned below the reservoir outlet [see Fig. 3].
Claim(s) 5-6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bullard (US 5,515,773) in view of Yang et. al (US 2020/0284451 A1) and further in view of Tse (US 2009/0250452 A1).
With respect to claim 5 Bullard discloses a steam outlet system [reference characters 33-34 and 38] extending from the cooking chamber to the drip tray.
The combination of Bullard and Yang do not disclose a steam generator fluidly connected between the inlet fitting and the cooking chamber. Note that the steam generator [reference character 58] taught by Bullard is located in the water tank receptacle.
Tse discloses a steam oven that includes a water tank [reference character 30] and a water tank receptacle [reference character 32] and a steam generator [reference character 60] connected between an inlet fitting [reference character 52] and the cooking chamber.
It would have been obvious to one of ordinary skill in the art at the time of the filing date of the invention to modify the system taught by Bullard by separating the steam generator from the water tank receptacle so that it is between the inlet fitting and the cooking chamber, as taught by Tse, in order to allow for repair or replacement of the steam generator as a separate unit, and to bring the steam generator closer to the cooking chamber, to prevent condensation.
With respect to claim 6 the combination of Bullard, Yang and Tse discloses an exhaust manifold [reference characters 83, 88, 86, 90, and 92 of Tse] located above the drip tray (in combination with Bullard), and wherein the reservoir outlet and the steam outlet system are fluidly connected to the exhaust manifold.
Allowable Subject Matter
Claims 7-10 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims.
Claims 11-14 and 16-19 are allowed.
Conclusion
THIS ACTION IS MADE FINAL. 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 VIVEK K SHIRSAT whose telephone number is (571)272-3722. The examiner can normally be reached M-F 9:00AM-5:20AM.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Steven B McAllister can be reached at 571-272-6785. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/VIVEK K SHIRSAT/Primary Examiner, Art Unit 3762