Prosecution Insights
Last updated: April 19, 2026
Application No. 18/130,961

COOKING APPLIANCE WITH VAPOR GENERATOR

Non-Final OA §102§103§112
Filed
Apr 05, 2023
Examiner
WANG, FRANKLIN JEFFERSON
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Whirlpool Corporation
OA Round
1 (Non-Final)
51%
Grant Probability
Moderate
1-2
OA Rounds
3y 8m
To Grant
99%
With Interview

Examiner Intelligence

Grants 51% of resolved cases
51%
Career Allow Rate
59 granted / 116 resolved
-19.1% vs TC avg
Strong +51% interview lift
Without
With
+51.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
56 currently pending
Career history
172
Total Applications
across all art units

Statute-Specific Performance

§101
2.0%
-38.0% vs TC avg
§103
60.3%
+20.3% vs TC avg
§102
14.5%
-25.5% vs TC avg
§112
20.3%
-19.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 116 resolved cases

Office Action

§102 §103 §112
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification, as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: “handle-supporting portion” in claims 3 and 9, “engagement member” in claim 10, and “biasing member” in claim 10. Regarding the limitation “engagement member” in claim 10, because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. A review of the specification and drawing found the corresponding structure of circular component capable of being received a notch of the projection (per fig. 6-7). Regarding the limitation “biasing member” in claim 10, because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. A review of the specification and drawing found the corresponding structure of a spring (per paragraph 41 and fig. 6-7). Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 4-6, 8, and 19-20 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. The term “area proximate from” in claim 4 is a relative term which renders the claim indefinite. The term “area proximate from” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. One of ordinary skill in the art would be unable to determine how close an area would need to be from said axis to satisfy the limitation. Claim 19 recites the limitation “the upper handle-supporting adjacent surface”. There is insufficient antecedent basis for this limitation in the claim. Claim 18 recites the limitation “an upper handle-adjacent surface”. For purposes of examination, it will be interpreted that “the upper handle-supporting adjacent surface” draws antecedent basis from the limitation “an upper handle-adjacent surface” of claim 18. Claims 5-6, 8, and 20 are rejected upon being dependent upon either claim 4 or 19. Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 1-9 and 16-19 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by JANG (US 20240044192 A1). Regarding claim 1, JANG (US 20240044192 A1) teaches a cooking appliance, comprising: a body (Figure 8 Paragraph 197, inner casing 100 and outer casing 200); a cooking cavity defined by the body (Paragraph 117, cavity S1 is provided in the inner casing 100); a fluid tank (front housing 420, water tank 450, and panel unit 500) removably coupled to the body (Paragraph 114, water tank 450 may be ejected out while the panel unit 500 is opened; Figure 8, rest of water tank including front housing 420 and panel unit 500 can reasonably be disassembled), wherein the fluid tank is movable between an installed position and an extended position relative to the body (Paragraph 114, water tank 450 may be ejected out while the panel unit 500 is opened; Figure 8, rest of water tank including front housing 420 and panel unit 500 can reasonably be disassembled), and wherein the fluid tank comprises a handle (panel unit 500) that is rotatable about an axis between a neutral position and a rotated position (Figure 47 Paragraph 372, panel unit 500 is moved by the opening device 480 between a first opening section and then the panel unit 500 is moved by the user within the second opening section extending from the last end of the first opening section to the second position); and a vapor generator in fluid communication with and that receives a fluid from the fluid tank (Paragraph 102, steam device includes a heater that heats water and a water tank 450 that supplies water to the heater), wherein vapor produced by the vapor generator is provided to the cooking cavity (Paragraph 119, steam flow into the cavity through the opening 120). Regarding claim 2, JANG teaches the cooking appliance of claim 1, wherein: the handle of the fluid tank comprises an exterior surface (Figure 5 Paragraph 259, front surface of the panel unit 500) and an interior surface (Figure 5 Paragraph 429, rear surface 551), and wherein the exterior surface of the handle is substantially coplanar with a front surface of the body (Paragraph 116, panel unit 500 is disposed in parallel to the door 300 in the closed state of the panel unit 500) when the fluid tank is in the installed position (Paragraph 115, panel unit 500 is disposed in front of the water tank 500 when the water tank is in inserted in the oven) and the handle is in the neutral position (Paragraph 116, panel unit 500 is disposed in parallel to the door 300 in the closed state of the panel unit 500). Regarding claim 3, JANG teaches the cooking appliance of claim 2, wherein: the fluid tank comprises a handle-supporting portion (Figure 20 Paragraph 283, surface around pocket P) having an upper portion (Paragraph 302, surface 455a of the second pocket 455; Paragraph 300, water tank 450 includes a second pocket 455 which provides a gripping space for the user) angled away from interior surface of the handle (Figure 20, surface 445a of the second pocket has an angle which is not perpendicular nor parallel to the rear surface of the panel unit 500) such that the interior surface of the handle (rear surface 551 of the panel unit 500) at an upper region of the handle is spaced from the upper portion when the handle is in the neutral position (Figure 31, second pocket 455 is spaced from the interior surface of the rear surface of the panel unit 500) and contacts an adjacent surface of the upper portion of the handle-supporting portion in the rotated position (Paragraph 369, panel unit serves as a type of support when the water tank 450 is removed or inserted; water tank 450 is supported on the rear surface of the panel unit which means that the rear surface 551 of the panel unit is at least capable of contacting at least one surface of the water tank 450, all of which are adjacent to the surface 455a of the second pocket 455). Regarding claim 4, JANG teaches the cooking appliance of claim 3, wherein: an angled orientation of the upper portion of the handle-supporting portion (upper surface 445a of the second pocket 455 where the slip prevention ribs 455a’ are located) extends from an area proximate to the axis to a perimeter wall of the handle-supporting portion (Figure 31, surface 455a of the second pocket extends from the bottom end of the rear surface 551 of the panel unit, which is an area proximate to the axis of rotation of the panel unit as can be seen by Figures 2 and 4, and towards the vertically extending wall of the surface 455a of the second pocket 455). Regarding claim 5, JANG teaches the cooking appliance of claim 4, wherein: the handle-supporting portion (Figure 20 Paragraph 283, pocket P) has a lower portion (surface of first pocket 425) angled away from the interior surface of the handle (Figure 31, surface of the first pocket 425 is disposed at an angle which is neither parallel nor perpendicular to the rear of the panel unit) such that the interior surface of the handle at a lower region of the handle is spaced from the lower portion when the handle is in the neutral position (Figure 31, lower region of the rear surface 551 of the panel unit is spaced from surface of the first pocket 425). Regarding claim 6, JANG teaches the cooking appliance of claim 5, wherein: the upper portion and the lower portion of the handle-supporting portion are asymmetrical with one another along at least one cross-sectional plane of the fluid tank (Figure 31, surface of the first pocket and surface of the second pocket are not symmetrical with one another across any plane of the fluid tank; Figure 31, a portion of the surface of the second pocket can reasonably include a portion of the vertical wall of the second pocket which also is asymmetrical to the surface of the first pocket). Regarding claim 7, JANG teaches the cooking appliance of claim 3, wherein: the interior surface of the handle is provided with an upper protrusion positioned in an upper region thereof (Figure 38 Paragraphs 419-421, cover inclined portion 559 is formed in the cover frame 550 forms a protrusion with the rest of rear surface 551), such that the upper protrusion is in contact with the adjacent surface of the handle-supporting portion in the rotated position (Paragraph 369, panel unit serves as a type of support when the water tank 450 is removed or inserted; water tank 450 is supported on the rear surface of the panel unit which means that the protrusion formed by the rear surface and the cover inclined portion is capable of contacting at least one surface of the water tank 450 under normal operations). Regarding claim 8, JANG teaches the cooking appliance of claim 5, wherein: the interior surface of the handle is provided with a lower protrusion positioned in a lower region thereof (Figure 38 Paragraphs 419-421, cover inclined portion 559 is formed in the cover frame 550 forms a protrusion with the rest of rear surface 551), such that the lower protrusion is in contact with an adjacent surface of the lower portion of the handle-supporting portion in the rotated position (Paragraph 369, panel unit serves as a type of support when the water tank 450 is removed or inserted; water tank 450 is supported on the rear surface of the panel unit which means that the protrusion formed by the rear surface and the cover inclined portion is capable of contacting at least one surface of the water tank 450 under normal operations). Regarding claim 9, JANG (US 20240044192 A1) teaches a cooking appliance, comprising: a body (Figure 8 Paragraph 197, inner casing 100 and outer casing 200); a cooking cavity defined by the body (Paragraph 117, cavity S1 is provided in the inner casing 100); a fluid tank (front housing 420, water tank 450, and panel unit 500) removably coupled to the body (Paragraph 114, water tank 450 may be ejected out while the panel unit 500 is opened; Figure 8, rest of water tank including front housing 420 and panel unit 500 can reasonably be disassembled), wherein the fluid tank is movable between an installed position and an extended position relative to the body (Paragraph 114, water tank 450 may be ejected out while the panel unit 500 is opened; Figure 8, rest of water tank including front housing 420 and panel unit 500 can reasonably be disassembled), and wherein the fluid tank comprises a handle (panel unit 500) that is rotatable about an axis between a neutral position and a rotated position (Figure 47 Paragraph 372, panel unit 500 is moved by the opening device 480 between a first opening section and then the panel unit 500 is moved by the user within the second opening section extending from the last end of the first opening section to the second position) and a handle-supporting portion (drive arm 620 and surfaces of pocket P) having an angled portion angled away from an interior surface of the handle (Paragraph 302, surface 455a of the second pocket 455; Paragraph 300, water tank 450 includes a second pocket 455 which provides a gripping space for the user; Figure 20, surface 445a of the second pocket has an angle which is not perpendicular nor parallel to the rear surface of the panel unit 500) such that the interior surface of the handle (rear surface 551 of the panel unit 500) at a predetermined region of the handle is spaced from the angled portion when the handle is in the neutral position (Figure 31, second pocket 455 is spaced from the interior surface of the rear surface of the panel unit 500) and contacts an adjacent surface of the angled portion of the handle-supporting portion when the handle is in the rotated position (Paragraph 369, panel unit serves as a type of support when the water tank 450 is removed or inserted; water tank 450 is supported on the rear surface of the panel unit which means that the rear surface 551 of the panel unit is at least capable of contacting at least one surface of the water tank 450 all of which are adjacent to the surface 455a of the second pocket 455); and a vapor generator in fluid communication with and that receives a fluid from the fluid tank (Paragraph 102, steam device includes a heater that heats water and a water tank 450 that supplies water to the heater), wherein vapor produced by the vapor generator is provided to the cooking cavity (Paragraph 119, steam flow into the cavity through the opening 120). Regarding claim 16, JANG as modified teaches the cooking appliance of claim 9, wherein: the handle of the fluid tank includes pivot brackets that extend from the interior surface (Figure 53 Paragraphs 473-476, panel unit 500 comprises hinge coupled portion 520 is provided at the rear surface of the main housing which include first hinge coupled portion 521 and second hinge coupled portion 525), each pivot bracket defining a slot therein (Figure 53 Paragraphs 473-480, first hinge coupled portion 521 and second hinge coupled portion 525 serve as coupling portions each comprising a spot for connection block 625 where the hinge modules 600 and panel unit 500 are coupled to each other; Figure 52A Paragraphs 477, block fastener B4 extends from the rear surface of the panel unit 500 such as to pass through the connection block 625 and each cover hinge hole), and wherein each of the slots receive a tab that extends from the handle-supporting portion of the fluid tank (Figure 53 Paragraphs 473-480, each of first hinge coupled portion 521 and second hinge receive a connection block 625). Regarding claim 17, JANG as modified teaches the cooking appliance of claim 9, wherein: the fluid tank is received within a tank housing mounted to the body (Figures 8 and 24 Paragraphs 273-275, tank housing 460 receives the water tank 450; Figure 8 Paragraph 168, upper cover 260 surrounds the upper surface of the front housing 420) and collectively the fluid tank and the tank housing comprise a set of cooperating alignment surfaces that allow insertion of the fluid tank within the tank housing in a single angular orientation relative a front surface of the body (Paragraph 269, guides extend in a direction parallel to removal and insertion directions of the water tank 450 such as to facilitate the water tank being ejected and inserted; Paragraph 275, water tank 450 is configured such that a main surface is mainly supported by the front housing 420 such that stable insertion of the water tank is possible), such that a fill aperture on the fluid tank is oriented on an upper surface of the fluid tank when in the installed position (Paragraph 295, tank cover 452’ can be removed such that the user can fill water into the water storage space 451 through said opening). Regarding claim 18, JANG (US 20240044192 A1) teaches a cooking appliance, comprising: a cooking cavity defined by a body (Paragraph 117, cavity S1 is provided in the inner casing 100); a fluid tank (front housing 420, water tank 450, and panel unit 500) removably coupled to the body (Paragraph 114, water tank 450 may be ejected out while the panel unit 500 is opened; Figure 8, rest of water tank including front housing 420 and panel unit 500 can reasonably be disassembled), wherein the fluid tank is movable between an installed position and an extended position relative to the body (Paragraph 114, water tank 450 may be ejected out while the panel unit 500 is opened; Figure 8, rest of water tank including front housing 420 and panel unit 500 can reasonably be disassembled), and wherein the fluid tank comprises a handle (panel unit 500) that is rotatable about an axis rotatable between a neutral position and a rotated position (Figure 47 Paragraph 372, panel unit 500 is moved by the opening device 480 between a first opening section and then the panel unit 500 is moved by the user within the second opening section extending from the last end of the first opening section to the second position), and wherein the fluid tank comprises an upper handle-adjacent surface (surface of water tank adjacent to surface of the second pocket 455; Paragraph 302, surface 455a of the second pocket 455; Paragraph 300, water tank 450 includes a second pocket 455 which provides a gripping space for the user) and a lower handle-adjacent surface (surface of water tank adjacent to surface of the first pocket 425; Figure 31, surface of the first pocket 425 is disposed at an angle which is neither parallel nor perpendicular to the rear of the panel unit) each sloped away from the handle (Figure 20, surface 445a of the second pocket has an angle which is not perpendicular nor parallel to the rear surface of the panel unit 500; Figure 31, surface of the first pocket 425 is disposed at an angle which is neither parallel nor perpendicular to the rear of the panel unit) such that an upper recess and a lower recess are provided (Figure 20 Paragraph 283, pocket P formed from a first pocket 425 and second pocket 455); and a vapor generator in fluid communication with and that receives a fluid from the fluid tank (Paragraph 102, steam device includes a heater that heats water and a water tank 450 that supplies water to the heater), wherein vapor produced by the vapor generator is provided to the cooking cavity (Paragraph 119, steam flow into the cavity through the opening 120). Regarding claim 19, JANG teaches the cooking appliance of claim 18, wherein: an interior surface of the handle (rear surface 551 of the panel unit 500) at an upper region of the handle is spaced from the upper handle-supporting adjacent surface when the handle is in the neutral position (Figure 31, second pocket 455 is spaced from the interior surface of the rear surface of the panel unit 500) and the upper region of the handle is in contact with the upper handle-supporting adjacent surface in the rotated position (Paragraph 369, panel unit serves as a type of support when the water tank 450 is removed or inserted; water tank 450 is supported on the rear surface of the panel unit which means that the rear surface 551 of the panel unit is at least capable of contact at least one surface of the water tank 450 all of which are adjacent to the surface 455a of the second pocket 455). 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(s) 10-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over JANG (US 20240044192 A1) as applied to claim 9 above, and further in view of Novin (US 20120174339 A1) . Regarding claim 10, JANG teaches the cooking appliance of claim 9. JANG fails to explicitly teach: an engagement member disposed on the handle-supporting portion a biasing member, wherein the biasing member biases the engagement member to an extended position such that the engagement member maintains physical contact with the handle Novin (US 20120174339 A1) teaches a detent hinge, wherein: an engagement member disposed on the handle-supporting portion (Figures 14-15 Paragraphs 48-29, needle rollers are disposed as part of the detent mechanism connecting the first hinge part 240 with the second hinge part 260); and a biasing member, wherein the biasing member biases the engagement member to an extended position such that the engagement member maintains physical contact with the handle (Paragraph 48, one or more springs which bias one or more needle rollers into engagement with the outer surface of the hinge shaft). It would have thus been obvious to someone of ordinary skill in the art before the filing date of the claimed invention to have modified JANG with Novin and used a detent mechanism in the rotation of the panel unit. This would have been done to provide a compact method of preventing inadvertent movements of the cover portion (Novin Paragraphs 6 and 15). Regarding claim 11, JANG teaches the cooking appliance of claim 10. Novin further teaches: the interior surface of the handle includes a projection extending from the interior surface and toward the engagement member (Figures 12A-12B Paragraph 48, hinge shaft 210 includes a portion extending from the bore 248 of an adaptor 240), and wherein a cavity within the handle-supporting portion includes a channel that receives the biasing member and the engagement member (Figure 16 Paragraph 44, second hinge part 260 has a housing or base 260 in which the spring and needle rollers are located). It would have been obvious for the same motivation as claim 10. Regarding claim 12, JANG teaches the cooking appliance of claim 11. Novin further teaches: the projection of the handle defines a notch within which the engagement member is received (Figure 15 Paragraph 51, needle rollers 284 engage the detent grooves 286 by means of the spring). It would have been obvious for the same motivation as claim 10. Regarding claim 13, JANG as modified teaches the cooking appliance of claim 12. Novin further teaches: a pair of notches are defined on the projection and the pair of notches are separated by a step (Figure 15 Paragraph 51, detent grooves 286 are separated from one another by a step), and wherein a first one of the pair of notches is associated with the neutral position of the handle and a second one of the pair of notches is associated with the rotated position of the handle (Figures 14-16 Paragraph 38, hinge assembly to allow rotational movement relative to the second member between predetermined positions including an open position, partially open position, and a closed position), whereby when the handle is in the neutral position, the biasing member provides a biasing force in an outward direction from the channel such that the engagement member is held in physical contact with the first one of the pair of notches (Figure 15 Paragraphs 53-54, detent springs provide a force on the rollers such as to ensure that the rollers 284 engage a second set of detent grooves 286 when the detent grooves 286 register with the needle rollers 284; Figure 54, Paragraph 62, reverse the positions of the channel 297 and grooves 286 such as to provide a force in an outward direction) and when the handle is in the rotated position, the biasing member provides a force in an outward direction from the channel such that the engagement member is in physical contact with the second one of the pair of notches (Figure 16 Paragraphs 53-54, detent springs provide a force on the rollers such as to ensure that the rollers 284 engage a first set of detent grooves 286 when the detent grooves 286 register with the needle rollers 284; Figure 54, Paragraph 62, reverse the positions of the channel 297 and grooves 286 such as to provide a force in an outward direction). It would have been obvious for the same motivation as claim 10. Regarding claim 14, JANG as modified teaches the cooking appliance of claim 13, wherein: when an inward force is applied to the predetermined region of the handle while the handle is in the neutral position, the handle is transitioned towards the rotated position (Paragraphs 352-358, cam or electromagnet is used to provide a force for pushing the panel unit; Paragraph 361, panel unit 500 is moved from a first opening section to the second position) Novin further teaches: the handle is transitioned toward the rotated position and the engagement member is transitioned from the first one to the second one of the pair of notches (Figures 14-15 Paragraph 61, detent positions are approximately 20 degrees wherein said adaptor 240 is rotated from a first set of notches to a second set of notches as the handle moves from the vertical position to a second position; Paragraph 11, needle roller roll on the surface of the hinge shaft as the hinge shaft is rotated relative to the spring), such that the handle is retained in the rotated position until a second external force is applied to the handle (Paragraph 46, increased resistance to relative rotation occurs at the detent positions of the hinge part; Paragraph 47, threshold torque for moving the hinge member is high enough to prevent most inadvertent movements of the member). It would have been obvious for the same motivation as claim 13. Regarding claim 15, JANG as modified teaches the cooking appliance of claim 14, wherein: the axis is disposed parallel to a horizontal plane (Figures 2 and 4, panel unit 500 rotates relative to the horizontal plane), and the predetermined region of the handle is defined as a region above the axis relative the horizontal plane (Figures 2 and 4, horizontal axis of rotation is located at the bottom of the panel unit 500). Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over JANG (US 20240044192 A1) as applied to claim 19 above, and further in view of Harris (US 20230018909 A1), LEE (US 20200245804 A1), Yeung (US 20060169693 A1), and LEWIS (US 4902182 A). Regarding claim 20, JANG teaches the cooking appliance of claim 19, wherein the fluid tank further comprises: a fill aperture disposed on an upper surface of the fluid tank through which the fluid may be added to the fluid tank when the fluid tank is in the extended position (Paragraph 295, separate tank lid 452’ can be removed such that the user can fill water into the water storage space 451 through said opening when the water tank is removed from the cooking appliance); an opening proximate the fill aperture (Paragraph 295, tank cover 452 can be a separate object from the water tank which would result in an opening in proximate to the separate tank lid 452’); and JANG fails to explicitly teach: a fill cover constructed of a pliable material and configured to retain the fluid within the fluid tank, wherein a snap tab on a first end of the fill cover is fittingly received within the opening to secure the fill cover to the upper surface of the of the fluid tank proximate the fill aperture, a rib provided on an inner surface of the fill cover resiliently engages an outer perimeter of the fill aperture to form a seal therewith when engaged, and a grip on a second opposite end of the fill cover is provided by which a user may manipulate the fill cover into and out of engagement with the fill aperture. However, Harris (US 20230018909 A1) teaches a container lid for covering a hatch opening for inserting liquid sealing liquid within a container (Figures 16c-16D) comprising a front edge tab used to allow the user to manipulate and grip the cover (Harris Figure 8A). It would have thus been obvious to someone of ordinary skill in the art before the filing date of the claimed invention to have modified JANG with Harris and included grip for the user in the form of a front edge tab. This would have been done to allow the user to easily manipulate the lid of the container (Harris Paragraph 223). The Office further notes that using a pivotable lid to seal a water tank is known in the art as evidenced by Ball (US 20250024979 A1). LEE (US 20200245804 A1) teaches a heating apparatus and cooking apparatus which comprises a container configured to contain water and which the lid comprises a third sealing member 147 as part of the lid and made of silicone such as to protrude from the lid and come into close contact with the upper end bending part 121 of the container such as to form a seal between the lid and the container (Lee Figure 7 Paragraphs 161-162). It would have thus been obvious to someone of ordinary skill in the art before the filing date of the claimed invention to have modified JANG with LEE and included a sealing rib provided on the interior surface of the cover. This would have been done to form an airtight structure between the container and cover (LEE Paragraphs 163-166). Yeung (US 20060169693 A1) teaches that silicone lids are used for sealing open containers containing liquids (Yeung Paragraphs 26 and 29). It would have thus been obvious to someone of ordinary skill in the art before the filing date of the claimed invention to have modified JANG with Yeung and have the lid be made of pliable silicone. This would have been done to provide a lid which is pliable and able to conform to the shape of an open-ended container (Yeung Paragraph 12). LEWIS (US 4902182 A) teaches a push-in fastener which is used to join one component to another. It would have thus been obvious to someone of ordinary skill in the art before the filing date of the claimed invention to have modified JANG with LEWIS and used a push-in fastener as a snap tab to join the lid to the water tank by inserting through a performed opening in the water tank. This would have been done to provide a removable lid secured by a snap tab to allow access to the opening while also providing a low resistance to installation and a high resistance to removal (Column 2 Lines 15-18) to prevent the lid from accidentally opening. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to FRANKLIN JEFFERSON WANG whose telephone number is (571)272-7782. The examiner can normally be reached M-F 10AM-6PM (E.S.T). 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, Ibrahime Abraham can be reached at (571) 270-5569. 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. /F.J.W./Examiner, Art Unit 3761 /IBRAHIME A ABRAHAM/Supervisory Patent Examiner, Art Unit 3761
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Prosecution Timeline

Apr 05, 2023
Application Filed
Feb 20, 2026
Non-Final Rejection — §102, §103, §112 (current)

Precedent Cases

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
51%
Grant Probability
99%
With Interview (+51.3%)
3y 8m
Median Time to Grant
Low
PTA Risk
Based on 116 resolved cases by this examiner. Grant probability derived from career allow rate.

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