Prosecution Insights
Last updated: April 19, 2026
Application No. 18/132,210

Electronic Devices with Multiple Energy Storage Devices, Thermal Mitigation Circuits, and Corresponding Methods

Non-Final OA §103
Filed
Apr 07, 2023
Examiner
HENZE, DAVID V
Art Unit
2859
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Motorola Mobility LLC
OA Round
1 (Non-Final)
70%
Grant Probability
Favorable
1-2
OA Rounds
2y 10m
To Grant
94%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
492 granted / 699 resolved
+2.4% vs TC avg
Strong +24% interview lift
Without
With
+23.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
49 currently pending
Career history
748
Total Applications
across all art units

Statute-Specific Performance

§101
2.0%
-38.0% vs TC avg
§103
49.8%
+9.8% vs TC avg
§102
21.8%
-18.2% vs TC avg
§112
19.1%
-20.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 699 resolved cases

Office Action

§103
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 Rejections - 35 USC § 103 This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. 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 , 11, 14-15 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. US PGPUB 2020/0036198, in view of Sahu et al. US PGPUB 2018/0224871 . Regarding claim s 1 and 15 , Kim discloses a deformable electronic device [par. 38; flexible electronic device] , comprising: a flexible display supported by a deformable housing comprising a plurality of energy storage devices [figs. 1-2; pars. 12-13, 40-41, 50 & 72-73; flexible device including flexible display 100 comprising a plurality of batteries (pars. 12-13 & 50)] ; one or more processors operable with the flexible display [figs. 1-2; par. 50] ; one or more sensors operable with the one or more processors [fig. 4; par. 93; temperature sensor and voltage and current are sensed as well] ; and a thermal mitigation circuit operable with each energy storage device, the thermal mitigation circuit selecting a subset of the plurality of energy storage devices to power the one or more processors [fig. 4; pars. 76-80; the charging current is controlled based on the temperature by the PMIC , which is controlled by processor 470 (fig. 4) , thus the processor is a thermal mitigation circuit; the processor also chooses a subset of the batteries to power the load (par. 77 ; fig. 8, pars. 137-138 ) ] . Kim discloses the deformable device [see above] and selecting a subset to control power [see above] but does not explicitly disclose the power is controlled as a function of a support condition of the electronic device. However, Sahu discloses a power storage system for a wearable electronic device wherein the power is chosen as a function of a support condition of the electronic device [pars. 26, 28, 30 & 36; power is throttled based on whether or not the device is supported (worn)]. It would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify Kim to further include wherein the power is chosen as a function of a support condition of the electronic device for the purpose of making sure the temperature is acceptable to a user , as taught by Sahu (par . 30 ). Regarding claim 15, the method steps disclosed therein would have been are deemed as being obvious to one of ordinary skill based on the teachings of the prior art reference(s) applied above, since the prior art of record herein is construed as teaching or suggesting all of the elements recited in the method claim, as pointed out in the above rejection of claim 1. The claim is accordingly rejected. Regarding claim 11, Kim discloses the thermal mitigation circuit further selecting the subset of the plurality of energy storage devices to power the one or more processors as a function of a geometric configuration of the deformable electronic device [par. 95 & 137-138; based on the geometric state (folded) the power is controlled (“low power”), and only a single battery may be connected to supply power (fig. 8)] . Regarding claim 14, Kim discloses wherein the plurality of energy storage devices is situated on a rear side of the deformable electronic device between an electronics component enclosure and an end cap, with each energy storage device of the plurality of energy storage devices spanning a width of the deformable electronic d evice [fig. 3, batteries 410 and 420 span a width (the long dimension) of the device between electronics enclosure 610 and end cap 580/590; pars. 72-73]. Regarding claim 18, Kim discloses a deformable electronic device, comprising: a flexible display spanning a first major surface of the deformable electronic device [figs. 1-2; pars. 12-13, 40-41, 50 & 72-73; flexible device including flexible display 100 comprising a plurality of batteries (pars. 12-13 & 50)] ; a plurality of energy storage devices situated along a second major surface of the deformable electronic device [fig. 3, batteries 410 and 420 span a width (the long dimension) of the device between electronics enclosure 610 and end cap 580/590; pars. 72-73] ; one or more processors [figs. 1-2; par. 50] ; one or more sensors [fig. 4; par. 93; temperature sensor and voltage and current are sensed as well] ; and a thermal mitigation circuit ; the thermal mitigation circuit selecting which energy storage devices of the plurality of energy storage devices will power the one or more processors as a function of a geometric configuration of the deformable electronic device [fig. 4; pars. 76-80; the charging current is controlled based on the temperature by the PMIC, which is controlled by processor 470 (fig. 4), thus the processor is a thermal mitigation circuit; the processor also chooses a subset of the batteries to power the load (par. 77; fig. 8, pars. 137-138); fig. 3, batteries 410 and 420 span a width (the long dimension) of the device between electronics enclosure 610 and end cap 580/590; pars. 72-73]. Kim discloses the deformable device [see above] and selecting a subset to control power [see above] but does not explicitly disclose the power is controlled as a function of a support condition of the electronic device. However, Sahu discloses a power storage system for a wearable electronic device wherein the power is chosen as a function of a support condition of the electronic device [pars. 26, 28, 30 & 36; power is throttled based on whether or not the device is supported (worn)]. It would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify Kim to further include wherein the power is chosen as a function of a support condition of the electronic device for the purpose of making sure the temperature is acceptable to a user , as taught by Sahu (par . 30 ). Allowable Subject Matter Claim s 2-10, 12-13, 16-17 and 19-20 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. With respect to claim 2 , the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ wherein when the support condition comprises the deformable electronic device being held at a first end of the deformable housing the subset of the plurality of energy storage devices are situated closer to a second end of the deformable housing than the first end of the deformable housing ” in combination with all the other elements recited in claim 2 . Claims 3-9 , being dependent on claim 2 , would be allowable for the same reasons as claim 2 . With respect to claim 10, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ wherein when the support condition comprises the deformable electronic device being held at a first end of the deformable housing while the deformable electronic device is adjacent to an ear, the subset of the plurality of energy storage devices are situated closer to the first end of the deformable housing than a second end of the deformable housing ” in combination with all the other elements recited in claim 10 . With respect to claim 12, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ when the geometric configuration comprises the deformable electronic device defining a loop the thermal mitigation circuit selects all energy storage device to power the one or more processors ” in combination with all the other e lements recited in claim 12 . With respect to claim 13, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ the thermal mitigation circuit further selecting another subset of the plurality of energy storage devices to be charged as a function of the support condition of the deformable electronic device ” in combination with all the other elements recited in claim 13 . With respect to claim 16, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ the support condition comprising the deformable electronic device being held at a first end, wherein the subset of the plurality of energy storage devices are separated from the first end by at least one energy storage device excluded from the subset of the plurality of energy storage devices ” in combination with all the other elements recited in claim 16 . With respect to claim 17, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ the deformable electronic device being held at a central portion, wherein the subset of the plurality of energy storage devices comprises a first set of energy storage devices and a second set of energy storage devices separated from the first set of energy storage devices by at least one energy storage device excluded from the subset of the plurality of energy storage devices ” in combination with all the other elements recited in claim 17 . With respect to claim 19, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ when the support condition comprises a wrist-worn support condition, the thermal mitigation circuit selects the all energy storage devices of the plurality of energy storage devices to power the one or more processors ” in combination with all the other elements recited in claim 19 . With respect to claim 20, the following is an examiner' s statement of reasons for the indication of allowable subject matter : the prior art fails to further teach or suggest “ when the geometric configuration comprises the deformable electronic device being bent to define a loop, the thermal mitigation circuit selects a subset of the plurality of energy storage devices to power the one or more processors ” in combination with all the other elements recited in claim 20 . Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Huang et al. et al. US PGPUB 2016/0254664 discloses a wearable electronic device wherein a subset of batteries is chosen to control the power . Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT DAVID V HENZE whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)272-3317 . The examiner can normally be reached FILLIN "Work Schedule?" \* MERGEFORMAT M to F, 9am to 7pm . 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, FILLIN "SPE Name?" \* MERGEFORMAT Taelor Kim can be reached at FILLIN "SPE Phone?" \* MERGEFORMAT 571-270-7166 . 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. /DAVID V HENZE/ Primary Examiner, Art Unit 2859
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Prosecution Timeline

Apr 07, 2023
Application Filed
Mar 21, 2026
Non-Final Rejection — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
70%
Grant Probability
94%
With Interview (+23.8%)
2y 10m
Median Time to Grant
Low
PTA Risk
Based on 699 resolved cases by this examiner. Grant probability derived from career allow rate.

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