Prosecution Insights
Last updated: April 19, 2026
Application No. 18/183,513

METHODS OF FORMING ARTICLES BY APPLYING ELECTRIC CURRENT AND PRESSURE TO MATERIALS, AND RELATED ARTICLES

Final Rejection §103
Filed
Mar 14, 2023
Examiner
AFZALI, SARANG
Art Unit
3726
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
BATTELLE MEMORIAL INSTITUTE
OA Round
4 (Final)
73%
Grant Probability
Favorable
5-6
OA Rounds
3y 1m
To Grant
99%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allow Rate
670 granted / 918 resolved
+3.0% vs TC avg
Strong +46% interview lift
Without
With
+45.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
33 currently pending
Career history
951
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
40.7%
+0.7% vs TC avg
§102
25.5%
-14.5% vs TC avg
§112
28.6%
-11.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 918 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 . Response to Amendment The Applicant’s amendment filed 12/19/2025 has been fully considered and made of record. As such, the rejections of claims 1-11 and 21-24 under 112(a) and (b), as outlined in the office action mailed 09/09/2025, have been withdrawn. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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) 1-5 and 21-24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cologna et al. (US 20160158840A1, hereinafter “Cologna”) in view of Mizuno et al. (US 20130255619A1, hereinafter “Mizuno”) and as evident by Ozbaysal et al. (US 11,697,865, hereinafter “Ozbaysal”) and Tarshis et al. (US 3,696,500, hereinafter “Tarshis”). As applied to claims 1-3, 5 and 21-24, Cologna teaches a method of fabricating an article (gas turbine engine blade) wherein a first component (reads on “a first structure comprising a first material”) made of electrically conductive nickel-based superalloy sheet material (button made of CM 247 having the claimed composition of nickel alloy and manganese, chromium, cobalt, tungsten, molybdenum, carbon, iron, silicon as shown in Table IV of Tarshis) and a second component (reads on “a second structure comprising a second material) made of electrically conductive nickel-based superalloy sheet material (button made of Rene 80 having the claimed composition of nickel alloy and chromium, cobalt, molybdenum, aluminum, carbon, tungsten as shown in Table II of Ozbaysal and which has a composition different than the first material composition of CM 247) are directly contacted (at adjoining contact surfaces), laminated and subjected to electric current and pressure by a direct current sintering apparatus (spark plasma sintering apparatus, paragraphs [0007], [0013], Fig. 1). Although, Cologna does not explicitly teach a die of the direct current sintering apparatus, does explicitly teach the use of a spark plasma sintering device which applies pressure and electric current to the adjoining sheets of materials which would inherently require that some form of die or molding is used to hold the sheet of materials during the sintering and diffusion bonding step. In addition, Cologna does not explicitly teach the first material comprises a plurality of channels, at least one channel extending into the first material from a first side of the first material and the second material directly contacts the first side of the first material in regions between a pair of the channels. Mizuno teaches a method of diffusion bonding a pair of metallic members made of conductive material and bonding surfaces including a plurality of grooves (channels) on at least one of the members wherein the members are put in direct contact with one another at their bonding surfaces, placed into a die (60/62/64) and subjected to electric heating and pressure to form the finished article (first embodiment, paragraphs [0028], [0042], Fig. 1). Therefore, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to employ a die into the spark plasma sintering apparatus of Cologna, as taught by Mizuno, as an effective means of holding the laminated stack together to be subjected to the electric current and pressure resulting in a finished article having enhanced diffusion bond interface. In addition, it would been obvious to one of ordinary skill in the art at the time the invention was filed to incorporate a plurality of grooves/channels into the bonding surface of first material of Cologna, as taught by Mizuno, as a matter of combining prior art elements according to known methods to yield predictable results (see MPEP 2143, KASR, Rationale “A’). The resulting method would be reasonably expected to perform in the manner taught by Cologna without modification of the principles of operation of Cologna, because Cologna does not dissuade one of ordinary skill in the art to have any particular surface finish of the bonding surfaces prior to the bonding operation. The combined process allows the end article to have any desired interior channels without the need for any additional steps of forming channels subsequent to the forming of the article which results in significant manufacturing cost savings. As applied to claim 4, the combination of Cologna and Mizuno as evident by Ozbaysal and Tarshis teaches the invention cited including Cologna further teaches that the material composition of the first sheet of nickel-based alloy and the material composition of the second nickel-based alloy can be either the same or different (paragraph [0005]). Claim(s) 6-11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cologna et al. (US 20160158840A1, hereinafter “Cologna”) in view of Mizuno et al. (US 20130255619A1, hereinafter “Mizuno”) and as evident by Ozbaysal et al. (US 11,697,865, hereinafter “Ozbaysal”) and Tarshis et al. (US 3,696,500, hereinafter “Tarshis”) as applied to claim 1 above, and further in view of Suzuki et al. (US 9,096,471, hereinafter “Suzuki”). As applied to claims 6-7, 9 and 10, the combination of Cologna and Mizuno as evident by Ozbaysal and Tarshis teaches the invention cited but the combination does not explicitly teach the claimed ranges of from 1,240 amps to 50,000 amps (as in claim 6), from 10,000 amps to 50,000 amps (as in claim 7) and applying the electric current and pressure to the first and second materials simultaneously (as in claim 10). Suzuki teaches a method of bonding layered materials by applying an electric current across the first and second materials at from 1,000 to 30,000 amps (which overlaps the range of 1,240 to 50,000 amps in claim 6, the range of 10,000 to 50,000 amps in claim 7). Suzuki further teaches applying the pressure to the first and second materials at 10 to 100 MPa (which overlaps the range of 20 to 50 MPa as in claim 9, see Suzuki, col. 13, lines 35-44). Suzuki teaches that the pressure and electric current is applied simultaneously to the first and second materials (col. 13, lines 12-19 “pressure is applied while pulse current is applied” which reads on the “simultaneously” in claim 10). Therefore, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to employ into the method of Cologna as modified by Mizuno and evident by Ozbaysal and Tarshis a simultaneous application of electric current and pressure having values in the claimed ranges, as taught by Suzuki, as an effective means of diffusion bonding the first and second materials to one another based on specific design requirement which would result in an enhanced diffusion bonding interface of the materials of the article that would withstand the high-temperature and high-corrosive operating environment. As applied to claim 8, Cologna as modified by Mizuno and evident by Ozbaysal and Tarshis and further modified by Suzuki teaches the claimed electric current ranges and Suzuki teaches an upper range of 30,000 amps used as electric current but the combination does not explicitly teach the range of 35,000 to 50,000 amps. However, it is noted that the value of the electric current that is applied during the spark plasma sintering process in diffusion bonding layers of materials to one another is a known result effective variable because it is well known in the art of layered material manufacturing that if the electric current value is too low then not enough heat is generated to effect bonding between the stacked materials and if the electric current is too high then excess heat is generated which could overheat and melt the materials in the stack which would be detrimental to the bonding of the materials. As such, it would have been obvious to one of ordinary skill in the art at the time of invention was filed to have selected the claimed range from 35,000 amps to 50,000 amps for the electric current value depending on the type of materials being bonded together. As applied to claim 11, the combination of Cologna as modified by Mizuno and evident by Ozbaysal and Tarshis and further modified by Suzuki teaches the invention cited including applying the electric current and the pressure simultaneously but does not explicitly teach that the step of applying electric current to the first and second materials is done prior to applying the pressure to the first and second materials. However, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to employ into the method of Cologna/Mizuno/Suzuki and as evident by Ozbaysal and Tarshis the step of applying the electric current prior to applying the pressure as a matter of obvious to try by choosing from a finite number of identified, predictable solutions (either before, after or simultaneously), with a reasonable expectation of success (see MPEP 2143, KSR, Rationale “E”). The resultant method would still provide adequate pressure and heat to the stacked assembly of Cologna/Mizuno/Suzuki and as evident by Ozbaysal and Tarshis that would result in an enhanced diffusion bonding of the first and second materials. Response to Arguments Applicant's arguments filed 12/09/2025 have been fully considered but they are not persuasive. Applicant mainly argues that the combination of Cologna in view of Mizuno and as evident by Ozbaysal and Tarshis does not teach the invention of claim 1 as amended. Applicant main argument is that combining Cologna with Mizuno, as suggested by the Office, would change the principle of operation of Cologna and thus render the method of Cologna unsatisfactory for its intended purpose. In order to support this assertion, Applicant further argues that the primary art of Cologna uses spark plasma sintering to join the two components (which results in diffusion bonding of the two materials at the joint surface) while the secondary art of Mizuno teaches bonding by carrying out resistance heating while sliding the members to be bonded (which results in liquid phase formed at the interface surface) The examiner respectfully disagrees with such arguments. First, in response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., Spark Plasma Sintering) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). Second, in response to applicant's argument that it would have not been obvious to combine Cologna and Mizuno, it is noted that the test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference; nor is it that the claimed invention must be expressly suggested in any one or all of the references. Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981). The reliance on Mizuno is to teach that when forming an article by using electric current and pressure to combine two structures comprising first and second materials, it would have been obvious to use a forming die that could be utilized to place the two materials of the two structures into contact with one another to effect the formation of the end article into a single unit. In addition, having surface features such as channels and grooves at the joint surface prior to the forming the single unit would have also been obvious in order to eliminate any additional post formation process to add the desired channels. As for Applicant’s argument regarding rejoining method claims 12-16, it is noted that claims 12-16 were restricted from method claims 1-11 and product claims 17-20 and withdrawn in the Office Action mailed 09/18/2024. As such, the withdrawal of claims 12-16 is still maintained. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Hugot et al. (US 9,221,101) teaches spark plasma sintering technology having a die and mold used for receiving a part (abstract). Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to SARANG AFZALI whose telephone number is (571)272-8412. The examiner can normally be reached M-F 7 am - 4 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, Thomas Hong can be reached at 571-272-0993. 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. /SARANG AFZALI/Primary Examiner, Art Unit 3726 02/16/2026
Read full office action

Prosecution Timeline

Mar 14, 2023
Application Filed
Sep 11, 2024
Examiner Interview (Telephonic)
Sep 17, 2024
Non-Final Rejection — §103
Feb 18, 2025
Response Filed
Apr 22, 2025
Final Rejection — §103
Jul 25, 2025
Response after Non-Final Action
Aug 15, 2025
Request for Continued Examination
Aug 19, 2025
Response after Non-Final Action
Sep 05, 2025
Non-Final Rejection — §103
Dec 09, 2025
Response Filed
Feb 16, 2026
Final Rejection — §103
Apr 01, 2026
Interview Requested
Apr 07, 2026
Examiner Interview Summary
Apr 07, 2026
Applicant Interview (Telephonic)

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

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Prosecution Projections

5-6
Expected OA Rounds
73%
Grant Probability
99%
With Interview (+45.5%)
3y 1m
Median Time to Grant
High
PTA Risk
Based on 918 resolved cases by this examiner. Grant probability derived from career allow rate.

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