Prosecution Insights
Last updated: April 18, 2026
Application No. 18/202,229

ELECTRONIC DEVICES WITH A LOOPED THERMAL MODULE HAVING A UNIDIRECTIONAL VALVE

Final Rejection §102§103
Filed
May 25, 2023
Examiner
JONES, GORDON A
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Apple Inc.
OA Round
2 (Final)
60%
Grant Probability
Moderate
3-4
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allow Rate
331 granted / 548 resolved
-9.6% vs TC avg
Strong +39% interview lift
Without
With
+39.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
65 currently pending
Career history
613
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
50.3%
+10.3% vs TC avg
§102
22.0%
-18.0% vs TC avg
§112
27.1%
-12.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 548 resolved cases

Office Action

§102 §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 . Claim Rejections - 35 USC § 102 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 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. Claim(s) 1-3, 5-7 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by TSENG et al. US 2020/0003498 Al. Re claim 1, TSENG et al. teach a thermal module (50), comprising: an enclosure (50 casing fig 9) that stores components, the components comprising: a first section (fig 9, V) configured to convert a refrigerant to a first state, a second section (LC) configured to convert the refrigerant to a second state different from the first state, and a plurality of flow barriers (512, annotated fig, and certain 111, see the rejection of claim 6 ) configured to: allow the refrigerant to circulate in a first direction through the plurality of flow barriers from the first section to the second section, and impede the refrigerant from circulating in a second direction through the plurality of flow barriers from the second section to the first section,. the second direction opposite the first direction (annotated fig, paras 49-51). PNG media_image1.png 524 587 media_image1.png Greyscale PNG media_image2.png 461 819 media_image2.png Greyscale Re claim 2, TSENG et al. teach wherein: the first section is configured to convert the refrigerant to the first state corresponding to a gas state, and the second section is configured to convert the refrigerant from the second state corresponding to a liquid state (paras 49-51). Re claim 3, TSENG et al. teach wherein: the enclosure comprises a first part and a second part coupled to the first part, and the plurality of flow barriers extend from the first part (top and bottom of casing, and noting any three dimensional structure “extend from” to take space and volume). Re claim 5, TSENG et al. teach wherein the plurality of flow barriers comprises a flow barrier, the flow barrier comprising: a leading edge that faces the first section; and trailing edges, wherein the trailing edges face the second section (noting base of L and long side of L shape making two structures per each flow barrier, and each section faces all interior portions of evaporator since the term “face” is broad). Re claim 6, TSENG et al. teach wherein the plurality of flow barriers comprises: a first column of flow barriers, and a second column of flow barriers staggered with respect to the first column of flow barriers (annotated fig, noting certain portions alternate, fig 9 ). PNG media_image3.png 869 695 media_image3.png Greyscale Re claim 7, TSENG et al. teach further comprising an intermediate section (GC) between the first section and the second section, the intermediate section comprising a plurality of channels (middle layer and channels in between 341, 311, and channel provided in wick 17) configured to transport the refrigerant from the first section to the second section. Claim(s) 9-12, 16 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by CHENG US 2019/0226770 Al. Re claim 9, CHENG teach a thermal module, comprising: an enclosure comprising: a first housing part (10) comprising a first opening (11), and a second housing part (20) coupled with the first housing part, the second housing part comprising a second opening (24), wherein the first housing part and the second housing part define a void (fig 4 holes making voids) comprising an open portion unoccupied based on the first opening and the second opening; an evaporator section; a condensation section, wherein each of the evaporator section and the condensation section is configured to change a state of a refrigerant (para 7 noting vapor chambers have evaporator and condensing sections); and flow barriers (30, 52) positioned between the evaporator section and the condensation section, the flow barriers configured to cause the refrigerant to circulate around the void. Re claim 10, CHENG teach further comprising a plurality of channels (channels in between 30, 52, and micro channels provided in wick 42) configured to direct the refrigerant from the evaporator section to the condensation section. Re claim 11, CHENG teach wherein the flow barriers extend from a surface of the first housing part (figs). Re claim 12, CHENG teach wherein the flow barriers contact the second housing part (figs). Re claim 16, CHENG teach wherein the evaporator section, the condensation section, and the flow barriers are located between the first housing part and the second housing part (figs). 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. 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) 4 is/are rejected under 35 U.S.C. 103 as being unpatentable over TSENG et al. in view of CHOI US 20160021784 A1. Re claim 4, TSENG et al. fail to explicitly teach includes a herringbone shape. CHOI teach wherein the plurality of flow barriers comprises a flow barrier that includes a herringbone shape (para 6) to provide a known fin shape to alter working medium flow. It would have been obvious to one of ordinary skill in the art at the time the invention was made to include includes a herringbone shape as taught by CHOI in the TSENG et al. invention in order to advantageously allow for provide improved cooling performance . Additionally, it would have been an obvious matter of design choice to provide the plurality of flow barriers comprises a flow barrier that includes a herringbone shape(given the teachings of Choi, see above), since such a modification would have involved a mere change in the shape of the component. A change in shape is generally recognized as being within the level of ordinary skill in the art for design choice. See MPEP 2144.04, section IV, part B. Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over CHENG US 2019/0226770 Al in view of CHOI US 20160021784 A1. Re claim 14, CHENG fail to explicitly teach includes a herringbone shape. CHOI teach wherein one or more flow barriers of the flow barriers comprises a herringbone shape (para 6) to provide a known fin shape to alter working medium flow. It would have been obvious to one of ordinary skill in the art at the time the invention was made to include includes a herringbone shape as taught by CHOI in the CHENG invention in order to advantageously allow for provide improved cooling performance . Additionally, it would have been an obvious matter of design choice to provide the plurality of flow barriers comprises a flow barrier that includes a herringbone shape (given the teachings of Choi, see above), since such a modification would have involved a mere change in the shape of the component. A change in shape is generally recognized as being within the level of ordinary skill in the art for design choice. See MPEP 2144.04, section IV, part B. Claim(s) 17-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over TSENG et al. in view of ROSALES US 20190257589 A1. Re claim 17, TSENG et al. teach the thermal module comprising: an enclosure ( 50 casing fig 9) that stores components, the components comprising: a first section (fig 9, V) configured to convert a refrigerant to a first state, a second section (LC) configured to convert the refrigerant to a second state different from the first state, and a plurality of flow barriers comprising a first column of flow barriers, and a second column of flow barriers staggered (noting certain portions alternate, fig 9) with respect to the first column of flow barriers, wherein the plurality of flow barriers is configured to: allow the refrigerant to circulate from the first section to the second section through i) the first column of flow barriers and ii) the second column of flow barriers, and impede the refrigerant based on i) the first column of flow barriers and ii)the second column of flow barriers from the second section to the first section (figs, see the rejection of claim 1, paras 5-15). TSENG et al. fail to explicitly teach an electronic device. ROSALES teach an electronic device, comprising: a heat-generating component and a thermal module thermally coupled to the heat-generating component (para 9) to employ heat removal from an electronic device. It would have been obvious to one of ordinary skill in the art at the time the invention was made to include an electronic device as taught by ROSALES in the TSENG et al. invention in order to advantageously allow for operation and prevention of overheating. PNG media_image3.png 869 695 media_image3.png Greyscale Re claim 18, TSENG et al. teach wherein the plurality of flow barriers extend from a surface of the enclosure (fig 9). Re claim 19, TSENG et al. teach wherein: the first section comprises an evaporator section, and the second section comprises a condensation section (paras 49-51). Re claim 20, TSENG et al. teach further comprising an intermediate section (GC) between the evaporator section and the condensation section, wherein the plurality of flow barriers is configured to: direct the refrigerant from the evaporator section to the condensation section via the intermediate section, and restrict the refrigerant from directly flowing from the evaporator section to the condensation section (paras 49-51). Claim(s) 8, 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over TSENG et al. in view of CHENG US 20190226770 A1 or vice a versa. Re claim 8, TSENG et al. fail to explicitly teach voids. CHENG teach wherein the enclosure comprises: a first part comprising (10) a first opening (11); a second part (20) comprising a second opening (24); and a void surrounded by the first part and the second part (fig 4 holes making voids), the void defined by the first opening, wherein the plurality of flow barriers is further configured to cause the refrigerant to circulate around the void from the first section to the second section (in the instant combination the refrigerant will circulate around walls made by hole walls and voids) to seal two plates It would have been obvious to one of ordinary skill in the art at the time the invention was made to include voids as taught by CHENG in the TSENG et al. invention in order to advantageously allow for thinner plates used in vapor chambers Re claim 15, CHENG fail to explicitly teach a standoff. TSENG et al. teach further comprising a standoff (annotated fig) extending from the second housing part and engaging the first housing part to provide a vapor chamber with working fluid. It would have been obvious to one of ordinary skill in the art at the time the invention was made to include a standoff as taught by TSENG et al. in the CHENG invention in order to advantageously allow for enhanced heat exchange flow and a layered chamber. PNG media_image4.png 767 857 media_image4.png Greyscale Claim(s) 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over CHENG in view of TSENG et al. and Cheng ‘148 US 10980148 B2. Re claim 13, CHENG, as modified, fail to explicitly teach flow barriers details. Cheng ‘148 teach wherein the flow barriers do not contact the second housing part (53) to provide small posts on the bottom plate. It would have been obvious to one of ordinary skill in the art at the time the invention was made to include flow barriers details as taught by Cheng ‘148 in the CHENG, as modified, invention in order to advantageously allow for enhanced heat exchange flow and a layered chamber. Response to Arguments Applicant's arguments filed 2/09/2026 have been fully considered but they are not persuasive. The applicant argues that the previously cited art does not teach the limitations of claim 1 because refrigerant cannot pass through 512. The examiner respectfully disagrees. Refrigerant does not need to pass through 512 to meet the limitations “circulate in a first direction”, “impede”, etc in claim 1. The applicant argues that the limitations of claim 6 are not taught. The examiner respectfully disagrees. A new rejection of record has been provided in view in the change in scope of the claim (see detailed rejection above). Applicant argues that Tseng fails to teach claim 9 details. However, the scope of claim 9 has been changed in the latest reply and therefore the examiner is now relying on CHENG to teach the recited void details (see detailed rejection above). Therefore, the applicants’ arguments are not persuasive. The applicant argues that Tseng fail to teach claim 17. The examiner respectfully disagrees. Applicant's arguments fail to comply with 37 CFR 1.111(b) because they amount to a general allegation that the claims define a patentable invention without specifically pointing out how the language of the claims patentably distinguishes them from the references. Applicant argues the claims dependent on the independent claim(s) are allowable based upon their dependence from an independent claim. Examiner respectfully disagrees. The arguments with respect to claim(s) 1, 9, 17 have been addressed above. Thus, the rejections are proper and remain. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 12,173,969 B2. 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 GORDON A JONES whose telephone number is (571)270-1218. The examiner can normally be reached 7:30-5 M-F PST. 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, Len Tran can be reached at 571-272-1184. 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. /GORDON A JONES/ Examiner, Art Unit 3763
Read full office action

Prosecution Timeline

May 25, 2023
Application Filed
Nov 06, 2025
Non-Final Rejection — §102, §103
Jan 28, 2026
Examiner Interview Summary
Jan 28, 2026
Applicant Interview (Telephonic)
Feb 09, 2026
Response Filed
Apr 03, 2026
Final Rejection — §102, §103 (current)

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

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Prosecution Projections

3-4
Expected OA Rounds
60%
Grant Probability
99%
With Interview (+39.1%)
3y 4m
Median Time to Grant
Moderate
PTA Risk
Based on 548 resolved cases by this examiner. Grant probability derived from career allow rate.

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