Prosecution Insights
Last updated: April 19, 2026
Application No. 18/209,984

REFRIGERATOR

Non-Final OA §103
Filed
Jun 14, 2023
Examiner
GAYE, SAMBA NMN
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Samsung Electronics Co., Ltd.
OA Round
3 (Non-Final)
63%
Grant Probability
Moderate
3-4
OA Rounds
2y 11m
To Grant
99%
With Interview

Examiner Intelligence

Grants 63% of resolved cases
63%
Career Allow Rate
89 granted / 141 resolved
-6.9% vs TC avg
Strong +37% interview lift
Without
With
+36.6%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
54 currently pending
Career history
195
Total Applications
across all art units

Statute-Specific Performance

§103
52.5%
+12.5% vs TC avg
§102
8.2%
-31.8% vs TC avg
§112
37.4%
-2.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 141 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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 11/14/2025 has been entered. Status This Office Action is in response to the remarks and amendments filed on 11/14/2025. The previous objections to the claims have been withdrawn. Claims 1 and 3-15 remain pending for consideration. 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. 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. Claims 1 and 7-12 are rejected under 35 U.S.C. 103 as being unpatentable over Kang et al. (US20120204581A1, herein after referred to as Kang), in view of Sakurasawa et al. (WO2012039195A1, herein after referred to as Sakurasawa), and in further view of Kim et al. (KR20180129215A, herein after referred to as Kim’15). Regarding claim 1, Kang teaches a refrigerator (Fig. 1) comprising: an inner case (inner case 13 Fig. 1) defining a storage compartment (refrigerating chamber 23 Fig. 1); a cold air outlet (upper most cold air discharge hole 51 Figs. 1-2) provided on one side of the storage compartment (rear wall 13a Fig. 2) and configured to discharge cold air (paragraph [0045]); and a purifier assembly (sterilizer 100 Fig. 2) provided at an upper surface of the storage compartment (upper surface 13b Fig. 2) and configured to purify a portion of the cold air (air discharged by upper cold air discharge hole 51 Fig. 6) discharged from the cold air outlet (paragraph [0047]); and a duct (duct 50 Fig. 1) comprising a circulation flow path (air passage formed by duct 50 Figs. 1 and 6) configured to circulate the cold air in the storage compartment (paragraph [0043]), wherein the purifier assembly comprises: an air purifier (ion generation unit 140 and deodorizing filter 190 Fig. 4) configured to deodorize or sterilize the cold air (paragraph [0047]); a housing (housing 110 Fig. 3) accommodating the air purifier (Fig. 4) and an inlet (air inflow hole 114 Fig. 6); and a first flow path (see below annotated Fig. 6 of Kang), and wherein the purifier assembly penetrates the inner case (Fig. 2), and the air purifier of the purifier assembly is configured to receive, through the inlet, the cold air discharged from the cold air outlet (Fig. 6), wherein the air purifier is provided on the first flow path (see below annotated Fig. 6 of Kang), wherein a portion of the housing (lower cover 111 Fig. 6) is provided in an upper end portion (Fig. 6) inside the storage compartment (Fig. 6) and a remaining portion of the housing (upper cover 115 Fig. 6) is provided outside the storage compartment (Fig. 6), wherein the cold air outlet is provided at an upper end of one surface of the duct (upper end of the front surface of duct 50 Figs. 1 and 6) forming a rear surface of the storage compartment (Fig. 1). PNG media_image1.png 386 784 media_image1.png Greyscale Kang teaches the invention as described above but fails to explicitly teach “the purifier assembly comprises: the inlet facing the cold air outlet”. However, Sakurasawa teaches a purifier assembly (ion delivery unit 20 Fig. 4 corresponds to the purifier assembly of Kang) comprises: an inlet (suction port 30a Fig. 4 corresponds to the inlet of Kang) facing a cold air outlet (Fig. 1 and paragraph [38] where the outlet of circulation path 13 corresponds to the cold air outlet of Kang). Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of Kang to include “the purifier assembly comprises: the inlet facing the cold air outlet” in view of the teachings of Sakurasawa to provide an arrangement in which the entirety of the cold air flowing in the duct flows also in the purifier assembly. The combined teachings teach the invention as described above but fail to explicitly teach “the purifier assembly comprises: the first flow path and a second flow path in which the cold air received by the inlet flows and which are partitioned from each other, wherein a part of the cold air discharged from the cold air outlet is circulated into the storage compartment through the second flow path, and a remaining part of the cold air discharged from the cold air outlet is deodorized or sterilized by the air purifier through the first flow path, and wherein the first flow path and the second flow path are arranged in a horizontal direction inside the housing”. However, Kim’15 teaches a purifier assembly (air purification apparatus 600 Figs. 20-22 corresponds to the purifier assembly of Kang) comprises: a first flow path (see below annotated Fig. 21 of Kim’15) and a second flow path (see below annotated Fig. 21 of Kim’15) in which cold air (the arrow illustrated in Fig. 20 entering air inlet 10 corresponds to the cold air of Kang) received by an inlet (air inlet 10 Fig. 20 corresponds to the inlet of Kang) flows and which are partitioned from each other (see below annotated Fig. 21 of Kim’15), wherein a part of the cold air discharged from a cold air outlet (see below annotated Fig. 21 of Kim’15) is circulated into a storage compartment (paragraph [0048] where the cabin of the vehicle corresponds to the storage compartment of Kang) through the second flow path (see below annotated Fig. 21 of Kim’15), and a remaining part of the cold air discharged from the cold air outlet (see below annotated Fig. 21 of Kim’15) is deodorized or sterilized by the air purifier (paragraph [0048]) through the first flow path (see below annotated Fig. 21 of Kim’15), and wherein the first flow path and the second flow path are arranged in a horizontal direction (see below annotated Fig. 21 of Kim’15) inside a housing (upper housing 611 and lower housing 612 Figs. 20 corresponds to the housing of Kang) to provide an air purifier assembly that does not shield the flow path (paragraph [0134]). PNG media_image2.png 673 1260 media_image2.png Greyscale Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “the purifier assembly comprises: the first flow path and a second flow path in which the cold air received by the inlet flows and which are partitioned from each other, wherein a part of the cold air discharged from the cold air outlet is circulated into the storage compartment through the second flow path, and a remaining part of the cold air discharged from the cold air outlet is deodorized or sterilized by the air purifier through the first flow path, and wherein the first flow path and the second flow path are arranged in a horizontal direction inside the housing” in view of the teachings of Kim’15 to provide an air purifier assembly that does not shield the flow path. Regarding claim 7, the combined teachings teach wherein the inner case comprises an insertion hole (the recess that accommodates installation part 80 Fig. 2 of Kang), and wherein the housing penetrates the insertion hole (Figs. 2-3 of Kang). Regarding claim 8, the combined teachings teach further comprising a fixing cover (installation part 80 Fig. 2 of Kang) provided outside the inner case and to which the housing penetrating the insertion hole is fixed (Figs. 2-3 and paragraph [0059] of Kang). Regarding claim 9, the combined teachings teach wherein the housing further comprises a coupling hook (insertion ribs 120 Fig. 4 of Kang) provided on an upper surface of the housing (Fig. 4 of Kang) and configured to be coupled to the fixing cover (paragraph [0060] of Kang). Regarding claim 10, the combined teachings teach wherein the inlet is configured to receive the cold air discharged from the fan (Fig. 6 and paragraph [0045] of Kang). Regarding claim 11, the combined teachings teach wherein the inlet is provided inside the storage compartment (Fig. 6 of Kang). Regarding claim 12, the combined teachings teach wherein the inlet is adjacent to the cold air outlet (Fig. 1 and paragraph [38] of Sakurasawa). Claims 3-4 and 6 are rejected under 35 U.S.C. 103 as being unpatentable over Kang, in view of Sakurasawa, in view of Kim’15, and in further view of Kim et al. (US20230003403A1, herein after referred to as Kim). Regarding claim 3, the combined teachings teach (ii) an ion sterilization device (ion generation unit 140 Fig. 4 of Kang) comprising a discharge electrode (electrode unit 141 Fig. 4 of Kang) and a printed circuit board (drive circuit board 170 Fig. 4 of Kang) configured to control the discharge electrode (paragraph [0089] of Kang). The combined teachings teach the invention as described above but fail to explicitly teach “wherein the air purifier further comprises at least one of (i) a photocatalytic device comprising an ultraviolet (UV) light source and a photocatalytic filter configured to react with light from the UV light source”. However, Kim teaches wherein the air purifier (air cleaning module 10 Fig. 1B corresponds to the air purifier of Kang) further comprises (i) a photocatalytic device (light source unit 200 and filter 300 Fig. 1B) comprising an ultraviolet (UV) light source (light source unit 200 Fig. 1B and paragraph [0101]) and a photocatalytic filter (filter 300 Fig. 1B and paragraph [0110]) configured to react with light from the UV light source (paragraph [0118]) to cause a chemical reaction and decomposes various contaminants and germs in the air in contact with the photocatalyst through an oxidation-reduction reaction (paragraph [0118]). Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “wherein the air purifier further comprises at least one of (i) a photocatalytic device comprising an ultraviolet (UV) light source and a photocatalytic filter configured to react with light from the UV light source” in view of the teachings of Kim to cause a chemical reaction and decomposes various contaminants and germs in the air in contact with the photocatalyst through an oxidation-reduction reaction. Regarding claim 4, the combined teachings teach wherein the air purifier comprises the photocatalytic device (Fig. 1B of Kim), wherein the purifier assembly further comprises a supporter (light source fixing part 161 Fig. 1B of Kim) provided on the first flow path (Fig. 1B of Kim where the flow path formed by guide 150 corresponds to the first flow path of Kang) and configured to support the UV light source (paragraph [0100] of Kim) to be disposed above the photocatalytic filter (Fig. 1C of Kim), and wherein the supporter comprises a protrusion (Fig. 1B of Kim) that includes a groove (Fig. 1B of Kim). Regarding claim 6, the combined teachings teach wherein the housing further comprises a mounting portion (understood the hooks located on the back of light transmitting member 185 Fig. 4 of Kang) on which the discharge electrode is mounted (Figs. 4-5 of Kang), and wherein the purifier assembly further comprises an outlet (ion discharge hole 113 Fig. 4 of Kang) provided on a bottom surface of the mounting portion (Fig. 4 and paragraph [0074] of Kang) and through which the cold air in the first flow path is discharged to the storage compartment (Fig. 6 of Kang). Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Kang, in view of Sakurasawa, in view of Kim’15, in view of Kim, and in further view of Yun (US20210063050A1). Regarding claim 5, the combined teachings teach wherein the purifier assembly further comprises an electronic component room (see below annotated Fig. 6 of Kang), wherein the air purifier comprises the ion sterilization device (Fig. 4 of Kang), wherein the discharge electrode is provided on the first flow path (see below annotated Fig. 6 of Kang), and wherein the printed circuit board is provided in the electronic component room (see below annotated Fig. 6 of Kang). PNG media_image3.png 406 1212 media_image3.png Greyscale The combined teachings teach the invention as described above but fail to explicitly teach “the electronic component room partitioned from the first flow path and the second flow path”. However, Yun teaches the electronic component room (mounting unit 518 Fig. 3 corresponds to the electronic component room of Kang) partitioned from the first flow path (see below annotated Fig. 5 of Yun) and the second flow path (see below annotated Fig. 5 of Yun) to protect the electronic components of the purifier assembly. PNG media_image4.png 311 1143 media_image4.png Greyscale Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “the electronic component room partitioned from the first flow path and the second flow path” in view of the teachings of Yun to protect the electronic components of the purifier assembly. Claims 13-14 are rejected under 35 U.S.C. 103 as being unpatentable over Kang, in view of Sakurasawa, in view of Kim’15, and in further view of Jang et al. (KR20140124659A, herein after referred to as Jang). Regarding claim 13, the combined teachings teach the invention as described above but fail to explicitly teach “wherein a flow rate of the cold air discharged from the second flow path to the storage compartment is greater than a flow rate of the cold air discharged from the first flow path to the storage compartment”. However, Jang teaches wherein a flow rate of the cold air (understood to be the amount of cold air flowing out of discharge opening 114a Fig. 4) discharged from the second flow path (see below annotated Fig. 4 of Jang) to the storage compartment (refrigerating chamber 22 Fig. 1 corresponds to the storage compartment of Kang) is greater than a flow rate of the cold air (understood to be the amount of cold air flowing out of discharge opening 114b Fig. 4 which a person skilled in the art would recognize as being smaller than the amount of cold air flowing out of discharge opening 114a since discharge opening 114b is smaller in size than discharge opening 114a) discharged from the first flow path to the storage compartment (see below annotated Fig. 4 of Jang) to provide different amounts of treated air to different sections of the storage compartment. PNG media_image5.png 386 823 media_image5.png Greyscale Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “wherein a flow rate of the cold air discharged from the second flow path to the storage compartment is greater than a flow rate of the cold air discharged from the first flow path to the storage compartment” in view of the teachings of Yun to provide different amounts of treated air to different sections of the storage compartment. Regarding claim 14, the combined teachings teach the invention as described above but fail to explicitly teach “wherein a direction in which the cold air is discharged from the first flow path to the storage compartment is different from a direction in which the cold air is discharged from the second flow path to the storage compartment”. However, Jang teaches wherein a direction (understood to be the direction of cold air flowing out of discharge opening 114b Fig. 4) in which the cold air is discharged from the first flow path (see below annotated Fig. 4 of Jang) to the storage compartment (refrigerating chamber 22 Fig. 1 corresponds to the storage compartment of Kang) is different from a direction (understood to be the direction of cold air flowing out of discharge opening 114a Fig. 4) in which the cold air is discharged from the second flow path (see below annotated Fig. 4 of Jang) to the storage compartment to evenly spread the treated air in the storage compartment (paragraph [0051]). PNG media_image5.png 386 823 media_image5.png Greyscale Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “wherein a direction in which the cold air is discharged from the first flow path to the storage compartment is different from a direction in which the cold air is discharged from the second flow path to the storage compartment” in view of the teachings of Yun to evenly spread the treated air in the storage compartment. Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Kang, in view of Sakurasawa, in view of Kim’15, and in further view of Kim et al. (US20180274839A1, herein after referred to as Kim’39). Regarding claim 15, the combined teachings teach the invention as described above but fail to explicitly teach “further comprising a deodorization filter provided on a rear surface of the storage compartment”. However, Kim’39 teaches further comprising a deodorization filter (filter 132 Fig. 3) provided on a rear surface of the storage compartment (Fig. 1 where refrigerating chamber 12 corresponds to the storage compartment of Kang) to further improve the deodorizing capabilities of the refrigerator. Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “further comprising a deodorization filter provided on a rear surface of the storage compartment” in view of the teachings of Kim’39 to further improve the deodorizing capabilities of the refrigerator. Response to Arguments Applicant’s arguments with respect to amended claim 1 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Applicant's arguments filed on 11/14/2025 have been fully considered but they are not persuasive. Regarding Applicant’s arguments on pages 9-10 that Kang is silent regarding “a cold air outlet is provided at an upper end of one surface of a duct” as recited by amended claim 1, Examiner disagrees. For clarity purposes, the above rejection of amended claim 1 is reproduced below: Kang teaches a cold air outlet (upper most cold air discharge hole 51 Figs. 1-2) is provided at an upper end of one surface of a duct (upper end of the front surface of duct 50 Figs. 1, 2, and 6) forming a rear surface of the storage compartment (Fig. 1). Furthermore, the phrase “an upper end” is broadly interpreted as an upper portion of a structure, and in the present case it is the upper portion of a duct. The claim as recited does not disclose that the cold air outlet is at the terminal end of the duct. Therefore, Applicant’s arguments are not persuasive and the rejections are maintained. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SAMBA NMN GAYE whose telephone number is (571)272-8809. The examiner can normally be reached Monday-Thursday 4:30AM to 2:30PM. 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, Jerry -Daryl Fletcher can be reached at 571-270-5054. 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. /SAMBA NMN GAYE/Examiner, Art Unit 3763 /JERRY-DARYL FLETCHER/Supervisory Patent Examiner, Art Unit 3763
Read full office action

Prosecution Timeline

Jun 14, 2023
Application Filed
Feb 28, 2025
Non-Final Rejection — §103
Apr 18, 2025
Interview Requested
Apr 19, 2025
Interview Requested
May 07, 2025
Applicant Interview (Telephonic)
May 07, 2025
Examiner Interview Summary
Jun 10, 2025
Response Filed
Sep 11, 2025
Final Rejection — §103
Nov 14, 2025
Request for Continued Examination
Nov 26, 2025
Response after Non-Final Action
Feb 13, 2026
Non-Final Rejection — §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
63%
Grant Probability
99%
With Interview (+36.6%)
2y 11m
Median Time to Grant
High
PTA Risk
Based on 141 resolved cases by this examiner. Grant probability derived from career allow rate.

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