Prosecution Insights
Last updated: April 19, 2026
Application No. 18/212,592

PILLOW AND METHOD OF MAKING SAME

Non-Final OA §103
Filed
Jun 21, 2023
Examiner
KURILLA, ERIC J
Art Unit
3619
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Precision Textiles LLC
OA Round
1 (Non-Final)
71%
Grant Probability
Favorable
1-2
OA Rounds
2y 5m
To Grant
98%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allow Rate
560 granted / 788 resolved
+19.1% vs TC avg
Strong +27% interview lift
Without
With
+27.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
32 currently pending
Career history
820
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
40.2%
+0.2% vs TC avg
§102
26.9%
-13.1% vs TC avg
§112
24.0%
-16.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 788 resolved cases

Office Action

§103
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 § 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) 1-7 and 15-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grinstead (US 10,660,462) in view of Wagner (US 2,898,975). Regarding Claim 1, Grinstead discloses a pillow (500), comprising: a first pillow half (502) including an outer surface and an inner surface opposite the outer surface; and a second pillow half (604) including an outer surface and an inner surface opposite the outer surface, wherein the inner surface of the first pillow half contacts the inner surface of the second pillow half (see Figs. 5-6B). Grinstead fails to disclose wherein the first pillow half defines a first interior concavity in the inner surface of the first pillow half, and wherein the first interior concavity extends into an interior of the first pillow half. Wanger teaches wherein the first pillow half defines a first interior concavity (2a) in the inner surface of the first pillow half, and wherein the first interior concavity extends into an interior of the first pillow half. Grinstead and Wagner are analogous art because they are from the same field of endeavor, i.e. pillows. It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the pillow of Grinstead with the concavities of Wagner. The motivation would have been to “to reduce the weight of the product, at the same time utilizing less material, and with the further purpose of controlling or modifying the cushioning characteristics of the product” (see Col. 1, Lines 30-34 of Wagner). Regarding Claim 2, Grinstead as modified teaches wherein the second pillow half defines a second interior concavity in the inner surface of the second pillow half, the second interior concavity extending into an interior of the second pillow half, the second interior concavity aligned with the first interior concavity (Wagner: 2b, see Fig. 1). Regarding Claim 3, Grinstead discloses wherein the first pillow half defines a first vent (512) in the outer surface of the first pillow half, the first vent extending into the interior of the first pillow half. Regarding Claim 4, Grinstead discloses wherein the second pillow half defines a second vent (512) in the outer surface of the second pillow half, the second vent extending into the interior of the second pillow half (see Fig. 6A). Regarding Claim 5, Grinstead discloses the first pillow half defines a plurality of first vents in the outer surface of the first pillow half, the plurality of first vents extending into the interior of the first pillow half, and wherein the second pillow half defines a plurality of second vents in the outer surface of the second pillow half, the plurality of second vents extending into the interior of the second pillow half (see Figs. 5 and 6A). Regarding Claim 6, Grinstead as modified teaches wherein the plurality of first vents and the plurality of second vents extend into the first and second interior concavities (see Wagner Fig. 1 and Grinstead Fig. 6A). Regarding Claim 7, Grinstead discloses wherein the first pillow half comprises a molded polyurethane (See Col. 5, Lines 34-46 and Col. 4, Lines 17-20). Regarding Claim 15, Grinstead as modified teaches a method, comprising: molding a first pillow half (Grinstead: 502, see Col. 5, Lines 34-46), wherein the first pillow half includes an outer surface, an inner surface opposite the outer surface (Grinstead: see Fig. 6A), and a first interior concavity (Wagner: see 2a in Fig. 1) in the inner surface, wherein the first inner concavity extends into an interior of the first pillow half; molding a second pillow half (Grinstead: 604, see Col. 5, Lines 34-46), wherein the second pillow half includes an outer surface and an inner surface opposite the outer surface of the second pillow half (Grinstead: see Fig. 6A); and connecting the inner surface of the first pillow half and the inner surface of the second pillow half, thereby to form a pillow (Grinstead: see Col. 5, Lines 45-46). Regarding Claim 16, Grinstead as modified teaches wherein molding the second pillow half comprises molding a second interior concavity (Wagner: 2b) in the inner surface of the second pillow half, wherein the second interior concavity extends into an interior of the second pillow half, and wherein the second interior concavity is aligned with the first interior concavity (Wagner: see Fig. 1). Claim(s) 8-14 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grinstead (US 10,660,462) in view of Wagner (US 2,898,975), as applied to claim 1 above, and further in view of Ulrich (EP 1938715). Regarding Claim 8, Grinstead as modified by Wagner teaches a pillow comprising: a first pillow half (Grinstead: 502) including an outer surface and an inner surface opposite the outer surface; a second pillow half (Grinstead: 604) including an outer surface and an inner surface opposite the outer surface; and wherein the first pillow half defines a first interior concavity in the inner surface of the first pillow half (Wagner: 2a), the first interior concavity extending into an interior of the first pillow half. Grinstead fails to disclose a support layer having a first surface and a second surface opposite the first surface, wherein the inner surface of the first pillow half contacts the first surface of the support layer, wherein the inner surface of the second pillow half contacts the second surface of the support layer. Ulrich teaches a support layer (5) having a first surface and a second surface opposite the first surface, wherein an inner surface of a first pillow half (4) contacts the first surface of the support layer, wherein an inner surface of a second pillow half (6) contacts the second surface of the support layer. Grinstead and Ulrich are analogous art because they are from the same field of endeavor, i.e. pillows. It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the pillow of Grinstead with the support layer of Ulrich. The motivation would have been to “to [restrict] the softness and sinking of the upper foam layer 4 into the lower foam layer 6 ” (see para. [0013] of English translation of Ulrich). Regarding Claim 9, Grinstead as modified teaches wherein the second pillow half defines a second interior concavity in the inner surface of the second pillow half, the second interior concavity extending into an interior of the second pillow half, (Wagner: 2b, see Fig. 1). Regarding Claim 10, Grinstead discloses wherein the first pillow half defines a first vent (512) in the outer surface of the first pillow half, the first vent extending into the interior of the first pillow half. Regarding Claim 11, Grinstead discloses wherein the second pillow half defines a second vent (512) in the outer surface of the second pillow half, the second vent extending into the interior of the second pillow half (see Fig. 6A). Regarding Claim 12, Grinstead discloses the first pillow half defines a plurality of first vents in the outer surface of the first pillow half, the plurality of first vents extending into the interior of the first pillow half, and wherein the second pillow half defines a plurality of second vents in the outer surface of the second pillow half, the plurality of second vents extending into the interior of the second pillow half (see Figs. 5 and 6A). Regarding Claim 13, Grinstead as modified teaches wherein the plurality of first vents and the plurality of second vents extend into the first and second interior concavities (see Wagner Fig. 1 and Grinstead Fig. 6A). Regarding Claim 14, Grinstead discloses wherein the first pillow half comprises a molded polyurethane (See Col. 5, Lines 34-46 and Col. 4, Lines 17-20). Regarding Claim 19, Grinstead as modified teaches a method, comprising: molding a first pillow half (Grinstead: 502, see Col. 5, Lines 34-46) including an outer surface, an inner surface opposite the outer surface, and an interior concavity Wagner: see 2a in Fig. 1) in the inner surface, the inner concavity extending into an interior of the first pillow half; molding a second pillow half (Grinstead: 604, see Col. 5, Lines 34-46) including an outer surface and an inner surface opposite the outer surface of the second pillow half; obtaining a support layer (Ulrich: 5) including a first surface and a second surface opposite the first surface; connecting the inner surface of the first pillow half to the first surface of the support layer (Ulrich: see Fig.1 ); and connecting the inner surface of the second pillow half to the second surface of the support layer (Ulrich: see Fig. 1), thereby to form a pillow. Claim(s) 17-18 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grinstead (US 10,660,462) in view of Wagner (US 2,898,975), as applied to claim 16 above, and further in view of Official Notice. Regarding Claims 17 and 18, Grinstead discloses drilling out the first and second vents in Col. 6, Lines 60-65 wherein the first vent extends into the interior of the first pillow half and wherein the second vent extends into the interior of the second pillow half, and therefore fails to disclose wherein molding the first pillow half comprises molding a first vent in the outer surface of the first pillow half, and wherein molding the second pillow half comprises molding a second vent in the outer surface of the second pillow half. Examiner takes Official Notice that is well-known within the art to mold vents, e.g. using pins in the mold, to provide vents in molded foams (see e.g. Lee US 2011/0094033 [0026], Roberts US 2023/0292942, or Talalay US 3,028,610). It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the method of molding of Grinstead with the molding of the vents as required in Claims 17 and 18. The motivation would have been to reduce steps in the manufacturing process, therefore reducing time required to manufacture the pillow of Grinstead. Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Grinstead (US 10,660,462) in view of Wagner (US 2,898,975) and Ulrich (EP 1938715) as applied to claim 19 above, and further in view of Official Notice. Regarding Claim 20, Grinstead discloses drilling out the first and second vents in Col. 6, Lines 60-65 wherein the first vent extends into the interior of the first pillow half, and therefore fails to disclose wherein molding the first pillow half comprises molding a first vent in the outer surface of the first pillow half, and Examiner takes Official Notice that is well-known within the art to mold vents, e.g. using pins in the mold, to provide vents in molded foams (see e.g. Lee US 2011/0094033 [0026], Roberts US 2023/0292942, or Talalay US 3028610). It would have been obvious to one having ordinary skill in the art at the time the invention was filed to modify the method of molding of Grinstead with the molding of the vent as required in Claim 20. The motivation would have been to reduce steps in the manufacturing process, therefore reducing time required to manufacture the pillow of Grinstead. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. See attached PTO-892. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ERIC J KURILLA whose telephone number is (571)270-7294. The examiner can normally be reached Monday-Thursday 7AM-6PM. 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, Anita Coupe can be reached at 571-270-3614. 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. /ERIC J KURILLA/ Primary Examiner, Art Unit 3619
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Prosecution Timeline

Jun 21, 2023
Application Filed
Aug 28, 2025
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12599257
PILLOW WITH GUSSET AND OPEN CELL CONSTRUCTION
2y 5m to grant Granted Apr 14, 2026
Patent 12599526
SURGICAL SUPPORT SYSTEM WITH SUPPORT TOP HEIGHT ADJUSTMENT
2y 5m to grant Granted Apr 14, 2026
Patent 12588775
LYING NECK PILLOW THAT IS EASY TO ADJUST AND USE
2y 5m to grant Granted Mar 31, 2026
Patent 12589839
AQUATIC BODYBOARD FOLDING CHAIR
2y 5m to grant Granted Mar 31, 2026
Patent 12582239
MATTRESS AND BED
2y 5m to grant Granted Mar 24, 2026
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
71%
Grant Probability
98%
With Interview (+27.1%)
2y 5m
Median Time to Grant
Low
PTA Risk
Based on 788 resolved cases by this examiner. Grant probability derived from career allow rate.

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