Prosecution Insights
Last updated: April 19, 2026
Application No. 18/214,621

THERMAL MANAGEMENT DEVICE

Non-Final OA §103
Filed
Jun 27, 2023
Examiner
RAMOS RIVERA, GILBERTO
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Subaru Corporation
OA Round
1 (Non-Final)
79%
Grant Probability
Favorable
1-2
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allow Rate
11 granted / 14 resolved
+13.6% vs TC avg
Strong +30% interview lift
Without
With
+30.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
44 currently pending
Career history
58
Total Applications
across all art units

Statute-Specific Performance

§103
63.3%
+23.3% vs TC avg
§102
24.4%
-15.6% vs TC avg
§112
10.3%
-29.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 14 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. 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 non-obviousness. Claim 1 is rejected under 35 U.S.C. 103 as being unpatentable over Kato et al. (US 20200198443 A1) in view of Makimoto et al. (US 20200207178 A1 ) . Regarding claim 1, Kato teaches a vehicle air conditioner system (1) (thermal management device) comprising a refrigeration cycle device (10), a high temperature coolant circuit (20), a low temperature coolant circuit (30) and a controller (60) for control all the operations [0017, 0047, 0049, 0075, Fig. 1 and 3]. The low temperature coolant circuit (30) comprises a circulating low-temperature heat medium (first thermal transfer medium), a low-temperature side radiator (32) (first radiator) and a battery (33), therefore it meets all the limitations of the first thermal circuit [0041 and 0049]. The high temperature coolant circuit (20) (second thermal circuit) comprises a circulating high temperature heat medium (second thermal transfer medium) and is connected to a condenser (12) (heater) which heats circulating high temperature heat medium [0030, 0042 and 0101]. In addition, the high temperature coolant circuit (20) (second thermal circuit) comprises a high-temperature side radiator (23) (second radiator) disposed on a radiator flow passage (20b) (first path) and a heater core (22) (heating appliance) disposed on a high-temperature side circulation flow passage (20a) (second path), which is parallel to the high-temperature side radiator flow passage (20b) (first path) [0045, 0046 and Fig. 1]. The heater core (22) (heating appliance) is an air heating heat exchanger that heats air to be blown into the interior of the vehicle cabin by exchanging heat between the coolant in the high-temperature coolant circuit (20) (second thermal circuit) and the air to be blown into the interior of the vehicle cabin [0044]. I t is comprised a high-temperature side three-way valve (24) (flow rate adjusting unit) which is able to divide the circulating high temperature heat medium (second thermal transfer medium) to pass through the radiator flow passage (20b) (first path) and the high-temperature side circulation flow passage (20a) (second path) [0047 and Fig. 1]. Additionally, it is comprised a high-temperature side pump ( 21 ) which is a high-temperature side flow-rate adjustment portion that adjusts the flow rate of the coolant circulating in the high-temperature coolant circuit ( 20 ) (second thermal circuit) [0043]. It is further taught that the controller (60) comprises a group of sensors connected to its input side, among which a high-temperature coolant (second thermal transfer medium) temperature sensor (67) is present [0081 and Fig. 3]. The high-temperature coolant (second thermal transfer medium) temperature sensor (67) can detect for example, the temperature of the temperature of the coolant in the condenser (12) (heater) which is part of the high temperature coolant circuit (20) (second thermal circuit) [0086]. The described embodiments comprise a heat transfer portion configured to transfer heat from the high-temperature side heat medium circuit to the low-temperature side heat medium circuit from which the limitation “configured such that heat is able to be exchanged between the first thermal transfer medium flowing through the first radiator and the second thermal transfer medium flowing through the second radiator” is met [0005]. Base on a target air outlet temperature (TAO) (target) and the like when the air conditioner switch is turned on, the controller (60) switches between the air-cooling mode or the air-heating mode [0091 and 0092]. In the air heating mode, heat contained in the high-pressure refrigerant which is discharged from the compressor (11) is dissipated at the condenser (12) (heater) into the coolant in the high-temperature coolant circuit (20) (second thermal circuit), which is dissipated into the air at the heater core (22) (heating appliance), so that the heated air can be blown into the interior of the vehicle cabin [0117]. The high-temperature side three-way valve (24) is controlled to close the radiator flow passage (20b) (first path) [0111]. The controller (60) executes a battery heating mode to heat the battery (33) when its temperature is lower than the lower limit of temperature (target) [0130]. In the battery heating mode, the heat from the high-pressure refrigerant is dissipated into the coolant in the high-temperature coolant circuit (20) (second thermal circuit) at the condenser (12) (heater) , so that the heated coolant can circulate to the battery (33) [0140]. The high-temperature side three-way valve (24) is controlled to close the radiator flow passage (20b) (first path) [0139]. In the battery heating mode, the coolant in the high-temperature coolant circuit (20) (second thermal circuit) flows to the heater core (22) (heating appliance), making it possible to perform air-heating while heating the battery (33). From the above descriptions the feature where the control unit “ executes flow dividing processing of heating the second thermal transfer medium by the heater when a battery heating request and an air heating request are made ” can be considered met. In addition, from the air and battery heating modes, a target temperature (TAO and the battery temperature lower limit) activates the corresponding heating process. From these target temperatures and because for both cases the heat from the high-pressure refrigerant is dissipated into the coolant in the high-temperature coolant circuit (20) (second thermal circuit) at the condenser (12) (heater), can be inferred that exists a target temperature for the high temperature heat medium (second thermal transfer medium), an actual value temperature for this fluid and a difference (deficiency) between the referred temperatures. Because the controller ( 60 ) switches an operation mode to either the air-cooling mode or the air-heating mode based on a target air outlet temperature ( TAO ) and the like when the air conditioner switch is turned on [0091]. From the above description can be said that a non-recited threshold is implied on the controller ( 60 ) decision making to switch between the heating and cooling modes. From the discussion above, the feature “ when a deficiency value of the measured temperature with respect to a target temperature of the second thermal transfer medium is greater than a first threshold value that is set in advance ” can be considered met . Kato does not teach the feature where “ the flow rate adjusting unit to divide the flow of the second thermal transfer medium to the first path and the second path and in the flow dividing processing, when a deficiency value of the measured temperature with respect to a target temperature of the second thermal transfer medium is greater than a first threshold value that is set in advance, a second flow dividing proportion of the flow divided to the second path is set to be greater than a first flow dividing proportion of the flow divided to the first path ”. Makimoto teaches a vehicular air conditioner (1) (thermal management device) mounted on an electric vehicle [0052]. According to a third embodiment, the vehicular air conditioner (1) (thermal management device) comprises a low temperature heat medium circuit (30) (first thermal circuit) including low-temperature heat medium ( first thermal transfer medium ), a low-temperature radiator ( 33 ) (first radiator) and a vehicle-mounted device ( 32 ) which is a battery [0225 -0230 and Fig. 6]. the vehicular air conditioner (1) (thermal management device) further comprises a high-temperature heat medium circuit ( 20 ) (second thermal circuit) including a high -temperature heat medium (second thermal transfer medium ), a refrigerant heat exchanger (12) (heater) and a high temperature radiator (23) (second radiator) [0057-0061 and Fig. 6]. From Fig. 6, can be observed that the high-temperature heat medium circuit ( 20 ) (second thermal circuit) comprises the high temperature radiator (23) (second radiator) positioned on a path (first path) that is parallel to the path (second path) of a heater core (22) (heating appliance) which is a heat exchanger that heats the ventilation air employing the heated high -temperature heat medium (second thermal transfer medium ) [0060, 0062 and 0063]. It is taught that the high-temperature radiator (23) (second radiator) and the low-temperature radiator ( 33 ) (first radiator) may be integrated together such that the heat of the high-temperature heat medium and the heat of the low-temperature heat medium can be thermally transferred to each other [0333] . The vehicular air conditioner (1) (thermal management device) comprises an air-conditioning control device ( 60 ) [0056]. The high-temperature heat medium circuit ( 20 ) (second thermal circuit) comprises a high-temperature flow rate regulation valve (24) ( adjusting unit ) that is an electric three-way flow rate regulation valve for continuously regulating a high-temperature flow rate ratio between a flow rate of the high-temperature heat medium flowing into the heater core (22) (heating appliance) and a flow rate of the high-temperature heat medium flowing into the high-temperature radiator (23) (second radiator) (first and second path) . The operation of the high-temperature flow rate regulation valve (24) ( adjusting unit ) is controlled according to a control signal output from the air-conditioning control device ( 60 ) [0063]. It is taught that the high-temperature flow rate regulation valve (24) ( adjusting unit ) allows to make adjustment s on the amount of heating of the ventilation air in the heater core (22) (heating appliance) [which is blown into the vehicle compartment ] [0064] . If the vehicle air conditioner system (1) (thermal management device) of Kato is modified by replacing its high-temperature side three-way valve (24) (flow rate adjusting unit) for the high-temperature flow rate regulation valve (24) ( adjusting unit ) taught by Makimoto , the claimed limitations would be met. Despite it is not explicitly recited, from the combination of the references, if Kato’s controller (60) detects a high-temperature coolant (second thermal transfer medium) temperature through sensor (67) that is lower than a specific threshold, the flow rate of the high-temperature coolant (second thermal transfer medium) entering the heater core (22) (heating appliance/second path) can be adjusted to be greater than the flowrate entering the high-temperature radiator (23) (second radiator/first path) in order to prevent heat loss. Kato and Makimoto are analogous art to the current invention because they are concerned with the same field of endeavor, namely a thermal management device installed in a vehicle, the thermal management device comprising: a first thermal circuit in which a first thermal transfer medium circulates; a second thermal circuit in which a second thermal transfer medium circulates; and a control unit, wherein: the first thermal circuit includes a first radiator and a battery; the second thermal circuit includes a heater that heats the second thermal transfer medium, a first path, a second radiator that is disposed on the first path, and is configured such that heat is able to be exchanged between the first thermal transfer medium flowing through the first radiator and the second thermal transfer medium flowing through the second radiator, a second path that is parallel to the first path and a heating appliance that is disposed on the second path for performing air heating of a cabin of the vehicle using the second thermal transfer medium as a heat source . It would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the vehicle air conditioner system (1) (thermal management device) of Kato by replacing its high-temperature side three-way valve (flow rate adjusting unit) for the high-temperature flow rate regulation valve ( adjusting unit ) taught by Makimoto to meet the features where “ the flow rate adjusting unit to divide the flow of the second thermal transfer medium to the first path and the second path and in the flow dividing processing, when a deficiency value of the measured temperature with respect to a target temperature of the second thermal transfer medium is greater than a first threshold value that is set in advance, a second flow dividing proportion of the flow divided to the second path is set to be greater than a first flow dividing proportion of the flow divided to the first path ”, because Makimoto teaches that its high-temperature flow rate regulation valve ( adjusting unit ) allows to make adjustments on the amount of heating of the ventilation air in the heater core (22) (heating appliance) [which is blown into the vehicle compartment ]. Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over Kato et al. (US 20200198443 A1) in view of Makimoto et al. (US 20200207178 A1 ) as applied to claim 1 above, further in view of Miura et al. (US 20180354344 A1). Regarding claim 2, Kato and Makimoto teach all the elements of the current invention in claim 1, except “wherein a second threshold value that is smaller than the first threshold value is set in advance, and in the flow dividing processing, when the deficiency value is greater than the first threshold value, the second flow dividing proportion is controlled to a first fixed value, when the deficiency value is smaller than the second threshold value, the second flow dividing proportion is controlled to a second fixed value that is smaller than the first fixed value, and when the deficiency value is no greater than the first threshold value and no smaller than the second threshold value, the second flow dividing proportion is controlled to be monotonously reduced from the first fixed value to the second fixed value in accordance with the deficiency value decreasing”. Miura teaches a v ehicle thermal management system ( 10 ) used to adjust various devices mounted on a vehicle or the vehicle interior to an appropriate temperature [0019 and Fig. 1] . The v ehicle thermal management system ( 10 ) includes a battery-temperature adjustment heat exchanger ( 81A ) , an inverter ( 81B ) , and an engine cooling heat exchanger ( 81C ) [0066] . In addition it comprises a controller (60) for controlling various control target devices connected to its output side [0097 and Fig. 2] . Miura teaches about a high coolant temperature circuit having a coolant which temperature (Th) is monitored and compared with two temperature thresholds. The first temperature threshold (Th1) is greater than the second one (Th2). If the coolant temperature ( Th ) exceeds a first threshold value ( Th1 ) , the compressor ( 22 ) is driven , if is below a second threshold value ( Th2 ) , the compressor ( 22 ) is stopped [0149-0152 and Fig. 1] . By employing the above referred procedure is possible to prevent the compressor ( 22 ) from being excessively driven, further reducing the power consumption of the compressor ( 22 ) [0154]. Miura is analogous art to the current invention because it is concerned with the same field of endeavor, namely a thermal management device installed in a vehicle , having at least a thermal transfer circuit in which a thermal transfer medium circulates. Despite the teachings of Miura are regarding a specific temperature value, the general procedure can be applied to the modified invention of Kato and Makimoto . In this case if the temperature deficiency value of Kato is compared to the first and second thresholds (Th1 and Th2) as taught by Miura, from the compressor (22) start/stop is possible to say that a first fixed value and a second fixed value , lower than the first one, are achieved. Given that heat transfer can be controlled by adjusting a flowrate of a specific fluid, the above discussed features and “ when the deficiency value is no greater than the first threshold value and no smaller than the second threshold value, the second flow dividing proportion is controlled to be monotonously reduced from the first fixed value to the second fixed value in accordance with the deficiency value decreasing ” can be achieved by controlling the high-temperature side pump ( 21 ) of Kato or the modified high-temperature side three-way valve (24) (flow rate adjusting unit) of Kato in view of Makimoto . It would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the vehicle air conditioner system (thermal management device) of Kato and Makimoto to include the feature “wherein a second threshold value that is smaller than the first threshold value is set in advance, and in the flow dividing processing, when the deficiency value is greater than the first threshold value, the second flow dividing proportion is controlled to a first fixed value, when the deficiency value is smaller than the second threshold value, the second flow dividing proportion is controlled to a second fixed value that is smaller than the first fixed value, and when the deficiency value is no greater than the first threshold value and no smaller than the second threshold value, the second flow dividing proportion is controlled to be monotonously reduced from the first fixed value to the second fixed value in accordance with the deficiency value decreasing”, because Miura teaches that by a similar temperature comparison process is possible to prevent the compressor from being excessively driven, further reducing the power consumption of the compressor . Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Kato et al. (US 20200198443 A1) in view of Makimoto et al. (US 20200207178 A1 ) and Miura et al. (US 20180354344 A1) as applied to claim 2 above, further evidenced by Sabharwall et al. ( Effect of mass flow rate on the convective heat transfer coefficient: analysis for constant velocity and constant area case , see NPL documents for citation). Regarding claim 3, Kato, Makimoto and Miura teach all the elements of the current invention in claim 2 . Kato further teaches that the controller (60) calculates the target air outlet temperature ( TAO ) based, among other parameters on the vehicle interior preset temperature ( Tset ) set by the temperature setting switch of the operation panel ( 70 ) [0092-0093]. Since the heater core (22) (heating appliance) was described on claim 1 as an air heating heat exchanger that heats air to be blown into the interior of the vehicle cabin by exchanging heat between the coolant in the high-temperature coolant circuit ( 20 ) (second thermal circuit) and the air to be blown into the interior of the vehicle cabin , it may be required to increase its air heating load depending on the vehicle interior preset temperature ( Tset ) set by the user. Sabharwall evidence that the convective heat transfer coefficient magnitude will change depending on operating conditions, mainly the flow rate [p. 197; par. 1]. From this evidence, can be concluded that if the air heating load of the heater core (22) (heating appliance) is increased, the flowrate of the coolant in the high-temperature coolant circuit ( 20 ) (second thermal circuit) entering the heater core (22) (heating appliance) should be increased to satisfy the heating load request. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Kato et al. (US 20200198443 A1) in view of Makimoto et al. (US 20200207178 A1 ) as applied to claim 1 above, further evidenced by OpenStax (U niversity P hysics II: T hermodynamics , Electricity & M agnetism. 1.7: Mechanisms of Heat Transfer , see NPL documents for citation) . Regarding claim 4, Kato and Makimoto teach all the elements of the current invention in claim 1. Kato further teaches that the controller (60) calculates the target air outlet temperature ( TAO ) based, among other parameters on the vehicle interior preset temperature ( Tset ) set by the temperature setting switch of the operation panel ( 70 ) [0092-0093]. This description implies that the target air outlet temperature ( TAO ) is a variable temperature within a range defined by its parameters. Because the heating processes as discussed on claim 1, heat the high-temperature coolant circuit (20) (second thermal circuit) at the condenser (12) (heater), can be inferred that exists a target temperature for the high temperature heat medium (second thermal transfer medium). Because of the reasons above can be said that the controller (60) is able to variably control the non-recited target temperature of the high temperature heat medium (second thermal transfer medium) within a range which responds to the range of the target air outlet temperature ( TAO ). By setting the target temperature to the upper limit would result on the highest possible temperature difference between the measured high temperature heat medium (second thermal transfer medium) and the target temperature . OpenStax evidence that the convection rate is often approximately proportional to the temperature difference [p. 1.7.10; par. 1]. Based on the evidence, setting the target temperature to the upper limit would result on a higher (faster) energy transfer from the condenser (12) (heater) to the high temperature heat medium (second thermal transfer medium) . Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT GILBERTO RAMOS RIVERA whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)272-2740 . The examiner can normally be reached FILLIN "Work Schedule?" \* MERGEFORMAT Mon-Fri 7:30-5:00 pm . 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, Nicole Buie-Hatcher can be reached at (571) 270-3879 . 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. /G.R./ Examiner, Art Unit 1725 /NICOLE M. BUIE-HATCHER/ Supervisory Patent Examiner, Art Unit 1725
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Prosecution Timeline

Jun 27, 2023
Application Filed
Mar 18, 2026
Non-Final Rejection — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
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Grant Probability
99%
With Interview (+30.0%)
3y 4m
Median Time to Grant
Low
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