Prosecution Insights
Last updated: April 19, 2026
Application No. 18/227,457

COOKING DEVICE

Non-Final OA §103
Filed
Jul 28, 2023
Examiner
CAMPBELL, THOR S
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
75%
Grant Probability
Favorable
1-2
OA Rounds
3y 1m
To Grant
76%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allow Rate
954 granted / 1276 resolved
+4.8% vs TC avg
Minimal +1% lift
Without
With
+0.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
57 currently pending
Career history
1333
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
44.9%
+4.9% vs TC avg
§102
35.0%
-5.0% vs TC avg
§112
12.8%
-27.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1276 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 nonobviousness. The Supreme Court in KSR International Co. v. Teleflex Inc., 82 USPQ2d 1385, 1395-97 (2007) identified a number of rationales to support a conclusion of obviousness which are consistent with the proper “functional approach” to the determination of obviousness as laid down in Graham. The key to supporting any rejection under 35 U.S.C. 103 is the clear articulation of the reason(s) why the claimed invention would have been obvious. The Supreme Court in KSR noted that the analysis supporting a rejection under 35 U.S.C. 103 should be made explicit. EXEMPLARY RATIONALES Exemplary rationales that may support a conclusion of obviousness include: (A) Combining prior art elements according to known methods to yield predictable results; (B) Simple substitution of one known element for another to obtain predictable results; (C) Use of known technique to improve similar devices (methods, or products) in the same way; (D) Applying a known technique to a known device (method, or product) ready for improvement to yield predictable results; (E) “Obvious to try” – choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success; (F) Known work in one field of endeavor may prompt variations of it for use in either the same field or a different one based on design incentives or other market forces if the variations are predictable to one of ordinary skill in the art; (G) Some teaching, suggestion, or motivation in the prior art that would have led one of ordinary skill to modify the prior art reference or to combine prior art reference teachings to arrive at the claimed invention. Claim (s) 1 , 9, 11, 13 -15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bhogal (US 2020/0278117A1) in view of Young et al (US 3585360 ) . Bhogal discloses in reference to claim: 1 . A cooking device comprising: a main body 100 ; a cooking chamber 200 inside the main body; a door at a front of the main body to open and close the cooking chamber (see figure 6) ; a grill heater 300 in an upper portion of the cooking chamber to heat an inside of the cooking chamber a camera module 710 disposed above the grill heater, and configured to photograph the inside of the cooking chamber; a first lighting module 730 disposed at a first side of the camera module above the grill heater, and configured to radiate light toward the inside of the cooking chamber; and a second lighting module 730 disposed at a second side, opposite to the first side, of the camera module above the grill heater, and configured to radiate light toward the inside of the cooking chamber, Bhogal does not explicitly disclose the grill heater including: a plurality of straight sections arranged in parallel, and a plurality of curved sections connecting the plurality of straight sections; wherein portions of at least some of the plurality of straight sections and portions of at least some of the plurality of curved sections are configured as detour sections bypassing a photographing area of the camera module, a light irradiation area of the first lighting module, and a light irradiation area of the second lighting module so that the grill heater does not interfere with the photographing area, the light irradiation area of the first lighting module, and the light irradiation area of the second lighting module. Young discloses a similar oven device including heater located at the top of the heating cavity , the heater including: a plurality of straight sections A arranged in parallel, and a plurality of curved sections B connecting the plurality of straight sections . It would have been obvious to one of skill in the art to modify the Bhogal device to substitute the heating element configuration of Young at least under KSR rationales A or B above, by making such a substitution, arriving at a configuration wherein portions of at least some of the plurality of straight sections A and portions of at least some of the plurality of curved sections B are configured as detour sections bypassing a photographing area C of the camera module, a light irradiation area of the first lighting module, and a light irradiation area of the second lighting module so that the grill heater does not interfere with the photographing area, the light irradiation area of the first lighting module, and the light irradiation area of the second lighting module. 9 . The cooking device of claim 1, wherein the camera module 710 is disposed along a center line X of the upper portion of the cooking chamber in a front-back direction. 11 . The cooking device of claim 1, wherein the first and the second lighting modules are disposed in alignment with the camera module. See figure 9 13 . The cooking device of claim 1, wherein a radiation angle at which the first and the second lighting modules radiate light is 80° or more. See Figure 9 14 . The cooking device of claim 1, wherein the photographing area of the camera module covers a plane size of a middle height of the cooking chamber. See Figure 9 15 . The cooking device of claim 1, wherein the light irradiation area of the first lighting module and the light irradiation area of the second lighting module each cover at least half of a plane size of a middle height of the cooking chamber. See Figure 9 Claim (s) 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bhogal (US 2020/0278117A1) in view of Young et al (US 3585360) and Ebert et al. (US 2019/0242584A1) . Bhogal in view of Young discloses the claimed invention as discussed above except in reference to claim: 10 . The cooking device of claim 9, further comprising: wherein the camera module is disposed closer to the door along the center line than to a back of the cooking chamber. Ebert discloses an oven including a camera and illumination source similar to Bhogal and including wherein the camera module 7 is disposed closer to the door 5 along the center line than to a back of the cooking chamber . At least under KSR rationale A or B above, one of skill in the art would find it obvious to inform the front to back camera position of Ebert for that of Bhogal since Bhogal does not provide a front to back position relative to the door. Claim (s) 2-8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bhogal (US 2020/0278117A1) in view of Young et al (US 3585360) and Wurm et al. (US 2001/0020612A1) . Bhogal in view of Young only fall short of teaching the specific shape of the heating element, however, a modification involving a mere change in size or shape of a component is generally recognized as being within the level of ordinary skill in the art . As such the question of obviousness becomes one of where the artisan having the knowledge, common sense, and creativity normally brought to bear when considering modifications and combinations would choose to modify the shape/size of the heating element. Wurm discloses a similar oven device having along the top side of the heating cavity a shaped heating element 5 having both parallel straight sections and curved connecting sections therebetween and further where the sections are formed to bypass areas of the cavity aligned with other functional components, so as not to interfere therewith. As such one of skill in the art would find it an obvious matter of design choice to modify the shape and spacing of the heating element provided at the top to the oven cavity such that a functional components —such as the camera and lighting modules of Bhogal —are not interfered with by the heating element while also providing a heating element that provides good area coverage for uniform heating of the cavity. Claim (s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bhogal (US 2020/0278117A1) in view of Young et al (US 3585360) and Erbe et al. (US 2017/0115008A1) and Jang et al. ( US 20210018182 A1 ) Bhogal in view of Young discloses the claimed invention as discussed above except in reference to claim: 12 . The cooking device of claim 1, wherein the main body includes: an electrical chamber positioned above the cooking chamber so as to be separated from the cooking chamber, and the camera module includes: a camera disposed in the electrical chamber to face the cooking chamber, a first glass positioned in the upper portion of the cooking chamber so as to block heat transfer from the cooking chamber to the camera, a second glass positioned between the camera and the first glass so as to block the heat transfer to the camera, and a third glass positioned between the camera and the second glass so as to block the heat transfer to the camera. Erbe discloses a similar oven device wherein the main body 4 includes: an electrical chamber Q positioned above the cooking chamber so as to be separated from the cooking chamber, and the camera module 2 includes: a camera disposed in the electrical chamber Q to face the cooking chamber 6 , a first glass (viewing window 11) positioned in the upper portion of the cooking chamber so as to block heat transfer from the cooking chamber to the camera . Erbe does not disclose a second and third window to assist in blocking heat, however, the mere duplication of functional elements to increase functionality or to provide for redundancy involves only routine skill in the art and such a modification would be obvious to the skilled artisan . Additionally, Jang discloses the use of multiple glass windows (at least three ) to provide for thermal protection. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT THOR S CAMPBELL whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)272-4776 . The examiner can normally be reached FILLIN "Work Schedule?" \* MERGEFORMAT M,W -F 6:30-10:30, 12-4 . 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, FILLIN "SPE Name?" \* MERGEFORMAT Ibrahime Abraham can be reached at FILLIN "SPE Phone?" \* MERGEFORMAT 5712705569 . 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. FILLIN "Examiner Stamp" \* MERGEFORMAT /THOR S CAMPBELL/ Primary Examiner Art Unit 3761 tsc
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Prosecution Timeline

Jul 28, 2023
Application Filed
Mar 11, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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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
75%
Grant Probability
76%
With Interview (+0.8%)
3y 1m
Median Time to Grant
Low
PTA Risk
Based on 1276 resolved cases by this examiner. Grant probability derived from career allow rate.

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