Prosecution Insights
Last updated: April 19, 2026
Application No. 18/233,533

THERMAL MANAGEMENT SYSTEM FOR AN AIRCRAFT WITH A HEAT EXCHANGER THAT TRANSFERS WASTE HEAT ENERGY

Final Rejection §103§112
Filed
Aug 14, 2023
Examiner
LISOWSKI, JACEK
Art Unit
3741
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Rolls-Royce
OA Round
4 (Final)
65%
Grant Probability
Favorable
5-6
OA Rounds
3y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 65% — above average
65%
Career Allow Rate
143 granted / 219 resolved
-4.7% vs TC avg
Strong +43% interview lift
Without
With
+42.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
20 currently pending
Career history
239
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
56.5%
+16.5% vs TC avg
§102
14.5%
-25.5% vs TC avg
§112
26.3%
-13.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 219 resolved cases

Office Action

§103 §112
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 . Response to Amendment This Office Action is responsive to the amendment filed on 02/26/2026. Claims 1-10 and 13-14 are examined. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-10 and 13-14 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the applicant, regards as the invention. Regarding Claims 1 and 13, the recitation “the first ancillary system is either a power converter that controls the first electric machine or a battery” (ll. 14-15 in claim 1, ll. 9-10 in claim 13) renders the claim indefinite because it is unclear if the first ancillary system is supposed to be a battery because applicant previously argued, in arguments filed 09/04/2025, that Rambo’s energy storage unit 140 [battery] does not read as “the first ancillary system” because energy storage unit 140 does not create waste heat energy that is transferred to the first heat transfer fluid in a first thermal bus, as required in claims 1 and 13. Therefore, it is unclear if “a battery” is supposed to be an option as a “first ancillary system”. Therefore, the scope of the claim is unascertainable. The foregoing is interpreted in accordance with the claim rejections below. Claims 2-10 are rejected under 35 U.S.C. 112(b) based on their dependency on claim 1. Claim 14 is rejected under 35 U.S.C. 112(b) based on their dependency on claim 13. 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 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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. Claims 1-2, 4, and 13-14 are rejected under 35 U.S.C. 103 as being unpatentable over Brookes 2021/0071573 in view of Niergarth 2019/0153953 and further in view of Malkamaki 2018/0252158. Regarding Claim 1, as best understood, Brookes teaches an aircraft (electric aircraft) ([0003]) a first gas turbine engine 101 (Fig. 1), a first electric machine 111 rotatably coupled to the first gas turbine engine 101 ([0081, 0083]; Fig. 1). Brookes does not teach a thermal management system for the aircraft, thermal management system comprising a first thermal bus, a first heat exchanger, and a first ancillary system; the first thermal bus comprises a first heat transfer fluid, the first heat transfer fluid being in fluid communication, in a closed loop flow sequence, between the first electric machine, the first gas turbine engine, the first heat exchanger, and the first ancillary system, such that waste heat energy that is created by each of the first gas turbine engine, the first electric machine, and the first ancillary system, is transferred to the first heat transfer fluid, the first heat exchanger is configured to transfer the waste heat energy from the first heat transfer fluid to a dissipation medium, the first ancillary system is either a power converter that controls the first electric machine or a battery. Niergarth teaches a thermal management system (Fig. 2) for the aircraft, thermal management system (Fig. 2) comprising a first thermal bus 102, and a first heat exchanger 108, [a] ([0051; 0056-57; 0059]; Annotated Fig. 2, below), the first thermal bus comprises a first heat transfer fluid (pump 104 may generate a flow of the heat exchange fluid) ([0056]), the first heat transfer fluid (fluid in loop 102) being in fluid communication, in a closed loop flow sequence (closed loop 102), between the first electric machine 106, [b] ([b] is one of three heat sources 106 interpreted to be a heat source from the first electric machine), the first gas turbine engine 106, [c] ([c] is the other of the three heat sources 106 interpreted to be the heat source from the first gas turbine engine), the first heat exchanger 108, [a], and the first ancillary system 106, [d] ([d] is a heat exchanger 106 that can be an electronics cooling system heat exchanger for transferring heat from an electronics cooling system 88. This is interpreted and reads as the first ancillary system) ([0051-52; 0056-57; 0059]; Annotated Fig. 2, below. Niergarth teaches in [0051-52, 0057] that the heat source 106 is a first electric machine because the heat source can be from a generator lubrication system 84 for cooling/heat removal for the electronic generator; and the other heat source 106 is a first gas turbine because the heat sources can be from various sources such as a compressor cooling air system CCA 80, which is from the first gas turbine engine. Furthermore, Niergarth teaches that the heat exchanger 106 [d] that can be an electronics cooling system heat exchanger for transferring heat from an electronics cooling system 88. This is interpreted and reads as the first ancillary system that creates waste energy heat that is transferred to the first heat transfer fluid in the first thermal bus), such that waste heat energy that is created by each of the first gas turbine engine 106, [c] (waste heat from one of the heat sources 106 being a compressor cooling air system 80), the first electric machine 106, [b] (waste heat from another one of the heat sources 106 being a generator lubrication system 84), and the first ancillary system 106, [d] ([d] electronics cooling system heat exchanger for transferring heat from an electronics cooling system) is transferred to the first heat transfer fluid (fluid in loop 102) ([0057]; Fig. 2), and the first heat exchanger 108, [a] is configured to transfer the waste heat energy from the first heat transfer fluid (fluid in loop 102) to a dissipation medium (ram air is the dissipation medium part of the ram air heat exchanger 108) ([0059]; Fig. 2. The heat sink heat exchanger 108 for transferring heat from the heat exchange fluid in the thermal transport bus 102, e.g., to atmosphere; for example, heat sink exchanger 108 includes a RAM air heat exchanger, thus the dissipation medium being the RAM air). PNG media_image1.png 715 932 media_image1.png Greyscale Figure A: Annotated Fig. 2 of Niergarth (U.S. 2019/0153953) It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to provide the first gas turbine engine 101 of Brookes to include Niergarth’s thermal management system comprising a first thermal bus 102, and a first heat exchanger 108, [a]; the first heat transfer fluid (fluid in loop 102) being in fluid communication, in a closed loop flow sequence (closed loop 102), between the first electric machine 106, [b] ([b] is one of three heat sources 106 interpreted to be a heat source from the first electric machine), the first gas turbine engine 106, [c] ([c] is the other of the three heat sources 106 interpreted to be the heat source from the first gas turbine engine), the first heat exchanger 108,[a], and the first ancillary system 106, [d] ([d] is a heat exchanger 106 that can be an electronics cooling system heat exchanger for transferring heat from an electronics cooling system 88. This is interpreted and reads as the first ancillary system), such that waste heat energy that is created by each of the first gas turbine engine 106, [c] (waste heat from one of the heat sources 106 being a compressor cooling air system 80), and the first electric machine 106, [b] (waste heat from another one of the heat sources 106 being a generator lubrication system 84), and the first ancillary system 106, [d] ([d] electronics cooling system heat exchanger for transferring heat from an electronics cooling system) is transferred to the first heat transfer fluid (fluid in loop 102), and the first heat exchanger 108, [a] is configured to transfer the waste heat energy from the first heat transfer fluid (fluid in loop 102) to a dissipation medium (ram air is the dissipation medium part of the ram air heat exchanger 108), in order to provide efficient cooling of high temperature components (compressor cooling air and electric machine/generator) during operation of the gas turbine engine and provide more efficient management of thermal needs of the gas turbine engine (Niergarth [0085]). Brookes in view of Niergarth does not teach the first ancillary system is either a power converter that controls the first electric machine or a battery. Malkamaki teaches (in [0097]; Fig. 1) that power electronics unit can include frequency converters, rectifiers, or inverters (interpreted as a power converter) connected to electrical generators used for converting power with desired frequency such as the frequency of an AC load. ([0097]; Fig. 1. This is interpreted as a power converter being part of an electronics system, and therefore, reads as the first ancillary system that is a power converter, as claimed.). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the first ancillary system 106, [d] of Brookes in view of Niergarth to include the first ancillary system that is a power converter (frequency converters, rectifiers, or inverters), as part of Niergarth’s electronics cooling system 88, as taught by Malkamaki, in order to provide the desired frequency of an AC load (Malkamaki, [0097). Regarding Claim 2, Brookes in view of Niergarth and Malkamaki teaches the invention as claimed and as discussed above for claim 1. However, Brookes in view of Niergarth and Malkamaki, as discussed so far, does not teach the first thermal bus is arranged in a recirculatory ring configuration with the first heat transfer fluid passing through each of the first gas turbine engine, the first electric machine, the first heat exchanger, and the first ancillary system. However, Brookes in view of Niergarth and Malkamaki, as discussed so far, teaches the thermal management system comprising Brookes first gas turbine engine 101, first electric machine 111, Niergarth’s first thermal bus 102 comprising a first heat transfer fluid (fluid in loop 102), heat exchanger 108, [a] and Malkamaki’s first ancillary system 106, [d]. Therefore, Brookes in view of Niergarth and Malkamaki’s first thermal bus 102 is arranged in a recirculatory ring configuration (loop 102 makes up the recirculatory ring) with the first heat transfer fluid (fluid in loop 102) passing through each of the first gas turbine engine 101, the first electric machine 111, the first heat exchanger 108,[a], and the first ancillary system 106,[d], as claimed. Regarding Claim 4, Brookes in view of Niergarth and Malkamaki teaches the invention as claimed and as discussed above for claim 1, and Brookes further teaches the first gas turbine engine 101 comprises, in axial flow sequence (seen in Fig. 1), a compressor module 104, a combustor module 106, and a turbine module 107 ([0076]; Fig. 1). Brookes in view of Niergarth and Malkamaki, as discussed so far, does not teach the dissipation medium is a fuel flow passing through the first heat exchanger and subsequently being directed to the combustor module. Niergarth further teaches the dissipation medium is a fuel flow (medium can be a fuel in a fuel heat exchanger 108) passing through the first heat exchanger 108, [a] and subsequently being directed (the fuel is then directed) to the combustor module 26 ([0059; Fig. 2). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention modify the dissipation medium of Brookes in view of Niergarth and Malkamaki with Niergarth’s dissipation medium that is a fuel flow (medium can be a fuel in a fuel heat exchanger 108) passing through the first heat exchanger 108, [a] and subsequently being directed (the fuel is then directed) to the combustor module 26, for the same reason as discussed in rejection of claim 1 above. Regarding Claim 13, as best understood, Brookes teaches an aircraft (electric aircraft) ([0003]) a first gas turbine engine 101 (Fig. 1), a first electric machine 111 rotatably coupled to the first gas turbine engine 101 ([0081, 0083]; Fig. 1). Brookes does not teach a method of operating a thermal management system for an aircraft, the thermal management system comprising a first heat exchanger, and one or more first ancillary systems, the method comprising the steps of: (i) providing a first thermal bus comprising a first heat transfer fluid with the first heat transfer fluid providing fluid communication, in a closed loop flow sequence, between the first electric machine, the first gas turbine engine, the first heat exchanger, and the first ancillary system, the first ancillary system is either a power converter that controls the first electric machine or a battery; (ii) transferring a waste heat energy generated that is created by each of the first gas turbine engine, the first electric machine, and the first ancillary system, to the first heat transfer fluid; and (iii) transferring the waste heat energy from the first heat transfer fluid to a dissipation medium. Niergarth teaches a method of operating a thermal management system (seen in Fig. 2) for an aircraft, the thermal management system comprising a first thermal bus 102 a first heat exchanger 108, [a] ([0051; 0056-57; 0059]; Annotated Fig. 2, below), the method comprising the steps of: (i) providing a first thermal bus 102 comprising a first heat transfer fluid (pump 104 may generate a flow of the heat exchange fluid) with the first heat transfer fluid (fluid in loop 102) providing fluid communication, in a closed loop flow sequence (closed loop 102), between the first electric machine 106, [b] ([b] is one of three heat sources 106 interpreted to be a heat source from the first electric machine), the first gas turbine engine 106, [c] ([c] is the other of the three heat sources 106 interpreted to be the heat source from the first gas turbine engine), the first heat exchanger 108, [a], and the first ancillary system 106, [d] ([d] is a heat exchanger 106 that can be an electronics cooling system heat exchanger for transferring heat from an electronics cooling system 88. This is interpreted and reads as the first ancillary system) ([0051-52; 0056-57; 0059]; Annotated Fig. 2, below. Niergarth teaches in [0051, 0057] that the heat source 106 is a first electric machine because the heat source can be from a generator lubrication system 84 for cooling/heat removal for the electronic generator; and the other heat source 106 is a first gas turbine because the heat sources can be from various sources such as a compressor cooling air system CCA 80, which is from the first gas turbine engine. Furthermore, Niergarth teaches that the heat exchanger 106 [d] that can be an electronics cooling system heat exchanger for transferring heat from an electronics cooling system 88. This is interpreted and reads as the first ancillary system that creates waste energy heat that is transferred to the first heat transfer fluid in the first thermal bus); (ii) transferring a waste heat energy that is created by each of the first gas turbine engine 106, [c] (waste heat from one of the heat sources 106 being a compressor cooling air system 80), the first electric machine 106, [b] (waste heat from another one of the heat sources 106 being a generator lubrication system 84), and the first ancillary system 106, [d] ([d] electronics cooling system heat exchanger for transferring heat from an electronics cooling system) to the first heat transfer fluid (fluid in loop 102) ([0057]; Fig. 2); and (iii) transferring the waste heat energy from the first heat transfer fluid (fluid in loop 102) to a dissipation medium (ram air is the dissipation medium part of the ram air heat exchanger 108, [a]) ([0059]; Fig. 2. The heat sink heat exchanger 108 for transferring heat from the heat exchange fluid in the thermal transport bus 102, e.g., to atmosphere; for example, heat sink exchanger 108 includes a RAM air heat exchanger, thus the dissipation medium being the RAM air). PNG media_image1.png 715 932 media_image1.png Greyscale Figure A: Annotated Fig. 2 of Niergarth (U.S. 2019/0153953) It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to provide the first gas turbine engine 101 of Brookes to include Niergarth’s thermal management system comprising a first thermal bus 102, and a first heat exchanger 108, [a] and the method comprising the steps of: (i) providing a first thermal bus 102 comprising a first heat transfer fluid (pump 104 may generate a flow of the heat exchange fluid) with the first heat transfer fluid (fluid in loop 102) providing fluid communication, in a closed loop flow sequence (closed loop 102), between the first electric machine 106, [b] ([b] is one of three heat sources 106 interpreted to be a heat source from the first electric machine), the first gas turbine engine 106, [c] ([c] is the other of the three heat sources 106 interpreted to be the heat source from the first gas turbine engine), the first heat exchanger 108, [a], and the first ancillary system 106, [d] ([d] is a heat exchanger 106 that can be an electronics cooling system heat exchanger for transferring heat from an electronics cooling system 88. This is interpreted and reads as the first ancillary system); (ii) transferring a waste heat energy that is created by each of the first gas turbine engine 106, [c] (waste heat from one of the heat sources 106 being a compressor cooling air system 80), the first electric machine 106, [b] (waste heat from another one of the heat sources 106 being a generator lubrication system 84), and the first ancillary system 106, [d] ([d] electronics cooling system heat exchanger for transferring heat from an electronics cooling system) to the first heat transfer fluid (fluid in loop 102); and (iii) transferring the waste heat energy from the first heat transfer fluid (fluid in loop 102) to a dissipation medium (ram air is the dissipation medium part of the ram air heat exchanger 108, [a]), for the same reason as discussed in rejection of claim 1 above. Brookes in view of Niergarth does not teach the first ancillary system is either a power converter that controls the first electric machine or a battery. Malkamaki teaches (in [0097]; Fig. 1) that power electronics unit can include frequency converters, rectifiers, or inverters (interpreted as a power converter) connected to electrical generators used for converting power with desired frequency such as the frequency of an AC load. ([0097]; Fig. 1. This is interpreted as a power converter being part of an electronics system, and therefore, reads as the first ancillary system that is a power converter, as claimed.). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the first ancillary system 106, [d] of Brookes in view of Niergarth to include the first ancillary system that is a power converter (frequency converters, rectifiers, or inverters), as part of Niergarth’s electronics cooling system 88, as taught by Malkamaki, for the same reason as discussed in rejection of claim 1 above. While Brookes in view of Niergarth and Malkamaki teaches an apparatus, if a prior art device, in its normal and usual operation, would necessarily perform the method claimed, then the method claimed will be considered an obvious extension of prior art teachings. Regarding Claim 14, Brookes in view of Niergarth and Malkamaki teaches the method as claimed and as discussed above for claim 13. Brookes in view of Niergarth and Malkamaki, as discussed so far, does not teach the first thermal bus is arranged in a recirculatory ring configuration with the first heat transfer fluid passing through each of the first gas turbine engine, the first electric machine, the first heat exchanger, and the first ancillary system. However, Brookes in view of Niergarth and Malkamaki, as discussed so far, teaches the thermal management system comprising Brookes first gas turbine engine 101, first electric machine 111, Niergarth’s first thermal bus 102 comprising a first heat transfer fluid (fluid in loop 102), heat exchanger 108, [a] and Malkamaki’s first ancillary system 106, [d]. Therefore, Brookes in view of Niergarth and Malkamaki’s first thermal bus 102 is arranged in a recirculatory ring configuration (loop 102 makes up the recirculatory ring) with the first heat transfer fluid (fluid in loop 102) passing through each of the first gas turbine engine 101, the first electric machine 111, the first heat exchanger 108,[a], and the first ancillary system 106,[d], as claimed. Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Brookes in view of Niergarth and Malkamaki, as applied to claim 1, and further in view of Marchaj 2021/0270148 Regarding Claim 3, Brookes in view of Niergarth and Malkamaki teaches the invention as claimed and as discussed above for claim 1, and Brookes further teaches the first gas turbine engine 101 comprises, in axial flow sequence (seen in Fig. 1), a compressor module 104, a combustor module 106, and a turbine module 107 ([0076]; Fig. 1). Brookes in view of Niergarth and Malkamaki, as discussed so far, does not teach the dissipation medium is an inlet air flow passing through the first heat exchanger and entering the compressor module. Niergarth further teaches the dissipation medium is an inlet air flow (ram air) passing through the first heat exchanger 108, [a] ([0059; Fig. 2 The heat sink heat exchanger 108 for transferring heat from the heat exchange fluid in the thermal transport bus 102, e.g., to atmosphere; for example, heat sink exchanger 108 includes a RAM air heat exchanger, thus the dissipation medium being the RAM air). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention modify the dissipation medium of Brookes in view of Niergarth and Malkamaki to be an inlet air flow (ram air) as taught by Niergarth, for the same reason as discussed in rejection of claim 1 above. Brookes in view of Niergarth and Malkamaki does not teach the first gas turbine engine comprises, in axial flow sequence, the first heat exchanger upstream of the compressor module. Marchaj teaches a gas turbine engine (Fig 1) in axial flow sequence a heat exchanger 110 (fan inlet guide vanes 110, Para 0040, where a thermal bus 99 carrying a heat transfer coolant for lubrication oil is positioned within the vanes 110, Para 0043, thus the vanes 110 are functionally equivalent to a heat exchanger with fan inlet air being the dissipation medium) upstream of a compressor module 24 ([0034; 0040; 0043]; Fig. 1. Marchaj teaches a heat exchanger 110 that is a fan inlet guide vanes 110 where a thermal bus 99 carrying a heat transfer coolant for lubrication oil is positioned within the vanes 110, thus the vanes 110 are functionally equivalent to a heat exchanger with fan inlet air being the dissipation medium). Brookes in view of Niergarth, Malkamaki, and Marchaj, as discussed so far does not teach the first gas turbine engine comprises, in axial flow sequence, the first heat exchanger, a compressor module, a combustor module, and a turbine module, and the dissipation medium is an inlet air flow passing through the first heat exchanger and entering the compressor module. However, Brookes in view of Niergarth, Malkamaki, and Marchaj, teaches Brooke’s first gas turbine engine 101 that comprises, in axial flow sequence, Marchaj’s heat exchanger 110 arranged upstream of Brooke’s compressor module 104, a combustor module 106, and a turbine module 107, and having Niergarth’s dissipation medium that is an inlet air flow (ram air) passing through Marchaj’s first heat exchanger 110 and entering the compressor module 104, as claimed. It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to provide the first gas turbine engine 101 of Brookes in view of Niergarth and Malkamaki to include a plurality in fan inlet guide vanes 110, as taught by Marchaj, and configured the fan inlet guide vanes 110 to be a heat exchanger 110, as suggested and taught by Marchaj, to be in axial flow sequence with the compressor module in Brookes in view of Niergarth and Malkamaki, because the fan inlet guide vanes can provide several benefits being to aerodynamically guide the inlet airflow into the fan as well as using cold ambient air as a dissipation medium to cool the heat transfer fluid, effectively cooling the lubrication oil. Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Brookes in view of Niergarth and Malkamaki, as applied to claim 1, and further in view of Juchymenko 2020/0308992. Regarding Claim 5, Brookes in view of Niergarth and Malkamaki teaches the invention as claimed and as discussed above for claim 1. However, Brookes in view of Niergarth and Malkamaki does not teach the first heat transfer fluid is a water/glycol mix. Juchymenko teaches the heat transfer fluid (thermal fluid) is a water/glycol mix (water/glycol mixture) and that it can be used in the engine and in more than one loops ([0198]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the first heat transfer fluid (fluid in loop 102) of Brookes in view of Niergarth and Malkamaki with Juchymenko’s heat transfer fluid (thermal fluid) is a water/glycol mix (water/glycol mixture), because it was known in the art to use water/glycol mixture in several loops in an engine as part of the heat transfer management (Juchymenko [0198]). Claims 6-7 are rejected under 35 U.S.C. 103 as being unpatentable over Brookes in view of Niergarth and Malkamaki, and further in view of Andres 2011/0219786. Regarding Claim 6, Brookes in view of Niergarth and Malkamaki teaches the invention as claimed and as discussed above for claim 1. However, Brookes in view of Niergarth and Malkamaki does not teach the thermal management system further comprises a vapour compression system, a second ancillary system, and a second heat exchanger, and wherein waste heat energy generated by the second ancillary system is transferred to a second heat transfer fluid, the second heat exchanger is configured to transfer the waste heat energy from the second heat transfer fluid circuit to the first heat transfer fluid circuit, the first heat transfer fluid being in fluid communication, in a closed loop flow sequence, between the first electric machine, the first gas turbine engine, the first heat exchanger, the second heat exchanger, and the first ancillary system, and the vapour compression system is configured to increase a temperature of the second heat transfer fluid having passed through the second ancillary system to a value greater than a temperature of the first heat transfer fluid entering the second heat exchanger, such that waste heat energy generated by the second ancillary system can be transferred to the first heat transfer fluid. Andres teaches the thermal management system further (seen in Fig. 2) comprises a vapour compression system 22 a second ancillary system 130, and a second heat exchanger 140, and waste heat energy generated by the second ancillary system 130 is transferred to a second heat transfer fluid (fluid in line 134a, line 134a part of system 22) (Fig. 2), the second heat exchanger 145 is configured to transfer the waste heat energy from the second heat transfer fluid circuit 22 (loop 22 comprised of lines 142, 126a-b, 128, 134a-b, 138) to the first heat transfer fluid circuit (circuit made of lines 78, 48 going through heat exchanger 140) (Fig. 2), and the vapour compression system 22 is configured to increase a temperature of the second heat transfer fluid (loop 22 comprised of lines 142, 126a-b, 128, 134a-b, 138) having passed through the second ancillary system 130 to a value greater than a temperature of the first heat transfer fluid 78, 48 entering the second heat exchanger 140, such that waste heat energy generated by the second ancillary system 130 can be transferred to the first heat transfer fluid 78, 48 ([0007; 0013-17]); Fig. 2). Brookes in view of Niergarth, Malkamaki, and Andres, as discussed so far, does not teach the first heat transfer fluid being in fluid communication, in a closed loop flow sequence, between the first electric machine, the first gas turbine engine, the first heat exchanger, the second heat exchanger, and the first ancillary system. However, Brookes in view of Niergarth, Malkamaki, and Andres teaches a thermal management system for the aircraft (aircraft), thermal management system comprising Brookes first gas turbine engine 101, first electric machine 111, Niergarth’s first thermal bus 102 comprising a first heat transfer fluid (fluid in loop 102), heat exchanger 108, [a], Malkamaki’s first ancillary system 106, [d], and Andres’ vapour compression system 22 having second ancillary system 130, and a second heat exchanger 140. Therefore, Brookes in view of Niergarth, Malkamaki, and Andres’ the thermal management system comprises the first heat transfer fluid (fluid in loop 102) is in fluid communication, in a closed loop flow sequence, between the first electric machine 111, the first gas turbine engine 101, the first heat exchanger 108, [a], the second heat exchanger 140, and the first ancillary system 106, [d], as claimed. It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to provide the thermal management system of Brookes in view of Niergarth and Malkamaki to include Andres’ vapour compression system 22, the second ancillary system 130, and a second heat exchanger 140, in order to increase the temperature of the fluid passing through the heat exchanger 140 (Andres, [0017]). Regarding Claim 7, Brookes in view of Niergarth, Malkamaki, and Andres teaches the invention as claimed and as discussed above for claim 6. However, Br Brookes in view of Niergarth, Malkamaki, and Andres, as discussed so far, does not teach the vapour compression system employs a vapour-compression cycle or an air-compression cycle. Andres further teaches the vapour compression system 22 employs a vapour-compression cycle or an air-compression cycle 22 (vapor compression system 22 is an air compression cycle as fluid gets compressed though compressor 136 as part of the system 22) ([0016]; Fig. 2). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the vapour compression system 22 of Brookes in view of Niergarth, Malkamaki, and Andres with Andres’ the vapour compression system 22 employs a vapour-compression cycle or an air-compression cycle 22, for the same reason as discussed in rejection of claim 6 above. Claims 8-9 are rejected under 35 U.S.C. 103 as being unpatentable over Brookes in view of Niergarth and Malkamaki, and further in view of Owoeye 2023/0349328. Regarding Claim 8, Brookes in view of Niergarth and Malkamaki teaches the invention as claimed and as discussed above for claim 1, and Brookes further teaches the first gas turbine engine 101 is a first turbofan gas turbine engine 101 (seen in Fig. 1), the turbofan gas turbine engine 101 comprising, in axial flow sequence, a fan module 102, a compressor module 104, a combustor module 106, and a turbine module 107, the fan module 102 comprising at least one fan stage having a plurality of fan blades 102 extending radially from a hub (hub housing gearbox 109 and fan shaft 110), the plurality of fan blades defining a fan diameter (DFAN) (interpreted to be the diameter of the fan 102) ([0076]; Fig. 1). Brookes in view of Niergarth and Malkamaki does not teach the fan diameter DFAN is within the range of 0.3m to 2.0m. Owoeye teaches a fan assembly 134 (Fig. 1) having a plurality of fan blades, the fan diameter DFAN is within the range of 0.3m to 2.0m (fan diameter of fan 134 is between 0.7 m and 3.5 m) ([0067]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the fan blades 102 of Brookes in view of Niergarth and Malkamaki to have a fan diameter between 0.7 m and 3.5 m, which is within the range of 0.3m to 2.0m, as taught by Owoeye, because in the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" (in this case, the range taught by Owoeye is 0.7 – 3.5 m which overlaps with the claimed range 0.3 – 2.0 m), a prima facie case of obviousness exists. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976). Regarding Claim 9, Brookes in view of Niergarth, Malkamaki, and Owoeye teaches the invention as claimed and as discussed above for claim 8, and Brookes further teaches the first turbofan gas turbine engine further comprises an outer casing (nacelle/outer casing, annotated in Fig 1), the outer casing enclosing the sequential arrangement of fan module 102, compressor module 104, combustor module 106, and turbine module 107 ([0076]; Fig. 1), an annular bypass duct (bypass duct B, annotated in Fig 1) being defined between the outer casing (outer casing) and the sequential arrangement of compressor module 104, combustor module 106, and turbine module 107, a bypass ratio being defined as a ratio of a mass air flow rate through the bypass duct (the amount of air within bypass duct B) to a mass air flow rate through the sequential arrangement of compressor module 104, combustor module 106, and turbine module 107 (the amount of air C entering the core engine inlet at compressor 104; since the engine 101 has both the bypass flow B and the core flow C, the ratio between these flows is interpreted to be the bypass ratio). Brookes in view of Niergarth, Malkamaki, and Owoeye, as discussed so far, does not teach the bypass ratio is less than 4.0. Owoeye further teaches a gas turbine engine (Fig 1) having a bypass ratio, the bypass ratio is less than 4.0 (the bypass ratio being the ratio of mass flow rate of the bypass air 158 to mass flow rate of core engine 106 can be between 3 and 20 or 3 and 10 ([0068]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the bypass ratio of Brookes in view of Niergarth, Malkamaki, and Owoeye to have a ratio between 3 and 20 or 3 and 10, which overlaps with the claimed range of less than 4.0, as taught by Owoeye, because in the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" (in this case, the range taught by Owoeye is 3 – 20 which overlaps with the claimed range of less than 4.0), a prima facie case of obviousness exists. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976). Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Brookes in view of Niergarth, Malkamaki, and Owoeye, as applied to claim 8, and further in view of Coffinberry 2010/00043396. Regarding Claim 10, Brookes in view of Niergarth, Malkamaki, and Owoeye teaches the invention as claimed and as discussed above for claim 8. However, Brookes in view of Niergarth, Malkamaki, and Owoeye, as discusses so far, does not teach the fan module has two or more fan stages, at least one of the fan stages comprising a plurality of fan blades defining the fan diameter DFAN. Owoeye further teaches a fan assembly 134 (Fig. 1) having a plurality of fan blades, the fan diameter DFAN is within the range of 0.3m to 2.0m (fan diameter of fan 134 is between 0.7 m and 3.5 m) ([0067]). Coffinberry teaches the fan module has two or more fan stages (three stage fan 112) ([0020]; Fig. 2). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify the fan assembly 102 of Brookes in view of Niergarth, Malkamaki, and Owoeye to be a three-stage fan, as taught by Coffinberry, because all the claimed elements were known in the prior art (a gas turbine engine with a bypass duct, a fan assembly with three stages) and one skilled in the art could have combined the elements as claimed by known methods (manufacture the fan assembly to have three stages) with no change in their respective functions (the fan assembly to draw in ambient air for the bypass duct and the core engine to produce thrust), and the combination yielded nothing more than predictable results to one of ordinary skill in the art. KSR, 550 U.S. at 416, 82 USPQ2d at 1395. Response to Argument Applicant's arguments, filed on 02/26/2026, with respect to 35 U.S.C. 103 rejections of claims 1-10 and 13-14 have been considered, but are moot because the arguments do not apply to new combination of references used in the current rejection, necessitated by Applicant’s amendment. However, to the extent possible, Applicant’s arguments have been addressed in the body of the rejections at the appropriate locations. Conclusion 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JACEK LISOWSKI whose telephone number is (408) 918-7635. The examiner can normally be reached on Monday - Friday 10 am - 6 pm 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, Phutthiwat Wongwian can be reached on (571) 270-5426. 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. /JACEK LISOWSKI/Examiner, Art Unit 3741 /PHUTTHIWAT WONGWIAN/Supervisory Patent Examiner, Art Unit 3741
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Prosecution Timeline

Aug 14, 2023
Application Filed
Nov 30, 2024
Non-Final Rejection — §103, §112
Mar 05, 2025
Response Filed
Jun 17, 2025
Final Rejection — §103, §112
Sep 03, 2025
Examiner Interview Summary
Sep 03, 2025
Applicant Interview (Telephonic)
Sep 04, 2025
Response after Non-Final Action
Nov 12, 2025
Request for Continued Examination
Nov 14, 2025
Response after Non-Final Action
Nov 15, 2025
Non-Final Rejection — §103, §112
Feb 19, 2026
Examiner Interview Summary
Feb 19, 2026
Applicant Interview (Telephonic)
Feb 26, 2026
Response Filed
Mar 24, 2026
Final Rejection — §103, §112 (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

5-6
Expected OA Rounds
65%
Grant Probability
99%
With Interview (+42.6%)
3y 3m
Median Time to Grant
High
PTA Risk
Based on 219 resolved cases by this examiner. Grant probability derived from career allow rate.

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