DETAILED ACTION
Examiner’s Note
This office action is in response to applicants’ remarks filed September 16, 2025, Claims 1-8 remain pending.
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.
Claims 1-4 are rejected under 35 U.S.C. 103 as being unpatentable over Fujita et al. (KR20110105403, references herein made to the English translation dated March 11, 2025).
Regarding applicants’ claim 1, Fujita et al. disclose a cold-rolled steel sheet comprising in wt. %: C: not more than 0.025%, Si: not more than 0.1%, Mn: 0.05 to 0.5%, P: not more than 0.03%, S: not more than 0.02%, sol.Al: 0.01 to 0.1%, Ti: 0.002 to 0.05%, Nb: 0.002 to 0.05%, B: 0.0001 to 0.005% (paragraphs 0024-0042). Regarding the nitrogen content Fujita et al. provide for exemplary steel sheets having a nitrogen content ranging from 0.0012 to 0.0025 wt.% (Table 1). One of ordinary skill in the art would expect the nitrogen content in the cold-rolled steel sheet to be within the range of the exemplary steel sheets disclosed by Fujita et al.
Fujita et al. do not appear to explicitly disclose the exact compositional ranges claimed including values resulting in a reinforcement index of the exact range of 1.0 to 3.0, however the compositional proportions disclosed overlap those claimed, including values which result in a reinforcement index within the claimed range. One of ordinary skill in the art before the effective filing date of the inventions would have found it obvious to select from the disclosed compositional proportions, including proportions which fall within the claimed range, and which result in a reinforcement index which falls within the claimed range.
Fujita et al. disclose an average ferrite grain size of 15µm or less (paragraph 0050), but do not appear to explicitly disclose a recrystallization ratio, an average grain diameter, or a grain aspect ratio as claimed, however one of ordinary skill in the art would expect substantially identical materials treated in a substantially identical manner to have substantially identical structures. In addition to the compositional proportions discussed above, Fujita et al. disclose a process of manufacturing the cold-rolled steel sheet substantially identical to that disclosed by applicants.
Applicants disclose a hot-rolling step with a finishing temperature of Ar3 or higher, coiling at 600 to 700ºC, cold-rolling at a reduction ratio of 20.0 to 60.0% and annealing the cold-rolled steel sheet at a temperature of 400.0 to 580.0ºC (page 16 line 10 – page 18 line 20).
Fujita et al. disclose hot-rolling with a finishing temperature of Ar3 or higher, coiling at 500 to 650ºC, cold rolling at a reduction ratio that is preferably 30% or more and 75% or less, and annealing at 500 or 600ºC depending on the addition of Nb or Ti (paragraphs 0053-0064).
Given substantially identical materials treated in a substantially identical manner, the cold-rolled steel sheet of Fujita et al. would be expected to have a substantially identical structure to the cold-rolled steel sheet disclosed by applicants, including having a recrystallization ratio and grain aspect ratio within, or at least overlapping, applicants’ claimed range.
Regarding applicants’ claim 2, Fujita et al. disclose that the steel comprises niobium at 0.002 to 0.05 wt.% which overlaps applicants’ claimed range of 0.01 wt.% or less. One of ordinary skill in the art before the effective filing date of the invention would have found it obvious to select from the proportions disclosed by Fujita et al. including values which fall within the presently claimed range.
Regarding applicants’ claim 3, Fujita et al. do not appear to explicitly disclose a dislocation density however, as discussed above, substantially identical materials treated in a substantially identical manner would be expected to have substantially identical structures. The cold-rolled steel sheet of Fujita et al. would therefore be expected to have a dislocation density within, or at least overlapping, applicants’ claimed range.
Regarding applicants’ claim 4, Fujita et al. disclose plating of the cold-rolled steel sheet (paragraph 0065). When plated one or both sides of the sheet would include a plating as required.
Response to Arguments
Applicants’ arguments filed September 16, 2025 have been considered but have not been found to be persuasive.
Applicants argue that obviousness is not established where Fujita et al. is absent a specific example, and absent a specific example it is difficult for one of ordinary skill in the art to derive a particular condition from a broad range. However Fujita is considered as a whole for all that it teaches and is not limited to specific examples. Fujita et al. disclose compositional proportions and production parameters overlapping those claimed by applicants (as discussed in the rejections above). It is within the ordinary level of skill in the art to select from disclosed ranges which would include values which are substantially identical to those disclosed by applicants. Applicants have not provided persuasive evidence that the conditions disclosed could not have resulted in the claimed features. For example, a showing that a critical parameter is not disclosed in the prior art, or that a disclosed parameter necessarily results in a product outside the claims. Alternativity applicants can demonstrate non-obviousness buy demonstrating that a particularly claimed range is critical, such as by a showing of unexpected results (MPEP 2144.01). Absent a showing that the examiner has erred in demonstrating that the overlapping disclosure is substantially identical to that disclosed by applicants, or a showing of unexpected results, the present claims are not found to establish a patentable distinction over Fujita et al., and the rejections of record are maintained.
Conclusion
THIS ACTION IS MADE FINAL. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADAM C KRUPICKA whose telephone number is (571)270-7086. The examiner can normally be reached Monday-Friday 8-5pm EST.
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/Adam Krupicka/Primary Examiner, Art Unit 1784