Prosecution Insights
Last updated: April 19, 2026
Application No. 18/268,568

STEAM COOKING APPARATUS AND METHOD

Non-Final OA §103§112
Filed
Jun 20, 2023
Examiner
JENNISON, BRIAN W
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Koninklijke Philips N V
OA Round
1 (Non-Final)
72%
Grant Probability
Favorable
1-2
OA Rounds
3y 8m
To Grant
94%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
1023 granted / 1426 resolved
+1.7% vs TC avg
Strong +22% interview lift
Without
With
+22.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
56 currently pending
Career history
1482
Total Applications
across all art units

Statute-Specific Performance

§101
3.3%
-36.7% vs TC avg
§103
47.1%
+7.1% vs TC avg
§102
24.9%
-15.1% vs TC avg
§112
20.4%
-19.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1426 resolved cases

Office Action

§103 §112
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 § 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 1-15 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. Claim 1 recites the limitation "another opening" in lines 14 and 16. There is insufficient antecedent basis for this limitation in the claim. The claims should recite, first opening, second opening, third opening, etc… Claim 5 recites the limitation "an opening" in line 5. There is insufficient antecedent basis for this limitation in the claim. Claim 5 recites the limitation "another opening" in lines 14 and 16. There is insufficient antecedent basis for this limitation in the claim. The claims should recite, first opening, second opening, third opening, etc… All other claims are rejected due to their dependency on a rejected claim. 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. Claim(s) 1-4, 7-10, 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hong (US 5,756,974) in view of Rabie et al. (US 2017/0016623), and Xu (CN 1843277) as cited by applicant, with references made to attached machine translation. Regarding claims 1-2, Hong discloses, A cooking apparatus comprising (See Figs 1 and 2) a food chamber (cooking chamber 100); a lid (lid 21); a heating arrangement; (Abstract, “A heater 101 is installed in the cooking chamber.”, See Column 4, Lines 5-15); a circulation system comprising an extraction vent through which air is drawn from inside the food chamber, and a delivery vent arrangement for delivering air to the food chamber (“A duct 50 is mounted at the rear plate 12 having openings 121, 122. The openings 121, 122 are used as the inlet and outlet for the forced circulation air.”, where the 121 is the inlet/ extraction and 122 is the outlet/ delivery, Page 4, Column 4, lines 8-10, “The inlet 121 is formed at the lower portion of the rear plate 12, whilst the outlet 122 is formed at the upper portion of the rear plate 12 as shown in Figure 4.” See Column 4, Lines 8-24; Page 4, Section 5, lines 52-54, “Figure 7 shows the inlet like in Figure 6 except an outlet 122' formed as a larger single opening.”, where in Figure 7, the outlet or delivery vent is located above the extraction vent 121’) and extending across at least half of the width of the rear wall area (Figure 7, where the larger single opening for the delivery vent 122’ spans at least half of the rear wall of the cooking chamber), Hong fails to disclose, an apparatus specifically for steam cooking. However, the claim does not contain any functional language where steam is generated. Hong also fails to disclose, a water reservoir and, wherein the lid is a transparent lid, and comprises a first, inner, glass plate and a second, outer, glass plate separated by an air spacing of at least 5mm, wherein the air spacing has: an opening to a body of the apparatus adjacent a front wall area and another opening to the body of the apparatus adjacent a rear wall area; or an opening to a body of the apparatus adjacent a first side wall area and another opening to the body of the apparatus adjacent a second side wall area, such that the circulation system is for creating a forced airflow through the air spacing. However, Rabie discloses, in the similar field of cooking apparatuses (Abstract, “…automated cooking device…”), where a similar cooking chamber can be used specifically for steam cooking (Para. 0003, “The boiler is structured to controllably inject steam into the cooking chamber.”), where a water reservoir is present to provide water for steam (Para. 0028, “The boiler 218 is structured to boil water stored in the water tank 220 so as to create steam for cooking with "wet heat." Steam may be utilized in a steaming cooking mode or in combination with other cooking modes.”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the cooking apparatus in Hong to include a water reservoir to allow for steam cooking as taught by Rabie. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of providing the user with other cooking modes, where steam can be beneficial to existing cooking modes as well, as stated by Rabie, Para. 0028, “Steam may be utilized in a steaming cooking mode or in combination with other cooking modes.”. Xu discloses, regarding claims 1, 2 and 4, an electronic oven with a cooling system, and specifically discloses (see specification pages 1-3, Figures 1 6): As shown in Figures 1 to 6, the electronic oven with cooling system comprises a box consisting of a bottom panel 16, an outer lid panel 2, an inner lid panel 26 dividing the inner chamber of the box into upper and lower two spaces, a lower space being a high temperature zone 17, an air inlet opening 24 is provided, and the air duct cover plate 11 is connected to the inner cover plate 26 to form the air duct 3. The cooling fan axial intake communicates with the upper chamber of the case, the radial outlet of the fan is relative to the air duct 3, which extends to the top of the door frame, with the upper guide plate 7 connecting the air duct cover plate 11 to the inside of the outer glass layer, in the aperture between the outer glass layer 10, 9, and with the lower guide plate 14 outside the lower end of the inner glass layer, allowing the air to exit forward from the bottom outlet 15 of the door. It would have been obvious to adapt Hong in view of Xu to provide the transparent lid comprising a first, inner, glass plate and a second, outer, glass plate separated by an air spacing of at least 5mm, wherein the air spacing has an opening to a body of the apparatus adjacent a front wall area and another opening to the body of the apparatus adjacent a rear wall area; or an opening to a body of the apparatus adjacent a first side wall area and another opening to the body of the apparatus adjacent a second side wall area, such that the circulation system is for creating a forced airflow through the air spacing for insulating the cooking chamber while simultaneously reducing the temperature of the outer door surface and handle to prevent injury to a user. It would have been obvious to provide the air spacing of at least 5mm and the thickness of the plates to be between 2 mm and 5 mm thick since it has been held that discovering an optimum value of a result effective variable involves only routine skill in the art and where the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. The thickness and spacing would depend on the desired amount of air flow and thermal gradient. Regarding claim 3, Xu discloses the outer surface of the outer plate is flat (See Fig 1, the outer surface is shown as being flat). It would have been obvious to provide the flat surface for providing a uniform surface for uniform air flow. Regarding claim 7, Hong fails to disclose the air spacing being present all around the outer periphery of the lid. However, Xu discloses regarding claim 7, the spacing through the entirety of the panels, including the outer periphery (See Fig 1). Regarding claim 8, the frame 12 supports the inner and outer glass 9 and 10. Regarding claim 9, a rubber seal is used for sealing the glass 9 and 10 to the frame, including the top and bottom portion. It would have been obvious to adapt Hong in view of Xu to provide the air spacing, frame and seal for creating a forced airflow through the air spacing for insulating the cooking chamber while simultaneously reducing the temperature of the outer door surface and handle to prevent injury to a user. Regarding claim 10, the claim does not set forth any structure to indicate how the seal is “adapted to” release overpressure in the food chamber. Limitations for the specification are not to be read into the claims. As the seal is taught in Xu, opening the door or lid could be considered releasing overpressure. Regarding claim 12, Hong discloses, a base, rear wall, opposing walls and front wall area where the vent is in the rear wall as shown in the figures. (See Figs 1-3, with the openings 122 being in the rear wall) Claim(s) 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hong (US 5,756,974) in view of Rabie et al. (US 2017/0016623), Xu (CN 1843277) and Manzoni (GB 2013872) as provided by applicant. The teachings of Hong have been discussed above. Hong as modified fails to disclose, an opening to ambient surroundings adjacent the front wall area and another opening to the ambient surroundings adjacent the rear wall area; or an opening to ambient surroundings adjacent the first side wall area and another opening to the ambient surroundings adjacent the second side wall area, thereby to create a convection airflow through the lid air spacing. Manzoni discloses, Pages 1-3 of the specification, Figures 1 3): Air (as indicated by the arrows in Figures 1 and 2) enters the path 22 through a slot 23 provided along the entire lower edge 4 of the door and exits from a slot 24 provided in the upper area 11 of the frame 7, immediately beyond the upper edge of the outer glazing panel 5 and below the sides 15 of the elongated members 13 and parallel to the glazing panels 5 and 6. While specifically positioning the opening to the ambient environment and the location of another opening to the ambient environment to create convective airflow through the lid air spacing for cooling, is considered obvious in the art. It would have been obvious to adapt Hong as modified in view of Manzoni to provide an opening to ambient surroundings adjacent the front wall area and another opening to the ambient surroundings adjacent the rear wall area; or an opening to ambient surroundings adjacent the first side wall area and another opening to the ambient surroundings adjacent the second side wall area for air circulation and further cooling the front of the glass panel and the handle. Claim(s) 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hong (US 5,756,974) in view of Rabie et al. (US 2017/0016623), Xu (CN 1843277) and Miwa (US 4,617,452). The teachings of Hong have been discussed above. Hong fails to disclose, wherein the lid has a spring-loaded hinge for coupling to the food chamber and a latch arrangement, and the second plate has an actuation area for touching by a user to open the lid by releasing the latch arrangement and to close the lid. Miwa discloses, See Figs 1-4, a lid to a cooking chamber, having a spring-loaded hinge (70, See Abstract) for urging the lid open and a latch for securing the lid to the body. (See Abstract and Column 3, Lines 35-53) It would have been obvious to adapt Hong in view of Miwa to provide the spring-loaded hinge for automatically opening the lid when the latch is unlocked. Claim(s) 13-14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hong (US 5,756,974) in view of Rabie et al. (US 2017/0016623), Xu (CN 1843277) and Popeil et al. (US 2014/0227411). Regarding claim 13, modified Hong does not disclose: wherein the transparent lid is inclined downwardly from the rear wall area towards the front wall area. However, Popeil discloses where the transparent lid can be slanted (Para. 0078, “The transparent portions of the lid may be inclined to minimize buildup of vision obscuring moisture.”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the transparent lid of modified Hong to be slanted or inclined as taught by Popeil. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of minimizing the buildup of vision blocking moisture, which can prevent a user from seeing the food items within the cooking chamber, as stated by Popeil, Para. 0078, “…preferred embodiment may have a lid whose area is over 90% transparent to facilitate viewing of foods being cooked, and thus stimulate appetite appeal, and aid in gauging of food cooking progress. The transparent portions of the lid may be inclined to minimize buildup of vision obscuring moisture.”. Regarding claim 14, modified Hong does not disclose the reflective coating. However, Popeil discloses a nickel coating. Nickel reflects infrared radiation (See Paragraph [1023]) It would have been obvious to adapt Hong in further view of Popeil to provide the reflective coating for preventing corrosion. However, it would also have been obvious to reflect infrared radiation as this is an inherent property of a nickel coating. Claim(s) 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hong (US 5,756,974) in view of Rabie et al. (US 2017/0016623), Xu (CN 1843277) and Hoffman (EP 2390587). The teachings of Hong as modified have been discussed above. Hong in view of Rabie discloses a boiler heating the water to create steam but fails to disclose, a feed arrangement for providing water from the water reservoir into contact with a heated surface of the heating arrangement, more particularly of a first heater of the heating arrangement. Hoffman discloses a feed arrangement 17 for feeding water from water supply 16 for placing the water in contact with the heating arrangement 3 for creating steam. (See Paragraphs [0031]-[0033]) It would have been obvious to adapt Hong as modified in view of Hoffman to provide a feed arrangement for providing water from the water reservoir into contact with a heated surface of the heating arrangement as this is an obvious variant for creating steam in a cooking apparatus. The steam is either created directly or indirectly by the heating element. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to BRIAN W JENNISON whose telephone number is (571)270-5930. The examiner can normally be reached M-Th 9-5. 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, Ibrahime Abraham can be reached at 571-270-5569. 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. /BRIAN W JENNISON/Primary Examiner, Art Unit 3761 2/25/2026
Read full office action

Prosecution Timeline

Jun 20, 2023
Application Filed
Feb 25, 2026
Non-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

1-2
Expected OA Rounds
72%
Grant Probability
94%
With Interview (+22.4%)
3y 8m
Median Time to Grant
Low
PTA Risk
Based on 1426 resolved cases by this examiner. Grant probability derived from career allow rate.

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