Prosecution Insights
Last updated: October 02, 2026
Application No. 18/284,493

COOKING ASSEMBLY FOR A MICROWAVE OVEN

Final Rejection §103
Filed
Sep 27, 2023
Priority
Apr 13, 2021 — nonprovisional of PCTCN2021086944
Examiner
CHOU, JIMMY
Art Unit
Tech Center
Assignee
WHIRLPOOL Corporation
OA Round
2 (Final)
71%
Grant Probability
Favorable
3-4
OA Rounds
2m
Est. Remaining
86%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allowance Rate
617 granted / 869 resolved
+11.0% vs TC avg
Moderate +15% lift
Without
With
+14.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
53 currently pending
Career history
896
Total Applications
across all art units

Statute-Specific Performance

§101
1.0%
-39.0% vs TC avg
§103
46.0%
+6.0% vs TC avg
§102
12.9%
-27.1% vs TC avg
§112
35.9%
-4.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 869 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 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. Claim(s) 1-6, 25-27 and 29 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189). Regarding claim 1, Staun et al. discloses “a microwave oven” (abstract, i.e., a microwave oven and figs.17-18), comprising: “a housing” (100) having “an upper portion, a lower portion, and a cavity defined by the upper portion and the lower portion” (fig.17 shows the cavity 102 having upper portion (chamber above glass 112) and a lower portion (another chamber for accommodate heating element 124)); “a accessory” (126) selectively disposed within “the cavity” (the cavity 102) and having “ a support surface projections defined along the support surface, “the support surface” (annotated fig.18) including “a heating plate” (130) disposed proximate to “the accessory” (126) and operably coupled to “the lower portion of the housing” (130 is coupled to the lower portion of housing), “the heating plate defining at least a portion of a bottom surface of the cavity” (fig.18 shows the heating plate 130 defining at least a portion of a bottom surface of the cavity), the heating plate having an engagement surface” (130 has an upper surface) configured to support the tray thereon” (the upper surface of 130 is capable of supporting an object such as a tray); and “heat conductors” (124) operably coupled to “the heating plate” (130), wherein “the heat conductors” (124) are in thermal communication with “the heating plate” (130). Staun et al. is silent regarding a tray having a peripheral wall and a support surface contiguous between opposing portions of the peripheral wall, the tray having projections defined along the support surface, a tray including a ceramic coating configured to minimize sticking of a food item on the tray; the plate including a metal oxide coating disposed along the engagement surface. Han teaches “a tray” (fig.3, 85) having “a peripheral wall” (annotated fig.3) and a support surface” (annotated fig.3) contiguous between “opposing portions of the peripheral wall” (two opposite side of the peripheral wall), “the tray having projections defined along the support surface” (annotated fig.3). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Han, by adding Han’s tray to Staun et al.’s microwave device, to provide support for food. Park teaches “the tray including a ceramic coating configured to minimize sticking of a food item on the tray” (abstract, i.e., a non-stick ceramic coating layer. [0035] In addition, the heat-cooker according to the present invention is a heat-cooker such as an assembly (i.e., tray, cavity assembly, or the like) … which is configured to have a non-stick ceramic coating layer 40). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Park, by replacing Staun et al.’s accessory with Park’s accessory (i.e., non-stick tray), to provide a holding container with corrosion resistance, abrasion resistance, heat resistance and prevent food from sticking thereto when heating food (para.0001) as taught by Park. The combination of Staun et al. and Park would meet the claim limitation of “a heating plate disposed proximate to the tray” because Staun et al. teaches a heating plate disposed proximate to the accessory. Park teaches the accessory is the tray. It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Park, by replacing Staun et al.’s accessory with Park’s accessory (i.e., non-stick tray), to provide a holding container with corrosion resistance, abrasion resistance, heat resistance and prevent food from sticking thereto when heating food (para.0001) as taught by Park. Cheng et al. teaches “the heating plate” ([0039] The heating plate 2) including “a metal oxide coating disposed along the engagement surface” ([0039] The heating plate 2 … The porous insulating layer 21 is made of an insulating oxide, such as aluminum oxide. Fig.3B, 2 includes 21, 22 and 23. The layer 21 is interpreted as the coating disposed along the engagement surface (refers to the upper surface)). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Cheng et al., by replacing Staun et al.’s heating plate with Cheng et al.’s heating plate, to facilitate thermal energy transmission. PNG media_image1.png 1370 1130 media_image1.png Greyscale PNG media_image2.png 1128 1596 media_image2.png Greyscale Regarding claim 2, modified Staun et al. discloses “the heating plate at least partially defines the lower portion of the housing” (Staun et al., the heating plate 130 defines the lower portion of the housing). Regarding claim 3, modified Staun et al. discloses “the heating plate is configured to project heat via the lower portion of the housing” (Staun et al., the heating plate 130 is capable of project heat via the lower portion of the housing to permits heat radiation from heating element 124). Regarding claim 4, modified Staun et al. discloses “the tray” (Park teaches a tray) is selectively disposed on “the engagement surface of the heating plate” (Staun et al., the upper surface of 130), and wherein “the heat conductors” (Staun et al.,124) are in thermal communication with “the tray via the metal oxide coating disposed on the engagement surface of the heating plate” (Park teaches a tray. Examiner noted that a tray is movable at any position in the chamber. User can manually place the tray on the engagement surface of the heating plate). Regarding claim 5, modified Staun et al. discloses “a power supply” (Staun et al, col.2 at lines 22-34, i.e., an electrical circuit or battery) in electrical communication with “the heat conductors” (Staun et al, 124), wherein “the power supply” (Staun et al, col.2 at lines 22-34, i.e., an electrical circuit or battery) is configured to “define heat along the metal oxide coating of the heating plate via the electrical heat conductors” (Cheng et al., [0039] The heating plate 2 … The porous insulating layer 21 is made of an insulating oxide, such as aluminum oxide. Fig.3B, 2 includes 21, 22 and 23. The layer 21 is interpreted as the coating disposed along the engagement surface (refers to the upper surface)). Regarding claim 6, modified Staun et al. discloses “the housing includes a bottom surface defined by the heating plate, and wherein the bottom surface is a planar surface” (Staun et al, fig.18, 130. fig.18 shows a bottom surface of the chamber defined by the heating plate and the bottom surface is a planar surface). Regarding claim 25, modified Staun et al. discloses “the heating plate is planar along the bottom surface of the housing” (Staun et al., fig.17 shows the heating plate 130 is planar along the bottom surface of the housing). Regarding claim 26, modified Staun et al. discloses “the peripheral wall extends upward and away from a horizontal portion of the support surface” (Han, annotated fig.3 shows the peripheral wall extends upward and away from a horizontal portion of the support surface). Regarding claim 27, modified Staun et al. discloses “a microwave system configured to generate microwaves to heat the food item within the cavity” (abstract, i.e., a microwave oven and a toaster oven apparatus in combination, the toaster oven being contained entirely within the interior of the microwave oven. Col.2 at lines 35-41, i.e., supply microwave energy to heat an item or items to a desired temperature). Regarding claim 29, modified Staun et al. discloses “the housing defines a perimeter frame around the heating plate” (Staun et al., the housing (102 pointed at the housing), the housing which defines a perimeter frame around the heating plate 130), and “the heating plate” (Staun et al., 130) is centrally disposed within “the perimeter frame” (Staun et al., 130 is within 102) to define a bottom surface of the housing” (Staun et al., the bottom surface of housing is at least partially define by the heating plate 130 along with the bottom surface of the housing). Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Theodos et al. (US 20110253698). Regarding claim 7, modified Staun et al. discloses the heating plate to Modified Staun et al. is silent regarding a seal disposed around the heating plate to further define the bottom surface of the housing. Theodos et al. teaches “a seal disposed around the heating plate” ([0060], i.e., a seal to heater plates 112 and 114). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Theodos et al., by modifying Staun et al.’s heating plate with Theodos et al.’s heating plate with seal, to mitigating oil and/or grease migration [0060] as taught by Theodos et al. The combination of Staun et al. with Theodos et al. would meet the claim limitations of “a seal disposed around the heating plate to further define the bottom surface of the housing” because Staun et al. teaches the heating plate to define the bottom surface of the housing. Theodos et al. teaches the seal around the heating plate for sealing purpose. Thus, modified Staun et al. would have seal around heating plate to further define the bottom surface of the housing. It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Theodos et al., by modifying Staun et al.’s heating plate with Theodos et al.’s heating plate with seal, to mitigating oil and/or grease migration [0060] as taught by Theodos et al. Claim(s) 21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Kim (US 7041949). Regarding claim 21, modified Staun et al. discloses all the features of claim limitations as set forth above except for a user interface defined along a front surface of the housing, wherein the user interface includes buttons corresponding to cooking conditions of the microwave oven. Kim teaches “a user interface” (16) defined along “a front surface of the housing” (front surface of 100), wherein “the user interface” (16) includes “buttons” (18) “corresponding to cooking conditions of the microwave oven” (col.3 at lines 10-12, i.e., a plurality of control buttons 18 which controls several functions of the microwave oven). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Kim, by adding Kim’s user interface to Staun et al.’s device, to allow user to control several functions of the microwave oven (col.3) as taught by Kim. Claim(s) 22 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Ye et al. (US 20210231311). Regarding claim 22, modified Staun et al. discloses all the features of claim limitations as set forth above except for the housing includes sidewalls separating the upper portion from the lower portion, the sidewalls including protrusions on which a rack is positioned. Ye et al. teaches “the housing includes sidewalls separating the upper portion from the lower portion” (the housing includes the sidewalls 11, 12 separating the upper portion (i.e., fig.3 shows above 11b is upper portion and below 11b is the lower portion)), “the sidewalls including protrusions on which a rack is positioned” (fig.3 shows the sidewalls including protrusions 11c). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Ye et al., by modifying Staun et al.’s sidewall according to Ye et al.’s sidewall, to allow user to insert tray and easy maintenance. Claim(s) 23 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Yamaguchi et al. (US 5,082,999) and Kim (US 20140322417). Regarding claim 23, modified Staun et al. discloses all the features of claim limitations as set forth above except for the upper portion of the housing defines an opening in which a reflector and a heating tube are disposed, the opening being covered by a grate operably coupled to the upper portion of the housing. Yamaguchi et al. teaches “the upper portion of the housing defines an opening in which a reflector and a heating tube are disposed” (figs.7-8 shows the upper portion of housing defines an opening or a space in which a reflector 32 and a heating tube are disposed 20). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify Staun et al. with Yamaguchi et al., by adding Yamaguchi et al.’s heat pipe to Staun et al.’s device, to provide fast food heating. Kim teaches “the opening” (fig.8 shows the opening at around 141 that is covered by the grate 141) being covered by “a grate” (141) operably coupled to “the upper portion of the housing” (fig.8 shows the upper portion of the housing). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to further modify Staun et al. with Kim, by adding Kim’s grate at the opening of Yamaguchi et al.’s opening, to provide protection to the heating device. Claim(s) 24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Hitchcock et el. (US 8563901). Regarding claim 24, modified Staun et al. discloses “a sensor operably coupled to the heating tube and configured to detect heat within the cavity” ([0108], i.e., The temperature sensor 530 may check and/or measure the temperature inside the cooking chamber 11 and transmit the measured temperature value to the processor 610. Fig.7 show the temperature sensor coupled to the heating tube). Modified Staun et al. is silent regarding a controller configured to activate and deactivate the heating tube comprising heating unit based on a temperature detected by the sensor. Hitchcock et el. teaches “a controller” (col.3 at lines 42-45, i.e., a microprocessor or other device that is in communication with such components) configured to “activate and deactivate the heating tube comprising heating unit” (claim 12, i.e., activating the bottom heating element until the oven temperature reaches a second predetermined temperature … deactivating the bottom heating element after the oven temperature reaches the second predetermined temperature) “based on a temperature detected by the sensor” (see fig.3 shows the temperature sensor feedback and col.3, i.e., Such processing device (used herein to refer generally to single and/or multiple processing devices) is also in communication with a temperature sensor 38). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to further modify Staun et al. with Hitchcock et al., by adding Hitchcock et al.’s control algorithm to control Staun et al.’s heating tube, to allow user to activate and deactivate the heating unit for controlling oven at desired temperature. Claim(s) 31 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Kateman et al. (US 20090117242). Regarding claim 31, modified Staun et al. discloses all the features of claim limitations as set forth above except for the heating plate is formed from at least one of a non-conductive ceramic material, a glass, or a glass-ceramic material. Kateman et al. teaches “the heating plate is formed from at least one of a non-conductive ceramic material, a glass, or a glass-ceramic material” ([0006] In one apparatus of this disclosure, the cold plate includes a ceramic coating along its exposed surface, including, for instance, a ceramic coating available from General Magnaplate of Linden, N.J.). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to further modify Staun et al. with Kateman et al., by adding Kateman et al.’s ceramic coating to Staun et al.’s eating plate, to allow user to clean up the heating plate faster. Claim(s) 32 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Park (US 10602878). Regarding claim 32, modified Staun et al. discloses all the features of claim limitations as set forth above except for the ceramic coating is disposed over an entirety of the tray. Park teaches “the ceramic coating is disposed over an entirety of the tray” (fig.3, 31 and 32. Col.2 at lines 10-20, i.e., enamel layers 31 and 32. Examiner noted that enamel is considered as a specialized type of ceramic coating). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to further modify Staun et al. with Park, by adding Park’s ceramic coating, to Staun et al.’s tray, to provide safe, non-stick surface that helps remove food residuals and make clean up fast. Claim(s) 33 is/are rejected under 35 U.S.C. 103 as being unpatentable over Staun et al. (US 11,109,712) in view of Han (EP 2456284 A1), Park (US 2012/0118168) and Cheng et al. (US 2007/0108189) as applied in claims 1-6, 25-27 and 29 above, and further in view of Wheatley (US 20160183710). Regarding claim 33, modified Staun et al. discloses “the tray” (Han, fig.3, 85) defines “a grasping portion” (Han, 86) that “upwardly extends proximate a front surface of the microwave oven” (Han, 86 extends upwardly proximate a front surface (see fig.1)), Modified Staun et al. is silent regarding the grasping portion being covered in an insulation material. Han teaches the grasping portion being covered in an insulation material. Wheatley teaches “the grasping portion being covered in an insulation material” (fig.3 shows the handle or grasping portion covered in insulation material 115. [0020], i.e., The handle 115 is preferably composed of a heat resistant material, for example silicon, which allows the user to transport the rice cooking insert after it has been heated). It would have been obvious to one of ordinary skill in the art at the time the invention was filed to further modify Staun et al. with Wheatley, by adding Wheatley’s silicon insulation material to Staun et al.’s handle, to slow down or block heat transfer from the cooking utensil to user’s hand for burn prevention and better control. Allowable Subject Matter Claims 28 and 30 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. 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 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 JIMMY CHOU whose telephone number is (571)270-7107. The examiner can normally be reached Mon-Friday. 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, Edward Landrum can be reached at (571) 272-5567. 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. /JIMMY CHOU/Primary Examiner, Art Unit 3761
Read full office action

Prosecution Timeline

Sep 27, 2023
Application Filed
Jun 01, 2026
Non-Final Rejection mailed — §103
Jul 07, 2026
Response Filed
Aug 19, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
71%
Grant Probability
86%
With Interview (+14.9%)
3y 2m (~2m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 869 resolved cases by this examiner. Grant probability derived from career allowance rate.

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