Prosecution Insights
Last updated: October 01, 2026
Application No. 18/288,389

INDUCTION ENERGY SUPPLY DEVICE

Non-Final OA §103§112
Filed
Oct 26, 2023
Priority
May 03, 2021 — EU 21382393 +1 more
Examiner
CHEN, SIMPSON ABRAHAM
Art Unit
Tech Center
Assignee
BSH Hausgeräte GmbH
OA Round
1 (Non-Final)
62%
Grant Probability
Moderate
1-2
OA Rounds
6m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 62% of resolved cases
62%
Career Allowance Rate
121 granted / 195 resolved
+2.1% vs TC avg
Strong +42% interview lift
Without
With
+42.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
37 currently pending
Career history
229
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
54.5%
+14.5% vs TC avg
§102
15.1%
-24.9% vs TC avg
§112
22.4%
-17.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 195 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 . Claim Objections Claims 21-22 and 32-33 objected to because of the following informalities: Claims 21 and 32 recites “a total electrical capacitance of the snubber unit to a first one of at least two different levels, with the first one of at least two different levels.” This should be –the total electrical capacitance of the snubber unit to a first one of the least two different levels, with the first one of the at least two different levels--. Emphasis added to highlight the change. Claim 22 and 33 recites “the second one of at least two different levels having a value of at least 15 nF and of at most 40 nF.” This should be --the second one of the at least two different levels having a value of at least 15 nF and of at most 40 nF-- Appropriate correction is required. Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: Control unit in claim 14. A review of the specification shows that the following appears to be the corresponding structure described in the specification for the 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph limitation: specification par. 15 states “Preferably, the control unit comprises a computer unit and, in particular in addition to the computer unit, a memory unit with a control and/or regulating program which is stored therein and which is provided to be executed by the computer unit.” Data reception element in claim 14. A review of the specification shows that the following appears to be the corresponding structure described in the specification for the 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph limitation: specification par. 16 states “ The data reception element is preferably provided for a bi-directional wireless data transmission, i.e. both for wireless reception and wireless transmission of data. The data reception element could be provided for wireless data transmission between the positioned unit and the control unit by RFID or by WIFI or by Bluetooth or by ZigBee, or for wireless data transmission according to another suitable standard.” For examination, the limitation will be interpreted as –a data reception element that is capable of at least receiving wireless data transmission such as but not limited by RFID, WIFI, Bluetooth, NFC, etc--. Measuring unit in claim 16. A review of the specification shows that the following appears to be the corresponding structure described in the specification for the 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph limitation: specification par. 22 states “preferably, the measuring unit comprises a microprocessor.” Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. 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. Claim 29 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 29 recites “further comprising considering the further operating parameter when setting the snubber unit.” The term “considering” is indefinite because it is unclear what the step of “considering” requires. 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. Claim(s) 14-15, 18-19, 23-30 is/are rejected under 35 U.S.C. 103 as being unpatentable over Garde (WO 2010/069789 A1) in view of Park (US 20220394825 A1). Claim 14. Garde discloses an induction energy supply device (induction hob, Fig. 1), comprising: a supply unit (power supply unit 40, Fig. 1) comprising a supplying induction element (inductors 30 that is powered by the power supply unit 40, Fig. 1) designed to inductively provide energy to a positioned unit (cookware 34 is heated by the inductors 30, par. 24); an inverter unit designed to operate the supplying induction element (inverters 10 generate high-frequency AC which flows through the inductors, par. 24); a snubber unit (damping capacitor system 24, par. 28) interacting with the inverter unit and comprising a plurality of snubber capacitors (capacitors 28a and 28b, Fig. 3); and a control unit (control unit 32, Fig. 1) designed to control the inverter unit (control unit is connected to the inverter 10, par. 24, wherein the total power can be controlled) and Garde does not disclose a data reception element designed for wireless reception of an operating parameter from the positioned unit where the snubber unit is adjusted based on the operating parameter. Park discloses a wireless power transfer cooktop device where the cooktop can generate heat and send power to an appliance (par. 7) wherein inductive elements in the cooktop can transmit power to an electric appliance (abstract) wherein the electric appliance has an NFC tag 102 (Fig. 3) that can send information to the NFC reader 202 (Fig. 3) in the cooktop relating to the size of the electric appliance (par. 95). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Garde to incorporate the teachings of Park and have the cookware have an NFC tag send information to the control unit about the size of the cookware. Doing so would have the benefit of helping the control unit identify the size of the cookware to adjust the snubber unit accordingly. Claim 15. Garde in view of Park does not disclose the induction energy supply device of claim 14, wherein the operating parameter is a target power of the positioned unit. Park further discloses that another information that the NFC tag can transmit is the power used by the electric appliance (claim 9). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Garde in view of Park to incorporate the teachings of Park and adjust the snubber unit based on the power requirements. Doing so would have the benefit of helping reduce power loss (par. 4, Garde). Claim 18. Garde in view of Park discloses the induction energy supply device of claim 14, wherein at least one of the plurality of snubber capacitors of the snubber unit is a variable capacitor (variable capacitor, par. 10). Claims 19 and 30. Garde in view of Park discloses the induction energy supply device of claim 14, wherein the snubber unit comprises a switching element designed to enable the control unit to switch at least one of the plurality of snubber capacitors on or off (capacitors can be turned on or off, par. 10). Claim 23. Garde discloses an induction energy transmission system (induction hob, Fig. 1), comprising: a positioned unit (cookware 34, Fig. 1); and an induction energy supply device (induction hob, Fig. 1) comprising a supply unit (power supply unit 40, Fig. 1) which includes a supplying induction element designed to inductively provide energy to the positioned unit (inductors 30 that is powered by the power supply unit 40, Fig. 1), an inverter unit designed to operate the supplying induction element (inverters 10 generate high-frequency AC which flows through the inductors, par. 24), a snubber unit interacting with the inverter unit (damping capacitor system 24, par. 28) and comprising a plurality of snubber capacitors (capacitors 28a and 28b, Fig. 3), and a control unit designed to control the inverter unit (control unit 32 is connected to the inverter 10, par. 24, wherein the total power can be controlled) and Garde does not disclose a data reception element designed for wireless reception of an operating parameter from the positioned unit where the snubber unit is adjusted based on the operating parameter. Park discloses a wireless power transfer cooktop device wherein inductive elements in the cooktop can transmit power to an electric appliance (abstract) wherein the electric applicance has an NFC tag 102 (Fig. 3) that can send information to the NFC reader 202 (Fig. 3) in the cooktop relating to the size of the electric appliance (par. 95). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Garde to incorporate the teachings of Park and have the cookware have an NFC tag send information to the control unit about the size of the cookware. Doing so would have the benefit of helping the control unit identify the size of the cookware to adjust the snubber unit accordingly. Claim 24. Garde in view of Park discloses the induction energy transmission system of claim 23, further comprising a positioning plate arranged above the supply unit of the induction energy supply device for positioning the positioned unit (top plates with distinct heating areas 211-215, Fig. 2, Park). Claim 25. Garde in view of Park discloses the induction energy transmission system of claim 23, wherein the positioned unit is designed as a small household appliance (small electric appliance 100, Fig. 1, Park). Claim 26. Garde in view of Park discloses the induction energy transmission system of claim 23, further comprising at least one further positioned unit designed as an item of cookware (cookware 34, Fig. 1). Claim 27. Garde discloses a method for operating an induction energy supply device (induction hob, Fig. 1), the method comprising: inductively supplying energy to a positioned unit (inductors 30 heats the cookware 34, Fig. 1); adjusting a setting of a snubber unit of the induction energy supply device (total capacitance to the damping capacitor system 24 can be adapted to the load, par. 33) based on the Garde does not disclose wirelessly receiving in an operating state an operating parameter of the positioned unit by a data reception element where the snubber unit is adjusted based on the operating parameter. Park discloses a wireless power transfer cooktop device wherein inductive elements in the cooktop can transmit power to an electric appliance (abstract) wherein the electric applicance has an NFC tag 102 (Fig. 3) that can send information to the NFC reader 202 (Fig. 3) in the cooktop relating to the size of the electric appliance (par. 95). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Garde to incorporate the teachings of Park and have the cookware have an NFC tag send information to the control unit about the size of the cookware. Doing so would have the benefit of helping the control unit identify the size of the cookware to adjust the snubber unit accordingly. Claim 28. Garde in view of Park discloses the method of claim 27, further comprising determining a further operating parameter of the positioned unit (control unit 32 can detect the size and shape of the cookware element 34 or multiple cookware elements, par. 23). Claim 29. Garde in view of Park discloses the method of claim 28, further comprising considering the further operating parameter when setting the snubber unit (different inductors are combined into a flexibly defined heating area based on the cookware size and shape, par. 23). Claim(s) 16-17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Garde in view of Park as applied to claim 14 above, and further in view of Artigas (US 2010/0282740 A1) Claim 16. Garde in view of Park discloses the induction energy supply device of claim 14, further comprising a Garde in view of Park does not explicitly disclose the measuring unit within the control unit that is capable of determining the size and shape of the cookware. However, it would have been obvious to one of ordinary skill in the art to have a processor that can detect the size and shape of the cookware. For example, Artigas discloses an induction hob that has a control unit with a processor that can detect the size and position of the cooking utensils (par. 38). Claim 17. Garde in view of Park discloses the induction energy supply device of claim 16, wherein the control unit is designed to consider the further operating parameter when setting the snubber unit (different inductors are combined into a flexibly defined heating area based on the cookware size and shape, par. 23). Claim(s) 20-22 and 31-33 is/are rejected under 35 U.S.C. 103 as being unpatentable over Garde in view of Park as applied to claim 14 above, and further in view of Jung (US 2020/0359468 A1) Claims 20 and 31. Garde in view of Park does not disclose the induction energy supply device of claim 14, wherein the control unit is designed to set a total electrical capacitance of the snubber unit to at least two different levels within a value range of at least 0 nF and of at most 40 nF. Garde discloses that the total capacitance has three levels: the capacitance of 28a, 28a + 28b, and 28a + 28b + 28c. Jung discloses an induction heating device with multiple capacitance levels (1 to 2 nF) CSP2 and CPS1 (33 nF, par. 91) by switching the relay R1. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Garde in view of Park to incorporate the teachings of Jung and have different capacitance level be at 1-2 nF and 33 nF. Jung demonstrates that one of ordinary skill in the art would be capable of choosing the total capacitance level of the snubber unit based on the load (par. 33, Garde) Claims 21 and 32. Garde in view of Park and Jung discloses the induction energy supply device of claim 20, wherein the control unit is designed to set a total electrical capacitance of the snubber unit to a first one of at least two different levels, with the first one of at least two different levels having a value of at least 0 nF and of at most 20 nF (1-2 nF, par. 91, Jung). Claims 22 and 33. Garde in view of Park and Jung discloses the induction energy supply device of claim 21, wherein the control unit is designed to set the total electrical capacitance of the snubber unit to a second one of the at least two different levels, with the second one of at least two different levels having a value of at least 15 nF and of at most 40 nF (33 nF, par. 91, Jung). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SIMPSON A CHEN whose telephone number is (571)272-6422. The examiner can normally be reached Mon-Fri 8-5. 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, Steven Crabb can be reached at (571) 270-5095. 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. /SIMPSON A CHEN/Examiner, Art Unit 3761 /ELIZABETH M KERR/Primary Examiner, Art Unit 3761
Read full office action

Prosecution Timeline

Oct 26, 2023
Application Filed
Sep 02, 2026
Non-Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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SPOT PREHEATING
5y 1m to grant Granted Sep 01, 2026
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ELECTRON BEAM WELDING APPLIANCE
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Patent 12696915
DYNAMIC POWER APPLIANCE FOR CONTAINERS, PACKAGES AND VESSELS METHOD AND SYSTEM
5y 7m to grant Granted Aug 04, 2026
Patent 12696360
COOKING APPARATUS
4y 5m to grant Granted Jul 28, 2026
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
62%
Grant Probability
99%
With Interview (+42.4%)
3y 5m (~6m remaining)
Median Time to Grant
Low
PTA Risk
Based on 195 resolved cases by this examiner. Grant probability derived from career allowance rate.

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