Prosecution Insights
Last updated: April 19, 2026
Application No. 18/288,391

Induction energy supply device

Final Rejection §103§112
Filed
Oct 26, 2023
Examiner
BARNIE, REXFORD N
Art Unit
2836
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Bsh Hausgeräte GmbH
OA Round
6 (Final)
11%
Grant Probability
At Risk
7-8
OA Rounds
3y 5m
To Grant
52%
With Interview

Examiner Intelligence

Grants only 11% of cases
11%
Career Allow Rate
5 granted / 46 resolved
-57.1% vs TC avg
Strong +41% interview lift
Without
With
+40.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
62 currently pending
Career history
108
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
49.5%
+9.5% vs TC avg
§102
23.0%
-17.0% vs TC avg
§112
25.2%
-14.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 46 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 Arguments Applicants' arguments filed January 14, 2026 have been fully considered but they are not persuasive. The §112(b) rejection is maintained. Comments regarding why and potential fixes are included in the rejection, below. Regarding the art rejection, Azukawa discloses a plurality of induction elements (see figure 16) and operating them in opposite phases (par 69). Thus, when the first induction element is off, the second induction element is activated (by a detection signal). Thus, the first inductive element is detecting its electrical parameter that is created by the inductive field generated by the second inductive element. Furthermore, Azukawa discloses that the detected parameter is “resonance frequency” (par 38). The Azukawa transmission frequency is resonant (see par 26-29) and the foreign object detection includes “the frequencies of the voltage and the current” (par 38). These “frequencies” are the resonance frequencies created by the resonant circuitry of the transmitter. The Examiner notes that method claim 27 does not recite any language directed to activating a second induction element. The “detecting a foreign object” limitation ends with “in response to a detection signal provided to” – without reciting where. The resonance frequency amendment in claim 27 is taught by Azukawa, as discussed above. The Applicants’ remarks simply conclude “that Azukawa and Kim fail to remedy these deficiencies of Lulofs” without presenting any analysis of the references. The art rejections are maintained. 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. Claims 14, 16-18, 20-27, 29-30 and 33 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention. Claim 14 recites “wherein the control unit is configured to detect a foreign object [] by detecting a change in resonance frequency of the supply unit in response to the control unit providing a detection signal” – but there is no antecedent basis in the claim for the control unit having the configuration to provide detection signals to one induction unit and not the other. The claim recites that the control unit has three “configured to” features – not one of them is directed to the configuration to provide a detection signal. This lack of antecedent basis makes the claim indefinite. Claims 16-18 and 20-26 are similarly rejected as they depend from, and inherit the deficiencies of, claim 14. Claim 27 recites “detecting a foreign object [] by detecting a change in a resonance frequency of the supply unit in response to a detection signal”. There is no method step, however, of creating/providing this detection signal to establish antecedent basis for completing any actions in response to it. This lack of antecedent basis makes the claim indefinite. Claims 29-30 and 33 are similarly rejected as they depend from, and inherit the deficiencies of, claim 27. Claim 27 is also indefinite because it recites method steps that are out of order, redundant and/or contradictory. The first four method steps appear to be clear (driving, providing communication, detecting a foreign object, inductively supplying). They are written as generic steps that don’t have to be carried out in order. The last of these steps (inductively supplying) appears to be the result of not detecting a foreign object. The claim then shifts to a wherein clause that indicates that the previous step (inductively supplying) comprises additional sub-steps. These steps must occur in order. They each build on each other and cannot be rearranged. One of the issues is that the last four method steps begins with the introduction “wherein the inductively supplying energy to the placeable unit [] comprises” – but the first step is “interrupting”. If the inverter is interrupted, then the transmitter is no longer “supplying energy”. Further, this interrupt step is “for the wireless communication” – it is unclear how the “inductively supplying energy” method step can be defined by the completion of a completely opposite step (wireless communication). The second step is “supplying the detection signal”. The entire purpose of the detection signal is for foreign object detection – NOT “supplying energy”. The third and fourth steps describes a transition time window. Again, the transition is not the actual supply of energy – it is the transition between the interruption (the stopping of the supply) and the supply of energy. It appears that the last four steps are defining (in a very specific order of operation) the “providing a wireless communication” step and the “detecting a foreign object” step (it is clearly NOT the inductively supplying energy step, as the first lines after the wherein clause are defining the interruption of inductive energy). Further, the Applicants allege that the method steps aren’t supposed to be in order. This appears to be true for the generic steps at the beginning of the claim (driving, communicating, detecting foreign object, inductively supplying). But the order of the last steps is critical and they can’t be interchanged. So the claim has a mix of both. The Applicants are requested to consider: Changing the wherein clause to be “wherein detecting a foreign object comprises” – or to be “wherein the providing a wireless communication comprises”. As noted above, the last four steps define the interruption window (during which there is communication and foreign object detection, not the inductive supply of wireless power). Changing the “interrupting” limitation to state, “interrupting an operation of the inverter at regular intervals to cease the inductive supply of energy to create an interruption time window for the wireless communication”. This would more clearly tie in how the interrupt is a break/stoppage in the “inductively supplying energy” step to create an interruption window. It’s not just the inverter that is interrupted – it’s the supply of inductive energy also. Add a specific step for where wireless communication occurs. Currently, the “interrupting” phrase ends with “for the wireless communication” – but there is no actual recitation of carrying out the communication. The Examiner agrees that “providing a wireless communication” language is in the claim – but the problem is that this language is part of a generic (non-timed) limitation. These wherein clauses are directed to specific timed method steps. If the interruption window is created “for the wireless communication”, then there should be a method step of “communicating”. Add a specific step for foreign object detection. The second step recites “supplying the detection signal”, but there is no indication in the claim that the foreign object detection (detecting a change in a resonance frequency) is also carried out. The earlier language in the claim (lines 7-9) is a generic (non-timed) description of foreign object detection functionality. And the “in response to” language does not explicitly require that every detection signal results in a corresponding resonance frequency detection. The claim would be much clearer if the Applicants added a step (after the “supplying the detection signal”) to recite “detecting the resonance frequency of the supply unit”. Mixing generic method steps (non-timed) with a particular order of method steps (timed) is not the issue. The problem with claim 27 is that the wherein clause defines steps that do not clearly correspond to the generic ones that were previously listed. Claims 29-30 and 33 are similarly rejected as they depend from, and inherit the deficiencies of, claim 27. 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 14, 20, 23-27 and 33 are rejected under 35 U.S.C. 103 as being unpatentable over Lulofs (US 2024/0213816) in view of Azukawa (US 2017/0005524) and Kim (US 2018/0159371). With respect to claim 14, Lulofs discloses an induction energy supply device (fig 1-2, 7-8; par 67-113), comprising: a supply unit (see fig 2) comprising supply induction elements (103; par 163, “singular references do not exclude a plurality.”), the supply induction elements configured to inductively provide energy to a placeable unit (the receiver 105-107 shown in figure 1); an inverter unit (201) configured to provide an alternating current to drive the supply induction elements; a control unit (205, 207, 209) configured to control the inverter unit (see arrow from 205 to 201) and comprising a communication unit (207) for wireless communication between the control unit and the placeable unit, said control unit configured to interrupt an operation of the inverter unit at temporally repeating intervals during an interruption time window for the wireless communication (see fig 7-8; par 97-99), the control unit configured to provide a detection signal (par 78; “controller 205 is in particular arranged to control the generation of the drive signal by the driver 201”); wherein the control unit is configured to detect a foreign object in the vicinity of a first one of the supply induction elements (par 98) during the interruption time window (par 98); wherein the control unit is configured to operate the inverter unit during a transition time window (fig 8, the 1ms after 805) temporally immediately following the interruption time window (805) at an adjusted power level (see ramp up). Lulofs discloses foreign object detection, but does not expressly disclose how to carry it out. Lulofs also does not expressly disclose the controller comprises a storage unit. Azukawa discloses an induction energy supply device (fig 1, 16; par 26-43, 69-73), comprising: a supply unit (2) comprising supply induction elements (fig 16 shows the plurality) at least one of the supply induction elements configured to inductively provide energy to a placeable unit (the receiver); an inverter unit (131) configured to provide an alternating current to drive the supply induction elements; a control unit (132) configured to control the inverter unit (par 37) and comprising a storage unit (133), the control unit configured to provide a detection signal (par 36, 40 – the command to complete the frequency sweep is interpreted as the detection signal); wherein the control unit is configured to detect a foreign object (par 41) in the vicinity of a first one of the supply induction elements by detecting a change in a resonance frequency (par 38, “the frequencies of the voltage and the current” is the “resonance frequency”, as supported by par 26-29) of the supply unit in response to the control unit providing a detection signal to activate a second one of the supply induction elements (par 69, “perform power transmission at opposite phases and at the same fixed frequency”). Azukawa discloses a wireless power transmitter that completes foreign object in the vicinity of two coils by providing a detection signal to one coil and sensing various electrical parameters at the other (and then sharing the result). The sensed electrical parameter includes current/voltage frequencies, which would be the “resonance frequency” of the transmitter (par 26-29 discusses that the entire transmitter is resonant). When combined, the Azukawa foreign object detection (detection signal and frequency detection) would be provided during the Lulofs interruption time window (i.e. when that reference carries out its foreign object detection). Lulofs and Azukawa are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with foreign object detection. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify Lulofs to include the parameter-comparison based foreign object detection taught by Azukawa. The motivation for doing so would have been to fill in the blanks in the Lulofs disclosure. Lulofs states that foreign objection detection is carried out, but does not detail how. Thus, the skilled artisan would have consulted the prior art to understand how this can be successfully achieved. Azukawa provides the necessary teachings for the skilled artisan to apply foreign object detection to Lulofs, with a reasonable expectation of success. Lulofs does not expressly the control unit is configured to operate the inverter, in the transition time window, at an adjusted power frequency that is higher than the target power frequency. Kim discloses an induction energy supply device (fig 1, 3; par 68-89, 167-184), comprising: a supply unit (324), an inverter (322), and a control unit (312) configured to operate the inverter unit at an adjusted power frequency (fig 8-9, “b”; fig 10, any of the frequencies that is not the left-most one; at least par 177-178) that is higher than a target power frequency (fig 8-9, “a”; fig 10, left-most frequency). Kim discloses a known correlation between wireless power transmission frequency and transmitted power. There exists a frequency for which power transmission is maximum and for any frequency higher than this, power decreases and frequency increases. Kim teaches that a control unit is “designed” to control the inverter to output many different frequencies including an “adjusted” frequency that is higher than a “target” frequency. For whatever time the Kim control unit selects a higher frequency, the transmitter is interpreted as being in a “transition time window”. Lulofs and Kim are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with inverter frequency control. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify the Lulofs control unit to include the configuration to operate at an adjusted frequency, as taught by Kim. The motivation for doing so would have been to control power. The prior art teaches that power can be controlled through frequency regulation – thus, the skilled artisan would have considered that for Lulofs. With respect to claim 20, Lulofs discloses the control unit is configured to arrange the transition time window and the interruption time window temporally immediately adjoining one another (see fig 8). With respect to claim 23, Lulofs discloses the control unit is configured, during the interruption time window, aside from an interaction with the communication unit, to carry out at least one further operation (par 98). Lulofs discloses that a foreign object detection interval can be included in the repeating time frame. This foreign object detection interval is not the same as, or part of, the power interval – therefore, it occurs during an interruption time window. With respect to claim 24, Lulofs discloses the further operation comprises detecting the foreign object in the vicinity of the supply induction elements (par 98). With respect to claim 25, Lulofs discloses the placeable unit is configured as a small household appliance (par 1). With respect to claim 26, Lulofs discloses the placeable unit is configured as a cooking equipment item (par 1). The claim does not define what type of “cooking”. Lulofs’ disclosure of a kitchen appliance meets the broadest reasonable interpretation of an equipment item that is to be used for cooking. With respect to claims 27 and 33, Lulofs, Azukawa and Kim combine to disclose the apparatus necessary to complete the recited method steps, and the references are analogous, as discussed above in the art rejections of claims 14 and 24, respectively. Claim 27 recites providing communication between “one of the supply inductive elements” and the placeable unit (claim 14 only broadly refers to communication between the control unit and placeable unit – it doesn’t recite how it is accomplished). Lulofs discloses in-band communication (par 79) and, thus, teaches this limitation. Claim 27 differs from claim 14 in that the detection signal is not required to be sent to a different induction element than where the resonance frequency sensing occurs. Claims 16-18, 21-22 and 29-30 are rejected under 35 U.S.C. 103 as being unpatentable over Lulofs in view of Azukawa, Kim and Joye (US 2016/0156232). With respect to claim 16, Lulofs discloses the interruption time window (see fig 8), but does not expressly disclose how long it is. Joye discloses an induction energy supply device (fig 1, 3, 5; par 151-206), comprising: a supply unit (see fig 3) comprising a supply induction element (103) configured to inductively provide energy to a placeable unit (105-107); an inverter unit (301) configured to provide an alternating current to drive the supply induction element; a control unit (303, 305, 309) configured to control the inverter unit (see arrow from 303 to 301) and comprising a communication unit (305) for wireless communication between the control unit and the placeable unit, said control unit configured to interrupt an operation of the inverter unit at temporally repeating intervals during an interruption time window for the wireless communication (see fig 5; par 135, 184-187); Joye discloses that the transmitter has two types of time intervals: a power time interval with full transmission power; and a reduced power time interval that includes “the power transfer signal may be completely switched off” (par 135). Figure 5 shows how the two intervals alternate. Joye further discloses a duration of the interruption time window is at least 1.0 ms (par 180-182). Joye discloses that the “time frame” (the power interval plus the interrupt interval) can be between 5-200ms and the ratio of power:interrupt is 2:1, 3:1, 5:1 or 10:1. Within these possible ranges and ratios, Joye obviously discloses setting the interruption time window to > 1ms. The combination (Lulofs and Kim) and Joye are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with inverter timing control. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify the combination to include the at least 1ms interruption time window, as taught by Joye. The motivation for doing so would have been to select from known communication time durations with a reasonable expectation of success. With respect to claim 17, Joye discloses the control unit is configured to extend a duration of the interruption time window for reducing the inductively provided energy (par 180-182). Joye discloses various ratios, and therefore, discloses extending the interruption time window duration (i.e. changing the ratio from 2:1 to 3:1). The references are analogous, as discussed above. With respect to claim 18, Joye discloses the control unit is configured to space successive interruption time windows temporally by at least a half period duration of a mains alternating voltage (par 182). The Joye repetition frequency is between 5-200Hz. This equates to the spacing between interrupt windows of 200ms (5Hz) and 5ms (200Hz). In the United States, mains AC voltage is 60Hz (half a period is 8.3ms). Joye’s possible spacing (5-200ms) clearly satisfies “at least” 8.3ms. The references are analogous, as discussed above. With respect to claims 21-22, Kim teaches that the transition time window affects the amount of transmitted power (par 177-178). Thus, the duration of the transition time window is a result effective variable. MPEP §2144.05. The longer the window, the less power/energy is transmitted (because a higher frequency is selected for a longer time). Thus, it would have been within the level of one of ordinary skill in the art to adjust the length of the Kim transition time window. This would obviously include the situation (purposeful or coincidental) where a duration of the transition time window is at least one duration of the interruption time window (claim 21) or less than half a period of the mains AC voltage (claim 22). Furthermore, Joye teaches the obviousness of changing the length of the interruption time window (see art rejections of claims 16-17). Thus, the combination (of all three references) teaches how to adjust the time windows to satisfy the claimed relationship. For claim 21, setting the transition time to be equal to or greater than the interruption time would have been obvious given the power needs of the receiver. For claim 22, setting the transition time to be less than half of the AC mains frequency (half of 60Hz is a time of 0.0333 seconds). With respect to claims 29-30, the four references combine to disclose the apparatus necessary to complete the recited method steps, and the references are analogous, as discussed above in the art rejections of claims 17-18, respectively. Conclusion Applicants' 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 ADI AMRANY whose telephone number is (571)272-0415. The examiner can normally be reached Monday - Friday, 8am-7pm. 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, Rex Barnie can be reached at 5712722800 x36. 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. /ADI AMRANY/ Primary Examiner, Art Unit 2836
Read full office action

Prosecution Timeline

Oct 26, 2023
Application Filed
Dec 03, 2024
Non-Final Rejection — §103, §112
Feb 12, 2025
Response Filed
Feb 21, 2025
Final Rejection — §103, §112
Apr 25, 2025
Response after Non-Final Action
May 27, 2025
Request for Continued Examination
May 28, 2025
Non-Final Rejection — §103, §112
May 28, 2025
Response after Non-Final Action
Jun 03, 2025
Applicant Interview (Telephonic)
Jul 23, 2025
Response Filed
Jul 30, 2025
Final Rejection — §103, §112
Sep 24, 2025
Response after Non-Final Action
Oct 24, 2025
Request for Continued Examination
Oct 30, 2025
Response after Non-Final Action
Nov 03, 2025
Non-Final Rejection — §103, §112
Jan 14, 2026
Response Filed
Jan 20, 2026
Final Rejection — §103, §112
Apr 07, 2026
Request for Continued Examination
Apr 13, 2026
Response after Non-Final Action

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

7-8
Expected OA Rounds
11%
Grant Probability
52%
With Interview (+40.9%)
3y 5m
Median Time to Grant
High
PTA Risk
Based on 46 resolved cases by this examiner. Grant probability derived from career allow rate.

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