Prosecution Insights
Last updated: April 19, 2026
Application No. 18/305,176

ELECTRONIC DEVICE

Non-Final OA §103
Filed
Apr 21, 2023
Examiner
MULARSKI, ROSS TERRY
Art Unit
2841
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Samsung Display Co., Ltd.
OA Round
3 (Non-Final)
87%
Grant Probability
Favorable
3-4
OA Rounds
2y 11m
To Grant
99%
With Interview

Examiner Intelligence

Grants 87% — above average
87%
Career Allow Rate
20 granted / 23 resolved
+19.0% vs TC avg
Strong +20% interview lift
Without
With
+20.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
25 currently pending
Career history
48
Total Applications
across all art units

Statute-Specific Performance

§103
47.8%
+7.8% vs TC avg
§102
35.0%
-5.0% vs TC avg
§112
17.3%
-22.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 23 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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on December 4, 2025 has been entered. Response to Amendment The amendment filed December 4, 2025 has been entered. Claims 1, 18, and 20 have been amended. Claims 1-5 and 7-20 remain pending in the application. Response to Arguments Applicant's arguments, filed December 4, 2025, have been fully considered but they are not persuasive. Applicant reasserts the argument (see Remarks/Arguments dated November 11, 2025) that Hosoda does not disclose that the second transparent layer 14 includes a conductive polymer. Paragraph 0018 of Hosoda states that “preferably, the transparent layer includes either one of metal oxide particles exhibiting conductivity by electron conduction and a pi electron-conjugated conductive polymer.” Applicant asserts that paragraph 0018 is referring to only the first transparent layer 13, and not to the second transparent layer 14. Examiner respectfully disagrees. Examiner believes that paragraph 0018 is referring to the transparent layer as a whole, of which the first transparent layer 13 and the second transparent layer 14 are a part. Applicant also argues that there is no apparent reason for one of ordinary skill in the art to incorporate Hosoda’s film into a display device that includes an organic light emitting element. Examiner respectfully disagrees. As stated below, one of ordinary skill in the art would be motivated to incorporate the features of the film taught by Hosoda in order to protect the display panel from static electricity, dust, and dirt. 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. 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. Claims 1-5, 7-14, and 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over Lee et al. (US 2021/0055760 A1) in view of Kim et al. (US 2021/0029841 A1) and Hosoda et al. (US 2012/0213967 A1), hereinafter Lee, Kim and Hosoda, respectively. Regarding claim 1, Lee teaches an electronic device (display device DD) comprising: a display panel (display element layer DP-OLED, circuit element layer DP-CL, and thin film encapsulation layer TFE) comprising an organic light emitting element (from paragraph 0072: “The display element layer DP-OLED may include an organic light emitting diode OLED.”), a first non-folding area (first non-folding area NFA1), a second non-folding area (second non-folding area NFA2), and a folding area (folding area FA) between the first non-folding area and the second non-folding area (from paragraph 0042: “The first non-folding area NFA1 and a second non-folding area NFA2 are disposed opposing each other with the folding area FA therebetween.”); and a protective film (protective film PF) under the display panel (DP-OLED, DP-CL, and TFE). Lee fails to disclose a support member under the protective film. Kim teaches a foldable display device (display 400) that includes a support member (polymer member 440) disposed underneath a display panel (display panel 430). Lee and Kim are both considered to be analogous art because they are in the same field of endeavor as the claimed invention. Therefore it would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to include a support member underneath Lee’s protective film to “act as a cushioning member for preventing the display [] from being damaged by absorbing an impact from the outside of the electronic device.” (Kim, paragraph 0073). Modified Lee fails to disclose that the protective film comprises: a base layer including an upper surface adjacent to the display panel, and a lower surface adjacent to the support member; and an antistatic coating layer on the lower surface of the base layer, and comprising a coating base material layer comprising a conductive polymer, and a plurality of fillers dispersed in the coating base material layer comprising the conductive polymer, wherein an average diameter of the plurality of fillers is greater than a thickness of the coating base material layer, and wherein the protective film including the antistatic coating layer is attached between the display panel and the support member. Hosoda teaches a protective film for a display device (optical laminate film 20) comprising: a base layer (support 11) including an upper surface and a lower surface; an antistatic coating layer (transparent layer 16) on the lower surface of the base layer (11), and comprising a coating base material layer (second transparent layer 14) comprising a conductive polymer (from paragraph 0018: “[P]referably, the transparent layer includes either one of metal oxide particles exhibiting conductivity by electron conduction and a pi electron-conjugated conductive polymer.”), and a plurality of fillers (particles 15a-b) dispersed in the coating base material layer comprising the conductive polymer (14), wherein an average diameter of the plurality of fillers (15a-b) is greater than a thickness of the coating base material layer (see paragraph 0030; see also Figs. 1-3). Hosoda is considered to be analogous art because it is in the same field of endeavor as the claimed invention. Therefore it would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to incorporate the features of the protective film taught by Hosoda into the protective film of modified Lee, and attach the antistatic coating layer between the display panel and the support member, in order to protect the display panel from static electricity, dust, and dirt (see Hosoda, paragraph 0081). Regarding claim 2, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein the thickness of the coating base material layer (Hosoda: 14) is 0.3 micrometers or more, and 1 micrometer or less (Hosoda: see paragraph 0086 stating that the second transparent layer 14 may have a thickness anywhere between 0.4 µm to 3.0 µm). Regarding claim 3, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein the average diameter of the plurality of fillers (Hosoda: 15a-b) is 1.5 micrometers or more, and 3 micrometers or less (Hosoda: see paragraph 0029 stating that the preferred diameter r of the particles is 1.0 µm ≤ r ≤ 3.0 µm). Regarding claim 4, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein each of the plurality of fillers (Hosoda: 15a-b) comprises at least one selected from a group consisting of polyethylene, polypropylene, and polystyrene (Hosoda: see paragraph 0132). Regarding claim 5, Lee in view of Kim and Hosoda teaches all of the limitations of claim 4 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 4, wherein each of the plurality of fillers (Hosoda: 15a-b) further comprises an acrylic monomer additive (Hosoda: see paragraph 0132). Regarding claim 7, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein the base layer (Hosoda: 11) comprises a heat-resistant synthetic resin film (Hosoda: see paragraph 0067 stating that a preferred material for support 11 is polyimide). Regarding claim 8, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein the protective film (Hosoda: 20) further comprises an intermediate layer (first transparent layer 13) on at least one of the upper surface or the lower surface of the base layer (11), and comprising an additional filling particle (Hosoda: see paragraph 0080 stating that first transparent layer 13 may include metal oxide particles). Regarding claim 9, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein some of the plurality of fillers (Hosoda: 15a-b) comprise an exposed surface that is exposed in a direction toward the support member (Hosoda: from paragraph 0030: “Since the volume average particle diameter r of the translucent particles 15 is larger than the average film thickness r of the transparent layer 16, the translucent particles 15 project from the surface of the transparent layer 16.”; see also Figs. 1-3), and wherein others of the plurality of fillers (Hosoda: 15a-b) is covered by the coating base material layer (Hosoda: from paragraph 0030: “However, this does not mean that all of the translucent particles 15 project.”). Regarding claim 10, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda lack the specific teaching that an area ratio of a portion of the antistatic coating layer including the plurality of fillers with respect to a total area of the antistatic coating layer in a plan view is 1% or less. It would have been obvious to one of ordinary skill in the art, prior to the effective fling date of the present application, to configure an area ratio of a portion of the antistatic coating layer including the plurality of fillers with respect to a total area of the antistatic coating layer in a plan view be 1% or less. It has been held the 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. In re Aller, 105 USPQ 233. Regarding claim 11, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, wherein a content of the plurality of fillers (Hosoda: 15a-b) with respect to a total content of the antistatic coating layer (Hosoda: 16) is 1 weight percentage (wt%) or less (Hosoda: see paragraph 0029). Regarding claim 12, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Hosoda mentions methods and materials used for adjusting the friction coefficient (Hosoda: see paragraph 0127), but is silent as to an optimal range. It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to ensure that the friction coefficient of a lower surface of the antistatic coating layer is 1 or less, since it has been held that 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. In re Aller, 105 USPQ 233. Regarding claim 13, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, further comprising: a window (Lee: window panel WP) on the display panel (Lee: DP-OLED, DP-CL, and TFE); an upper protective film (Lee: base film WP-BS; from paragraph 0057: “The base film WP-BS may include a glass substrate and/or a synthetic resin film. The base film WP-BS is not limited to a single layer. The base film WP-BS may include two or more films coupled to each other by a coupling member such as an adhesive layer.”) between the window (Lee: WP) and the display panel (Lee: DP-OLED, DP-CL, and TFE); and an anti-reflection layer (Lee: anti-reflection panel RPP) between the upper protective film (Lee: WP-BS) and the display panel (Lee: DP-OLED, DP-CL, and TFE). Regarding claim 14, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, further comprising: a barrier layer (Kim: adhesive member P2) between the protective film (Hosoda: 20) and the support member (Kim: 440); a digitizer under the support member (Kim: see paragraph 0074 stating that a digitizer may be disposed between polymer member 440 and conductive plate 450); a metal layer under the digitizer (Kim: see paragraph 0074 stating that display 400 may include additional functional members disposed between polymer member 440 and conductive plate 450, including members that comprise metal such as FPCBs, a communication antenna radiator, and conductive tape); a metal plate under the metal layer (Kim: one of the additional metal members referenced in paragraph 0074); and a heat dissipation layer under the metal plate (Kim: graphite sheet for heat dissipation referenced in paragraph 0074). Regarding claim 17, Lee in view of Kim and Hosoda teaches all of the limitations of claim 1 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 1, further comprising: an upper adhesive layer (Lee: adhesive member PSA) between the display panel (Lee: DP-OLED, DP-CL, and TFE) and the protective film (Lee: PF; Hosoda: 20); and a lower adhesive layer (Kim: P2) between the protective film (Lee: PF; Hosoda: 20) and the support member (Kim: 440). Regarding claim 18, Lee teaches an electronic device (DD) comprising: a display panel (DP-OLED, DP-CL, and TFE) comprising an organic light emitting element (see paragraph 0072), a first non-folding area (NFA1), a second non-folding area (NFA2), and a folding area (FA) between the first non-folding area and the second non-folding area (see paragraph 0042); and a protective film (PF) under the display panel (DP-OLED, DP-CL, and TFE). Lee fails to disclose a support member under the protective film. Kim teaches a foldable display device (400) that includes a support member (440) disposed under a display panel (430). It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to include a support member under Lee’s protective film to “act as a cushioning member for preventing the display [] from being damaged by absorbing an impact from the outside of the electronic device.” (Kim, paragraph 0073). Modified Lee fails to disclose that the protective film comprises: a base layer; and an antistatic coating layer on one surface of the base layer, wherein the antistatic coating layer comprises: a coating base material layer comprising a conductive polymer; and a filler dispersed in the coating base material layer comprising the conductive polymer, wherein a thickness of the coating base material layer is 0.3 micrometers or more, and 1 micrometer or less, wherein a diameter of the filler is 1.5 micrometers or more, and 3 micrometers or less, and wherein the protective film including the antistatic coating layer is attached between the display panel and the support member. Hosoda teaches a protective film for a display device (20) comprising: a base layer (11); and an antistatic coating layer (16) on one surface of the base layer (11), wherein the antistatic coating (16) layer comprises: a coating base material layer (14) comprising a conductive polymer (see paragraph 0018); and a filler (15a-b) dispersed in the coating base material layer comprising the conductive polymer (14), wherein a thickness of the coating base material layer (14) is 0.3 micrometers or more, and 1 micrometer or less (Hosoda: see paragraph 0086 stating that the second transparent layer 14 may have a thickness anywhere between 0.4 µm to 3.0 µm), and wherein a diameter of the filler (15a-b) is 1.5 micrometers or more, and 3 micrometers or less (see paragraph 0029), and It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to incorporate the features of the protective film taught by Hosoda into the protective film of modified Lee, and attach the antistatic coating layer between the display panel and the support member, in order to protect the display panel from static electricity, dust, and dirt (see Hosoda, paragraph 0081). Regarding claim 19, Lee in view of Kim and Hosoda teaches all of the limitations of claim 18 as stated above. Lee in view of Kim and Hosoda further teaches the electronic device of claim 18, wherein the filler (Hosoda: 15a-b) comprises: a base material comprising at least one selected from a group consisting of polyethylene, polypropylene, and polystyrene; and an acrylic monomer (Hosoda: see paragraph 0132). Regarding claim 20, Lee teaches an electronic device comprising: a display device (DD) comprising: a window (WP) defining an upper surface of the display device (DD); a display panel (DP-OLED, DP-CL, and TFE) under the window (WP), and comprising an organic light emitting element (see paragraph 0072), a first non-folding area (NFA1), a second non-folding area (NFA2), and a folding area (FA) between the first non-folding area and the second non-folding area (see paragraph 0042); and a protective film (PF) under the display panel (DP-OLED, DP-CL, and TFE). Lee mentions that the display device may comprise a camera module (see paragraph 0045), but lacks the specific teaching of: a sensing area configured to pass an optical signal through, and a display area adjacent to the sensing area; and an electro-optic module below the display device, and overlapping with the sensing area, the electro-optic module being configured to receive the optical signal. Kim teaches a foldable display device (electronic device 100) comprising: a sensing area configured to pass an optical signal through (sensor region 131d), and a display area (display 130) adjacent to the sensing area (131d); and an electro-optic module (camera 182) below the display device (100), and overlapping with the sensing area (131d), the electro-optic module (182) being configured to receive the optical signal. It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application to include the above-described features taught by Kim in order to incorporate a camera module into the display device. Devices with cameras adjacent to a display area are common in the art. Modified Lee fails to disclose that the protective film comprises: a base layer including an upper surface adjacent to the display panel, and a lower surface opposite to the upper surface; and an antistatic coating layer on the lower surface of the base layer, and comprising a coating base material layer comprising a conductive polymer, and first filling particles dispersed in the coating base material layer comprising the conductive polymer, wherein a diameter of the first filling particles is greater than a thickness of the coating base material layer, and wherein the protective film including the antistatic coating layer is attached under the display panel, and the protective film is not released from the display panel. Hosoda teaches a protective film for a display device (20) comprising: a base layer (11) including an upper surface adjacent to a display panel (30), and a lower surface opposite to the upper surface; and an antistatic coating layer (16) on the lower surface of the base layer (11), and comprising a coating base material layer (14) comprising a conductive polymer (see paragraph 0018), and first filling particles (15a-b) dispersed in the coating base material layer comprising the conductive polymer (14), wherein a diameter of the first filling particles is greater than a thickness of the coating base material layer (see paragraph 0030; see also Figs. 1-3), and wherein the protective film (20) including the antistatic coating layer (16) is attached under the display panel (30), and the protective film (20) is not released from the display panel (30). It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to incorporate the features of the protective film taught by Hosoda into the protective film of modified Lee in order to protect the display panel from static electricity, dust, and dirt (see Hosoda, paragraph 0081). Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Lee in view of Kim and Hosoda as applied to claim 14 above, and further in view of JP 3806550 B2, hereinafter JP. Lee in view of Kim and Hosoda teaches all of the limitations of claim 14 as stated above. Lee in view of Kim and Hosoda lacks the specific teaching that the support member comprises carbon fiber reinforced plastic or glass fiber reinforced plastic. JP teaches a support member made of glass fiber reinforced plastic (see paragraph 0058 describing a reinforcing sheet that is made from epoxy-impregnated glass fiber). JP is considered to be analogous art because it is in the same field of endeavor as the claimed invention, electronic devices. Therefore it would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to modify Lee in view of Kim and Hosoda and incorporate the teachings of JP by using an epoxy-impregnated glass fiber as the material for the support member. Doing so would improve the strength and durability of the support member. Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Lee in view of Kim and Hosoda as applied to claim 14 above, and further in view of Lee (US 10,516,119 B2), hereinafter Lee 2. Lee in view of Kim and Hosoda teaches all of the limitations of claim 14 as stated above. Lee in view of Kim and Hosoda lacks the specific teaching that a plurality of openings overlapping with the folding area are defined in the support member. Lee 2 (see Fig. 5) teaches an electronic device (flexible display device 100) comprising a support member (protection film 150) with a plurality of openings (folding holes 171) that overlap with a folding area (folding area 116). Lee 2 is considered to be analogous art because it is in the same field of endeavor as the claimed invention. Therefore it would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the present application, to modify the device of Lee in view of Kim and Hosoda by incorporating a support member with a plurality of openings as taught by Lee 2. Doing so would reduce the bending stiffness of the device (see Lee 2 col. 8, lines 9-10). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROSS TERRY MULARSKI whose telephone number is (571)272-0284. The examiner can normally be reached Monday - Friday, 8:00 am - 5:00 pm EST. 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, Imani Hayman can be reached at (571)270-5528. 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. /R.T.M./Examiner, Art Unit 2841 /IMANI N HAYMAN/Supervisory Patent Examiner, Art Unit 2841
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Prosecution Timeline

Apr 21, 2023
Application Filed
Apr 07, 2025
Non-Final Rejection — §103
Jul 01, 2025
Examiner Interview Summary
Jul 01, 2025
Applicant Interview (Telephonic)
Jul 09, 2025
Response Filed
Sep 08, 2025
Final Rejection — §103
Nov 11, 2025
Response after Non-Final Action
Dec 04, 2025
Request for Continued Examination
Dec 16, 2025
Response after Non-Final Action
Jan 13, 2026
Non-Final Rejection — §103 (current)

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Expected OA Rounds
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Grant Probability
99%
With Interview (+20.0%)
2y 11m
Median Time to Grant
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