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 In claim 9, at line 10, replace “first” in “first bridge” with “full” to correct a typographical error. In claim 9, at line 11, replace “the external device” with “the external electronic device” to correct an antecedent basis issue. 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 appl icant regards as his invention. Claim s 4, 5, 7, 13-16, and 19 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. In claim s 4 and 19, the term “same” in phrase “in a same range as the reference current value” renders the claim indefinite. The term invites subjectiveness and it is unclear to a POSITA what the bounds of this range are unless it is strictly defined in the specification or claims. In claims 5, 7, 13, 14, 15, and 16, the term “certain” in phrases “within a certain error range” and “the certain error range” render the claim indefinite. As used, “certain” is a relative term of degree that renders the boundaries of the claim unclear. While the Specification (¶ 0118) may disclose an embodiment where the error range is 5%, the claim language itself is not explicitly limited to the percentage, leaving the exact scope of the claimed error range ambiguous and left to subjective interpretation. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis ( i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness . Claims 1, 2, 6, 8, and 17 are rejected under 35 U.S.C. 103 as being unpatentable over US Pub. No. 2010/0181961 to Novak et al. (“Novak”) in view of US Pub. No. 2009/0174263 to Baarman et al. (“ Baarman ”) . In independent claim 1 and similarly recited claim 17 , Novak teaches: a method/CRM/processor (¶ 0126 , 0127 ) for wirelessly charging an electronic device (¶ 0006 , 0030 . Novak is directed to wireless charging /wireless power transfer systems including a transmitter delivering energy to receiver devices. ) , the method /CRM/processor comprising: entering, by a first electronic device, a wireless charging mode upon determining that a second electronic device is accessing the first electronic device ( ¶ 0042. Novak teaches a transmitter (first device) that determines receiver presence (second device) using a load sensing circuit, and uses that determination to enable transmission. Specifically, Novak discloses a controller for enabling the oscillator during transmit phases (or duty cycles) and a load sensing circuit for detecting the presence or absence of active receivers, where the load sensing circuit monitors the current flowing to the power amplifier and detection of changes is monitored for use in determining whether to enable the oscillator for transmitting energy.) ; setting, by the first electronic device, a power transmission duty ratio of the first electronic device at a first level ; wirelessly supplying, by the first electronic device, power to the second electronic device at the power transmission duty ratio ( ¶ 0039. Novak teaches wirelessly supplying power from the transmitter to receiver devices once they are present in the coupling region.) ; monitoring, by the first electronic device, a current value of the first electric device used to provide the power to the second electronic device ( ¶ 0042, 0061. Novak teaches monitoring a transmitter-side current used to provide wireless power. The load sensing circuit monitors the current flowing to the power amplifier, and changes in that current are used by the controller in connection with enabling transmission. ) ; and controlling, by the first electronic device, the power transmission duty ratio according to the monitored current value . Novak does teach transmit phases/duty cycles generally and also teaches tailoring delivered power by adjusting the amount of power transmitted, adjusting the amount of time that power is transmitted, or a combination thereof (¶ 0041, 0065). Novak, however, does not explicitly teach setting a power transmission duty ratio to a first level, and dynamically controlling that duty ratio according to the monitored current value to limit power. Baarman is directed to a wireless power supply that controls the amount of power transferred by adjusting the duty cycle (Abstract) . Baarman teaches setting an initial duty cycle (i.e., first duty level) at the beginning of operation ( ¶ 0008 ) . Baarman states the primary circuit sets the initial duty cycle and the initial duty cycle is set at 20% , which is considered low enough to not risk over powering (¶ 0008) . Baarman further teaches controlling duty cycle based on current sensing feedback (¶ 0047). It would have been obvious to a POSITA to modify the wireless power transmitter of Novak to include initial duty cycle setting and current-based duty cycle control method taught by Baarman . The modification would provide an additional , fine-tuned level of control over the wireless power transfer, specifically to prevent short-circuiting or overpowering the receiving device during the initial connection and charging phases, thereby improving the safety and stability of the power transfer system taught by Novak. As to claim 2 , t he method of claim 1, wherein the monitoring the current value includes the first electronic device comparing a value of a current measured by a current sensor included in the first electronic device with a reference current value (Novak: ¶ 0071) . As to claim 6 , t he method of claim 2, wherein the controlling the power transmission duty ratio according to the monitored current value includes, when the value of the current measured by the current sensor included in the first electronic device is less than the reference current value, controlling the power transmission duty ratio of the first electronic device to a second level higher than the first level ( Baarman : Fig. 5: If the power is not too high at 510 (which equates to being less than the reference current value ), the duty cycle is increased 512. The increased duty cycle 512 is greater than the set initial duty cycle 506.) . As to claim 8 , t he method of claim 1, wherein the first level is lower than a highest power transmission duty ratio supported by the first electronic device ( Baarman : ¶ 0008, initial duty cycle set low to 20%.) . Claims 3 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Novak in view of Baarman and in further view of US Patent No. 7,385,357 to Kuennen et al. (“ Kuennen ”) . Novak in view of Baarman teach the limitations of claim 2 from which claim 3 depends and which are similarly recited limitations in claim 18 (Novak: ¶ 0071) . Novak in view of Baarman , however, do not teach an overcurrent reference value such that, when exceeded, the wireless charging operation is blocked at that overcurrent value. Kuennen teaches an inductively coupled wireless power supply comprising an current limit circuit that provides overcurrent protection on the primary side (Abstract). Specifically, Kuennen teaches the current limit circuit monitors the primary tank current and disables the primary circuit when the current exceeds a predetermined threshold (Abstract, i.e., an overcurrent value). It would have been obvious to a POSITA to modify the wireless power transmitter of Novak and Baarman to include the primary-side overcurrent disablement feature taught by Kuennen . This combination ensures that if a severe fault condition occurs that cannot be resolved by merely throttling the duty ratio, the transmitter will completely block the charging operation, thereby preventing thermal damage to components. Claim 4 and similarly recited claim 19, and claim 20 are rejected under 35 U.S.C. 103 as being unpatentable over Novak in view of Baarman and in further view of US 2019/0089171 to Fischer et al. (“Fischer”). Novak in view of Baarman does not teach claim 4 or similarly recited claim 19, which require the duty ratio control is performed such that the value of the current measured is maintained to be lower than the reference current value or in a same range as the reference current value. Fischer teaches comparing a measured coil current amplitude to a predefined threshold and altering a PWM control signal (including duty cycle) to reduce the current below that threshold (¶ 0007, 0014). Fischer’s predefined threshold corresponds to “reference current value” and reducing the measured current “below” that threshold corresponds to maintained to be lower than or in a same range as the reference value. It would have been obvious to a POSITA to modify Novak’s transmitter system as controlled by Baarman’s duty cycle technique to further implement Fischer’s threshold based current limiting via duty cycle adjustment. The combination provides improved protection against inrush currents and hardware damage, and makes use of a known, predictable control refinement to keep current below the threshold. As to claim 20 , the non-transitory computer-readable medium of claim 19, wherein the control of the power transmission duty ratio according to the monitored current value includes, when the value of the current measured by the current sensor included in the device configured to transmit the power signal is less than the reference current value, controlling the power transmission duty ratio of the device configured to transmit the power signal, to be at a second level higher than the first level ( Baarman : Fig. 5: If the power is not too high at 510 (which equates to being less than the reference current value), the duty cycle is increased 512. The increased duty cycle 512 is greater than the set initial duty cycle 506.) . Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Novak in view of Baarman and in further view of US Patent No. 11,050,307 to Qiu et al. (“Qiu”). Novak in view of Baarman teach in Baarman’s Fig. 5: if power is too high, decrease duty cycle; if not too high, increase duty cycle, which lacks a defined “error range” wherein the system maintains the initial duty cycle without stepping it up or down. Thus, the combination does not teach claim 5. Qiu teaches a method for operating a wireless power transmitter that utilizes inverter circuitry at different respective duty cycles (Abstract) . Qiu teaches monitoring load current and load voltage, and comparing this measured information against an expected baseline (reference values) (Abstract, Fig. 7) . To prevent unnecessary interruptions or extreme system reactions to minor fluctuations, Qiu teaches establishing a “threshold amount” for these deviations (10:25-37) . If the monitored current deviates from the expected reference by less than this threshold amount, the system tolerates the minor shift and maintains the ongoing wireless power transmission at its current duty cycle (Fig. 7: 86, 90) . It would have been obvious to a POSITA to modify Novak’s transmitter as controlled by Baarman’s current sensor-based duty cycle method to further incorporate the threshold control behavior taught by Qiu. The combination improves stability and avoid unnecessary duty cycle adjustments when the sensed current is sufficiently close to the reference value. Claim s 9 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over US Pub. No. 2021/0237602 to Wang et al. (“Wang”) in view of Baarman . As to claim 9 , Wang teaches: an electronic device configured to wirelessly transmit power to an external electronic device (¶ 0040: DIPT system.) , the electronic device comprising: a power source (¶ 0040: AC-to-DC power converter 30 provides a regulated DC output current 39. ) ; a transmission coil ( ¶ 0076: module transmitter coil and compensation circuit 70 comprising transmitter coil 71. ) ; a full bridge circuit electrically connected to the power source and the transmission coil (¶ 0076: module transmitter 60 is a H-bridge. Fig. 10A depicts this full bridge having four unidirectional switches 62a, 62b, 62c, and 62d electrically connected to power source (via 39) and coil 71.) ; a controller configured to communicate with the external electronic device via the transmission coil, and transmit a power signal via the transmission coil by controlling the full bridge circuit (¶ 0077: Controller 80 is configured to control the state of the module transmitter circuit 60 (full bridge) based on input signals.) ; and a current sensor configured to sense a current flowing through the full bridge circuit (¶ 0092, 0093: Power transmitter module includes first current sensing circuit 55a to measure current flow through the module, and a second current sensing circuit 55b to measure current flow through the transmitter coil and compensation circuit 70.) , wherein the controller is configured enter a first operation mode to control the first bridge circuit to wirelessly provide the power signal to the external device at a power transmission duty ratio of a first level upon determining that the external electronic device is accessing the electronic device at a first time, and wherein the controller is configured to increase the power transmission duty ratio of the power signal to a second level higher than the first level at a second time after the first time and then enter a second operation mode (¶ 0077: Controller 80 is configured to control the state of the module transmitter circuit 60 (full bridge) based on input signals.) . Wang provides the hardware recited in claim 9, but does not teach two functional limitations of claim 9: communicate with the external electronic device via the transmission coil, and the first/second operation mode. Baarman teaches communicating data from the secondary to primary controller using the transmission coils. It does this via “planned shunting of the signal resistor on the secondary using reflected impedance detected with the current sensor 322 (¶ 0030). Baarman further teaches a startup protocol where the primary circuit sets an “initial duty cycle” to a “relatively low value” (e.g., 20%) so it does not risk overpowering the remote device upon initial connection (¶ 0008). This is the first operation mode at a first level. Then, if power is not too high, the system enters a continuous process where the duty cycle of the power being transferred is increased (Fig. 5). This is maps to increasing the duty ratio to a second level higher than the first level and the second operation mode. It would have been obvious to a POSITA to combine Wang’s H-bridge wireless charging hardware with Baarman’s control logic. The combination provides for safely managing initial power connection and prevents massive inrush currents or overpowering when a vehicle/device first aligns with the charging pad. As to claim 10 , t he electronic device of claim 9, wherein the full bridge circuit comprises: a first switch electrically connected to one end of the transmission coil and turned on in response to a first gate signal of the controller ( Wang: ¶ 0082-0087: Four switches (62a-62d) of full bridge in a H-bridge configuration disclosed, each switch is electrically connected to transmission coil 71, and operates in response controller 80.) ; a second switch electrically connected to the one end of the transmission coil and turned on in response to a second gate signal of the controller ( Wang: ¶ 0082-0087: Four switches (62a-62d) of full bridge in a H-bridge configuration disclosed, each switch is electrically connected to transmission coil 71, and operates in response controller 80.) ; a third switch electrically connected to the other end of the transmission coil and turned on in response to a third gate signal of the controller ( Wang: ¶ 0082-0087: Four switches (62a-62d) of full bridge in a H-bridge configuration disclosed, each switch is electrically connected to transmission coil 71, and operates in response controller 80.) ; and a fourth switch electrically connected to the other end of the transmission coil and turned on in response to a fourth gate signal of the controller ( Wang: ¶ 0082-0087: Four switches (62a-62d) of full bridge in a H-bridge configuration disclosed, each switch is electrically connected to transmission coil 71, and operates in response controller 80.) , wherein the controller is configured to control the power transmission duty ratio of the power signal by shifting switching timings of some of the first gate signal, the second gate signal, the third gate signal, and the fourth gate signal in the first operation mode ( Wang: ¶ 0086, 0089. Wang teaches controlling the current/power output by shifting the timing of these switches. ) . Allowable Subject Matter Claims 7 and 11-16 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 , and further amended to overcome any applicable § 112 rejection set forth above. Claims 7 and 11-16 would be allowable if rewritten in the manner above because the prior art of record does not teach or suggest method or device having all the combinations of steps or elements as recited in and required by claim 7 or claim 11. Claims 12-16 depend from claim 11. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Examiner SURESH MEMULA whose telephone number is (571)272-8046 , and any inquiry for a formal Applicant initiated interview must be requested via a PTOL-413A form and faxed to the Examiner's personal fax phone number: (571) 273-8046. Furthermore, Applicant is invited to contact the Examiner via email ( suresh.memula@uspto.gov ) on the condition the communication is pursuant to and in accordance with MPEP §502.03 and §713.01. The Examiner can normally be reached Monday-Thursday: 9am-6pm. If attempts to reach the Examiner by telephone are unsuccessful, the Examiner’s supervisor, Jack Chiang, can be reached on 571-272-7483. The fax phone number for the organization where this application or proceeding is assigned (i.e., central fax phone number) is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /SURESH MEMULA/ Primary Examiner, Art Unit 2851