Prosecution Insights
Last updated: May 29, 2026
Application No. 18/339,518

REFRIGERATOR APPLIANCE AND WATER FILTER ASSEMBLY

Final Rejection §103
Filed
Jun 22, 2023
Examiner
GAYE, SAMBA NMN
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Haier US Appliance Solutions Inc.
OA Round
2 (Final)
64%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allowance Rate
93 granted / 146 resolved
-6.3% vs TC avg
Strong +36% interview lift
Without
With
+36.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
34 currently pending
Career history
199
Total Applications
across all art units

Statute-Specific Performance

§101
0.6%
-39.4% vs TC avg
§103
83.4%
+43.4% vs TC avg
§102
1.0%
-39.0% vs TC avg
§112
14.0%
-26.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 146 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 . Status This Office Action is in response to the remarks and amendments filed on 11/10/2025. The previous objections to the specification have been withdrawn. Claims 1-20 from which claims 5 and 15 are withdrawn remain pending for consideration. 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 1, 6-7, 9-11, 16-17, and 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over Subrahmanya et al. (US 20200306672 A1, herein after referred to as Subrahmanya) in view of Ebrom et al. (US 20110085287 A1, herein after referred to as Ebrom). Regarding claim 1, Subrahmanya teaches a water filtration assembly (filter assembly 200 Fig. 4) comprising: a filtration housing (the housing of filter cartridge 204 Fig. 4); a fluid inlet port (see below annotated Fig. 5 of Subrahmanya) and a fluid outlet port (see below annotated Fig. 5 of Subrahmanya) fixed to the filtration housing (Fig. 4); a first electrical contact (second contact 306 Fig. 5) positioned on the filtration housing (Fig. 5) separate and spaced apart from the fluid inlet port and the fluid outlet port (Fig. 5); a housing label (upper printed circuit board 252 Fig. 5) disposed on the filtration housing apart from the fluid inlet port and the fluid outlet port (Fig. 5); and an electrical connector (see below annotated Fig. 7 of Subrahmanya) joined to the housing label (Fig. 5), the electrical connector defining an intermediate electrical path (paragraph [0080]) to conduct power or communication signals (paragraph [0080]) between the water filtration assembly and a separate appliance (refrigerator appliance 100 Fig. 1 and paragraph [0080]). PNG media_image1.png 605 543 media_image1.png Greyscale PNG media_image2.png 514 810 media_image2.png Greyscale Subrahmanya teaches the invention as described above but fails to explicitly teach “a housing contact pad disposed beneath the housing label in electrical communication with the first electrical contact; the intermediate electrical path extending between the first electrical contact and the housing contact pad”. However, Ebrom teaches a housing contact pad (third service connector 164 Fig. 15) disposed beneath a housing label (badge 120 Fig. 15 corresponds to the housing label of Subrahmanya) in electrical communication with a first electrical contact (Fig. 15 and paragraph [0090] where second service connector 162 corresponds to the first electrical contact of Subrahmanya); an intermediate electrical path (service lines 166 Fig. 15 correspond to the intermediate electrical path of Subrahmanya) extending between the first electrical contact and the housing contact pad (Fig. 15) to provide communication between different components (paragraph [0089]). Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of Subrahmanya to include “a housing contact pad disposed beneath the housing label in electrical communication with the first electrical contact; the intermediate electrical path extending between the first electrical contact and the housing contact pad” in view of the teachings of Ebrom to provide communication between different components. Regarding claim 6, the combined teachings teach further comprising: an internal electrical path (see below annotated Fig. 7 of Subrahmanya) disposed within the filtration housing in electrical communication with the intermediate electrical path (paragraph [0080] of Subrahmanya). PNG media_image3.png 514 1129 media_image3.png Greyscale Regarding claim 7, the combined teachings teach wherein the housing contact pad is fixed to an external surface of the filtration housing (external surface of front end wall 154 Fig. 15 of Ebrom where side wall 156 corresponds to the filtration housing of Subrahmanya) in electrical communication between the internal electrical path (Fig. 16 of Ebrom where the internal electrical wiring path of badge 120 corresponds to the internal electrical path of Subrahmanya) and the intermediate electrical path (paragraph [0089] of Ebrom). Regarding claim 9, the combined teachings teach further comprising a validating electrical circuit or electrical chip (microcontroller 156 Fig. 7 of Subrahmanya which is understood to refer to the disclosed “dedicated controller” in paragraph [0069] of Subrahmanya) disposed on the housing label along the intermediate electrical path (Fig. 7 of Subrahmanya). Notes: the phrase “validating electrical circuit” is interpreted as being the same as the disclosed “electrical chip” in accordance to paragraph [0058] of the specification. Regarding claim 10, the combined teachings teach wherein the validating electrical circuit or electrical chip is configured to evaluate one or more electrical signals (paragraphs [0080] and [0081] of Subrahmanya) from the first electrical contact and selectively permit power transfer through the validating electrical circuit or electrical chip to the filtration housing based on the evaluation (paragraphs [0080] and [0081] of Subrahmanya). Furthermore, it is understood that claim 10 includes an intended use recitation, for example “…configured to...”. The Applicant is reminded that a recitation with respect to the manner which a claimed apparatus is intended to be does not differentiate the claimed apparatus from a prior art apparatus satisfying the structural limitations of the claims, as is the case here. While features of an apparatus may be recited either structurally or functionally, the claims are directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. Regarding claim 11, Subrahmanya teaches a refrigerator appliance (refrigerator appliance 100 Fig. 2) comprising: a cabinet (cabinet 102 Fig. 2) defining a chilled chamber (fresh food chamber 122 Fig. 2); a water filter (filter assembly 200 Fig. 2) selectively mounted to the cabinet (Fig. 3), the water filter comprising a filtration housing (the housing of filter cartridge 204 Fig. 4), a fluid inlet port (see below annotated Fig. 5 of Subrahmanya) and a fluid outlet port (see below annotated Fig. 5 of Subrahmanya) fixed to the filtration housing (Fig. 4), a first electrical contact (second contact 306 Fig. 5) positioned on the filtration housing (Fig. 5) separate and spaced apart from the fluid inlet port and the fluid outlet port (Fig. 5); a housing label (upper printed circuit board 252 Fig. 5) disposed on the filtration housing apart from the fluid inlet port (Fig. 5), and an electrical connector (see below annotated Fig. 7 of Subrahmanya) joined to the housing label (Fig. 5), the electrical connector defining an intermediate electrical path (paragraph [0080]) to conduct power or communication signals (paragraph [0080]) between the water filter and the cabinet (paragraph [0080]); and a second electrical contact (contact member 300 Fig. 5 of Subrahmanya) fixed to the cabinet and spaced apart from the filtration housing (Figs. 3 and 5). PNG media_image4.png 605 543 media_image4.png Greyscale PNG media_image5.png 514 810 media_image5.png Greyscale Subrahmanya teaches the invention as described above but fails to explicitly teach “a housing contact pad disposed beneath the housing label in electrical communication with the first electrical contact, the intermediate electrical path extending between the first electrical contact and the housing contact pad”. However, Ebrom teaches a housing contact pad (third service connector 164 Fig. 15) disposed beneath a housing label (badge 120 Fig. 15 corresponds to the housing label of Subrahmanya) in electrical communication with a first electrical contact (Fig. 15 and paragraph [0090] where second service connector 162 corresponds to the first electrical contact of Subrahmanya); an intermediate electrical path (service lines 166 Fig. 15 correspond to the intermediate electrical path of Subrahmanya) extending between the first electrical contact and the housing contact pad (Fig. 15) to provide communication between different components (paragraph [0089]). Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of Subrahmanya to include “a housing contact pad disposed beneath the housing label in electrical communication with the first electrical contact; the intermediate electrical path extending between the first electrical contact and the housing contact pad” in view of the teachings of Ebrom to provide communication between different components. The combined teachings teach the invention as described above but fail to explicitly teach “the second electrical contact in selective electrical communication with the first electrical contact”. However, a different embodiment of Subrahmanya teaches the second electrical contact (contact member 300 Fig. 14) in selective electrical communication with the first electrical contact (paragraph [0085] and Fig. 14) to provide a different electrical coupling between the appliance and the filter assembly. Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “the second electrical contact in selective electrical communication with the first electrical contact” in view of the teachings of a different embodiment of Subrahmanya to provide a different electrical coupling between the appliance and the filter assembly. Regarding claim 16, the combined teachings teach further comprising: an internal electrical path (see below annotated Fig. 7 of Subrahmanya) disposed within the filtration housing in electrical communication with the intermediate electrical path (paragraph [0080] of Subrahmanya). PNG media_image6.png 514 1129 media_image6.png Greyscale Regarding claim 17, the combined teachings teach wherein the housing contact pad is fixed to an external surface of the filtration housing (external surface of front end wall 154 Fig. 15 of Ebrom where side wall 156 corresponds to the filtration housing of Subrahmanya) in electrical communication between the internal electrical path (Fig. 16 of Ebrom where the internal electrical wiring path of badge 120 corresponds to the internal electrical path of Subrahmanya) and the intermediate electrical path (paragraph [0089] of Ebrom). Regarding claim 19, the combined teachings teach further comprising a validating electrical circuit or electrical chip (microcontroller 156 Fig. 7 of Subrahmanya which is understood to refer to the disclosed “dedicated controller” in paragraph [0069] of Subrahmanya) disposed on the housing label along the intermediate electrical path (Fig. 7 of Subrahmanya). Regarding claim 20, the combined teachings teach wherein the validating electrical circuit or electrical chip is configured to evaluate one or more electrical signals (paragraphs [0080] and [0081] of Subrahmanya) from the first electrical contact and selectively permit power transfer through the validating electrical circuit or electrical chip to the filtration housing based on the evaluation (paragraphs [0080] and [0081] of Subrahmanya). Furthermore, it is understood that claim 20 includes an intended use recitation, for example “…configured to...”. The Applicant is reminded that a recitation with respect to the manner which a claimed apparatus is intended to be does not differentiate the claimed apparatus from a prior art apparatus satisfying the structural limitations of the claims, as is the case here. While features of an apparatus may be recited either structurally or functionally, the claims are directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. Claims 2-4 and 12-14 are rejected under 35 U.S.C. 103 as being unpatentable over Subrahmanya and Ebrom as applied to claims 1 and 11 above, and further in view of Leimbach et al. (US 20220218344 A1, herein after referred to as Leimbach). Regarding claims 2 and 12, the combined teachings teach the invention as described above but fails to explicitly teach “wherein the first electrical contact comprises a conductive ring extending about the filtration housing”. However, Leimbach teaches wherein a first electrical contact (slip ring connector 1600 Fig. 20 corresponds to the first electrical contact of Subrahmanya) comprises a conductive ring (circuit trace assembly 1620 Fig. 21) extending about a filtration housing (Fig. 23 where shaft assembly 1200 corresponds to the filtration housing of Subrahmanya) to improve the electrical connection between the filter assembly and the appliance. Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “wherein the first electrical contact comprises a conductive ring extending about the filtration housing” in view of the teachings of Leimbach to improve the electrical connection between the filter assembly and the appliance. Regarding claims 3 and 13, the combined teachings teach wherein the first electrical contact comprises a plurality of parallel conductive rings (electrically-conductive paths 1636, 1646, 1656, and 1666 Figs. 21-22 and paragraph [0244] of Leimbach) axially spaced apart along the filtration housing (Figs. 21-22 of Leimbach). Regarding claim 4, the combined teachings teach further comprising: a second electrical contact (contact member 300 Fig. 5 of Subrahmanya) apart from the filtration housing (Fig. 5 of Subrahmanya). Regarding claim 14, the combined teachings teach the second electrical contact comprising a spring-loaded pin (pivoting arm 340 Fig. 14 of Subrahmanya) in selective contact with the electrical connector apart from the first electrical contact (paragraph [0085] and Fig. 14 of Subrahmanya). Claims 8 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Subrahmanya and Ebrom as applied to claims 1 and 11 above, and further in view of Primdahl et al. (US 5888381, herein after referred to as Primdahl). Regarding claims 8 and 18, the combined teachings teach the invention as described above but fails to explicitly teach “further comprising a housing cap selectively disposed on the filtration housing; and a cap contact pad fixed to the housing cap in electrical communication between the internal electrical path and the intermediate electrical path”. However, Primdahl teaches further comprising a housing cap (flexible cap 14 Fig. 1) selectively disposed on a filtration housing (Fig. 1 where housing 12 corresponds to the filtration housing of Subrahmanya); and a cap contact pad (actuator member 90 Fig. 5) fixed to the housing cap (Fig. 5) in electrical communication (Col. 6 lines 4-14) between an internal electrical path (electrical circuit 127 Fig. 8 corresponds to the internal electrical path of Subrahmanya) and an intermediate electrical path (flow switch 128 Figs. 7-8 corresponds to the intermediate electrical path of Subrahmanya) to monitor the amount of time elapsed since the filter cartridge has been last replaced. Therefore, it would have been obvious to a person skilled in the art before the effectively filed date to modify the apparatus of the combined teachings to include “further comprising a housing cap selectively disposed on the filtration housing; and a cap contact pad fixed to the housing cap in electrical communication between the internal electrical path and the intermediate electrical path” in view of the teachings of Primdahl to monitor the amount of time elapsed since the filter cartridge has been last replaced. Response to Arguments Applicant’s arguments with respect to the claims have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to SAMBA NMN GAYE whose telephone number is (571)272-8809. The examiner can normally be reached Monday-Thursday 4:30AM to 2:30PM. 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, Jerry -Daryl Fletcher can be reached at 571-270-5054. 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. /SAMBA NMN GAYE/Examiner, Art Unit 3763 /JERRY-DARYL FLETCHER/Supervisory Patent Examiner, Art Unit 3763
Read full office action

Prosecution Timeline

Jun 22, 2023
Application Filed
Sep 11, 2025
Non-Final Rejection mailed — §103
Nov 10, 2025
Response Filed
Apr 07, 2026
Final Rejection mailed — §103 (current)

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

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Prosecution Projections

3-4
Expected OA Rounds
64%
Grant Probability
99%
With Interview (+36.5%)
2y 10m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 146 resolved cases by this examiner. Grant probability derived from career allowance rate.

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