Prosecution Insights
Last updated: April 19, 2026
Application No. 18/345,343

SPACE-BASED SOLAR POWER SYSTEM

Final Rejection §103
Filed
Jun 30, 2023
Examiner
DINH, BACH T
Art Unit
1726
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Overview Energy Inc.
OA Round
3 (Final)
55%
Grant Probability
Moderate
4-5
OA Rounds
3y 2m
To Grant
87%
With Interview

Examiner Intelligence

Grants 55% of resolved cases
55%
Career Allow Rate
530 granted / 966 resolved
-10.1% vs TC avg
Strong +32% interview lift
Without
With
+32.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
50 currently pending
Career history
1016
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
50.5%
+10.5% vs TC avg
§102
26.7%
-13.3% vs TC avg
§112
19.3%
-20.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 966 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 . Summary This is the response to the communication filed on 01/13/2026. Claims 1-15, 19-20 and 28-29 remain pending in the application. 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. Claim(s) 1-7, 20 and 29 is/are rejected under 35 U.S.C. 103 as being unpatentable over Tillotson (US 2023/0035481 or ‘481) in view of Tillotson (US 2008/0275572 or ‘572). Addressing claim 1, Tillotson ‘481 discloses a system comprising: an artificial light source (space apparatus 110 with light emitting devices, [0020]) configured to be disposed at a distance from earth or other celestial body [0020], wherein the artificial light source is configured to project one or more beams of light onto the earth or another celestial body (paragraph [0028] discloses space apparatus 110 includes a first photovoltaic cell 112 and light emission system 120 that implies the space apparatus is configured to project one or more beams of light via the light emission system 120 to a second photovoltaic cell 112 located on earth); a terrestrial photovoltaic receiver (second photovoltaic cell located on earth [0028]) disposed in an area on earth or other celestial body that is 200 m – 20 km in any one dimension (the photovoltaic cell of Tillotson is positioned in an area on earth, which includes a surrounding area that is 200 m – 20 km as claimed; for instance, when the photovoltaic cell of Tillotson is positioned in the middle of the state of Virginia, which has an area of 110,862 km2; therefore, the area in the state of Virginia in which the photovoltaic cell of Tillotson is positioned is between 200 m – 20 km in any one dimension as claimed) that is configured to receive the projected one or more beams of light and is configured to convert the received one or more beams of light into electricity [0028]. Tillotson ‘481 is silent regarding the photovoltaic array. Tillotson ‘572 discloses a photovoltaic array 104 (the plurality of photovoltaic panels that are electrically coupled to function as an entity corresponds to the claimed photovoltaic array) configured to receive energy beam 104, such as laser beam, for converting laser beam into electricity [0034]. At the time of the effective filing date of the invention, one with ordinary skill in the art would have found it obvious to modify the system of Tillotson ‘481 by applying the known technique of coupling a plurality of solar panels into a known photovoltaic array entity as disclosed by Tillotson ‘572 in order to obtain the predictable result of converting laser energy beam in to electrical power (Rationale D, KSR decision, MPEP 2143). Furthermore, the photovoltaic array configuration of Tillotson ‘572 has sufficient area to capture and convert essentially all of the meaningful energy content of the laser energy beam [0036], thus improving photoelectric conversion efficiency [0040]. In the modified system of Tillotson ‘481 in view of Tillotson ‘572, the photovoltaic array is positioned in an area on earth, which has an area that is 200 m – 20 km in any one dimension as discussed above. Addressing claim 2, Tillotson ‘481 discloses in paragraph [0045] the light emitting devices with one or more beams of light having peak wavelengths that fall within the claimed range. Addressing claim 3, the limitation of current claim is drawn to the process of selecting the peak wavelength of the one or more beams of artificial light source corresponding to the efficiency range of the terrestrial photovoltaic array without reciting any numerical values associated with the claimed peak wavelength and efficiency range of the terrestrial photovoltaic array to structurally differentiate the claimed system from that of the prior art. Furthermore, fig. 2 of Tillotson ‘481 shows the selection of the peak wavelength of the light emitting devices that correspond to the absorption characteristics of the semiconductor material of the terrestrial photovoltaic array that satisfies the claimed limitation. Addressing claim 4, paragraph [0026] of Tillotson ‘481 discloses the claimed materials. Addressing claims 5-6, fig. 1 of Tillotson ‘481 discloses the space apparatus or the claimed artificial light source combines light from a plurality of sources to form the one or more projected beams of light. The different light sources correspond to the claimed incoherently combined. Addressing claim 7, Tillotson ‘481 discloses the light emission system comprises a plurality of lasers emitting different wavelengths and/or photon energies (Abstract). Addressing claim 20, see figs. 2 and 4-5 of Tillotson ‘481. Addressing claim 29, the system of Tillotson ‘481 includes structures that operate in outer space environment and terrestrial environment, that includes temperatures that fall within the claimed range of 210K to 315K; for example, the terrestrial photovoltaic receiver of Tillotson ‘481 is situated on Earth, which has a surface temperature that falls within the claimed range. Claim(s) 8-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Tillotson (US 2023/0035481 or ‘481) in view of Tillotson (US 2008/0275572 or ‘572) as applied to claims 1-7, 20 and 29 above, and further in view of Virdee (US 2024/0067366). Addressing claim 8, Tillotson ‘481 and Tillotson ‘572 are silent regarding the limitation of current claim. Virdee discloses artificial light source comprises laser diodes coupled to delivery fiber [0069-0070] for sending laser to photovoltaic array for converting laser beam to electrical energy (fig. 1). At the time of the effective filing date of the invention, one with ordinary skill in the art would have found it obvious to modify the system of Tillotson ‘481 with the known laser diodes coupled to delivery fibers as disclosed by Virdee in order to obtain the predictable result of delivering laser team to the target photovoltaic array for energy conversion (Rationale B, KSR decision, MPEP 2143) with improved beam quality (Virdee, [0070]. Addressing claim 9, fig. 1 of Virdee shows the deliver fibers are combined to send one or more beams of light from the system towards the intended photovoltaic arrays that meet the claimed limitation. Claim(s) 10-12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Tillotson (US 2023/0035481 or ‘481) in view of Tillotson (US 2008/0275572 or ‘572) and Virdee as applied to claims 8-9 above, and further in view of Atwater et al. (US 2016/0056321). Addressing claims 10-11, Tillotson ‘481, Tillotson ‘572 and Virdee are silent regarding the limitations of current claims. Atwater discloses each module, which comprises the photovoltaic array and the associated structure for sending laser beam, includes radiative heat sink to control the operating temperature within a range from 150 to 300 K [0084] that overlaps with the claimed temperature range. Therefore, it would have been obvious for one of ordinary skill in the art to modify the plurality of modules of Tillotson ‘481 modified system with the radiative heat sink disclosed by Atwater in order to manage the temperature of the modules in their optimum operating condition. With regard to the limitation of claim 11, both Tillotson ‘481 and Atwater disclose the claimed satellite on which the photovoltaic array, the laser modules and the associated heat sink are positioned; therefore, the limitation of claim 11 would have been obvious based on the teaching of Tillotson ‘481 in view of Atwater and Virdee as discussed above. Addressing claim 12, Atwater discloses the need for lightweight satellite by reducing the dimension of the satellite prior to deployment; therefore, absent evidence of unexpected results, one with ordinary skill in the art would have arrived at the claimed size of the satellite when perform routine experimentation with the length, height and/or width of the satellite (Atwater, [0067]) to optimize the weight of the satellite for deployment. Claim(s) 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Tillotson (US 2023/0035481 or ‘481) in view of Tillotson (US 2008/0275572 or ‘572) as applied to claims 1-7, 20 and 29 above, and further in view of Niedrig (EP2056144 with provided machine English translation). Addressing claim 13, Tillotson ‘481 and Tillotson ‘572 are silent regarding the claimed minimum beam parameter product range. Niedrig discloses laser used for optoelectronic transmitter (paragraph [0005] of the translation document); wherein, the BPP of the laser source is between 0.3 to about 20 mm-mrad [0023]. At the time of the effective filing date of the invention, one with ordinary skill in the would have arrived at the claimed BPP of the artificial light source in the range greater than 10 mm-mrad when perform routine experimentation with the BPP of the laser source of Tillotson ‘481 in the range disclosed by Niedrig in order to optimize the quality of the laser beam. Claim(s) 14-15, 19 and 28 is/are rejected under 35 U.S.C. 103 as being unpatentable over Tillotson (US 2023/0035481 or ‘481) in view of Tillotson (US 2008/0275572 or ‘572) as applied to claims 1-7, 20 and 29 above, and further in view of Atwater et al. (US 2016/0056321). Addressing claims 14 and 28, Tillotson discloses the system comprises a satellite (the space apparatus 110) comprising the artificial light source (light emitting devices) and a photovoltaic array (first photovoltaic cell [0028]) electrically coupled to the artificial light source and configured to power the artificial light source [0028]. Tillotson is silent regarding at least one radiator panel configured to dissipate heat generated by the artificial light source into space. Atwater discloses in fig. 4a that the photovoltaic array 113 and the power transmitter 114 (for transmitting laser light [0066 and 0072]) are provided on the same space vehicle. Atwater further discloses heat sink associated with the photovoltaic array to improve the efficiency of the photovoltaic cell [0084]. The heat sink, as the structural equivalence to the claimed radiator panel, is configured to dissipate heat generated by the artificial light source into space because it is provided in the same structure as the artificial light source. At the time of the effective filing date of the invention, one with ordinary skill in the art would have found it obvious to modify the space apparatus of Tillotson with the heat sink disclosed by Atwater in order to cool and improve the efficiency of the photovoltaic array (Atwater, [0084]). In the modified space apparatus of Tillotson in view of Atwater, the heat sink, as the structural equivalence to the claimed radiator panel, is configured to dissipate heat generated by the artificial light source into space because the heat sink is provided in the same vehicle as the photovoltaic array and the artificial light source. Addressing claim 15, the heat sink disclosed by Atwater is configured to increase the efficiency of the artificial light source indirectly because it increases the efficiency of the photovoltaic array which provides more power to the artificial light source. The heat sink also increases the output power of the artificial light source by increasing the efficiency of the photovoltaic array, which provides more power to the artificial light source. Addressing claim 19, the limitation of current claim is drawn to the selection of a size and mass of the radiator panel without reciting any numerical values associated with the size and mass of the radiator panel to structurally differentiate the claimed radiator panel from that of the prior art. Atwater discloses each module, which comprises the photovoltaic array and the associated structure for sending laser beam, includes radiative heat sink to control the operating temperature within a range from 150 to 300 K [0084] that overlaps with the claimed temperature range of 210K – 315K. Response to Arguments Applicant's arguments filed 01/13/2026 have been fully considered but they are not persuasive. With regard to the rejection of claims 1-7, 20 and 29 as being unpatentable over the disclosure of Tillotson ‘481 in view of Tillotson ‘572, the Applicant argued that the cited references do not teach the limitation “a terrestrial photovoltaic array disposed in an area on the earth or other celestial body that is 200 m – 20 km in any one dimension that is configured to receive the projected one or more beams of light and is configured to convert the received one or more beams of light into electricity” because Tillotson ‘481 does not disclose the size of the energy receiving device and Tillotson ‘572 only discloses the size of the beam receiving device is no more than a few meters in span (pages 6-7 of the Remarks). The argument is not persuasive because the limitation “a terrestrial photovoltaic array disposed in an area on the earth or other celestial body that is 200 m – 20 km in any one dimension” (emphasis added), when read in light of the specification, means any one dimension of the area on the earth or other celestial body in which the terrestrial photovoltaic array is disposed is 200 m – 20 km. In other words, the aforementioned limitation, when read in light of the specification, does not mean the area or size of the terrestrial photovoltaic array is between 200 m – 20 km in any one dimension because the claimed distance range in any one dimension is drawn to the area in which the terrestrial photovoltaic array is disposed. Not only the originally filed disclosure does not disclose that the size of the terrestrial photovoltaic array is 200 m – 20 km in any one dimension as alleged by the Applicant but the originally filed disclosure also does not disclose how much of the area on the earth or other celestial body that is 200 m – 20 km in any one dimension is covered by the terrestrial photovoltaic array. Two photovoltaic devices, regardless of their size, that constitutes the claimed terrestrial photovoltaic array could be positioned in an area that is 20 km in any one dimension and would still satisfy the aforementioned limitation when it is read in light of the specification. In instant situation, the photovoltaic array of Tillotson ‘481 in view of Tillotson ‘572 is positioned on earth, which quality the photovoltaic array as the claimed terrestrial photovoltaic array. The area on the earth, which has an area that is larger than 200 m – 20 km in any one dimension, in which the terrestrial photovoltaic array of Tillotson ‘481 in view of Tillotson ‘572 is positioned inherently is 200 m – 20 km in any one dimension. Therefore, the Applicant’s argument is not persuasive because it does not address the content of the claims and the content of the rejection. For the reason above, Examiner maintains the position that claims 1-7, 20 and 29 are obvious based on the disclosure of Tillotson ‘481 and Tillotson ‘572. The arguments regarding the rejection of claims 8-15, 19 and 28 are not persuasive because the arguments regarding the rejection of claim 1 are not persuasive. 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 BACH T DINH whose telephone number is (571)270-5118. The examiner can normally be reached Mon-Friday 8:00 - 4:30 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, Jeffrey Barton can be reached at (571)-272-1307. 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. /BACH T DINH/Primary Examiner, Art Unit 1726 02/19/2026
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Prosecution Timeline

Jun 30, 2023
Application Filed
Apr 23, 2025
Non-Final Rejection — §103
Sep 11, 2025
Applicant Interview (Telephonic)
Sep 11, 2025
Examiner Interview Summary
Sep 24, 2025
Response Filed
Oct 24, 2025
Non-Final Rejection — §103
Jan 13, 2026
Response Filed
Feb 19, 2026
Final Rejection — §103
Mar 19, 2026
Examiner Interview Summary
Mar 19, 2026
Applicant Interview (Telephonic)

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

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Prosecution Projections

4-5
Expected OA Rounds
55%
Grant Probability
87%
With Interview (+32.5%)
3y 2m
Median Time to Grant
High
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