Prosecution Insights
Last updated: April 19, 2026
Application No. 18/357,331

THERMOELECTRIC COUPLER FOR SELECTIVE HEAT TRANSFER BETWEEN COOLANT LOOPS IN A DEVICE COOLING SYSTEM

Final Rejection §102§103
Filed
Jul 24, 2023
Examiner
MARONEY, JENNA M
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Microsoft Technology Licensing, LLC
OA Round
2 (Final)
64%
Grant Probability
Moderate
3-4
OA Rounds
2y 11m
To Grant
86%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allow Rate
318 granted / 494 resolved
-5.6% vs TC avg
Strong +21% interview lift
Without
With
+21.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
33 currently pending
Career history
527
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
45.8%
+5.8% vs TC avg
§102
20.8%
-19.2% vs TC avg
§112
30.9%
-9.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 494 resolved cases

Office Action

§102 §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 . Response to Amendment This Final Office Action is in response to Applicant’s Remarks/Amendments filed on 29 December, 2025. The amendments have been entered. Disposition of Claims Claims 1-5, 7-16, and 21-23 are pending. Claims 21-23 are new. Claims 6 and 17-20 have been cancelled. Claims 10-16 have been withdrawn. Information Disclosure Statement The information disclosure statement (IDS) submitted on 13 February, 2026 is being considered by the examiner. Specification Amendments to the abstract were received on 29 December, 2025. These amendments are acceptable, and overcome the objection set forth at page 3 of the Non-Final Office Action mailed on 30 September, 2025. 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. Claim(s) 1-4, 8, and 22 is/are rejected under 35 U.S.C. 103 as being unpatentable over KULKARNI (US 11,249,522 B2 – published 15 February, 2022), in view of SUNG (US 2019/0383528 A1 – published 19 December, 2019). As to claim 1, KULKARNI discloses a device cooling system (abstract; 1000; col.17, lines 43-52; col. 15, line 55-col.16, line 3) including: an air coolant loop(202 with structure 104; col.6, lines 30-36; col.7, lines 26-41)that circulates air through the device; an liquid coolant loop(202 with structure 104; col.6, lines 30-36; col.7, lines 26-41) that circulates liquid through a device; a thermoelectric cooler (TEC) (108) positioned between the air coolant loop and the liquid coolant loop (positioned thermally between, in addition to physically between 102 and 104 as shown in figures 1-3; col. 5, lines 18-67); and control electronics (col. 15, line 67-col.16, line 3) configured control the TEC to transfer heat between the first coolant loop and the second coolant loop (figure 9; col. 16, lines 40-61). However, KULKARNI does not expressly disclose wherein the control electronics is configured to selectively toggle the TEC from an off state to an on state to transfer heat away from the liquid coolant loop and into the air coolant loop responsive to determining that such a state of the device satisfies predefined criteria, and selectively toggle the TEC from the on state to the off state responsive to determining that the stat of the device no longer satisfies the predefined criteria. SUNG, however, is within the field of endeavor provided a device cooling system (abstract). SUNG teaches a liquid coolant loop (112) and an air coolant loop (combination of 108 and 130), wherein the thermoelectric cooler is positioned between the air and liquid coolant loops (figures 2A, 2B, 7A, and 7B). SUNG teaches control electronics (114) configured to control the TEC (par. 26 and 61), such that the control electronics is configured to(figure 9) selectively toggle the TEC from an off state to an on state (par. 62) to transfer heat away from the liquid coolant loop and into the air coolant loop responsive to determining that such a state of the device satisfies predefined criteria (figures 2A, 2B, 7A, and 7B; par. 62, in view of par. 44-45 and 57-58), and selectively toggle the TEC from the on state to the off state responsive to determining that the stat of the device no longer satisfies the predefined criteria(figures 2A, 2B, 7A, and 7B; par. 62). This enables control of the device cooling system to prevent degradation of the one or more heat sources, upon detection by the system that a predefined criteria is or is not met (par. 61). Therefore, it would have been obvious to one having ordinary skill within the art, prior to the date the invention was effectively filed, to modify KULKARNI, in view of the teachings of SUNG, to include such control teachings for the purpose of preventing degradation of the heat sources attached to such device cooling systems. As to claim 2, KULKARNI, as modified, further discloses wherein the air (col. 4, lines 10-32) coolant loop includes an air-cooled heat-sink (102; col. 4, lines 10-32) thermally coupled to a first side of the TEC (figure 1; col.5, lines 18-25). As to claim 3, KULKARNI, as modified, further discloses wherein the liquid coolant (col.4, lines 48-63) loop includes a cold plate (104; col. 4, lines 48-63) thermally coupled to a second side of the TEC opposite the first side of the TEC (figure 1; col.5, lines 18-25). As to claim 4, KULKARNI, as modified, further discloses wherein the air coolant loop includes a first cold plate (102; col. 4, lines 10-32) thermally coupled to a first side of the TEC(figure 1; col. 5, lines 18-25) and the liquid coolant loop includes a second cold plate (104; col. 4, lines 18-63) thermally coupled to a second side of the TEC opposite the first side (figure 1; col. 5, lines 18-25). As to claim 8, KULKARNI, as modified, previously disclosed wherein control electronic are configured to drive the TEC to transfer heat between the air and liquid coolant loops (see rejection of claim 1) so as to transfer heat between the first coolant loop and the second coolant loop to maintain temperature of a heat-generating component of the device within a target temperature range(figure 9; col. 5, lines 8-17, 33-40, 53-67; col. 7, line 50 – col.8, line 33; col. 15, line 67 - col.17, line 42). Furthermore, SUNG previously taught the control electronics selectively driving the TEC (see rejection of claim 1). As such, the combination yields the requirements set forth by the claim for the reasons previously set forth within the rejection of claim 1. As to claim 22, KULKARNI, as modified, previously taught the state of the device satisfies a predefined criteria (see rejection of claim 1). However, KULKARNI, along does not define this specific predefined criteria as being when a temperature of the device exceeds a predefined threshold. SUNG, however, expressly the state of the device satisfies predefined criteria (figures 2A, 2B, 7A, and 7B; par. 62, in view of par. 44-45 and 57-58 when a temperature of the device exceeds a predefined threshold (par. 61-62). This enables control of the device cooling system to prevent degradation of the one or more heat sources, upon detection by the system that a predefined criteria is or is not met (par. 61). Therefore, it would have been obvious to one having ordinary skill within the art, prior to the date the invention was effectively filed, to modify KULKARNI, in view of the teachings of SUNG, to include such control teachings for the purpose of preventing degradation of the heat sources attached to such device cooling systems. Claim(s) 9 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by KULKARNI (US 11,249,522 B2 – published 15 February, 2022), in view of SUNG (US 2019/0383528 A1 – published 19 December, 2019) and MONROE (US 6,418,728 B1 – published 16 July, 2002). As to claim 9, KULKARNI, as modified, previously disclosed where the control electronics drive the TEC (figure 9; col. 5, lines 8-17, 33-40, 53-67; col. 7, line 50 – col.8, line 33; col. 15, line 67 - col.17, line 42)by selectively altering a direction of the heat transfer in response to: detecting that a temperature differential between the first cooling media and the second cooling media exceeds a predefined threshold (col. 16, line 4 – col.17, line 42). Furthermore, KULKARNI discloses wherein the TEC operates based on a Peltier effect (col.5, lines 3-17), which is known to be able to alter the direction of the heat transfer based on the current applied (See MONROE – US 6,418,728 B1 – published 16 July, 2002 at col.5, line 26 – col.6, line 14). It is noted, "To serve as an anticipation when the reference is silent about the asserted inherent characteristic, such gap in the reference may be filled with recourse to extrinsic evidence. Such evidence must make clear that the missing descriptive matter is necessarily present in the thing described in the reference, and that it would be so recognized by persons of ordinary skill." Continental Can Co. USA v. Monsanto Co., 948 F.2d 1264, 1268, 20 USPQ2d 1746, 1749-50 (Fed. Cir. 1991). See MPEP § 2131.01 -III. To this end, the TEC and control electronics of KULKARNI are fully capable of performing the function of “selectively altering a direction of the heat transfer”, as required by the claims. Allowable Subject Matter Claims 5, 7, 21, and 23 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. Response to Arguments Applicant’s arguments, see pages 8-10, filed 29 December, 2025, with respect to the rejection(s) of claim(s) 1-8 under 35 U.S.C. 102(a)(1) as being anticipated by KULKARNI and the rejection(s) of claim(s) 9 under 35 U.S.C. 102(a)(1) as being anticipated by KULKARNI, in view of MONROE have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of SUNG (US 2019/0383528 A1 – published 19 December, 2019). SUNG teaches a liquid coolant loop (112) and an air coolant loop (combination of 108 and 130), wherein the thermoelectric cooler is positioned between the air and liquid coolant loops (figures 2A, 2B, 7A, and 7B). SUNG teaches control electronics (114) configured to control the TEC (par. 26 and 61), such that the control electronics is configured to(figure 9) selectively toggle the TEC from an off state to an on state (par. 62) to transfer heat away from the liquid coolant loop and into the air coolant loop responsive to determining that such a state of the device satisfies predefined criteria (figures 2A, 2B, 7A, and 7B; par. 62, in view of par. 44-45 and 57-58), and selectively toggle the TEC from the on state to the off state responsive to determining that the stat of the device no longer satisfies the predefined criteria(figures 2A, 2B, 7A, and 7B; par. 62). This enables control of the device cooling system to prevent degradation of the one or more heat sources, upon detection by the system that a predefined criteria is or is not met (par. 61). For this reason, the solution set forth within independent claim 1 is obvious, in view of the combination of prior art set forth herein. It will be noted, Applicant requests rejoinder of the method claims of claims 10-16. However, the method claims do not depend from an allowable product claim or otherwise require all the limitations of an allowable product claim. It will be noted, the method claims remain to be absent any recitation of control electronics, such that even if the product claims were found to be allowable, the method does not include all the limitations of the product claim or otherwise depend therefrom. 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 JENNA M MARONEY whose telephone number is (571)272-8588. The examiner can normally be reached Monday - Friday 7AM to 4PM, 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, Len Tran can be reached at (571) 272-1184. 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. /JENNA M MARONEY/Primary Examiner, Art Unit 3763 2/19/2026 JENNA M. MARONEY Primary Examiner Art Unit 3763
Read full office action

Prosecution Timeline

Jul 24, 2023
Application Filed
Sep 25, 2025
Non-Final Rejection — §102, §103
Dec 17, 2025
Applicant Interview (Telephonic)
Dec 17, 2025
Examiner Interview Summary
Dec 29, 2025
Response Filed
Feb 19, 2026
Final Rejection — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12600499
REFRIGERATION METHOD USING AN ARTIFICIAL NEURAL NETWORK
2y 5m to grant Granted Apr 14, 2026
Patent 12601553
METHOD FOR IDENTIFYING AND ELIMINATING AMMONIUM SALT DEPOSITION CHARACTERISTICS IN PIPE BUNDLE OF HYDROGENATION AIR COOLER
2y 5m to grant Granted Apr 14, 2026
Patent 12590676
MINIMIZING RECYCLE FLOW IN PUMP OPERATION
2y 5m to grant Granted Mar 31, 2026
Patent 12583289
Construction Machine
2y 5m to grant Granted Mar 24, 2026
Patent 12578125
METHOD FOR THE STABILISATION AND/OR OPEN-LOOP AND/OR CLOSED-LOOP CONTROL OF A WORKING TEMPERATURE, HEAT EXCHANGER UNIT, DEVICE FOR TRANSPORTING ENERGY, REFRIGERATING MACHINE AND HEAT PUMP
2y 5m to grant Granted Mar 17, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
64%
Grant Probability
86%
With Interview (+21.4%)
2y 11m
Median Time to Grant
Moderate
PTA Risk
Based on 494 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month