Prosecution Insights
Last updated: August 12, 2026
Application No. 18/373,567

IMMERSION COOLING CONTAINER

Non-Final OA §103
Filed
Sep 27, 2023
Priority
Apr 01, 2021 — EU 21305427.3 +1 more
Examiner
PAPE, ZACHARY
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Ovh
OA Round
4 (Non-Final)
72%
Grant Probability
Favorable
4-5
OA Rounds
0m
Est. Remaining
92%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allowance Rate
803 granted / 1108 resolved
+4.5% vs TC avg
Strong +19% interview lift
Without
With
+19.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
38 currently pending
Career history
1139
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
50.3%
+10.3% vs TC avg
§102
27.1%
-12.9% vs TC avg
§112
17.8%
-22.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1108 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 . Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. It is noted that the priority document dated 4/1/2021 is NOT believed to support the present claims and, accordingly, the effective filing date of the claims is considered to be 4/1/2022. Information Disclosure Statement The Information Disclosure Statements filed 3/25/2026, 5/5/2026 have been fully considered and are attached hereto. Claim Objections The objection to claims 9-15, 19 are withdrawn in view of the amendment to claim 9. 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. 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, 3, 5, 6-17, 19 are rejected under 35 U.S.C. 103 as being unpatentable over Hirari et al. (US 2018/0153058 – previously cited on an IDS) in view of Kong (CN 110430725 – previously cited on an IDS) and further in view of Berlin et al. (US 2007/0025081 – hereinafter, “Berlin”) and further in view of Chen et al. (CN 210591899 – hereinafter, “Chen”). With respect to claims 1 and 3, Hirari teaches (In Fig 3) an autonomous immersive cooling container configured to cool at least one electronic device (15), the autonomous immersive cooling container comprising: a container (11), having sidewalls (See Fig 3), that contains a dielectric immersion cooling liquid (13, ¶ 0027, “As the coolant 13, for example, a fluorine compound such as, for example, 3M™ Fluorinert™”, where Fluorinert™ is a known dielectric cooling liquid), the at least one electronic device being, at least in part, immersed in the dielectric immersion cooling liquid (See Fig 3); and a plurality of cooling structures (16 + 18) disposed at non-perpendicular angles on a sidewall (See Fig 3), the plurality of cooling structures configured to transfer heat from an interior of the container to exterior air such that no additional cooling subsystem is used to cool the dielectric immersion cooling liquid (¶ 0060, “Therefore, because facilities such as a pump for circulating the coolant 13 and a chiller for cooling the coolant 13 are unnecessary, electric power required for the cooling of the electronic device 15 may be remarkably reduced.”). Hirari fails to specifically teach or suggest that the plurality of cooling structure are disposed on multiple sidewalls, and a door that may be opened and closed to facilitate insertion and removal of the at least one electronic device, wherein the door comprises one or more cooling structures integrally connected to the door configured to transfer heat from an interior of the autonomous immersive cooling container to exterior air (Cl. 1), wherein the door is configured to seal the autonomous immersive cooling container when closed (Cl. 3). Kong, however, teaches (In Fig 1) a plurality of cooling structures (4) disposed on multiple sidewalls (3) of a container. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Kong with that of Hirari, such that the plurality of cooling structures in Hirari are provided on multiple sidewalls, as taught by Kong, since doing so would increase heat transfer from the cooling liquid to the atmosphere. With respect to the limitations that a door that may be opened and closed to facilitate insertion and removal of the at least one electronic device, wherein the door comprises one or more cooling structures configured to transfer heat from an interior of the autonomous immersive cooling container to exterior air, wherein the door is configured to seal the autonomous immersive cooling container when closed (Cl. 3), Berlin teaches (In Fig 1) a door (12A) that may be opened and closed to facilitate insertion and removal of at least one electronic device (16), wherein the door is configured to seal a container (12b) when closed (¶ 0017, “The cover 12A is sealed via a seal (e.g., gasket) 30 and fasteners (e.g., threaded screws) (not shown) to the base 12B to define a sealed enclosure that prevents ingress and egress of fluid.”), wherein the door (12A) comprises one or more cooling structures (24) configured to transfer heat from an interior of the container to exterior air (See Fig 1). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Berlin with that of Hirari, such that Hirari includes a door that may be opened and closed to facilitate insertion and removal of the at least one electronic device, wherein the door is configured to seal the autonomous immersive cooling container when closed, wherein the door comprises one or more cooling structures configured to transfer heat from an interior of the autonomous immersive cooling container to exterior air, as taught by Berlin, since doing so would allow for the electronic device inside the container to be easily accessed and to provide additional cooling means to the dielectric immersion cooling liquid. With respect to the limitations which require that the one or more cooling structures be integrally connected to the door, Chen teaches one or more cooling structures (3) which are integrally connected to a door (2, “the access door 2 and the heat dissipation fin 3 is an integral structure made of metal aluminium material”). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Chen with that of modified Hirari, such that the fins on the door of modified Hirari are integrally connected therewith, as taught by Chen, since doing so would reduce the number of manufacturing steps necessary to make the door with cooling structures (IE the cooling structures and the door can be made together in a single step). Further, it has been held that making a multi-piece structure, as taught by Berlin with its seemingly separate door and cooling structures, into a single integral piece is obvious1 . With respect to claim 5, Hirari as modified by Kong, Berlin and Chen teaches the limitations of claim 1 as per above and Kong further teaches that the plurality of cooling structures (4) comprise fins (See Fig 1). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the further teachings of Kong with that of Hirari such that the sidewalls of the container of Hirari includes fins disposed at non-perpendicular angles on the sidewalls, as taught by Kong, since doing so would increase heat transfer from the dielectric immersion cooling liquid in the container. With respect to claim 6, Hirari as modified by Kong, Berlin and Chen teaches the limitations of claim 5 as per above but fails to specifically teach or suggest that the fins are formed as a unitary part of the sidewalls and/or the door. However, it has been held that making a multi-piece structure into a single integral piece is obvious1. Thus, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to make the sidewall and fins as an integral structure to reduce manufacturing time and expense (Making the sidewall and fins as one piece reduces manufacturing steps, for example). With respect to claims 7-8, Hirari as modified by Kong, Berlin and Chen teaches the limitations of claim 1 as per above and Kong further teaches that the cooling structures (4) are made of copper (“the radiating plate 3 and the fins 4 are made of copper material”). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Kong with that of Hirari as modified by Kong and Berlin, such that the fins comprise copper, as taught by Kong, since doing so would allow for the fins to be made of a material which is relatively cheap, easy to manufacture and has a good thermal conductivity. With respect to claim 9, Hirari further teaches that the cooling structures (16) comprise heat pipes (¶ 0030, “a plurality of heat pipes 16”), the heat pipes comprising: a first end disposed within the autonomous immersive cooling container, the first end configured to collect thermal energy from the dielectric immersive cooling liquid or vaporized dielectric immersive cooling liquid (See Fig 3); a second end disposed external to the autonomous immersive cooling container, the second end configured to transfer thermal energy to air outside of the autonomous immersive cooling container (See Fig 3); and a working liquid (17) disposed in an internal sealed chamber defined by the heat pipe, the working liquid configured to vaporize at the first end due to the thermal energy from the dielectric immersive cooling liquid or vaporized dielectric cooling liquid, and to condense at the second end as thermal energy is transferred to the air outside of the autonomous immersive cooling container (¶ 0055-0058). With respect to claim 10, Hirari further teaches that the heat pipes (16) have a cylindrical form (¶ 0032, “the heat pipe 16 is a hollow cylindrical member”). With respect to claim 11, Hirari further teaches that the heat pipes (16) are shaped as fins (¶ 0032, “the heat pipe 16 is a hollow cylindrical member”, where fins are well known to be shaped as cylinders). With respect to claim 12, Hirari further teaches that the heat pipes (16) include a plurality of fins (18) disposed on an external surface of the heat pipes (See Fig 3). With respect to claims 13-14, Hirari further teaches that the heat pipes comprise a metallic material, a thermally conductive plastic material, and/or a thermally conductive ceramic material (¶ 0032, “the heat pipe 16 is a hollow cylindrical member, opposite ends of which are dosed, and the exterior side thereof is formed by a material having a high thermal conductivity such as, for example, copper or aluminum”). With respect to claim 15, Hirari as modified by Kong teaches the limitations of claim 9 as per above but fails to specifically teach or suggest that the heat pipes are formed as integral parts of the sidewalls and/or door. However, it has been held that making a multi-piece structure into a single integral piece is obvious1. Thus, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to make the sidewall and heat pipes as an integral structure to reduce manufacturing time and expense (Making the sidewall and heat pipes as one piece reduces manufacturing steps, for example). With respect to claim 16, Hirari further teaches that the plurality of cooling structures (16) comprise vapor chambers, thermosyphons, loop heat pipes, capillary pumped loops (¶ 0033-0036, where, the noted passages of Hirari describe a capillary pumped loop heat pipe), and/or a geothermal heat exchanger. With respect to claim 17, Hirari as modified by Kong, Berlin and Chen teaches the limitations of claim 1 as per above and modified Hirari further teaches that each cooling structure of the plurality of cooling structures comprises a fin and a heat pipe (When Hirari is modified so that it has the door and cooling structures of Berlin, modified Hirari will have one fin cooling structure (on the door as disclosed by Berlin) and one heat pipe cooling structure (on the sidewall, as disclosed by Hirari). With respect to claim 19, Hirari further teaches that wherein the first ends (Left ends) of the heat pipes (16) are in contact with the dielectric immersive cooling liquid (13) or vaporized dielectric immersive cooling liquid (See Fig 3). Claim 18 is rejected under 35 U.S.C. 103 as being unpatentable over Hirari in view of Kong in view of Berlin in view of Chen and further in view of Chiu et al. (US 2020/0323100 – hereinafter, “Chiu”). With respect to claim 18, Hirari as modified by Kong, Berlin and Chen teaches the limitations of claim 1 as per above but fails to specifically teach or suggest wherein the autonomous immersive cooling container is adapted for use in a telecommunications cabinet or in a data center. Chiu, however, teaches an immersive cooling container (102) that is adapted for use in a data center (¶ 0083, “As another example, data center cooling systems that utilize a container-in-container concept as described herein”). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Chiu with that of Hirari, such that the immersive cooling container of Hirari is adapted for use in a data center, as taught by Chiu, since doing so would allow for the immersive cooling container of Hirari to be used in a data center thus expanding the potential use for the container. Response to Arguments With respect to the Applicant’s remarks to claim 1 that, “The Applicant respectfully submits that a person of ordinary skill in the art would not combine Berlin with Hirai, because doing so would require a fundamental change to the operating principle of Hirai. Hirai is designed to operate using a passive natural-convection cooling loop, in which heated coolant 13 rises due to buoyancy, heat is removed only at specific sidewall locations via heat pipes 16, and the cooled liquid then descends to complete the circulation loop. The coolant is designed to complete the circulation loop through deliberately designed flow paths formed between the housing 12 and the immersion tank 11. These defined flow paths guide the rising hot coolant toward the sidewall heat pipes 16 and ensure the return of cooled coolant to the lower portion of the housing 12, thereby sustaining a stable, pump-free natural-convection cycle. Hirai thus relies on maintaining a vertical thermal gradient and deliberately localizing heat extraction in order to preserve predictable and efficient natural convection. Berlin discloses a sealed electronic package that relies on forced internal fluid circulation, such as fans, and a door formed of a thermally conductive material with cooling fins that dissipate heat from within the enclosure of housing to the outside ambient environment. Berlin's door operates in the context of an actively agitated fluid system and does not rely on natural convection or controlled thermal stratification. Incorporating Berlin's door into Hirai would disrupt Hirai's convection-driven flow paths and thermal stratification. Specifically, incorporating such a thermally conductive, finned door into Hirai would introduce a competing heat-rejection path at the top of the container, prematurely cooling rising hot liquid, collapsing the buoyancy-driven thermal gradient, and disrupting the natural-convection loop upon which Hirai fundamentally depends. This would defeat Hirai's deliberate insulation and side-extraction design and would require substantial re-engineering of Hirai's flow paths and heat-removal strategy. Accordingly, the Examiner's proposed combination is not a simple addition of known elements, but an impermissible modification that changes Hirai's principle of operation. (Present remarks pages 6-7) the Examiner respectfully disagrees. While the Examiner agrees that the Applicant has properly identified an operating principle of the apparatus disclosed in Fig 3 of Hirari, the Examiner respectfully notes that the Applicant’s conclusion that “incorporating Berlin’s door into Hirari would disrupt Hirai's convection-driven flow paths and thermal stratification. Specifically, incorporating such a thermally conductive, finned door into Hirai would introduce a competing heat-rejection path at the top of the container, prematurely cooling rising hot liquid, collapsing the buoyancy-driven thermal gradient, and disrupting the natural-convection loop upon which Hirai fundamentally depends.” is conjecture. While adding a door with cooling structures may increase heat removal from the apparatus of Hirari, there is no way of knowing, based on the evidence of record, if the door + cooling structure system of Berlin would indeed cause the buoyancy-driven thermal gradient to collapse and thus fundamentally change a cooling principle of Hirari as alleged. Accordingly, claim 1 is believed to be prima facie obvious in view of Hirari, Kong, Berlin, and Chen. With respect to the Applicant’s remarks to claim 1 that, “Without acquiescing to this interpretation, the Applicant respectfully submits that a person of ordinary skill in the art would not look to Chen, as Chen is directed to a completely unrelated problem of of actively generating heat to prevent freezing in a railway toilet enclosure, rather than passively removing heat from a thermally loaded immersion cooling system. In Chen, the door and the fins are disclosed as being formed as a one-piece aluminum structure; however, this structural integration is merely incidental to Chen's distinct and unrelated objective. Specifically, Chen relates to a heating hood for a railway toilet system, in which a resistive electric heat tracing band 4 is mounted on the inner surface of the door 2 and wrapped around the fins 3 to actively generate heat and prevent freezing. The fins in Chen serve to distribute heat generated by the heating element within the enclosure, rather than to transfer heat from a thermally loaded door or from a fluid contained within a container to the external environment. Chen does not recognize, address, or seek to reduce thermal resistance between the door and attached cooling structures for purposes of improving passive heat transfer from an interior cooling liquid to exterior air. Chen does not disclose the door as being thermally coupled to an immersion-cooled volume, nor does Chen attribute any system-level cooling performance benefit to forming the fins integrally with the door. By contrast, in the currently claimed arrangements, the cooling structures being integrally connected to the door is not a mere combination of a multi-piece structure into an integral piece, but rather a deliberate configuration that enables efficient heat transfer from the door to the cooling structures (see par. 52). By minimizing thermal resistance at the interface, this arrangement improves the overall cooling performance of the container. In other words, the door is part of the thermal envelope and participates in heat rejection; the immersion container itself (including its walls and door) serves a passive heat exchanger that removes heat directly to ambient air, making the system autonomous and eliminating the need for external cooling infrastructure. Therefore, person of ordinary skill in the art would therefore not look to Chen, which is directed to a completely unrelated functionality, to modify the prior art cooling systems cited by the Examiner.” (Present remarks page 8) the Examiner respectfully disagrees. The above argument appears to be an argument that Chen is non-analogous art. In response to this argument, it has been held that a prior art reference must either be in the field of the inventor’s endeavor or, if not, then be reasonably pertinent to the particular problem with which the inventor was concerned, in order to be relied upon as a basis for rejection of the claimed invention2. In this case, it is respectfully submitted that Chen is both a) in the same field of endeavor and also b) reasonably pertinent to the particular problem with which the inventor was concerned. Broadly, the field of endeavor for the present application is heating and cooling. First ends of cooling structures (620) are heated via heat generating devices (602) and provide cooling via second ends of the cooling structures to move heat in a certain direction away from a heating source to effectively and efficiently heat the surrounding atmosphere. This is similar to the teachings of Chen where Chen teaches cooling structures (3) which are integral with a door (2) and provide an efficient means to move heat from a heat generating device (4) to the areas surrounding the fins. The particular problem that the Applicant is trying to solve by integrating the fins with the cover is more efficient heat transfer between the fins and the cover (Present remarks page. 8, see also ¶ 0052). This also appears to be a concern with Chen since Chen explicitly teaches fins (3) which are integral with a door (2) and that using such a structure results in a system which quickly heats while reducing energy consumption (Chen: “the access door is further provided with a heat dissipation fin of radiating conveniently, heat tape with flame-retardant, automatic heating, and the temperature limitation. waterproof characteristics such as, heating quickly, saving electric energy, convenient installation and low operation cost; the whole structure is simple, the heating effect is good, it avoids the connecting pipeline in the toilet dirt box and freezing the other bare place, ensures the normal use of the toilet system and normal emptying. at the same time effectively reduces the energy consumption and saves the energy.”). That is, the goal of the door with integrated fins is to provide more efficient heat removal from the heat generating device (4) of Chen. Accordingly, claim 1 is believed to be prima facie obvious in view of Hirari, Kong, Berlin, and Chen. Conclusion THIS ACTION IS MADE FINAL. 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 ZACHARY M PAPE whose telephone number is (571)272-2201. The examiner can normally be reached M-F: 9am - 6pm 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, JAYPRAKASH Gandhi can be reached at 571-272-3740. 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. /ZACHARY PAPE/Primary Examiner, Art Unit 2841 1 In re Larson, 340 F.2d 965, 968, 144 USPQ 347, 349 (CCPA 1965) 2 See In re Oetiker, 977 F.2d 1443, 24 USPQ2d 1443 (Fed. Cir. 1992).
Read full office action

Prosecution Timeline

Show 3 earlier events
Nov 10, 2025
Final Rejection mailed — §103
Jan 09, 2026
Response after Non-Final Action
Jan 19, 2026
Request for Continued Examination
Jan 27, 2026
Response after Non-Final Action
Feb 13, 2026
Non-Final Rejection mailed — §103
May 13, 2026
Response Filed
Jun 04, 2026
Final Rejection mailed — §103
Jul 24, 2026
Response after Non-Final Action

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Prosecution Projections

4-5
Expected OA Rounds
72%
Grant Probability
92%
With Interview (+19.2%)
2y 5m (~0m remaining)
Median Time to Grant
High
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