Prosecution Insights
Last updated: April 19, 2026
Application No. 18/373,567

IMMERSION COOLING CONTAINER

Non-Final OA §103
Filed
Sep 27, 2023
Examiner
PAPE, ZACHARY
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Ovh
OA Round
3 (Non-Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
2y 5m
To Grant
92%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
792 granted / 1094 resolved
+4.4% vs TC avg
Strong +20% interview lift
Without
With
+19.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
33 currently pending
Career history
1127
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
46.5%
+6.5% vs TC avg
§102
27.9%
-12.1% vs TC avg
§112
19.7%
-20.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1094 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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 1/19/2026 has been entered. Email Communication Applicant is encouraged to authorize the Examiner to communicate via email by filing form PTO/SB/439 either via USPS, Central Fax, or EFS-Web. See MPEP 502.01, 502, 502.05. 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. Claim Objections Claims 9-15, 19 are objected to because of the following informalities: Claim 9 recites, “the cooling structures” which lacks antecedent basis since it is unclear if this recitation is referring back to “a plurality of cooling structures” or “one or more cooling structures”. Claims 10-15, 19 are objected to since they depend from claim 9 and inherit the deficiency therein. Appropriate correction is required. 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, “By the present, the Applicant has amended claim 1 to better recite the scope of the technology. More specifically, the currently claimed arrangements relate to an autonomous immersive cooling container having "a door that may be opened and closed to facilitate insertion and removal of the at least one electronic device, the door comprising 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." The feature of 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. None of the references of record teaches or suggests this feature, nor would it be obvious over a combination thereof. For at least the above reasons, the Applicant submits that claim 1 is not obvious over Hirari in view of Kong and Berlin. It is submitted that independent claim 1 is thus patentable over the references of record.” (Present remarks pages 6-7) the Examiner notes newly cited Chen which discloses fins which are integral with a door. This teaching by Chen is believed to resolve any deficiencies of Hirari, Kong, and Berlin. Accordingly, claim 1 is believed to be prima facie obvious in view of Hirari, Kong, Berlin, and Chen. Conclusion 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 N 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 2835 1 In re Larson, 340 F.2d 965, 968, 144 USPQ 347, 349 (CCPA 1965)
Read full office action

Prosecution Timeline

Sep 27, 2023
Application Filed
Jul 16, 2025
Non-Final Rejection — §103
Oct 17, 2025
Response Filed
Nov 06, 2025
Final Rejection — §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 11, 2026
Non-Final Rejection — §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
72%
Grant Probability
92%
With Interview (+19.9%)
2y 5m
Median Time to Grant
High
PTA Risk
Based on 1094 resolved cases by this examiner. Grant probability derived from career allow rate.

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