Prosecution Insights
Last updated: May 29, 2026
Application No. 18/377,017

COOLING DISTRIBUTION UNITS AND IN-RACK THERMAL MANAGEMENT SYSTEMS

Final Rejection §103§112
Filed
Oct 05, 2023
Examiner
RUBY, TRAVIS C
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Nvidia Corporation
OA Round
2 (Final)
53%
Grant Probability
Moderate
3-4
OA Rounds
1y 0m
Est. Remaining
81%
With Interview

Examiner Intelligence

Grants 53% of resolved cases
53%
Career Allowance Rate
434 granted / 818 resolved
-16.9% vs TC avg
Strong +28% interview lift
Without
With
+28.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
35 currently pending
Career history
865
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
84.7%
+44.7% vs TC avg
§102
12.3%
-27.7% vs TC avg
§112
1.4%
-38.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 818 resolved cases

Office Action

§103 §112
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 of Claims The status of the claims as filed in the submission dated 1/29/2026 are as follows: Claims 9, 12, 15, and 18 are cancelled by the applicant; Claims 21-24 are newly added; Claims 1-8, 10, 11, 13, 14, 16, 17, and 19-24 are pending and are being examined. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore: “a fluid distribution housing separate from the data center rack” (claims 1 and 10). The drawings illustrate only a CDU connected to the fluid distribution unit (Figure 4) and a CDU in a rack (Figures 7-8), but no figure illustrates the entire system in which the CDU is in the rack and the fluid distribution unit is a separate housing connected to the rack. “the fluid distribution housing is a modular component that can be attached to the data center rack” (claim 21). As above, no figure illustrates the entire system in which the CDU is in the rack and the fluid distribution unit is a separate housing attached to the rack. “the fluid distribution housing is a modular component that can be located proximate to the data center rack” (claim 22). As above, no figure illustrates the entire system in which the CDU is in the rack and the fluid distribution unit is a separate housing proximate to the rack. “the one or more thermal management components comprises a plate heat exchanger” (claim 23). Figure 9 illustrates a generic box heat exchanger 700 with no indication of what type of heat exchanger 700 is. Thus, no plate heat exchanger is illustrated. “the heat is dissipated from the fluid by transferring heat from the one or more thermal management components to an additional fluid loop” (claim 24). No additional fluid loop is illustrated. must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: “thermal management components” in claims 1 and 10. The generic placeholder “component” is modified by the functional language “thermal management” without reciting sufficient structure to perform the recited function. Paragraph 45 of the applicants’ specification outlines the thermal management components as “the thermal management components 304 may include, among other components, a heat exchanger 700, a power supply 702, a fill pump 704, and/or one or more internal fluid conduit(s) 706”. Thus, the “thermal management components” will be interpreted as any one of the recited components. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-8 and 21-24 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 1 preamble recites “a cooling distribution unit supported by a data center rack, the CDU comprising”. Then claim 1 lines 13-19 recite details of the fluid distribution system. However, the fluid distribution system is a distinct apparatus from the cooling distribution unit apparatus. Thus, it is unclear of the scope of the claim since the preamble limits the apparatus to only the CDU. Based on the preamble, the features of the fluid distribution system are not actually being positively recited. Since the metes and bounds of the limitation cannot be ascertained, the claim is indefinite. The remaining claims are rejected as being dependent upon an indefinite claim. 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 1-5, 8-14, and 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over Steinke (US2017/0049009A1, as previously cited) in view of Gao (US2023/0060854A1). Re Claim 1. Steinke teaches a cooling distribution unit (CDU) (40) supported by a data center rack (10 is the rack; Figures 2, 3, 5; Paragraphs 25-32), the CDU comprising: a housing (housing of 40) defining: a fluid inlet (63); and a fluid outlet (61) (Figures 2-3, 5; Paragraphs 23-26, 29-32); one or more thermal management components (as interpreted under 112(f) above; heat exchanger 50, fans 42, pumps 48, power supply 47, conduits 44 & 46) supported by the housing, wherein, in operation, the one or more thermal management components are configured to dissipate heat of a fluid received by the CDU via the fluid inlet (Figures 2, 3, 5; Paragraphs 29-32); and one or more direct mechanical connections (63, 64 are quick connects for blind mating) coupled with the fluid inlet and the fluid outlet, wherein the one or more direct mechanical connections are configured to directly interface with a fluid distribution system (manifolds 60, 62) to provide fluid communication between the CDU and the fluid distribution system (Figures 2, 3, 5; Paragraphs 25-27, 29), and wherein the fluid distribution system comprises: a primary fluid channel (62) directly coupled with the direct mechanical connection of the fluid inlet, and a secondary fluid channel (60) directly coupled with the direct mechanical connection of the fluid outlet (Figures 2, 3, 5; Paragraphs 25-27, 29). Steinke fails to specifically teach a fluid distribution housing separate from the data center rack and configured to at least partially enclose the primary fluid channel and the secondary fluid channel. However, Gao teaches a fluid distribution housing (220) separate from the data center rack (100) and configured to at least partially enclose the primary fluid channel (210) and the secondary fluid channel (210) (Figures 3A-F, Paragraphs 52-58; The fluid containment panels 220 are a distinct element from the data center rack and thus the panels 220 form a fluid distribution housing that is separate from the data center rack. The panels 220 cover the sides of the manifolds and thus partially enclose the primary and secondary fluid channels). Therefore, in view of Gao's teaching, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to form a housing around the fluid distribution of Steinke in order to contain potential leaks that could damage the components in the rack (Gao Paragraphs 56-57). Re Claim 10. Steinke teaches an in-rack thermal management system (Figures 1-5) comprising: a cooling distribution unit (CDU) (40) supported by a data center rack (10 is the rack) (Figures 2, 3, 5; Paragraphs 25-32), the CDU comprising: a housing (housing of 40) defining: a fluid inlet (63); and a fluid outlet (61) (Figures 2-3, 5; Paragraphs 23-26, 29-32); one or more thermal management components (as interpreted under 112(f) above; heat exchanger 50, fans 42, pumps 48, power supply 47, conduits 44 & 46) supported by the housing (Figures 2, 3, 5; Paragraphs 29-32); and one or more direct mechanical connections (63, 64 are quick connects for blind mating) coupled with the fluid inlet and the fluid outlet (Figures 2, 3, 5; Paragraphs 25-27, 29); and a fluid distribution system (manifolds 60, 62) comprising: a primary fluid channel (62) directly coupled with the direct mechanical connection of the fluid inlet; and a secondary fluid channel (60) directly coupled with the direct mechanical connection of the fluid outlet; and wherein, in operation, the one or more thermal management components are configured dissipate heat of a fluid received by the CDU via the fluid inlet, and wherein the direct mechanical connections are configured to directly interface with the fluid distribution system to provide fluid communication between the CDU and the fluid distribution system (Figures 2, 3, 5; Paragraphs 25-32, 35). Steinke fails to specifically teach a fluid distribution housing separate from the data center rack and configured to at least partially enclose the primary fluid channel and the secondary fluid channel. However, Gao teaches a fluid distribution housing (220) separate from the data center rack (100) and configured to at least partially enclose the primary fluid channel (210) and the secondary fluid channel (210) (Figures 3A-F, Paragraphs 52-58; The fluid containment panels 220 are a distinct element from the data center rack and thus the panels 220 form a fluid distribution housing that is separate from the data center rack. The panels 220 cover the sides of the manifolds and thus partially enclose the primary and secondary fluid channels). Therefore, in view of Gao's teaching, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to form a housing around the fluid distribution of Steinke in order to contain potential leaks that could damage the components in the rack (Gao Paragraphs 56-57). Re Claim 2 & 11. Steinke teaches the direct mechanical connections are configured to directly interface with the fluid distribution system in the absence of external fluid conduits (Figures 2, 3, 5; Paragraphs 25-32). Re Claim 3. Steinke teaches the direct mechanical connections are configured to be removably attached with the fluid distribution system without external fluid conduits extending therebetween (Figures 2, 3, 5; Paragraphs 25-32). Re Claim 4 & 13. Steinke teaches the one or more direct mechanical connections comprise one or more blind mate connectors (Figures 2, 3, 5; Paragraphs 25-32; Paragraph 25 specifically recites the connections are “blind mating”). Re Claim 5 & 14. Steinke teaches wherein a first temperature associated with the fluid received by the fluid inlet is greater than a second temperature associated with the fluid exiting the housing via the fluid outlet (Figures 2, 3, 5; Paragraphs 25-32; Inlet 63 is for warm coolant that is cooled by air heat exchanger 50 and outputted at outlet 61 as cooled coolant). Re Claim 8 & 17. Steinke teaches the one or more dimensions of the housing comprise an internal dimension such that the housing is further configured to support one or more redundant thermal management components (Figures 2, 3, 5; Paragraphs 25-32; Steinke teaches having redundant pumps 48). Re Claim 19. Steinke teaches further comprising: a server housing (70) defining: a server inlet (66, 74); and a server outlet (65, 72); one or more processing components (32, 34) supported by the server housing; one or more direct mechanical connections (65, 66) coupled with the server inlet and the server outlet, wherein the one or more direct mechanical connections are configured to directly interface with the fluid distribution system to provide fluid communication between the server housing and the fluid distribution system (Figures 2, 4, 5; Paragraphs 23-26, 33-35). Re Claim 20. Steinke teaches the direct mechanical connections of the server housing are configured to directly interface with the fluid distribution system in the absence of external fluid conduits (Figures 2, 4, 5; Paragraphs 23-26, 33-35). Re Claim 21. Steinke as modified by Gao teach the fluid distribution housing is a modular component that can be attached to the data center rack (Steinke Figures 2, 4, 5; Paragraphs 23-26, 33-35; Gao Figures 2-4; Paragraphs 52-58. Gao teaches numerous configurations for the containment panels and thus is considered a modular component). Re Claim 22. Steinke as modified by Gao teach the fluid distribution housing is a modular component that can be located proximate to the data center rack (Steinke Figures 2, 4, 5; Paragraphs 23-26, 33-35; Gao Figures 2-4; Paragraphs 52-58. Gao teaches numerous configurations for the containment panels and thus is considered a modular component. The fluid distribution housing of Gao is adjacent to the data center rack and thus is considered to be proximately located). Re Claim 23. Steinke teaches the one or more thermal management components comprises a heat exchanger (50) (Figures 2, 3, 5; Paragraphs 29-32) but fails to specifically teach a plate heat exchanger. However, the examiner takes Official Notice of the well-known and understood use of plate heat exchangers for dissipating heat from enclosures. Thus, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to select the heat exchanger of Steinke to be a plate heat exchanger in order to provide compact thermal heat transfer. Re Claim 24. Steinke teaches the heat is dissipated from the fluid by transferring heat from the one or more thermal management components to an additional fluid loop (Figures 2, 4, 5; Paragraphs 23-26, 33-35; Figures 4 and 5 illustrate numerous coolant loops in the server rack). Claims 6, 7, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Steinke (US2017/0049009A1, as previously cited) in view of Gao (US2023/0060854A1) and in view of Eckberg (US2016/0066480A1, as previously cited). Re Claim 6. Steinke teaches the housing further defines one or more bays (11, 21, 23) by which the housing may be positioned within a datacenter rack (10 is the rack) (Figures 2, 3, 5; Paragraphs 25-32). Steinke fails to specifically teach rails in the rack. However, Eckberg teaches the housing further defines one or more support rails (21, 23) by which the housing may be positioned within a datacenter rack (20) (Figure 1; Paragraphs 27-28) Therefore, in view of Eckberg's teaching, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to add support rails to the rack of Steinke in order to better align the modules with the blind mating quick connections at the manifolds. Further, the use of rails in server racks is well-known and established in the art and would only require routine skill in the art to implement. Re Claim 7 & 16. Steinke as modified by Eckberg teach the housing, via movement along the one or more support rails, is configured to be removably attached with the fluid distribution system (Steinke Figures 2, 3, 5; Paragraphs 25-32; Eckberg Figure 1, Paragraphs 27-28). Response to Arguments Applicant’s arguments with respect to claim(s) above 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 TRAVIS RUBY whose telephone number is (571)270-5760. The examiner can normally be reached M-F: 9AM-5PM. 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, Jianying Atkisson can be reached at 571-270-7740. 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. /TRAVIS RUBY/Primary Examiner, Art Unit 3763
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Prosecution Timeline

Oct 05, 2023
Application Filed
Oct 30, 2025
Non-Final Rejection mailed — §103, §112
Jan 14, 2026
Examiner Interview Summary
Jan 14, 2026
Applicant Interview (Telephonic)
Jan 29, 2026
Response Filed
Apr 14, 2026
Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

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Expected OA Rounds
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Grant Probability
81%
With Interview (+28.3%)
3y 8m (~1y 0m remaining)
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