Prosecution Insights
Last updated: April 17, 2026
Application No. 18/387,013

SELF-POWERED IRRIGATION IN-LINE ELEMENT

Non-Final OA §102§103
Filed
Nov 03, 2023
Examiner
CUEVAS, PEDRO J
Art Unit
2896
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
unknown
OA Round
1 (Non-Final)
70%
Grant Probability
Favorable
1-2
OA Rounds
2y 3m
To Grant
86%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
712 granted / 1018 resolved
+1.9% vs TC avg
Strong +16% interview lift
Without
With
+15.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
24 currently pending
Career history
1042
Total Applications
across all art units

Statute-Specific Performance

§101
7.6%
-32.4% vs TC avg
§103
41.4%
+1.4% vs TC avg
§102
24.9%
-15.1% vs TC avg
§112
21.7%
-18.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1018 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 . Claim Objections Claim 16 is objected to because of the following informalities: the word ‘and’ is missing at the end of line 4. Appropriate correction is required. Claim Rejections - 35 USC § 102 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 the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claims 1, 3, 4, 9-11, and 16-19 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by U.S. Patent Application Publication No. 2015/0053786 A1 to Rosa. Rosa clearly teaches an intelligent precision irrigation system, comprising: a body (132), the body for allowing water to move; an energy harvesting circuit (122) for converting mechanical energy of water moving through the body to electrical energy for use by the irrigation in-line element (210see Figure 2A); a communication circuit (126) for receiving instructions from a system controller (121), the instructions related to operation of the irrigation in-line element; and a processing circuit (see Figure 5) for providing control signals to an apparatus (123) for controlling a flow of water through the body (see Figure 5). With regards to claim 3, Rosa discloses: a valve (123) disposed within the body, the valve for mechanically controlling a flow of water through the body (see Figure 2A). With regards to claim 4, Rosa discloses: the processing circuit is further for: receiving information from the communication circuit; processing the received information; and returning processed information to the system controller via the communication circuit. With regards to claim 9, Rosa discloses: a communication circuit (126) for receiving instructions from a system controller, the instruction related to the operation of the smart irrigation in-line element (210); a processing circuit (see Figure 5) for processing instructions received at the communication circuit and for controlling operation of the irrigation in-line element; and an energy harvesting circuit (122) for converting mechanical energy of water moving through the irrigation in-line element to electrical energy for use by the processing circuit and the communication circuit (see Figure 2A). With regards to claim 10, Rosa discloses: the processing circuit is for providing control signals to a valve (123), the valve for mechanically controlling a flow of water through the irrigation in-line element. With regards to claim 11, Rosa discloses: the processing circuit is for sending data representative of operation of the in-line element to the system controller. With regards to claim 16, Rosa discloses a method comprising the steps of: converting a mechanical energy from water moving through an irrigation in-line element to electrical energy; enabling a communication circuit; and establishing communication with a system controller by the irrigation in-line element through the communication circuit. With regards to claim 17, Rosa discloses: 17. The method of claim 16, further comprising: receiving, by the communication circuit, at least one control signal from a system controller. With regards to claim 18, Rosa discloses: 18. The method of claim 16, further comprising: closing a valve disposed within the irrigation in-line element in response to receiving the at least one control signal. With regards to claim 19, Rosa discloses: 19. The method of claim 16, further comprising: sending, by the communication circuit, at least one packet of information related to the status of the irrigation element to a system controller. 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 2, 5, 6, and 12 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Application Publication No. 2015/0053786 A1 to Rosa in view of U.S. Patent Application Publication No. 2009/0204265 A1 to Hackett. Rosa discloses an intelligent precision irrigation system as described in paragraph 4 above. However, it fails to disclose a nozzle through which water flows to a coverage area. Hackett discloses long-range radio frequency receiver-controller module and wireless control system, comprising: a nozzle (see paragraph [0006]) through which water flows to a coverage area. It would have been obvious to one skilled in the art before the effective filling date of the invention to use the nozzle disclosed by Hackett on the intelligent precision irrigation system disclosed by Rosa, for the purpose of popping “up from the top of the housing during desired irrigation times and irrigates by throwing a jet or spray of water that is rotated about a generally vertical axis.” With regards to claim 5, Hackett discloses: a communication circuit (104) comprises an antenna (102). With regards to claim 6, Hackett discloses: the antenna being disposed proximate to a body (see Figure 6). With regards to claim 12, Hackett discloses: the communication circuit comprising at least one antenna (102). With regards to claim 20, Hackett discloses: the system controller being a mobile device (see paragraph [0058]). Claims 7, 8, and 13-15 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Patent Application Publication No. 2015/0053786 A1 to Rosa in view of U.S. Patent No. 9,046,071 B2 to Portolan et al. Rosa discloses an intelligent precision irrigation system as described in paragraph 4 above, further comprising: an energy storage module (124); and a processing circuit (see Figure 5). However, it fails to disclose the energy harvesting circuit comprising: at least one permanent magnet configured to move with a plurality turbine blades in response to a flow of water through the body; and a rectifier and period detection module. Portolan et al. discloses an apparatus for generating electricity, comprising: an energy harvesting circuit comprising: at least one permanent magnet (see column 10, line 48) configured to move with a plurality turbine blades (see column 10, lines 55-60) in response to a flow of water through the body; and a rectifier (56) and period detection module (see column 13, lines 56-61). It would have been obvious to one skilled in the art before the effective filling date of the invention to use the permanent magnet, rectifier, and period detecting module disclosed by Portolan et al. on the intelligent precision irrigation system disclosed by Rosa, for the purpose of generating electricity that can be stored in the energy storage module. With regards to claim 8, Portolan et al. discloses: the at least one permanent magnet and at least one other permanent magnet are disposed on at least two of the plurality of turbine blades (see column 10, lines 55-60). With regards to claim 13, Rosa in view of Portolan et al. disclose: a rectifier (56 of Portolan et al.) and period detection module (see column 13, lines 56-61 of Portolan et al.); an energy storage module (124 of Rosa); and a processing circuit (see Figure 5 of Rosa). With regards to claim 14, Rosa in view of Portolan et al. disclose: the rectifier and period detection module receive an induced current and provide the induced current to the energy storage module. With regards to claim 15, Rosa in view of Portolan et al. disclose: the communication circuit, the processing circuit, and energy harvesting circuit are disposed within a body (150; see Figure 2A of Rosa), the body for allowing the flow of water therethrough. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to PEDRO J CUEVAS whose telephone number is (571)272-2021. The examiner can normally be reached 9:00 AM - 6:00 PM. 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, Jessica Han can be reached at (571) 272-2078. 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. /PEDRO J CUEVAS/Primary Examiner, Art Unit 2896 January 21, 2026
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Prosecution Timeline

Nov 03, 2023
Application Filed
Jan 21, 2026
Non-Final Rejection — §102, §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

1-2
Expected OA Rounds
70%
Grant Probability
86%
With Interview (+15.8%)
2y 3m
Median Time to Grant
Low
PTA Risk
Based on 1018 resolved cases by this examiner. Grant probability derived from career allow rate.

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