Response to Amendment
The Amendment filed 12/18/25 has been entered. Claims 1-20 remain pending in the application, of which claims 13-20 are withdrawn. As such, the claims being examined are claims 1-12. Applicant’s amendments to the claims have overcome each and every 112(b) rejection previously set forth in the Non-Final Office Action mailed 10/1/25.
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 text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claims 1-12 are rejected under 35 U.S.C. 103 as being unpatentable over Andersen (US 2014/0034310- cited previously) in view of Giroux et al. (US 2014/0305662- cited previously)
With respect to independent claim 1, Andersen discloses an integrated sub system for isolating formations above a targeted reservoir in a well ([0005], [0029], and Figs. 1B and 5A-5E), the integrated sub system comprising: an off-bottom liner deployed in the well ([0029] and Fig. 1B; liner 15);
a float shoe disposed at an end of the off-bottom liner comprising a first float valve, the first float valve being configured to regulate a flow of a fluid in a single direction ([0029], [0030], [0076] and Figs. 1B and 5A-5E; float shoe, check valve);
a ball seat disposed within the off-bottom liner configured to receive a ball, the ball seat comprising an aperture configured to permit the fluid through the ball seat prior to the ball seat receiving the ball ([0005], [0046], [0059]-[0067], Figs. 2C and 5A-5E);
a tubular body disposed at the end of the off-bottom liner configured to house the float shoe and the ball seat ([0029], [0030], [0046], [0059]-[0067], Figs. 1B and 5A-5E); and
valves actuated hydraulically ([0023], [0024], and [0033]). Regarding claim 1, Andersen discloses a method for cementing a liner, wherein the liner comprises multiple valves that are actuated hydraulically. However, he fails to expressly disclose wherein the valve is specifically “a circulation valve,” as instantly claimed. Giroux teaches a method for cementing a liner, wherein the liner comprises circulation valves that are actuated hydraulically (Abstract and [0081]-[0083]). Employing circulation valves as taught by Giroux in the liner cementing method disclosed by Andersen amounts to nothing more than employing a known technique to a comparable device in a comparable situation, i.e., injecting cement to hang a liner, and it therefore would have been obvious for a person having ordinary skill in the art at the time of the invention since it has been taught “[I]f a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious unless its actual application is beyond his or her skill... [A] court must ask whether the improvement is more than the predictable use of prior art elements according to their established functions." KSR at 1396 Furthermore, adding additional valves through which cement might flow would aid in zonal isolation and control over specific cement placement.
With respect to depending claim 2, Andersen discloses wherein the float shoe and ball seat are formed of a drillable material ([0030] and [0043]).
With respect to depending claim 3, Andersen discloses further comprising a float collar comprising a second float valve, the float collar being formed of a drillable material ([0029], [0036], [0053] and Figs. 1B and 2A).
With respect to depending claim 4, Andersen discloses further comprising one or more packers and one or more slips ([0029]).
With respect to depending claim 5, which is dependent upon claim 4, Andersen discloses wherein the one or more packers are hydraulically actuated subsequent to a first predetermined pressure being reached within the body by pumping the fluid onto the ball received in the ball seat ([0029] and [0048]; packers are set using a hydraulically actuated liner deployment assembly by pumping a ball to rest on a seat in the liner deployment assembly). Furthermore, regarding the timing of actuation, the act of actuating the packers once a predetermined pressure is reached amounts to nothing more than choosing from a finite number of possible and predictable solutions, as it has been taught "When there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person having ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense." KSR at 1397 Moreover, the term “predetermined” is being treated under Broadest Reasonable Interpretation as any pressure value which might possibly be decided in advance.
With respect to depending claim 6, the combination of Andersen and Giroux teaches wherein the circulation valve is disposed along the body uphole from the ball seat (Abstract, [0081]-[0083], and [0136]).
With respect to depending claim 7, the combination of Andersen and Giroux teaches wherein the circulation valve is hydraulically actuated from a closed position to an open position subsequent to a predetermined pressure being reached within the body by pumping the fluid onto the ball received in the ball seat (Andersen- [0029] and [0048]; Giroux- Abstract, [0081]-[0083], and [0136]). Furthermore, regarding the timing of actuation, the act of actuating the valve once a predetermined pressure is reached amounts to nothing more than choosing from a finite number of possible and predictable solutions, as it has been taught "When there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person having ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense." KSR at 1397 Moreover, the term “predetermined” is being treated under Broadest Reasonable Interpretation as any pressure value which might possibly be decided in advance.
With respect to depending claim 8, Andersen discloses further comprising a plug seat configured to receive a plug, the plug seat comprising an aperture configured to permit the fluid through the plug seat prior to the plug seat receiving the plug ([0046] and [0047]).
With respect to depending claim 9, which is dependent upon claim 8, the combination of Andersen and Giroux teaches wherein the plug seat is disposed within a landing collar or a float collar housed within the body uphole from the circulation valve (Andersen- [0029], [0036], [0053] and Figs. 1B and 2A; Giroux- Abstract, [0010], and [0081]-[0083]). With respect to depending claim 10, which is dependent upon claim 9, the combination of Andersen and Giroux teaches wherein the circulation valve is hydraulically actuated from an open position to a closed position subsequent to the plug seat receiving the plug and a pressure within the body falling below a determined pressure (Andersen[0029], [0036], [0053] and Figs. 1B and 2A; Giroux- Abstract, [0081]-[0083], and [0136]). Furthermore, regarding the timing of actuation, the act of actuating the valve once a predetermined pressure is reached amounts to nothing more than choosing from a finite number of possible and predictable solutions, as it has been taught "When there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person having ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense." KSR at 1397 Moreover, the term “predetermined” is being treated under Broadest Reasonable Interpretation as any pressure value which might possibly be decided in advance.
With respect to depending claim 11, Andersen discloses wherein an uphole end of the body comprises a threaded connection configured to connect with a complimentary threaded connection of a liner or casing string of the well ([0021]).
With respect to depending claim 12, Andersen discloses a tubular body housing a float shoe and ball seat ([0029], [0030], [0046], [0059]-[0067], Figs. 1B and 5A-5E). Although silent to wherein the tubular body has “a length… equal to or less than 16 feet and greater than 0 feet,” as instantly claimed, it would have been obvious for a person having ordinary skill in the art before the effective filing date of the claimed invention to provide for the length as claimed insofar as because it has been held "[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation." In re Aller, 220 F. 2d 454, 456, 105 USPQ 233, 235 (CCPA 1955) Moreover, selecting the dimension as claimed would have been obvious for a person having ordinary skill in the art before the effective filing date of the claimed invention since the claimed dimension amounts to nothing more than scaling up or down of the disclosed device and a device having the claimed dimensions would not perform differently than the prior art device In re Rose, 220 F.2d 459, 105 USPQ 237 (CCPA 1955). Furthermore, obviousness can be shown in a predictable art when a difference between the claimed ranges is virtually negligible absent any showing of unexpected results or criticality. In re Brandt, 886 F. 3d 1171, 1177, 126 USPQ2d 1079, 1082 (Fed. Cir. 2018).
Response to Arguments
Applicant's arguments filed 12/18/25 have been fully considered but they are not persuasive.
Applicant argues that “Anderson is completely silent regarding use of an off-bottom liner where the casing string cannot or does not run to a target depth to the bottom of the wellbore.” The Examiner finds this argument unpersuasive. Anderson discloses a liner which does not reach the bottom of the wellbore (see Fig. 1B, for example). In addition to the figures, inasmuch as Anderson discloses wherein cement is injected down through the liner, out of the liner, and around and up the annulus (Abstract), he discloses a liner which is “off-bottom.” In other words, a liner reaching the bottom of the wellbore- as Applicant argues is what is disclosed by Anderson- would not be able to have cement go through it and up into the annulus. Although the Applicant specifies that the distance between the liner and the bottom of the wellbore is “greater than 10 feet away,” this feature is not claimed.
Applicant argues that “Giroux fails to supply that which Anderson lacks.” This argument is moot since Anderson does indeed disclose an off-bottom liner, as claimed.
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 AVI T. SKAIST whose telephone number is (571)272-9348. The examiner can normally be reached M-F 9:30-6.
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/AVI T SKAIST/Examiner, Art Unit 3674
/WILLIAM D HUTTON JR/Supervisory Patent Examiner, Art Unit 3674