Prosecution Insights
Last updated: July 17, 2026
Application No. 18/403,581

SYSTEMS AND METHODS FOR IMMERSION COOLING WITH SUBCOOLED SPRAY

Non-Final OA §102§103§112
Filed
Jan 03, 2024
Priority
Feb 01, 2021 — provisional 63/144,371 +1 more
Examiner
AL SAMIRI, KHALED AHMED ALI
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Microsoft Technology Licensing, LLC
OA Round
1 (Non-Final)
47%
Grant Probability
Moderate
1-2
OA Rounds
6m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 47% of resolved cases
47%
Career Allowance Rate
63 granted / 135 resolved
-23.3% vs TC avg
Strong +58% interview lift
Without
With
+58.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
29 currently pending
Career history
173
Total Applications
across all art units

Statute-Specific Performance

§103
85.2%
+45.2% vs TC avg
§102
6.5%
-33.5% vs TC avg
§112
8.4%
-31.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 135 resolved cases

Office Action

§102 §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 . Election/Restrictions Applicant’s election without traverse of Species E in the reply filed on 01/09/2026 is acknowledged. Examiner notes that Claims 1-20, as originally filed, read on Species E. 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 1-16 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. Regarding claim 1, the recitation of “receiving thermal energy from heat-generating components” is unclear since the claim already recites “A method of thermal management for heat-generating components”. Therefore, it’s unclear if the “heat-generating components” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “receiving thermal energy from the heat-generating components”. Regarding claim 6, the recitation of “wherein adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger” is unclear since claim 1 already recites “a liquid working fluid”. Therefore, it’s unclear if the “liquid working fluid” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “wherein adjusting the temperature difference includes changing a flowrate of the liquid working fluid through a heat exchanger”. Regarding claim 10, the recitation of “wherein adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger” is unclear since claim 1 already recites “a liquid working fluid”. Therefore, it’s unclear if the “liquid working fluid” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “wherein adjusting the temperature difference includes changing a flowrate of the liquid working fluid through a heat exchanger”. Regarding claim 11, the recitation of “adjusting a temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath” is unclear since claim 7 already recites “a temperature difference between the plurality of droplets and the vapor working fluid”. Therefore, it’s unclear if the “temperature difference” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “adjusting the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath”. Regarding claim 13, the recitation of “wherein adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger” is unclear since claim 1 already recites “a liquid working fluid”. Therefore, it’s unclear if the “liquid working fluid” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “wherein adjusting the temperature difference includes changing a flowrate of the liquid working fluid through a heat exchanger”. Regarding claims 15 and 16, the recitation of “wherein adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger” is unclear since claim 1 already recites “a liquid working fluid”. Therefore, it’s unclear if the “liquid working fluid” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “wherein adjusting the temperature difference includes changing a flowrate of the liquid working fluid through a heat exchanger”. Claims 2-5, 7-9, 12, and 14 are rejected at least insofar as they are dependent on rejected claim(s), and therefore include the same error(s). Claims 17 and 18 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. Regarding claim 17, the recitation of “receiving thermal energy from heat-generating components” is unclear since the claim already recites “A method of thermal management for heat-generating components”. Therefore, it’s unclear if the “heat-generating components” in both recitations are the same or different. Moreover, the recitation of “adjusting a temperature difference between the plurality of droplets and the vapor working fluid” is unclear since the claim already recites “a temperature difference between the plurality of droplets and the vapor working fluid”. Therefore, it’s unclear if the “temperature difference” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “receiving thermal energy from the heat-generating components” and “adjusting the temperature difference between the plurality of droplets and the vapor working fluid”. Claim 18 is rejected at least insofar as it is dependent on rejected claim(s), and therefore include the same error(s). Claims 19 and 20 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. Regarding claim 19, the recitation of “receiving thermal energy from heat-generating components” is unclear since the claim already recites “A method of thermal management for heat-generating components”. Therefore, it’s unclear if the “heat-generating components” in both recitations are the same or different. Moreover, the recitation of “changing a fan speed of a heat exchanger and a flowrate of liquid working fluid through a heat exchanger” is unclear since the claim already recites “liquid working fluid” and “a heat exchanger”. Therefore, it’s unclear if each of the “liquid working fluid” and “a heat exchanger” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “receiving thermal energy from the heat-generating components” and “changing a fan speed of a heat exchanger and a flowrate of the liquid working fluid through the heat exchanger”. Regarding claim 20, the recitation of “a heat-exchanger outside of the immersion tank” is unclear since claim 19 already recites “a heat exchanger”. Therefore, it’s unclear if the “heat exchanger” in both recitations are the same or different. To expedite prosecution, Examiner interprets the above to read as “the heat-exchanger outside of the immersion tank”. The following is a quotation of 35 U.S.C. 112(d): (d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. The following is a quotation of pre-AIA 35 U.S.C. 112, fourth paragraph: Subject to the following paragraph [i.e., the fifth paragraph of pre-AIA 35 U.S.C. 112], a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. Claim 16 is rejected under 35 U.S.C. 112(d) or pre-AIA 35 U.S.C. 112, 4th paragraph, as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, or for failing to include all the limitations of the claim upon which it depends. Claim 16 is identical to claim 15, therefore, claim 16 fail to further limit the subject matter of claim 15. Applicant may cancel the claim(s), amend the claim(s) to place the claim(s) in proper dependent form, rewrite the claim(s) in independent form, or present a sufficient showing that the dependent claim(s) complies with the statutory requirements. 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 and 2 are rejected under 35 U.S.C. 102(a) (1) as being anticipated by Cray (US 5131233 A). Regarding claim 1, Cray teaches a method of thermal management for heat-generating components (29: see Figure 1), the method comprising: receiving thermal energy from heat-generating components (29) with a liquid working fluid (38) in an immersion bath (bath of 38) in an immersion tank (26), the liquid working fluid (38) of the immersion bath (bath of 38) contacting the heat-generating components (29: see Figure 1); vaporizing the liquid working fluid (38) into a vapor working fluid located in a headspace (40) above the immersion bath (bath of 38: see Col 3 Lines [45-50]); spraying (via 32) a portion of the liquid working fluid (38) into the headspace (40) as a plurality of droplets (see Col 6 Lines [47-52]); and condensing at least a portion of the vapor working fluid with the plurality of droplets (see Col 9 Lines [38-63]). Regarding claim 2, Cray further teaches further comprising cooling the portion of the liquid working fluid (38) with a heat-exchanger (48) outside of the immersion tank (26: see Figure 1). 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. 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 3, 4, 6-8, 10, 11, 13, 15, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Cray (US 5131233 A) as applied to claims 1 and 2 above, and further in view of Antonetti (US3774677A). Regarding claims 3 and 7, Cray does not explicitly teach wherein a temperature difference between the plurality of droplets and the vapor working fluid is at least 4°C. However, temperature difference between the plurality of droplets and the vapor working fluid is a results effective variable, as recognized by Antonetti (see at least Col 5 Lines [20-56]). It would, therefore, have been obvious to one having ordinary skill in the art before the effective filing date of the invention to provide the method of Cray with a temperature difference between the plurality of droplets and the vapor working fluid is at least 4°C, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or working ranges involves only routine skill in the art (see In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955); In re Antonie, 559 F.2d 618, 195 USPQ 6 (CCPA 1977)). Regarding claims 4, 8, and 11, Cray does not explicitly teach further comprising: measuring a temperature of the immersion bath; and adjusting a temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath. However, it’s old and well known in the art for thermal management to adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath, as evidenced by Antonetti, see Antonetti’s Col 6 Lines [46-61] where Antonetti adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath by adjusting the flow rate. It would, therefore, have been obvious to one having ordinary skill in the art before the effective filing date of the invention to provide the method of Cray with measuring a temperature of the immersion bath; and adjusting a temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath, since as evidenced by Antonetti, such provision was old and well-known in the art, and would provide the predictable benefit of increasing the heat transfer rate. Regarding claims 6, 10, 15, and 16, Cray in view of Antonetti further teaches wherein adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger (see Antonetti’s Col 6 Lines [46-61] where Antonetti adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath by adjusting the flow rate to nozzles (30) which implicitly would result to adjusting the flow rate of liquid working fluid through the heat exchanger (42)). Regarding claim 13, Cray does not explicitly teach wherein adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger. However, it’s old and well known in the art for thermal management to adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath, as evidenced by Antonetti, (see Antonetti’s Col 6 Lines [46-61] where Antonetti adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath by adjusting the flow rate to nozzles (30) which implicitly would result to adjusting the flow rate of liquid working fluid through the heat exchanger (42)). It would, therefore, have been obvious to one having ordinary skill in the art before the effective filing date of the invention to provide the method of Cray with adjusting the temperature difference includes changing a flowrate of liquid working fluid through a heat exchanger, since as evidenced by Antonetti, such provision was old and well-known in the art, and would provide the predictable benefit of increasing the heat transfer rate. Claims 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Cray (US 5131233 A) in view of Antonetti (US3774677A). Regarding claim 17, Cray teaches a method of thermal management for heat-generating components (29: see Figure 1), the method comprising: receiving thermal energy from heat-generating components (29) with a liquid working fluid (38) in an immersion bath (bath of 38) in an immersion tank (26), the liquid working fluid (38) of the immersion bath (bath of 38) contacting the heat-generating components (29: see Figure 1); vaporizing the liquid working fluid (38) into a vapor working fluid located in a headspace (40) above the immersion bath (bath of 38: see Col 3 Lines [45-50]); spraying (via 32) a portion of the liquid working fluid (38) into the headspace (40) as a plurality of droplets (see Col 6 Lines [47-52]); and condensing at least a portion of the vapor working fluid with the plurality of droplets (see Col 9 Lines [38-63]). Cray does not explicitly teach measuring a temperature of the immersion bath, wherein a temperature difference between the plurality of droplets and the vapor working fluid is at least 40C; adjusting a temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath. However, temperature difference between the plurality of droplets and the vapor working fluid is a results effective variable, as recognized by Antonetti (see at least Col 5 Lines [20-56]). Furthermore, it’s old and well known in the art for thermal management to adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath, as evidenced by Antonetti, see Antonetti’s Col 6 Lines [46-61] where Antonetti adjust the temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath by adjusting the flow rate. It would, therefore, have been obvious to one having ordinary skill in the art before the effective filing date of the invention to provide the method of Cray with a temperature difference between the plurality of droplets and the vapor working fluid is at least 4°C, since it has been held that where the general conditions of a claim are disclosed in the prior art, discovering the optimum or working ranges involves only routine skill in the art (see In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955); In re Antonie, 559 F.2d 618, 195 USPQ 6 (CCPA 1977)). Moreover, it would, have been obvious to one having ordinary skill in the art before the effective filing date of the invention to provide the method of Cray with measuring a temperature of the immersion bath; adjusting a temperature difference between the plurality of droplets and the vapor working fluid based on the temperature of the immersion bath, since as evidenced by Antonetti, such provision was old and well-known in the art, and would provide the predictable benefit of increasing the heat transfer rate. Regarding claim 18, Cray further teaches further comprising cooling the portion of the liquid working fluid (38) with a heat-exchanger (48) outside of the immersion tank (26: see Figure 1). Allowable Subject Matter Claims 5, 9, 12, 14 would be allowable if rewritten to overcome the rejection(s) under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), 2nd paragraph, set forth in this Office action and to include all of the limitations of the base claim and any intervening claims. Claim 19 would be allowable if rewritten or amended to overcome the rejection(s) under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), 2nd paragraph, set forth in this Office action. The following is a statement of reasons for the indication of allowable subject matter: Claims 5, 9, 12, 14, and 19 are containing allowable subject matter since Cray in view of Antonetti fails to teach “adjusting the temperature difference includes changing a fan speed of a heat exchanger”. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to KHALED AL SAMIRI whose telephone number is (571)272-8685. The examiner can normally be reached 10:30AM~3:30PM, M-F (E.S.T.). 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. /KHALED AHMED ALI AL SAMIRI/ Examiner, Art Unit 3763 /JIANYING C ATKISSON/ Supervisory Patent Examiner, Art Unit 3763
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Prosecution Timeline

Jan 03, 2024
Application Filed
May 05, 2026
Non-Final Rejection mailed — §102, §103, §112
Jun 25, 2026
Interview Requested

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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
47%
Grant Probability
99%
With Interview (+58.5%)
3y 0m (~6m remaining)
Median Time to Grant
Low
PTA Risk
Based on 135 resolved cases by this examiner. Grant probability derived from career allowance rate.

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