Prosecution Insights
Last updated: August 17, 2026
Application No. 18/416,951

POWER SOURCE

Non-Final OA §103§112
Filed
Jan 19, 2024
Priority
Mar 27, 2023 — JP 2023-049820
Examiner
RICKMAN, HOLLY C
Art Unit
Tech Center
Assignee
Toyota Motor Corporation
OA Round
1 (Non-Final)
71%
Grant Probability
Favorable
1-2
OA Rounds
4m
Est. Remaining
93%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allowance Rate
411 granted / 581 resolved
+10.7% vs TC avg
Strong +22% interview lift
Without
With
+22.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
15 currently pending
Career history
601
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
47.6%
+7.6% vs TC avg
§102
25.2%
-14.8% vs TC avg
§112
17.8%
-22.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 581 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 . 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 1-3 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 requires that “other fuel cell systems excluding the first fuel cell system generate power using a current command having the same current value as an output current of the first fuel cell system.” It is not clear from the claim whether this means that there is the same current value for the other fuel cell systems combined or the same current value for each of the other fuel cell systems. 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. Claim(s) 1 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hammadi et al. (US 2022/0384837) in view of Astrom et al. (WO 2011/004058). Hammadi et al. discloses an electrochemical system having a plurality of identical fuel cells electrically connected in series wherein the fuel cells are supplied with fuel and oxidant in parallel. The reference teaches that during operation of the system, the same current flows through the electrically connected fuel cells, and therefore, a uniform and constant supply of oxidant and fuel to the fuel cells must be ensured so that the fuel cells each generate the same amount of electrical energy – see para [0007], abstract and Fig 1. The fact that the current is the same for each of the fuel cells implies the presence of a current command such that each of the fuel cells have the same output current as the first fuel cell in the series. The reference is silent with regard to a boost converter. Astrom et al. disclose a power supply in which a plurality of fuel cell systems and one dc-dc converter are connected in series (see Fig 3 and description thereof on pages 6-8, especially p. 7, lines 7-8). It is well known in the art that DC to DC converters include boost converters. It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to add a boost converter in series with the fuel cells taught by Hammadi et al. in order to step up the voltage to a required output level as suggested by Astrom. Claim(s) 2-3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hammadi et al. (US 2022/0384837) in view of Astrom et al. (WO 2011/004058) and further in view of Hinsenkamp et al. (US2010/0273079). Hammadi et al. in view of Astrom et al. discloses all of the features of the claim, as detailed above in paragraph 5, except for the presence of (1) an independent air supply system for each of the fuel cell systems and (2) an independent coolant supply system for each of the fuel cell systems. With regard to claim 2, Hinsenkamp et al. disclose a fuel cell system including two fuel cell units that can be controlled independently and each fuel cell unit includes a plurality of fuel cells connected in series. While the reference does not specifically disclose separate air supplies for each fuel cell, it is implied by the fact that the fuel cells can be independently controlled and would therefore be expected to have independent air supplies to tailor control of each unit. It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to add independent air supplies to each of the fuel cell units taught by Hammadi in order to better tailor control of each individual fuel cell unit. With regard to claim 3, Hinsenkamp et al. also teaches that the individual fuel cell units each have an individual cooling unit associated therewith (see para [0022]-[0023] and Fig 1). It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to add independent cooling supplies to each of the fuel cells taught by Hammadi et al. in order to have better control of cooling needs of individual cells. Any inquiry concerning this communication or earlier communications from the examiner should be directed to HOLLY RICKMAN whose telephone number is (571)272-1514. The examiner can normally be reached Mon, Tues, Thurs, 9am-3pm 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, Mark Ruthkosky can be reached at 571-272-1291. 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. /Holly Rickman/Primary Examiner, Art Unit 1785
Read full office action

Prosecution Timeline

Jan 19, 2024
Application Filed
Aug 03, 2026
Non-Final Rejection mailed — §103, §112 (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
71%
Grant Probability
93%
With Interview (+22.5%)
2y 11m (~4m remaining)
Median Time to Grant
Low
PTA Risk
Based on 581 resolved cases by this examiner. Grant probability derived from career allowance rate.

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