Prosecution Insights
Last updated: August 18, 2026
Application No. 18/420,364

SYSTEMS AND METHODS FOR LIQUID COOLING OF MULTICOMPONENT PACKAGES

Non-Final OA §102§103
Filed
Jan 23, 2024
Examiner
WEILAND, HANS R.
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Microsoft Technology Licensing, LLC
OA Round
3 (Non-Final)
56%
Grant Probability
Moderate
3-4
OA Rounds
6m
Est. Remaining
69%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allowance Rate
293 granted / 527 resolved
-14.4% vs TC avg
Moderate +13% lift
Without
With
+13.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
25 currently pending
Career history
542
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
44.7%
+4.7% vs TC avg
§102
21.5%
-18.5% vs TC avg
§112
31.1%
-8.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 527 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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 5/26/2026 has been entered. 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. Claim(s) 1-6, 9, 12-14, 17, 18 and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2). Regarding claim 1, Koyama discloses (Figure 1-4) A thermal management device (cooler 100b) comprising: a body (at jacket 21 and top plate 20) including: an internal volume configured to receive a working fluid through an inlet (inflow port 23) and exhaust the working fluid through an outlet in fluid communication with a single chamber of the internal volume (outflow port 24 for flow out of a chamber for refrigerant flow in the jacket 21)), and an inner contact surface (at top plate 20) configured to transfer heat from a heat-generating component (at one of semiconductor chips 8) to the internal volume; a first zone of the internal volume including a first thermal management feature; a second zone of the internal volume including a second thermal management feature different from the first thermal management feature (as the thermal management features are only broadly defined these can be any feature associated with thermal management such as zones around the fins 22 and pines 25 below one of the semiconductor chips 8 as seen in figure 1(a) and 1(b), or the main refrigerant path 30, or the inlet and outlet zones around the inflow and outflow port, as some examples of what can classify as a first or second thermal management feature as all are features associated with zones of the cooler 100b) ; and a proportioning valve located in the internal volume and configured to direct a portion of the working fluid flow toward or away from the first zone and/or second zone (one of bimetal valves 26 can direct fluid flow to or away from the fins 22 or the main refrigerant path 30 per paragraph 0063). However Koyama does not explicitly disclose exhausting working fluid through a plurality of outlets in fluid communication with a single chamber of the internal volume. Andry teaches (Figure 1-4) a thermal management device (cooling device 100, 300 or 400) comprising: a body (at cooling module 101, substrate 301 or 401) including: an internal volume configured to receive a working fluid through an inlet (one of inlets 101a, I, or 405 seen in figure 1-4) and exhaust the working fluid through a plurality of outlets (one of outlets 101a, O, or 407 seen in figure 1-4) in fluid communication with a single chamber of the internal volume (as clearly seen in the flow paths of figure 3A and 4). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the single outlet of Koyama to be a plurality of outlets as taught by Andry. Doing so would allow for varying the number of inlets and outlets depending on the particular design of the system as recognized by Andry (per Col. 5, line 43-55) and would allow for inflow and outflow points closer to individual cannels a seen in figure 3A and 4 of Andry. Regarding claim 2, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the first thermal management feature is a thermal transfer structure (the fins 22 provide a structure for thermal transfer per paragraph 0063). Regarding claim 3, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the first thermal management feature is a nozzle (a nozzle is only generally defined the inflow regions around inflow port can form an inlet nozzle). Regarding claim 4, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the first zone and the second zone (where the first and second zones are in fins 22 on opposite sides of the central path ) are in fluid parallel to one another (per paragraph 0067 the refrigerant is directed to the fins from the central path 30 via the bimetal valves 26 and as such fluid would be directed to the fins on either side of the central path via the valves). Regarding claim 5, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the first zone and the second zone are in fluid series to one another (from the zone around the inlet 23 to the any of the downstream zones at the fins 22 or outlet 24 would be in fluid series). Regarding claim 6, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the inner contact surface (20) is a contact surface of a contact wall (20 contacts the semiconductor module 100a) including a continuous heat spreader (as the heat spreader is only vaguely defined the heat spreader can simply be a sheet with high heat transfer capabilities such as the metal base 1) . Regarding claim 9, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the working fluid is a single-phase working fluid (it is desirable that the refrigerant is a liquid per paragraph 0024). Regarding claim 12, Koyama as modified discloses the claim limitations of claim 1 above and Koyama further discloses the proportioning valve is a passive valve (bimetal valve 26 per paragraph 0058). Regarding claim 13, Koyama as modified discloses the claim limitations of claim 12 above and Koyama further discloses the proportioning valve includes a plurality of materials with different coefficients of thermal expansion (per paragraph 0059). Regarding claim 14, Koyama as discloses (Figure 1-4) a thermal management device (cooler 100b) comprising: a body (at jacket 21 and top plate 20) including: an internal volume configured to receive a working fluid ( in the jacket 21), at least one inlet to a chamber of the internal volume (at inflow port 23, into a chamber for refrigerant flow in the jacket 21) at least one outlet from the internal volume (at outflow port 24), a proportioning valve located in the internal volume and configured to direct a portion of the working fluid flow toward or away from a first zone and/or a second zone (one of bimetal valves 26 can direct fluid flow to or away from the fins 22 or the main refrigerant path 30 per paragraph 0063) and an inner contact surface (at top plate 20) configured to transfer heat from a heat-generating component (at one of semiconductor chips 8) to the internal volume; the first zone of the internal volume including a first thermal management feature; the second zone of the internal volume including a second thermal management feature different from the first thermal management feature (as the thermal management features are only broadly defined these can be any feature associated with thermal management such as zones around the fins 22 and pines 25 below one of the semiconductor chips 8 as seen in figure 1(a) and 1(b), or the main refrigerant path 30, or the inlet and outlet zones around the inflow and outflow port, as some examples of what can classify as a first or second thermal management feature as all are features associated with zones of the cooler 100b). However Koyama does not explicitly disclose a plurality of outlets in fluid communication with the chamber of the internal volume. Andry teaches (Figure 1-4) a thermal management device (cooling device 100, 300 or 400) comprising: a body (at cooling module 101, substrate 301 or 401) including: an internal volume configured to receive a working fluid (inside the cooling ,module 101 or substrate 301 or 401), at least one inlet to a chamber of the internal volume (one of inlets 101a, I, or 405 seen in figure 1-4) a plurality of outlets in fluid communication with the chamber of the internal volume (one of outlets 101a, O, or 407 seen in figure 1-4). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the single outlet of Koyama to be a plurality of outlets as taught by Andry. Doing so would allow for varying the number of inlets and outlets depending on the particular design of the system as recognized by Andry (per Col. 5, line 43-55) and would allow for inflow and outflow points closer to individual cannels a seen in figure 3A and 4 of Andry. Regarding claim 17, Koyama as modified discloses the claim limitations of claim 14 above and Koyama further discloses the first zone is in a first portion of the internal volume and the second zone is in a second portion of the internal volume, wherein the first portion and second portion are discrete fluid volumes from one another ( in the fins on the 22 on the upper side of figure 1(a) and the fins 22 on the lower side of figure 1(a)). Regarding claim 18, Koyama as modified discloses the claim limitations of claim 14 above and Andry further discloses the at least one inlet is a first inlet and the body includes a second inlet to the chamber (at the second one of inlets 101a, I, or 405 seen in figure 1-4). Regarding claim 20, Koyama discloses (Figure 1-17) a thermal management device (cooler 100b) comprising: a body (at jacket 21 and top plate 20) including: an internal volume ( in jacket 21), a first inlet to a first portion of a chamber (a chamber for refrigerant flow in the jacket 21) of the internal volume configured to receive a first working fluid (at inflow port 23), a second portion of the chamber of the internal volume configured to receive a second working fluid, a first outlet from the first portion of the chamber of the internal volume (outflow port 24), and an inner contact surface (at top plate 20) configured to transfer heat from a heat-generating component (at one of semiconductor chips 8) to the internal volume; a proportioning valve located in the internal volume and configured to proportion a flow of the firs working fluid and the second working fluid (one of bimetal valves 26 can direct fluid flow to or away from the fins 22 or the main refrigerant path 30 per paragraph 0063) a first zone in the first portion of the internal volume including a first thermal management feature; a second zone in the second portion of the of the internal volume including a second thermal management feature different from the first thermal management feature (as the thermal management features are only broadly defined these can be any feature associated with thermal management such as zones around the fins 22 and pines 25 below one of the semiconductor chips 8 as seen in figure 1(a) and 1(b), or the main refrigerant path 30, or the inlet and outlet zones around the inflow and outflow port, as some examples of what can classify as a first or second thermal management feature as all are features associated with zones of the cooler 100b) . However Koyama does not explicitly disclose a second inlet to a second portion of the chamber of the internal volume configured to receive a second working fluid and a second outlet from the second portion of the chamber of the internal volume as Koyama only explicitly discloses one inlet and one outlet. Andry teaches (Figure 1-4) a thermal management device (cooling device 100, 300 or 400) comprising: a body (at cooling module 101, substrate 301 or 401) including: an internal volume configured to receive a working fluid (inside the cooling ,module 101 or substrate 301 or 401), at least one inlet to a chamber of the internal volume (one of inlets 101a, I, or 405 seen in figure 1-4) a plurality of outlets in fluid communication with the chamber of the internal volume (one of outlets 101a, O, or 407 seen in figure 1-4). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the single outlet of Koyama to be a plurality of outlets as taught by Andry. Doing so would allow for varying the number of inlets and outlets depending on the particular design of the system as recognized by Andry (per Col. 5, line 43-55) and would allow for inflow and outflow points closer to individual cannels a seen in figure 3A and 4 of Andry. Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2) and Shih et al. (US 2013/0039012 A1). Regarding claim 7, Koyama as modified discloses the claim limitations of claim 1 above however Koyama does not explicitly disclose the inner contact surface is at least partially integrally formed with a die surface. Shih teaches (figure 1-5) a thermal management device with an inner contact surface (at the inner surface of container 26 and substrate 22 in contact with cooling substance/ water 24), where the inner contact surface is at least partially integrally formed with a die surface (the cooling substance /water 24 directly contacts the semiconductor device 20 through the opening 261 per paragraph 0041-0042 and 0045). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the contact surface of Koyama to be integrally formed with a die/semiconductor surface as taught by Shih. Doing so would allow for an structure that could improve the heat dissipation efficiency as recognized by Shih (per paragraph 0008 and 0045). Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2) and Zaffetti et al. (US 2011/0232879 A1). Regarding claim 8 Koyama as modified discloses the claim limitations of claim 1 above and Koyama does not explicitly disclose further discloses the working fluid is a first working fluid in the first zone, and further comprising a second working fluid in the second zone. Zaffetti teaches (figure 1-3) a thermal management device with multiple zones (in the individual cooling plates 22 and 24 per paragraph 0012) where the working fluid in the first zone and the second zone are different fluids ( per paragraph 0013). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the working fluid in different zones of Koyama to be different working fluids as taught by Zaffetti. Doing so would allow for different mediums in different zones/circuits which would allow for each of the zones/circuits to provide desired thermal control capabilities as recognized by Shih (per paragraph 0013). Claim(s) 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2) and Kang et al. (US 2023/0284414 A1). Regarding claim 10, Koyama as modified discloses the claim limitations of claim 1 above however Koyama does not explicitly disclose that the working fluid is a dual-phase working fluid. Koyama does not explicitly disclose that the medium/working fluid is in a dual phase state. Kang discloses a thermal management device ( heat exchanger 1) that uses a dual phase working fluid ( phase changing coolant per paragraphs 0030 and 0033-0034). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the working fluid of Koyama to be a two phase/ dual phase working fluid as taught by Kang. Doing so would provide an alternative coolant to a single phase coolant which can absorb large amounts of heat though the latent heat of vaporization as recognized by Kang (per paragraph 0030). Claim(s) 11 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2) and Shedd et al ( US 2016/0120059 A1). Regarding claim 11, Koyama as modified discloses the claim limitations of claim 1 above, however Koyama does not explicitly disclose a three-way valve configured to change a working fluid flow in at least the first zone. Shedd teaches (Figure 12C and 12D) a thermal management device (at heat sink module 100) with a inlet connected to a three way valve (60) configured to change/proportion a working fluid flow in the thermal management device (where a first portion of coolant 51-1 and a second portion of coolant 51-2 pass through the valve to be delivered at different rates to the heat exchanger 40 and the heat sink module 100 per paragraph 0057-0058 and 00365). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the thermal management device of Koyama to include a three way valve attached to the inlet of the thermal management device to allow of a portion of the coolant to either bypass or be delivered to the thermal management device as recognized by Shedd (per paragraph 0057 and 0058). Regarding claim 19, Koyama as modified discloses the claim limitations of claim 17 above, however Koyama does not explicitly disclose the at least one inlet is connected to a three-way valve configured to proportion flow therethrough. Shedd teaches (Figure 12C and 12D) a thermal management device (at heat sink module 100) with a inlet connected to a three way valve (60) configured to change/proportion a working fluid flow in the thermal management device (where a first portion of coolant 51-1 and a second portion of coolant 51-2 pass through the valve to be delivered at different rates to the heat exchanger 40 and the heat sink module 100 per paragraph 0057-0058 and 00365). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified the thermal management device of Koyama to include a three way valve attached to the inlet of the thermal management device to allow of a portion of the coolant to either bypass or be delivered to the thermal management device as recognized by Shedd (per paragraph 0057 and 0058). Claim(s) 15 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2) and Bratkovski et al, (US 7,763,973 B1, previously cited by the examiner) Regarding claim 15, Koyama discloses the claim limitations of claim 14 above and Koyama does not explicitly disclose an inlet valve configured to change a flowrate of the working fluid through the first zone. Bratkovski discloses (figure 1-6) an integrated heat sink structure where flow to individual zones of an internal volume (at individual electronic devices 14, as the fluid flows through the microchannels 22), a valve configured to change a working fluid flow in at least the first zone (at one of the valves 38 controlling flow to one of the electronic devices 14 forming a first zone as seen in figure 6) where the valve (38) is present at an inlet and an outlet from an individual electronic device ( where valves 38 are seen on either side of an individual electronic device 14 as seen in figure 6, and per Col. 3, line 46-60 where the valve can control a flow through at least a portion of the system). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified inlet and/or outlet of Koyama to include valves as taught by of Bratkovski. Doing so would allow for an automatically controlled valve that could open or close to control flow to an individual component to be cooled which could vary the amount of coolant suppled to a heat sink in response to cooling needs as recognized by Bratkovski (per Col. 3, line 48-60). Regarding claim 16, Koyama discloses the claim limitations of claim 14 above however Koyama does not explicitly disclose an outlet valve configured to change a flowrate of the working fluid through the first zone. Bratkovski discloses (figure 1-6) an integrated heat sink structure where flow to individual zones of an internal volume (at individual electronic devices 14, as the fluid flows through the microchannels 22), a valve configured to change a working fluid flow in at least the first zone (at one of the valves 38 controlling flow to one of the electronic devices 14 forming a first zone as seen in figure 6) where the valve (38) is present at an inlet and an outlet from the an individual electronic device ( where valves 38 are seen on either side of an individual electronic device 14 as seen in figure 6, and per Col. 3, line 46-60 where the valve can control a flow through at least a portion of the system). It would have been obvious to one having ordinary skill in the art at the time the invention was effectively filed to have modified inlet and/or outlet of Koyama to include valves as taught by of Bratkovski. Doing so would allow for an automatically controlled valve that could open or close to control flow to an individual component to be cooled which could vary the amount of coolant suppled to a heat sink in response to cooling needs as recognized by Bratkovski (per Col. 3, line 48-60). Response to Arguments Applicant’s arguments, see pages 6-10, filed 5/26/2026, with respect to the rejection(s) of claim(s) 1-6, 11 and 14-20 under 35 U.S.C. 102 and 103 in view of the prior art of Koyama and Koyama in view of Todorovic have been fully considered and are persuasive based upon the amendments made to the claims. Therefore, the rejections has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in light of Koyama et al. (US 2016/0190038 A1) in view of Andry et al. (US Patent 7,888,786 B2) as noted above where Andry discloses the newly added limitations of a multiple inlets and outlets to the thermal management device. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Morra (US 20100078155 A1), Tang (US 20120103575 A1), Tsai et al. (US 20160216048 A) and Tousignant et al. (US 5205348 A) disclose thermal management devices with multiple inlets and/or outlets. Any inquiry concerning this communication or earlier communications from the examiner should be directed to HANS R. WEILAND whose telephone number is (571)272-9847. The examiner can normally be reached Monday-Thursday 6-3 EST and alternating Fridays. 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, Len Tran can be reached at 571-272-1184. 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. /HANS R WEILAND/Examiner, Art Unit 3763 /ERIC S RUPPERT/Primary Examiner, Art Unit 3763
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Prosecution Timeline

Show 5 earlier events
Nov 12, 2025
Response Filed
Feb 26, 2026
Final Rejection mailed — §102, §103
Apr 09, 2026
Interview Requested
Apr 21, 2026
Examiner Interview Summary
Apr 21, 2026
Applicant Interview (Telephonic)
May 26, 2026
Request for Continued Examination
May 28, 2026
Response after Non-Final Action
Jun 04, 2026
Non-Final Rejection mailed — §102, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
56%
Grant Probability
69%
With Interview (+13.0%)
3y 0m (~6m remaining)
Median Time to Grant
High
PTA Risk
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