Prosecution Insights
Last updated: October 04, 2026
Application No. 18/424,356

INTEGRATION OF ACTIVE MEMS COOLING SYSTEMS INTO SMART PHONES

Non-Final OA §102§103
Filed
Jan 26, 2024
Priority
Jan 27, 2023 — provisional 63/441,723
Examiner
DRAVININKAS, ADAM B
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Frore Systems Inc.
OA Round
1 (Non-Final)
75%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
90%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allowance Rate
713 granted / 953 resolved
+6.8% vs TC avg
Moderate +15% lift
Without
With
+14.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
15 currently pending
Career history
964
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
47.5%
+7.5% vs TC avg
§102
32.4%
-7.6% vs TC avg
§112
17.5%
-22.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 953 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 . Drawings The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they include the following reference character(s) not mentioned in the description: “603A” and “603B”. Corrected drawing sheets in compliance with 37 CFR 1.121(d), or amendment to the specification to add the reference character(s) in the description in compliance with 37 CFR 1.121(b) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. 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. Claim(s) 1-20 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Ganti et al. (US 2023/0012794 A1) Re. claim 1: Ganti discloses a mobile phone, comprising: a cover (inherent in a mobile phone as described) defining an interior portion of the mobile phone; (see para. 0002, 0015, 0016) a circuit board (102, 602, 702) to which a heat-generating structure is coupled, the circuit board being within the interior portion; (see fig, 1, 6, 7; para. 0022-0025) a cooling system (100, 200, 600, 700) including at least one active cooling cell, the heat-generating structure being thermally coupled (190, 690, 790) with the cooling system, the at least one active cooling cell being configured to utilize vibrational motion to drive a fluid for transferring heat from the heat- generating structure, the cooling system being contained by the cover; and (see fig, 1, 6, 7; para. 0022-0024) wherein at least one of A) the mobile phone includes an interposer (630 and 682 combined or 730 and distal vertical walls combined), B) the cover includes a raised portion, or C) the mobile phone includes a cavity therein, the interposer being coupled (through 190, 690, 790) to the circuit board and including a gap (gap between two walls 682 or between distal vertical walls near 730) configured such that a first portion of the cooling system (620, 720) thermally coupled with the heat-generating structure resides within the gap, (see fig. 6, 7; para. 0077-0084) the raised portion of the cover being configured such that a second portion of the cooling system resides in the raised portion, the cavity including the cooling system therein, separating the cooling system from the interior portion of the mobile phone, and configured such that the interior portion is water resistant. (Ganti teaches the limitations of the interposer and so is not required to teach the limitations of the cover raised portion or the cavity) Re. claims 4-5: limitations of these claims are not required to be taught by the prior art of Ganti because Ganti teaches the interposer in claim 1 and the cavity is a non-selected option. Re. claim 6: Ganti discloses wherein the cooling system has a total height not exceeding 3.5 millimeters. (see para. 0026) Re. claim 7: Ganti discloses wherein the total height is not less than 1 millimeter and not exceeding three millimeters. (see para. 0026) Re. claim 8: Ganti discloses wherein the heat-generating structure includes a processor for the mobile phone. (see para. 0013) Re. claim 9: Ganti discloses wherein the cooling system further includes a heat sink, the heat sink being thermally coupled with the heat-generating structure. (see para. 0025) Re. claim 10: Ganti discloses wherein the cooling system (300) includes a first cooling cell (301A) and a second cooling cell (301B). (see fig. 3A-B; para. 0056-0057) Re. claim 11: Ganti discloses a battery, the cooling system being configured to utilize the vibrational motion to transfer the heat from the battery. (see para. 0025) Re. claim 12: Ganti discloses wherein each of the at least one active cooling cell includes at least one cooling element (120, 620, 720) configured to undergo the vibrational motion to drive the fluid toward the heat-generating structure. (see fig. 1, 6, 7; para. 0022-0024, 0075-0077, 0081-0082) Re. claim 13: Ganti discloses wherein the cooling element has a first cantilevered arm (left 120), a second cantilevered arm (right 120), and a central portion (portion near anchor 160) between the first cantilevered arm and the second cantilevered arm, the first cantilevered arm and the second cantilevered arm undergoing the vibrational motion. (see fig. 1; para. 0023-0024) Re. claim 14: Ganti discloses wherein each of the at least one active cooling cell further includes: a top plate (110) having at least one vent (112) therein; and (see fig. 1; para. 0023-0024) an orifice plate (130) including a plurality of orifices therein, the at least one cooling element (120) being between the top plate and the orifice plate, the vibrational motion drawing the fluid through the vent, directing the fluid past the cooling element, and driving the fluid out of the plurality of orifices. (see fig. 1; para. 0023-0024) Re. claim 15: Ganti discloses a mobile phone, comprising: a front cover (inherent in a mobile phone as described); (see para. 0002, 0015, 0016) a back cover (inherent in a mobile phone as described), an interior of the mobile phone being defined between the front cover and the back cover; (see para. 0002, 0015, 0016) a heat-generating structure (102, 602, 702); (see fig, 1, 6, 7; para. 0022-0025) a circuit board including a plurality of computing components thereon; and (see para. 0022-0025) a cooling system (100, 200, 600, 700) including at least one active cooling cell, the at least one active cooling cell being configured to utilize vibrational motion to drive a fluid for removing heat from the heat-generating structure; (see fig, 1, 6, 7; para. 0022-0024) wherein at least one of: A) the mobile phone includes an interposer (630 and 682 combined or 730 and distal vertical walls combined), (see fig. 6, 7) B) at least one of the front cover or the back cover includes a raised portion, or C) the cover includes a cavity therein, the interposer being coupled (through 190, 690, 790) to the circuit board and including a gap (gap between two walls 682 or between distal vertical walls near 730) configured such that a first portion of the cooling system (620, 720) thermally coupled with the heat-generating structure resides within the gap, (see fig. 6, 7; para. 0077-0084) the raised portion of the cover being configured such that a second portion of the cooling system resides in the raised portion, the cavity including the cooling system therein, separating the cooling system from the interior portion of the mobile phone, and configured such that the interior portion is water resistant. (Ganti teaches the limitations of the interposer and so is not required to teach the limitations of the cover raised portion or the cavity) Re. claim 17: limitations of this claim are not required to be taught by the prior art of Ganti because Ganti teaches the interposer in claim 1 and the cavity is a non-selected option. Re. claim 18: Ganti discloses wherein the heat-generating structure is at least one of a processor mounted on the circuit board or a battery. (see para. 0013) Re. claim 19: Ganti discloses a method for cooling a mobile phone having a cover defining an interior portion of the mobile phone, the method comprising: driving a plurality of active cooling cells (301) in a cooling system (300) of the mobile phone, (see fig. 3; par. 0056-0057) the mobile phone further including a circuit board (inherent within a mobile phone) within the interior portion and a heat-generating structure (102, 602, 702) thermally coupled with the cooling system, the plurality of active cooling cells being configured to utilize vibrational motion to drive a fluid for transferring heat from the heat-generating structure; (see fig, 1, 6, 7; para. 0022-0025) wherein at least one of A) the mobile phone includes an interposer, 630 and 682 combined or 730 and distal vertical walls combined), (see fig. 6, 7) B) the cover includes a raised portion, or C) the mobile phone includes a cavity therein, the interposer being coupled (through 190, 690, 790) to the circuit board and including a gap (gap between two walls 682 or between distal vertical walls near 730) configured such that a first portion of the cooling system (620, 720) thermally coupled with the heat-generating structure resides within the gap, (see fig. 6, 7; para. 0077-0084) the raised portion of the cover being configured such that a second portion of the cooling system resides in the raised portion, the cavity including the cooling system therein, separating the cooling system from the interior portion of the mobile phone, and configured such that the interior portion is water resistant. Re. claim 20: Ganti discloses driving the plurality of active cooling cells such that the vibrational motion is substantially at a structural resonance for the plurality of active cooling cells and substantially at a fluidic resonance for the plurality of active cooling cells. (see fig, 1, 6, 7; para. 0022-0024, 0035) 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) 2-3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Ganti as applied to claim 1 above, and further in view of Kock et al. (US 2022/0286545 A1). Re. claims 2, 3, and 16: Ganti fails to disclose: an additional circuit board, the interposer being coupled to and between the circuit board and the additional circuit board, the additional circuit board including a circuit board gap aligned with the gap of the interposer such that the first portion of the cooling system fits within the circuit board gap. However, Kock discloses: an additional circuit board (2104), the interposer (2106) being coupled to and between the circuit board (2102) and the additional circuit board (see fig. 21A-D; para. 0467-0477) wherein the additional circuit board (2104) includes a circuit board gap (hole to accommodate 2119-2120) aligned with the gap of the interposer (2106) such that the first portion of the cooling system fits within the circuit board gap. (see fig. 21D; para. 0474-0475) Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the interposer between the circuit board and an additional circuit board as taught by Kock to the device of Ganti. One of ordinary skill would have been motivated to do this in order to provide an additional circuit board and to protect the electronic components within the internal volume. (Kock para. 0467) Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Sathyamurthy et al. (US 2022/0189852 A1) discloses a vibrational cooling device. Nootens et al. (US 2022/0278021 A1) discloses an interposer within a power transistor. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADAM B DRAVININKAS whose telephone number is (571)270-1353. The examiner can normally be reached Monday - Friday 9a-6p MT. 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, JAYPRAKASH (JP) N GANDHI can be reached at 571-272-3740. 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. August 14, 2026 /ADAM B DRAVININKAS/Primary Examiner, Art Unit 2841
Read full office action

Prosecution Timeline

Jan 26, 2024
Application Filed
Aug 18, 2026
Non-Final Rejection mailed — §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
75%
Grant Probability
90%
With Interview (+14.8%)
2y 5m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 953 resolved cases by this examiner. Grant probability derived from career allowance rate.

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