Prosecution Insights
Last updated: April 19, 2026
Application No. 18/432,342

PRESSURE RELIEF VALVE AND ADSORBENT CHAMBER FOR TWO-PHASE IMMERSION COOLING SYSTEMS AND METHODS FOR USING SAME

Non-Final OA §103§DP
Filed
Feb 05, 2024
Examiner
BUTTAR, MANDEEP S
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Mts Ip Holdings Ltd.
OA Round
1 (Non-Final)
80%
Grant Probability
Favorable
1-2
OA Rounds
2y 1m
To Grant
96%
With Interview

Examiner Intelligence

Grants 80% — above average
80%
Career Allow Rate
430 granted / 539 resolved
+11.8% vs TC avg
Strong +17% interview lift
Without
With
+16.6%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 1m
Avg Prosecution
14 currently pending
Career history
553
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
52.5%
+12.5% vs TC avg
§102
28.5%
-11.5% vs TC avg
§112
12.9%
-27.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 539 resolved cases

Office Action

§103 §DP
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 . Information Disclosure Statement The information disclosure statement (IDS) submitted on 5/2/2024 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. Claims 1-20 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-30 of U.S. Patent No. 11,894,288. Although the claims at issue are not identical, they are not patentably distinct from each other because Pat ‘288 anticipates the claim limitation set forth on 2/5/2024. With respect to Claim 1, Pat ‘288 discloses a two-phase immersion cooling system, comprising: a tank configured to contain a coolant liquid and one or more printed circuit boards having semiconductor die (Claim 1, lines 17-20); and a one-way pressure relief valve (Claim 1, line 28), coupled to the tank, having an open position and a closed position (Claim 1), the valve being configured to remain in the closed position and only move from the closed position towards the open position when A) a pressure difference across the valve generates a net force directed towards the open position (Claim 1, lines 33-67) and B) the pressure difference is greater than a pressure threshold of the valve, wherein: the pressure threshold of the valve ranges from about 0.5 pounds per square inch (psi) to about 2 psi (Claim 2); and when the valve is at the open position or between the open position and the closed position, the valve is configured to allow a fluid to flow through the valve at a rate ranging from about 0 cubic feet per minute (cfm) to about 2000 cfm (Claim 2). With respect to Claim 2, claims 1 & 2 of Pat ‘288 discloses the system of claim 1, wherein the passage has a diameter ranging from about 2 inches to about 6 inches (Claim 3). With respect to Claim 3, claims 1 & 2 of Pat ‘288 discloses the system of claim 1, wherein the spring has a diameter ranging from about 1.5 inches to about 1.7 inches (Claim 3). With respect to Claim 4, claims 1 & 2 of Pat ‘288 discloses the system of claim 1, wherein the valve comprises: a valve body defining a passage; a poppet assembly coupled to the valve body and movable between and including the closed position and the open position, the poppet assembly comprising: a poppet to seal the passage at the closed position; and a spring, disposed between the valve body and the poppet assembly, to apply a spring force to the poppet assembly to keep the poppet assembly at the closed position, the pressure threshold corresponding to the spring force (Claim 1, lines 50-67). With respect to Claim 5, claim 1 of Pat ‘288 discloses the system of claim 4, wherein: the valve further comprises: a guide plate, coupled to the valve body, having a guide plate opening; and the poppet assembly further comprises: a guide rod, securely coupled to the poppet and movable through the guide plate opening, to laterally constrain the poppet. Dependent claims 6-12 are rejected under claims 1-9 of Pat ‘288. With respect to Claim 13, claim 1 of Pat ‘288 discloses A two-phase immersion cooling system, comprising: a tank configured to contain a coolant liquid and one or more printed circuit boards having semiconductor die (Claim 1); and a one-way pressure relief valve coupled to the tank, the valve comprising: a valve body defining a passage; a guide plate, coupled to the valve body, having a guide plate opening; a poppet assembly coupled to the valve body and movable between and including a closed position and an open position, the poppet assembly comprising: a poppet to seal the passage at the closed position; and a guide rod, securely coupled to the poppet and movable through the guide plate opening, to laterally constrain the poppet; and a spring, disposed between the valve body and the poppet assembly, to apply a spring force to the poppet assembly to keep the poppet assembly at the closed position unless a pressure difference across the poppet generates a net force that opposes the spring force and is greater than or equal to a pressure threshold corresponding to the spring force (Claim 1, lines 30-67). With respect to Claim 14, claim 1 of Pat ‘288 discloses the system of claim 13, wherein the pressure threshold ranges from about 0.5 pounds per square inch (psi) to about 2 psi (Claim 2). With respect to Claim 15, claim 1 of Pat ‘288 discloses the system of claim 13, wherein when the poppet assembly is at the open position or between the open position and the closed position, the valve is configured to allow a fluid to flow through the valve at a rate ranging from about 0 cubic feet per minute (cfm) to about 2000 cfm (Claim 2). With respect to Claim 16, claim 1 of Pat ‘288 discloses the system of claim 13, wherein the passage has a diameter ranging from about 2 inches to about 6 inches (Claim 3). With respect to Claim 17, claim 1 of Pat ‘288 discloses the system of claim 13, wherein the spring has a diameter ranging from about 1.5 inches to about 1.7 inches (Claim 3). With respect to Claim 18, claim 1 of Pat ‘288 discloses a two-phase immersion cooling system, comprising: a tank configured to contain a coolant liquid and one or more printed circuit boards having semiconductor die; and a one-way pressure relief valve, coupled to the tank, having an open position and a closed position, the valve being configured to remain in the closed position and only move from the closed position towards the open position when A) a pressure difference across the valve generates a net force directed towards the open position (Claim 1) and B) the pressure difference is greater than a pressure threshold of the valve, wherein: the pressure threshold of the valve ranges from about 0.5 pounds per square inch (psi) to about 2 psi (Claim 2, Col. 31, lines 2-3); and the valve defines a passage for a fluid to flow through the valve at the open position or between the open position and the closed position, the passage having a diameter ranging from about 2 inches to about 6 inches (Claim 3, Col. 31, line 10-11). With respect to Claim 19, claims 1, 2, and 3 of Pat ‘288 discloses the system of claim 18, wherein: when the valve is at the open position or between the open position and the closed position, the valve is configured to allow a fluid to flow through the valve at a rate ranging from about 0 cubic feet per minute (cfm) to about 2000 cfm (Claim 2, Col. 31, lines 4-8); and the spring has a diameter ranging from about 1.5 inches to about 1.7 inches (Claim 3, Col. 31, lines 12-13). With respect to Claim 20, claims 1, 2, and 3 of Pat ‘288 discloses the system of claim 18, wherein the valve comprises: a valve body defining a passage; a guide plate, coupled to the valve body, having a guide plate opening; a poppet assembly coupled to the valve body and movable between and including the closed position and the open position, the poppet assembly comprising: a poppet to seal the passage at the closed position; and a guide rod, securely coupled to the poppet and movable through the guide plate opening, to laterally constrain the poppet; and a spring, disposed between the valve body and the poppet assembly, to apply a spring force to the poppet assembly to keep the poppet assembly at the closed position, the pressure threshold corresponding to the spring force (Claim 1, Col. 30, lines 55-67). 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claims 1 and 8-12 are rejected under 35 U.S.C. 103 as being unpatentable over LIN (U.S 2023/0027917) in view of Enright (U.S 2020/0093038 A1). In regards to Claim 1, Lin discloses a two-phase immersion cooling system (Fig.1), comprising: a tank (Fig.1, #20) configured to contain a coolant liquid (Fig.1, #30) and one or more printed circuit boards having semiconductor die (Fig.1, #E); and a one-way pressure relief valve (Fig.1, #61), coupled to the tank (Fig.1), having an open position and a closed position (Paragraph [0030], #61 has an open and closed position), the valve being configured to remain in the closed position and only move from the closed position towards the open position when A) a pressure difference across the valve generates a net force directed towards the open position (Fig.1, #61 and paragraph [0031], discloses when a pressure across the valve generates enough pressure to force #61 to open) B) the pressure difference is greater than a pressure threshold of the valve (Paragraph [0031], when pressure exceeds a first upper limit) wherein; and when the valve is at the open position or between the open position and the closed position, the valve is configured to allow a fluid to flow through the valve at a rate ranging from about 0 cubic feet per minute (cfm) to about 2000 cfm (Fig.1, disclose a fluid to flow through #61 at a rate ranging from 0 to 2000 CFM, see paragraph [0030]). Lin does disclose a pressure threshold of the valve to have limits (see paragraph [0014-0015 & 0031]). Lin fails to explicitly disclose: The pressure threshold of the valve ranges from about 0.5 pounds per square inch (psi) to about 2 psi. However, Enright discloses: The pressure threshold of the valve ranges from about 0.5 pounds per square inch (psi) to about 2 psi (Paragraph [0036 & 0059], which discloses the immersion tank includes pressure valves which have a threshold of 2 or below, as such the office notes that with the combination of Lin in view of Enright, the two phase immersion system comprising a pressure valve having a threshold (as taught by Lin) would be modified to have a threshold of about 2 or less PSI (as taught by Enright) to ensure the components are being properly cooled). Therefore, it would of have been obvious to one of ordinary skill in the art at the time the application was filed to have modified the two phase immersion system comprising a pressure valve having a threshold (as taught by Lin) would be modified to have a threshold of about 2 or less PSI (as taught by Enright) to ensure the components are being properly cooled. By maintaining a pressure of 2 PSI or less, would reduce the boiling point of the coolant which would benefit of increase cooling which allows for more electricity to be passed through the components of said system (Enright, Paragraph [0039-0038]). In regards to Claim 8, Lin in view of Enright discloses the system of claim 1, wherein the valve is configured to be an outlet valve (Lin Fig.1, #61 is an outlet valve by releasing pressure). In regards to Claim 9, Lin in view of Enright discloses the system of claim 1, wherein the valve is configured to be an inlet valve (Lin, Fig.1, #61 has an inlet to receive access vapor/gas). In regards to Claim 10, Lin in view of Enright discloses the system of claim 1, wherein: the valve is a first valve (Lin, Fig.1, #61); the system further comprises: a second valve (Lin, Fig.1, #63) identical to the first valve (Lin, Fig.1, paragraphs [030 & 0036], discloses both valves being similar); and the first valve is configured to be an outlet valve (Lin, Fig.1, #61 is an outlet valve releasing vapor) and the second valve is configured to be an inlet valve (Lin , Fig.1, #63 is configured to be an inlet valve to introduce air (pressure) within the tank). In regards to Claim 11, Lin in view of Enright discloses the system of claim 1, further comprising: a bellows assembly (Enright, Fig.10c, #517), comprising: a container (Enright, Fig.10c, #517 contains a container) defining a container volume configured to contain a mixture of air and coolant vapor from the tank volume; and a venting tube to fluidically couple the container to the tank (Enright, paragraph [0151], which discloses a tube connected to #517 for venting access fluid mixture to reduce pressure within the tank). In regards to Claim 12, Lin in view of Enright discloses the system of claim 11, wherein the valve is directly coupled to the bellows assembly (Enright, Fig.10c and paragraph [0036 & 0246-47], disclose valves can directly connected to the bellows assembly to further reduce any pressure differential). Allowable Subject Matter Claims 2-4 and 6 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. In regards to Claim 2, no prior art fairly suggests or discloses “wherein the passage has a diameter ranging from about 2 inches to about 6 inches”. In regards to Claim 3, no prior art fairly suggests or discloses “ wherein the spring has a diameter ranging from about 1.5 inches to about 1.7 inches”. In regards to Claim 4, no prior art fairly suggests or discloses “a valve body defining a passage; a poppet assembly coupled to the valve body and movable between and including the closed position and the open position, the poppet assembly comprising: a poppet to seal the passage at the closed position; and a spring, disposed between the valve body and the poppet assembly, to apply a spring force to the poppet assembly to keep the poppet assembly at the closed position, the pressure threshold corresponding to the spring force”. Dependent claim 5 is allowably by virtue of it dependency from claim 4. In regards to Claim 6, no prior art fairly suggests or discloses “further comprising: an adsorbent chamber coupled to and disposed between the tank and the valve”. Dependent claim 7 is allowably by virtue of it dependency from claim 6. The following is a statement of reasons for the indication of allowable subject matter: With respect to the independent claim 13, no prior art fairly suggests or discloses “a valve body defining a passage; a guide plate, coupled to the valve body, having a guide plate opening; a poppet assembly coupled to the valve body and movable between and including a closed position and an open position, the poppet assembly comprising: a poppet to seal the passage at the closed position; and a guide rod, securely coupled to the poppet and movable through the guide plate opening, to laterally constrain the poppet; and a spring, disposed between the valve body and the poppet assembly, to apply a spring force to the poppet assembly to keep the poppet assembly at the closed position unless a pressure difference across the poppet generates a net force that opposes the spring force and is greater than or equal to a pressure threshold corresponding to the spring force”, in conjunction with the remaining elements. Dependent claims 14-17 are allowably by virtue of their dependency from claim 13. In regards to Claim 18, no prior art fairly suggests or discloses “the passage having a diameter ranging from about 2 inches to about 6 inches”, in conjunction with the remaining elements. Dependent claims 19-20 are allowably by virtue of their dependency from claim 18. Any comments considered necessary by applicant must be submitted no later than the payment of the issue fee and, to avoid processing delays, should preferably accompany the issue fee. Such submissions should be clearly labeled “Comments on Statement of Reasons for Allowance.” Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Lee (U.S Patent 11,589,483) - Discloses a two phase cooling system, comprising: a tank defining a tank volume configured to contain one or more printed circuit boards having semiconductor die that generate heat; coolant liquid, disposed within the tank volume, configured to immerse the one or more printed circuit boards and remove the heat from the respective semiconductor die via vaporization thereby producing coolant vapor; and a valve assembly coupled to the tank, the valve assembly comprising: a pressure relief valve. Any inquiry concerning this communication or earlier communications from the examiner should be directed to MANDEEP S BUTTAR whose telephone number is (571)272-4768. The examiner can normally be reached 7:00AM-4:00PM. 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 Gandhi can be reached at 5712723740. 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. /MANDEEP S BUTTAR/ Primary Examiner, Art Unit 2835
Read full office action

Prosecution Timeline

Feb 05, 2024
Application Filed
Mar 06, 2026
Non-Final Rejection — §103, §DP (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
80%
Grant Probability
96%
With Interview (+16.6%)
2y 1m
Median Time to Grant
Low
PTA Risk
Based on 539 resolved cases by this examiner. Grant probability derived from career allow rate.

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