Prosecution Insights
Last updated: April 19, 2026
Application No. 18/434,210

Trimless Foldable Displays

Final Rejection §102§103
Filed
Feb 06, 2024
Examiner
KRIM, PETER
Art Unit
2841
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Google LLC
OA Round
2 (Final)
83%
Grant Probability
Favorable
3-4
OA Rounds
2y 6m
To Grant
84%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allow Rate
76 granted / 92 resolved
+14.6% vs TC avg
Minimal +2% lift
Without
With
+1.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
38 currently pending
Career history
130
Total Applications
across all art units

Statute-Specific Performance

§103
48.1%
+8.1% vs TC avg
§102
29.4%
-10.6% vs TC avg
§112
21.4%
-18.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 92 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 . Claim Rejections - 35 USC § 102 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)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 15, 20-21 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Choi et al (US 20250211665; “Choi” hereinafter). Regarding claim 15, Choi discloses: a foldable electronic device comprising: a housing (110, 120, 141, 135, fig. 4) having a first folding region (141, fig. 2B) that intersects a first non-folding region (110, fig. 2B) and a second non-folding region (120, fig. 2B), at least one of the first non-folding region or the second non-folding region configured to rotate about the first folding region (along F-axis, ¶[0041]); and a foldable display structure (411 and 430) positioned within at least portions of the first non-folding region and the second non-folding region of the housing, the foldable display structure comprising: a display panel (430, figs. 9D, and 13B), the display panel having a top face within which a plurality of light-emitting pixels are disposed (¶[0074]); a cover layer (411, fig. 9D) positioned as a topmost layer of a foldable display structure (figs. 11 and 13B), the cover layer having a top face and a bottom face (see annotated fig. 9D below), the bottom face of the cover layer having an area larger than an area of the top face of the display panel such that at least portions of the cover layer extend beyond one or more edges of the display panel (as disclosed in fig. 9D ); and a compliant material (510, 510’, figs. 11, 13B) disposed in at least one of the first non-folding region (120, fig. 9D) or the second non-folding region of the housing (i) between the housing and the display panel and (ii) underneath the at least portions of the cover layer (411) that extend beyond the one or more edges of the display panel (as disclosed in figs. 9D, 13B); and a rigid material (553, as disclosed upon examination of fig. 9D, ¶[0102]) disposed in at least one of the first non-folding region or the second non-folding region (120) of the housing (fig. 9D), the rigid material disposed (i) between the housing and the compliant material and (ii) underneath the at least portions of the cover layer that extend beyond the one or more edges of the display panel (fig. 9D), the compliant material and the rigid material being different materials (as disclosed upon examination of ¶[0102], ¶[0117]). PNG media_image1.png 390 703 media_image1.png Greyscale Regarding claim 20, Choi discloses the limitation of claim 15, and further discloses: wherein the rigid material is configured to provide a normal force to the bottom face of the cover layer sufficient to provide mechanical support (fig. 12, “since the second extension part 5533 exposed to the outside is disposed to be supported by the second support member 1231, it may further help to improve the support structure of the flexible display 400 in direction of a backward side (rear side)”, ¶[0102]). Regarding claim 21, Choi discloses the limitation of claim 15, and further discloses: wherein the compliant material is configured to withstand a shearing stress when at least one of the first non-folding region or the second non-folding region are rotated about the first folding region orienting the foldable electronic device in an unfolded state (as understood upon examination of figures 9D-11, ¶[0117], Choi) . 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. Claims 1, 4-7, 13 are rejected under 35 U.S.C. 103 as being unpatentable over Choi et al (US 20250211665; “Choi” hereinafter), in view of Choi2 et al (US 20220336772; “Choi2” hereinafter). Regarding claim 1, Choi discloses: a foldable electronic device (100) comprising: a housing (110, 120, 141, 135, fig. 4) having a first folding region (141, fig. 2B) that intersects a first non-folding region (110, fig. 2B) and a second non-folding region (120, fig. 2B), at least one of the first non-folding region or the second non-folding region configured to rotate about the first folding region (along F-axis, ¶[0041]); and a foldable display structure (411 and 430) positioned within at least portions of the first non-folding region and the second non-folding region of the housing, the foldable display structure comprising: a display panel (430, figs. 11 and 13B), the display panel having a top face within which a plurality of light-emitting pixels are disposed (¶[0074]); and a cover layer (411, fig. 11) positioned as a topmost layer of a foldable display structure (figs. 11 and 13B), the cover layer having a top face and a bottom face (see annotated fig. 11 below), the bottom face of the cover layer having an area larger than an area of the top face of the display panel such that at least portions of the cover layer extend beyond one or more edges of the display panel (as disclosed in fig. 11); a first compliant material (510, fig. 13B) disposed (i) between the housing and the display panel and (ii) underneath the at least portions of the cover layer (411) that extend beyond the one or more edges of the display panel (as disclosed in fig. 13B), the first compliant material disposed in the first folding region (see fig. 13A-13B, ¶[0129]-[0131]); and PNG media_image2.png 496 837 media_image2.png Greyscale a second compliant material (510’, fig. 11) disposed in at least one of the first non-folding region (110, fig. 11) or the second non-folding region of the housing. Choi does not explicitly teach: the second compliant material in contact with an underside of the display panel when the foldable electronic device is in a folded state to provide support for the display panel. However, Song teaches: a second compliant material (401, fig. 4F) in contact with an underside of a flexible display (330 and 301c, fig. 5]) when the foldable electronic device is in a folded state to provide support for the display panel (¶[0095]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to apply Choi2’s teaching into Choi, such that the second compliant material is in contact with an underside of the display panel when the foldable electronic device is in a folded state to provide support for the display panel, in order to reduce damage of the rear surface of the display panel (¶[0055]). Furthermore, it has been held that rearranging parts of an invention involves only routine skill in the art. In re Japikse, 86 USPQ 70 (CCPA 1950). Regarding claim 4, Choi in view of Choi2 discloses the limitations of claim 1, but does not explicitly disclose: wherein the first compliant material and the second compliant material comprise a resin-based compound. However, Choi2 discloses: Compliant materials (401, figs. 4A-4F) comprising a resin-based compound (¶[0110]-[0111]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to apply Choi2’s teaching to Choi’s first compliant material and second compliant material, in order to reduce cracking of first compliant material and second compliant material due to elongation during folding and unfolding of the foldable electronic device (¶[0107]). Furthermore, it has been held that the selection of a known material based on its suitability for its intended use is obvious (MPEP 2144.07) Regarding claim 5, Choi in view of Choi2 discloses the limitation of claim 1, and the combination further discloses: wherein the second compliant material is configured to provide a normal force to the bottom face of the cover layer sufficient to provide mechanical support (as disclosed upon examination of fig. 11, and the placement of 510’ between 1131 and 411, Choi). Regarding claim 6, Choi view of Choi2 discloses the limitation of claim 1, the combination further discloses: wherein the second compliant material is configured to withstand a shearing stress when at least one of the first non-folding region or the second non-folding region are rotated about the first folding region orienting the foldable electronic device in an unfolded state (as understood upon examination of figure 11, ¶[0117], Choi). Regarding claim 7, Choi in view of Choi2 discloses the limitation of claim 1, the combination further discloses: further comprising: a rigid material (520’, fig. 11, ¶[0118], Choi) disposed in at least one of the first non-folding region (110) or the second non-folding region of the housing, and wherein the rigid material is disposed (i) between the housing and the second compliant material and (ii) underneath the at least portions of the cover layer that extend beyond the one or more edges of the display panel (fig. 11, Choi). Regarding claim 13, Choi in view of Choi2 discloses the limitations of claim 7, and Choi further teaches: wherein the second compliant material and the rigid material being different materials (as disclosed upon examination of ¶[0117]-[0118]). Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over Choi in view of Choi2 as applied to claim 1, and further in view of Son et al (US 20170102809; “Son” hereinafter). Regarding claim 8, Choi in view of Choi2 discloses the limitations of claim 1, but does not explicitly disclose: wherein the first compliant material comprises a rubber gasket or a foam gasket. However, Son discloses: a first compliant material (144, figs. 2a-2b) disposed between a cover layer (110, fig. 2a, ¶[0039]) and a housing (140, fig. 2a), comprises a rubber gasket or a foam gasket (¶[0028], ¶[0030], ¶[0045]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to apply Son’s teaching to Choi’s first compliant material, such that the first compliant material comprises a rubber gasket or a foam gasket, in order to seal the space below the cover layer and protect the display panel from dust or fluids that may be present over the cover layer (¶[0045]). Furthermore, it has been held that the selection of a known material based on its suitability for its intended use is obvious (MPEP 2144.07) Claims 9-12, 14 are rejected under 35 U.S.C. 103 as being unpatentable over Choi in view of Choi2, as applied to claim 1, and further in view of Park et al (US 20200324521; “Park” hereinafter). Regarding claim 9, Choi in view of Choi2 discloses the limitations of claim 1, but does not explicitly disclose: wherein the cover layer comprises: a first groove on the top face of the cover layer along a first plane; and a second groove on the bottom face of the cover layer along the first plane, the first groove and the second groove forming a variable thickness in the cover layer along a dimension of the cover layer perpendicular to the first plane sufficient to define the first folding region. However, Park discloses: wherein a cover layer (100, fig. 12) comprises: a first groove on a top face of the cover layer along a first plane (120, fig. 8, see annotated fig. 12 below); and a second groove on a bottom face of the cover layer along the first plane (120, fig. 8, see annotated fig. 12 below), the first groove and the second groove forming a variable thickness in the cover layer along a dimension of the cover layer perpendicular to the first plane sufficient to define the first folding region (as disclosed in figs. 8 and 12). PNG media_image3.png 215 609 media_image3.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify Choi’s cover layer with Parks teaching of a first and second groove as claimed, including resin elements 130, in order to enhance the strength and folding performance of the cover layer while also improving visibility (¶[0021]). Regarding claim 10, Choi in view of Choi2 and Park discloses the limitations of claim 9, and Park further teaches: wherein the cover layer further comprises: a first resin (130, see annotated fig. 12 below) deposited within the first groove, the first resin contiguous with the top face of the cover layer; and a second resin (130, see annotated fig. 12 below) deposited within the second groove. PNG media_image4.png 215 609 media_image4.png Greyscale Regarding claim 11, Choi in view of Choi2 and Park discloses the limitations of claim 9, and Park further teaches: wherein the first groove and the second groove forming the variable thickness in the cover layer along the dimension of the cover layer perpendicular to the first plane define a thick region (see annotated fig. 12 below) and a thin region in the cover layer (see annotated fig. 12 below), and wherein the variable thickness between the thick region and the thin region comprises a ratio of at least six-to-one (as disclosed upon examination of fig. 3, ¶[0040], ¶[0059]-[0061], ¶[0075]). PNG media_image5.png 211 609 media_image5.png Greyscale Regarding claim 12, Choi in view of Choi2 and Park discloses the limitations of claim 9, and Park further teaches: wherein: the first groove comprises a first depth shallower than a second depth of the second groove (see annotated fig. 8 below); and the first groove comprises a first width narrower than a second width of the second groove (see annotated fig. 8 below). PNG media_image6.png 301 374 media_image6.png Greyscale PNG media_image7.png 387 725 media_image7.png Greyscale Regarding claim 14, Choi in view of Choi2 and Park discloses the limitations of claim 10, and Park further discloses: wherein the second resin extends beyond the second groove to cover an entire surface of the bottom face of the cover layer (fig. 12, ¶[0105]-[0106]). Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Choi, in view of Lee et al (US 20200042125; “Lee” hereinafter). Regarding claim 16, Choi discloses the limitation of claim 15, but does not explicitly disclose: wherein the portions of the cover layer that extend beyond the one or more edges of the display panel are uncovered to form a trimless foldable display (as disclosed upon examination of annotated fig. 9D below, where a portion of the cover layer (410) that extend beyond the one or more edges of the display panel (430) are uncovered). However, Park teaches: portions of a cover layer (10, fig. 3) that extend beyond the one or more edges of a display panel (30, fig. 3) are uncovered to form a trimless foldable display (as disclosed upon examination of fig. 3, ¶ [0081]). It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to apply Lee’s teaching into Choi, such that portions of the cover layer extend beyond the one or more edges of the display panel are uncovered to form a trimless foldable display, since the claim would have been obvious because the particular known technique (cover layer and display panel stacked arrangements) was recognized as part of the ordinary capabilities of one skilled in the art, as evidenced by Hansson. Moreover, the claimed subject matter would have been no more than a predictable combination of a plurality of known techniques according to their respective purposes within routine skill and creativity (MPEP 2143). Claim 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Choi et al (US 20250211665; “Choi” hereinafter), in view of Park et al (US 20200324521; “Park” hereinafter). Regarding claim 17, Choi discloses the limitations of claim 15, but does not explicitly disclose: wherein the cover layer comprises: a first groove on the top face of the cover layer along a first plane; and a second groove on the bottom face of the cover layer along the first plane, the first groove and the second groove forming a variable thickness in the cover layer along a dimension of the cover layer perpendicular to the first plane sufficient to define the first folding region, wherein the first groove further comprises: a first depth shallower than a second depth of the second groove; and a first width narrower than a second width of the second groove. However, Park discloses wherein a cover layer (100, fig. 12) comprises: a first groove on a top face of the cover layer along a first plane (120, fig. 8, see annotated fig. 12 below); and a second groove on a bottom face of the cover layer along the first plane (120, fig. 8, see annotated fig. 12 below), the first groove and the second groove forming a variable thickness in the cover layer along a dimension of the cover layer perpendicular to the first plane sufficient to define the first folding region (as disclosed in figs. 8 and 12), wherein the first groove further comprises: a first depth shallower than a second depth of the second groove (see annotated fig. 8 below); and a first width narrower than a second width of the second groove (see annotated fig. 8 below). PNG media_image3.png 215 609 media_image3.png Greyscale PNG media_image8.png 301 374 media_image8.png Greyscale PNG media_image6.png 301 374 media_image6.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filling date of the claimed invention to modify Choi’s cover layer with Parks teaching of a first and second groove as claimed, in order to enhance the strength and folding performance of the cover layer while also improving visibility (¶[0021]). Regarding claim 18, Choi in view of Park discloses the limitations of claim 17, and Park further discloses: wherein the cover layer further comprises: a first resin (130, see annotated fig. 12 below) deposited within the first groove, the first resin contiguous with the top face of the cover layer (fig. 12); and a second resin (130, see annotated fig. 12 below) deposited within the second groove, wherein the first groove and the second groove forming the variable thickness in the cover layer along the dimension of the cover layer perpendicular to the first plane define a thick region (see annotated fig. 12 below) and a thin region (see annotated fig. 12 below) in the cover layer, and wherein the variable thickness between the thick region and the thin region comprises a ratio of at least six-to-one (as disclosed upon examination of fig. 3, ¶[0040], ¶[0059]-[0061], ¶[0075]). PNG media_image4.png 215 609 media_image4.png Greyscale PNG media_image5.png 211 609 media_image5.png Greyscale Regarding claim 19, Choi in view of Park discloses the limitations of claim 17, and Park further discloses: wherein the second resin extends beyond the second groove to cover an entire surface of the bottom face of the cover layer (fig. 12, ¶[0105]-[0106]). Response to Arguments Applicant’s arguments with respect to claim 1 have been considered but are moot because the new ground of rejection does not rely on any combination of references applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. More specifically, not previously applied reference Choi2 for claim 1, teaches the limitation of “the second compliant material in contact with an underside of the display panel when the foldable electronic device is in a folded state to provide support for the display panel”, as presented in this office action for claim 1 above. Therefore, Choi in view of Choi2 teaches the limitations of claim 1. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to PETER KRIM whose telephone number is (703)756-1246. The examiner can normally be reached 8:00am -4:30pm. 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, Allen L Parker can be reached at (303) 297-4722. 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. /P.K./Examiner, Art Unit 2841 /SAGAR SHRESTHA/Primary Examiner, Art Unit 2841
Read full office action

Prosecution Timeline

Feb 06, 2024
Application Filed
Oct 10, 2025
Non-Final Rejection — §102, §103
Dec 23, 2025
Applicant Interview (Telephonic)
Dec 23, 2025
Examiner Interview Summary
Jan 07, 2026
Response Filed
Jan 27, 2026
Final Rejection — §102, §103 (current)

Precedent Cases

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Prosecution Projections

3-4
Expected OA Rounds
83%
Grant Probability
84%
With Interview (+1.9%)
2y 6m
Median Time to Grant
Moderate
PTA Risk
Based on 92 resolved cases by this examiner. Grant probability derived from career allow rate.

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