DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application is being examined under the pre-AIA first to invent provisions.
Response to Arguments
Applicants' arguments filed March 18, 2026, have been fully considered but they are not persuasive.
In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). Singh discloses the foreign object threshold is reference power value (par 46, 51-52). Sogabe is relied upon for its teaching of storing foreign object detection thresholds in the receiver and then communicating them to the transmitter. It is not necessary for Sogabe to also teach the exact same reference power value as already disclosed by Singh. This was noted in the Non-Final Rejection (12/18/25; see page 4, second full paragraph; page 7, last full paragraph). The Applicants’ response does not address or rebut this analysis.
The Applicants incorrectly state that “The Office Action’s combination relies on replacing Singh’s internally generated threshold with Sogabe’s wirelessly transmitted safety threshold” (Remarks, page 8). To the contrary, the combination relies on modifying Singh’s reference power value to be stored in the receiver, instead of the transmitter. Singh’s reference power value is not “replaced”.
Singh discloses the reference power value. Singh is modified by Sogabe to have this reference power value (not the safety threshold) be stored in the receiver and sent to the transmitter. Sogabe also discloses the receiver sends its unique ID (fig 12; par 104-109). The receiver sends a negotiation frame that includes, at least, a unique ID (par 107, “coil ID") and a foreign object threshold (see fig 12C; par 108).
The Applicants’ contention that Singh “teaches away” from the combination is not persuasive (Remarks, page 9). The Singh sentence quoted by the Applicants includes the phrase “may be performed”. This is an option – not a mandate that prevents all communications. The combination of references can also be interpretated as duplicating the reference power value – i.e. keeping the Singh internal reference power value and adding a second one to the receiver (as taught by Sogabe). The art rejection is updated to include both types of modification.
The Examiner also notes that if the Applicants’ remarks were persuasive, and Singh would not be able to communicate with a block/attenuated receiver to access the reference power value, then the same would apply to the Applicants’ transmitter. The Applicants’ foreign object detection would fail under the same conditions.
The contention that the modification would “completely destroy Singh’s principle of operation and render Singh unsuitable for its intended purpose” is also not persuasive (Id). The Singh principle of operation is foreign object detection – not storing its own threshold power value or detection “precisely” when communication is blocked or attenuated. Singh, under its “Field” heading, states, “Embodiments of the present disclosure relate generally to inductive power transfer, and, more particularly … to detecting a foreign object that is present during inductive wireless power transfer.” (par 2, emphasis added). The underlined demonstrates that Singh’s principle of operation is not foreign object detection “in the absence of communication with the wireless power receiver”, as alleged.
The claims are directed to the transmitter only and do not require the receiver. Apparatus claims 1 and 14 are directed to the control unit structure to receive a packet – Singh clearly has this, even if communication is blocked or unsuccessful sometimes. Method claim 8 recites the act of receiving a packet (which hints at successful communication). The Examiner notes that the Singh/Sogabe combination is operable to successfully communicate the reference power value at least once. The blockage/attenuation does not always exist – it is merely a possibility or hypothetical. Also, there is no requirement in the claim of 100% success rate of packet reception.
Furthermore, for at least the apparatus claims, the specific information within the received packets does not further limit the structure of the transmitter or its control unit. The claim scope is limited to that the control unit is “configured to receive” information. The name of the source (a receiver) is not further limiting – no modifications are required to be made of the control circuit to receive information from a wireless power receiver, as opposed to from some other data transmitter. No updates/modifications are needed to have the control unit receive more or different information items. Therefore, the limitations of a unique ID and a specific reference power value do not further limit the claimed apparatus. This interpretation was previously presented to the Applicants (Non-Final, page 4, penultimate paragraph) and has not been addressed or rebutted.
The same interpretation applies to how the reference power value is created (through experimentation; see Non-Final page 2, last paragraph; page 3, first paragraph) and that the reference power value is “specific” to the receiver (the receiver doesn’t exist within the context of apparatus claims 1/14 – at best, there is one receiver required to execute the method of claim 8; with one receiver, there is nothing to which to compare it to be “specific”).
The Applicants do not separately argue against the art rejections of the dependent claims. The art rejection is maintained.
Claim Rejections - 35 USC § 103
The following is a quotation of pre-AIA 35 U.S.C. 103(a) which forms the basis for all obviousness rejections set forth in this Office action:
(a) A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 1, 3-8, 10-16 and 18-20 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Singh (US 2013/0257168) in view of Sogabe (US 2010/0244579).
With respect to claim 1, Singh discloses a wireless power transmitting apparatus (fig 1-4; all text), comprising:
a primary coil (114);
an electric driving unit (230) coupled to the primary coil; and
a control unit (rest of 110) configured to:
receive configuration information including a reference power value (par 51, lines 8-18) indicating an expected amount of power at the primary coil if there is no foreign object present (par 46, 52) after completion of an initial setting of the wireless power receiving apparatus (par 52 – the foreign object reference and detection are to be based on a time after the transmitter/receiver have been paired through a ping/response process [i.e. an initial setting]);
cause the electric driving unit to generate an AC signal (par 51, lines 1-8 – since Singh actually measures the power, it is obviously “caused” to be generated/emitted) after completion of the initial setting (the power transfer comes after the ping & response, as is well known in the art);
measure an initial transmission power produced by the AC signal at the primary coil (step 310; par 51, lines 1-8), and
detect a foreign object based on the initial transmission power being larger than the reference value (step 320, step 435; par 53, 55-56).
Singh discloses an initial setting of detecting a receiver through a ping and response (par 52). Once this is completed, the Singh transmitter uses a stored configuration information (including a reference power value) and real-time sensed power at the primary coil to determine if a foreign object is present. Paragraphs 46 and 52 disclose how the Singh reference power value is “indicating” an expected power amount at the primary coil. The use of “indicating” here is broad and refers to information that can be inferred from the value – not the actual properties of the value itself.
As previously discussed (see Non-Final 5/28/25, bottom of page 9), the “initial setting” is not defined – the claim only broadly recites that the foreign objection detection procedure/packet functions happen “after” it. It is unclear what “initial settings” the Applicants intend to include within the scope of the claim – as none are listed. These initial settings can be interpreted as any steps that come before Singh 435 and Sogabe S4 in their flowcharts. This includes the ping and response detailed in paragraph 52. No clarification or amendments have been forthcoming to address the ambiguity of this language. The lack of any rebuttal indicates that the Examiner’s interpretation is correct; thus, it will continue to be used in the art limitation analysis.
Singh does not expressly disclose obtaining the configuration information from a receiver, obtaining a unique ID from the receiver, or that the reference power value is specific. Sogabe discloses a wireless power transmitter (fig 9, 12, 15), comprising a control unit configured to receive (in fig 15, step S4), from a wireless power receiving apparatus,
an identification packet (fig 12A, “matching code”) indicating a unique ID of the receiver (the matching code includes the items shown in figure 12B, which include the “coil code” see par 17) and
configuration information for foreign object detection (fig 12A, “hardware information code”; par 108-109) that is specific to the receiver (par 109).
Sogabe teaches a transmitter control unit that is configured to receive configuration and identification information from a receiver. This information includes foreign object data that is “specific” to the receiver as well as a unique receiver ID.
Singh already discloses that the foreign object detection information is a reference power value for expected amount of power at the primary coil. Thus, the combination only relies on Sogabe’s teaching of storing a foreign objection detection threshold in its memory and sending it to the transmitter (the combination does not rely on the specifics of the Sogabe “safety” threshold.
Singh and Sogabe are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with foreign object detection thresholds. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify Singh to have the configuration to receive foreign objection detection information and identification information from the receiver, as taught by Sogabe. The motivation for doing so would have been the application of a known technique to a known device ready for improvement to yield predictable results. MPEP §2143(D). This modification could replace Singh’s internally stored foreign object threshold or could supplement it (by adding a second one).
Singh discloses a “base” device with the power threshold value stored in memory. The claimed invention can be seen as an “improvement” on Singh by having the threshold value (also or instead) be stored in the receiver. The prior art contained this technique that is applicable to the base device (because they are both wireless power transmitters). The person of ordinary skill in the art would have recognized that applying the known technique (Sogabe’s sending the configuration information) would have yielded predictable results and improved the Singh system. The skilled artisan, viewing the prior art, would have understood that the threshold can be kept in the transmitter or kept in the receiver (and transmitted to the transmitter when required) – both produce the same result of letting the transmitter compare its initial power value to Singh’s threshold (discussed throughout par 46, 51-52).
In other words, Singh already discloses the necessary configuration information. The combination of references modifies how Singh retrieves the information – the combination does not change the information to be the Sogabe safety threshold.
While Singh may disclose an internally stored threshold can be used if communication to the receiver is blocked or attenuated, this is only one hypothetical and not every occurrence. Singh is expected to successfully communicate with its receiver and, therefore, Singh does not teach away or is inoperable because the foreign object detection threshold is also present in the receiver.
With respect to claim 3, Singh discloses the reference power value is defined as a value having been experimentally measured under controlled conditions of the wireless power receiving apparatus when no foreign object is present (par 46, 52 details the process of creating the threshold – these are all evidence of some “experimentation”, as opposed to randomly setting the threshold to a value that could be inaccurate for its intended purpose of distinguishing between the presence/absence of a foreign object) after completion of the initial setting of the wireless power receiving apparatus (par 51 defines the timing of the foreign object detection as being after the initial setting – i.e. the ping/response).
The Singh threshold is the result of “experimentation” (par 46, 52) to distinguish between the presence/absence of a foreign object. This includes the possibility of adding a “margin of error”, using real-time measured power values or dynamically adjusting the threshold. These are all evidence of “experimentation” – designing the threshold to be a specific value for a specific purpose. As discussed above, there is no requirement in the claim that there is unique value for different receivers. The claim is directed to the one transmitter. The claim scope does not include a plurality of receivers with different thresholds. That the combination teaches the interaction with one receiver (to get an ID and power reference value) is sufficient to teach the claimed limitations.
With respect to claim 4, Singh discloses the control unit performs at least one of:
refrain from entering a power transfer phase based on detection of the foreign object (par 53, “message or other notification”); or
operate in an emergency mode after detecting the foreign object (par 53, “reducing the power”).
With respect to claim 5, Sogabe discloses the control unit is further configured to: determine that an initial voltage of an output terminal (not claimed) of the wireless power receiving apparatus (not claimed) connected to an external load (not claimed) is at a steady state within a range of a reference voltage before measuring the initial transmission power (fig 5, step S4; par 164).
The receiver is not claimed – neither are its output terminal, load connection or any manner by which it can sense its voltage. Claim 5 does not require that the transmitter carry out any comparison of the output terminal voltage to a range of reference voltages. Claim 6 clearly recites that the transmitter’s determination is accomplished “by receiving [] a foreign object state packet”. Thus, any output terminal voltage measurement and analysis are carried out within an unclaimed receiver (meaning it not further limiting to the structure of the transmitter) – the transmitter assumes/infers that this has been done when it receives the packet.
Sogabe S4 teaches the reception of a “foreign object state packet” (because it includes the reference power value and because foreign object detection can only occur after S4). Since the combination teaches the narrow feature of the reception of this foreign state packet (claim 6), it also teaches the broader determination of claim 5.
With respect to claim 6, Sogabe discloses the control unit determines that the initial voltage is within the range of the reference voltage by receiving from the wireless power receiving apparatus a foreign object state packet indicating a start of a foreign object detection procedure (S4; see analysis above).
With respect to claim 7, Sogabe discloses the control unit is configured to start a foreign object detection procedure (S6) after determining that the initial voltage is within the range of the reference voltage (S4). As noted above, the transmitter does not actually make any initial voltage determination (comparison, analysis, etc.). claim 6 defines the determination as being satisfied when a foreign object packet is received. Sogabe discloses that receiving the foreign object packet precedes the foreign object detection procedure.
With respect to claims 8 and 10-13, Singh and Sogabe combine to disclose the apparatus necessary to complete the recited method steps, and the references are analogous, as discussed above in the art rejections of claims 1 and 3-6, respectively.
The properties of the receiver (its unique ID, its specific foreign object threshold) do not further limit the method carried out in the transmitter. The method would be carried out successfully regardless of whether all IDs/thresholds were the same or varied from receiver to receiver. The transmitter doesn’t keep a tally of which ID/threshold it has already used – it simply applies them to its foreign object detection. Alternatively, it is possible to interpret the successful execution of the method steps as requiring the presence of a receiver. Even so, this results in one receiver. With only one receiver, there are no other receivers to compare it to in order to establish what is “unique” or “specific” about it.
With respect to claim 14, Singh and Sogabe combine to disclose the wireless power transmitting apparatus, and the references are analogous, as discussed above in the art rejections of claims 1 and 4.
With respect to claim 15, Singh discloses the initial voltage (it is part of a ping, fig 4, step 420) is lower than a power transmission voltage for a transfer of wireless power to a wireless power receiving apparatus (step 440; par 36, 54). It would be obvious to the skilled artisan that a ping voltage is less than the voltage used for wireless power transmission to operate/charge a receiver.
With respect to claim 16, Singh discloses the control unit is configured to determine that the foreign object is not present if the first value is less than or equal to the reference power value (step 455; par 55-56).
With respect to claim 18, Singh discloses the control unit is configured to:
perform a digital ping via the primary coil during a ping phase (step 420 – Singh doesn’t state the type of ping – the skilled artisan would have understood it to be either analog or digital – both are equally plausible), and
receive the configuration information from the wireless power receiving apparatus (step 435) after the ping phase and before the power transfer phase (step 440).
Sogabe teaches the reference power value is obtained before the foreign object detection process (see Sogabe fig 15, steps S4 and S6). In Singh, this corresponds to receiving the reference power value at step 435 (which is the only data reception step prior to carrying out the foreign object detection procedure at steps 450 and 455).
With respect to claim 19, Singh (as modified by Sogabe) discloses the control unit is configured to: receive a foreign object detection status packet (Sogabe packet at S4 would correspond to Singh step 435) from the wireless power receiving apparatus, wherein the foreign object detection status packet is associated with initiating a foreign object detection procedure after the initial setting is completed (whatever steps occur prior to this Singh/Sogabe step).
With respect to claim 20, Singh discloses the experimental measurement, as discussed above in the art rejection of claim 3.
Conclusion
THIS ACTION IS MADE FINAL. 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 ADI AMRANY whose telephone number is (571)272-0415. The examiner can normally be reached Monday - Friday, 8am-7pm.
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, Rex Barnie can be reached at 5712722800 x36. 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.
/ADI AMRANY/Primary Examiner, Art Unit 2836
