Office Action Predictor
Last updated: April 15, 2026
Application No. 18/473,795

SYSTEMS AND METHODS FOR THERMAL MANAGEMENT OF ELECTRONIC DEVICES

Non-Final OA §102§103
Filed
Sep 25, 2023
Examiner
JONES, GORDON A
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Microsoft Technology Licensing, LLC
OA Round
1 (Non-Final)
60%
Grant Probability
Moderate
1-2
OA Rounds
3y 3m
To Grant
87%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allow Rate
331 granted / 548 resolved
-9.6% vs TC avg
Strong +27% interview lift
Without
With
+27.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
65 currently pending
Career history
613
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
50.2%
+10.2% vs TC avg
§102
22.0%
-18.0% vs TC avg
§112
27.2%
-12.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 548 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 . Election/Restrictions Claims 12 and 14-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected Group/Species, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 7/21/2025. Applicant’s election without traverse of Group I/Species A in the reply filed on 7/21/2025 is acknowledged. 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) 1-7, 10-11, 13 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Hisano et al. US 5,198,889. Re claim 1, Hisano et al. teach a thermal management device, comprising: a heat sink body (fig 29) defining a fluid reservoir (81); a working fluid in the fluid reservoir (60); and a movable contact surface (81a, 82) configured to transfer heat from a heat-generating component (1) to the working fluid, wherein at least a portion of the movable contact surface is movable relative to the heat sink body (col 17). Re claim 2, Hisano et al. teach wherein the movable contact surface includes a plurality of contact surface segments (fig 27). Re claim 3, Hisano et al. teach wherein at least one contact surface segment of the plurality of contact surface segments is connected to the heat sink body by a flexible support element (“bellows” see the rejection of claim 1). Re claim 4, Hisano et al. teach wherein the flexible support element is a bellows having a plurality of convolutions (see the rejection of claims 1 and 3). Re claim 5, Hisano et al. teach wherein the flexible support element allows rotation of the at least one contact surface segment relative to the heat sink body (col 17). Re claim 6, Hisano et al. teach wherein at least one contact surface segment of the plurality of contact surface segments includes a flexible contact surface (see the rejection of claims 1 , 3, 5, col 17). Re claim 7, Hisano et al. teach wherein the movable contact surface includes a flexible contact surface (see the rejection of claims 1 , 3, 5, col 17). Re claim 10, Hisano et al. teach further comprising a headspace in the fluid reservoir with a compressible gas positioned therein (fig 29, not air is compressible). Re claim 11, Hisano et al. teach further comprising at least one heat exhaustion feature (83) coupled to the heat sink body. Re claim 13, Hisano et al. teach wherein at least a portion of the heat sink body is elastically deformable to change a volume of the fluid reservoir (see the rejection of claims 1 , 3, 5, 7, col 17). 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. Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hisano et al. in view of US 10398061 B1. Re claim 8, Hisano et al. fail to explicitly teach material details. Ross teach the flexible contact surface includes an elastically deformable polymer to create a flexible bellows out of a known material (col 26 lines 45-50). It would have been obvious to one of ordinary skill in the art at the time the invention was made to include materials as taught by Ross in the Hisano et al. invention in order to advantageously allow for flexibility . Additionally, it would have been obvious to one having ordinary skill in the art at the time the invention was made to form the flexible contact surface includes an elastically deformable polymer for flexibility, since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as matter of obvious design choice. See MPEP 2144.07. Claim(s) 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hisano et al. in view of Kessler US 20230018694 A1. Re claim 9, Hisano et al. fail to explicitly teach material details. Kessler teach wherein the flexible contact surface includes an elastically deformable metal to construct a bellows from metal (para 101). It would have been obvious to one of ordinary skill in the art at the time the invention was made to include materials as taught by Kessler in the Hisano et al. invention in order to advantageously allow for increased heat transfer and strength . Additionally, it would have been obvious to one having ordinary skill in the art at the time the invention was made to form wherein the flexible contact surface includes an elastically deformable metal for increased heat transfer and strength, since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as matter of obvious design choice. See MPEP 2144.07. Claim(s) 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hisano et al. in view of SATOUS 20200211925 A1. Re claim 9, Hisano et al. fail to explicitly teach material details. SATOteach wherein the flexible contact surface includes an elastically deformable metal to construct a bellows from metal (para 55-57). It would have been obvious to one of ordinary skill in the art at the time the invention was made to include materials as taught by SATO in the Hisano et al. invention in order to advantageously allow for increased heat transfer and strength . Additionally, it would have been obvious to one having ordinary skill in the art at the time the invention was made to form wherein the flexible contact surface includes an elastically deformable metal for increased heat transfer and strength, since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as matter of obvious design choice. See MPEP 2144.07. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 12,104,856, US 4,138,692, US 10,660,236, US 6,269,866. Any inquiry concerning this communication or earlier communications from the examiner should be directed to GORDON A JONES whose telephone number is (571)270-1218. The examiner can normally be reached 7:30-5 M-F PST. 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. /GORDON A JONES/Examiner, Art Unit 3763
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Prosecution Timeline

Sep 25, 2023
Application Filed
Aug 10, 2025
Non-Final Rejection — §102, §103
Apr 13, 2026
Response after Non-Final Action

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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
60%
Grant Probability
87%
With Interview (+27.0%)
3y 3m
Median Time to Grant
Low
PTA Risk
Based on 548 resolved cases by this examiner. Grant probability derived from career allow rate.

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