Prosecution Insights
Last updated: May 29, 2026
Application No. 18/487,413

Closed-Loop Thermal Management System

Final Rejection §103
Filed
Oct 16, 2023
Examiner
KIM, CRAIG SANG
Art Unit
3741
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
General Electric Company
OA Round
3 (Final)
86%
Grant Probability
Favorable
4-5
OA Rounds
4m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 86% — above average
86%
Career Allowance Rate
671 granted / 779 resolved
+16.1% vs TC avg
Moderate +10% lift
Without
With
+10.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
19 currently pending
Career history
806
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
68.2%
+28.2% vs TC avg
§102
18.5%
-21.5% vs TC avg
§112
8.8%
-31.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 779 resolved cases

Office Action

§103
DETAILED ACTION This is a non-final rejection in response to RCE filed 4/2/26. Claims 1-20 are currently pending. Response to Arguments Applicant’s arguments with respect to claim(s) 1-20 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. 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. 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) 1-6, 11-13 and 19-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Moriyama (WO2021/117105) in view of Manning et al. (US 5233842) and further in view of Hodes et al. (WO2009/154663). Regarding independent claim 1 and 19, Moriyama teaches a closed-loop thermal management system, comprising: a thermal transport bus 100 including a plurality of fluid conduits configured to circulate a thermal working fluid therethrough; an accumulator 83 including a shell defining a multiphase fluid volume therein configured to contain a multiphase fluid, the shell defining an opening, wherein the accumulator is fluidly coupled to the thermal transport bus in a closed-loop fluid circuit [0023-0024]; and a temperature regulator 2. It should be noted the invention of Moriyama is directed towards a thermal management system for an aircraft [0150]. Moriyama is silent to the temperature regulator disposed along the accumulator. Manning teaches it was known to have a temperature regulator disposed along the accumulator (as seen in figures 1 and 2). It is noted that the use of a known prior art structure (in this case the use of a temperature regulator disposed along the accumulator as taught by Manning), to obtain predictable results (in this case to ensure precise control of heating and cooling of the fluid within the accumulator) was an obvious extension of prior art teachings, KSR; MPEP 2141 III A. Moriyama teaches the temperature regulator (Peltier element) thermally coupled to the accumulator/refrigerant line and thus configured to provide heating to the multiphase fluid inside the multiphase fluid volume [0026-0028]. However, Moriyama in view of Manning is silent to the temperature regulator being configured to provide heating and provide cooling to the multiphase fluid inside the multiphase fluid volume. Hodes teaches bidirectional heating and cooling with thermoelectric modules is known to provide both heating and cooling by reversing electric polarity (pg. 10, line 29 – pg. 11, line 12). It would have been obvious to one of ordinary skill in the art at the time of filing to further modify Moriyama in view of Manning with heating and cooling with the temperature regulator, as taught by Hodes. Hodes teaches increased efficiency of the TEM in temperature control, and power generation applications (pg. 5, ll.15-23). Regarding dependent claim 2, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Moriyama further teaches wherein the thermal working fluid comprises the multiphase fluid [0023-0024]. Regarding dependent claim 3 and 20, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Moriyama further teaches further comprising a heat source heat exchanger 5 in thermal communication with the thermal working fluid. Regarding dependent claim 4, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Moriyama further teaches further comprising a heat sink heat exchanger 51,52 in thermal communication with the thermal working fluid. Regarding dependent claim 5, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Moriyama further teaches wherein the multiphase fluid includes a liquid portion in a saturated liquid state and a gas portion in a saturated vapor state within the multiphase fluid volume [0023-0024]. Regarding dependent claim 6, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Moriyama further teaches further comprising a pump 3 having an inlet and an outlet fluidly coupled to the thermal transport bus, wherein the closed-loop fluid circuit includes the thermal transport bus, the pump, and the accumulator. Regarding dependent claim 11, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Manning teaches wherein the shell of the accumulator comprises a wall defining an inner wall surface and an outer wall surface, wherein the temperature regulator comprises at least one electric resistance heater 64 disposed along at least one of the outer wall surface and the inner wall surface. Regarding dependent claim 12-13, Moriyama in view of Manning and further in view of Hodes teaches the invention as claimed and discussed above. Moriyama further teaches wherein the shell of the accumulator comprises a wall defining an outer wall surface, wherein the temperature regulator comprises a thermoelectric module in thermal contact with the outer wall surface and wherein thermoelectric module is in thermal contact with the thermal transport bus. [0020]. Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Moriyama in view of Manning and Hodes and further in view of Thayer (US 2017/0016782). Regarding dependent claim 14, Moriyama in view of Manning and Hodes teaches the invention as claimed and discussed above. Moriyama teaches wherein the shell of the accumulator comprises a wall defining an inner wall surface and an outer wall surface, but is silent to wherein the temperature regulator comprises a thermal fluid jacket at least partially disposed along the inner wall surface. Thayer teaches it was known to have an accumulator with an inner and outer shell and having a thermal fluid jacket disposed along the inner wall surface (see figure 2, annular space 48). It is noted that the use of a known prior art structure (in this case the use of a thermal fluid jacket as taught by Thayer), to obtain predictable results (in this case to improve insulation and efficiency) was an obvious extension of prior art teachings, KSR; MPEP 2141 III A. Allowable Subject Matter Claims 7-10 and 15-18 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. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to CRAIG SANG KIM whose telephone number is (571)270-1418. The examiner can normally be reached 7:00 AM - 3:00 PM. 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, Devon Kramer can be reached at 571-272-7118. 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. /CRAIG KIM/ Primary Examiner Art Unit 3741
Read full office action

Prosecution Timeline

Oct 16, 2023
Application Filed
Aug 14, 2025
Non-Final Rejection mailed — §103
Oct 30, 2025
Response Filed
Jan 21, 2026
Final Rejection mailed — §103
Apr 02, 2026
Request for Continued Examination
Apr 08, 2026
Response after Non-Final Action
Apr 27, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12623787
ENGINE ARRANGEMENT FOR AN AIRCRAFT, AND AIRCRAFT
1y 2m to grant Granted May 12, 2026
Patent 12607145
OPERATING A GAS TURBINE ENGINE
1y 4m to grant Granted Apr 21, 2026
Patent 12601296
GAS TURBINE ENGINE HAVING A HEAT EXCHANGER LOCATED IN AN ANNULAR DUCT
2y 2m to grant Granted Apr 14, 2026
Patent 12601297
GAS TURBINE ENGINE HAVING A HEAT EXCHANGER LOCATED IN AN ANNULAR DUCT
2y 2m to grant Granted Apr 14, 2026
Patent 12601313
SYSTEMS AND METHODS FOR ROCKET PROPULSION INCLUDING ROCKET MOTOR USING POWDER MONOPROPELLANT
1y 6m to grant Granted Apr 14, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

4-5
Expected OA Rounds
86%
Grant Probability
96%
With Interview (+10.0%)
3y 0m (~4m remaining)
Median Time to Grant
High
PTA Risk
Based on 779 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month