Prosecution Insights
Last updated: April 19, 2026
Application No. 18/510,602

HEAT TRANSFER DEVICES FOR ENHANCED THERMAL PERFORMANCE OF ELECTRONIC SYSTEMS

Non-Final OA §103§112
Filed
Nov 15, 2023
Examiner
HOFFBERG, ROBERT JOSEPH
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Micron Technology, Inc.
OA Round
3 (Non-Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
2y 3m
To Grant
95%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
656 granted / 908 resolved
+4.2% vs TC avg
Strong +23% interview lift
Without
With
+23.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
38 currently pending
Career history
946
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
38.0%
-2.0% vs TC avg
§102
26.2%
-13.8% vs TC avg
§112
30.5%
-9.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 908 resolved cases

Office Action

§103 §112
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 . 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 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. Response to Arguments Applicant included a “Summary of Examiner Interview” with a prompt to include a date, but without a date that the Interview was supposedly held (Applicant’s remarks dated 2/25/26. pp. 8-9). The Examiner has no recollection of an interview actually being conducted. Applicant's arguments filed 2/25/26 have been fully considered but they are not persuasive. Applicant argues Ma is directed to "a mobile display device" that includes "a heat dissipation unit which is also provided on the circuit board and is configured to dissipate heat from the chip." (Ma, Abstract). Ma teaches "a battery and a circuit board both provided within the housing, the battery being interposed between the circuit board and the housing, or alternatively, the battery and the circuit board being arranged side-by-side." (Id. at col. 1, lns. 62-65). Applicant respectfully submits that "a battery and a circuit board" are not the same as "a memory sub-system," as recited in claim 1. Accordingly, Applicant respectfully submits that Ma does not teach or suggest at least the bolded features of claim 1 as presented. (Applicant’s remarks dated 2/25/26. p. 10). Applicant has presented this identical quoted argument for both claim 12 on p. 10 and for claim 1 on p. 12. Applicant has not considered their broad definition of the term “memory sub-system” which Applicant has defined as “can include one or more memory devices that store data” (Spec para. [003]). Despite Applicant’s characterization that Ma has "a battery and a circuit board both provided within the housing, the battery being interposed between the circuit board and the housing, or alternatively, the battery and the circuit board being arranged side-by-side." Ma at col. 5, lines 25-26 discloses a “mobile display device may for example be mobile phone, laptop computer, or other mobile display device(s)” which invariably has a “memory sub-system” based upon Applicant’s own disclosure of what a “memory sub-system” is. Regarding claim 12, these devices would include a memory sub-system because each of these types of devices stores data, whether in a processor, a dedicated memory device or component that is required to store data as part of its operation capabilities. Applicant also defines “thermally coupled” as “may refer to a connection of two or more object[s] such that the two or more objects, in direct or indirect contact, can transmit thermal energy by thermal conduction, unless otherwise described (e.g., by thermal convection)” (see specification, ¶[0021, ll. 3-5)). Certainly thermal energy is either directly or indirectly coupled through Ma’s structure of its mobile display device. It is noted that the bolded features of claim 1 as argued for claim 1 are not claimed in claim 12. For claim 1, the rejection has been modified to now includes Eriksson (US 2008/0310108) to address the added limitation of “a singular heatsink coupled with the top portion of the enclosure.” The term “coupled” allows for either direct or indirect coupling. In this case as long as the singular heatsink is coupled to some portion of the enclosure, the singular heatsink will either directly to the top portion of the enclosure or indirectly through other portions of the enclosure to the top portion of the enclosure. Claim 1 provides a claimed definition of “a memory sub-system” as “comprising a circuit board comprising a plurality of heat-generating components.” Only claim 11 which is dependent on claim 1 provides “the first electrical component is a non-volatile memory device” which has anything to do with a memory device or a memory sub-system. Claim Interpretation The term “memory sub-system” is not being interpreted under 35 U.S.C. 112(f). However, the claims do not provide any limitations specifically address “memory” or “memory sub-system” with the exception of dependent claim 11 requiring “the first electrical component is a non-volatile memory device.” The claims in the instant application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art (see MPEP 2111). However, it is improper to import claim limitations from the specification (see MPEP 211.01 (II)). For claim 12, the Examiner understands based upon para. [003] of the specification that the term “memory sub-system can include one or more memory devices that store data.” For claim 1, the term “memory sub-system” is defined by the structure claimed. The requirement of claim 11 is consistent with this definition of the term “memory sub-system” because a “non-volatile memory device” is a memory device that stores data. Applicant has defined the term “’[t]hermal coupling’ may refer to a connection of two or more object[s] such that the two or more objects, in direct or indirect contact, can transmit thermal energy by thermal conduction, unless otherwise described (e.g., by thermal convection)” see specification, ¶[0021, ll. 3-5)). Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, “a heatsink with one or more fins” (claim 10) in combination with “a singular heatsink” (claim 1) must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Specification The disclosure is objected to because of the following informalities: para. [0021], line 3, “object” should be objects”. Appropriate correction is required. Claim Objections Claims 6-9 are objected to because of the following informalities: Claim 6, lines 3-4 and 5-7; Claim 8, line 3; and Claim 9, line 3, “the plurality of heat-generating components” should be “the first sub-plurality of heat-generating components”; and Claim 7, line 6, “the plurality of heat-generating components” should be “the first sub-plurality of heat-generating components”. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 10, 12-14, and 16-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. a. Claim 10, lines 1-2 requires “the top portion of the enclosure comprises a heatsink with one or more fins” and Claim 1, line 10 requires “a singular heatsink coupled with the top portion of the enclosure.” Currently claim 10 requires both “a singular heatsink” and “a heatsink with one or more fins.” The specification at para. [0047] discloses “a heatsink (not pictured) may couple to one or both of top enclosure 310 and/or bottom enclosure 350. In some embodiments, a heatsink may be integrated with one or both of top enclosure 310 and/or bottom enclosure 350.” This is understood by the Examiner as being a “singular heatsink” and “a heatsink with one or more fins” as being alternatives and not be used together. b. Claim 12, lines 2-3 requires “a first heat transfer device thermally coupled to a memory sub-system comprising a singular heatsink.” Based upon fig. 1, a memory sub-system 110 includes a heat transfer device 150. If the memory sub-system 110 includes a heat transfer device 150, how can heat transfer device 150, which is a portion of the memory sub-system 110 be coupled to itself as amended claim 12 requires? Further, based upon the disclosure, a heat sink is disclosed as being either attached to or integrated with the enclosure (see paras. [0047] and [0055]). Therefore, the originally filed application, does not disclose that either the memory sub-system 110 or the heat transfer device 150 includes a heat sink or a singular heat sink. See the different possible interpretations in the 35 U.S.C. 112b rejection below. The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 10, 12-14, and 16-20 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 10, lines 1-2 requires “the top portion of the enclosure comprises a heatsink with one or more fins” and Claim 1, line 10 requires “a singular heatsink coupled with the top portion of the enclosure.” Claim 10 appears to require both “a singular heatsink” and “a heatsink with one or more fins.” Are these both heatsinks required by claim 10? Claim 12, lines 2-3 requires “a first heat transfer device thermally coupled to a memory sub-system comprising a singular heatsink.” Which of the first heat transfer device or the memory sub-system comprises the singular heatsink? Based upon the rule of last antecedence, it appears that “a memory sub-system comprising a singular heatsink” is the correct interpretation. Is this correct? 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 of this title, 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 12, 16, 17, and 19, as best understood, are rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331). Alternate I With respect to Claim 12, Ma teaches an apparatus (fig. 1) comprising: a first heat transfer device (51) thermally coupled to a memory sub-system (col. 5, ll. 25-26, memory sub-system of mobile display device based upon the definition of “memory sub-system above) comprising a singular heatsink (4), the first heat transfer device comprising: an exterior surface (exterior facing surface of 51) comprising a first portion (outer top of 51), a second portion (outer bottom of 51), and a third portion (outer right side of 51) located between the first portion and the second portion, wherein the first portion faces (see fig. 1) opposite the second portion; and an interior surface (interior facing surface of 51) comprising a fourth portion (inner top of 51), a fifth portion (inner bottom of 51), and a sixth portion (inner right side of 51) located between the fourth portion and the fifth portion, wherein the fourth portion faces (see fig. 1) the fifth portion, wherein the first portion of the exterior surface is configured to thermally couple (thermally coupled to top of 1 thru right side of 51, col. 3, ll. 33-34) to a top portion (top portion of 1) of an enclosure (1) of a circuit board (2) comprising a plurality of heat-generating components (3 [col. 4, l. 37] and 2 [col. 1, 33-34]), wherein the second portion of the exterior surface is configured to thermally couple (see fig. 1) to a bottom portion (fig. 1, horizontal bottom portion of 1) of the enclosure, wherein the fourth portion of the interior surface is configured to thermally couple (thru 53) to a first electrical component (3) of the plurality of heat-generating components, the first electrical component mounted on a primary side (top of 6) of the circuit board and configured to generate first thermal energy (col. 4, l. 37), and wherein the fifth portion of the interior surface is configured to thermally couple (see fig. 1) to a second electrical component (2) of the plurality of heat-generating components, the second electrical component mounted on a secondary side (bottom of 6) of the circuit board and configured to generate second thermal energy (col. 1, 33-34), the first heat transfer device configured to distribute a first portion (1st portion of heat from 3) of the first thermal energy and a first portion (1st portion of heat from 2) of the second thermal energy to (transferred to top of 1 thru right side of 1) the top portion of the enclosure, and a second portion (2nd portion of heat from 3) of the first thermal energy and a second portion (2nd portion of heat from 2) of the second thermal energy to the bottom portion of the enclosure, wherein the first thermal energy is greater (3 is a chip that usually generates more heat than a battery) than the second thermal energy. Ma fails to specifically disclose a memory sub-system and the first thermal energy is greater than the second thermal energy and specifically a memory sub-system. Official Notice is taken that a memory sub-system is well-known in the art. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the appratus of Ma with a well-known memory sub-system for the purpose of providing storage capability for Ma’s mobile display device so that Ma’s mobile display device can perform ins intended purpose which requires storage of data within a processor, a dedicated memory device or component that is required to store data as part of its operation capabilities. It would be obvious to one of ordinary skill at the time of the invention, given the limited number of possibilities for relevant amount of thermal energies of the chip and battery of Ma and the limited number of permutations of thermal energies (greater than, equal to, or less than). The rationale to support a conclusion that the claim would have been obvious is that "a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense. In that instance the fact that a combination was obvious to try might show that it was obvious under § 103." KSR, 550 U.S. _at_, 82 USPQ2d 1385, at 1397 (2007). Official Notice is taken that a memory sub-system is well-known in With respect to Claim 16, Ma further teaches the first portion of the exterior surface that is configured to thermally couple (fig. 3, top of 51 thermally couples to top of 1 thru right side of 51) the top portion of the enclosure is configured to transfer the thermal energy and the second portion of the exterior surface that is configured to thermally couple (fig. 3, bottom of 51 against bottom horizontal portion of 1) to the bottom portion of the enclosure are configured to transfer thermal energy via thermal conduction. With respect to Claim 17, Ma discloses the claimed invention including the exterior surface of the first heat transfer device is a first exterior surface (outside surface of 51), wherein the interior surface of the first heat transfer device is a first interior surface (inside surface of 51). Ma fail to disclose a second heat transfer device and a third electrical component. Ma teaches the apparatus further comprising: a second heat transfer device (another 51), comprising: a second exterior surface (exterior surface of another 51) comprising a seventh portion (exterior top of another 51), an eighth portion (exterior bottom side of another 51), and a ninth portion (exterior right side of another 51) located between the seventh portion and the eighth portion, wherein the seventh portion faces (see fig. 1) opposite the eighth portion; and a second interior surface (inside of another 51) comprising a tenth portion (inside top of another 51), an eleventh portion (inside bottom of another 51), and a twelfth portion (inside right side of another 51) located between the tenth portion and the eleventh portion, wherein the tenth portion faces (see fig. 1) the eleventh portion, wherein the seventh portion of the second exterior surface is configured to thermally couple (transferred to top of 1 thru right side of 1) to the top portion of the enclosure, wherein the eighth portion of the second exterior surface is configured to thermally couple (see fig. 1) to the bottom portion of the enclosure, wherein the tenth portion of the second interior surface is configured to thermally couple to a third electrical component (another 3) of the plurality of heat-generating components, the third electrical component mounted on the primary side (top of 6) of the circuit board (6), and wherein the eleventh portion of the second interior surface is configured to face the secondary side (bottom of 6) of the circuit board, the second heat transfer device configured to distribute a portion of thermal energy (heat from another 3) generated from at least the third electrical component to the top portion (3,4 thru right side of 1 to top of 1) and the bottom portion (from 3 thru 51 to bottom horizontal portion of 51) of the enclosure (1). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first heat transfer device and first electrical component of Ma, so that an additional (i.e., third) electrical component can use the enclosure for thermal management of the additional electrical component, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. With respect to Claim 19, Ma further teaches the fourth portion of the interior surface is configured to extend over (see fig. 1) a top surface (top of 3) of the first electrical component of the plurality of heat-generating components, and wherein the fifth portion of the interior surface is asymmetric (see fig. 1) to the fourth portion about an axis (fig. 1, horizontal axis passing thru midpoint of vertical portion of 51) bisecting the sixth portion. Alternate II With respect to Claim 12, Ma’s fig. 3 teaches an apparatus (fig. 3) comprising: a first heat transfer device (51) thermally coupled to a memory sub-system (col. 5, ll. 25-26, memory sub-system of mobile display device based upon the definition of “memory sub-system above) comprising a singular heatsink (4), the first heat transfer device comprising: an exterior surface (exterior facing surface of 51) comprising a first portion (outer top of 51), a second portion (outer bottom of 51) , and a third portion (outer right side of 51) located between the first portion and the second portion, wherein the first portion faces (see fig. 3) opposite the second portion; and an interior surface (interior facing surface of 51) comprising a fourth portion (inner top of 51), a fifth portion (inner bottom of 51), and a sixth portion (inner right side of 51) located between the fourth portion and the fifth portion, wherein the fourth portion faces (see fig. 3) the fifth portion, an enclosure (1) of a circuit board (2) comprising a plurality of heat-generating components (3 [col. 4, l. 37], 53, 2 [col. 1, 33-34]), wherein the second portion of the exterior surface is configured to thermally couple (see fig. 3) to a bottom portion (fig. 3, horizontal bottom portion of 1) of the enclosure, wherein the fourth portion of the interior surface is configured to thermally couple (thru 53) to a first electrical component (3,53) of the plurality of heat-generating components, the first electrical component mounted on a primary side (top of 6) of the circuit board and configured to generate first thermal energy (col. 4, l. 37), and wherein the fifth portion of the interior surface is configured to thermally couple (see fig. 3) to a second electrical component (2) of the plurality of heat-generating components, the second electrical component mounted on a secondary side (bottom of 6) of the circuit board and configured to generate second thermal energy (col. 1, 33-34), wherein the first thermal energy is greater (3 is a chip that generates more heat than a battery) than the second thermal energy. Ma’s fig. 3 fails to disclose wherein the first portion of the exterior surface is configured to thermally couple to a top portion (top portion of 1) of an enclosure of a circuit board and the first heat transfer device configured to distribute a first portion of the first thermal energy and a first portion of the second thermal energy the top portion of the enclosure, and a second portion of the first thermal energy and a second portion of the second thermal energy to the bottom portion of the enclosure. Ma further fails to specifically disclose a memory sub-system and the first thermal energy is greater than the second thermal energy and specifically a memory sub-system. Ma’s fig. 6 teaches the first portion (top of 51) of the exterior surface is configured to thermally couple (see fig. 6) to a top portion (top portion of 1) of an enclosure (1) and the first heat transfer device configured to distribute a first portion (1st portion of heat from 3,53) of the first thermal energy and a first portion (1st portion of heat from 2) of the second thermal energy to (transferred to top of 1) the top portion of the enclosure. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the apparatus of Ma’s fig. 3 with that of Ma’s fig. 6 for the purpose of having to the top portion of the first heat transfer device touching the top portion of housing for increased transfer of thermal energy from the first heat transfer device to the top portion of housing. Ma fails to specifically disclose that the first thermal energy is greater than the second thermal energy. Official Notice is taken that a memory sub-system is well-known in the art. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the apparatus of Ma with a well-known memory sub-system for the purpose of providing storage capability for Ma’s mobile display device so that Ma’s mobile display device can perform ins intended purpose which requires storage of data within a processor, a dedicated memory device or component that is required to store data as part of its operation capabilities. It would be obvious to one of ordinary skill at the time of the invention, given the limited number of possibilities for relevant amount of thermal energies of the chip and battery of Ma and the limited number of permutations of thermal energies (greater than, equal to, or less than). The rationale to support a conclusion that the claim would have been obvious is that "a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense. In that instance the fact that a combination was obvious to try might show that it was obvious under § 103." KSR, 550 U.S. _at_, 82 USPQ2d 1385, at 1397 (2007). Claims 13 and 14, as best understood, are rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331) and Chen (US 11,477,915). With respect to Claim 13, Ma discloses the claimed invention except for a third electrical component. Chen teaches the fourth portion (fig. 4A, bottom of 442) of the interior surface (bottom of 442,bottom of 452) is configured to thermally couple to the first electrical component (440a) and at least a third electrical component (440b) of the plurality of heat-generating components (440a,450a,440b), the at least the third electrical component mounted on the primary side (432) of the circuit board (430, col. 7, l. 49). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first electrical component of Ma, so that the first heat transfer device can be used to simultaneously cool multiple electrical components, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. With respect to Claim 14, Ma discloses the claimed invention except for a third electrical component. Chen teaches the fifth portion (fig. 4A, top of 452) of the interior surface (bottom of 442,bottom of 452) is configured to thermally couple to the second electrical component (450a) and at least a third electrical component (450b) of the plurality of heat-generating components (440a,450a,450b), the at least the third electrical component mounted on the secondary side (434) of the circuit board (430, col. 7, l. 49). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first electrical component of Ma, so that the first heat transfer device can be used to simultaneously cool multiple electrical components, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Claim 18, as best understood, is rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331) and Han (US 7,468,887). Ma further teaches the fourth portion of the interior surface is configured to extend over (see fig. 1) a top surface (top of 3,4) of the first electrical component of the plurality of heat-generating components; and wherein the fifth portion of the interior surface is substantially asymmetric (see fig. 1) to the fourth portion about an axis (fig. 1, horizontal axis passing thru midpoint of vertical portion of 51) bisecting the sixth portion. Ma fails to disclose the fifth portion of the interior surface is substantially symmetric to the fourth portion about an axis bisecting the sixth portion. Han teaches the fifth portion (fig. 3, bottom surface of 19c) of the interior surface (fig. 3, inner surface of 19) is substantially symmetric (see fig. 3) to the fourth portion (fig. 3, top surface of 19a) about an axis (fig. 3, horizontal axis bisecting 19b) bisecting the sixth portion (19b). It would have been an obvious matter of choice for the legs of the first heat transfer device to be sized including of equal lengths to maximize the heat transfer between the first electrical component and the enclosure, since such a modification would have involved a mere change in the size of a component. A change in size is generally recognized as being within the level of ordinary skill in the art. In re Rose, 105 USPQ 237 (CCPA 1955). Claim 20, as best understood, is rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331) and Hayashida (US 9,430,006). Ma discloses the claimed invention including the first heat transfer device “may be formed by one or more of various specific materials, for example . . . a metallic thermally-conductive sheet” (col. 4, ll. 18-19). Ma fail to disclose the first heat transfer device comprises at least one of titanium or graphite. Hayashida teaches the first heat transfer device comprises graphite (col. 2, l. 58). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to for the first heat transfer device to be made of good thermally conductive such as graphite for increased heat transfer from the electrical components to the enclosure, 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 a matter of obvious design choice. In re Leshin, 125 USPQ 416. Claims 1-3, 6, 7, and 9-11 are rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331), Eriksson (US 2008/0310109) and Chen (US 11,477,915). Alternate I With respect to Claim 1, Ma teaches a system (fig. 1) comprising: a circuit board 6) comprising a plurality of heat-generating components (3 [col. 4, l. 37] and 2 [col. 1, 33-34]), wherein a first heat-generating component (3) is mounted to a primary side (top of 6) of the circuit board, and wherein a second heat-generating component is mounted to a secondary side (bottom of 6) opposite the primary side of the circuit board; an enclosure (1) comprising a top portion (top horizontal portion of 1) and a bottom portion (bottom horizontal portion of 1), the enclosure configured to enclose (see fig. 1) the circuit board; and a first heat transfer device (51), comprising: an exterior surface (exterior surface of 51) comprising a first portion (top exterior surface of 51), a second portion (bottom exterior surface of 51), and a third portion (right side exterior surface of 51) located between the first portion and the second portion, wherein the first portion faces opposite (see fig. 1) the second portion; and an interior surface (interior surface of 51) comprising a fourth portion (top interior surface of 51), a fifth portion (bottom interior surface of 51), and a sixth portion (right side interior surface of 51) located between the fourth portion and the fifth portion, wherein the fourth portion faces (see fig. 1) the fifth portion, wherein the first portion of the exterior surface is configured to thermally couple (thermally coupled to top of 1 thru right side of 51, col. 3, ll. 33-34) to the top portion of the enclosure, wherein the second portion of the exterior surface is configured to thermally couple (see fig. 1) to the bottom portion of the enclosure, wherein the fourth portion of the interior surface is configured to couple (see fig. 1) to a first electrical component (3), the first electrical component mounted (see fig. 1) on the primary side of the circuit board and configured to generate first thermal energy (col. 4, l. 37), and wherein the fifth portion of the interior surface is configured to couple to a second electrical component (6), the second electrical component mounted (see fig. 1) on the secondary side of the circuit board and configured to generate second thermal energy (col. 1, 33-34), the first heat transfer device configured to distribute a first portion (1st portion of heat from 3) of the first thermal energy and a first portion (1st portion of heat from 2) of the second thermal energy to the top portion of the enclosure, and a second portion (2nd portion of heat from 3) of the first thermal energy and a second portion (2nd portion of heat from 3) of the second thermal energy to the bottom portion of the enclosure, wherein the first thermal energy (3 is a chip that usually generates more heat than a battery) than the second thermal energy. Ma fails to a singular heatsink coupled with the top portion of the enclosure. Ma further fails to specifically disclose that the first thermal energy is greater than the second thermal energy, and a first sub-plurality of heat-generating components are mounted to a primary side of the circuit board, and wherein a second sub-plurality of heat-generating components are mounted to a secondary side opposite the primary side of the circuit board. It would be obvious to one of ordinary skill at the time of the invention, given the limited number of possibilities for relevant amount of thermal energies of the chip and battery of Ma and the limited number of permutations of thermal energies (greater than, equal to, or less than). The rationale to support a conclusion that the claim would have been obvious is that "a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense. In that instance the fact that a combination was obvious to try might show that it was obvious under § 103." KSR, 550 U.S. _at_, 82 USPQ2d 1385, at 1397 (2007). Chen teaches a first sub-plurality of heat-generating components (fig. 1, 440a,440b) are mounted to a primary side (432) of the circuit board (430, col. 7, l. 49), and wherein a second sub-plurality of heat-generating components (450a,450b) are mounted to a secondary side (434) opposite the primary side of the circuit board. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first electrical component of Ma, so that the first heat transfer device can be used to simultaneously cool multiple electrical components, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Eriksson teaches a singular heatsink (44) coupled with the top portion (fig. 1, back of 10) of the enclosure (10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the apparatus of Ma with the singular heat sink of Eriksson for the purpose of “improv[ing] performance and reliability of mobile phones, particularly during periods of excess heat generation” (¶[0006], ll. 1-2). With respect to Claim 2, Ma discloses the claimed invention except for at least a third electrical component. Chen teaches the fourth portion (fig. 4A, bottom of 442) of the interior surface (bottom of 442,bottom of 452) is configured to couple (thermally) to the first electrical component (440a) and at least a third electrical component (440b) of the plurality of heat-generating components (440a,450a,440b), the at least the third electrical component mounted on the primary side (432) of the circuit board (430, col. 7, l. 49). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first electrical component of Ma, so that the first heat transfer device can be used to simultaneously cool multiple electrical components, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. With respect to Claim 3, Ma discloses the claimed invention except for at least a third electrical component. Chen teaches the fifth portion (fig. 4A, top of 452) of the interior surface (bottom of 442,bottom of 452) is configured to couple (thermally) to the second electrical component (450a) and at least a third electrical component (450b) of the plurality of heat-generating components (440a,450a,450b), the at least the third electrical component mounted on the secondary side (434) of the circuit board (430, col. 7, l. 49). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first electrical component of Ma, so that the first heat transfer device can be used to simultaneously cool multiple electrical components, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. With respect to claim 6, Ma’s fig. 1 further teaches a second thermal pad (4) located between the interior surface of the first heat transfer device (51) and a top surface (top of 3) of at least the first electrical component (3) of the plurality of heat-generating components, and configured to thermally couple (see fig. 1) the interior surface of the first heat transfer device and the top surface of the first electrical component of the plurality of heat-generating components. With respect to Claim 7, Ma’s fig. 1 discloses the claimed invention including the exterior surface of the first heat transfer device is a first exterior surface (outside surface of 51), wherein the interior surface of the first heat transfer device is a first interior surface (inside surface of 51). Ma fail to disclose a second heat transfer device and a third electrical component. Ma teaches the system further comprising: a second heat transfer device (another 51), comprising: a second exterior surface (exterior surface of another 51) comprising a seventh portion (exterior top of another 51), an eighth portion (exterior bottom side of another 51), and a ninth portion (exterior right side of another 51) located between the seventh portion and the eighth portion, wherein the seventh portion faces (see fig. 1) opposite the eighth portion; and a second interior surface (inside of another 51) comprising a tenth portion (inside top of another 51), an eleventh portion (inside bottom of another 51), and a twelfth portion (inside right side of another 51) located between the tenth portion and the eleventh portion, wherein the tenth portion faces (see fig. 1) the eleventh portion, wherein the seventh portion of the second exterior surface is configured to thermally couple (transferred to top of 1 thru right side of 1) to the top portion of the enclosure, wherein the eighth portion of the second exterior surface is configured to thermally couple (see fig. 1) to the bottom portion of the enclosure, wherein the tenth portion of the second interior surface is configured to thermally couple to a third electrical component (another 3) of the plurality of heat-generating components, the third electrical component mounted on the primary side (top of 6) of the circuit board (6), and wherein the eleventh portion of the second interior surface is configured to face the secondary side (bottom of 6) of the circuit board, the second heat transfer device configured to distribute a portion of thermal energy (heat from another 3) generated from at least the third electrical component to the top portion (3 thru right side of 1 to top of 1) and the bottom portion (from 3,4 thru 51 to bottom horizontal portion of 51) of the enclosure (1). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first heat transfer device and first electrical component of Ma, so that an additional (i.e., third) electrical component can use the enclosure for thermal management of the additional electrical component, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. With respect to Claim 9, Ma’s fig. 1 further teaches the fourth portion of the interior surface is configured to extend over (see fig. 1) a top surface (top of 3) of the first electrical component of the plurality of heat-generating components, and wherein the fifth portion of the interior surface is asymmetric (see fig. 1) to the fourth portion about an axis (fig. 1, horizontal axis passing thru midpoint of vertical portion of 51) bisecting the sixth portion. With respect to Claim 10, Ma’s fig. 1 discloses the claimed invention including the top portion (fig. 1, top of 1). Ma fails to disclose the top portion (fig. 4A, 412) of the enclosure comprises a heatsink (412 is a heat sink) with one or more fins (460). of the enclosure except for the top portion (fig. 1, 200) of the enclosure comprises a heatsink with one or more fins. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Ma with the heat sink of Chen for the purpose of increasing the surface area for greater heat transfer to the surrounding environment. With respect to Claim 11, Ma and Chen disclose the claimed invention except for the first electrical component is a non-volatile memory device. It would have been an obvious matter of choice to for the first electrical component to be any type of electrical component including a non-volatile memory device that is needed by the system to perform its intended function, since applicant has not disclosed that the non-volatile memory device solves any stated problem or is for any particular purpose and it appears that the invention would perform equally well with any type of electrical component that requires thermal management. Alternate II With respect to Claim 1, Ma teaches a system (fig. 3) comprising: a circuit board 6) comprising a plurality of heat-generating components (3 [col. 4, l. 37] and 2 [col. 1, 33-34]), wherein a first heat-generating component (3) are mounted to a primary side (top of 6) of the circuit board, and wherein a second heat-generating component mounted to a secondary side (bottom of 6) opposite the primary side of the circuit board; an enclosure (1) comprising a top portion (top horizontal portion of 1) and a bottom portion (bottom horizontal portion of 1), the enclosure configured to enclose (see fig. 3) the circuit board; and a first heat transfer device (51), comprising: an exterior surface (exterior surface of 51) comprising a first portion (top exterior surface of 51), a second portion (bottom exterior surface of 51), and a third portion (right side exterior surface of 51) located between the first portion and the second portion, wherein the first portion faces opposite (see fig. 3) the second portion; and an interior surface (interior surface of 51) comprising a fourth portion (top interior surface of 51), a fifth portion (bottom interior surface of 51), and a sixth portion (right side interior surface of 51) located between the fourth portion and the fifth portion, wherein the fourth portion faces (see fig. 3) the fifth portion, wherein the second portion of the exterior surface is configured to thermally couple (see fig. 3) to the bottom portion of the enclosure, wherein the fourth portion of the interior surface is configured to couple (see fig. 3) to a first electrical component (3), the first electrical component mounted (see fig. 3) on the primary side of the circuit board and configured to generate first thermal energy (col. 4, l. 37), and wherein the fifth portion of the interior surface is configured to couple to a second electrical component (6), the second electrical component mounted (see fig. 3) on the secondary side of the circuit board and configured to generate second thermal energy (col. 1, 33-34), the first heat transfer device configured to distribute a first portion (1st portion of heat from 3) of the first thermal energy and a first portion (1st portion of heat from 2) of the second thermal energy to the top portion of the enclosure, and a second portion (2nd portion of heat from 3) of the first thermal energy and a second portion (2nd portion of heat from 3) of the second thermal energy to the bottom portion of the enclosure, wherein the first thermal energy (3 is a chip that usually generates more heat than a battery) than the second thermal energy. Ma’s fig. 3 fails to disclose wherein the first portion of the exterior surface is configured to thermally couple to a top portion (top portion of 1) of an enclosure of a circuit board and the first heat transfer device configured to distribute a first portion of the first thermal energy and a first portion of the second thermal energy the top portion of the enclosure, and a second portion of the first thermal energy and a second portion of the second thermal energy to the bottom portion of the enclosure. Ma’s fig. 6 teaches the first portion (top of 51) of the exterior surface is configured to thermally couple (see fig. 6) to a top portion (top portion of 1) of an enclosure (1) and the first heat transfer device configured to distribute a first portion (1st portion of heat from 3) of the first thermal energy and a first portion (1st portion of heat from 2) of the second thermal energy to (transferred to top of 1) the top portion of the enclosure. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the apparatus of Ma’s fig. 3 with that of Ma’s fig. 6 for the purpose of having to the top portion of the first heat transfer device touching the top portion of housing for increased transfer of thermal energy from the first heat transfer device to the top portion of housing. Ma fails to a singular heatsink coupled with the top portion of the enclosure. Ma fails to specifically disclose that the first thermal energy is greater than the second thermal energy, and a first sub-plurality of heat-generating components are mounted to a primary side of the circuit board, and wherein a second sub-plurality of heat-generating components are mounted to a secondary side opposite the primary side of the circuit board.. It would be obvious to one of ordinary skill at the time of the invention, given the limited number of possibilities for relevant amount of thermal energies of the chip and battery of Ma and the limited number of permutations of thermal energies (greater than, equal to, or less than). The rationale to support a conclusion that the claim would have been obvious is that "a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense. In that instance the fact that a combination was obvious to try might show that it was obvious under § 103." KSR, 550 U.S. _at_, 82 USPQ2d 1385, at 1397 (2007). Chen teaches a first sub-plurality of heat-generating components (fig. 1, 440a,440b) are mounted to a primary side (432) of the circuit board (430, col. 7, l. 49), and wherein a second sub-plurality of heat-generating components (450a,450b) are mounted to a secondary side (434) opposite the primary side of the circuit board. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention was made to duplicate the first electrical component of Ma, so that the first heat transfer device can be used to simultaneously cool multiple electrical components, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Eriksson teaches a singular heatsink (44) coupled with the top portion (fig. 1, back of 10) of the enclosure (10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the apparatus of Ma with the singular heat sink of Eriksson for the purpose of “improv[ing] performance and reliability of mobile phones, particularly during periods of excess heat generation” (¶[0006], ll. 1-2). Claim 5 is rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331), Eriksson (US 2008/0310109), Chen (US 11,477,915) and de la Fuente (US 10,551,886). Ma’s figs 3 and 6, Eriksson and Chen disclose the claimed invention except for a first thermal pad. de la Fuente teaches a first thermal pad (fig. 2, 220-1) located between the exterior surface (fig. 2, outer surface of 210-1,210-2,210-3) of the first heat transfer device and the top portion (202) of the enclosure (202,204,206,208), and configured to thermally couple (fig. 2 and col. 8, ll. 46-48) the exterior surface of the first heat transfer device and the top portion of the enclosure. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Ma’s figs. 3 and 6, Eriksson and Chen with the first thermal pad of de la Fuente for the purpose of increasing heat transfer between the first heat transfer device and the enclosure. Claim 8 is rejected under AIA 35 U.S.C. 103 as being unpatentable over Ma (US 10,945,331), Eriksson (US 2008/0310109), Chen (US 11,477,915) and Han (US 7,468,887). Ma’s fig. 1 further teaches the fourth portion of the interior surface is configured to extend over (see fig. 1) a top surface (top of 3) of the first electrical component of the plurality of heat-generating components; and wherein the fifth portion of the interior surface is substantially asymmetric (see fig. 1) to the fourth portion about an axis (fig. 1, horizontal axis passing thru midpoint of vertical portion of 51) bisecting the sixth portion. Ma, Eriksson and Chen fail to disclose the fifth portion of the interior surface is substantially symmetric to the fourth portion about an axis bisecting the sixth portion. Han teaches the fifth portion (fig. 3, bottom surface of 19c) of the interior surface (fig. 3, inner surface of 19) is substantially symmetric (see fig. 3) to the fourth portion (fig. 3, top surface of 19a) about an axis (fig. 3, horizontal axis bisecting 19b) bisecting the sixth portion (19b). It would have been an obvious matter of choice for the legs of the first heat transfer device to be sized including of equal lengths to maximize the heat transfer between the first electrical component and the enclosure, since such a modification would have involved a mere change in the size of a component. A change in size is generally recognized as being within the level of ordinary skill in the art. In re Rose, 105 USPQ 237 (CCPA 1955). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROBERT J HOFFBERG whose telephone number is (571) 272-2761. The examiner can normally be reached on Mon - Fri 9 AM - 5 PM. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Jayprakash Gandhi can be reached on (571) 272-3740. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. 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. 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. RJH 3/7/2026 /ROBERT J HOFFBERG/ Primary Examiner, Art Unit 2835
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Prosecution Timeline

Nov 15, 2023
Application Filed
Aug 02, 2025
Non-Final Rejection — §103, §112
Nov 06, 2025
Response Filed
Nov 22, 2025
Final Rejection — §103, §112
Feb 25, 2026
Request for Continued Examination
Mar 05, 2026
Response after Non-Final Action
Mar 07, 2026
Non-Final Rejection — §103, §112 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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