Prosecution Insights
Last updated: April 19, 2026
Application No. 18/523,302

WATER SUPPLY SYSTEM FOR A REFRIGERATOR

Non-Final OA §103
Filed
Nov 29, 2023
Examiner
ZERPHEY, CHRISTOPHER R
Art Unit
3799
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Haier US Appliance Solutions Inc.
OA Round
3 (Non-Final)
48%
Grant Probability
Moderate
3-4
OA Rounds
3y 1m
To Grant
67%
With Interview

Examiner Intelligence

Grants 48% of resolved cases
48%
Career Allow Rate
360 granted / 749 resolved
-21.9% vs TC avg
Strong +19% interview lift
Without
With
+19.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
53 currently pending
Career history
802
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
51.7%
+11.7% vs TC avg
§102
17.9%
-22.1% vs TC avg
§112
23.4%
-16.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 749 resolved cases

Office Action

§103
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 . The claims received 12/3/2025 are entered. Claim 9 is cancelled and claims 6-7 and 19-20 are withdrawn. Election/Restrictions Claims 6-7 and 19-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected species, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 8/5/2025. 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) 1, 8, and 10-14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al (US 2012/0111048), in view of Azcarate Castrellon et al (US 7,204,092), in view of Smale et al (US 2007/0204648), and as further evidenced by Kim (US 10,584,908; hereinafter Kim’908). Regarding claims 1 and 14, Kim discloses a refrigerator appliance defining a vertical direction, a lateral direction, and a transverse direction, comprising: a cabinet (1) defining a chilled chamber; a door (22) being rotatably mounted to the cabinet using a hinge (14) and being rotatable to provide selective access to the chilled chamber; a first icemaker (100) mounted to the door; a second icemaker (200); a water dispenser (26) mounted to the door; and a water supply system (shown in at least figure 7) for supplying water to the first icemaker, the second icemaker, and the water dispenser, the water supply system comprising: a water source (60); a water dispenser supply line passing from the water source, through the hinge (14; passage through hinge 14 shown in at least figure 6 and discussed at [0065]), and to the water dispenser (26); an icemaker supply line passing from the from the water source (60), through the hinge (14; passage through hinge 14 shown in at least figure 6 and discussed at [0065]), and to the first icemaker (100); a first multi-way valve (250) fluidly coupled to the icemaker supply line, the first multi- way valve comprising a plurality of outlets; a first supply line (252) providing fluid communication between the first icemaker (100) and a first outlet of the plurality of outlets. Kim lacks the second ice maker is mounted to the door and is supplied by the first multi-way valve. Azcarate Castrellon discloses a plurality of door mounted ice makers (40) each having a respective supply line (208 of figure 15) from a valve and manifold (212 and 210). It would have been obvious to one of ordinary skill in the art to have provided Kim with plural door mounted ice makers as taught by Azcarate Castrellon in order to provide additional ice making capacity. Further it follows, as Kim teaches using a multi-way valve to supply a plurality of users, to similarly connect additional ice makers in the same manner. In other words, provide an additional outlet of valve 250 to supply an additional ice maker. Kim discloses the first multi-way valve (250) within the door but is silent concerning a junction housing having a connection chamber. Smale discloses a refrigeration having a junction housing recessed within the door and defining a connection chamber (54) that contains a dispenser water connection, wherein an opening to the connection chamber is defined on an outer surface of the door. It would have been obvious to one of ordinary skill in the art to have provided Kim with the junction housing of Smale in order to provide a location to house the respective valve/outlets, including the first multi-way valve, and allow access to installation/servicing. Moreover Kim provides a schematic of the connections of the system, when employing the arrangement of Kim one of skill in the art would necessarily select particular means of implementation. In other words the recited components must go somewhere and Smale provides one solution for locating plumbing connections on a refrigerator door. Further regarding the location of the junction housing being at an opposite of the door relative to the hinge; Smale illustrates the junction housing (54) at about midway along the width direction of the door. It has been held that the particular position of an element does not render a claim non-obvious when rearranging said element would not have modified the operation of the device. Further the particular location can be regarded as an obvious matter of design choice. MPEP 2144.04 VI. C. In this instance locating the junction housing to be more distal from the hinge would not have modified operation of the device. Further Kim’908 evidences junction location (shown at valve 328) that is on an opposite side of the door relative to the hinge. Regarding claim 8, Kim discloses the first multi-way valve (250) is a double valve. Regarding claim 10, Kim discloses 1 the junction housing is positioned on a top side of the door (shown in figure 2). Regarding claim 11, Kim discloses the junction housing is recessed within the door but is silent concerning foam at the door. In the previous office action on the merits the Examiner took Official Notice that foam insulation at refrigerator doors is old and well known. In his subsequent reply to this office action, the applicant did not traverse Examiner’s assertion of Official Notice with regard to these elements. Therefore the Official Notice statements by the Examiner regarding these elements are now taken as admitted prior art by Applicant. See MPEP §2144.03(C). It would have been obvious to one of ordinary skill in the art to have provided insulation foam at the refrigerator door in order to maintain a temperature difference between the refrigerator interior and exterior thereby enhancing efficiency. Regarding claim 12, Kim as modified discloses the refrigerator appliance of claim 9, but lacks the junction housing being above an upper hinge. It has been held that the particular position of an element does not render a claim non-obvious when rearranging said element would not have modified the operation of the device. Further the particular location can be regarded as an obvious matter of design choice. MPEP 2144.04 VI. C. It would have been obvious to one of ordinary skill in the art to have provided Kim with a junction housing for the first multi-way valve in order to allow access for assembly/maintenance. Regarding claim 13, Kim discloses the refrigerator appliance of claim 1, wherein the refrigerator appliance is a side-by-side refrigerator appliance (the refrigerator and freezer are side-by-side in the vertical direction alternatively the doors 22 are in a side-by-side arrangement also known as a French door type). Alternatively, In the previous office action on the merits the Examiner took Official Notice that refrigerator/freezers in a horizontally side-by-side arrangement are old and well known. In his subsequent reply to this office action, the applicant did not traverse Examiner’s assertion of Official Notice with regard to these elements. Therefore the Official Notice statements by the Examiner regarding these elements are now taken as admitted prior art by Applicant. See MPEP §2144.03(C). It has been held that a "simple substitution of one known element for another to obtain predictable results” is obvious. In this instance the prior art provides, as officially noticed, for the element of side-by-side refrigerators. It is known in the art to substitute top-bottom refrigerator freezers for side-by-side refrigerator freezers. The result of the substitution would have been predictable. MPEP 2143 B. Claim(s) 2-5, 8, and 15-18 is/are rejected under 35 U.S.C. 103 as being unpatentable over in view of Kim et al (US 2012/0111048), in view of Azcarate Castrellon et al (US 7,204,092), in view of Smale et al (US 2007/0204648), evidenced by Kim’908 (US 10,584,908), and in further view of Ryu et al (US 2010/0050681). Regarding claims 2, 8, and 15, Kim, as modified, discloses the refrigerator appliance of claim 1, but lacks the second multi-way valve as claimed. Ryu discloses a refrigerator having a plurality of ice makers including a first multi-way valve (87) configured to supply the first and second ice makers (shown in figure 9), further comprising: a second multi-way valve (85) comprising an inlet, a first outlet, and a second outlet, wherein the water dispenser supply line provides fluid communication between the first outlet of the second multi-way valve and the water dispenser (50 by way of water tank 90), and wherein the icemaker supply line provides fluid communication between the second outlet of the second multi-way valve and the first multi-way valve; and a water supply line providing fluid communication between the water source and the inlet of the second multi-way valve (as shown in figure 9). Moreover figure 8 of Ryu shows a pair of valves (81 and 83) downstream of a junction which is a similar arrangement to figure 8 of Kim. It has been held that a "simple substitution of one known element for another to obtain predictable results” is obvious. In this instance the prior art provides for the element of valves controlling water supply to dispensers/icemakers. It is known in the art to substitute valves downstream from a junction for valves arranged in series (as evidenced by figures 8 and 9 of Ryu). The result of the substitution would have been predictable. MPEP 2143 B. Additionally in regard to claim 8, Kim as modified by Ryu provides that the first valve is a double valve (85 of Ryu). Regarding claims 3 and 16, Kim discloses a water filter (130 of Kim or 60 of Ryu as modified in claim 2) fluidly coupled to the water supply line between the water source and the inlet of the second multi-way valve. Regarding claims 4 and 17, Kim discloses a water tank (120) fluidly coupled to the water dispenser supply line for storing a volume of water from the water source. Regarding claims 5 and 18, Kim discloses the water tank (120) but lacks that it is within the fresh food compartment. In the previous office action on the merits the Examiner took Official Notice that providing a water tank within a refrigerator fresh food compartment is old and well known. In his subsequent reply to this office action, the applicant did not traverse Examiner’s assertion of Official Notice with regard to these elements. Therefore the Official Notice statements by the Examiner regarding these elements are now taken as admitted prior art by Applicant. See MPEP §2144.03(C). It would have been obvious to one of ordinary skill in the art to have provided Kim with a fresh food compartment mounted water tank in order to provide chilled water as well as provide a large storage capacity. Response to Arguments Applicant's arguments filed 12/3/2025 have been fully considered but they are not persuasive. The examiner agrees that the junction housing of Smale (referring to recess 54) is not at an opposite side of the door relative to the hinge. Rather the junction housing is generally midway in regarded to the width direction of the door. However; it has been held that the particular position of an element does not render a claim non-obvious when rearranging said element would not have modified the operation of the device. Further the particular location can be regarded as an obvious matter of design choice. MPEP 2144.04 VI. C. To further evidence that it is known to provide junction components, e.g. valves connecting a plurality of lines, at a location opposite to the door hinge, Kim’908 is provided. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Son et al (US 2007/0251261) water supply arrangement Kang (US 10,969,153) refrigerator valve. Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTOPHER R ZERPHEY whose telephone number is (571)272-5965. The examiner can normally be reached M-F 7:00-4:00 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, Jianying Atkisson can be reached at 5712707740. 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. /CHRISTOPHER R ZERPHEY/Primary Examiner, Art Unit 3799
Read full office action

Prosecution Timeline

Nov 29, 2023
Application Filed
Aug 25, 2025
Non-Final Rejection — §103
Oct 02, 2025
Response Filed
Oct 14, 2025
Final Rejection — §103
Dec 03, 2025
Response after Non-Final Action
Dec 19, 2025
Request for Continued Examination
Feb 13, 2026
Response after Non-Final Action
Feb 23, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12578119
HOT WATER SUPPLY TANK
2y 5m to grant Granted Mar 17, 2026
Patent 12558952
VEHICLE COOLING USING EXTERNAL FLUID SOURCE
2y 5m to grant Granted Feb 24, 2026
Patent 12560338
AIR CONDITIONING SYSTEM USING HEAT PUMP AND AIR HEATING DEVICE
2y 5m to grant Granted Feb 24, 2026
Patent 12553640
AIR CONDITIONER
2y 5m to grant Granted Feb 17, 2026
Patent 12546491
A BUFFERED BALANCED TYPE MOBILE PRIMARY-SECONDARY AIR CONDITIONER SYSTEM
2y 5m to grant Granted Feb 10, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
48%
Grant Probability
67%
With Interview (+19.1%)
3y 1m
Median Time to Grant
High
PTA Risk
Based on 749 resolved cases by this examiner. Grant probability derived from career allow 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