Prosecution Insights
Last updated: October 25, 2026
Application No. 18/524,356

ELECTROSTATIC RECOATER

Final Rejection §103§112
Filed
Nov 30, 2023
Priority
Dec 01, 2022 — provisional 63/429,265
Examiner
HEVEY, JOHN A
Art Unit
1735
Tech Center
1700 — Chemical & Materials Engineering
Assignee
VulcanForms Inc.
OA Round
2 (Final)
62%
Grant Probability
Moderate
3-4
OA Rounds
6m
Est. Remaining
82%
With Interview

Examiner Intelligence

Grants 62% of resolved cases
62%
Career Allowance Rate
393 granted / 636 resolved
-3.2% vs TC avg
Strong +20% interview lift
Without
With
+19.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
50 currently pending
Career history
690
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
52.6%
+12.6% vs TC avg
§102
7.9%
-32.1% vs TC avg
§112
23.9%
-16.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 636 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 . Claim Status An amendment, filed 9/15/2026, is acknowledged. Claims 21-23, 25-27, 29-32, 36-38 are amended; Claims 40-48 are newly added; claims 1-20, 28, and 39 are canceled. Claims 21-27, 29-38, and 40-48 are currently pending. The rejection of claims 26 and 38 under 35 U.S.C. 112(b) is withdrawn in view of Applicant’s amendments to the claims. Claim Interpretation Independent Claim 21 is drawn to “A method for additive manufacturing” and wherein an electrode and a dielectric shield “are movable relative to one another in directions along the interface during additive manufacturing,” however, the claim does not recite any specific steps for additive manufacturing, nor does the claim provide any scope or limitations drawn to how the electrode and dielectric shield are used or located in an additive manufacturing method and corresponding structure comprising means for additive manufacturing. Therefore, so long as an additive manufacturing method may, under a broadest reasonable interpretation, comprise an electrode and dielectric shield movable relative to one another in directions along the interface between them during a method of additive manufacturing, in any capacity/use, it meets the instant claim. Claim Rejections - 35 USC § 112 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 23, 31-32, and 40 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. Claims 21 and 29 both require a method wherein a dielectric shield is movable relative to an electrode along an interface during an additive manufacturing method. Claims 23, 31-32, and 40 respectively dependent on claims 21 or 29, are each drawn to limitations requiring a clamp for applying a force on the dielectric shield in a direction perpendicular to the lower surface of the electrode to hold the dielectric shield in contact with the lower surface of the electrode. A reasonable interpretation of a “clamp” providing a force to hold one object to another would also comprise limiting or preventing relative movement of said objects; therefore, it is unclear what clamp force and/or what magnitude of allowed relative movement is required by the claims. The following is a quotation of 35 U.S.C. 112(d): (d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. The following is a quotation of pre-AIA 35 U.S.C. 112, fourth paragraph: Subject to the following paragraph [i.e., the fifth paragraph of pre-AIA 35 U.S.C. 112], a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. Claims 23, 31-32, and 40 are rejected under 35 U.S.C. 112(d) or pre-AIA 35 U.S.C. 112, 4th paragraph, as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, or for failing to include all the limitations of the claim upon which it depends. Claims 21 and 29 both require a method wherein a dielectric shield is movable relative to an electrode along an interface during an additive manufacturing method. Claims 23, 31-32, and 40 respectively dependent on claims 21 or 29, are each drawn to limitations requiring a clamp for applying a force on the dielectric shield in a direction perpendicular to the lower surface of the electrode to hold the dielectric shield in contact with the lower surface of the electrode. A reasonable interpretation of a “clamp” providing a force to hold one object to another would also comprise limiting or preventing relative movement of the objects and therefore, the limitations of claims 23, 31-32, and 40 may be interpreted to fail to include all of the limitations of the claim upon which they depend. Applicant may cancel the claim(s), amend the claim(s) to place the claim(s) in proper dependent form, rewrite the claim(s) in independent form, or present a sufficient showing that the dependent claim(s) complies with the statutory requirements. 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) 21-22, 24-27, 29-30, 33, 36-38, 41-42, and 41-42 are rejected under 35 U.S.C. 103 as being unpatentable over Coward (US 2022/0184709) in view of Li (CN 216670479)(machine translation provided). With respect to Claim 21, Coward teaches a method of additive manufacturing, the method comprising a voltage supply to supply alternating current to an electrode of a powder bed recoater, generating an electric field below a lower surface of the electrode, wherein a dielectric shield extends over the lower surface of the electrode, and therefore, forms a planar interface between the dielectric and the electrode forming a shield from powder below. (para. 18-26; Figs. 4-8). Coward does not specifically teach permitting movement of the electrode and the dielectric shield relative to one another along the interface during additive manufacturing. Li teaches a method of cleaning a lens for which focused light is provided through, the method comprising a an electrode to which voltage is supplied and generating an electric field below a lower surface of the electrode, wherein a dielectric shield extends over the lower surface at an interface between the dielectric shield and the electrode, and wherein the electrode and the dielectric shield are movable relative to one another in directions along the interface. (pgs. 1-4 of translation; Figs. 1-4). Li teaches the ability to move the dielectric shield relative to an electrode during operation of the intended device. (pgs. 3-4 of translation). Thus, Li teaches the utility of allowing for movement of a dielectric shield relative to an electrode and one of ordinary skill in the art would recognize that such a technique may be applied in a wide variety of contexts and specific structures/arrangements. It would have been obvious to one of ordinary skill in the art to modify the method of Coward to allow for relative movement of the dielectric shield and the electrode along the interface during the intended method of use (here during additive manufacturing), as taught by Li, in order to allow for enhanced control over the properties of the electrode and the generated electric field. With respect to Claim 22, Coward in view of Li teach wherein the interface is planar interface and wherein the electrode and the dielectric shield are movable relative to one another in directions parallel to a plane of the interface. (see rejection of claim 21 above). It would have been obvious to one of ordinary skill in the art to select one of the limited number of relative movements, including wherein the electrode and dielectric shield move relative to one another in direction(s) parallel to the plane of the interface. See MPEP 2144.05. With respect to Claim 24, Coward teaches wherein the dielectric shield is a planar layer of dielectric material. (para. 18, 102; Figs. 4-8, 14-16). With respect to Claim 25, Coward teaches wherein the method further comprises exposing a layer of powder build material to the electric material using the electrode and dielectric shield, and smoothing an upper surface of the layer of powder without contacting the upper surface of the powder material. (para. 18-26; Figs. 4-8). With respect to Claim 26, Coward teaches wherein the method is used as part of a powder bed fusion-type additive manufacturing process, such as selective laser melting or selective laser sintering, wherein a part is formed by selectively fusing portions of the powder with laser energy to form a part w herein at least one laser beam selectively irradiates a powder build surface and thus, comprises wherein the one or more laser energy pixels are directed onto a build surface by one or more laser energy sources, deemed to meet the instantly claimed limitation. (para. 3-4, 108; Figs. 1, 5-6). With respect to Claim 27, Coward teaches wherein the dielectric material may comprise, for example, glass or ceramic, deemed to encompass a range of dielectric constants overlapping the claimed range. It would have been obvious to one of ordinary skill in the art to select a glass or ceramic dielectric shield with a dielectric constant from the overlapping portion of the ranges. Overlapping ranges have been held sufficient to establish a prima facie case of obviousness. MPEP § 2144.05. Furthermore, one of ordinary skill in the art would recognize that the selection of a dielectric material would include consideration of the dielectric constant of the material in order to obtain the desired performance of the electrostatic device. It would have been obvious to one of ordinary skill in the art to select a glass or ceramic dielectric shield with an optimum or workable dielectric constant from the overlapping portion of the ranges in order to perform the intended method of smoothing/leveling powder in an additive manufacturing method. With respect to Claim 29, Coward teaches a method of additive manufacturing, the method comprising a voltage supply to supply alternating current to an electrode of a powder bed recoater, generating an electric field below a lower surface of the electrode, wherein a dielectric shield extends over the lower surface of the electrode. (para. 18-26; Figs. 4-8). Coward teaches wherein the method further comprises exposing a layer of powder build material to the electric material using the electrode and dielectric shield, and smoothing/leveling an upper surface of the layer of powder without contacting the upper surface of the powder material using the electric field. (para. 18-26; Figs. 4-8). Coward does not specifically teach removably coupling the dielectric shield to a surface of the electrode. As demonstrated in Figs. 14-16, Coward teaches various means for cleaning unwanted powder off of the dielectric shield. Thus, one of ordinary skill in the art would recognize that cleaning the dielectric shield is an ordinary and beneficial step for a method of use of the powder recoater in an additive manufacturing method. Furthermore, MPEP 2144 recognizes that making a structure adjustable or separable, for example, for the purposes of removal would have been obvious to one of ordinary skill in the art. (MPEP 2144; In re Dulberg, 289 F.2d 522, 523, 129 USPQ 348, 349 (CCPA 1961) (The court held that "if it were considered desirable for any reason to obtain access to the end of [the prior art’s] holder to which the cap is applied, it would be obvious to make the cap removable for that purpose."). As Coward recognizes the need for cleaning the dielectric shield, it would have been obvious to one of ordinary skill in the art to removably couple the dielectric shield to a surface of the electrode in order to enable movement and/or removal the dielectric shield, for example, for the purposes of cleaning, replacement, and/or for further controlling the generated electric field. Coward does not specifically teach removably coupling the dielectric shield to a surface of the electrode such that the dielectric shield and electrode are movable relative to one another during additive manufacturing. Li teaches a method of cleaning a lens for which focused light is provided through, the method comprising a an electrode to which voltage is supplied and generating an electric field below a lower surface of the electrode, wherein a dielectric shield extends over the lower surface at an interface between the dielectric shield and the electrode, and wherein the electrode and the dielectric shield are movable relative to one another in directions along the interface. (pgs. 1-4 of translation; Figs. 1-4). Li teaches the ability to move the dielectric shield relative to an electrode during operation of the intended device. (pgs. 3-4 of translation). It would have been obvious to one of ordinary skill in the art to modify the method of Coward to allow for relative movement of the dielectric shield and the removably coupled electrode along the interface during the intended method of use (here during additive manufacturing), as taught by Li, in order to allow for enhanced control over the properties of the electrode and the generated electric field. With respect to Claim 30, as detailed with respect to Claims 21-22 and 29, Coward in view of Li teach wherein the interface is planar interface and wherein the electrode and the dielectric shield are movable relative to one another in directions parallel to a plane of the interface. (see rejections of claim 21-22 and 29 above). With respect to Claim 33, Coward teaches wherein the dielectric shield is a planar layer of dielectric material. (para. 18, 102; Figs. 4-8, 14-16). With respect to Claim 36, Coward teaches wherein the electrode (conductive element) is surrounded by an insulating material (dielectric), the conductive element and insulating material defining a planar structure that includes a planar surface. (see Fig. 17). With respect to Claim 37, Coward teaches wherein the method further comprises exposing a layer of powder build material to the electric material using the electrode and dielectric shield, and smoothing an upper surface of the layer of powder without contacting the upper surface of the powder material. (see rejection of claim 29 above; para. 18-26; Figs. 4-8). With respect to Claim 38, Coward teaches wherein the method is used as part of a powder bed fusion-type additive manufacturing process, such as selective laser melting or selective laser sintering, wherein a part is formed by selectively fusing portions of the powder with laser energy to form a part w herein at least one laser beam selectively irradiates a powder build surface and thus, comprises wherein the one or more laser energy pixels are directed onto a build surface by one or more laser energy sources, deemed to meet the instantly claimed limitation. (para. 3-4, 108; Figs. 1, 5-6). With respect to Claims 41-42, Coward in view of Li teach wherein the dielectric shield and the electrode are movable relative to one another along the surface during additive manufacturing and when leveling the layer of powder material. (see rejection of claim 29 above). Claim(s) 23 and 31 are rejected under 35 U.S.C. 103 as being unpatentable over Coward (US 2022/0184709) in view of Li (CN 216670479)(machine translation provided) as applied to claim 29 above in view of Spears (US 2018/0236549). With respect to Claims 23 and 31, Coward in view of Li are silent as to a clamp to apply force to hold the dielectric shield in contact with the lower surface of the electrode. Spears teaches a method of additive manufacturing comprising a traditional blade recoater, wherein the blade is removably attached to with a pair of clamps. One of ordinary skill in the art would recognize that clamps are a conventional means for removably attaching/coupling one component to another. It would have been obvious to one of ordinary skill in the art to use a known method of removably coupling one part to another, such as clamps, as taught by Spears, in order to removably couple the dielectric shield to the electrode such that clamps apply a force to the dielectric shield in a direction perpendicular to the lower surface of the electrode to hold the dielectric shield in contact with the lower surface. Claim(s) 34-35 are rejected under 35 U.S.C. 103 as being unpatentable over Coward (US 2022/0184709) in view of Li (CN 216670479)(machine translation provided) as applied to claim 29 above (with respect to Claim 34) in view of Matsunaga (US 6166897). With respect to Claims 34 and 35, Coward in view of Li are silent as to an interface layer between the dielectric shield and the electrode. Matsunaga teaches an electrostatic device comprising an electrode, an insulator/dielectric shield, wherein an adhesive interface is provided between the electrode and the insulator. (Figs. 1-2). Additionally, the reference teaches a second insulator in contact with both the electrodes and adhesively attached to the first insulator. (Fig. 2). Thus, Coward and Matsunaga are both drawn to the problem of insulating an electrode of an electrostatic device. It would have been obvious to one of ordinary skill in the art to modify the method of Coward in view of Li to include an interface layer, comprising an adhesive and/or a second insulator and adhesive, as taught by Matsunaga, in order to securely attach the insulator/dielectric shield to the electrode and provide sufficient insulation to prevent arcing as taught by Coward. Allowable Subject Matter Claims 43-48 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. The following is a statement of reasons for the indication of allowable subject matter: the prior art of record fails to teach the method of claims 21 or 29 further comprising moving the electrode and the dielectric shield relative to one another to accommodate a thermal expansion and/or contraction mismatch between the dielectric shield and the electrode during additive manufacturing. Response to Arguments Applicant’s arguments, filed 9/15/2026, with respect to the rejection(s) of claim(s) 21-27, 29-31 and 33-38 under 35 U.S.C. 103 over Coward have been fully considered and are persuasive in view of Applicant’s amendments to the claims. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of Coward in view of Li, as detailed above. Applicant’s arguments with respect to the 103 rejections over Coward et al. are moot in view of the new grounds of rejection. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOHN A HEVEY whose telephone number is (571)270-0361. The examiner can normally be reached Monday-Friday 9:00-5:30. 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, Keith Walker can be reached at 571-272-3458. 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. /JOHN A HEVEY/Primary Examiner, Art Unit 1735
Read full office action

Prosecution Timeline

Nov 30, 2023
Application Filed
Jun 16, 2026
Non-Final Rejection mailed — §103, §112
Aug 18, 2026
Interview Requested
Aug 26, 2026
Applicant Interview (Telephonic)
Aug 26, 2026
Examiner Interview Summary
Sep 15, 2026
Response Filed
Oct 01, 2026
Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12768016
THREE-DIMENSIONAL PRINTING WITH STAINLESS STEEL PARTICLES
4y 8m to grant Granted Oct 20, 2026
Patent 12753475
HIGH-STRENGTH SOLDER-PLATED AL-MG-SI ALUMINUM MATERIAL
4y 0m to grant Granted Oct 06, 2026
Patent 12753456
HIGH-STRENGTH ELECTROGALVANNEALED STEEL SHEET AND METHOD FOR MANUFACTURING THE SAME
3y 4m to grant Granted Oct 06, 2026
Patent 12753459
STEEL SHEET
3y 1m to grant Granted Oct 06, 2026
Patent 12728472
GAS CUTTING METHOD FOR CUTTING STEEL MATERIAL AND STEEL MATERIAL PRODUCING METHOD
4y 0m to grant Granted Sep 08, 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

3-4
Expected OA Rounds
62%
Grant Probability
82%
With Interview (+19.7%)
3y 5m (~6m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 636 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