Prosecution Insights
Last updated: July 17, 2026
Application No. 18/524,356

ELECTROSTATIC RECOATER

Non-Final OA §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
1 (Non-Final)
61%
Grant Probability
Moderate
1-2
OA Rounds
10m
Est. Remaining
82%
With Interview

Examiner Intelligence

Grants 61% of resolved cases
61%
Career Allowance Rate
383 granted / 624 resolved
-3.6% vs TC avg
Strong +20% interview lift
Without
With
+20.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
46 currently pending
Career history
664
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
76.1%
+36.1% vs TC avg
§102
4.0%
-36.0% vs TC avg
§112
2.4%
-37.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 624 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 . Election/Restrictions Applicant’s election without traverse of Group II, claims 21-27 and 29-38 and the species drawn a removably coupled dielectric shield (wherein claim 21 is interpreted as generic, and thus, species election includes claims 21-27 and 29-38) in the reply filed on 5/20/2026 is acknowledged. Claims 1-20, 28, and 39 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected Group I and nonelected species, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 5/20/2026. 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 23-27 and 38 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 21 recites “permitting movement of the electrode and the dielectric shield relative to one another in directions along the interface.” It is unclear if the method requires that the dielectric shield move in the method (i.e. move as a positive method step) or merely that the dielectric shield is capable of moving relative to the electrode. Further, it is unclear if “permitting movement” requires free or unencumbered movement (e.g. free rotation of a wheel on an axle) or that it capable of being removed or separated by some means (e.g. removing a screw enabling removal of one part from a component). Claims 22-27 are indefinite based on their dependency. Claims 26 and 38 recite “fusing at least a portion of powder material with one or more laser energy pixels to form one or more parts on a build surface.” The claims do not establish structure to render the term “pixel” definite in the claims. In other words, laser energy is not measured in pixels and it is unclear how a single pixel (e.g. the smallest or basic unit of fusing capable by the energy source) could form a “part” as instantly claimed. In short, the limitations of claims 26 and 38 rely on specifics of a method of additive manufacturing and associated structure that are not claimed and render the claims indefinite. 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 are rejected under 35 U.S.C. 103 as being unpatentable over Coward (US 2022/0184709). 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 an 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. 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 permit movement of the dielectric shield relative to the movement of the electrode, for example, for the purposes of cleaning or removal/separation for cleaning. With respect to Claim 22, as detailed with respect to Claim 21, it would have been obvious to one of ordinary skill in the art to permit movement of the dielectric shield relative to the movement of the electrode, for example, for the purposes of cleaning or removal/separation for cleaning. Coward teaches wherein the interface is planar and the electrode and dielectric shield are both substantially plate-shaped. (Fig. 15). Based on the structure taught by Coward, such as that of Fig. 15, there exist a limited number of movement directions the electrode and dielectric shield could make relative to one another. 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, 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 removal the dielectric shield, for example, for the purposes of cleaning or replacement. With respect to Claim 30, as detailed with respect to Claims 21 and 29, it would have been obvious to one of ordinary skill in the art to permit relative movement of the dielectric shield and the electrode along an interface between the dielectric shield and the electrode for the purposes of cleaning or removal/separation for cleaning or replacement. Coward teaches wherein the interface is planar and the electrode and dielectric shield are both substantially plate-shaped. (Fig. 15). Based on the structure taught by Coward, such as that of Fig. 15, there exist a limited number of movement directions the electrode and dielectric shield could make relative to one another. 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 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, deemed to meet the instantly claimed limitation. (para. 3-4, 108; Figs. 1, 5-6). Claim(s) 23 and 31 are rejected under 35 U.S.C. 103 as being unpatentable over Coward (US 2022/0184709) as applied to claim 29 above in view of Spears (US 2018/0236549). With respect to Claims 23 and 31, Coward is 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. As detailed above, it would have been obvious to one of ordinary skill in the art to modify the method of Coward to removably couple the dielectric shield to the electrode (and thus, permit movement of the shield relative to the electrode), and wherein the dielectric shield is provided on a lower surface of the electrode. 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) 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 is 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 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 Claim 32 is 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 a method as in claim 31 further comprising a frame for the clamp as required by claim 32 such that the arrangement removably couples the dielectric shield to the electrode as in claim 29. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 20230398553, teaching an electrostatic device where a dielectric material moves relative to the electrode but fails to teach providing an alternating electric voltage to the electrode. 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 (current)

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Prosecution Projections

1-2
Expected OA Rounds
61%
Grant Probability
82%
With Interview (+20.1%)
3y 5m (~10m remaining)
Median Time to Grant
Low
PTA Risk
Based on 624 resolved cases by this examiner. Grant probability derived from career allowance rate.

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