Prosecution Insights
Last updated: August 16, 2026
Application No. 18/547,839

ULTRASONIC TRANSDUCER

Non-Final OA §102§103§112
Filed
Aug 24, 2023
Priority
Feb 26, 2021 — DE 102021104697.1 +1 more
Examiner
PHAM, EMILY P
Art Unit
Tech Center
Assignee
TDK Corporation
OA Round
1 (Non-Final)
88%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 88% — above average
88%
Career Allowance Rate
747 granted / 854 resolved
+27.5% vs TC avg
Moderate +13% lift
Without
With
+13.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
16 currently pending
Career history
863
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
38.9%
-1.1% vs TC avg
§102
36.1%
-3.9% vs TC avg
§112
20.2%
-19.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 854 resolved cases

Office Action

§102 §103 §112
DETAILED ACTION Notice of 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 (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. Foreign Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statements (IDS) submitted on 11 September 2025, 20 May 2024 and 7 September 2023 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statements are being considered by the examiner. Specification The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed. The lengthy specification has not been checked to the extent necessary to determine the presence of all possible minor errors. Applicant’s cooperation is requested in correcting any errors of which applicant may become aware in the specification. The specification is objected to because of the following informalities: after “CROSS-REFERENCE TO RELATED APPLICATIONS”, the specification appears to omit the “BRIEF SUMMARY OF THE INVENTION” and “DETAILED DESCRIPTION OF THE INVENTION”, paragraphs [0001] – [0228] provide a lengthy and confusing descriptions of prior arts and present embodiments of the invention. Appropriate correction is required. The following guidelines illustrate the preferred layout for the specification of a utility application. These guidelines are suggested for the applicant’s use. Arrangement of the Specification As provided in 37 CFR 1.77(b), the specification of a utility application should include the following sections in order. Each of the lettered items should appear in upper case, without underlining or bold type, as a section heading. If no text follows the section heading, the phrase “Not Applicable” should follow the section heading: (a) TITLE OF THE INVENTION. (b) CROSS-REFERENCE TO RELATED APPLICATIONS. (c) STATEMENT REGARDING FEDERALLY SPONSORED RESEARCH OR DEVELOPMENT. (d) THE NAMES OF THE PARTIES TO A JOINT RESEARCH AGREEMENT. (e) INCORPORATION-BY-REFERENCE OF MATERIAL SUBMITTED ON A READ-ONLY OPTICAL DISC, AS A TEXT FILE OR AN XML FILE VIA THE PATENT ELECTRONIC SYSTEM. (f) STATEMENT REGARDING PRIOR DISCLOSURES BY THE INVENTOR OR A JOINT INVENTOR. (g) BACKGROUND OF THE INVENTION. (1) Field of the Invention. (2) Description of Related Art including information disclosed under 37 CFR 1.97 and 1.98. (h) BRIEF SUMMARY OF THE INVENTION. (i) BRIEF DESCRIPTION OF THE SEVERAL VIEWS OF THE DRAWING(S). (j) DETAILED DESCRIPTION OF THE INVENTION. (k) CLAIM OR CLAIMS (commencing on a separate sheet). (l) ABSTRACT OF THE DISCLOSURE (commencing on a separate sheet). (m) SEQUENCE LISTING. (See MPEP § 2422.03 and 37 CFR 1.821 - 1.825). A “Sequence Listing” is required on paper if the application discloses a nucleotide or amino acid sequence as defined in 37 CFR 1.821(a) and if the required “Sequence Listing” is not submitted as an electronic document either on read-only optical disc or as a text file via the patent electronic system. Content of Specification (a) TITLE OF THE INVENTION: See 37 CFR 1.72(a) and MPEP § 606. The title of the invention should be placed at the top of the first page of the specification unless the title is provided in an application data sheet. The title of the invention should be brief but technically accurate and descriptive, preferably from two to seven words. It may not contain more than 500 characters. (b) CROSS-REFERENCES TO RELATED APPLICATIONS: See 37 CFR 1.78 and MPEP § 211 et seq. (c) STATEMENT REGARDING FEDERALLY SPONSORED RESEARCH OR DEVELOPMENT: See MPEP § 310. (d) THE NAMES OF THE PARTIES TO A JOINT RESEARCH AGREEMENT. See 37 CFR 1.71(g). (e) INCORPORATION-BY-REFERENCE OF MATERIAL SUBMITTED ON A READ-ONLY OPTICAL DISC, AS A TEXT FILE OR AN XML FILE VIA THE PATENT ELECTRONIC SYSTEM: The specification is required to include an incorporation-by-reference of electronic documents that are to become part of the permanent United States Patent and Trademark Office records in the file of a patent application. See 37 CFR 1.77(b)(5) and MPEP § 608.05. See also the Legal Framework for Patent Electronic System posted on the USPTO website (https://www.uspto.gov/sites/default/files/documents/2019LegalFrameworkPES.pdf) and MPEP § 502.05 (f) STATEMENT REGARDING PRIOR DISCLOSURES BY THE INVENTOR OR A JOINT INVENTOR. See 35 U.S.C. 102(b) and 37 CFR 1.77. (g) BACKGROUND OF THE INVENTION: See MPEP § 608.01(c). The specification should set forth the Background of the Invention in two parts: (1) Field of the Invention: A statement of the field of art to which the invention pertains. This statement may include a paraphrasing of the applicable U.S. patent classification definitions of the subject matter of the claimed invention. This item may also be titled “Technical Field.” (2) Description of the Related Art including information disclosed under 37 CFR 1.97 and 37 CFR 1.98: A description of the related art known to the applicant and including, if applicable, references to specific related art and problems involved in the prior art which are solved by the applicant’s invention. This item may also be titled “Background Art.” (h) BRIEF SUMMARY OF THE INVENTION: See MPEP § 608.01(d). A brief summary or general statement of the invention as set forth in 37 CFR 1.73. The summary is separate and distinct from the abstract and is directed toward the invention rather than the disclosure as a whole. The summary may point out the advantages of the invention or how it solves problems previously existent in the prior art (and preferably indicated in the Background of the Invention). In chemical cases it should point out in general terms the utility of the invention. If possible, the nature and gist of the invention or the inventive concept should be set forth. Objects of the invention should be treated briefly and only to the extent that they contribute to an understanding of the invention. (i) BRIEF DESCRIPTION OF THE SEVERAL VIEWS OF THE DRAWING(S): See MPEP § 608.01(f). A reference to and brief description of the drawing(s) as set forth in 37 CFR 1.74. (j) DETAILED DESCRIPTION OF THE INVENTION: See MPEP § 608.01(g). A description of the preferred embodiment(s) of the invention as required in 37 CFR 1.71. The description should be as short and specific as is necessary to describe the invention adequately and accurately. Where elements or groups of elements, compounds, and processes, which are conventional and generally widely known in the field of the invention described, and their exact nature or type is not necessary for an understanding and use of the invention by a person skilled in the art, they should not be described in detail. However, where particularly complicated subject matter is involved or where the elements, compounds, or processes may not be commonly or widely known in the field, the specification should refer to another patent or readily available publication which adequately describes the subject matter. (k) CLAIM OR CLAIMS: See 37 CFR 1.75 and MPEP § 608.01(m). The claim or claims must commence on a separate sheet or electronic page (37 CFR 1.52(b)(3)). Where a claim sets forth a plurality of elements or steps, each element or step of the claim should be separated by a line indentation. There may be plural indentations to further segregate subcombinations or related steps. See 37 CFR 1.75 and MPEP 608.01(i) - (p). (l) ABSTRACT OF THE DISCLOSURE: See 37 CFR 1.72 (b) and MPEP § 608.01(b). The abstract is a brief narrative of the disclosure as a whole, as concise as the disclosure permits, in a single paragraph preferably not exceeding 150 words, commencing on a separate sheet following the claims. In an international application which has entered the national stage (37 CFR 1.491(b)), the applicant need not submit an abstract commencing on a separate sheet if an abstract was published with the international application under PCT Article 21. The abstract that appears on the cover page of the pamphlet published by the International Bureau (IB) of the World Intellectual Property Organization (WIPO) is the abstract that will be used by the USPTO. See MPEP § 1893.03(e). (m) SEQUENCE LISTING: See 37 CFR 1.821 - 1.825 and MPEP §§ 2421 - 2431. The requirement for a sequence listing applies to all sequences disclosed in a given application, whether the sequences are claimed or not. See MPEP § 2422.01. 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. Claim 1 is rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention. Claim 1 recites the limitation "the element" in line 6. There is insufficient antecedent basis for this limitation in the claim. Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claims 1-3 and 5-29 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Gebhart et al. (U. S. Pre-Grant Publication No. 20220260712, see IDS of 7 September 2023). Regarding independent claim 1, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses an ultrasonic transducer comprising: a carrier (container 2 having an opening, a base and a wall and a cover closing the container) with conductor traces (conductor tracks); and a piezoelectric element (5) with electrodes (a piezoelectric material which is arranged between two electrodes), wherein the piezoelectric element (5) has a contact side (contact-connection) which is fixed on the carrier (2), and wherein the conductor traces (conductor tracks) and the electrodes (two electrodes) are electrically coupled via the contact side (contact-connection) of the element (5). Regarding independent claim 2, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses an ultrasonic transducer comprising: a container (container 2 having an opening, a base and a wall and a cover closing the container) with a bottom designed as a carrier (2), a wall and an installation opening that is closable with a lid (a cover 6); electronics (7) integrated in the container (2) and/or in the lid (an electronics system integrated in the cover 6); a piezoelectric element (5) having a contact side (contact-connection) fixed on the carrier (2); and conductor traces (conductor tracks) electrically connecting electrodes (two electrodes) of the piezoelectric element (5) and connection points (contat-connections) of the electronics (7). Regarding claim 3, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the conductor traces (conductor tracks) and the electrodes (two electrodes) are electrically coupled via the contact side (contact-connection) of the piezoelectric element (5). Regarding claim 5, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the ultrasonic transducer is configured to apply a voltage (the operating voltage required by the piezoelectric disk 5) between the electrodes (two electrodes) during operation. Regarding claim 6, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the lid (cover 6) can be fixed to the container (2) by means of an electrically conductive lid adhesive (cover 6) and the electronics (7) integrated in the lid (cover 6) can be electrically contacted with the conductor traces (conductor tracks). Regarding claim 7, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses a damping element ([0011], [0012], [0033], [0059], [0080] the damping element 8) is arranged in a cavity in the container (2) between the carrier (2) with the piezoelectric element (5) and the lid (cover 6). Regarding claim 8, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the electrodes (two electrodes) on the piezoelectric element (5) and the connection points of the electronics (7) are electrically connected exclusively by the conductor traces (conductor tracks). Regarding claim 9, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the piezoelectric element (5) is a piezoelectric disk. Regarding claim 10, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the electrodes (two electrodes) electrically contact the conductor traces (conductor tracks) of the carrier (2). Regarding claim 11, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the first electrode is arranged areally on the contact side (contact-connection) of the piezoelectric element (5) and wherein the second electrode is arranged substantially areally on a side of the piezoelectric element (5) opposite to the contact side (contact-connection) and furthermore, wherein parts of the second electrode are arranged on a side surface and on the contact side (contact-connection) of the piezoelectric element (5). Regarding claim 12, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the contact side (contact-connection) of the piezoelectric element (5) is fixed to the support by means of a support adhesive. Regarding claim 13, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the carrier adhesive (2) is electrically insulating. Regarding claim 14, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the electrodes (two electrodes) and the conductor traces (conductor tracks) have rough surfaces that are spaced such that the electrodes (two electrodes) and the conductor traces (conductor tracks) are in direct contact. Regarding claim 15, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses portions of the electrodes (two electrodes) and the conductor traces (conductor tracks) are exposed to their surroundings and are in direct contact with each other. Regarding claim 16, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the electrodes (two electrodes) and the conductor traces (conductor tracks) are capacitively coupled. Regarding claim 17, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the carrier adhesive means (2) is anisotropically electrically conductive, so that the carrier adhesive means (2) is formed as an electrical contact between the electrodes (two electrodes) and the conductor traces (conductor tracks) and at the same time different electrodes (two electrodes) are insulated from each other. Regarding claim 18, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the conductor traces (conductor tracks) are arranged on an inner surface of the container (2). Regarding claim 19, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the conductor traces (conductor tracks) are integrated inside the container. Regarding claim 20, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the container (2) has rotational symmetry. Regarding claim 21, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the container (2) is cylindrical, conical or frustoconical. Regarding claim 22, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses the container (2) comprises means (11) interconnected with the electronics (7) to provide shielding of radiated electromagnetic disturbances in the form of Faraday shielding ([0100]). Regarding claim 23, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses a metallic coating is applied to an inner and/or outer side of the container (2) as means for Faraday shielding ([0100]). Regarding claim 24, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses internal electrode structures or metal meshes such as copper meshes are applied to an inner side of the container (2) as means for Faraday shielding ([0100]). Regarding claim 25, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses a protective mechanical coating is applied to the outside of the container (2). Regarding independent claim 26, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses an ultrasonic transducer comprising a container (2) with an installation opening which can be closed by a lid (a cover 6) that has integrated electronics (7), wherein the lid (cover 6) can be fixed to the container (2) by means of an electrically conductive lid adhesive (6) and the electronics (7) can be electrically contacted with conductor traces (conductor tracks) of the container (2). Regarding independent claim 27, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses an ultrasonic transducer that can be generally manufactured by a method of manufacturing an ultrasonic transducer, comprising the steps: a) providing a container (2) which can be closed by a lid (a cover 6) that has integrated electronics (7) and the container (2) having an installation opening that comprises a bottom designed as a support and conductor paths; and b) fixing a piezoelectric element (5) in the container (2) on the support so that electrodes (two electrodes) arranged on the piezoelectric element (5) are electrically connected via the conductor traces (conductor tracks) to connection points (contat-connections) of the electronics (7). Regarding claim 28, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses fixing the piezoelectric element (5) so that the electrodes (two electrodes) are electrically coupled to the conductor traces (conductor tracks); and closing the installation opening with the lid (cover 6), wherein connection points of the electronics (7) are electrically coupled to the conductor traces (conductor tracks) so that the electronics (7) are electrically connected to the electrodes (two electrodes) in a wireless manner. Regarding claim 29, Gebhart et al. (e. g. see FIG. 1, FIG. 4, Abstract, [0069]-[0070], [0093]) discloses inserting a damping element ([0011], [0012], [0033], [0059], [0080] the damping element 8) that fills the container (2) between the piezoelectric element (5) and the lid (cover 6). 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Gebhart et al. (U. S. Pre-Grant Publication No. 20220260712). Regarding claim 4, Gebhart et al. does not explicitly disclose “the ultrasonic transducer is configured such that the electrodes are differently polarized during operation.” However, Gebhart et al. ([0010] and [0082]) teaches [0010] During transmitting operation, the piezoelectric disk can be excited, via an AC voltage applied by the electronics system [0082] The integrated circuit 17 has a charge pump with which the operating voltage required by the piezoelectric disk 5, which operating voltage is higher than a supply voltage of the circuit of between 5 and 12 V, can be generated. It is well known in the art that AC voltage is differently polarized because the current continuously alternates direction. Examiner’s Remark: In this Office Action, Examiner has cited particular figures, column numbers, paragraph numbers, and line numbers of the prior arts applied in the rejections. However, other figures and passages of the same prior arts may anticipate the claim limitations as well. Therefore, Applicants are respectfully requested to consider the prior arts in their entirety as potentially teaching claimed invention. For amendment purpose, Applicants are very much appreciated for indicating the portion(s) of the specification which dictates the structure(s) relied on for proper interpretation as well as for verification and determination of the metes and bounds of the claimed invention. Applicants’ indication of the specific figures and items of figures which represent features of the invention disclosed in the amended claims, is also expected. Additionally, in the event that other prior art(s) is/are provided and made of record by the Examiner as being relevant or pertinent to applicant's disclosure but not relied upon, the examiner requests that the reference(s) be considered in any subsequent amendments, as the reference(s) is also representative of the teachings of the art and may apply to the specific limitations of any newly amended claim(s). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Hirao et al. (U. S. Pre-Grant Publication No. 20200086347) discloses a sonic device including a sonic transducer unit and a sonic propagation unit. The sonic transducer unit includes an ultrasonic transmitting-receiving element having a vibrator (piezoelectric body) for an ultrasonic probe and electrodes provided on both upper and lower surfaces of the vibrator. The sonic propagation unit is provided to be in contact with the wave transmitting-receiving surface (sonic function surface) of the sonic transducer unit, and is fixed to the wave transmitting-receiving surface of the sonic transducer unit via, for example, an adhesive layer. Contact Information Any inquiry concerning this communication or earlier communications from the examiner should be directed to EMILY P. PHAM whose telephone number is (571) 270-3046. The examiner can normally be reached MON-FRI 8:00AM-5:00PM. 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, DEDEI HAMMOND can be reached at (571) 270-7938. 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. 15 July 2026 /EMILY P PHAM/ Primary Examiner, Art Unit 2837
Read full office action

Prosecution Timeline

Aug 24, 2023
Application Filed
Jul 17, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
88%
Grant Probability
99%
With Interview (+13.4%)
2y 6m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 854 resolved cases by this examiner. Grant probability derived from career allowance rate.

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