Prosecution Insights
Last updated: April 19, 2026
Application No. 18/549,534

FILM-LAMINATED METAL SHEET AND METHOD OF PRODUCING THE SAME, SUBSTRATE FOR FLEXIBLE ELECTRONICS, AND ORGANIC EL SUBSTRATE

Non-Final OA §103
Filed
Sep 07, 2023
Examiner
LAWLER, JOHN VINCENT
Art Unit
1787
Tech Center
1700 — Chemical & Materials Engineering
Assignee
JFE Steel Corporation
OA Round
1 (Non-Final)
56%
Grant Probability
Moderate
1-2
OA Rounds
3y 0m
To Grant
99%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allow Rate
183 granted / 328 resolved
-9.2% vs TC avg
Strong +43% interview lift
Without
With
+42.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
32 currently pending
Career history
360
Total Applications
across all art units

Statute-Specific Performance

§103
62.5%
+22.5% vs TC avg
§102
8.9%
-31.1% vs TC avg
§112
23.4%
-16.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 328 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 . DETAILED ACTION Election/Restrictions Applicant’s election of Group A, claims 12-25 without traverse in the reply filed on 17 Dec. 2025 is acknowledged. As part of their response, applicant cancelled claims 13, 15, 17, 19, 21, 23, 25, 27, 29, and 31. Claims 26, 28, and 30 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 17 Dec. 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 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. 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. 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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. Claims 12, 14, 16, 18, 22, and 24 are rejected under 35 U.S.C. 103 as being unpatentable over Lee et al. (EP 3812146 A1, priority 20 Jun. 2018, published 28 Apr. 2021, hereinafter Lee) in view of Morikawa et al. (US Patent Application 2015/0367605 A1, published 24 Dec. 2015, hereinafter Morikawa) and evidence provided by Sim (“1D hypo-crystals: A novel concept for the crystallization of stereo-irregular polymers,” Materials Today, Vol. 40, pp. 26-37, published Nov. 2020, hereinafter Sim), Engineering Toolbox (“Friction – Coefficients for Common Materials and Surfaces,” accessed 03 Jan. 2026, hereinafter Engineering Toolbox), and Engineers Edge (“Coefficient of Friction Equation and Table Chart,” accessed 03 Jan. 2026). Regarding claims 12, 22, and 24, Lee teaches a laminated steel sheet comprising a steel sheet and a first sheet disposed on the steel sheet, wherein the first sheet comprises an acrylic resin layer and a fluorinated polymer resin layer (Abstract and paragraph 0022). Lee teaches the acrylic resin is poly(methyl methacrylate), PMMA (paragraph 0036). Lee teaches the thickness of the acrylic layer is 10 to 50 µm (paragraph 0046), and the surface roughness Ra of the acrylic resin is 0.01 to 2.0 µm (claim 5). As set forth in MPEP 2144.05, in the case where the claimed range “overlap or lie inside ranges disclosed by the prior art”, a prima facie case of obviousness exists, In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). Therefore, it would have been obvious to one of ordinary skill in the art to have selected an arithmetic average roughness from the overlapping portion of the range taught by Lee because overlapping ranges have been held to be prima facie obviousness. The roughness parameters in the prior art references refer to profile-average roughness values, whereas the claims of the present invention cite roughness values averaged over a surface. It is the examiner’s position that given the overlaps in these values between the prior art profile values and the claimed surface-average values, the prior art references are teaching the claimed surface roughness values. Given that Lee teaches the average surface roughness Ra is 10 nm to 2.0 µm, it is the examiner’s position that the maximum peak height Sp and the maximum valley depth of Lee’s acrylic resin surface would inherently overlap with the claimed ranges of 0.3 µm or less and 1.0 µm or less, respectively, since these maximum peaks and valleys are 30 and 100 times, respectively, the lower range of the average roughness value taught by Lee. Lee teaches an embodiment in which his acrylic film is laminated to his metal sheet, since his additional layers between these two layers are all described as being optional. Lee does not disclose the kurtosis Sku of his acrylic film. Morikawa teaches a coated metallic material in which the surface of the shaped metal material has a kurtosis Rku value in the range of 2 to 3 (paragraph 0032). Given that Lee and Morikawa are drawn to metal sheets coated with polymeric materials, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have a polymer layer-metal interface with a kurtosis Rku as taught by Morikawa in the laminated steel sheet taught by Lee. Since Lee and Morikawa are both drawn to metal sheets covered with polymeric materials, one of ordinary skill in the art would have a reasonable expectation of success in having a polymer layer-metal interface with a kurtosis Rku as taught by Morikawa in the laminated steel sheet taught by Lee. Further, Morikawa teaches a surface of the shaped metal material having Rku of 5.0 or more has projecting portions in a sharp-pointed shape which may cause some sites to be not covered with the polymeric layer, which will reduce the joining power between the coated shaped metal material and the molded article of a thermoplastic resin composition (paragraph 0032). Although the Rku value taught by Morikawa is based on a roughness profile along a line, and the claimed Sku value is based on a roughness profile over a surface, it is the examiner’s position that the roughnesses represented by the roughness range taught by Lee and the Rku range of 2-3 taught by Morikawa results in surfaces that overlap with surfaces with the claimed average roughness, maximum peak height, and maximum valley depth. Regarding claim 14, Lee in view of Morikawa teaches the elements of claim 12, and Lee does not disclose the inclusion of any inorganic pigment or filler in the acrylic layer. Therefore, Lee in view of Morikawa teaches an acrylic layer with an ash content of essentially zero ppm. Regarding claim 16, Lee in view of Morikawa teaches the elements of claim 12. Lee in view of Morikawa does not disclose the static friction coefficient of his resin film. As evidenced by Engineers Edge, the static friction coefficient between polyethylene and steel is 0.2 (page 3, table). As evidenced by Engineering Toolbox, the static friction coefficient between PTFE (a fully fluorinated polymer) and steel is 0.05-0.2 (page 5, table). Lee teaches the use of partially fluorinated resin, polyvinylidene fluoride (PVdF), so it is the examiner’s position that the static friction coefficient of the coated metal sheet of Lee in view of Morikawa will have the claimed static friction coefficient. Regarding claim 18, Lee in view of Morikawa teaches the elements of claim 12. As evidenced by Sim, PMMA is typically a glassy polymer, since crystallization of PMMA is very difficult because its high monomeric friction slows down crystallization rate and the flexible alpha methyl and methyl ester side groups hinder packing of PMMA chains (page 28, 1st column, 1st paragraph). Thus, the amorphous PMMA polymer would have a ratio of ΔHc/ΔHm less than 0.30. Allowable Subject Matter Claim 20 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. Lee, Morikawa, and the references cited below do not teach or motivate a laminated metal sheet with resin film with a glass transition temperature between 120 and 200°C. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Fujimoto and Asona (EP 3372382 A1, published 12 Sep. 2018, hereinafter Fujimoto) teaches a metal laminated film (paragraph 0012) comprising a biaxially oriented polypropylene film (paragraph 0013) that has a surface average roughness Sra of 0.3-0.1 µm (paragraph 0018), maximum valley depth SRv of 0.1-0.5 µm (paragraph 0019), a maximum profile peak height of 0.3 to 1 µm (paragraph 0021), an ash content of 50 ppm or less (paragraph 0030), and a resin film thickness of 1-10 µm (paragraph 0023). Kanefuji et al. (JP 2016/193580 A, published 17 Nov. 2016) teaches a coated metal sheet with a polyester resin or acrylic resin with a thickness of 5-20 µm and a roughness of 20 nm or less. Minamidate et al. (US Patent Application 2018/0257978 A1, published 13 Sep. 2018) teaches a kurtosis Rku value of 1 to 3 from the standpoint of tactile properties of a display device. Atake and Yoshikawa (KR 960000732 B1, published 12 Jan. 1996) teaches a laminated metal sheet with a polycarbonate resin and a surface roughness of 1 µm or less. Hirano et al. (WO 2015/151773 A1, published 08 Oct. 2015) teaches a metal substrate with a resin coating with a thickness of 12-250 µm and a surface roughness of less than 30 nm. Inui et al. (JP 2006/160999 A, published 22 Jun. 2006) teaches a polyester film for laminating a metal plate, in which the polyester film has a roughness of 10 to 30 nm, a coefficient of dynamic friction of 0.1 to 0.2, and a thickness of 16 µm. Oshima et al. (US Patent Application 2010/0310824 A1, published 09 Dec. 2010) teaches a laminated metal sheet with a polyester resin layer with a roughness of 0.2 to 1.8 µm and a thickness of 5 to 50 µm. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOHN VINCENT LAWLER whose telephone number is (571)272-9603. The examiner can normally be reached on M - F 8:00 am - 5:00 pm ET. 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, Callie Shosho can be reached on 571-272-1123. 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 VINCENT LAWLER/Primary Examiner, Art Unit 1787
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Prosecution Timeline

Sep 07, 2023
Application Filed
Jan 03, 2026
Non-Final Rejection — §103
Mar 23, 2026
Interview Requested
Mar 30, 2026
Examiner Interview Summary
Mar 30, 2026
Applicant Interview (Telephonic)

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

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Prosecution Projections

1-2
Expected OA Rounds
56%
Grant Probability
99%
With Interview (+42.8%)
3y 0m
Median Time to Grant
Low
PTA Risk
Based on 328 resolved cases by this examiner. Grant probability derived from career allow rate.

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