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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on February 3, 2026 has been entered.
Response to Arguments
Applicant's arguments filed with the RCE have been fully considered but they are only persuasive to overcome the anticipation rejection. Sankar and Lisi are maintained as the basis of a §103 obviousness rejection. In addition to these two references:
Hellinger (US 2012/0181858) is relied upon for its teaching of providing wireless power (as in Sankar) to a magnetic levitation train (see at least the abstract).
The Applicant’s Admitted Prior Art (“APA”; par 28) is relied upon for its teaching of introducing an electrical driver current into the transmitting coil.
Claims 11 and 18, and their dependent claims, are obvious in view of these four references.
The Applicant’s remarks are not persuasive for the following reasons:
Pages 11-13 repeat the entirety of the independent claims. There are no actual arguments included.
Pages 13-14, bridging paragraph, summaries Sankar’s impedance network 102 and auto-tuning network 105. There are no actual arguments included in this paragraph.
In the middle of page 14, the Applicant alleges that Sankar does not teach that its receiver is movable along its transmitter. To the contrary, Sankar clearly discloses that its transmitter/receiver are physically separate devices. Further, paragraph 36 begins with “On detecting a wireless power receiver …”. This indicates that there are times when the receiver is not present – in other words, it moves towards/away from the transmitter. “move along and/or over” is broad and is not limiting to train movements over a track. The Examiner agrees that Sankar does not disclose a train system, but the Applicant is not making this argument. The contention that Sankar’s pieces don’t move relative to each other is incorrect.
In the bridging paragraph of pages 14-15, the Applicant contends that Sankar does not disclose an electromagnetic transport system. The Examiner agrees. It is for this reason that the §102 rejection is withdrawn and Hellinger is introduced. Taking Sankar’s wireless power system and applying it to a known wireless power device (Hellinger’s train) would have been within the level of one of ordinary skill in the art.
In the middle of page 15, the Applicant argues that Sankar does not disclose the introduction of the electrical drive current. First, this limitation was taken from claim 13 and the Applicant does not acknowledge or rebut the art rejection of that claim. Sankar discloses the option of including energy storing components in the impedance network (102) and any of these can discharge current into the transmitter coil “in addition to the primary current” that is provided by the Sankar source. To art rejection is updated to cite to APA (par 28) for this teaching.
At the bottom of page 15, the Applicant repeats the argument that Sankar’s parts are not moveable relative to each other. Within the same paragraph (bridging pages 15-16), the Applicant argues that Sankar does not disclose that the increased resulting output active power. In response, the Examiner, again, directs the Applicant to the passive language used throughout the independent claims. For example, method claim 11 recites “feeding a primary electrical current [] into a transmitting coil” and “feeding a secondary-side compensation current into the receiving coil…”. The second wherein clause is entirely descriptive of the resulting consequences of these two “feeding” steps – there are no method steps in this paragraph– just descriptions of the inherent magnetic and electrical effects of the secondary-side compensation current. “changes a phase shift”, “in such a way that”, “a resulting output active power” – all of these phrases are descriptive. If the combination discloses the associated structure (transmitter, receiver) and functionality (feeding primary current, feeding compensation current), then the evidence supports the interpretation that the combination’s structure will react in the same way (i.e. an increase in the active output power as compared to not making any compensation current additions).
If the Applicant will not address the language of the claim or the Examiner’s interpretation, then it is unclear how they can persuasively overcome the prior art.
On page 16, the Applicant repeats the rebutted argument that Sankar does not disclose “no storage elements are connected in series with the transmitting coil”. In response, the Examiner directs the Applicant to their admission that “it is readily apparent that SANKAR’s disclosure does not expressly disclose a series connection between components of the impedance network 102 and wireless power transmitter 100a.” (Remarks, page 16, last 3 lines). The Applicant’s position that Sankar must explicitly disclose a negative limitation is not persuasive (Remarks, pages 16-17, bridging sentence).
Furthermore, the Sankar impedance network (102) is composed of “at least one or more of… a resistor” (see par 30, which lists various passive and active devices) – this means that the combination does not have to include any energy storage elements at all (let alone ones in series).
On page 17, the Applicant shifts back to arguing that Sankar’s compensation current, even if producing a phase shift, would not increase active output power. The Examiner, again, points out that the claim recites a passive chain of events that ends with the increase in output active power. The previous office action (as does this one) even included a distinct section heading to ensure that the Applicant was aware of this interpretation). Sankar has the structure and functionality necessary to begin the chain of events – it is therefore obvious that this chain will continue until the end (increase in active output power). Even the Applicant’s argument states that Sankar does not disclose that “such a phase shift will also lead to an increase…” (Remarks, page 17, middle). “lead” here indicates a passive chain of events effect. “also” means that Sankar’s passive chain of events would be in addition to the Applicant’s passive chain of events. It is the Applicant’s burden to prove otherwise (not just disagree) or amend the claim.
At the bottom of page 17, the Applicant states that their “claimed embodiments recite that the transferred active power is increased, whereas a general change in phase shift can also lead to a decrease in active power, or to an increase in reactive power, etc.” (first sentence of the last paragraph of page 17). It is unclear to what the Applicant is referred to by “claimed embodiments” – the claim only recites the (passive) increase in active power - there is no mention of a active power decrease or any reactive power. The prior art is not required to disclose various embodiments that only appear in the specification.
Regarding Lisi, the reference is cited for its teaching that Sankar’s functionality of feeding a compensation current into the receiver coil will produce a phase shift, as claimed. The Applicant does not dispute this interpretation. Rather, their argument is based on the incorrect premise that Lisi (as a secondary reference) must disclose all of the other limitations of the claim as well (Remarks, pages 18-19).
The art rejection is not “moot” (Remarks, page 19).
The §112(d) rejection of claim 21 is maintained. The claim is descriptive of conditions. These conditions would affect the device of claim 16 regardless of whether or not they are specifically identified or listed. For example, “aging” will affect any electrical device. Simply acknowledging this in a dependent claim does not introduce any narrowing structure or functionality that was not already present in the previous claim.
Specification
The disclosure is objected to because there are no section headings. This objection has been made before (See Non-Final 6/20/25), but has not been addressed. Appropriate correction is required.
Claim Objections
Claim 18 is objected to because the limitations that device what the secondary part comprises are scattered across the claim. The Applicant is requested to keep related structural components together.
Appropriate correction is required.
Claim Interpretation
Many of the claims (namely 11 and 18) contain passive voice phrasing. The Applicant has been put on notice that this type of language does not explicitly define the verb as a distinct method step (it describes something that happens to the device, not a distinct action/verb the device is/does). The Applicant has amended the claims in several locations, but passive voice remains throughout the claims.
Therefore, the presence of any remaining passive voice phrases will be interpreted as intentional. They will be interpreted as a description of inherent effects/consequence that happen to the subject. They are not distinct method steps or functionalities.
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.
Claims 18-19 are 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 18 is indefinite because of its use of passive voice language. Claim 18 has been amended to recite, “wherein, in addition to the primary current, an electrical drive current is introduced into the transmitting coil…”. The passive language is descriptive of something that happens to the device, outside the scope of the claim – not structure or functionality within the device itself.
The public would be confused as to the Applicant’s intention with this language – are they claiming the introduction of the electrical drive current or just describing its existence. The presence of the words implies that the Applicant intends to claim it, but the language they have selected indicates that they do not. Different readers would draw different conclusions and, therefore, the claim is indefinite.
Claim 19 is similarly rejected as it depends from, and inherit the deficiencies of, claim 18.
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.
Claim 21 is rejected under 35 U.S.C. 112(d) 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.
Claim 21 claim describes inherent parameters that would “influence” an inductive power transfer system (“result from at least one of”). All circuits degrade as they get old. All circuits are affected by temperature (cold or heat). The relative positions of primary/secondary components inherently affects their alignment and transfer efficiency. There are no method steps being recited.
The listed conditions would inherently affect the device of claim 16, even if they were not explicitly listed. The claim is entirely descriptive of conditions that could impact the claim 16 method.
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.
Claims 11-12, 14-19 and 21 are rejected under 35 U.S.C. 103 as being unpatentable over Sankar (US 2017/0040846) in view of Hellinger (US 2012/0181858) and the Applicant’s Admitted Prior Art (“APA”; paragraph 28). Alternatively, claims 11-12, 14-19 and 21 are rejected as unpatentable over Sankar in view of Lisi (US 2016/0043562), Hellinger and APA. The apparatus claims are treated first.
With respect to claim 18, Sankar discloses a device for inductive energy transmission (fig 1-1A; par 23-26, 34), comprising:
a primary part (100a);
a secondary part (100b), and
the primary part includes a supply unit (101 and/or 102) and a transmitting coil (103), the supply unit being configured to feed an electrical primary current into the transmitting coil to create a first alternating magnetic field for energy transmission,
the secondary part, which is moved (passive) along and/or over the primary part (par 36 discloses that the two Sankar parts are movable relative to each other, this is interpreted to include sideways motion [“moved along”] and lateral movement across [“over”]), includes a receiving coil (104) and at least one load (any/all of 106, 107, 108) which is electrically connected to the receiving coil,
wherein an electrical AC voltage is induced in the receiving coil by the first alternating magnetic field for energy transmission (inherent in wireless power systems), which causes an AC current on the secondary part and thus a power flow comprising an uncompensated active power to the at least one load connected to the receiving coil (which no tuning active, any power that reaches the rectifier is “uncompensated”), and
the secondary part further includes at least one compensation unit (105; shown in more detail in figure 1A) configured to feed a secondary-side compensation current into a receiving coil that generates a second alternating magnetic field which is superimposed on the first alternating magnetic alternating field for energy transmission and which induces a primary-side compensation voltage in the transmitting coil (these are inherent electrical effects, see analysis below),
wherein the primary-side compensation voltage induced (passive) in the transmitting coil changes (passive) a phase shift between the primary voltage dropping across the transmitting coil and the primary current flowing through the transmitting coil (par 25-26, see analysis below) such that, after the phase shift change, the primary part transmits the resulting output active power to the at least one load that is electrically connected to the receiving coil (power transfer to the load is through the receiving coil), which is increased compared to the uncompensated active power without a changed phase shift (par 25-26), and
wherein no electrical storage elements are connected in series with the transmitting coil on the primary part between the transmitting coil and the supply unit (par 30 – item 102 does not have to include any inductors or capacitors – when item 102 includes only a resistor, there are no series storage elements. Also, any capacitor(s)/inductor(s) included within 102 can be in parallel) to feed a primary-side compensation current for changing the phase shift between the electrical primary voltage dropping across the transmitting coil and the primary current flowing through the transmitting coil into the transmitting coil.
Sankar discloses a wireless power transmission system with a primary part (transmitter) and relatively movable secondary part (receiver). The transmitter uses coils to create a wireless AC magnet field between the two parts. Sankar discloses that the impedance network (102) “comprises one or more of passive electronic components [] resistor, capacitor…” (par 30). The “one or more of” indicates that the reference is enabling for as few as one of the listed components. This includes the embodiment in which there is only a resistor. Thus, there is at least one disclosed embodiment in which Sankar does not discloses any energy storage elements in series with the transmission coil. Further, Sankar’s network 102 can include only parallel energy storage elements.
The receiver includes an auto-tuning network that has similarly structure as disclosed by the Applicant (figure 2a – selectable switches to adjust how many capacitors are connected in parallel). Since Sankar discloses the same parallel-capacitor structure, its compensation current would inherently produce the same passive electrical effects – a reflected power wave, a phase shift on the transmitter side, and a change (increase/decrease depending on the direction of control) in power transfer efficiency. Sankar even expressly states that the capacitance selection is to adjust the level of received power (par 25-26). As noted above, the language and passive voice used in the wherein clause indicates passive/inherent effects (not any distinct actions). The Applicant does not contend otherwise; thus, this interpretation is presumed to be correct.
Since Sankar anticipates the structure and functionality of the device, it follows that it would experience the same effects. Lisi supports the interpretation that impedance control on the receiver side inherently affect a phase shift on the transmitter side (see par 42).
Alternatively, Sankar discloses a compensation circuit but does not expressly disclose it induces a phase shift in the transmitter. Lisi discloses that such a resulting effect would obviously happen (par 42). Sankar and Lisi are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmission systems with receiver impedance control. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify Sankar to include a transmitter voltage/current phase shift, as taught by Lisi. The motivation for doing so would have been to include known electrical effects that are the result of impedance control.
Sankar (alone or in combination with Lisi) does not expressly disclose the primary part is configured as a stator of an electromagnetic transport system or that the secondary part is configured as a transport unit of that system. Hellinger discloses that it is known to transfer wireless power to a magnetic levitation train. Thus, the combination teaches that the Sankar primary/secondary are the stator and transport of an electromagnetic transport system, wherein the secondary part is moved along and/or over the primary part, and the electromagnetic transport system is a magnetic levitation railroad system.
Sankar and Hellinger are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transfer systems. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to apply the Sankar primary/secondary parts and control techniques to the transport system taught by Hellinger. The motivation for doing so would have been to apply the wireless power transfer system to a device/method that requires it to achieve predictable results.
The combination (Sankar/Hellinger or Sankar/Lisi/Hellinger) does not expressly disclose the introduction of an electrical drive current in addition to the primary current. APA (par 28) teaches that this concept is known.
The combination and APA are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmission to electromagnetic transport systems. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify the combination to include this electrical drive current. The motivation for doing so would have been to achieve the known benefits of such a current.
With respect to claim 19, Sankar discloses the at least one compensation unit comprises at least one of:
at least electrically variable capacitor (see fig 1A, items Cn), and/or
at least one electrically variable coil (compensation network 105 is disclosed to include inductor(s) as well – see par 24), and/or
an interconnection of at least one electrically variable capacitor and one electrically variable coil (supported by par 24 and the icons in fig 1A, item 105).
With respect to claim 11, Sankar, Hellinger and APA combine to discloses the apparatus necessary to complete the recited method steps, and the references are analogous, as discussed above in the art rejection of claim 18. Alternative, claim 11 is obvious over Sankar in view of Lisi, Hellinger and APA.
With respect to claim 12, Sankar discloses the phase shift between the electrical primary voltage dropping across the transmitting coil and the primary current flowing through the transmitting coil is changed only by the primary-side compensation voltage caused by the secondary-side compensation current and induced in the transmitting coil (see fig 1 and 1A).
Sankar discloses that both sides have an impedance network (102, 105). While it is possible that the transmitter’s impedance network (102) can affect a phase shift – the operation of the two impedance networks are independent. Thus, when Sankar operates the receiver-side network, it, and only it, will affect the phase shift on the primary side (inherently or obviously).
With respect to claim 14, Sankar discloses a direct current is introduced into the transmitting coil with the electrical drive current (the parallel capacitor within 102 can only store/release DC power). “is introduced” is passive and does not include any information for how, when or why this DC is “introduced”. As a method claim, the claim should be limited to actual method steps.
With respect to claim 15, Sankar discloses the electrical primary voltage dropping across the transmitting coil and the primary current flowing through the transmitting coil are determined and transmitted to the compensation unit (par 25-26 – the voltage/current on the primary side is wirelessly transmitted to the secondary side), the method further comprising:
determining from the primary voltage and primary current transmitted to the compensation unit, the phase shift between primary voltage and primary current (see below); and
wherein, on the basis of the phase shift between primary voltage and primary current, the secondary-side compensation current is changed in order to bring the phase shift between primary voltage and primary current closer to zero or closer to 180 degrees (par 25-26 – Sankar uses the received power to determine how to adjust its impedance – this will inherently/obviously increase or decrease the phase shift. Any increase would be “closer” to 1800, any decrease would be “closer” to 00).
Sankar discloses a constant impedance adjustment as rectifier output voltage changes. This will result in the phase shift on the primary side being adjusted as well (either inherently or obviously). This phase shift change can only be an increase or decrease – this inherently brings the phase shift “closer” to none (00) or a lot (1800). The claim is broadly written and is anticipated by a coincidental phase shift change – Sankar is not required to disclose a purposeful control to make the phase shift be exactly 00 or 1800.
Sankar expressly discloses the control over the phase shift. Sankar does this in response to received power (“from the primary voltage and primary current transmitted to the compensation unit”). Sankar, therefore, appears to have a direct control from transmitted voltage/current to phase shift control (A [Wingdings font/0xE0] C). Sankar does not expressly disclose making a determination of the phase shift in between (A [Wingdings font/0xE0] B [Wingdings font/0xE0] C).
At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify Sankar to include a determination about the phase shift (either before or after the adjustment is made). The motivation for doing so would have been the obviousness of knowing the effect of the control the Sankar device. The skilled artisan, seeing that Sankar will affect phase shift would have been motivated to measure/determine what the phase shift is.
Further, the claim only broadly recites that “on the basis of the phase shift [] secondary side compensation current is changed”. 1) “on the basis of” does not explicitly recite how this information (phase shift) is used. Thus, the generic ability to know it reads on the claim language. 2) “is changed” is a passive voice phrase and does not explicitly recite any cause-and-effect control functionality. The claim does not recite: a) determine the phase shift; b) compare the phase shift to a threshold; and c) when the phase shift exceeds the threshold, change (not “is changed”) the compensation current.
The Applicant does not address or rebut this interpretation; thus, it is presumed to be correct.
With respect to claim 16, Sankar discloses, based on changes in the transmission conditions between the coils, the compensation unit adapts the secondary-side compensation current fed into the receiving coil (see below).
Sankar anticipates the structure of the compensation unit. The components within the unit are switched in/out of the receiver as needed (par 32 – it is an “auto-tuning network”). Thus, as conditions change, the auto-tuning network will “adapt” the secondary-side compensation current fed into the receiver coil.
The claim does not define what “adapt” means. It can be interpreted as any adjustment/change.
With respect to claim 17, Sankar discloses adjusting the frequency of the primary current, which is fed from the supply unit into the transmitting coil arranged on the primary part to conform to an arising resonance frequency of a resonant electrical circuit, which is formed by at least the transmitting coil, the receiving coil, the compensation unit and the at least one load (see figs 1-1A). Sankar’s primary frequency is adjusted through changing the impedance that is placed in parallel with the transmitter coil. Any of the selected elements within the tuner (102; except for a series-connected capacitor) would inherently or obviously “adjust” the transmission frequency. This change can be in either direction (towards or away from resonance).
With respect to claim 21, the combination’s system would inherently (or obviously) be “influenced” by the same recited parameters. Sankar, for example, discloses that its transmitter periodically tests to see if the receiver is in proximity (par 31, 34). This, the relative position of the transmitter/receiver is critical to the functionality of the system. Also, it is inherent/obvious that moving the receiver closer to, or further away from, a transmitter will affect power transfer efficiency and how much power is actually received. This would then affect Sankar’s rectifier output voltage, which is the determining parameter to controlling the compensation circuit.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADI AMRANY whose telephone number is (571)272-0415. The examiner can normally be reached Monday - Friday, 8am-7pm.
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, Rex Barnie can be reached at 5712722800 x36. 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.
/ADI AMRANY/ Primary Examiner, Art Unit 2836