Prosecution Insights
Last updated: July 17, 2026
Application No. 18/582,455

Steamer

Non-Final OA §102§103§112
Filed
Feb 20, 2024
Priority
Feb 21, 2023 — provisional 63/447,249
Examiner
AYALEW, TINSAE B
Art Unit
1711
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Vornado Air LLC
OA Round
3 (Non-Final)
76%
Grant Probability
Favorable
3-4
OA Rounds
2m
Est. Remaining
85%
With Interview

Examiner Intelligence

Grants 76% — above average
76%
Career Allowance Rate
461 granted / 610 resolved
+10.6% vs TC avg
Moderate +9% lift
Without
With
+9.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
17 currently pending
Career history
633
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
82.3%
+42.3% vs TC avg
§102
4.1%
-35.9% vs TC avg
§112
11.9%
-28.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 610 resolved cases

Office Action

§102 §103 §112
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 5/21/26 has been entered. Response to Amendment Amendments submitted on 5/13/26 include amendments to the claims. Claims 1-20 are pending. Claims 1, 3-9, 11, 13, 15-16, 18-20 have been amended. Response to Arguments Applicant's arguments filed 5/13/26 have been fully considered but are not found to be persuasive. Regarding applicant’s arguments that none of the references teach a thick film heating element, and that Lai only teaches a u-shaped heating element and not a thick film heating element: Lai teaches a film heating element 58/60 (see abstract, paragraph [0068], figures 9-10, whereby the film heating element 58/60 is shown as having a thickness that reads on a thick film heating element under the broadest reasonable interpretation). The claims do not specify any particular shape of the heating element. Regarding applicant’s arguments that none of the references teach dual fluid pathways extending from the liquid inlet such that liquid flows in opposing directions through the dual fluid pathways while being heated by the thick film heating element and converted to steam: Lai teaches that the flow chamber 80, 82 includes a liquid inlet 72 and a winding, or back-and-forth fluid pathway (reads on dual fluid pathways; see also multiple branched exit pathways at 84, as shown in figure 12, which also reads on dual fluid pathways) extending from the liquid inlet 72 through which liquid is able to flow while being heated by the film heating element 58/60 and converted to steam (see abstract, paragraphs [0068]-[0070], figures 12-21). Regarding applicant’s arguments that none of the references teach that the flow chamber comprises a metal plate having the at least one fluid pathway stamped into the metal plate, because Chen teaches stamping heat conductive bumps rather than stamping a fluid pathway: Lai teaches in figures 13-16 and paragraph [0069] that the flow chamber 80, 82 is a flat metal plate having the at least one fluid pathway therein. Lai does not explicitly teach that the fluid pathway is stamped on the metal plate. Chen et al. teaches a steamer (see abstract, paragraph [0003]) and that the bottom plate 103 may be of a metal material and that stamping on the metal plate allows for easy and cost-effective manufacturing (see paragraphs [0022], [0043]-[0044]). Since both Lai and Chen et al. teach steamers it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention that the flow chamber in the system by Lai may be of metal material with the fluid pathway stamped thereon so as to allow for easy and cost-effective manufacturing, as shown to be known and conventional by Chen et al. Hence, Lai teaches that the fluid pathway is formed on a metal plate and Chen et al. is only relied upon for the teaching of the use of stamping to manufacture said fluid pathway. 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 1-20 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. The term “thick film heating element” in claims 1, 4-9, 11, 13, 15, 16 and 18-20 is a relative term which renders the claim indefinite. The term “thick film heating element” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. It is unclear what size of the film heating element is being claimed. Claim Rejections - 35 USC § 102 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. 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, 3-11, 13, 15-16, 18-20 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Lai (US20210277589). Regarding claims 1, 3, 5 and 15, Lai teaches a steamer is provided for creating steam from a liquid (see abstract), the steamer comprising: a reservoir 28 capable of storing the liquid (see paragraph [0089], figure 6); a pump 40 capable of pumping the liquid from the reservoir 28 (see paragraph [0089], figure 6); a steam generation assembly, the steam generation assembly comprising (i) a film heating element 58/60 (see abstract, paragraph [0068], figures 9-10, whereby the film heating element 58/60 is shown as having a thickness that reads on a thick film heating element under the broadest reasonable interpretation); and (ii) a flow chamber 80, 82 positioned adjacent to the film heating element, 58/60 where the flow chamber 80, 82 including a liquid inlet 72 capable of receiving the liquid pumped by the pump 40 (see abstract, paragraphs [0068]-[0070], figures 12-21) and at least one winding, or back-and-forth fluid pathways extending from the liquid inlet 72, wherein the pump 40 pumps the liquid through the at least one winding, or back-and-forth fluid pathway such that the liquid is heated by the adjacent film heating element 58/60 and converted to steam (see figures 12, 17-18, paragraphs [0068]-[0070]) (reads on claim 1); one or more steam outlets 48 positioned adjacent to a top of the flow chamber 80, 82 and configured to discharge steam produced in the winding, or back-and-forth fluid pathway (see paragraphs [0074]-[0076], figures 1-4, 6-8, 12, 26, 29-30) (reads on claim 3); the flow chamber 80, 82 has a first side and a second side opposite the first side, the at least one fluid pathway being formed within the flow chamber 80, 82, and wherein the film heating element 58/60 is positioned adjacent to the first side of the flow chamber 80, 82 (see figures 12, 17-18, paragraphs [0068]-[0070]) (reads on claim 5); a temperature control regulator 68 capable of regulating a temperature of the film heating element 58/60 (see paragraph [0079], figure 9); a power supply 22, 26 configured to provide power to the film heating element 58/60 (see paragraphs [0066], [0068], figures 1-4) (reads on claim 15). Regarding claims 4 and 16, Lai teaches the limitations of claims 1 and 15. Lai also teaches in paragraphs [0069]-[0070], figures 12-21 that substantially an entire length of the at least one fluid pathway is positioned adjacent to the film heating element 58/60 such that liquid flowing through the at least one fluid pathway is heated along substantially the entire length of the at least one fluid pathway. Regarding claim 6, Lai teaches the limitations of claim 1. Lai also teaches that the winding, or back-and-forth fluid pathway includes dual pathways (see e.g. flow in opposing directions, as shown in figure 12, which reads on dual fluid pathways; see also multiple branched exit pathways at 84, as shown in figure 12, which also reads on dual fluid pathways) extending from the liquid inlet 72 such that liquid flows in opposing directions through the dual pathways while being heated by the film heating element 58/60 and converted to steam (see figures 12, 17-18, paragraphs [0068]-[0070]). Regarding claims 8-11, 18-20, Lai teaches a steam generation assembly (see abstract), the steam generation assembly comprising: a film heating element 58/60 (see abstract, paragraph [0068], figures 9-10, whereby the film heating element 58/60 is shown as having a thickness that reads on a thick film heating element under the broadest reasonable interpretation); a flow chamber 80, 82 positioned adjacent to the film heating element 58/60, the flow chamber 80, 82 including a liquid inlet 72 and a winding, or back-and-forth fluid pathway (reads on claim 10) extending from the liquid inlet 72 through which liquid is able to flow while being heated by the film heating element 58/60 and converted to steam, wherein substantially an entire length of the fluid pathway is positioned adjacent to the film heating element (see abstract, paragraphs [0068]-[0070], figures 12-21); and one or more steam outlets 48 fluidly coupled to the winding, or back-and-forth fluid pathway (see paragraphs [0074]-[0076], figures 1-4, 12, 26, 29-30) (reads on claims 8 and 18); a temperature control regulator 68 capable of regulating a temperature of the film heating element 58/60 (see paragraph [0079], figure 9) (reads on claim 9); substantially an entire length of the winding, or back-and-forth fluid pathway is positioned adjacent to the film heating element 58/60 (see paragraphs [0069]-[0070], figures 12-21) (reads on claim 19); the winding, or back-and-forth fluid pathway includes dual pathways (see e.g. flow in opposing directions, as shown in figure 12, which reads on dual fluid pathways; see also multiple branched exit pathways at 84, as shown in figure 12, which also reads on dual fluid pathways) extending from the liquid inlet 72 such that liquid flows in opposing directions through the dual pathways while being heated by the film heating element 58/60 and converted to steam (see figures 12, 17-18, paragraphs [0068]-[0070]) (reads on claims 11 and 20). Regarding claims 7 and 13, Lai teaches the limitations of claims 1 and 9. Lai also teaches in figures 13-19, 21, paragraph [0068], a mounting member 62 coupled with the flow chamber 80, 82 and the film heating element 58/60 and the temperature control regulator 68 secured against the mounting member 62 on the side opposing the film heating element 58/60. 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. Claims 2, 12, 14 and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Lai (US20210277589) as applied to claims 1 and 8, and further in view of Chen et al. (EP3613895A1). Regarding claims 2, 12, Lai teaches the limitations of claims 1 and 8. Lai teaches in figures 13-16 and paragraph [0069] that the flow chamber 80, 82 is a flat metal plate having the at least one fluid pathway therein. Lai does not explicitly teach that the fluid pathway is stamped on the metal plate. Chen et al. teaches a steamer (see abstract, paragraph [0003]) and that the bottom plate 103 may be of a metal material and that stamping on the metal plate allows for easy and cost-effective manufacturing (see paragraphs [0022], [0043]-[0044]). Since both Lai and Chen et al. teach steamers it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention that the flow chamber in the system by Lai may be of metal material with the fluid pathway stamped thereon so as to allow for easy and cost-effective manufacturing, as shown to be known and conventional by Chen et al. Regarding claims 14 and 17, Lai teaches the limitations of claims 8 and 15. Lai teaches in figures 1-2, 4, 6, paragraph [0066], a handle 20 and a layer (see e.g. 18 or any of the parts disposed between 44 and 20, as shown in figure 6) positioned on at least one side of the steam generation assembly capable of preventing heat loss and heat transfer to the handle 20 of the steamer. Lai does not teach the sheet of insulation comprising silicone. Chen et al. teaches a steamer (see abstract, paragraph [0003]) and a sheet of silicone 106 positioned on a side of the steam generation assembly capable of preventing heat loss (see paragraphs [0006] and [0049]). Since both Lai and Chen et al. teach steamers it would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention that silicone may be used as insulation material on a side of the steam generation assembly in the system by Lai so as to provide the expected reduction in heat transfer, as shown to be known and conventional by Chen et al. Furthermore, it has been determined that the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination in Sinclair & Carroll Co. v. Interchemical Corp., 325 U.S. 327, 65 USPQ 297 (1945). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to TINSAE B AYALEW whose telephone number is (571)270-0256. The examiner can normally be reached Monday-Friday, 8:30am-5pm. 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, MICHAEL BARR can be reached at 571-272-1414. 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. /TINSAE B AYALEW/EXAMINER, Art Unit 1711
Read full office action

Prosecution Timeline

Show 1 earlier event
Mar 25, 2024
Response after Non-Final Action
Oct 16, 2025
Non-Final Rejection mailed — §102, §103, §112
Jan 16, 2026
Response Filed
Feb 13, 2026
Final Rejection mailed — §102, §103, §112
May 13, 2026
Response after Non-Final Action
May 21, 2026
Request for Continued Examination
May 22, 2026
Response after Non-Final Action
Jun 05, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12680213
WASHING APPARATUS WITH MECHANICAL STABILIZER
2y 2m to grant Granted Jul 14, 2026
Patent 12674269
WASHING MACHINE DOOR ASSEMBLY
3y 2m to grant Granted Jul 07, 2026
Patent 12661693
SUBSTRATE PROCESSING MODULE AND SUBSTRATE PROCESSING DEVICE PROVIDED WITH SAME
2y 3m to grant Granted Jun 23, 2026
Patent 12655568
CLOTHING TREATMENT APPARATUS
2y 3m to grant Granted Jun 16, 2026
Patent 12655566
CLOTHING PROCESSING APPARATUS
2y 1m to grant Granted Jun 16, 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
76%
Grant Probability
85%
With Interview (+9.2%)
2y 7m (~2m remaining)
Median Time to Grant
High
PTA Risk
Based on 610 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