Prosecution Insights
Last updated: April 19, 2026
Application No. 18/599,992

AIR CONDITIONING SYSTEM WITH VAPOR INJECTION COMPRESSOR

Non-Final OA §112§DP
Filed
Mar 08, 2024
Examiner
CRENSHAW, HENRY T
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Waterfurnace International Inc.
OA Round
1 (Non-Final)
76%
Grant Probability
Favorable
1-2
OA Rounds
2y 11m
To Grant
91%
With Interview

Examiner Intelligence

Grants 76% — above average
76%
Career Allow Rate
753 granted / 992 resolved
+5.9% vs TC avg
Moderate +15% lift
Without
With
+14.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
17 currently pending
Career history
1009
Total Applications
across all art units

Statute-Specific Performance

§101
1.1%
-38.9% vs TC avg
§103
45.4%
+5.4% vs TC avg
§102
12.3%
-27.7% vs TC avg
§112
37.6%
-2.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 992 resolved cases

Office Action

§112 §DP
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 . This action is in response to the filing made 3/8/2024. Claims 1-19 are pending. Allowable Subject Matter The claims will be allowable provided a terminal disclaimer is filed, and the 112 rejections are overcome without broadening the scope of the claims. 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. Claim 10 is 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 10 The claim recites, “compute a pressure difference between a desired refrigerant pressure and a detected refrigerant pressure at the EEEV”. This is not clear because if the pressure being measured is a high pressure upstream of the expansion valve, or a low pressure downstream of the expansion valve. Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. Claims 1-19 are rejected on the ground of nonstatutory double patenting as being unpatentable over: claims 1-20 of U.S. Patent No. 11,927,377 (‘377), claims 1-21 of US Patent 11,480,372 (‘372), claims 1-20 of US Patent 10,753,661 (‘661), and US 2014-0020637 to Yamin claims 1-22 of US Patent 10,119,738 (‘738). Although the claims at issue are not identical, they are not patentably distinct from each other. In the case of the ‘377 patent, the present application’s independent claims are essentially the same, except that the ‘377 patent’s claims recite a “diverter” while the present application’s claims recite a “fluid divider”. In the specifications and figures of ‘377 and the present application, these are merely different terms, for the same structure, at the same location, in the same system. The present application’s claim language adds details on the position and function provided by the fluid divider, (i.e., the fluid divider being positioned to direct a portion of the refrigerant from the refrigerant circuit to the economizer circuit in the heating mode and to direct none of the refrigerant from the refrigerant circuit to the economizer circuit in the cooling mode). However, this added detail would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the invention, given that the claimed system layouts of both documents are the same, they operate in the same or similar modes, and diverters/dividers have to be at the same position and function the same way for each system to perform their claimed operating modes. In the case of the ‘372 patent, the comments above regarding the “fluid divider” and diverter also apply in this case. Further, in the independent claims of both the ‘372 patent and the present application, two different expansion valves (the EPEV and EEEV) are claimed, and are arranged in the same fashion and perform the same functions in various modes. However, the present application adds additional details to describe how these valves function in different operating modes. This added detail is obvious to one of ordinary skill in the art, prior to the effective filing date, because the same valves, located in the same places in both system layouts, will necessarily perform in the same manner in the same operating modes. In the case of the ‘661 patent, the comments above regarding the “fluid divider” and diverter also apply in this case. The ‘661 patent’s independent claims add some functional details regarding the expansion valves that can also be performed by the structure of the instant application, similar to the situation discussed in the immediately preceding discussion of the ’372 patent. While the claims of both documents recite heat exchangers, the ‘661 patent’s claims further limit such heat exchangers to “coaxial” heat exchangers.” However, the use of coaxial heat exchangers is obvious, to one of ordinary skill in the art, prior to the effective filing date, in view of US 2014-0020637 to Yamin, which teaches that coaxial heat exchangers can be interchanged with other types of heat exchangers (par. 47). In the case of the ‘738 patent, the comments above regarding the “fluid divider” and diverter also apply in this case. The ‘738 patent independent claims also limit the heat exchangers to co-axial heat exchangers, and limits the compressor to a scroll compressor, while the present application does not limit the heat exchangers and compressor to any specific type. Consequently the present application would be obvious to one of ordinary skill in the art, prior to the effective filing date, in view of the ‘738 patent, because the present application is a broader version of the device than that found in the ‘738 patent.. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to HENRY T CRENSHAW whose telephone number is (571)270-1550. The examiner can normally be reached M-F 9:00 am to 5:00 pm. 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, JD Fletcher can be reached on 571-270-5054. 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. /HENRY T CRENSHAW/Primary Examiner, Art Unit 3763
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Prosecution Timeline

Mar 08, 2024
Application Filed
Nov 21, 2025
Non-Final Rejection — §112, §DP (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12584669
REFRIGERATION SYSTEM
2y 5m to grant Granted Mar 24, 2026
Patent 12578137
REFRIGERATOR WITH FILTER HAVING PHOTOCATALYST
2y 5m to grant Granted Mar 17, 2026
Patent 12578133
IMPROVED COOLING SYSTEM CONTROL
2y 5m to grant Granted Mar 17, 2026
Patent 12571400
VARIABLE FREQUENCY DRIVE (VFD) SURGE DETECTION AND RESPONSE
2y 5m to grant Granted Mar 10, 2026
Patent 12560349
AIR CONDITIONING SYSTEM
2y 5m to grant Granted Feb 24, 2026
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
76%
Grant Probability
91%
With Interview (+14.9%)
2y 11m
Median Time to Grant
Low
PTA Risk
Based on 992 resolved cases by this examiner. Grant probability derived from career allow rate.

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