Prosecution Insights
Last updated: August 17, 2026
Application No. 18/606,611

SYSTEMS AND METHODS FOR OPERATING AN OVEN APPLIANCE INCLUDING A COOKING ASSEMBLY

Non-Final OA §103
Filed
Mar 15, 2024
Examiner
BOGUE, JESSE SAMUEL
Art Unit
Tech Center
Assignee
Haier US Appliance Solutions Inc.
OA Round
2 (Non-Final)
79%
Grant Probability
Favorable
2-3
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allowance Rate
893 granted / 1127 resolved
+19.2% vs TC avg
Strong +21% interview lift
Without
With
+20.6%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
23 currently pending
Career history
1143
Total Applications
across all art units

Statute-Specific Performance

§101
1.3%
-38.7% vs TC avg
§103
46.8%
+6.8% vs TC avg
§102
30.1%
-9.9% vs TC avg
§112
20.0%
-20.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1127 resolved cases

Office Action

§103
DETAILED ACTION The Amendment filed 6/23/2026 has been entered. Claims 1-3,5-12,14-19 remain pending in the application. Claim Rejections - 35 USC § 103 The following is a quotation of pre-AIA 35 U.S.C. 103(a) 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. 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. Claims 1-3,7-12,16-18 are rejected under 35 U.S.C. 103 as being unpatentable over US Publication 201903277796 to Hannah in view of US Patent 9119231 to Johnson and further in view of US Publication 20040099656 to Sauter. As to claim 1, Hannah A method of operating an oven appliance, the oven appliance comprising a cabinet defining a cooking chamber (Fig 2), one or more heating elements (124,126) positioned within the cooking chamber, and a cooking accessory (18) provided within the cooking chamber, the cooking accessory comprising a temperature sensor (28) embedded within the cooking accessory (Par 0027), the method comprising: receiving an oven input indicative of an operation mode of the oven appliance (Par 0032-0034); determining a pre-heat cycle in response to receiving an input indicative of the operation mode (Par 0039); performing a pre-heat sequence of the oven appliance based on the determined pre-heat cycle (Par 0039). Hannah does not expressly disclose determining a pre-heat temperature, the pre-heat sequence having a predetermined pre-heat condition; detecting completion of the predetermined pre-heat condition; and initiating a user notification at a user interface in response to detecting completion of the predetermined pre-heat condition, wherein the user notification comprises an alert that the cooking accessory is preheated and ready to receive a food item to be cooked, where the pre-heat sequence comprises: operating the one or more heating elements at a first predetermined heat setting; determining, via the temperature sensor, that a first predetermined temperature has been reached, wherein the first predetermined temperature is lower than the pre-heat temperature; reducing the heat setting of the one or more heating elements to a second predetermined heat setting in response to determining that the first predetermined temperature has been reached; determining, via the temperature sensor, that a predetermined pre-heat temperature has been reached; and maintaining the predetermined pre-heat temperature. Johnson discloses determining a pre-heat temperature, the pre-heat sequence having a predetermined pre-heat condition (Change from Phase 1 to Phase 2, and from Phase 2 to Phase 3); detecting completion of the predetermined pre-heat condition (Col 5, Line 50-55, Col 6, Line 4-10, Col 6, Line 46-Col 7, Line 53; Col 1, Line 5-25), wherein performing the pre-heat sequence comprises: operating the one or more heating elements at a first predetermined heat setting (Johnson, Phase 1); determining, via the temperature sensor, that a first predetermined temperature has been reached (Johnson: Col 11, Line 5-25), wherein the first predetermined temperature is lower than the pre-heat temperature (Johnson: Col 11, Line 5-25); reducing the heat setting of the one or more heating elements to a second predetermined heat setting in response to determining that the first predetermined temperature has been reached (Johnson: Phase 1 to Phase 2 power reduction to heating element Fig 6, Col 11, Line 5-25); determining, via the temperature sensor, that a predetermined pre-heat temperature has been reached (Johnson: Col 11, Line 5-25); and maintaining the predetermined pre-heat temperature (Johnson: Maintaining oven temperature in Phase 3, Col 11, Line 5-25). Sauter discloses initiating a user notification at a user interface in response to detecting completion of the predetermined pre-heat condition (Par 0019). At the time of invention, it would have been obvious to one of ordinary skill in the art to modify Hannah to include the pre-heat sequence having a predetermined pre-heat condition, wherein performing the pre-heat sequence comprises: operating the one or more heating elements at a first predetermined heat setting; determining, via the temperature sensor embedded within the cooking accessory, that a first predetermined temperature has been reached, wherein the first predetermined temperature is lower than the pre-heat temperature; reducing the heat setting of the one or more heating elements to a second predetermined heat setting in response to determining that the first predetermined temperature has been reached; determining, via the temperature sensor embedded within the cooking accessory, that a predetermined pre-heat temperature of the cooking accessory has been reached; and maintaining the predetermined pre-heat temperature of the cooking accessory detecting completion of the predetermined pre-heat condition (by Hannah sensor 28 as disclosed for controlling preheat stage Par 0039, Par 0041); and initiating a user notification at a user interface in response to detecting completion of the predetermined pre-heat condition, wherein the user notification comprises an alert that the cooking accessory is preheated and ready to receive a food item to be cooked using the teachings of Johnson and Sauter so as to preheat the oven to the steady state temperature for optimized cooking as set within Hannah, and to alert the user when the preheating is accomplished. This is further improved by the teachings of Johnson so as to scale the heating up in two phases (Johnson Fig 6, Col 6, Line 4-10, Col 6, Line 46-Col 7, Line 53) so as to accommodate an user early insertion of food while providing a steady power to food items in the oven. As to claim 2, Hannah discloses receiving the oven input comprises: receiving a food selection from a plurality of predetermined food options, the food selection corresponding to the food item to be cooked (Par 0032-0034). As to claim 3, Hannah discloses receiving the oven input comprises: receiving a texture selection from a plurality of predetermined texture options, the texture selection corresponding to a cooking preference of the food item to be cooked (Par 0032-0034). As to claim 4, Hannah discloses the oven appliance comprises one or more heating elements (Fig 2), wherein the cooking accessory comprises a temperature sensor embedded therewithin (Hannah, Par 0034)(Johnson 113) wherein performing the pre-heat sequence comprises: operating the one or more heating elements at a first predetermined heat setting (Johnson, Phase 1); determining, via the temperature sensor, that a first predetermined temperature has been reached (Johnson: Col 11, Line 5-25), wherein the first predetermined temperature is lower than the pre-heat temperature (Johnson: Col 11, Line 5-25); reducing the heat setting of the one or more heating elements to a second predetermined heat setting in response to determining that the first predetermined temperature has been reached (Johnson: Phase 1 to Phase 2 power reduction to heating element Fig 6, Col 11, Line 5-25); determining, via the temperature sensor, that a predetermined pre-heat temperature has been reached (Johnson: Col 11, Line 5-25); and maintaining the predetermined pre-heat temperature (Johnson: Maintaining oven temperature in Phase 3, Col 11, Line 5-25). As to claim 7, Hannah discloses measuring, via a temperature sensor embedded within the cooking accessory (28 in 18), a temperature profile of the cooking accessory following performing the pre-heat sequence (Hannah: Par 0040-0042) (Johnson: Fig 6); and determining a food item is cooked within the cooking accessory based on the temperature profile of the cooking accessory (Hannah: Par 0040-0042). As to claim 8, Hannah discloses initiating a second user notification at the user interface in response to determining the food item is cooked within the cooking accessory (Sauter: Par 0019) where such end user notification would be obvious to notify the user food is done so as to not overcook the food. As to claim 9, Hannah discloses the user interface is a user interface of an external device in operative communication with a controller of the oven appliance (Par 0025). As to claim 10, Hannah discloses An oven appliance comprising: a cabinet defining a cooking chamber; one or more heating elements positioned within the cooking chamber a cooking accessory positioned within the cooking chamber, wherein the cooking accessory comprises a temperature sensor embedded within the cooking accessory; and a controller operable for: receiving an oven input indicative of an operation mode of the oven appliance; determining a pre-heat temperature in response to receiving an input indicative of the operation mode; performing a pre-heat sequence of the oven appliance based on the determined pre-heat temperature, the pre-heat sequence having a predetermined pre-heat condition, wherein performing the pre-heat sequence comprises: operating the one or more heating elements at a first predetermined heat setting; determining, via the temperature sensor embedded within the cooking accessory, that a first predetermined temperature has been reached, wherein the first predetermined temperature is lower than the pre-heat temperature; reducing the heat setting of the one or more heating elements to a second predetermined heat setting in response to determining that the first predetermined temperature has been reached; determining, via the temperature sensor embedded within the cooking accessory, that a predetermined pre-heat temperature of the cooking accessory has been reached; and maintaining the predetermined pre-heat temperature of the cooking accessory; detecting completion of the predetermined pre-heat condition; and initiating a user notification at a user interface in response to detecting completion of the predetermined pre-heat condition, wherein the user notification comprises an alert that the cooking accessory is preheated and ready to receive a food item to be cooked (as cited and rejected Claim 1 above). As to claim 11, Hannah discloses receiving the oven input comprises: receiving a food selection from a plurality of predetermined food options, the food selection corresponding to the food item to be cooked (Par 0032-0034). As to claim 12, Hannah discloses receiving the oven input comprises: receiving a texture selection from a plurality of predetermined texture options, the texture selection corresponding to a cooking preference of the food item to be cooked (Par 0032-0034). As to claim 16, Hannah discloses measuring, via a temperature sensor embedded within the cooking accessory (28 in 18), a temperature profile of the cooking accessory following performing the pre-heat sequence (Hannah: Par 0040-0042) (Johnson: Fig 6); and determining a food item is cooked within the cooking accessory based on the temperature profile of the cooking accessory (Hannah: Par 0040-0042). As to claim 17, Hannah discloses initiating a second user notification at the user interface in response to determining the food item is cooked within the cooking accessory (Sauter: Par 0019) where such end user notification would be obvious to notify the user food is done so as to not overcook the food. As to claim 18, Hannah discloses the user interface is a user interface of an external device in operative communication with a controller of the oven appliance (Par 0025). Claims 5-6,14-15 are rejected under 35 U.S.C. 103 as being unpatentable over US Publication 201903277796 to Hannah as applied to Claim 1,10 above and further in view of US Publication 20230172383 to Wade. As to claim 5, Hannah discloses preheating the system up toa present temperature (Johnson: Col 11, Line 5-25) but does not expressly disclose maintaining the predetermined pre-heat temperature comprises: detecting, via the temperature sensor, a temperature of the cooking accessory is outside a pre-heat threshold of the predetermined pre-heat temperature, which is taught by Wade (Par 0083). At the time of invention, it would have been obvious to one of ordinary skill in the art to have Hannah in light of the teachings of Wade to monitor the temperature sensor and determine it is outside the temperature threshold (ie. below the preheat temperature it has previously set), and to maintain preheating as a result of the determination to effectively reach the preheat temperature. As to claim 6, Hannah discloses maintaining the predetermined pre-heat temperature further comprises: adjusting the heat setting of the one or more heating elements in response to detecting the temperature of the cooking accessory is outside the pre-heat threshold (Wade Par 0083). As to claim 14, Hannah discloses preheating the system up toa present temperature (Johnson: Col 11, Line 5-25) but does not expressly disclose maintaining the predetermined pre-heat temperature comprises: detecting, via the temperature sensor, a temperature of the cooking accessory is outside a pre-heat threshold of the predetermined pre-heat temperature, which is taught by Wade (Par 0083). At the time of invention, it would have been obvious to one of ordinary skill in the art to have Hannah in light of the teachings of Wade to monitor the temperature sensor and determine it is outside the temperature threshold (ie. below the preheat temperature it has previously set), and to maintain preheating as a result of the determination to effectively reach the preheat temperature. As to claim 15, Hannah discloses maintaining the predetermined pre-heat temperature further comprises: adjusting the heat setting of the one or more heating elements in response to detecting the temperature of the cooking accessory is outside the pre-heat threshold (Wade Par 0083). Claims 19 are rejected under 35 U.S.C. 103 as being unpatentable over US Publication 201903277796 to Hannah as applied to Claim 10 above and further in view of US Publication 20230380626 to Lavins. As to claim 19, Hannah does not expressly disclose the cooking accessory comprises a first plate, a second plate, and a hinge accessory, wherein the first plate and the second plate are coupled together via the hinge accessory, wherein the cooking accessory is moveable between an open position and a closed position. Lavins discloses a cooking accessory for insertion into a heating chamber cooking accessory comprises a first plate, a second plate, and a hinge accessory (Par 0041), wherein the first plate and the second plate are coupled together via the hinge accessory, wherein the cooking accessory is moveable between an open position and a closed position (Fig 4). At the time of invention, it would have been obvious to one of ordinary skill in the art to modify Hannah to include the cooking accessory comprises a first plate, a second plate, and a hinge accessory, wherein the first plate and the second plate are coupled together via the hinge accessory, wherein the cooking accessory is moveable between an open position and a closed position using the teachings of Lavins so as to allow for the oven cooking of certain foods such as Paninis as desired by user. Response to Arguments Applicant’s arguments with respect to claims have been considered. With regards to Applicant’s argument that “Claim 1 as amended, now recites a method of operating an oven appliance wherein the pre-heat sequence is controlled based on temperature feedback measured directly from a temperature sensor embedded within the cooking accessory itself. Specifically, amended claim1 requires determining that both a first predetermined temperature has been reached and a predetermined pre-heat temperature have been reached, with these determination being made via the temperature sensor embedded within the cooking accessory. Such limitations are neither taught nor suggested by the materials cited. In rejecting original claim 4, the Examiner's combination proposes modifying Hannah's cooking method with the pre-heat algorithm of Johnson. While Johnson teaches a pre-heat algorithm, its control logic is based on the temperature of the oven cavity, not a specific cooking assembly within it. Johnson provides no teaching or suggestion of embedding a sensor in a cooking accessory and using that accessory's temperature as the primary input to drive the transitions between its pre-heat phases.” the examiner is unconvinced. Hannah expressly states that the preheat stage (Par 0039) and all other stages are controlled (Par 0041) by the embedded (Par 0027) temperature sensor (28). As such it would be obvious to use to improved heating routine of Johnson as it would readily apply to the sensor and control thereof of the preheat of Hannah. Further, it would be understood and obvious that the temperature desired to contact the food in Johnson would also be the same desire in Hannah, ie the preheat would be related directly to the temperature of that would directly contact the food, as is stated throughout Hannah (Par 0041). With regards to Applicant’s argument that “Hannah teaches using its sensor to "directly measure a temperature of a food item" during the cooking cycle to transition between cooking stages, not pre-heat stages (Hannah, para. [0041]). There is no teaching in Hannah to use its food temperature sensor (30) to determine when a first pre-heat temperature is reached, reduce the heat setting, and then determine when a final pre-heat temperature is reached, all before food is even inserted” the examiner is unconvinced. Hannah expressly states that the temperature sensor (28) is embedded in the utensil container (18), and that the preheat is a stage (Par 0039) and all stages are controlled by the embedded sensor (Par 0041-0042). And it is the combination with the improvement of Johnson that is used to better control the preheat routine where the control would be maintained using the temperature sensor embedded in the utensil as disclosed in Hannah so as to reach appropriate temperature for the food, at the food, without burning it or applying a too small amount of heat due to thermal transience or absorption by the utensil. Conclusion THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any extension fee pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JESSE SAMUEL BOGUE whose telephone number is (571)270-1406. The examiner can normally be reached M-F 8:00-5:00. 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, Mark Laurenzi can be reached on (571) 270-7878. 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. JESSE SAMUEL. BOGUE Examiner Art Unit 3748 /JESSE S BOGUE/Primary Examiner, Art Unit 3746
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Prosecution Timeline

Mar 15, 2024
Application Filed
Apr 29, 2026
Non-Final Rejection mailed — §103
Jun 23, 2026
Response Filed
Jul 16, 2026
Final Rejection mailed — §103
Jul 28, 2026
Response after Non-Final Action

Precedent Cases

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

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Prosecution Projections

2-3
Expected OA Rounds
79%
Grant Probability
99%
With Interview (+20.6%)
2y 6m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 1127 resolved cases by this examiner. Grant probability derived from career allowance rate.

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