Prosecution Insights
Last updated: April 19, 2026
Application No. 18/607,660

AIRCRAFT ENGINE HYBRID ELECTRIC THERMAL MANAGEMENT SYSTEM

Final Rejection §102§103
Filed
Mar 18, 2024
Examiner
TANENBAUM, TZVI SAMUEL
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
GE Aerospace Poland Sp Z O O
OA Round
2 (Final)
68%
Grant Probability
Favorable
3-4
OA Rounds
2y 8m
To Grant
78%
With Interview

Examiner Intelligence

Grants 68% — above average
68%
Career Allow Rate
516 granted / 764 resolved
-2.5% vs TC avg
Moderate +10% lift
Without
With
+10.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
25 currently pending
Career history
789
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
43.7%
+3.7% vs TC avg
§102
19.7%
-20.3% vs TC avg
§112
30.1%
-9.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 764 resolved cases

Office Action

§102 §103
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 . Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: flow control device (e.g. a valve) in claim 5. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. 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. Claim(s) 1-5, 7, 9 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Mochrie (US 20240077020). Regarding claim 1, Referring to Fig. 3, Mochrie teaches a propulsion system (e.g. a gas turbine engine, see par. 2) comprising: a thermal management system 300 defining a thermal management system flowpath 340 and operable to provide a flow of a fluid 342 to an electric machine 330 (see par. 442) and a power electronics assembly 370 through the thermal management system flowpath (see pars. 441-442), the thermal management system flowpath defining a first flowpath loop (e.g. the flowpath loop defined by the flow through pump 344, heat exchanger 410, and electric machine 330 but not assembly 370) and a second flowpath loop (e.g. the flowpath loop defined by the flow through pump 344 and assembly 370 but not heat exchanger 410), the power electronics assembly electrically connected to the electric machine (see par. 442), the thermal management system comprising: a first heat exchanger 351 thermally connected to the thermal management system flowpath and to the electric machine (see Fig. 3) along the first flowpath loop; and a second heat exchanger (e.g. the heat exchanger of power electronics assembly 370 whereby heat from assembly 370 is transferred to fluid 342, not labeled, see pars. 441-442, 444) thermally connected to the thermal management system flowpath downstream of the first heat exchanger (see pars. 441-442), the second heat exchanger thermally connected to the power electronics assembly (see pars. 441-442, 444) along the second flowpath loop. Regarding claim 2, Mochrie teaches wherein the thermal management system flowpath comprises a flow splitter 348 downstream of the first heat exchanger, the flow splitter separating the flow of the fluid into a first portion of the flow of the fluid (e.g. the portion flowing to bypass valve 349) and a second portion of the flow of the fluid (e.g. the portion flowing to heat exchanger 410), the flow splitter diverting the first portion of the flow of the fluid to the second heat exchanger (e.g. via bypass valve 349), and wherein at least the second portion of the flow of the fluid flows to the electric machine (e.g. via heat exchanger 410). Regarding claim 3, Mochrie teaches wherein the first portion is equal to or less than the second portion (e.g. when all outlets of flow splitter 348 are completely open). Regarding claim 4, Mochrie teaches wherein the thermal management system flowpath comprises a flow joiner (see annotated Fig. 3) positioned downstream of the power electronics assembly, the flow joiner combining the first portion of the flow of the fluid with the second portion of the flow of the fluid. PNG media_image1.png 832 691 media_image1.png Greyscale Regarding claim 5, Mochrie teaches wherein the thermal management system flowpath comprises a flow control device 349 regulating the flow of the fluid to the second heat exchanger. Regarding claim 7, Mochrie teaches wherein the first heat exchanger 351 comprises an air-cooled heat exchanger (see par. 418). Regarding claim 9, Mochrie tehacs wherein the fluid comprises at least one of oil, carbon dioxide, nitrogen, helium, or xenon (see par. 390). 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 (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 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. 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. Claim(s) 8, 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Mochrie. Regarding claim 8, Mochrie does not teach wherein the second heat exchanger comprises a fuel-cooled heat exchanger. However, Mochrie teaches a fuel-cooled heat exchanger (see pars. 420, 449, wherein fuel is used to cool a fluid heat exchanger). It would have been obvious to one of ordinary skill in the art before the filing date of the invention to modify Mochrie such that the second heat exchanger comprises a fuel-cooled heat exchanger with the motivation of effectively dissipating heat to a fuel flow prior to being combusted in a gas turbine engine 100 wherein it may be difficult to efficiently transfer heat to an air flow (see par. 449). Regarding claim 10, Mochrie teaches wherein the fluid comprises oil (see par. 390), and wherein the first heat exchanger comprises an air-cooled oil cooler (see par. 418), and wherein the second heat exchanger comprises a fuel-cooled oil cooler (see the rejection of claim 8). Response to Arguments Applicant's arguments filed 3/2/2026 have been fully considered but they are not persuasive. Applicant argues that Mochrie does not teach a first and second flowpath loop. However, referring to Fig. 3, Mochrie teaches a first and second flowpath loop (see the rejection of claim 1). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Smith, Hon, Snyder, Munevar and Lui teach thermal management systems for aircraft. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 STEVE S TANENBAUM whose telephone number is (313)446-6522. The examiner can normally be reached M-F 11 AM - 7 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, Frantz Jules can be reached at (571) 272-6681. 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. /Steve S TANENBAUM/Examiner, Art Unit 3763
Read full office action

Prosecution Timeline

Mar 18, 2024
Application Filed
Nov 26, 2025
Non-Final Rejection — §102, §103
Mar 02, 2026
Response Filed
Mar 17, 2026
Final Rejection — §102, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
68%
Grant Probability
78%
With Interview (+10.0%)
2y 8m
Median Time to Grant
Moderate
PTA Risk
Based on 764 resolved cases by this examiner. Grant probability derived from career allow rate.

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