Prosecution Insights
Last updated: October 02, 2026
Application No. 18/629,721

ELECTRONIC DEVICE

Final Rejection §103
Filed
Apr 08, 2024
Priority
Oct 27, 2021 — JP 2021-175720 +2 more
Examiner
CRUM, JACOB R
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Panasonic Holdings Corporation
OA Round
2 (Final)
75%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allowance Rate
487 granted / 653 resolved
+6.6% vs TC avg
Strong +28% interview lift
Without
With
+27.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
37 currently pending
Career history
677
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
56.1%
+16.1% vs TC avg
§102
23.7%
-16.3% vs TC avg
§112
13.8%
-26.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 653 resolved cases

Office Action

§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 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. Claim(s) 1-5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Furukawa (JP 2007124079 A) in view of Murakami (JPH 1065385 A). References provided with IDS, translations previously attached. As to claim 1, Furukawa discloses: An electronic device (Fig. 1-8) comprising: a communication module 14, 15, 16 (par. 0024-0025) that includes a communication function (cellular phone), and includes a first module surface (top surface of 15 and components in Fig. 1) and a second module surface (bottom surface) opposed to the first module surface; a first heat dissipation material 20, 23, 24 (leaf spring, fins, heat transfer sheet; par. 0028-0029) that is disposed on the first module surface; an input interface 4 that is operated by a user; a housing 1 that accommodates the communication module, and includes a first surface 1B facing the first module surface and a second surface 1A opposed to the first surface, the input interface 4 being provided on the second surface 1A. Furukawa does not explicitly disclose: wherein the first surface of the housing includes a first recess recessed toward the second surface, and the first recess includes a first wall coming into contact with the first heat dissipation material. However, Murakami discloses: wherein the first surface (upper surface; Fig. 1-7) of the housing 2 includes a first recess 6, 7 recessed toward the second surface, and the first recess includes a first wall 8, 9 coming into contact (thermal contact) with the first heat dissipation material 10 (Fig. 2); in order to transfer heat to the housing (par. 0031). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa as suggested by Murakami, e.g., providing: wherein the first surface of the housing includes a first recess recessed toward the second surface, and the first recess includes a first wall coming into contact with the first heat dissipation material; in order to transfer heat to the housing. Additionally, all claimed elements were known in the prior art and one skilled in the art could have combined/modified the elements as claimed by known methods with no change in their respective functions, and the combination/modification would have yielded predictable results to one of ordinary skill in the art before the effective filing date of the claimed invention. See KSR International Co. v. Teleflex Inc., 550 U.S.___, 82 USPQ2d 1385 (2007). As to claim 2, Furukawa in view of Murakami does not explicitly disclose (in the current embodiment): wherein the first recess includes one or a plurality of fins rising in a thickness direction from the second surface toward the first surface. However, Murakami discloses (in another embodiment): wherein the first recess 6, 7 (Fig. 5-7) includes one or a plurality of fins 13, 14 rising in a thickness direction from the second surface (bottom) toward the first surface (top); in order to improve heat radiation efficiency (par. 0042-0044). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa and Murakami as suggested by Murakami, e.g., providing: wherein the first recess includes one or a plurality of fins rising in a thickness direction from the second surface toward the first surface; in order to improve heat radiation efficiency. As to claim 3, Furukawa in view of Murakami discloses: wherein the first wall 8, 9 (Murakami) includes a bottom extending in a direction (left to right) orthogonal to the thickness direction (up and down), the bottom comes into contact with the first heat dissipation material 10 (as in Fig. 2), and the one or plurality of fins 13, 14 (as in Fig. 5-7) rise in the thickness direction from the bottom. As to claim 4, Furukawa in view of Murakami discloses: the first wall 9 (Fig. 5-7; Murakami) includes two side walls (slanted) that extend along the thickness direction and are opposed to each other, and the plurality of fins 14 are provided in the first recess to extend in parallel with each other between the two side walls. Furukawa in view of Murakami does not explicitly disclose: wherein the first recess is provided in a rectangular shape as viewed in the thickness direction. However, it would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa and Murakami, e.g., providing: wherein the first recess is provided in a rectangular shape as viewed in the thickness direction; since there is no evidence that the change in shape is significant. A change in shape, absent persuasive evidence that the change in shape is significant, is generally recognized as being within the level of ordinary skill in the art. In re Dailey, 357 F.2d 669, 149 USPQ 47 (CCPA 1966). As to claim 5, Furukawa in view of Murakami discloses: wherein the plurality of fins 14 (Murakami) are provided at equal intervals (Fig. 5-6). Claim(s) 6-12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Furukawa (JP 2007124079 A) in view of Murakami (JPH 1065385 A) as applied to claim 1 above, and further in view of Takano (US 20020029875 A1). As to claim 6, Furukawa in view of Murakami does not disclose: further comprising a second heat dissipation material that is disposed on the second module surface, wherein the second surface of the housing includes a second recess recessed toward the first surface, and the second recess includes a second wall coming into contact with the second heat dissipation material. However, Takano discloses: further comprising a second heat dissipation material 13 (Fig. 2-3) that is disposed on the second module surface (underside of the board 6 and component 1), wherein the second surface of the housing 3 includes a second recess 10 recessed toward the first surface, and the second recess includes a second wall coming into contact with the second heat dissipation material; in order to dissipate heat from the underside of the board/component to the case (par. 0030, 0035). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa and Murakami as suggested by Takano, e.g., providing: further comprising a second heat dissipation material that is disposed on the second module surface, wherein the second surface of the housing includes a second recess recessed toward the first surface, and the second recess includes a second wall coming into contact with the second heat dissipation material; in order to dissipate heat from the underside of the board/component to the case. As to claim 7, Furukawa in view of Murakami and Takano discloses: wherein the second recess, the communication module, and the first recess are lined up in a thickness direction from the second surface toward the first surface (each of the recesses would be lined up with the board 15 of Furukawa, since they dissipate heat from opposite sides of the board/components). As to claim 8, Furukawa in view of Murakami and Takano discloses: wherein the communication module includes a controller (e.g., CPU 17 in Furukawa, , and the second recess, the controller, and the first recess are lined up in the thickness direction (as in Murakami and Takano). As to claim 9, Furukawa in view of Murakami and Takano does not explicitly disclose: wherein the second recess is covered with the input interface. However, Murakami discloses providing the recess beneath a lid 11 (Fig. 6-7); in order to provide the external surface of the casing as a flat plate (par. 0035). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa, Murakami, and Takano as suggested by Murakami, e.g., providing: wherein the second recess is covered with the input interface; in order to provide the external surface as the input interface (as in Furukawa). As to claim 10, Furukawa in view of Murakami and Takano does not explicitly disclose: further comprising a lid that covers the second recess. However, Murakami discloses: further comprising a lid 11 (Fig. 6-7) that covers the second recess 6, 7; in order to provide better thermal conductivity (par. 0039). It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa, Murakami, and Takano as suggested by Murakami, e.g., providing: further comprising a lid that covers the second recess; in order to provide better thermal conductivity. As to claim 11, Furukawa in view of Murakami and Takano discloses: wherein the lid (inner surface of 11; Murakami) is covered with the input interface (outer surface 4, as in Furukawa). As to claim 12, Furukawa in view of Murakami and Takano does not explicitly disclose: wherein a depth of the second recess is larger than a depth of the first recess. However, Murakami discloses: wherein a depth of the second recess 6 (Murakami) is larger than a depth of the first recess 7; in order to contact components/portions of the circuit board with different heights. It would have been obvious to one of ordinary skill in the related art(s) before the effective filing date of the claimed invention to modify the device of Furukawa, Murakami, and Takano as suggested by Murakami, e.g., providing: wherein a depth of the second recess is larger than a depth of the first recess; in order to contact different portions of the communication module (e.g., height of chip and height of underside of the board). Response to Arguments Applicant's arguments filed 5/19/2026 have been fully considered but they are not persuasive. Claimed Elements Not Taught Applicant has suggested that Murakami does not disclose “that an interface is provided on an opposing surface of metal case 2” and does not disclose the claimed positional relationship between a second surface on which an interface is provided and a first surface including a recess recessed toward the second surface (Remarks, p. 8). In response, Examiner notes that primary reference Furukawa already discloses a heat dissipating housing with “the input interface being provided on the second surface”. Murakami is merely relied upon for the recess recessed toward the second surface and including a first wall coming into contact with the first heat dissipation material (see Office Action above). In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). 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 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 JACOB R CRUM whose telephone number is (571)270-7665. The examiner can normally be reached Monday - Friday 9:00 am - 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, Jayprakash Gandhi can be reached at (571) 270-1985. 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. /JACOB R CRUM/ Primary Examiner, Art Unit 2841
Read full office action

Prosecution Timeline

Apr 08, 2024
Application Filed
Feb 19, 2026
Non-Final Rejection mailed — §103
May 19, 2026
Response Filed
Aug 19, 2026
Final Rejection mailed — §103 (current)

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

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Prosecution Projections

3-4
Expected OA Rounds
75%
Grant Probability
99%
With Interview (+27.9%)
2y 5m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 653 resolved cases by this examiner. Grant probability derived from career allowance rate.

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