Prosecution Insights
Last updated: April 19, 2026
Application No. 18/636,404

Durable Coated Article Having a Metal Layer

Non-Final OA §103
Filed
Apr 16, 2024
Examiner
LAW, NGA LEUNG V
Art Unit
1717
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Vitro Flat Glass LLC
OA Round
1 (Non-Final)
56%
Grant Probability
Moderate
1-2
OA Rounds
3y 4m
To Grant
76%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allow Rate
299 granted / 533 resolved
-8.9% vs TC avg
Strong +20% interview lift
Without
With
+20.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
55 currently pending
Career history
588
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
51.9%
+11.9% vs TC avg
§102
13.8%
-26.2% vs TC avg
§112
28.3%
-11.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 533 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 . Election/Restrictions Claim 19 is withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on October 27, 2025. Accordingly, the requirement is made FINAL. 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. Claims 1-8, 10-12 and 15-17 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Finley1 (US20050258030) in view of Minami (JP3616128B2). Regarding claim 1, Finley1 teaches a method of forming coating layers in a coating stack by sputtering (abstract), wherein the stack is a Low-E coating stack having an overlaying protective coasting to protect the infrared reflective layer (paragraphs 0012, 0018 and 0020) (a method of making a coated article). Finley1 teaches to form the coating stacks on a glass substrate (forming a functional coating over at least a portion of the first surface of the second surface) (paragraphs 0072, 0165-0168). Finley1 teaches to form all the layers by sputtering, wherein the sputtering is conducted in a chamber (paragraph 0168). While Finley1 does not explicitly teaches the layers are formed in different chambers, Finley1 teaches the substrate is being conveyed during through the coating process (paragraphs 0079 and 0104), and different targets and atmosphere are required for each layers (paragraphs 0168), thus it would be obvious to one of ordinary skill in the art to use different chambers for each layers (and moving the substrate from one chamber to the other), especially the results of forming all the layers on the stacks can both be achieved by using one chambers or multiple chambers. In addition, it is obvious to choose from a finite number of identified, predictable solutions, with a reasonable expectation of success (MPEP 2143 I. E.). In this case, there is only two possible solutions: using one chambers or multiple chambers; all of the scenarios result in the same solution of achieving the goal of forming the coating stack. Thus, it would be obvious to one of ordinary skill in the art before the effectively filing date to form each layer in an individual chamber in light of the teaching of Finley1, especially Finley1 teaches different targets and atmosphere are required for each layer (paragraphs 0168). Thus, Finley teaches to position the substate in the first chamber comprising a first atmosphere to form the zinc stannate (first layer) on the substrate (glass substrate) (paragraphs 0167-0168), wherein the atmosphere is 50% and 50% mix of argon and oxygen (paragraph 0168) (greater than 0 vol% O2 to less than or equal to 80 vol% O2). Finley1 teaches to move the substrate to the second chamber comprising a second atmosphere of 100% argon to form an Al-Ti (seed layer) on the first layer (paragraphs 0167-0168); 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Finley1 teaches to move the substrate to the third chamber comprising a third atmosphere of 100% argon to form a silver layer (metallic layer) on the seed layer (paragraphs 0167-0168); 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Finley1 teaches to move the substrate into a fourth chamber comprising a fourth atmosphere of 100% argon to form an Al-Ti (primer layer) on the metallic layer (paragraphs 0167-0168); 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Finley1 teaches to move the substrate to the fifth chamber comprising a fifth atmosphere comprising 50% and 50% mix of argon and oxygen to form a second zinc stannate (second layer) on the primer layer (paragraphs 0167- 0168) (greater than 0 vol% O2 to less than or equal to 80 vol% O2). Finley1 does not explicitly teach the nitrogen gas is used instead of argon in forming the first and second layers. However, Minami teaches a method of forming a transparent conductive film, zinc stannate, by sputtering (paragraph 0006), and discloses oxygen is mixed in a with an amount of inert gas such as nitrogen or argon (paragraph 0006). Therefore, it would have been obvious to one of ordinary skill in the art to substitute nitrogen for argon as the inert gas in the method of sputtering zinc stannate as disclosed by Finley1. Regarding claim 2, Finley1 teaches the metallic layer and the primer layer are deposited in an atmosphere at 100% argon; 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Regarding claim 3, Finley1 teaches the functional coating consists of the first layer, the seed layer, the metallic layer, the primer layer and the second layer (paragraph 0167). Regarding claim 4, Finley1 teaches the seed layer is titanium aluminum (paragraphs 0167-0168). Regarding claim 5, Finley1 teaches the seed layer comprises titanium aluminum (paragraphs 0167-0168). Regarding claim 6, Finley1 teaches the coating (seed layer) is in the range of 10 to 80 wt% titanium with the balance of aluminum (paragraphs 0021, 0171), which overlaps with the claimed range. In the case where the claimed ranges “overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exist. In re Wertheim, 541 F.2d 257, 191USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990); In re Geisler,116 F.3d 1465, 1469-71, 43 USPQ2d 1362, 1365-66 (Fed. Cir. 1997). See MPEP 2144.05. Finley1 teaches the titanium and aluminum wt% governs the sheet resistance and stability when left unprotected (paragraph 0171). Therefore, it would have been within the skill of the ordinary artisan to adjust and the optimize the wt% of titanium and aluminum in the seed layer in the process to yield the desired sheet resistance and stability when left unprotected. Discovery of optimum value of result effective variable in known process is ordinarily within skill of art. In re Boesch, CCPA 1980, 617 F. 2d 272, 205 USPQ215. Regarding claim 7, Finley1 teaches the thickness of the titanium aluminum layers (seed layer and primer layer) governs the transmission of the layer under the same deposition parameters (paragraphs 0138-0164, see table F). Finley1 also teaches the titanium aluminum layer provided protection to the silver metallic layer against oxidation (paragraphs 0017 and 0019). Therefore, it would have been within the skill of the ordinary artisan to adjust and optimize the thickness of the seed layer in the process to yield the desired transmission of the layer and oxidation protection to the silver metallic layer. Discovery of optimum value of result effective variable in known process is ordinarily within skill of art. In re Boesch, CCPA 1980, 617 F. 2d 272, 205 USPQ215. Regarding claim 8, Finley1 teaches the primer layer is titanium aluminum (paragraph 0167). Regarding claim 10, Finley1 teaches the primer layer comprises titanium (paragraphs 0167-0168). Regarding claim 11, Finley1 teaches the thickness of the titanium aluminum layers (seed layer and primer layer) governs the transmission of the layer under the same deposition parameters (paragraphs 0138-0164, see table F). Finley1 also teaches the titanium aluminum layer provided protection to the silver metallic layer against oxidation (paragraphs 0017 and 0019). Therefore, it would have been within the skill of the ordinary artisan to adjust and optimize the thickness of the seed layer in the process to yield the desired transmission of the layer and oxidation protection to the silver metallic layer. Discovery of optimum value of result effective variable in known process is ordinarily within skill of art. In re Boesch, CCPA 1980, 617 F. 2d 272, 205 USPQ215. Regarding claim 12, Finley1 teaches the first layer comprises zinc stannate (paragraphs 0167-0168). Regarding claim 15, Finley1 teaches the metallic layer is silver (paragraphs 0167-0168). Regarding claim 16, Finley1 teaches the metallic layer is silver (paragraphs 0167-0168). Regarding claim 17, Finley1 teaches the second layer is zinc stannate (paragraphs 0167-0168). Regarding claim 20, Finley1 teaches a method of forming coating layers in a coating stack by sputtering (abstract), wherein the stack is a Low-E coating stack having overlaying protective coatings to protect metallic infrared reflective layer (paragraphs 0012, 0018 and 0020) (a method of protect a metallic layer in a coated article). Finley1 teaches to form the coating stacks on a glass substrate (forming a functional coating over at least a portion of the first surface of the second surface) (paragraphs 0072, 0165-0168). Finley1 teaches to form all the layers by sputtering, wherein the sputtering is conducted in a chamber (paragraph 0168). While Finley1 does not explicitly teaches the layers are formed in different chambers, Finley1 teaches the substrate is being conveyed during through the coating process (paragraphs 0079 and 0104), and different targets and atmosphere are required for each layers (paragraphs 0168), thus it would be obvious to one of ordinary skill in the art to use different chambers for each layers (and moving the substrate from one chamber to the other), especially the results of forming all the layers on the stacks can both be achieved by using one chambers or multiple chambers. In addition, it is obvious to choose from a finite number of identified, predictable solutions, with a reasonable expectation of success (MPEP 2143 I. E.). In this case, there is only two possible solutions: using one chambers or multiple chambers; all of the scenarios result in the same solution of achieving the goal of forming the coating stack. Thus, it would be obvious to one of ordinary skill in the art before the effectively filing date to form each layer in an individual chamber in light of the teaching of Finley1, especially Finley1 teaches different targets and atmosphere are required for each layer (paragraphs 0168). Thus, Finley teaches to position the substate in the first chamber comprising a first atmosphere to form the zinc stannate (first layer) on the substrate (glass substrate) (paragraphs 0167-0168), wherein the atmosphere is 50% and 50% mix of argon and oxygen (paragraph 0168) (greater than 0 vol% O2 to less than or equal to 80 vol% O2). Finley1 teaches to move the substrate to the second chamber comprising a second atmosphere of 100% argon to form an Al-Ti (seed layer) on the first layer (paragraphs 0167-0168); 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Finley1 teaches to move the substrate to the third chamber comprising a third atmosphere of 100% argon to form a silver layer (metallic layer) on the seed layer (paragraphs 0167-0168); 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Finley1 teaches to move the substrate into a fourth chamber comprising a fourth atmosphere of 100% argon to form an Al-Ti (primer layer) on the metallic layer (paragraphs 0167-0168); 100% argon is 0% oxygen and 0% nitrogen, which reads on the claimed limitations. Finley1 teaches to move the substrate to the fifth chamber comprising a fifth atmosphere comprising 50% and 50% mix of argon and oxygen to form a second zinc stannate (second layer) on the primer layer (paragraphs 0167- 0168) (greater than 0 vol% O2 to less than or equal to 80 vol% O2). Finley1 does not explicitly teach the nitrogen gas is used instead of argon in forming the first and second layers. However, Minami teaches a method of forming a transparent conductive film, zinc stannate, by sputtering (paragraph 0006), and discloses oxygen is mixed in a with an amount of inert gas such as nitrogen or argon (paragraph 0006). Therefore, it would have been obvious to one of ordinary skill in the art to substitute nitrogen for argon as the inert gas in the method of sputtering zinc stannate as disclosed by Finley1. Claims 9, 14 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Finley1 (US20050258030) in view of Minami (JP3616128B2) as applied to claims 1-8, 10-12 and 15-17 and 20 above, and further in view of Brochot (US20060257670). Regarding claim 9, Finley1 in view of Minami teaches all limitations of this claim except the primer layer is niobium. Brochot teaches forming multilayers on transparent substrate to protect a reflective silver layer (paragraphs 0002-0003, abstract). Brochot teaches niobium and titanium aluminum are functionally equivalent materials for protecting silver metallic layer against oxidization (paragraphs 0025-0029). Therefore, it would have been obvious to one of ordinary skill in the art to substitute niobium for titanium aluminum as the material for the primer layer in the method as disclosed by Finley1 and Minami. Regarding claim 14, Finley1 in view of Minami teaches all limitations of this claim, except the thickness of the metallic layer. However, Brochot teaches the metallic layer has a thickness of 5 to 13nm (paragraphs 0029 and 0017). Brochot teaches metallic layer provided reflection properties in the infrared and/or in the solar radiation (paragraph 0017). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to use the thickness for the metallic layer as suggested by Brochot in the method of Finley1 in view of Minami because Brochot teaches such thickness is suitable to provide reflection properties in the infrared and/or in the solar radiation for the glazing assembly (paragraph 0017). Regarding claim 18, Finley1 teaches the seed layer is titanium aluminum and the metallic layer is silver (paragraphs 0167 and 0168). Thus, Finley1 in view of Minami teaches all limitations of this claim except the primer layer is niobium. Brochot teaches forming multilayers on transparent substrate to protect a reflective silver layer (paragraphs 0002-0003, abstract). Brochot teaches niobium and titanium aluminum are functionally equivalent materials for protecting silver metallic layer against oxidization (paragraphs 0025-0029). Therefore, it would have been obvious to one of ordinary skill in the art to substitute niobium for titanium aluminum as the material for the primer layer in the method as disclosed by Finley1 and Minami. Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Finley1 (US20050258030) in view of Minami (JP3616128B2) as applied to claims 1-8, 10-12 and 15-17 and 20, and further in view of Finley2 (US4898790). Regarding claim 13, Finley1 in view of Minami does not explicitly teach the metallic layer thickness. Finley2 teaches a multiple layer, high transmittance, low emissivity coated article (abstract), comprising the first layer (zinc stannate) is 30nm (column 6 lines 30-35), which is inside the claimed range. Finley2 teaches the thickness governs the optical properties such as transmittance (column 7 lines 40-45). Therefore, it would have been within the skill of the ordinary artisan to adjust and optimize the thickness of the first layer in the process to yield the desired optical properties such as transmittance. Discovery of optimum value of result effective variable in known process is ordinarily within skill of art. In re Boesch, CCPA 1980, 617 F. 2d 272, 205 USPQ215. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to NGA LEUNG V LAW whose telephone number is (571)270-1115. The examiner can normally be reached M-F 8 am - 5 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, Dah-Wei Yuan can be reached at 5712721295. 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. /NGA LEUNG V LAW/Examiner, Art Unit 1717 /Dah-Wei D. Yuan/Supervisory Patent Examiner, Art Unit 1717
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Prosecution Timeline

Apr 16, 2024
Application Filed
Jan 10, 2026
Non-Final Rejection — §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

1-2
Expected OA Rounds
56%
Grant Probability
76%
With Interview (+20.1%)
3y 4m
Median Time to Grant
Low
PTA Risk
Based on 533 resolved cases by this examiner. Grant probability derived from career allow rate.

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