Prosecution Insights
Last updated: April 19, 2026
Application No. 18/641,795

NICKEL PHOSPHOROUS COATING

Final Rejection §103
Filed
Apr 22, 2024
Examiner
SEHN, MICHAEL L
Art Unit
3745
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Rtx Corporation
OA Round
2 (Final)
80%
Grant Probability
Favorable
3-4
OA Rounds
2y 9m
To Grant
94%
With Interview

Examiner Intelligence

Grants 80% — above average
80%
Career Allow Rate
521 granted / 647 resolved
+10.5% vs TC avg
Moderate +14% lift
Without
With
+13.6%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
16 currently pending
Career history
663
Total Applications
across all art units

Statute-Specific Performance

§101
0.9%
-39.1% vs TC avg
§103
44.1%
+4.1% vs TC avg
§102
26.2%
-13.8% vs TC avg
§112
23.5%
-16.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 647 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 . Response to Arguments Applicant's arguments filed 11/24/2025, regarding the rejections made under 35 U.S.C. §103 in view of Sorbo and Gold, have been fully considered but they are not persuasive. The applicant argues that one of ordinary skill in the art would not have combined the teachings of Sorbo and Gold, since, the applicant argues, Gold’s columnar microstructure directly contradicts Sorbo’s objective by degrading the performance of Sorbo’s coating. Therefore, the applicant argues that the rejections should be withdrawn. The Office respectfully disagrees. Sorbo discloses that the objective is to develop coatings “displaying both enhanced adhesion and strain tolerance to enable coatings to provide protection from chemicals” (Paragraph [0004], Lines 1-3), and Gold helps meet these objectives. Gold discloses that the coating’s columnar microstructure “may provide increased in-plane strain tolerance and improved thermal cycling resistance, resulting in better adhesion properties and a more robust article” (emphasis added) (Paragraph [0033], Lines 28-32). Gold discloses that two of the advantages of a coating having the columnar microstructure are better adhesion and increased strain tolerance – two objectives of Sorbo’s coating. Therefore, one of ordinary skill in the art would modify Sorbo with the teachings of Gold for the purpose of providing the coating of Sorbo with increased in-plane strain tolerance and improved thermal cycling resistance, resulting in better adhesion properties and a more robust article (as also mentioned in the rejections under 35 U.S.C. §103 in the non-final rejection). Because of this, the applicant’s arguments are not persuasive, and the rejections made under 35 U.S.C. §103 are maintained. 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) 1-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sorbo (US Publication No: 2011/0206532) in view of Gold (US Publication No: 2019/0017177). Regarding Claim 1: Sorbo discloses a method of applying a coating (Paragraph [0005], Lines 1-3) to an article for a gas turbine engine (Paragraph [0025]), comprising electroplating nickel phosphorous onto the surface of an article to form a coating (Abstract, Lines 2-4; Paragraph [0033]); and heat treating the coated article after the electroplating (Abstract, Lines 4-7; Paragraph [0035]); however, Sorbo fails to disclose the nickel phosphorous having a columnar microstructure. Gold teaches a method of applying a coating (Figure 1B, No. 42) to a gas turbine engine article (40), wherein the coating has a columnar microstructure (Paragraph [0033], Lines 28-29). Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art to make the nickel phosphorous coating of Sorbo with a columnar microstructure, as taught by Gold, for the purpose of providing the coating with increased in-plane strain tolerance and improved thermal cycling resistance, resulting in better adhesion properties and a more robust article (Paragraph [0033], Lines 28-32). Regarding Claim 2: Sorbo, as modified by Gold, discloses the method of Claim 1, wherein the columnar microstructure includes columns arranged approximately parallel to a plane of the substrate (Gold: Paragraph [0016], Lines 3-6). Regarding Claim 3: Sorbo, as modified by Gold, discloses the method of Claim 2, wherein the coating is between about 1 and 5 mils (25.4 to 127 microns) thick after the heat treating (Sorbo: Paragraph [0020]; Gold: Paragraph [0035]). Regarding Claims 4-5: Sorbo, as modified by Gold, discloses the method of Claim 3, wherein the article comprises a titanium alloy (Gold: Paragraph [0022], Lines 4-6). Regarding Claim 6: Sorbo, as modified by Gold, discloses the method of Claim 2, wherein the coating includes regions of pure nickel (Sorbo: Paragraph [0018]). Regarding Claim 7: Sorbo, as modified by Gold, discloses the method of Claim 2, wherein the coating has a hardness between about 750 and 1100 HV after the heat treating (property of the material - the structure of the prior art coating is the same as the structure of the claimed coating; therefore, the properties of the prior art coating, including the hardness, are the same as those of the claimed coating. See MPEP 2112.01). Regarding Claim 8: Sorbo, as modified by Gold, discloses the method of Claim 7, wherein the coating provides thermal (Gold: Paragraph [0033], Lines 28-32) and mechanical (Sorbo: Paragraph [0027], Lines 5-8) protection to the substrate. Regarding Claims 9-10: Sorbo, as modified by Gold, discloses the method of Claim 2, wherein the article is a component of a bearing system or a vane in a compressor or turbine of the gas turbine engine (Sorbo: Paragraph [0025]; Gold: Paragraph [0021], Lines 2-6). Regarding Claim 11: Sorbo, as modified by Gold, discloses the method of Claim 1, wherein the coating is between about 1 and 5 mils (25.4 to 127 microns) thick after the heat treating (Sorbo: Paragraph [0020]; Gold: Paragraph [0035]). Regarding Claims 12-13: Sorbo, as modified by Gold, discloses the method of Claim 11, wherein the article comprises a titanium alloy (Gold: Paragraph [0022], Lines 4-6). Regarding Claim 14: Sorbo, as modified by Gold, discloses the method of Claim 1, wherein the coating includes regions of pure nickel (Sorbo: Paragraph [0018]). Regarding Claim 15: Sorbo, as modified by Gold, discloses the method of Claim 14, wherein the coating has a hardness between about 750 and 1100 HV after the heat treating (property of the material - the structure of the prior art coating is the same as the structure of the claimed coating; therefore, the properties of the prior art coating, including the hardness, are the same as those of the claimed coating. See MPEP 2112.01). Regarding Claim 16: Sorbo, as modified by Gold, discloses the method of Claim 15, wherein the coating provides thermal (Gold: Paragraph [0033], Lines 28-32) and mechanical (Sorbo: Paragraph [0027], Lines 5-8) protection to the substrate. Regarding Claim 17: Sorbo, as modified by Gold, discloses the method of Claim 1, wherein the coating has a hardness between about 750 and 1100 HV after the heat treating (property of the material - the structure of the prior art coating is the same as the structure of the claimed coating; therefore, the properties of the prior art coating, including the hardness, are the same as those of the claimed coating. See MPEP 2112.01). Regarding Claim 18: Sorbo, as modified by Gold, discloses the method of Claim 1, wherein the coating provides thermal (Gold: Paragraph [0033], Lines 28-32) and mechanical (Sorbo: Paragraph [0027], Lines 5-8) protection to the substrate. Regarding Claims 19-20: Sorbo, as modified by Gold, discloses the method of Claim 1, wherein the article is a component of a bearing system or a vane in a compressor or turbine of the gas turbine engine (Sorbo: Paragraph [0025]; Gold: Paragraph [0021], Lines 2-6). Allowable Subject Matter Claim 21 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. The following is a statement of reasons for the indication of allowable subject matter: The prior art fails to disclose the method as claimed, wherein the electroplating of the nickel phosphorous causes formation of the columnar microstructure, and the heat treating is conducted at a temperature and time such that the columnar microstructure survives the heat treating and is present in the coating both before and after the heat treating. Sorbo discloses electroplating and heat treating a nickel-phosphorous coating; however, this electroplating does not cause the formation of the columnar microstructure of the coating of Sorbo, as modified by Gold. Gold discloses a columnar microstructure; however, Gold fails to disclose the columnar microstructure surviving heat treating and being present in the coating before and after said heat treating. The prior art fails to disclose a method as claimed in Claim 21; therefore, Claim 21 contains allowable subject matter. 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 MICHAEL L SEHN whose telephone number is (571)270-3564. The examiner can normally be reached M-F 8:30 AM-6 PM, every other Friday off. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Courtney Heinle can be reached at 571-270-3508. 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. /MICHAEL L SEHN/Primary Examiner, Art Unit 3745
Read full office action

Prosecution Timeline

Apr 22, 2024
Application Filed
Aug 20, 2025
Non-Final Rejection — §103
Nov 24, 2025
Response Filed
Mar 23, 2026
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

3-4
Expected OA Rounds
80%
Grant Probability
94%
With Interview (+13.6%)
2y 9m
Median Time to Grant
Moderate
PTA Risk
Based on 647 resolved cases by this examiner. Grant probability derived from career allow rate.

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