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.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
The following limitations are interpreted as invoking 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
Claims 1 and 11, recites the limitation “average value calculation means”. The term “means” is a generic placeholder (nonce term). The limitation recites the function of calculating average values but does not recite sufficient structure for performing the function. The corresponding structure in the disclosure is a processor or computer executing a program of instructions to calculate time-averaged values of sensor outputs (average calculation units 901, 902; see [0044] – [0045]). Therefore, the interpretation is a processor/computer programmed to calculate time averages of the detection values and equivalents thereof.
Claims 1 and 11, recites the limitation “comparison means”. The term “means” is a generic placeholder (nonce term). The limitation recites the function of comparing values without reciting sufficient structure. The corresponding structure in the disclosure is a processor or computer executing a program of instructions to compare the calculated average values with each other (comparison units 903, 904; see [0045]). Therefore, the interpretation is a processor/computer programmed to perform value comparisons and equivalents thereof.
Claims 1-3, 11, 12, and 16, recites the limitation “abnormality determination means”. The term “means” is a generic placeholder (nonce term). The limitations recite the functions of determining abnormalities and calculating/comparing division values without reciting sufficient structure. The corresponding structure in the disclosure is a processor or computer executing a program of instructions to calculate division values and determine fault conditions based on threshold comparisons (abnormality determination unit 305; see [0023], [0031] – [0034], [0045]). Therefore, the interpretation is a processor/computer programmed to perform the recited fault determination and ratio threshold algorithms and equivalents thereof.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 3, 4, and 14-16 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
As to claim 3, the claim recites the limitation “calculates a division value using a smaller value of the average values of the detection values output from the plurality of current detection sensors over the predetermined time as a numerator and a larger value of the detection values output from the plurality of current detection sensors as a denominator”. The claim is indefinite because the numerator requires an average value, whereas the denominator omits “average values of the” and recites raw “detection values”. It is unclear whether the denominator is intended to be the larger average value or a larger instantaneous detection value. As best understood from the disclosure ([0028]), the calculation is intended to compare the smaller average value against the larger average value. A possible correction would read “calculates a division value using a smaller value of the average values of the detection values output from the plurality of current detection sensors over the predetermined time as a numerator and a larger value of the average values of the detection values output from the plurality of current detection sensors as a denominator”.
As to claim 14, the claim recites the limitation “wherein a respective resistor is arranged in parallel with the respective plurality of switching elements of each of the plurality of rectifier circuits”. The claim is indefinite because it recites a singular “respective resistor” arranged in parallel with a plural “plurality of switching elements”. It is unclear whether a single resistor is placed in parallel across the entire group of switching elements as a whole, or whether each individual switching element has its own parallel resistor.
As to claim 15, the claim depends on claim 14 and recites the limitation “wherein a period during which each of the plurality of switching elements is conductive is determined based on a voltage generated across opposite ends of the corresponding resistor”. Because of the ambiguity in claim 14, the phrase “the corresponding resistor” lacks clear antecedent basis. If there is only one “respective resistor” for the entire plurality of switching elements, it is unclear how there is a “corresponding resistor” to determine the conductive period for each of the plurality of switching elements. A possible correction to resolve the ambiguities in both claims would be to amend claim 14 to read “wherein a respective resistor is arranged in parallel with each switching element of the respective plurality of switching elements of each of the plurality of rectifier circuits”.
Claims 4 and 16 are rejected for being dependent on a rejected claim.
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.
Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over Lee et al. (hereinafter, “Lee”; US 2021/0257866) in view of Ohno et al. (hereinafter, “Ohno”; US 2006/0203524) and Ichikawa et al. (hereinafter, “Ichikawa”; US 2013/0082627).
With regards to claim 11, Lee teaches a power receiving device (fig. 4; wireless power reception apparatus 200) that wirelessly receives power from a power transmission device (fig. 3A; power transfer apparatus 100), the power receiving device comprising:
a power receiving antenna (coil 210; fig. 4; [0140]);
a rectifier circuit that each includes a respective plurality of switching elements for converting an AC voltage received by the power receiving antenna into a DC voltage (fig. 4; rectifier 220 converts AC to DC [0144], and includes a plurality of switching elements [0145]);
Lee does not teach a plurality of rectifier circuits that are connected in parallel with each other, a plurality of current detection sensors respectively connected to output portions and GND portions of the plurality of rectifier circuits and configured to output detection values of detected currents, comparison means configured to compare the values with each other, and abnormality determination means configured to determine, based on a comparison result obtained by the comparison means, whether an abnormality has occurred in at least one rectifier circuit among the plurality of rectifier circuits.
However, Ohno teaches a plurality of rectifier circuits that are connected in parallel with each other (fig. 4; switching power supply units CONV1-CONVn are connected in parallel to apply a stable voltage to a load; [0004] – [0005]);
a plurality of current detection sensors respectively connected to output portions and GND portions of the plurality of rectifier circuits and configured to output detection values of detected currents (Ohno explicitly teaches integrating these configurations by stating the unit “has a configuration shown in, for example, FIG. 5” [0030] where output current detection circuit 55 is connected to the output portion, and utilizing the configuration of fig. 2 where a first resistor Rb connects to ground; [0032]-[0033]);
comparison means configured to compare the values with each other (“The current balancing terminals CB are connected to each other so as to compare output current values of the switching power supply units CONV1-CONVn”; [0005]);
and abnormality determination means configured to determine, based on a comparison result obtained by the comparison means, whether an abnormality has occurred in at least one rectifier circuit among the plurality of rectifier circuits (fig. 3 which is integrated with fig. 2 by [0033]; determination circuit 10 compares the branch current signals and determines whether there is a failure based on the detection signals; [0036]).
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to have modified the wireless power reception apparatus of Lee to incorporate the parallel circuit topology and series-connected current sensors of Ohno wherein a plurality of rectifier circuits that are connected in parallel with each other, a plurality of current detection sensors respectively connected to output portions and GND portions of the plurality of rectifier circuits and configured to output detection values of detected currents, comparison means configured to compare the values with each other, and abnormality determination means configured to determine, based on a comparison result obtained by the comparison means, whether an abnormality has occurred in at least one rectifier circuit among the plurality of rectifier circuits allow stable voltage supply to a load even when one of the switching power supply units fails, improving overall reliability ([0004] Ohno), and to provide a stable common reference voltage for comparing the parallel branch circuits ([0021], [0032] Ohno).
Lee as modified does not teach average value calculation means connected to the plurality of current detection sensors and configured to calculate average values, over a predetermined time, of the detection values output from the plurality of current detection sensors and compare, with each other, said average values.
However, Ichikawa teaches average value calculation means connected to the plurality of current detection sensors and configured to calculate average values (using digital or analog low-pass filters to extract an average current signal corresponding to the average value of the detected current; [0062], [0094], [0137]), over a predetermined time (evaluate the average current over a predetermined time to accurately determine if an abnormality/fault has occurred without false tripping; [0104], [0116]), of the detection values output from the plurality of current detection sensors.
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to have modified the wireless power reception apparatus of Lee as modified by Ohno to incorporate the average calculation logic of Ichikawa wherein average value calculation means connected to the plurality of current detection sensors and configured to calculate average values, over a predetermined time, of the detection values output from the plurality of current detection sensors and compare, with each other, said average values to allow appropriate protection from overcurrent and filter out switching noise ([0009] – [0010] and [0094] Ichikawa). Applying Ichikawa’s time-averaging to Ohno’s comparison circuit yields a system that compares the average values over the predetermined time with each other to provide a robust diagnostic method that ensures the system reacts only to genuine, sustained hardware failures rather than false alarms caused by instantaneous transients ([0074], [0116] Ichikawa).
Claims 12 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Lee et al. (hereinafter, “Lee”; US 2021/0257866) in view of Ohno et al. (hereinafter, “Ohno”; US 2006/0203524), Ichikawa et al. (hereinafter, “Ichikawa”; US 2013/0082627) and Normet (US 5369541).
With regards to claim 12, Lee as modified teaches the power receiving device according to claim 11. Lee as modified teaches comparing average values over a predetermined time but does not teach wherein the abnormality determination means calculates a division value using, as a numerator, at least one of the average values over the predetermined time of the detection values output from the plurality of current detection sensors and using, as a denominator, another of the average values, and determines that an abnormality has occurred in at least one rectifier circuit among the plurality of rectifier circuits when the division value is less than a threshold value.
However, Normet teaches wherein the abnormality determination means calculates a division value using, as a numerator, at least one of the average values over the predetermined time of the detection values output from the plurality of current detection sensors and using, as a denominator, another of the average values (Col. 2, lines 38-40; “sensing the presence of a trough voltage less than the predetermined fraction of the peak voltage”. This comparison inherently requires calculating a division value (ratio) where the trough (the smaller value of the detection signal) is compared as a numerator against the peak (the larger value of the detection signal) as a denominator.), and determines that an abnormality has occurred in at least one rectifier circuit among the plurality of rectifier circuits when the division value is less than a threshold value (Col. 4, lines 2-5; “amplifier 47 will provide an output indicating phase unbalance if the voltage across resistor 41 is less than the selected portion (threshold) of the voltage across resistor 43”).
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to have modified the wireless power reception apparatus of Lee as modified to incorporate the ratio-based determination logic of Normet wherein the abnormality determination means calculates a division value using, as a numerator, at least one of the average values over the predetermined time of the detection values output from the plurality of current detection sensors and using, as a denominator, another of the average values, and determines that an abnormality has occurred in at least one rectifier circuit among the plurality of rectifier circuits when the division value is less than a threshold value to detect very small unbalances of only a few percent without the expense and complications of transformers (Col. 4, lines 64-68; Normet)
With regards to claim 13, Lee teaches the power receiving device according to claim 12. Lee as modified does not explicitly teach wherein the threshold value is 0.6.
However, Normet further teaches utilizing a threshold fraction that is less than the expected balanced ratio to determine a fault (Col. 4, lines 21-23; “it can be calculated that Tn (balanced trough) is little more than 85% of Pn (balanced peak)”; this establishes the threshold must be set below 0.85).
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to have modified the wireless power reception apparatus of Lee as modified wherein the threshold is 0.6. A person having ordinary skill in the art would recognize that selecting a specific numerical value within a known workable range (less than 0.85) is matter of routine design choice and optimization (MPEP 2144.05), since Normet explicitly teaches that “one may simply calibrate the relationship between the position of movable contact 44 and the phase unbalance necessary to cause an output” (Col. 4, lines 27-30).
Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over Lee et al. (hereinafter, “Lee”; US 2021/0257866) in view of Ohno et al. (hereinafter, “Ohno”; US 2006/0203524), Ichikawa et al. (hereinafter, “Ichikawa”; US 2013/0082627), Normet (US 5369541), and Reschovsky et al. (hereinafter, “Reschovsky”; US 2011/0216449).
With regards to claim 14, Lee as modified teaches the power receiving device according to claim 13. Lee as modified does not teach wherein a respective resistor is arranged in parallel with the respective plurality of switching elements of each of the plurality of rectifier circuits.
However, Reschovsky teaches wherein a respective resistor is arranged in parallel with the respective plurality of switching elements of each of the plurality of rectifier circuits (fig. 12; “resistors R D1 21 and R D2 22 are of equal value (R), one installed in parallel across each of the diodes 12, 14”; [0060]).
It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to have modified the wireless power reception apparatus of Lee as modified to incorporate the parallel matching resistors of Reschovsky wherein a respective resistor is arranged in parallel with the respective plurality of switching elements of each of the plurality of rectifier circuits to compensate for the normal variations in diode characteristics and to minimize the potential for erroneous fault detection ([0011] Reschovsky).
Allowable Subject Matter
Claims 1, 2, and 17 are allowed.
Reasons for Allowance:
With regards to claims 1-4, and 17, the prior art of record fails to teach or render obvious the specific arrangement and diagnostic logic of the current detection sensors. While the prior art, Ohno, teaches utilizing parallel power receiving circuits and measuring output currents to detect macro-level failures in the branch circuits ([0004]-[0005]), the prior art does not teach or suggest “a plurality of current detection sensors respectively connected in series to the plurality of switching elements of the plurality of rectifying power receiving circuits” combined with calculation and comparison means to “compare the time-averaged values of these specific sensors with each other to determine whether an abnormality has occurred in at least one switching element among the plurality of switching elements” as recited. The prior art of record lacks a teaching or motivation to monitor the time-averaged current of individual rectifying AC to DC switching elements in series to diagnose micro-level switch failures.
With regards to claims 15 and 16, the prior art of record, Lee as modified, fails to teach or render obvious the specific diagnostic method claimed. While the prior art, Reschovsky, teaches placing a matching resistor in parallel with a switching element to stabilize reverse leakage currents for accurate ratio comparisons ([0059]-[0060]), the prior art does not teach or suggest “wherein a period during which each of the plurality of switching elements is conductive is determined based on a voltage generated across opposite ends of the corresponding resistor”, nor does the prior art teach “wherein the abnormality determination means further determines, based on the period during which each of the plurality of switching elements is respectively conductive and the comparison result obtained by the comparison means, whether an abnormality has occurred in at least one switching element among the plurality of switching elements”. The prior art utilizes voltage thresholds and ratios to detect faults, but lacks a teaching or motivation to utilize the voltage across a parallel resistor to dynamically calculate the conductive period of the specific switching element to diagnose a fault within the switching element itself.
Response to Arguments
Regarding the 35 U.S.C. 112(b) rejection, applicant’s arguments filed 06/12/2026 have been fully considered and they are persuasive.
With respect to the argument, on page 6, that the amended claims overcome the rejection under 35 U.S.C. 112(b), the Examiner agrees. Applicant amended Claim 3 to delete the duplicative text regarding the arrangement of the current detection sensors. Therefore, the previous rejection of claim 3 under 35 U.S.C. 112(b) is withdrawn.
Regarding the 35 U.S.C. 101 rejection, applicant’s arguments filed 06/12/2026 have been fully considered and they are persuasive.
With respect to the argument, on pages 6-8, that the claims overcome the rejection under 35 U.S.C. 101 because they integrate the judicial exception into a practical application, the Examiner agrees. The amended claims recite meaningful limitations that restrict the abstract idea to a practical technological environment to detect physical hardware failures in a wireless power receiver, providing significantly more that the abstract idea itself. Therefore, the rejection under 35 U.S.C. 101 is withdrawn.
Regarding the 35 U.S.C. 103 rejection of claims 1-4, applicant’s arguments filed 06/12/2026 have been fully considered and they are persuasive.
With respect to the argument, on pages 8-10, that the amended claims overcome the rejection under 35 U.S.C. 103 because Lee and Ohno fail to teach the specific arrangement of the current detection sensors, the Examiner agrees. Claim 1 specifically requires the sensors to be connected in series with switching elements of the rectifying power receiving circuits. The prior art, Ohno, teaches connecting sensors to the output portions of the branch circuits to balance the overall load, but fails to teach placing the sensors in series with the individual AC-to-DC switching elements themselves to diagnose specific switch level abnormalities. Also, because Normet does not teach this deficiency, the 35 U.S.C. 103 rejections of claims 1-4 are withdrawn.
Regarding the allowability of new claims 11-17, applicant’s arguments filed 06/12/2026 have been fully considered but they are not persuasive.
With respect to the argument, on page 10, that new claims 11-17 recite features that are neither taught nor obvious in view of the prior art, the Examiner respectfully disagrees in part. While claims 15-17 do contain allowable subject matter, new claim 11 recites a different sensor topology than claim 1, specifically requiring the sensors to be connected to the output portions and GND portions of the rectifier circuits. This broader monitoring topology is taught by Ohno. Therefore, claim 11 and its dependent claims 12-14 are rejected based on the newly updated combinations of prior art as detailed in the rejections above.
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 OSAMAH MURSHED whose telephone number is (571)272-9534. The examiner can normally be reached Monday - Friday, 11 a.m. 8 p.m. ET..
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/OSAMAH MURSHED/ Examiner, Art Unit 2858
/JUDY NGUYEN/ Supervisory Patent Examiner, Art Unit 2858
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