Prosecution Insights
Last updated: October 26, 2026
Application No. 18/650,780

Heated Circuit Board Apparatus

Non-Final OA §102§103
Filed
Apr 30, 2024
Examiner
FREAL, JOHN BRENDAN
Art Unit
2847
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Dell Products L.P.
OA Round
1 (Non-Final)
93%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 93% — above average
93%
Career Allowance Rate
193 granted / 207 resolved
+25.2% vs TC avg
Moderate +8% lift
Without
With
+8.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 2m
Avg Prosecution
21 currently pending
Career history
225
Total Applications
across all art units

Statute-Specific Performance

§101
0.9%
-39.1% vs TC avg
§103
53.3%
+13.3% vs TC avg
§102
39.4%
-0.6% vs TC avg
§112
5.4%
-34.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 207 resolved cases

Office Action

§102 §103
DETAILED ACTION This Office Action is responsive to the Applicant’s communication filed 30 April 2024. In view of this communication, claims 1-20 are pending in the application. 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 Objections Claim 18 is objected to because of the following informalities: Line 6 of claim 18 states “the heating element configured to generate when in an operating state” which the examiner believes may have been intended to be “the heating element configured to generate heat when in an operating state.” Appropriate correction is required. 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. 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) 1-2 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Kobayashi (US 20190014654 A1), hereinafter referred to as Kobayashi. Regarding claim 1, Kobayashi teaches a circuit board having one or more computer-based components, the circuit board comprising: a ground plane (50) (Fig. 4 and paragraph 33: bus bars 50 which may be grounded); a dielectric layer (20) overlaying the ground plane (50), the dielectric layer (20) having an opening (21) defined therein such that an area of the ground plane (50) is exposed (Fig. 3 and paragraph 30: circuit board 20 has openings 21 to expose areas of bus bars 50); and a heating device (30) mounted within the opening (21) and thermally coupled to the ground plane (50) such that energizing the heating device (30) transfers heat to the ground plane (50) (Fig. 3 and paragraph 30: MOSFETs 30 are connected to the bus bars 50 via the openings 21; paragraphs 42-43 and 48: the heat generated by MOSFETs 30 is dissipated through bus bars 50 to the plate 90). Regarding claim 2, Kobayashi teaches the circuit board of Claim 1, wherein the heating device (30) is a MOSFET heating device having a heating element thermally coupled to the ground plane (50) (Fig. 3 and paragraph 30: heat generating MOSFET 30 is connected to a bus bar 50). 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) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Morton et al. (US 6262392 B1), hereinafter referred to as Morton et al. Regarding claim 3, Kobayashi teaches the circuit board of Claim 2, but does not teach that the ground plane is a copper sheet. Morton et al. does teach that the ground plane may be a copper sheet (Morton et al. column 1, lines 64-65: the ground layers are usually copper). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to form the ground plane of Kobayashi from copper as taught by Morton et al. since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as a matter of obvious design choice. In re Leshin, 125 USPQ 416." Claim(s) 4-6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Parameswaran et al. (US 10620644 B1), hereinafter referred to as Parameswaran et al. Regarding claim 4, Kobayashi teaches the circuit board of Claim 1, but does not teach a heating manager device to which the heating device is responsive. Parameswaran et al. does teach a heating manager device (212) to which the heating device is responsive (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: heating element controller 212 adjusts the performance of the IC in response to temperature data from sensors 214). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the circuit board of Kobayashi with a heating manager device as taught by Parameswaran et al. because the heating manager device of Parameswaran et al. is able to monitor and adjust the behavior of the chips and resolve hotspots (Parameswaran et al. column 10, lines 15-18). Regarding claim 5, Kobayashi in view of Parameswaran et al. teaches the circuit board of Claim 4, wherein the one or more computer-based components comprises a temperature sensor (214) responsive to the heating manager device (212) (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: heating element controller 212 adjusts the performance of the IC in response to temperature data collected by the sensors 214). Regarding claim 6, Kobayashi in view of Parameswaran et al. teaches the circuit board of Claim 5, wherein the heating device (30) is a MOSFET heating device having a heating element thermally coupled to the ground plane (50) (Fig. 3 and paragraph 30: heat generating MOSFET 30 is connected to a bus bar 50). Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Parameswaran et al. in further view of Morton et al. Regarding claim 7, Kobayashi in view of Parameswaran et al. teaches the circuit board of Claim 6, but does not teach that the ground plane is a copper sheet. Morton et al. does teach that the ground plane may be a copper sheet (Morton et al. column 1, lines 64-65: the ground layers are usually copper). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to form the ground plane of Kobayashi as modified by Parameswaran et al. from copper as taught by Morton et al. since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as a matter of obvious design choice. In re Leshin, 125 USPQ 416." Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of White (US 20130180973 A1), hereinafter referred to as White. Regarding claim 8, Kobayashi teaches the circuit board of claim 1, but does not teach that the circuit board is associated with a computer-based server. White does teach that the circuit board may be associated with a computer-based server (White paragraph 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention that the circuit board of Kobayashi could be used in a computer-based server as mentioned in White because White (paragraph 3) teaches that servers are well-known applications in the art for PCBs, which mechanically support and couple the electronic components used in those servers. Claim(s) 9-11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of White, in further view of Parameswaran et al. Regarding claim 9, Kobayashi in view of White teaches the circuit board of Claim 8, but does not teach that the heating device is responsive to a heating manager device associated with the server. Parameswaran et al. does teach that the heating device is responsive to a heating manager device associated with the server (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: remote heating element controller 212 adjusts the performance of the IC in response to temperature data from sensors 214). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the circuit board of Kobayashi with a heating manager device as taught by Parameswaran et al. because the heating manager device of Parameswaran et al. is able to monitor and adjust the behavior of the chips and resolve hotspots (Parameswaran et al. column 10, lines 15-18). Regarding claim 10, Kobayashi in view of White and Parameswaran et al. teaches the circuit board of Claim 9, wherein the one or more computer-based components comprises a temperature sensor (214) responsive to the heating manager device (212) (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: heating element controller 212 adjusts the performance of the IC in response to temperature data collected by the sensors 214). Regarding claim 11, Kobayashi in view of White and Parameswaran et al. teaches the circuit board of claim 10, wherein the heating device (30) is a MOSFET heating device having a heating element thermally coupled to the ground plane (50) (Fig. 3 and paragraph 30: heat generating MOSFET 30 is connected to a bus bar 50). Claim(s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Parameswaran et al. and White, in further view of Morton et al. Regarding claim 12, Kobayashi in view of Parameswaran et al. and White teaches the circuit board of Claim 11, but does not teach that the ground plane is a copper sheet. Morton et al. does teach that the ground plane may be a copper sheet (Morton et al. column 1, lines 64-65: the ground layers are usually copper). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to form the ground plane of Kobayashi as modified by Parameswaran et al. from copper as taught by Morton et al. since it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as a matter of obvious design choice. In re Leshin, 125 USPQ 416." Claim(s) 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Arufuretsudo (JP H0690069 A), hereinafter referred to as Arufuretsudo et al. Regarding claim 13, Kobayashi teaches the circuit board of claim 1, but does not teach a second dielectric layer overlaying an opposing side of the copper sheet and having a second opening defined therein such that a second area of the ground plane is exposed. Kobayashi does not teach a second heating device mounted within the second opening and thermally coupled to the ground plane such that energizing the heating device transfers heat to the ground plane. Arufuretsudo et al. does teach a second dielectric layer (11b) overlaying an opposing side of the copper sheet (15) and having a second opening (16) defined therein such that a second area of the ground plane (15) is exposed and a second heating device (12) mounted within the second opening (16) and thermally coupled to the ground plane (15) such that energizing the heating device (12) transfers heat to the ground plane (15) (Arufuretsudo et al. Fig. 2 and page 3, paragraphs 4 and 6: two layers of non-conductive material 11a, 11b are arranged on either side of a copper ground plane 15 with openings 15 in which devices 12 are mounted). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to form a second dielectric layer with an opening for a second heating device as taught by Arufuretsudo et al. on the circuit board of Kobayashi because Arufuretsudo et al. teaches that additional devices can be mounted as described on the lower side of the board to increase the functionality of the device while the additional heat that is generated can be compensated for (Arufuretsudo et al. Abstract). Claim(s) 14-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Arufuretsudo et al., in further view of Parameswaran et al. Regarding claim 14, Kobayashi in view of Arufuretsudo et al. teaches the circuit board of claim 13, but does not teach a heating manager device to which the heating device is responsive. Parameswaran et al. does teach a heating manager device (212) to which the heating device is responsive (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: remote heating element controller 212 adjusts the IC in response to temperature data from sensors 214). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the circuit board of Kobayashi with a heating manager device as taught by Parameswaran et al. because the heating manager device of Parameswaran et al. is able to monitor and adjust the behavior of the chips and resolve hotspots (Parameswaran et al. column 10, lines 15-18). Regarding claim 15, Kobayashi in view of Arufuretsudo et al. and Parameswaran et al. teaches the circuit board of claim 14, wherein the one or more computer-based components comprises a temperature sensor (214) responsive to the heating manager device (212) (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: heating element controller 212 adjusts the performance of the IC in response to temperature data collected by the sensors 214). Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Arufuretsudo et al., in further view of White. Regarding claim 16, Kobayashi in view of Arufuretsudo et al. teaches the circuit board of claim 13, but does not teach that the circuit board is associated with a computer-based server. White does teach that the circuit board may be associated with a computer-based server (White paragraph 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention that the circuit board of Kobayashi as modified by Arufuretsudo et al. could be used in a computer-based server as mentioned in White because White (paragraph 3) teaches that servers are well-known applications in the art for PCBs, which mechanically support and couple the electronic components used in those servers. Claim(s) 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kobayashi in view of Arufuretsudo et al. and White, in further view of Parameswaran et al. Regarding claim 17, Kobayashi in view of Arufuretsudo et al. and White teaches the the circuit board of Claim 16, but does not teach that the heating device is responsive to a heating manager device associated with the server and wherein the one or more computer-based components comprises a temperature sensor responsive to the heating manager device. Parameswaran et al. does teach that the heating device is responsive to a heating manager device associated with the server and wherein the one or more computer-based components comprises a temperature sensor (214) responsive to the heating manager device (212) (Parameswaran et al. Fig. 2, column 9, lines 53-60, and column 10, lines 4-18: remote heating element controller 212 adjusts the performance of the IC in response to temperature data from sensors 214). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide the circuit board of Kobayashi with a heating manager device as taught by Parameswaran et al. because the heating manager device of Parameswaran et al. is able to monitor and adjust the behavior of the chips and resolve hotspots (Parameswaran et al. column 10, lines 15-18). Allowable Subject Matter Claims 18-20 are allowed. Regarding claim 18, the prior art of record, taken alone or in combination, fails to teach or fairly suggest, in combination with the other limitations recited in the claim a heating element mounted within a hole in the top layer, wherein the heating element is configured to heat the ground plane and the at least one electronic component is configured to absorb heat thermally conducted from the heating element via the ground plane. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Van Straten (US 10272818 B2) Armani et al. (US 20180092198 A1) Chou (US 20140027435 A1) Chen et al. (US 8546904 B2) Any inquiry concerning this communication or earlier communications from the examiner should be directed to John B Freal whose telephone number is (571)272-4056. The examiner can normally be reached Mon-Fri 7:00-3:00. 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, Timothy J Thompson can be reached at (571)272-2342. 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. /JOHN B FREAL/Examiner, Art Unit 2847 /TIMOTHY J THOMPSON/Supervisory Patent Examiner, Art Unit 2847
Read full office action

Prosecution Timeline

Apr 30, 2024
Application Filed
Oct 14, 2026
Non-Final Rejection mailed — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12772391
INSULATION STRUCTURE AND ELECTRONIC DEVICE
2y 6m to grant Granted Oct 20, 2026
Patent 12757322
CIRCUIT BOARD AND ELECTRONIC DEVICE
2y 10m to grant Granted Oct 06, 2026
Patent 12723695
Water Grounding Apparatus for a Plastic Pipe Plumbing System
2y 3m to grant Granted Sep 01, 2026
Patent 12713538
PRINTED WIRING BOARD
2y 5m to grant Granted Aug 18, 2026
Patent 12707984
SUBSTRATE BARCODE READABILITY ENHANCEMENT STRUCTURES AND METHOD
3y 4m to grant Granted Aug 11, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

1-2
Expected OA Rounds
93%
Grant Probability
99%
With Interview (+8.5%)
2y 2m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 207 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month