Prosecution Insights
Last updated: April 19, 2026
Application No. 18/672,740

Flexible Displays with Heating Elements

Non-Final OA §102§103
Filed
May 23, 2024
Examiner
BUI, HUNG S
Art Unit
2841
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Apple Inc.
OA Round
1 (Non-Final)
87%
Grant Probability
Favorable
1-2
OA Rounds
2y 4m
To Grant
98%
With Interview

Examiner Intelligence

Grants 87% — above average
87%
Career Allow Rate
1430 granted / 1638 resolved
+19.3% vs TC avg
Moderate +10% lift
Without
With
+10.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
18 currently pending
Career history
1656
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
53.5%
+13.5% vs TC avg
§102
39.8%
-0.2% vs TC avg
§112
2.0%
-38.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1638 resolved cases

Office Action

§102 §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 . Information Disclosure Statement The IDS filed on 05/23/2024 has been considered and made of record. Oath/Declaration The oath/declaration filed on 05/23/2024 is acceptable. 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. Claims 1-4, 6-7, 10-11 and 16-20 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Myers et al. [US 2019/0069451]. The applied reference has a common assignee with the instant application. Based upon the earlier effectively filed date of the reference, it constitutes prior art under 35 U.S.C. 102(a)(2). This rejection under 35 U.S.C. 102(a)(2) might be overcome by: (1) a showing under 37 CFR 1.130(a) that the subject matter disclosed in the reference was obtained directly or indirectly from the inventor or a joint inventor of this application and is thus not prior art in accordance with 35 U.S.C. 102(b)(2)(A); (2) a showing under 37 CFR 1.130(b) of a prior public disclosure under 35 U.S.C. 102(b)(2)(B) if the same invention is not being claimed; or (3) a statement pursuant to 35 U.S.C. 102(b)(2)(C) establishing that, not later than the effective filing date of the claimed invention, the subject matter disclosed in the reference and the claimed invention were either owned by the same person or subject to an obligation of assignment to the same person or subject to a joint research agreement. Regarding claim 1, Myers et al., disclose an electronic device (10, figures 1-12), comprising: a foldable housing (12, figures 1, 3-4 and 8-9) having first and second housing portions (12A & 12B, figures 3-4 and 10-11) configured to rotate relative to one another about a fold axis (22, figures 1 and 3-4); a flexible display (14, figures 1, 3-4 and 6-11) having first and second display regions (14A and 14C, figures 1 and 6-9) that respectively overlap the first and second housing portions and having a bendable region (14B, figures 1, 3-4 and 6-11) overlapping the fold axis; a display cover layer (a cover layer forms on a top surface of the display panel 14, figure 1, paragraphs 0024-0025) overlapping the first and second display regions and the bendable region; and a heating element (68, figure 9) configured to heat the display cover layer based on a measured temperature (paragraphs 0041 and 0048-0051). Regarding claim 2, Myers et al., disclose a temperature sensor (56, figure 2, paragraph 0050) configured to measure the temperature. Regarding claim 3, Myers et al., disclose wherein the heating element comprises a conductive layer (68, figures 7 and 9) in the display cover layer that is configured to convey ohmic heating current (paragraph 0043). Regarding claim 4, Myers et al., disclose wherein the display cover layer comprises a glass layer (paragraph 0024) and wherein the conductive layer is formed on the glass layer. Regarding claim 6, Myers et al., further disclose wherein the display cover layer comprises a polymer layer (figure 1, paragraph 0025) and wherein the conductive layer is formed on the polymer layer. Regarding claim 7, Myers et al., disclose wherein movement of the first housing portion relative to the second housing portion is restricted when the measured temperature falls below a given threshold (paragraph 0041). Regarding claim 10, Myers et al., further disclose wherein the flexible display is configured to display a message based on the measured temperature (paragraph 0053). Regarding claim 11, Myers et al., disclose an electronic device (10, figures 1-11), comprising: a housing (12, figures 1, 3-4 and 8-9) having first and second housing portions (12A & 12B, figures 3-4 and 10-11) configured to rotate relative to one another about a fold axis (22, figures 1 and 3-4); a flexible display (14, figures 1, 3-4 and 6-11) having first and second display regions (14A and 14C, figures 1 and 6-9) that respectively overlap the first and second housing portions and having a bendable region (14B, figures 1, 3-4 and 6-11) overlapping the fold axis; a display cover layer (a cover layer forms on a top surface of the display panel 14, figure 1, paragraphs 0024-0025) overlapping the first and second display regions and the bendable region; and a temperature sensor (56, figure 2, paragraph 0050) configured to measure temperature (paragraphs 0041 and 0048-0051), wherein movement of the first housing portion relative to the second housing portion is restricted in response to measuring a temperature below a given threshold with the temperature sensor (paragraph 0041). Regarding claim 16, Myers et al., disclose an electronic device (10, figures 1-12), comprising: a foldable housing (12, figures 1, 3-4 and 8-9) having first and second housing portions (12A & 12B, figures 3-4 and 10-11) coupled by a hinge (22, figures 1 and 3-4); a flexible display (14, figures 1, 3-4 and 6-11) having first and second display regions (14A and 14C, figures 1 and 6-9) that respectively overlap the first and second housing portions and having a bendable region (14B, figures 1, 3-4 and 6-11) overlapping the hinge; a display cover layer (a cover layer forms on a top surface of the display panel 14, figure 1, paragraphs 0024-0025) overlapping the first and second display regions and the bendable region; and a heating element (68, figure 9) configured to heat the display cover layer in response to detecting a wrinkle in the display cover layer (a force-based touch sensor in the display device is configured to detect wrinkles in the cover layer, paragraph 0022). Regarding claim 17, Myers et al., further disclose a sensor (a force-based touch sensor in the display device is configured to detect wrinkles in the cover layer, paragraph 0022) configured to detect the wrinkle in the display cover layer. Regarding claim 18, Myers et al. further disclose wherein the sensor is selected from the group consisting of: a strain gauge and an optical sensor (paragraph 0028). Regarding claim 19, Myers et al., disclose a temperature sensor (56, figure 2, paragraph 0050) configured to measure the temperature, wherein the heating element is controlled at least partly based on the measured temperature (paragraph 0043). Regarding claim 20, Myers et al., disclose wherein the heating element comprises a conductive layer configured to convey ohmic heating current (68, figure 9, paragraph 0043). 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 5 is rejected under 35 U.S.C. 103 as being unpatentable over Myers et al., in view of Kim et al. [US 2021/0109619]. Regarding claim 5, Myers et al., disclose the claimed invention except for wherein the conductive layer comprises silver. Kim et al., disclose a foldable display device (DD, figures 1-11) comprising a flexible display (FS, figures 1A-1C) having first and second display regions (NBA1 and NBA2, figures 1A-1C) and having a bendable region (BA, figures 1A-1C) overlapping the fold axis (BX, figures 1A-1C), a plurality of conductive layers (IS-CL1, IS-CL2 and IS-CL3, figure 6) are disposed within the flexible display, and wherein at least one conductive layer comprises silver (paragraph 0104). It would have been to one of ordinary skill in the art at the time the invention was made to use silver material to build a conductive layer in a foldable display of Myers et al., as suggested by Kim et al., in order to bend, fold, and twist without breaking or losing conductivity of the foldable display. Allowable Subject Matter Claims 8-9 and 12-15 are 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 claim 8 discloses the combination features of “wherein the hinge is configured to lock when the measured temperature falls below the given threshold.” This feature(s), in conjunction with other features, as claimed in the combination features of the claims 7 and 1, were neither found to be disclosed, nor suggested by the prior art of records. Claim 9 depends on the allowed claim 8. The claim 12 discloses the combination features of “wherein the housing comprises a hinge coupled between the first and second housing portions and wherein the hinge is configured to lock in response to measuring the temperature below the given threshold with the temperature sensor.” These features, in conjunction with other features, as claimed in the claim 11, were neither found to be disclosed, nor suggested by the prior art of records. Claims 13-15 depend on the allowed claim 12. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: - Nguyen et al. [US 2024/0079442] disclose electronic device with folding display having textured flexible area; and - Ohsawa et al. [US 2017/0139511] disclose touch sensor. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Hung S. Bui whose telephone number is (571)272-2102. The examiner can normally be reached on M-F: 8am-5pm. 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, Allen L. Parker can be reached on (303) 297-4722. 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. /HUNG S. BUI/ Primary Examiner Art Unit 2841 /Hung S. Bui/ Primary Examiner, Art Unit 2841
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Prosecution Timeline

May 23, 2024
Application Filed
Jan 24, 2026
Non-Final Rejection — §102, §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
87%
Grant Probability
98%
With Interview (+10.2%)
2y 4m
Median Time to Grant
Low
PTA Risk
Based on 1638 resolved cases by this examiner. Grant probability derived from career allow rate.

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