Prosecution Insights
Last updated: October 04, 2026
Application No. 18/674,151

GOLF CLUB HEAD

Non-Final OA §103§112
Filed
May 24, 2024
Priority
Jun 23, 2023 — JP 2023-103421
Examiner
PASSANITI, SEBASTIANO
Art Unit
3711
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Bridgestone Corporation
OA Round
3 (Non-Final)
83%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
98%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allowance Rate
1440 granted / 1734 resolved
+13.0% vs TC avg
Strong +16% interview lift
Without
With
+15.5%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 10m
Avg Prosecution
37 currently pending
Career history
1762
Total Applications
across all art units

Statute-Specific Performance

§101
1.3%
-38.7% vs TC avg
§103
39.3%
-0.7% vs TC avg
§102
18.7%
-21.3% vs TC avg
§112
19.2%
-20.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1734 resolved cases

Office Action

§103 §112
DETAILED ACTION This Office action is responsive to communication received 08/17/2026 – Request for Continued Examination (RCE) and Amendment. 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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 08/17/2026 has been entered. Status of Claims Claims 1-15 remain pending. Response to Arguments In the arguments received 08/17/2026, the applicant contends that the operation of the prior art device detailed by Kuo (US PUBS 2006/0100028) would be altered by the proposed modification, as the weight member in Kuo would no longer protrude rearwardly as intended. Moreover, the applicant argues that, if the weight member in Kuo were made to be solid and include a metal, the resulting weight component would be too heavy and would destroy the weight balance and total mass of the club head. The applicant further contends that none of the further, applied teaching references cure the deficiencies in the primary Kuo club head. Applicant’s arguments, see scanned page 3, line 3 through scanned page 4, line 7, with respect to the rejections of claims under 35 U.S.C. §103 have been fully considered and are persuasive. Therefore, the rejections have been withdrawn. However, upon further consideration, and in view of the amendments to independent claim 1, a new ground(s) of rejection under 35 U.S.C. §103 is made in view of USPN 7,988,568 to Stites et al as a primary reference. Several of the previously-applied secondary references have again been applied upon for similar teachings when combined with the newly-cited reference USPN 7,988,568 to Stites et al. No further comments are deemed necessary, here. FOLLOWING IS AN ACTION ON THE MERITS: Claim Rejections - 35 U.S.C. § 112(b) 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. Claim 7 is 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 7, it is noted that independent claim 1 already sets forth that the weight member includes a metal. Perhaps line 4 should simply read --the face portion includes a metal--. Claim Rejections - 35 U.S.C. § 112(d) The following is a quotation of 35 U.S.C. 112(d): (d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. The following is a quotation of pre-AIA 35 U.S.C. 112, fourth paragraph: Subject to the following paragraph [i.e., the fifth paragraph of pre-AIA 35 U.S.C. 112], a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. Claim 9 is rejected under 35 U.S.C. 112(d) or pre-AIA 35 U.S.C. 112, 4th paragraph, as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, or for failing to include all the limitations of the claim upon which it depends. As to claim 9, note that independent claim 1 already sets forth that “the weight member forms a part of an outer surface of the sole portion, the crown portion, and the side portion”. Thus, claim 9 does not further limit the structure of independent claim 1. Applicant may cancel the claim(s), amend the claim(s) to place the claim(s) in proper dependent form, rewrite the claim(s) in independent form, or present a sufficient showing that the dependent claim(s) complies with the statutory requirements. 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. The Supreme Court in KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007) identified a number of rationales to support a conclusion of obviousness which are consistent with the proper "functional approach" to the determination of obviousness as laid down in Graham. The key to supporting any rejection under 35 U.S.C. 103 is the clear articulation of the reason(s) why the claimed invention would have been obvious. The Supreme Court in KSR noted that the analysis supporting a rejection under 35 U.S.C. 103 should be made explicit. In Ball Aerosol v. Ltd. Brands, 555 F.3d 984, 89 USPQ2d 1870 (Fed. Cir. 2009), the Federal Circuit offered additional instruction as to the need for an explicit analysis. The Federal Circuit explained that the Supreme Court’s requirement for an explicit analysis does not require record evidence of an explicit teaching of a motivation to combine in the prior art. PNG media_image1.png 18 19 media_image1.png Greyscale "[T]he analysis that "should be made explicit" refers not to the teachings in the prior art of a motivation to combine, but to the court’s analysis. . . . Under the flexible inquiry set forth by the Supreme Court, the district court therefore erred by failing to take account of 'the inferences and creative steps,' or even routine steps, that an inventor would employ and by failing to find a motivation to combine related pieces from the prior art." Ball Aerosol, 555 F.3d at 993, 89 USPQ2d at 1877. PNG media_image1.png 18 19 media_image1.png Greyscale The Federal Circuit’s directive in Ball Aerosol was addressed to a lower court, but it applies to Office personnel as well. When setting forth a rejection, Office personnel are to continue to make appropriate findings of fact as explained in MPEP § 2141 and § 2143, and must provide a reasoned explanation as to why the invention as claimed would have been obvious to a person of ordinary skill in the art at the time of the invention. This requirement for explanation remains even in situations in which Office personnel may properly rely on intangible realities such as common sense and ordinary ingenuity. PNG media_image1.png 18 19 media_image1.png Greyscale I. EXEMPLARY RATIONALES PNG media_image1.png 18 19 media_image1.png Greyscale Exemplary rationales that may support a conclusion of obviousness include: PNG media_image1.png 18 19 media_image1.png Greyscale (A) Combining prior art elements according to known methods to yield predictable results; PNG media_image1.png 18 19 media_image1.png Greyscale (B) Simple substitution of one known element for another to obtain predictable results; PNG media_image1.png 18 19 media_image1.png Greyscale (C) Use of known technique to improve similar devices (methods, or products) in the same way; PNG media_image1.png 18 19 media_image1.png Greyscale (D) Applying a known technique to a known device (method, or product) ready for improvement to yield predictable results; PNG media_image1.png 18 19 media_image1.png Greyscale (E) "Obvious to try" – choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success; PNG media_image1.png 18 19 media_image1.png Greyscale (F) Known work in one field of endeavor may prompt variations of it for use in either the same field or a different one based on design incentives or other market forces if the variations are predictable to one of ordinary skill in the art; PNG media_image1.png 18 19 media_image1.png Greyscale (G) Some teaching, suggestion, or motivation in the prior art that would have led one of ordinary skill to modify the prior art reference or to combine prior art reference teachings to arrive at the claimed invention. Claims 1, 3, 4, 6, 9, 11, 13 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings of USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi. As to independent claim 1, Stites shows a golf club head (402) that is hollow (i.e., wood-type club head formed by connecting a plurality of body members; col. 11, line 49 through col. 12, line 21), the golf club head comprising: a body portion (408) including a carbon fiber-reinforced plastic (i.e., col. 12, line 16); a face portion (404) including a face surface that is to be a striking surface; a weight member (410; col. 12, lines 56-61) attached to the body portion (408); and a screw that fastens the weight member (i.e., Stites notes that “other threaded arrangements” may be used to secure mass 410; col. 13, line 19), wherein the body portion (408) includes a sole portion, a crown portion, a side portion, and a back portion (i.e., col. 12, lines 3-7), the weight member (410) is disposed at an outer-surface side of the back portion, the weight member (410) forms a part of an outer shape of the golf club head (FIGS. 4A-4B), the back portion is not visible from an exterior of the golf club head (FIGS. 4A-4B), and the inner surface and the outer surface of the back portion are flat surfaces and parallel to each other (FIGS. 4A-4B; noting the back portion of hollow body 408, adjacent to the general area where the rails 412 enter and exit the flat inner and outer wall portion of body 408), wherein the weight member (410) includes a metal (i.e., weight body 410 may be made of any material that is available for constructing the remainder of the club head body 408; col. 12, lines 27-29), and wherein the weight member (410) forms a part of an outer surface of the sole portion, the crown portion, and the side portion (FIGS. 4A, 4B, 6A, 6B; and col. 12, lines 22-32). Stites differs from the claimed invention in that Stites does not explicitly disclose that the volume is “from 400 cc through 460 cc” or that the weight member identified as body portion (410) is “solid” or that the “other threaded arrangements” disclosed by Stites are fastened “from an inner-surface side of the back portion”. Hirano teaches a volume for a hollow club head body of between 400 cc and 460 cc in order to increase both the moment of inertia of the club head as well as the center of gravity depth of the club head, which leads to an increase in the carry distance and directional stability of a struck golf ball (i.e., col. 3, lines 1-9 in Hirano). Note that Stites is similarly concerned with manipulating the location of the center of gravity to improve the hitting efficiency of the club head (i.e., see col. 2, lines 1-11 in Stites). In view of the teachings in Hirano, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by providing the club head body (408) with a volume of between 400 cc and 460 cc for enlarging the moment of inertia of the golf club head so as to enhance the ball striking performance of the club head. In addition, the prior art reference to Kobayashi clearly shows a solid weight member (12) that covers all of the back portion of the club head when the weight member (12) is attached to the club head body. Note that the club head body (11) in Kobayashi may comprise a hollow-type construction and that the club head may comprise carbon-fiber reinforced plastic material while the weight 12 includes metal (i.e., col. 2, line 55 through col. 3, line 6). All of Stites, Hirano and Kobayashi are clearly related in terms of construction of the club head body (i.e., each shows a hollow club head body) and each is concerned with providing weight at a rear portion of the club head body. Thus, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by constructing the weight body (410) as a solid weight made of metal in order to add increased weight towards the rear of the club head so as to move the center of gravity rearward for enhanced club head performance. Moreover, Kuo shows it to be old in the art to use screws that are inserted from an inner-surface side of a back portion, with the screws continuing in the direction of an outer-surface side of the back portion to connect with a weight member (i.e., see FIGS. 3 and 5). In view of the teaching in Kuo, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by taking advantage of a screw to fasten the weight body (410), as the use of a screw to securely retain the weight body (410) to the main body (408) would have been a readily-recognized equivalent for the “other threaded arrangements” hinted by Stites. Such a modification would have involved the simple substitution of one known element (i.e., a screw, as used by Kuo) for another element (i.e., the “other threaded arrangements” of Stites) to obtain a predictable result (i.e., the fastening of the weight body 410 to the main body 408 in Stites). KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). As to claim 3, the face portion (404) and the body portion (408) in Stites may be separate members (i.e., col. 12, lines 3-10). As to claim 4, note that Kuo teaches the use of two screw holes (22) in the weight member (20), as shown in FIG. 5. It would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by using two or more internal thread holes for accommodating two or more respective screws for securing the weight body (410) in a manner that helps to avoid twisting of the weight body (410) that might occur during impact between the club head and a golf ball. As to claim 6, Stites lacks an explicit disclosure of “wherein the weight member includes a material having a specific gravity of from 7 through 14, the face portion includes a material having a specific gravity of from 1 through 5, and the body portion includes a material having a specific gravity of from 1 through 2”. In an analogous club head having a face portion, a body portion and a weight member, Hirano details the differences in specific gravity of the materials used in each part of the club head. For instance, in general, see col. 4, line 62 through col. 5, line 47, wherein Hirano sets forth the specific gravity of the face member (1F) as being not less than 3.0 and not more than 5.0 (i.e., specifically col. 5, lines 6-9); the specific gravity of the body member (1M) as being not less than 1.0 and not more than 3.5 (i.e., specifically col. 5, lines 37-41); and the specific gravity of the weight member (1R) as being not less than 6.0 and not more than 11.5 (i.e., specifically col. 5, lines 19-23). Hirano, within the general passage noted herein, sets forth the rationales for limiting the specific gravity of each of the face member, body member and weight member for reasons such as better castability, ease in increasing the moment of inertia, and sufficient strength of the club head. In view of the teaching in Hirano, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by incorporating materials in the construction of the club head such that the weight member (410) includes a material having a specific gravity of from 7 through 14, the face portion (404) includes a material having a specific gravity of from 1 through 5, and the body portion (408) includes a material having a specific gravity of from 1 through 2, with there being a reasonable expectation of success that including materials for the face portion, body portion and weight member having specific gravity values within the claimed ranges would have provided for a club head that maximizes the moment of inertia of the club head and relocates the center of gravity club head depth so as to improve the overall performance of the club head. As to claim 9, Stites shows that the weight member (410) forms a part of an outer surface of the sole portion, the crown portion, and the side portion (i.e., note similar limitations already treated under claim 1 supra, and note FIGS. 4A, 4B, 6A, 6B; and col. 12, lines 22-32). As to claim 11, see FIGS. 4 and 5 in Kuo, which shows it to be old to orient the screws (30) in a face-back direction when viewed in a crown-sole direction (i.e., when viewed from above, the screws 30 extend rearwardly from the face portion towards the weight member). Thus, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by orienting the screw provided by the modification through Kuo with an orientation in a face-to-back direction in order to enable the skilled artisan to assemble the club head when, for example, the club head is assembled from several separate pieces, as is described by Stites. Here, for example, having the screws oriented in a face-back direction would have facilitated securing the weight body (410) prior to installation of the face portion (404) in Stites. As to claim 13, Stites teaches that the body portion (408) may include a face (404) as a separate member that is attached to the body portion (408) through appropriate joining techniques (i.e., col. 12, lines 3-11). As to claim 15, again, note that Kuo teaches the use of two screw holes (22) in the weight member (20), as shown in FIG. 5. It would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by using two screws for securing the weight body (410) in a side-by-side configuration in a toe-heel direction, as taught by Kuo, to avoid twisting of the weight body (410) that might occur during impact between the club head and a golf ball. Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings of USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi and also in view of US PUBS 2009/0270199 to Chen. As to claim 2, it is noted that Stites makes a general mention of adhesive for connecting various club head body parts (i.e., col. 12, lines 8-12). However, Stites, as modified by the combined teachings of Kuo, Hirano and Kobayashi, does not explicitly disclose that the weight member is fastened “adhesively” to the back portion of the club head in combination with the screws. Chen shows a similarly-styled club head having three distinct pieces that are held together both adhesively and with screws (i.e., see paragraphs [0016] and [0018] in Chen). The arrangement in Chen securely fixes all the pieces of the club head together (i.e., see the Abstract in Chen). In view of the teaching in Chen, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by supplementing the connections that use screws to further include an adhesive attachment between the weight member (410) and the body portion (408) in the Stites club head for added club head integrity, wherein all of the pieces of the club head are securely mated to one another. Note that the club head in Stites, as depicted in FIG. 4A, may be used as a regular or normal club head when the weight body (410) is attached and held firmly against the main body (408). This is in contrast to the example in FIG. 4B of Stites, which may be more useful as a training club head (i.e., see col. 12, lines 53-56). Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites (‘568)”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings to USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi and also in view of US PUBS 2013/0324276 to Stites et al (hereinafter referred to as “Stites (‘276)”). As to claim 5, Stites (‘568) in view of the combined teachings of Kuo, Hirano and Kobayashi has been discussed above. Stites (‘568) shows what might be considered projections (512) that are introduced within respective recesses (514), as shown in FIGS. 5A, 5B. However, it is likely that these projections and recesses would have been replaced with the screws taught by Kuo, as advanced in the explanation supra under the rejection of claim 1. As such, it may be argued that Stites (‘568), as modified by the combined teachings of Kuo, Hirano and Kobayashi, does not explicitly disclose a “projection” as part of the back portion nor a “recess” as part of the weight member, wherein “the projection and the recess are fitted into each other”. Stites (‘276) shows it to be old in the art to provide a main body with projections that are fitted within matching apertures or recesses on an adjustable weight member (i.e., paragraph [0062] and FIG. 3). The arrangement in Stites (‘276) provides a secure engagement between mating club head parts. In view of the teaching in Stites (‘276), it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites (‘568) by additionally incorporating a combination of a projection and a recess for securely mating the weight member (410) to the main body (408). Such a modification would have involved the use of a known technique (i.e., the use of a complimentary projection and recess arrangement to secure mating parts of a club head, as taught by Stites(‘276), to improve similar devices in the same way (i.e., both Stites (‘276) and Stites (‘568) disclose multi-part club heads in which mechanical joining features are used to secure mating parts). KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Claims 7 and 8 are rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings to USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi and also in view of US PUBS 2023/0191211 to Hsu et al (hereinafter referred to as “Hsu”). Note that the publication to Hsu includes an earlier filing date of December 15, 2022 and relies on a foreign priority date of December 17, 2021. As to claim 7, Stites does disclose that the face portion and the weight member may include a metal material (i.e., col. 12, lines 11-17; and col. 12, lines 56-61). However, Stites, even as modified by the combined teachings of Kuo, Hirano and Kobayashi, does not explicitly disclose “a stack of sheets of the carbon fiber-reinforced plastic”. Here, Hsu shows it to be old in the art to construct a main body portion of a golf club head from plural sheets of fiber-reinforced material assembled together to form a unitary club head body (i.e., paragraph [0019] in Hsu). The use of multiple plies stacked together enables the characteristics of the club head to be selectively altered in terms of stiffness based upon the modulus of elasticity of the various carbon-fiber component plies (i.e., again, paragraph [0019] in Hsu) and offers the skilled artisan a magnitude of design freedom in selecting and arranging the multiple plies for effectively rearranging the mass distribution of the club head (i.e., paragraph [0032] in Hsu). As such, the performance requirements of the club head may be changed according to the type of club head produced (i.e., paragraph [0022] in Hsu). It is further noted that Hsu likewise incorporates metal material within both the face component as well as within a weight member disposed at the rear end of the club head body (i.e., [0023] and [0031] in Hsu). In view of the teachings in Hsu, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by utilizing a stack of sheets of carbon fiber-reinforced plastic material for the body portion in order to enable the weight and stiffness requirements of the club head body portion to be more selectively tailored for enhanced club head performance. As to claim 8, Stites, as modified by the combined teachings of Kuo, Hirano and Kobayashi, lacks “a weight of the weight member is from 25 g through 55 g”. Here, Hsu teaches that a weight located at the rear end of the body portion may include a weight of between 20 g to 70 g (i.e., paragraph [0032]). Hsu teaches that the weight of the weight component may be adjusted to set the center of gravity of the club head at a better position and to increase the moment of inertia of the club head. In view of the teaching in Hsu, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by structuring the weight portion (410) to include a weight of between 25 grams through 55 grams in order provide a high moment of inertia to reduce club head twisting. Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites (‘568)”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings to USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi and also in view of the combined teachings of US PUBS 2010/0173724 to Stites et al (hereinafter referred to as “Stites (‘724)”) and Document ID TW-M265079 to Li (hereinafter referred to as “Li”). As to claim 10, Stites (‘568), as modified by the combined teachings of Kuo, Hirano and Kobayashi, lacks an explicit disclosure of “a washer disposed at the inner-surface side of the back portion”. Each of Stites (‘724) and Li teaches that a washer may be situated between a head of a bolt or screw and a substrate against which the bolt or screw is tightened. A washer, in a mechanical application, is customarily used to ensure tightness between mating parts, distributes the pressure associated with the tightening of the bolt or screw, and facilitates installation and removal of the screw or bolt. See FIGS. 1-2 and scanned page 2, lines 14, 17-18, and 24-27 in Li, which describes the use of a washer between a bolt and a surface of the club head. See FIGS. 13-14 and paragraph [0051] in Stites (‘724), which describes the use of a washer to help retain a weight member on a rear portion of a club head. In view of the above reasoning and the combined teachings in Lin and Stites, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites (‘568) by taking advantage of a washer disposed at the inner-surface side of the back portion in order to help securely retain the screw(s) provided by the modification with Kuo to make it easier to remove and reinstall the weight portion (410) through the combination of a screw and washer assembly. Such a modification would have involved the use of a known technique (i.e., the use of a washer in a mechanical assembly to facilitate installation and removal of the screw or bolt, as taught by Lin and Stites (‘724)) to improve similar devices in the same way (i.e., each of Lin, Stites (‘724) and Stites (‘568) disclose multi-part club heads in which mechanical joining features are used to secure mating parts) in the same way. KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007). Claim 12 is rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings of USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi and also in view of US PUBS 2016/0271462 to Knuth et al (hereinafter referred to as “Knuth”). As to claim 12, Stites, as modified by the combined teachings of Kuo, Hirano and Kobayashi, lacks the feature “wherein a thickness of the back portion is greater than thicknesses of the sole portion, the crown portion, and the side portion”. In a related, hollow golf club head with varying shell thicknesses, Knuth shows it to be old in the art to dimension a back wall portion of the club head with a shell thickness that is greater than a thickness of the sole, crown and side portions in order to move the center of gravity rearwardly in the golf club head for improved weight distribution, thereby providing higher and longer golf ball travel with reduced golf ball spin (i.e., see paragraphs [0025] and [0026] and Fig. 4 in Knuth). In view of the teaching in Knuth, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the device in Stites by dimensioning the wall of the back portion of the club head body (408) with a greater thickness than each of the crown, sole and side portions in order to move the center of gravity rearwardly, away from the striking face, the motivation being to improve the overall performance of the golf club head by promoting less spin of a golf ball upon impact and promoting higher and longer ball travel. Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over USPN 7,988,568 to Stites et al (hereinafter referred to as “Stites”) in view of US PUBS 2006/0100028 to Kuo and also in view of the combined teachings of USPN 8,435,137 to Hirano and USPN 4,811,950 to Kobayashi and also in view of USPN 7,607,992 to Nishio. As to claim 14, Stites teaches that the face portion (404) may be a separate member that is attached to an opening in the body portion (408) to close the opening (i.e., col. 11, line 67 through col. 12, line 11). However, Stites does not explicitly disclose “a monocoque structure” for the sole portion, the crown portion, the side portion and the back portion. It is noted that Stites does mention the use of carbon fiber composite materials for the club head (i.e., col. 12, lines 15-16). Here, Nishio teaches that a sole portion, a crown portion, side portions and a back portion may collectively be formed from sheets of reinforcing fibers impregnated with a resin to form a monocoque main body. The monocoque construction enhances the strength of the main body (i.e., see col. 6, lines 59-67 in Nishio). In view of the teaching in Nishio, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Stites by using the disclosed carbon composite materials and forming the sole portion, the crown portion, the side portion and the back portion as a monocoque structure for increased strength of the main club head body. Further References of Interest The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Fig. 9 in Hettinger shows a weight portion (16) attached to the main body portion using screws (40, 41) inserted in a face-to-back direction. / / / Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SEBASTIANO PASSANITI whose telephone number is (571)272-4413. The examiner can normally be reached 9:00AM-5:00PM Mon-Fri. 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, Nicholas Weiss can be reached at (571)-270-1775. 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. SEBASTIANO PASSANITI Primary Examiner Art Unit 3711 /SEBASTIANO PASSANITI/Primary Examiner, Art Unit 3711
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Prosecution Timeline

May 24, 2024
Application Filed
Jan 15, 2026
Non-Final Rejection mailed — §103, §112
Apr 09, 2026
Response Filed
Jun 04, 2026
Final Rejection mailed — §103, §112
Aug 17, 2026
Request for Continued Examination
Aug 19, 2026
Response after Non-Final Action
Sep 15, 2026
Non-Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12741182
GOLF CLUB HEAD WITH VORTEX GENERATORS
4y 5m to grant Granted Sep 22, 2026
Patent 12734418
CUSTOMIZED GOLF PUTTERS AND METHODS OF CONSTRUCTING CUSTOMIZED GOLF PUTTERS
3y 9m to grant Granted Sep 15, 2026
Patent 12734416
GOLF CLUB HEAD
2y 7m to grant Granted Sep 15, 2026
Patent 12728329
Putter grip to help with golf club alignment
4y 2m to grant Granted Sep 08, 2026
Patent 12728322
GOLF CLUB HEAD HAVING A MULTI-MATERIAL FACE AND METHOD OF MANUFACTURE
4y 1m to grant Granted Sep 08, 2026
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
83%
Grant Probability
98%
With Interview (+15.5%)
1y 10m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 1734 resolved cases by this examiner. Grant probability derived from career allowance rate.

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