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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicants' submission filed on February 20, 2026 has been entered.
Response to Arguments
Applicants' arguments filed with the RCE have been fully considered but they are not persuasive.
Claim 1 recites “prior to a power transfer phase”. The claim does not recite the name/type of phase in which these steps occur. The use of “comprising” in the preamble also does not prohibit the existence of multiple power transfer phases.
Even if Martchovsky conducts its measurements and estimations during power transfer, the receiver’s request is for a negotiation or re-negotiation. This ends the power transfer phase and begins a (re)negotiation phase. When this (re)negotiation phase is over, a subsequent power transfer phase will begin. Thus, Martchovsky’s negotiation is “prior to a power transfer phase” (even if it also starting during a previous power transfer phase).
To clarify this interpretation of Martchovsky, the art rejection is updated to cite to Park (US 11,411,442) figures 11 and 15. These figures show how a power transfer phase is exited in order to conduct a negotiation (or renegotiation) phase.
The same analysis applies to claims 21 and 32.
Claim Objections
Claims 1 and 21 are objected to because it appears that the “negotiating” step (claim 1, line 8; claim 21, line 11) is incorrect. A negotiation requires a back-and-forth communication to arrive at an agreed upon result. This would include at least one request and one reply. But claim 1 already recites “receiving a Requested Power”. Half of the negotiation step is already present. The claim is missing a reply or confirmation. The method step which (incorrectly) begins “negotiating” is directed to how the transmitter internally makes a determination about its Guarantee Power. These are internal deliberations/calculations and not a back-and-forth negotiation process.
Appropriate correction is required.
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.
Claims 1-9, 11-13, 21-28 and 32-33 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention.
Claim 1 has been amended to recite the functionality of “controlling transmission of the wireless power” during the power transfer phase. This control method step, however, is unclearly defined.
The claim recites that this “controlling transmission” step is carried out by “using an operating control parameter”. “using” is indefinite and does not actually set forth the metes and bounds of the claim for the public to understand what is being done.
The claim then recites that this operating control parameter is “based on” three other signals. But there are no method steps that establish that the transmitter: A) receives P-request; B) measured P-measured; or C) measures PTx-loss. It is unclear how these data points exist in the transmitter if it never receivers, measures or creates them. The Applicants have established language for how the transmitter receives communications from the receiver (see first “receiving” step) and determines additional information (see “determining”, “negotiating” steps). The different language in the amended limitation indicates that the Applicant intends to treat this information differently. But if it isn’t actually received or determined within the scope of the method, it is unclear how the transmitter gets them.
Different readers would draw different conclusions as to the scope of the features of the last limitation of claim 1. This makes the claim indefinite.
Claims 2-9 and 11-13 are similarly rejected as they depend from, and inherit the deficiencies of, claim 1.
Claim 13 is indefinite because there is no antecedent basis in the claim for “the Magnetic Power Source”. The introduction of this limitation was deleted with the RCE amendment.
Claim 21 is indefinite for the similar same reason as claim 1, as it uses nearly the same language. Claims 22-28 are similarly rejected as they depend from, and inherit the deficiencies of, claim 21.
Claim 32 is indefinite for similar same reasons as claim 1, there is no basis in the claim for “based on [] a measured power (P-measured), and a measured PTx-loss. There are no method steps that explicitly recite that the transmitter makes these measurements. Claim 33 is similarly rejected as they depend from, and inherit the deficiencies of, claim 32.
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.
Claims 1-9, 11, 13, 21-28 and 32-33 are rejected under 35 U.S.C. 103 as being unpatentable over Martchovsky (US 2020/0227952) in view of Park (US 11,411,442).
With respect to claim 1, Martchovksy discloses a method for power negotiation by a Power Transmitter (figs 1-3; all text) of a wireless power system, comprising:
prior to a power transfer phase (obvious or supported by Park, as expanded upon below);
receiving a Requested Power negotiation value (step 302, “RP”; par 20) from a Power Receiver;
determining a value of estimated power transmission losses (PTx-loss) of the Power Transmitter associated with transmitting wireless power to the Power Receiver (par 18, 25 – there is a reduction in MAP, maximum available power, because of the environment [i.e. losses] – this value is “determined” in step 304);
negotiating [sic] a Guaranteed Power (Martchovsky refers to guaranteed power as “available power”, AP) for the Power Receiver based on the Requested Power negotiation value (“RP”), the estimated PTx-loss value (reductions in “MAP”, per par 25), and Available Power of the Power Transmitter (final value of “MAP”)(iteration of steps 304, 306, 308, 310, 312); and
reserving, from the Available Power, a Negotiated Power (P-nego) for transmission of the wireless power to the Power Receiver, wherein the Negotiated Power is based on the Guaranteed Power (step 314 – the reservation of P-nego is “adjust AP to support requested RP”; see also par 29); and
during the power transfer phase, controlling transmission of the wireless power to the Power Receiver (par 26, “Tx 102 is configured to maintain the power transfer level at the NP as long as the current MAP is greater than NP) using an operating control parameter (output of controller 107 that actually regulates the [unclaimed] power transmission circuitry; see par 21, lines 2-4) that is based on a Power Request (P-request) message received from the Power Receiver (RP; step 302), a measured power (P-measured) (MAP; step 304), and a measured PTx-loss (the reductions in MAP, discussed above).
Martchovsky discloses that a wireless power transmitter has at least two phases: a power transfer phase; and a (re)negotiation phase. These two phases constantly repeat and any one (re)negotiation phase is “prior to” the next power transfer phase.
The Martchovksy transmitter, upon (1) a receiver request for power, completes the following actions: (2) determines an estimated value of losses; (3) determines (i.e. negotiates with itself) how much power it can send; (4) reserves power for the receiver; and (5) controls transmission of this power to the receiver. Steps 5 is a subsequent power transfer phase and all other steps (1-4) are “prior to” it.
2) Step 304 discloses that the MAP and AP are monitored (par 25). If these values are known, then their difference (caused by losses; par 18, 25) is “determined”. The “estimated” Tx-loss value is not explicitly used – the guaranteed power is only broadly “based on” Tx-loss – it not “summed” or “combined”.
3) Steps 306 and 310 discloses how the transmitter uses the original request and transmission losses to determine how much power it can send.
4) Steps 308, 312, 314 discloses how the transmitter reserves power for transmission. If the transmitter has enough power to spare, then it is provided – thereby “reserving” it (308). If the transmitter does not have enough power to spare, then, it may either decline the request (312) or reserve a lower power value (314).
5) After the acknowledgement in step 306 that requested power can be satisfied, Martchovksy’s controller controls transmission of power “based on” the three listed information items (the request, the measured power, the measured losses). The claim only broadly recites “based on” without clearly establishes how these information items are related to the controlling method step. Martchovsky’s wireless power control is “based on” P-request because it is the receiver’s initial request (RP) that starts the whole process and the purpose is to send (if power is available) this power level. Martchovksy’s wireless power control is “based on” the measured power and PTx-loss because they set the upper limits of available power. Thus, what the transmitter does send is “based on” its determined limits.
The Examiner notes that the claim repeated refers to method steps being “based on” information items. The claim does not explicitly set forth how these information items are used in calculations or determinations to inform the public of the scope of the claim. “based on” implies some sort of relationship – but as none are defined (or argued for by the Applicants), it is up to the Office to make the only interpretation. All functionality within Martchovsky are “based on” the signals because they are all part of the same flowchart. Further, a parameter can be added and immediately subtracted (A + B – B + C = D) so that it won’t actually affect the solution, with the solution (D) still being “based on” the parameter (B).
Martchovsky discloses the repeated iteration of power transfer and a renegotiation, but does not expressly disclose that the renegotiation is a separate phase. Park (fig 11; col. 24-25) discloses that the known to separate transmitter-receiver interactions into phases that include separate negotiation (1130) and power (1140). The arrows between these phases indicate that the skilled artisan would have known that a transmitter can repeatedly transition back and forth between power and negotiation; as is found in Martchovsky.
Park figures 12-16 show how the transmitter determines its available power and guaranteed power and then makes a determination if the receiver’s request can be satisfied. This is similar to the underlying functionality of Martchovsky (Park does not disclose taking transmitter losses into account).
Martchovsky and Park are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with power transfer and renegotiation phases. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to label the Martchovksy renegotiation as a separate phase that is distinct from and “prior to” a subsequent power transfer phase, as taught by Park (fig 11). The motivation for doing so would have been to use a known wireless power standard for communication and power transfer between transmitter and receiver, with a reasonable expectation of success.
With respect to claim 2, Martchovsky discloses wherein negotiating the Guaranteed Power includes:
accepting the Requested Power negotiation value as the Guaranteed Power if the Available Power is more than a sum of the Requested Power negotiation value and the estimated PTx-loss (Y in 306 – sending acknowledgement in 308); and
rejecting the Requested Power negotiation value (No in 306 – decline the request in 312) or communicating an alternative power negotiation value to the Power Receiver if the Available Power is less than the sum of the Requested Power negotiation value and the estimated PTx-loss.
With respect to claim 3, Martchovsky discloses wherein negotiating the Guaranteed Power includes:
determining that the Available Power is less than a sum of the Requested Power negotiation value and the estimated PTx-loss (No in 306);
communicating a message to the Power Receiver to reject the Requested Power negotiation value (step 312);
receiving a subsequent Requested Power negotiation value from the Power Receiver (after 312, the process starts over – the receiver hasn’t gotten power and would request again, not abandon the effort); and
accepting the subsequent Requested Power negotiation value as the Guaranteed Power if the Available Power is more than a sum of the subsequent Requested Power negotiation value and the estimated PTx-loss (YES in 306 on any subsequent negotiation iteration).
With respect to claim 4, Martchovsky discloses wherein negotiating the Guaranteed Power includes:
determining that the Available Power is less than a sum of the Requested Power negotiation value and the estimated PTx-loss (NO in 306);
calculating an alternative power negotiation value that the Power Transmitter can satisfy, the alternative power negotiation value based on the Available Power minus the estimated PTx- loss (N in 310);
communicating a message to the Power Receiver to indicate the alternative power negotiation value (step 314);
receiving an acknowledgement from the Power Receiver if the Power Receiver accepts the alternative power negotiation value as the Guaranteed Power (par 28, “Rx 104 may resend the negotiation request for the same RP (at step 204) because the RP is lower than MAP”); and
setting the alternative power negotiation value as the Guaranteed Power for the Power Receiver after receiving the acknowledgment (the second iteration of the flowchart would accept “the same RP” because it is actually the transmitter’s offer).
With respect to claims 5-6, Martchovsky is interpreted as being enabling for having its receiver’s negotiation request be “indicative of” load power rating and estimated losses. The receiver isn’t claimed – so what the substance of the message infers does not further limit the transmitter’s method. Further, the claim only broadly recites that the initial request is “indicative of” – this does not actually define any individual information items that are included in the message or how the transmitter uses those specific features.
For claim 5, Martchovsky discloses the negotiating the Guaranteed Power includes the Power Transmitter selecting the Guaranteed Power to satisfy the power rating of the load (fig 3). Martchovsky includes at least one flow-chart path that complies with the receiver’s request for power. Thus, the transmitter Guaranteed Power “satisfies” the receiver’s load “rating” (i.e. it doesn’t give too much to damage the receiver/load).
For claim 6, Martchovsky discloses the negotiating the Guaranteed Power includes the Power Transmitter selecting the Guaranteed Power to satisfy the combination of the power rating and the estimated PRx-loss (fig 3). Same as for claim 5, since the receiver successfully operates, the Guaranteed power “satisfies” the receiver’s rating (see above) and estimated losses (which are not part of the scope of the claimed transmitter method).
“satisfy” is broad and is obvious in view of the prior art’s ability to transmit wireless power to the receiver to successfully operate its load and not damage it.
With respect to claim 7, Martchovsky discloses wherein the estimated PTx-loss includes power transmission losses associated with at least one member of a group consisting of:
a copper loss (par 25, last sentence) associated with a primary coil of the Power Transmitter, the copper loss calculated using a product of a resistance (R) associated with the primary coil and a square of an estimated rated current (Iinv2) associated with an inverter of the Power Transmitter to meet the Requested Power negotiation value; and
other losses associated with any combination of a rectifier, an inverter, a coil, a filter component, a capacitor, or friendly metals of the Power Transmitter associated with the Power Transmitter to meet the Requested Power negotiation value (par 29).
The Examiner notes that there are no method steps in claim 7. The claim is descriptive of what the PTx-losses includes. The first limitation recites “the copper loss calculated using …”. The claim does not recite “calculating” as a method step and then using the output of this equation as the specific value of PTx-loss (or other value).
The second limitation is just a list of components that are not distinctly claimed. The Applicants can add structure to a method claim, but the structure must have meaning (how are the pieces connected, how are their losses sensed/known, etc.).
With respect to claim 8, Martchovsky discloses obtaining the estimated PTx-loss from a memory of the Power Transmitter (par 18, 25). Martchovsky discloses that it knows the values of its transmitter (power, losses, etc.). This is obvious evidence of memory to store this information long enough to use it. Without memory, these values would be instantly forgotten.
With respect to claim 9, Martchovksy discloses adjusting the estimated PTx-loss based, at least in part, on a coupling factor (K- factor) indicating an efficiency of a wireless coupling between the Power Transmitter and the Power Receiver (par 25). The efficiency losses disclosed by Martchovsky is obviously “based, at least in part on,” the coupling factor. The claim does not recite any knowledge of the K-factor (there are no sensors or K-factor calculations) – just that an estimation is based on it. The K-factor is a unitless measure of efficiency between transmitter/receiver. Thus, losses within the transmitter are “based, at least in part, on” it.
With respect to claim 11, Martchovsky discloses the P-request message indicates a requested power that is less than or equal to the Guaranteed Power (YES in 306).
With respect to claim 13, Martchovsky discloses determining the Available Power as an amount of power available from the Magnetic Power Source (112) remaining after multiple Power Transmitters have reserved respective Negotiated Power amounts (not claimed).
That the claim 1 transmitter is part of a larger system does not change its underlying functionality. Claim 13 suggests the presence of other “multiple Power Transmitters”, but none are distinctly claimed. What these other (unclaimed) transmitters are doing and how they are using power does not affect the method of claim 1. Namely, there are no method steps in claim 13 to define how the claimed transmitter method actually interacts with the magnetic power source or other transmitters. The Martchovsky transmitter knows how much power it has to share with the receiver and this includes the hypothetical that other transmitters already took some from the source (112).
With respect to claims 21-28, Martchovsky and Park combine to disclose a power transmitter (all figures, all text) of a wireless power system, comprising:
a primary coil (106) configured to transmit wireless power to a secondary coil (not claimed) of a power receiver during a power transfer phase (the coil is “configured” to do this at all times – it is just a piece of metal);
a communication unit (113) configured to receive a requested power negotiation value (step 302) from the power receiver prior to the power transfer phase; and
a power controller (107) configured to carry out the recited functionality, and the references are analogous, as discussed above in the art rejection of claims 1-6 and 8-9, respectively.
Regarding claim 21, the Examiner notes that the power controller functionality is much broader than that of method claim 1.
Regarding claim 28, this claim is slightly different than its method counterpart, in that it actually determines K-factor (instead of just estimating “based on” it – see claim 9). But as Martchovsky explicitly discloses controlling efficiency, it is inherent that this specific level of control would include “determining” K-factor (a unitless measure of efficiency).
With respect to claims 32-33, Martchovsky and Park combine to disclose the recited method steps, and the references are analogous, as discussed above in the art rejection of claims 1-2. Claim 32 recites fewer steps than claim 1 and is obvious over the prior art for the same reasons.
Conclusion
There is no art rejection of claim 12. The claim would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims and when the §112(b) rejection of claim 1 is addressed/corrected.
The prior art does not teach or suggest the four method steps of claim 12, as previously indicated.
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/ADI AMRANY/Primary Examiner, Art Unit 2836