Prosecution Insights
Last updated: April 19, 2026
Application No. 18/699,649

AIR-CONDITIONING APPARATUS

Non-Final OA §102§103§112
Filed
Apr 09, 2024
Examiner
CRENSHAW, HENRY T
Art Unit
3763
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Mitsubishi Electric Corporation
OA Round
1 (Non-Final)
76%
Grant Probability
Favorable
1-2
OA Rounds
2y 11m
To Grant
91%
With Interview

Examiner Intelligence

Grants 76% — above average
76%
Career Allow Rate
753 granted / 992 resolved
+5.9% vs TC avg
Moderate +15% lift
Without
With
+14.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
17 currently pending
Career history
1009
Total Applications
across all art units

Statute-Specific Performance

§101
1.1%
-38.9% vs TC avg
§103
45.4%
+5.4% vs TC avg
§102
12.3%
-27.7% vs TC avg
§112
37.6%
-2.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 992 resolved cases

Office Action

§102 §103 §112
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 . This action is in response to the filing made 4/9/2024. Claims 1-8 are pending. Priority The priority date is 12/20/2021, based upon the parent PCT application. There are no claims to foreign priority made in the application. Specification The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed. The following title is suggested: Air-Conditioning Apparatus With Refrigerant Leak Management. Claim Interpretation The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP §2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation is: A relay unit . . . . configured to switch a flow passage to be used in the refrigerant circuit between plural flow passages, which is interpreted to mean the structure of item 17. Because this claim limitation is being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it is being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation recites sufficient structure to perform the claimed function so as to avoid it being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claim 2 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. Claim 2 – there is a lack of antecedent basis for “the external equipment pressure sensor”. 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. Claim(s) 1-6 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by US 9,335,078 to Buggs. Regarding claim 1, Buggs teaches, An air-conditioning apparatus comprising: an outdoor unit including a compressor and an outdoor heat exchanger, and configured to generate cooling energy or heating energy (condenser unit with compressor, col. 2, lines 3-16); an indoor unit (col. 2, lines 3-16) including an indoor heat exchanger, and configured to perform an air-conditioning operation with the cooling energy or the heating energy that is generated by the outdoor unit; a refrigerant pipe (52, 54, col. 4, lines 45-55, Fig. 4) provided between the outdoor unit and the indoor unit, and forming a refrigerant circuit in which refrigerant circulates; a shut-off valve (1A, 1B, col. 4, 60-67, also col. 6, lines 30-40)) provided at the refrigerant pipe, and configured to be closed when a refrigerant leak is detected; and a pressure sensor (pressure gauge, Col. 6, lines 10-40), wherein the shut-off valve includes a service port (9, 11 Fig. 3) communicating with the refrigerant pipe, and the pressure sensor is connected to the service port. (col. 6, 10-20). Regarding claim 2, Buggs teaches the air-conditioning apparatus of claim 1, wherein the service port has a tip (sealing element 12, Fig. 3) that is openable and closable and that allows the pressure sensor to be attached to and detached from the tip, and the tip is opened when the external equipment pressure sensor is connected to the tip. (col. 6, lines 5-20, this is how Schrader valves are typically designed to operate) Regarding claim 3, Buggs teaches the air-conditioning apparatus of claim 1, wherein the shut-off valve includes a block body (2) including a flow passage (31, 21) that is formed therein to communicate with the refrigerant pipe, and a valve body (32) to cause the flow passage to be opened or closed, and the service port (9) is provided at the block body in such a manner as to communicate with the flow passage. Regarding claim 4, Buggs teaches the air-conditioning apparatus of claim 1, wherein the shut-off valve includes a block body (4) including a flow passage (31, Fig. 3)that is formed in the block body to communicate with the refrigerant pipe (col. 5, lines 5-15), a valve body (32) configured to cause the flow passage to be opened or closed, (a shut off valve must have a feature to open and close flow passages) a connection pipe (24, Fig. 3) connected to the flow passage and protruding from the block body, the connection pipe is connected to the refrigerant pipe (Fig. 2, 3) see items (12, 52, 54), and the service port (9, 11, Fig. 3) is provided at the connection pipe (24, 10). Regarding claim 5, Buggs teaches the air-conditioning apparatus of claim 1, wherein a plurality of the shut-off valves are provided at the refrigerant pipe, and the plurality of shut-off valves include an indoor-unit-side shut-off valve located closer to the indoor unit than to the outdoor unit, and an outdoor-unit-side shut-off valve located closer to the outdoor unit than to the indoor unit. Compare the condenser (50) with valves 1A and 1B in Fig. 4, with the evaporator (56) with valves 1c and 1d in Fig. 5. Regarding claim 6, Buggs teaches the air-conditioning apparatus of claim 5, wherein a plurality of the indoor-unit-side shut-off valves are provided, the plurality of indoor-unit-side shut-off valves include an indoor-unit-side shut-off valve provided at part of the refrigerant pipe through which the refrigerant passes to flow into the indoor unit, and an indoor-unit-side shut-off valve provided at part of the refrigerant pipe through which the refrigerant flows after flowing out from the indoor unit, a plurality of the outdoor-unit-side shut-off valves are provided, and the plurality of outdoor-unit-side shut-off valves include an outdoor-unit-side shut-off valve provided at part of the refrigerant pipe through which the refrigerant passes to flow into the outdoor unit, and an outdoor-unit-side shut-off valve provided at part of the refrigerant pipe through which the refrigerant flows after flowing out from the outdoor unit. All of these features are shown in Figs. 4 and 5, showing the outside condenser 50 with inlet and outlet shut off valves 1A and 1B, and indoor evaporator 56 with shut off valves 1D and 1C. 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. Claim(s) 7, 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over US 9,335,078 to Buggs in view of US 2015/0034293 to Takayama. Regarding claim 7, Buggs as modified teaches the air-conditioning apparatus of claim 5, and Takeyama teaches, a plurality of the indoor units (2a-2d) are provided, a relay unit is provided between the outdoor unit and the plurality of indoor units, and is configured to switch a flow passage to be used in the refrigerant circuit between plural flow passages, (Taklayama Fig. 1, by the same applicant as the current application, shows a similar arrangement as that currently taught in the instant application, with numerous valves 56a & 57a to 56d and 57d, 59a-59c, and various interconnecting pipes 63 and 64, in a manner similar to applicant’s claimed relay unit) the outdoor unit, the relay unit, and the plurality of indoor units are connected by the refrigerant pipe, (Takayama is a refrigerant based system) each of a plurality of the indoor-unit-side shut-off valves is provided for an associated one of the plurality of indoor units, (providing additional indoor units is an obvious duplication of parts, and if such duplication is made in the instant application, it would also be obvious to also duplicate the shut off valves associated with each indoor unit) the indoor-unit-side shut-off valve is located closer to the associated indoor unit than to the relay unit. (In Buggs the shut off valves are immediately adjacent the evaporator 56, and if such arrangement is plugged into the system of Takeyama shown in Fig. 21, then they would be closer to the indoor unit than the relay unit.) It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the invention, to modify Buggs, in view of Takeyama, in order to make the system capable of providing indoor heating and cooling to more than one indoor space. Regarding the exact location of the shut-off valves, this feature can be determined as necessary by the installers as needed for a given end use installation. For example, there could be space constraints that would require this arrangement for ease of access in the event the valve needs to be replaced or repaired. In addition, the placement of the valves can be chosen to ensure that when a leak does occur, it is prevented from occurring in an undesirable area, such human occupied spaces. Given the essentially endless variations an end use configuration might take, it is obvious that in at least some of them this valve arrangement would be obvious to an ordinary skilled person at the time of filing the application. Claim 8 is obvious for the same reason as parent claim 7. 8. The air-conditioning apparatus of claim 7, wherein the plurality of shut-off valves include a relay-unit-side shut-off valve provided between the outdoor unit and the relay unit, the relay-unit-side shut-off valve is located closer to the relay unit than to the outdoor unit, and the outdoor-unit-side shut-off valve is located closer to the outdoor unit than to the relay unit. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to HENRY T CRENSHAW whose telephone number is (571)270-1550. The examiner can normally be reached M-F 9:00 am to 5:00 pm. 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, JD Fletcher can be reached on 571-270-5054. 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. /HENRY T CRENSHAW/Primary Examiner, Art Unit 3763
Read full office action

Prosecution Timeline

Apr 09, 2024
Application Filed
Oct 21, 2025
Non-Final Rejection — §102, §103, §112 (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
76%
Grant Probability
91%
With Interview (+14.9%)
2y 11m
Median Time to Grant
Low
PTA Risk
Based on 992 resolved cases by this examiner. Grant probability derived from career allow rate.

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