Prosecution Insights
Last updated: April 19, 2026
Application No. 18/744,836

DISPLAY DEVICE

Non-Final OA §102§103
Filed
Jun 17, 2024
Examiner
LIU, SHAN
Art Unit
2871
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Magnolia White Corporation
OA Round
3 (Non-Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
2y 2m
To Grant
99%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
436 granted / 606 resolved
+3.9% vs TC avg
Strong +40% interview lift
Without
With
+40.4%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 2m
Avg Prosecution
30 currently pending
Career history
636
Total Applications
across all art units

Statute-Specific Performance

§103
59.5%
+19.5% vs TC avg
§102
22.1%
-17.9% vs TC avg
§112
15.1%
-24.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 606 resolved cases

Office Action

§102 §103
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 01/13/2026 has been entered. Response to Amendment and Arguments The amendment filed 01/13/2026 has been entered. Claims 1-2 and 5-6 are currently pending in this application. Applicant’s arguments, see Pages 5-6, filed 01/13/2026, with respect to the rejection(s) of claim(s) 1-2 and 5-6 under 35 U.S.C. 102 and/or 35 U.S.C. 103 have been fully considered but they are not persuasive. Applicant states "…Applicant respectfully submits that Matsushima and Chen are silent regarding "when a side glass of a front passenger seat side is placed at a side of the display panel, a polarization axis of the second polarization layer is set in an angle range of +750 to +195"' as presently recited in independent Claim 1. Accordingly, Applicant respectfully submits that independent Claim 1 is patentably distinguished from the cited prior art and is currently in condition for allowance…". Examiner respectfully disagrees. The language of the claims is treated as the “metes and bounds” of the subject matter for which protection is being sought. As stated in the rejections of claims 1 and 5-6, with broadest reasonable interpretation, Matsushima teaches that in the light adjuster (the light adjuster corresponding to the elements of POL5, 2, POL4, 1, POL3, 100 and POL2 in Fig. 2 and Fig. 16), a first liquid crystal panel (2 in Fig. 2), a first polarization layer (POL4 in Fig. 2), a second liquid crystal panel (1 in Fig. 2), and a second polarization layer (POL2 in Fig. 2) are stacked from the light source side toward the display panel side (Fig. 16, Fig. 2), in the E-mode liquid crystal panel (Fig. 4), a rubbing direction (AD3 or AD4 in Fig. 4) of an alignment film (AL3 or AL4, respectively, in Fig. 4) stacked directly on a substrate (Fig. 2 and Fig. 4) and an orientation axis (T3 or T4, respectively, in Fig. 4) of a polarization layer (POL3 or POL4, respectively in Fig. 4) contacting (Fig. 2 and Fig. 16) the substrate are parallel to each other (Fig. 4); and in a case that a side glass (the inherent right side window glass at the right side of 222 in Fig. 12, Page 12, Paragraph 7) of a front passenger seat side (the side of 222 in Fig. 12) is placed at a side of the display panel (the display panel corresponding to DSP in Fig. 12, Page 12, Paragraph 7), a polarization axis of the second polarization layer (POL2 in Fig. 2) is set in an angle range of +75° to +195° (Fig. 3, Page 6, Paragraph 5 and 7, the transition axis T2 is located at an orientation of 180° since Fig. 3 shows the transition axis T2 is located at an orientation of 180° or 0°). As stated in the rejections of claims 1 and 2, with broadest reasonable interpretation, Chen teaches that in the light adjuster (SS in Fig. 1 and 2), a first liquid crystal panel (LC2 in Fig. 2), a first polarization layer (P2 in Fig. 2), a second liquid crystal panel (LC1 in Fig. 2), and a second polarization layer (P1 in Fig. 2) are stacked from the light source side toward the display panel side (Fig. 2), and in a case that the display panel (30 in Fig. 1, which is corresponding to the vehicle privacy panel, [0044, 0034]) is used in a vehicle ([0044]), and a polarization axis of the second polarization layer (the transmission axis of P1, which is perpendicular to the absorption axis AX1 of P1 in Fig. 2, [0026, 0040, 0030]) is set in an angle range of +75° to +195° (Fig. 2, since AX1 is 90 or 270 degree and the transmission axis of P1 is 0 or 180 degree, Chen teaches that the polarization axis of P1 is 180 degree, [0026, 0040, 0030]). Chen does not explicitly point out that the alignment direction of an alignment film is a rubbing direction of the alignment film, and in a case that a side glass of a front passenger seat side is placed at a side of the display panel, a polarization axis of the second polarization layer is set in an angle range of +75° to +195°. Matsushima teaches that an alignment direction (AD3 or AD4 in Fig. 4) of an alignment film (AL3 or AL4, respectively, in Fig. 4) is a rubbing direction of the alignment film (Page 7, Paragraph 5), and in a case that a side glass (the inherent right side window glass at the right side of 222 in Fig. 12, Page 12, Paragraph 7) of a front passenger seat side (the side of 222 in Fig. 12) is placed at a side of the display panel (the display panel corresponding to DSP in Fig. 12, Page 12, Paragraph 7), a polarization axis of the second polarization layer (POL2 in Fig. 2) is set in an angle range of +75° to +195° (Fig. 3, Page 6, Paragraph 5 and 7, the transition axis T2 is located at an orientation of 180° since Fig. 3 shows the transition axis T2 is located at an orientation of 180° or 0°). Before the effective filling date of the claimed invention, it would have been obvious to the artisan of ordinary skill to employ the above elements as taught by Matsushima for the system of Chen such that in the system of Chen, the alignment direction of an alignment film is a rubbing direction of the alignment film; and in a case that a side glass of a front passenger seat side is placed at a side of the display panel, the polarization axis of the second polarization layer of the system of Chen is set in an angle range of +75° to +195°. The motivation is to use a rubbing treatment as the orientation treatment for the alignment film and provide a desired relatively large pretilt angle, and provide display devices mounted on vehicles (Matsushima, Page 7, Paragraph 5, Page 2, Paragraph 7). Claim Objections Claim 1 is objected to because of the following informalities: In claim 1, line 22, "when " should read - - in a case that - - Appropriate correction is required. 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 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. Claim Rejections - 35 USC § 102 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 and 5-6 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Matsushima (WO2021192567A1). Regarding claim 1, Matsushima teaches a display device (Fig. 1-17, Pages 1-17 of English translation of WO2021192567A1) comprising: a display panel (PNL in Fig. 2, Fig. 16, Fig. 12-13) having a display region configured to output an image (Fig. 2 and Fig. 16, Page 3, Paragraph 7); a light source (IL in Fig. 2 and Fig. 16) configured to emit light toward one surface side of the display panel (Fig. 2 and Fig. 16); and a light adjuster (the light adjuster corresponding to the elements of POL5, 2, POL4, 1, POL3, 100 and POL2 in Fig. 2 and Fig. 16) interposed between the display panel (PNL in Fig. 2 and Fig. 16) and the light source (IL in Fig. 2 and Fig. 16) and provided to be able to change a transmission degree of light between the display panel and the light source (Fig. 2 and Fig. 16), wherein in the light adjuster (the light adjuster corresponding to the elements of POL5, 2, POL4, 1, POL3, 100 and POL2 in Fig. 2 and Fig. 16), a first liquid crystal panel (2 in Fig. 2), a first polarization layer (POL4 in Fig. 2), a second liquid crystal panel (1 in Fig. 2), and a second polarization layer (POL2 in Fig. 2) are stacked from the light source side toward the display panel side (Fig. 16, Fig. 2), one (1 in Fig. 2 and Fig. 4) of the first and second liquid crystal panels (1 and 2 in Fig. 2) is provided as an E-mode liquid crystal panel (Fig. 4), and the other (2 in Fig. 2 and Fig. 5) of the first and second liquid crystal panels (1 and 2 in Fig. 2) is provided as an O-mode liquid crystal panel (Fig. 5), in the E-mode liquid crystal panel (Fig. 4), a rubbing direction (AD3 or AD4 in Fig. 4) of an alignment film (AL3 or AL4, respectively, in Fig. 4) stacked directly on a substrate (Fig. 2 and Fig. 4) and an orientation axis (T3 or T4, respectively, in Fig. 4) of a polarization layer (POL3 or POL4, respectively in Fig. 4) contacting (Fig. 2 and Fig. 16) the substrate are parallel to each other (Fig. 4), and in the O-mode liquid crystal panel (Fig. 5), a rubbing direction (AD5 or AD6 in Fig. 5) of an alignment film (AL5 or AL6, respectively, in Fig. 5) stacked directly on a substrate and an orientation axis (T4 or T5, respectively, in Fig. 5) of a polarization layer (POL4 or POL5, respectively, in Fig. 5) contacting (Fig. 2 and Fig. 16) the substrate are orthogonal to each other (Fig. 5), a twist angle (Fig. 4, Picture 1) of the E-mode liquid crystal panel (Fig. 4, Picture 1) is 90°, or smaller than 90° and close to 90° (Fig. 4, Picture 1, [0064], since the alignment treatment direction AD4 of the alignment film AL4 is substantially orthogonal to the alignment treatment direction AD3 of the alignment film AL3, the angle between the lowest liquid crystal molecules A0 of the liquid crystal molecules LM1 and the highest liquid crystal molecules B0 of the liquid crystal molecules LM1 in picture 1 is substantially 90°), and a twist angle (Fig. 5, Picture 1) of the O-mode liquid crystal panel (Fig. 5, Picture 1) is 80° (Fig. 5, Picture 1, [0071], since the alignment treatment direction AD6 of the alignment film AL6 is substantially orthogonal to the alignment treatment direction AD5 of the alignment film AL5, the angle between the lowest liquid crystal molecules B0 of the liquid crystal molecules LM2 and the highest liquid crystal molecules B4 of the liquid crystal molecules LM2 in picture 1 is substantially 90°, therefore, there are inherent liquid crystal molecules are located between B0 and B4 and have a twist angle at 80°), and in a case that a side glass (the inherent right side window glass at the right side of 222 in Fig. 12, Page 12, Paragraph 7) of a front passenger seat side (the side of 222 in Fig. 12) is placed at a side of the display panel (the display panel corresponding to DSP in Fig. 12, Page 12, Paragraph 7), a polarization axis of the second polarization layer (POL2 in Fig. 2) is set in an angle range of +75° to +195° (Fig. 3, Page 6, Paragraph 5 and 7, the transition axis T2 is located at an orientation of 180° since Fig. 3 shows the transition axis T2 is located at an orientation of 180° or 0°). PNG media_image1.png 652 482 media_image1.png Greyscale Picture 1, from Fig. 4-5 of Matsushima (WO2021192567A1) Regarding claims 5-6, Matsushima also teaches the following elements: (Claim 5) a polarization generation layer (POL6 or POL 7 in Fig. 16, Page 14, Last Paragraph) provided between the light source (IL in Fig. 16) and the light adjuster (the light adjuster corresponding to the elements of POL3, 1, POL4, 2 and POL5 in Fig. 2 and Fig. 16) and configured to polarize light emitted from the light source in a specific direction (the direction corresponding to T4 or T5 in Fig. 3, Fig. 16, Page 14, Last Paragraph), wherein the specific direction (the direction corresponding to T4 or T5 in Fig. 3, Fig. 16, Page 14, Last Paragraph) is a direction intersecting all four sides of the display region having a rectangular shape (Fig. 3, Fig. 6A-6B, Fig. 16, Page 14, Last Paragraph). (Claim 6) in case that (Fig. 2-3, Fig. 6A-6B and Fig. 7-9, Page 10-11) the first and second liquid crystal panels are in operation (Fig. 6A-6B and Fig. 7-9, Page 10-11), the light adjuster (the light adjuster corresponding to the elements of POL3, 1, POL4, 2 and POL5 in Fig. 2 and Fig. 16) causes a first transmission degree and a second transmission degree to be different from each other (Fig. 7-9, Page 10-11), the first transmission degree is a transmission degree of light tilted toward one side in a longitudinal direction of the display panel having a rectangular shape with respect to a facing direction (Fig. 2-3, Fig. 6A-6B and Fig. 7-9, Page 10-11), the second transmission degree is a transmission degree of light tilted toward the other side in the longitudinal direction (Fig. 2-3, Fig. 6A-6B and Fig. 7-9, Page 10-11), and the facing direction is a direction in which the display panel and the light source face each other (Fig. 2-3, Fig. 6A-6B and Fig. 7-9, Page 10-11). 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 of this title, 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 and 2 rejected under 35 U.S.C. 103 as being unpatentable over Chen (US 2023/0127094) in view of Matsushima (WO2021192567A1). Regarding claim 1, Chen teaches a display device (Fig. 1-9, [0027-0076]) comprising: a display panel (30 in Fig. 1, [0034]) having a display region configured to output an image (Fig. 1, [0034]); a light source (40 in Fig. 1, [0034]) configured to emit light toward one surface side of the display panel (Fig. 1, [0034]); and a light adjuster (SS in Fig. 1 and 2) interposed between the display panel (30 in Fig. 1, [0034]) and the light source (40 in Fig. 1, [0034]) and provided to be able to change a transmission degree of light between the display panel and the light source (Fig. 1-2), wherein in the light adjuster (SS in Fig. 1 and 2), a first liquid crystal panel (LC2 in Fig. 2), a first polarization layer (P2 in Fig. 2), a second liquid crystal panel (LC1 in Fig. 2), and a second polarization layer (P1 in Fig. 2) are stacked from the light source side toward the display panel side (Fig. 2), and one (LC1 in Fig. 2) of the first and second liquid crystal panels (LC1 and LC2 in Fig. 2) is provided as an E-mode liquid crystal panel (the panel corresponding to 10 in Fig. 2), and the other (LC2 in Fig. 2) of the first and second liquid crystal panels (LC1 and LC2 in Fig. 2) is provided as an O-mode liquid crystal panel (the panel corresponding to 20 in Fig. 2), in the E-mode liquid crystal panel (the panel corresponding to 10 in Fig. 2), an alignment direction (AL1 or AL2 in Fig. 2) of an alignment film (Fig. 2, [0028, 0036-0037, 0047-0049]) stacked directly on a substrate (Fig. 2, [0028, 0036-0037, 0047-0049]) and an orientation axis (Ax1 or AX2, respectively, in Fig. 4) of a polarization layer (P1 or P2, respectively in Fig. 4) contacting the substrate are parallel to each other (Fig. 2), in the O-mode liquid crystal panel (the panel corresponding to 20 in Fig. 2), an alignment direction (AL3 or AL4 in Fig. 2) of an alignment film (Fig. 2, [0028, 0036-0037, 0047-0049]) stacked directly on a substrate and an orientation axis (AX2 or AX3, respectively, in Fig. 2) of a polarization layer (P2 or P3, respectively, in Fig. 2) contacting the substrate are orthogonal to each other (Fig. 2); a twist angle (Fig. 2) of the E-mode liquid crystal panel (the panel corresponding to 10 in Fig. 2) is 90°, or smaller than 90° and close to 90° (Fig. 2, [0036], since the first alignment axis AL1 of the first alignment layer may be perpendicular to the second alignment axis AL2 of the second alignment layer, the angle between the lowest liquid crystal molecules of the liquid crystal molecules 107 and the highest liquid crystal molecules of the liquid crystal molecules 107 in picture 1 is substantially 90°), and a twist angle (Fig. 2) of the O-mode liquid crystal panel (the panel corresponding to 20 in Fig. 2) is 80° (Fig. 2, [0037], since the third alignment axis AL3 of the third alignment layer may be perpendicular to the fourth alignment axis AL4 of the fourth alignment layer, the angle between the lowest liquid crystal molecules of the liquid crystal molecules 207 and the highest liquid crystal molecules of the liquid crystal molecules 207 in picture 1 is substantially 90°, therefore, there are inherent liquid crystal molecules which are located between the lowest liquid crystal molecules and the highest liquid crystal molecules and have a twist angle at 80°). Chen also teaches in a case that the display panel (30 in Fig. 1, which is corresponding to the vehicle privacy panel, [0044, 0034]) is used in a vehicle ([0044]), and a polarization axis of the second polarization layer (the transmission axis of P1, which is perpendicular to the absorption axis AX1 of P1 in Fig. 2, [0026, 0040, 0030]) is set in an angle range of +75° to +195° (Fig. 2, since AX1 is 90 or 270 degree and the transmission axis of P1 is 0 or 180 degree, Chen teaches that the polarization axis of P1 is 180 degree, [0026, 0040, 0030]). Chen does not explicitly point out that the alignment direction of an alignment film is a rubbing direction of the alignment film, and in a case that a side glass of a front passenger seat side is placed at a side of the display panel, a polarization axis of the second polarization layer is set in an angle range of +75° to +195°. Matsushima teaches that an alignment direction (AD3 or AD4 in Fig. 4) of an alignment film (AL3 or AL4, respectively, in Fig. 4) is a rubbing direction of the alignment film (Page 7, Paragraph 5), and in a case that a side glass (the inherent right side window glass at the right side of 222 in Fig. 12, Page 12, Paragraph 7) of a front passenger seat side (the side of 222 in Fig. 12) is placed at a side of the display panel (the display panel corresponding to DSP in Fig. 12, Page 12, Paragraph 7), a polarization axis of the second polarization layer (POL2 in Fig. 2) is set in an angle range of +75° to +195° (Fig. 3, Page 6, Paragraph 5 and 7, the transition axis T2 is located at an orientation of 180° since Fig. 3 shows the transition axis T2 is located at an orientation of 180° or 0°). Before the effective filling date of the claimed invention, it would have been obvious to the artisan of ordinary skill to employ the above elements as taught by Matsushima for the system of Chen such that in the system of Chen, the alignment direction of an alignment film is a rubbing direction of the alignment film; and in a case that a side glass of a front passenger seat side is placed at a side of the display panel, the polarization axis of the second polarization layer of the system of Chen is set in an angle range of +75° to +195°. The motivation is to use a rubbing treatment as the orientation treatment for the alignment film and provide a desired relatively large pretilt angle, and provide display devices mounted on vehicles (Matsushima, Page 7, Paragraph 5, Page 2, Paragraph 7). Regarding claim 2, Chen also teaches the following elements: (Claim 2) each of the first and second liquid crystal panels (LC1 and LC2 in Fig. 2) includes two alignment films (Fig. 2, [0028, 0036-0037, 0047-0049]) facing each other with liquid crystal interposed between the two alignment films (Fig. 2, [0028, 0036-0037, 0047-0049]), wherein one alignment film of the two alignment films is disposed on the light source side of the liquid crystal (Fig. 2, [0028, 0036-0037, 0047-0049]), and the other alignment film of the two alignment films is disposed on the display panel side of the liquid crystal (Fig. 2, [0028, 0036-0037, 0047-0049]), wherein the one alignment film (the alignment film corresponding to AL3 in Fig. 2) of the first liquid crystal panel (LC2 in Fig. 2) and the one alignment film (the alignment film corresponding to AL1 in Fig. 2) of the second liquid crystal panel (LC1 in Fig. 2) have a common first alignment direction (Fig. 2), and wherein the other alignment film (the alignment film corresponding to AL4 in Fig. 2) of the first liquid crystal panel (LC2 in Fig. 2) and the other alignment film (the alignment film corresponding to AL2 in Fig. 2) of the second liquid crystal panel (LC1 in Fig. 2) have a common second alignment direction (Fig. 2). As stated in the rejection of claim 1 above, Chen in view of Matsushima already teaches that the alignment direction of an alignment film is a rubbing direction of the alignment film, therefore, Chen in view of Matsushima teaches that the one alignment film of the first liquid crystal panel and the one alignment film of the second liquid crystal panel have a common first rubbing direction, and wherein the other alignment film of the first liquid crystal panel and the other alignment film of the second liquid crystal panel have a common second rubbing direction. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SHAN LIU whose telephone number is (571)270-0383. The examiner can normally be reached on 9am-5pm EST M-F. 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, Jennifer Carruth can be reached on 571-272-9791. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Shan Liu/ Primary Examiner, Art Unit 2871
Read full office action

Prosecution Timeline

Jun 17, 2024
Application Filed
Jul 12, 2025
Non-Final Rejection — §102, §103
Oct 06, 2025
Response Filed
Oct 14, 2025
Final Rejection — §102, §103
Jan 13, 2026
Request for Continued Examination
Jan 24, 2026
Response after Non-Final Action
Feb 13, 2026
Non-Final Rejection — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12596033
LIGHT SENSOR
2y 5m to grant Granted Apr 07, 2026
Patent 12591114
OPTICAL LENS ASSEMBLY AND ELECTRONIC DEVICE
2y 5m to grant Granted Mar 31, 2026
Patent 12578588
LENS DRIVING APPARATUS AND CAMERA MODULE INCLUDING THE SAME
2y 5m to grant Granted Mar 17, 2026
Patent 12560837
DISPLAY APPARATUS AND VIRTUAL REALITY DEVICE
2y 5m to grant Granted Feb 24, 2026
Patent 12560822
LIQUID CRYSTAL PANEL AND DISPLAY DEVICE
2y 5m to grant Granted Feb 24, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
72%
Grant Probability
99%
With Interview (+40.4%)
2y 2m
Median Time to Grant
High
PTA Risk
Based on 606 resolved cases by this examiner. Grant probability derived from career allow 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