Prosecution Insights
Last updated: July 17, 2026
Application No. 18/766,330

WATCH HOUSING WITH SLOT ANTENNA CONFIGURATION IN LOWER PLANE

Non-Final OA §102§103§112
Filed
Jul 08, 2024
Priority
Nov 10, 2023 — provisional 63/597,967
Examiner
DEWITT, JORDAN EDWARD
Art Unit
Tech Center
Assignee
Garmin International Inc.
OA Round
1 (Non-Final)
84%
Grant Probability
Favorable
1-2
OA Rounds
1m
Est. Remaining
98%
With Interview

Examiner Intelligence

Grants 84% — above average
84%
Career Allowance Rate
110 granted / 131 resolved
+24.0% vs TC avg
Moderate +14% lift
Without
With
+13.5%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 2m
Avg Prosecution
17 currently pending
Career history
148
Total Applications
across all art units

Statute-Specific Performance

§103
82.2%
+42.2% vs TC avg
§102
3.2%
-36.8% vs TC avg
§112
14.2%
-25.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 131 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 . Information Disclosure Statement The information disclosure statement (IDS) filed on 4/8/26 is considered by the examiner. Claim Objections Claims 11-16 and 18-19 are objected to because of the following informalities: A second claim 11 is recited after the first claim 11, and depends from itself; a claim cannot depend from itself. Claim 12 depends from itself; a claim cannot depend from itself; Claim 13 depends from itself; a claim cannot depend from itself; Claim 14 depends from itself; a claim cannot depend from itself; Claim 15 depends from itself; a claim cannot depend from itself; Claim 16 depends from itself; a claim cannot depend from itself; Claim 18 depends from itself; a claim cannot depend from itself; Claim 19 depends from itself; a claim cannot depend from itself; Claim 17 is believed to be intended to be listed as claim 18, along with other claims 11 (the second) through 19 intended to be listed as one claim number greater than they are currently listed (Examiner advises this as the most straightforward correction to the objections listed and the 112(d) rejection cited below). Appropriate correction is required. Claim Rejections - 35 USC § 112 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. Claims 11-16 and 18-19 are 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. In detail, Two instances of claim 11 are listed, the second depending upon claim 11; a claim cannot depend upon itself, thus claim 11 is construed as failing to further limit the subject matter of the claim upon which it depends. Claim 12 depends upon itself; a claim cannot depend upon itself, thus claim 12 is construed as failing to further limit the subject matter of the claim upon which it depends. Claim 13 depends upon itself; a claim cannot depend upon itself, thus claim 13 construed as failing to further limit the subject matter of the claim upon which it depends. Claim 14 depends upon itself; a claim cannot depend upon itself, thus claim 14 is construed as failing to further limit the subject matter of the claim upon which it depends. Claim 15 depends upon itself; a claim cannot depend upon itself, thus claim 15 construed as failing to further limit the subject matter of the claim upon which it depends. Claim 16 depends upon itself; a claim cannot depend upon itself, thus claim 16 is construed as failing to further limit the subject matter of the claim upon which it depends. Claim 18 depends upon itself; a claim cannot depend upon itself, thus claim 18 construed as failing to further limit the subject matter of the claim upon which it depends. Claim 19 depends upon itself; a claim cannot depend upon itself, thus claim 19 is construed as failing to further limit the subject matter of the claim upon which it depends. 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 § 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)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1 and 3 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Varjonen et al. (US PG Pub. No. 2019/0245272). Regarding claim 1, Varjonen et al. teaches (Fig. 10) a wrist-worn electronic device comprising: a housing including a circumferential side wall (101), and a bottom plate coupled to a lower surface of the side wall (105 coupled by ground pins 106 and 107), the bottom plate formed from electrically conductive material (sheet metal, see ¶53); a printed circuit board positioned within the housing above the bottom plate (102), the printed circuit board at least partially forming a ground plane (104); and a first slot antenna configured to transmit a first wireless signal, receive the first wireless signal, or both, the first wireless signal having a first frequency (slot formed by 101, 104, 105a; see ¶9, ¶53 lines 12-15, ¶45 lines 12-14), the first slot antenna formed in part by: a first portion of a circumference of the bottom plate, and the ground plane of the printed circuit board (slot formed by 101, 104, 105a; see Fig. 10). Regarding claim 3, Varjonen teaches the wrist-worn electronic device of claim 1, wherein the first slot antenna is configured as a first global navigation satellite system (GNSS) antenna configured to wirelessly receive a first location wireless signal (see ¶16), the first location wireless signal corresponding to the wireless signal (see ¶9). Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Varjonen et al. (US PG Pub. No. 2019/0245272) as applied to claim 3 above, and further in view of Sayem et al. (US PG Pub. No. 2021/0239847). Regarding claim 4, Varjonen teaches the wrist-worn electronic device of claim 3. Varjonen does not teach the wrist-worn electronic device further comprising a location determining element, wherein the first slot antenna is further configured to electronically communicate a first location electronic signal to the location determining element, the first location electronic signal corresponding to the first location wireless signal, and wherein the location determining element is configured to determine a current geolocation of the electronic device based on the first location electronic signal. Sayem et al. teaches (Figs. 1-4) a wrist-worn electronic device (10) comprising: a first antenna (48) configured to transmit a first wireless signal, receive the first wireless signal, or both, the first wireless signal having a first frequency (¶33, Fig. 4); wherein the first antenna is configured as a first global navigation satellite system antenna configured to wirelessly receive a first location wireless signal (¶16), the first location wireless signal corresponding to the first wireless signal (¶16); and further comprising a location determining element (26), wherein the first slot antenna is further configured to electronically communicate a first location electronic signal to the location determining element (see Fig. 4; ¶33), the first location electronic signal corresponding to the first location wireless signal, and wherein the location determining element is configured to determine a current geolocation of the electronic device based on the first location electronic signal (¶34). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the wrist-worn electronic device of Varjonen such that it further comprises a location determining element, wherein the first slot antenna is further configured to electronically communicate a first location electronic signal to the location determining element, the first location electronic signal corresponding to the first location wireless signal, and wherein the location determining element is configured to determine a current geolocation of the electronic device based on the first location electronic signal, employing the teachings of Sayem. Doing so would provide the predictable benefit of enabling operation of the wrist-worn electronic device to determine its geolocation based on a GNSS wireless signal (Sayem, ¶2 lines 23-27). Allowable Subject Matter Claims 2 and 5-10 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Regarding claim 2, the prior art does not teach or reasonably suggest, in combination with other claimed limitations, the limitations of “a plurality of bottom plate conductive elements, each bottom plate conductive element providing an electrical connection from the printed circuit board to the bottom plate; and the first slot antenna is further formed by: a first bottom plate conductive element positioned at a first end of the first portion of the circumference of the bottom plate, a second bottom plate conductive element positioned at a second end of the first portion of the circumference of the bottom plate, and the first portion of the circumference of the bottom plate extending between the first end and the second end of the first portion of the circumference of the bottom plate” and the modification of the art of record to incorporate all of these features would not have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention. Regarding claim 5, the prior art does not teach or reasonably suggest, in combination with other claimed limitations, the limitations of “a second slot antenna configured to transmit a second wireless signal, receive the second wireless signal, or both, the second wireless signal having a second frequency, the second slot antenna formed in part by: a second portion of a circumference of the bottom plate, and the ground plane of the printed circuit board; and a third bottom plate conductive element providing an electrical connection from the printed circuit board to the bottom plate and positioned at a first end of the second portion of the circumference of the bottom plate; wherein the first bottom plate conductive element is positioned at a second end of the second portion of the circumference of the bottom plate; and wherein the second portion of the circumference of the bottom plate extends between the first end and the second end of the second portion of the circumference of the bottom plate” and the modification of the art of record to incorporate all of these features would not have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention. Claims 6-10 are included for their dependence upon claim 5. Claim 11 (the first) is acknowledged as comprising allowable subject matter. Regarding claim 11 (the first), the closest found prior art is Varjonen et al. (US PG Pub. No. 2019/0245272) which teaches (Fig. 10) a wrist-worn electronic device comprising: a housing including a circumferential side wall (101), and a bottom plate coupled to a lower surface of the side wall (105 coupled by ground pins 106 and 107), the bottom plate formed from electrically conductive material (sheet metal, see ¶53); a printed circuit board positioned within the housing above the bottom plate (102), the printed circuit board at least partially forming a ground plane (104); and a first slot antenna configured to transmit a first wireless signal, receive the first wireless signal, or both, the first wireless signal having a first frequency (slot formed by 101, 104, 105a; see ¶9, ¶53 lines 12-15, ¶45 lines 12-14), the first slot antenna formed in part by: a first portion of the circumference of the bottom plate, and the ground plane of the printed circuit board (slot formed by 101, 104, 105a; see Fig. 10). Varjonen does not teach the wrist-worn electronic device comprising a plurality of bottom plate conductive elements, each bottom plate conductive element providing an electrical connection from the printed circuit board to the bottom plate; nor the first slot antenna being additionally formed in part by a first bottom plate conductive element positioned at a first end of the first portion of the circumference of the bottom plate, a second bottom plate conductive element positioned at a second end of the first portion of the circumference of the bottom plate, the first portion of the circumference of the bottom plate extending between the first end and the second end of the first portion of the circumference of the bottom plate, and the modification of the art of record to incorporate all of these features would not have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention. Claim 11 (the second) and claims 12-16 are believed by the examiner to be intended to be numbered 12-17, and thus believed to be intended to depend upon claim 11 (the first), therefore would be allowable if amended to overcome the 112(d) rejection detailed above. Regarding claim 17, the closest found prior art is Varjonen et al. (US PG Pub. No. 2019/0245272) which teaches (Fig. 10) a wrist-worn electronic device comprising: a housing including a circumferential side wall (101), and a bottom plate coupled to a lower surface of the side wall (105 coupled by ground pins 106 and 107), the bottom plate formed from electrically conductive material (sheet metal, see ¶53); a printed circuit board positioned within the housing above the bottom plate (102), the printed circuit board at least partially forming a ground plane (104); and a first slot antenna configured to transmit a first wireless signal, receive the first wireless signal, or both, the first wireless signal having a first frequency (slot formed by 101, 104, 105a; see ¶9, ¶53 lines 12-15, ¶45 lines 12-14), the first slot antenna formed in part by: a first portion of the circumference of the bottom plate extending between a first end and a second end of the first portion of the circumference of the bottom plate, and the ground plane of the printed circuit board (slot formed by 101, 104, 105a; see Fig. 10). Varjonen does not teach the wrist-worn electronic device further comprising: a plurality of bottom plate conductive elements, each bottom plate conductive element providing an electrical connection from the printed circuit board to the bottom plate; nor the first slot antenna additionally formed in part by: a first bottom plate conductive element positioned at a first end of the first portion of the circumference of the bottom plate, a second bottom plate conductive element positioned at a second end of the first portion of the circumference of the bottom plate; nor a second slot antenna configured to transmit a second wireless signal, receive the second wireless signal, or both, the second wireless signal having a second frequency, the second slot antenna formed in part by a second portion of a circumference of the bottom plate and the ground plane of the printed circuit board, and the modification of the art of record to incorporate all of these features would not have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention. Claims 18-19 are believed by the examiner to be intended to depend upon the independent claim currently listed as claim 17, therefore would be allowable if amended to overcome the 112(d) rejection detailed above. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Puuri (US PG Pub. No. 2007/0091004), Zhao (US PG Pub. No. 2023/0022192), Grange et al. (US PG Pub. No. 2011/0234461), Akiyama (US PG Pub. No. 2009/0033554), and Puuri (US PG Pub. No. 2007/0091004) each teach wrist-worn devices comprising various slot antennas on their circumference. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Jordan E. DeWitt whose telephone number is (571)270-1235. The examiner can normally be reached Monday thru Thursday from 8:30 AM to 3:30 PM ET. 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, Dameon Levi can be reached at 571-272-2105. 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. /DAMEON E LEVI/Supervisory Patent Examiner, Art Unit 2845 /Jordan E. DeWitt/Examiner, Art Unit 2845
Read full office action

Prosecution Timeline

Jul 08, 2024
Application Filed
Jul 08, 2026
Non-Final Rejection mailed — §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
84%
Grant Probability
98%
With Interview (+13.5%)
2y 2m (~1m remaining)
Median Time to Grant
Low
PTA Risk
Based on 131 resolved cases by this examiner. Grant probability derived from career allowance rate.

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