Office Action Predictor
Last updated: April 16, 2026
Application No. 18/770,129

REFRIGERATOR APPLIANCE AND WATER VALVE MOUNTING SYSTEM

Final Rejection §103
Filed
Jul 11, 2024
Examiner
ZERPHEY, CHRISTOPHER R
Art Unit
3799
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Whirlpool Corporation
OA Round
2 (Final)
48%
Grant Probability
Moderate
3-4
OA Rounds
3y 2m
To Grant
62%
With Interview

Examiner Intelligence

Grants 48% of resolved cases
48%
Career Allow Rate
360 granted / 749 resolved
-21.9% vs TC avg
Moderate +14% lift
Without
With
+13.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
53 currently pending
Career history
802
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
51.6%
+11.6% vs TC avg
§102
17.9%
-22.1% vs TC avg
§112
23.5%
-16.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 749 resolved cases

Office Action

§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 . The claims received 3/10/2026 are entered. 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) 1-2, 4-7, 9, 11-14, and 16-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Choi (KR101994688; provided by applicant on 7/11/2024, machine translation attached) in view of Griffin (US 4,678,003) Regarding claims 1 and 16-17, Choi discloses a refrigerator comprising: a cabinet defining a machine compartment (10); a water system (i) configured to receive water from a supply source and (ii) having a valve (20) configured to control water flow through the water system; and a bracket (300) secured to cabinet within the machine compartment (10) where the valve (20) is secured to the bracket (300). Choi lacks the bracket as claimed. Griffin discloses a bracket includes first, second, and third planar sections (25, 19, and 25; all sections include planar portions or 25, 25, 19 in regard to claim 17), (ii) the first planar section (25) is pivotably secured to the second planar section (19) via a first hinge (23), (iii) the second planar section (19) is pivotably secured to the third planar section (25) via a second hinge (23), (iv) the first, second, and third planar sections are oriented along the hinges such that the first, second, and third planar sections form an enclosure, and (v) the valve is secured to the bracket within the enclosure (the purpose of the enclosure is to protect a valve). It would have been obvious to one of ordinary skill in the art to have provided Choi with the enclosure type bracket of arrangement of Griffin in order to protect the valve from the surrounding environment, incidental or unintentional contact, or tampering. Regarding claim 2, Choi and Griffin further discloses the first planar section (25 of Griffin) and the third planar section (25) are substantially parallel to each other (as oriented in figure 2), the first and third planar sections are separated by the second planar section (19; shown in figure 3), and the second planar section is substantially parallel to the first and third planar sections along an outer region of the enclosure (the second planar section is substantially horizontal while the first and third are substantially vertical thus they are perpendicular). Regarding claim 4, Choi and Griffin discloses the refrigerator of claim 1, wherein (i) the bracket includes snaps (35 of Griffin) extending from the first planar section on an opposing end of the first planer section relative to the first hinge and (ii) the snaps engage the third planar section on an opposing end of the third planar section relative to the second hinge to attach the first planar section to the third planar section and to form the enclosure. Regarding claim 5, Choi and Griffin disclose the refrigerator of claim 1, wherein (i) the bracket includes a cradle positioned on the first planar section proximate to an opposing end of the first planer section relative to the first hinge and (ii) the cradle is configured to engage an inlet region of the valve to facilitate securing the valve to the bracket (Choi discloses the bracket cradles the valve 20; moreover in view of Griffin the first planar section includes a concave arrangement to receive the valve). Regarding claim 6, Choi and Griffin disclose the refrigerator of claim 5, wherein (i) the bracket includes a protrusion (320 of Choi) extending from the third planer section and (ii) the protrusion is configured to engage an opposing side of the inlet region of the valve relative to the cradle to force the inlet region of the valve into engagement with the cradle. Regarding claims 7 and 20, Choi and Griffin disclose the refrigerator of claim 1, wherein (i) the bracket includes a protrusion (21 of Griffin) extending from the second planar section and (ii) the protrusion is configured to (a) engage the first planar section to maintain a substantially perpendicular orientation of the second planar section relative to the first planar section along an outer region of the enclosure and (b) disengage the first planar section such that the orientation of the second planar section is greater than substantially perpendicular relative to the first planar section (as shown in figure 3 of Griffin the leaves 21 protruding from the second planar section allows for the perpendicular relative positioning of the respective planar sections). Regarding claim 8, Choi and Griffin disclose the refrigerator of claim 1, but lack noise absorbers. The examiner takes official notice that noise absorbers are old and well known, e.g. rubber or other resilient mounts. It would have been obvious to one of ordinary skill in the art to have provided Choi with noise absorbers extending from the third planar section and (ii) the noise absorbers are configured to engage the valve in order to reduce noise and vibration and otherwise prevent damage. Regarding claim 9, Choi and Griffin disclose the refrigerator of claim 1, wherein (i) the bracket includes at least one cradle ([0079]) positioned on the third planar section and (ii) the at least one cradle is configured to engage an outlet region (22 of the valve 20) of the valve to facilitate securing the valve to the bracket. Regarding claim 11, Choi and Griffin disclose the refrigerator appliance of claim 10, wherein (i) the bracket includes snaps (35 of Griffin) extending from a first of the sections on an opposing end of the first of the sections relative to a first of the pivots and (ii) the snaps engage a second of the sections on an opposing end of the second of the sections relative to a second hinge to attach the first of the sections to the second of the sections and to form the cage. Regarding claim 12, Choi and Griffin disclose the refrigerator appliance of claim 10, wherein (i) the bracket includes a cradle (241) positioned on a first of the sections proximate to an opposing end of the first of the sections relative to a first of the pivots and (ii) the cradle is configured to engage an inlet region (211) of the valve to facilitate securing the valve to the bracket. Regarding claim 13, Choi and Griffin disclose the refrigerator appliance of claim 12, wherein (i) the bracket includes a protrusion (321) extending from a second of the sections and (ii) the protrusion is configured to engage an opposing side of the inlet region (211) of the valve relative to the cradle (241) to force the inlet region of the valve into engagement with the cradle. Regarding claim 14, Choi and Griffin disclose the refrigerator appliance of claim 10, wherein (i) the bracket includes a protrusion (21 of Griffin) extending from a first of the sections and (ii) the protrusion is configured to (a) engage a second of the sections to maintain a substantially perpendicular orientation of the first of the sections relative to the second of the sections along an outer region of the cage and (b) disengage the second of the sections such that the orientation of the first of the sections is greater than substantially perpendicular relative to the second of the sections (as shown in figure 3 of Griffin the leaves 21 protruding from the second planar section allows for the perpendicular relative positioning of the respective planar sections). Regarding claim 15, Choi and Griffin disclose the refrigerator of claim 10, but lack noise absorbers. The examiner takes official notice that noise absorbers are old and well known, e.g. rubber or other resilient mounts. It would have been obvious to one of ordinary skill in the art to have provided Choi with noise absorbers extending from the sections and (ii) the noise absorbers are configured to engage the valve in order to reduce noise and vibration and otherwise prevent damage. Regarding claim 18, Choi and Griffin disclose the refrigerator water valve mounting bracket of claim 17, wherein (i) the second of the of the sections is operable to transition to a third position between a corresponding first position and second position and (ii) in the third position, the second of the sections is non-parallel and non-perpendicular to the first and second of the sections (the sections of Griffin rotate between the extremes of figures 2 and 3 and include an infinite amount of rotational positions between said extremes). Regarding claim 19, Choi and Griffin disclose the refrigerator water valve mounting bracket of claim 17 further comprising snaps (35 of Griffin) extending from the first of the sections on an opposing end of the first of the sections relative to a first of the hinges, and wherein the snaps engage the second of the sections on an opposing end of the second of the sections relative to a second of the hinges to attach the first of the sections to the second of the sections and to form the enclosure. Claim(s) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Choi (KR101994688; provided by applicant on 7/11/2024, machine translation attached), in view of Griffin (US 4,678,003), and in further view of Proto Labs (“Designing Living Hinges that Fold Flat” 12/1/2017) Regarding claim 3, Choi and Griffin disclose the refrigerator of claim 1, but lack living hinges. The examiner previously took official notice that living hinges are old and well known. Applicant has requested evidence. Proto Labs is provided who teaches design of a living hinge. It would have been obvious to have provided Choi and Griffin with living hinges in order to utilize their low cost and ease of manufacture. Claim(s) 8 and 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Choi (KR101994688; provided by applicant on 7/11/2024, machine translation attached), in view of Griffin (US 4,678,003), and in further view of Jefford et al (US 2014/0345709) Regarding claim 8, Choi and Griffin disclose the refrigerator of claim 1, but lack noise absorbers. The examiner previously took official notice that noise absorbers are old and well known, e.g. rubber or other resilient mounts. Jefford discloses a resilient rubber mounting arrangement for a valve for the purpose of minimizing noise. It would have been obvious to one of ordinary skill in the art to have provided Choi with noise absorbers extending from the third planar section and (ii) the noise absorbers are configured to engage the valve in order to reduce noise and vibration and otherwise prevent damage. Regarding claim 15, Choi and Griffin disclose the refrigerator of claim 10, but lack noise absorbers. The examiner previously took official notice that noise absorbers are old and well known, e.g. rubber or other resilient mounts. Jefford discloses a resilient rubber mounting arrangement for a valve for the purpose of minimizing noise. It would have been obvious to one of ordinary skill in the art to have provided Choi with noise absorbers extending from the sections and (ii) the noise absorbers are configured to engage the valve in order to reduce noise and vibration and otherwise prevent damage. Claim(s) 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Choi (KR101994688; provided by applicant on 7/11/2024, machine translation attached), in view of Griffin (US 4,678,003), and in view of Deem, Jr. (US 2005/0076667) Regarding claim 10, Choi discloses a refrigerator appliance comprising: a cabinet (14); at least one conduit (26) secured to the cabinet and configured to transport water; a valve (20) configured to control water flow through the at least one conduit; and a bracket (300) operable to secure the valve to the cabinet, wherein (i) the bracket includes a plurality of sections, and (iv) the valve is secured to the bracket (300). Choi is silent concerning a use for the water. The examiner previously took official notice that refrigerators are old and well known to include dispensers or ice makers. Deem is now provided who teaches a refrigerator including an ice maker and water dispenser. It would have been obvious to one of ordinary skill in the art to have provided Choi a dispenser and/or an ice maker as a destination for the supplied water in order to increase utility to a user. Choi lacks pivots. Griffin discloses a bracket includes a plurality of sections (25, 19, and 25), connected to each other via pivots (23), the plurality of sections form a cage for a valve (the purpose of the enclosure is to protect a valve). It would have been obvious to one of ordinary skill in the art to have provided Choi with the enclosure type bracket of arrangement of Griffin in order to protect the valve from the surrounding environment, incidental or unintentional contact, or tampering. Response to Arguments Applicant's arguments filed 3/10/2026 have been fully considered but they are not persuasive. At pages 7-8 applicant argues that the cap of Griffin does not “mount, secure, or otherwise support the valve”. First, Choi provides that the valve is secured to the bracket thus the argument is not addressing the rejection. Second, even assuming arguendo that Griffin was relied upon to teach the feature, said elements (i.e. the valve and bracket) are secured together. Said elements are provided together in an assembly. Still further the claims fail to delineate the valve or bracket in a manner that would frustrate such a reading. Regarding pages 8-9 applicant purports that the that Griffin is non-analogous art. A reference is analogous art to the claimed invention if: (1) the reference is from the same field of endeavor as the claimed invention (even if it addresses a different problem); or (2) the reference is reasonably pertinent to the problem faced by the inventor (even if it is not in the same field of endeavor as the claimed invention). Note that "same field of endeavor" and "reasonably pertinent" are two separate tests for establishing analogous art; it is not necessary for a reference to fulfill both tests in order to qualify as analogous art. MPEP 2141.01(a). Here, Griffin is concerned with the protection of a valve which is both in the same field of endeavor and the same problem being faced in the instant application. Thus both elements are satisfied, where only one is required. Regarding the transfer of force to the valve. As is provided in Choi the bracket is attached to the wall of the compartment, similar in that the bracket of Griffin is attached to the cylinder neck. Applicant is constructing some combination other than that which is presented above in order to suggest a deficiency. Also while not conceding any of the purported results of modification made by applicant it is noted that "[a] given course of action often has simultaneous advantages and disadvantages, and this does not necessarily obviate motivation to combine". MPEP 2141.02. Regarding pages 9-10, applicant discusses claims 6 and 13. Applicant argues that the fastening portions and part are not opposed to the cradle 241 relative to the inlet 211. However the cradle is below the inlet which the fastening portion and part are above. Regarding pages 10-11, applicant discusses claims 7, 14, and 20. Applicant argues that the element 21 does not engage with portion 25. Again reviewing figures 2 and 3 of Griffin demonstrates the that the protrusion or hinge portion 21 engages with the relevant planar portions to all for positioning of the first and third planar sections are recited in the claims. Regarding pages 11-12, applicant has requested evidence of that which is old and well known. Therefor references have been provided. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Deem, Jr. (US 2005/0076667) refrigerator water dispenser and ice maker water valve mounting. Ozarek et al (US 12,017,878) refrigerator valve mount. Prewitt (US 6,209,574) refrigerant valve lock box. Devine (US 7,243,674) water valve enclosure. Martin, Jr. (US 4,301,828) valve enclosure. Brady et al (US 6,062,254) valve manifold enclosure (plural valves in enclosure). Moore et al (US 5,078,171) water valve enclosure. Bayram et al (US 9,945,621) elastic valve mounting member Chang (US 6,206,033) living hinge for valve enclosure. THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTOPHER R ZERPHEY whose telephone number is (571)272-5965. The examiner can normally be reached M-F 7:00-4:00 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, Jianying Atkisson can be reached at 5712707740. 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. /CHRISTOPHER R ZERPHEY/Primary Examiner, Art Unit 3799
Read full office action

Prosecution Timeline

Jul 11, 2024
Application Filed
Dec 08, 2025
Non-Final Rejection — §103
Mar 10, 2026
Response Filed
Mar 25, 2026
Final Rejection — §103 (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

3-4
Expected OA Rounds
48%
Grant Probability
62%
With Interview (+13.9%)
3y 2m
Median Time to Grant
Moderate
PTA Risk
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