Prosecution Insights
Last updated: April 19, 2026
Application No. 18/774,511

AUTHENTICATABLE ENCLOSURE FOR AN ELECTRONIC DEVICE

Non-Final OA §102§112§Other
Filed
Jul 16, 2024
Examiner
POLLEY, CHRISTOPHER M
Art Unit
1785
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Sandisk Technologies Inc.
OA Round
1 (Non-Final)
73%
Grant Probability
Favorable
1-2
OA Rounds
2y 10m
To Grant
99%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allow Rate
446 granted / 613 resolved
+7.8% vs TC avg
Strong +27% interview lift
Without
With
+26.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
30 currently pending
Career history
643
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
44.9%
+4.9% vs TC avg
§102
24.4%
-15.6% vs TC avg
§112
21.7%
-18.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 613 resolved cases

Office Action

§102 §112 §Other
DETAILED ACTION Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. 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 limitations are: identification means in claim 19. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are 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/them 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(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. This application includes one or more claim limitations that use the word “means” or “step” but are nonetheless not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph because the claim limitation(s) recite(s) sufficient structure, materials, or acts to entirely perform the recited function. Such claim limitation(s) is/are: enclosure means in claim 16. Because this/these claim limitation(s) is/are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are not being interpreted to cover only the corresponding structure, material, or acts described in the specification as performing the claimed function, and equivalents thereof. If applicant intends 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 remove the structure, materials, or acts that performs the claimed function; or (2) present a sufficient showing that the claim limitation(s) does/do not recite sufficient structure, materials, or acts to perform the claimed function. 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. Claims 1-20 are 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. The term “random pattern” in claims 1, 10 and 16 is a relative term which renders the claim indefinite. The term “random pattern” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. One of ordinary skill in the art would know not when a pattern becomes a random pattern because a random pattern to one person may not be considered random to another person. As to claim 19, the phrase “identification means” has invoked 112 6th paragraph as the claims require a means for computer readable identification. However, this claim is indefinite because the corresponding specification fails to provide adequate structure to determine the metes and bounds of this limitation. As to claims 2-9, 11-15, 17, 18 and 20 they are rejected as being dependent from a rejected claim. 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 1-20 are rejected under 35 U.S.C. 102a1 as being anticipated by Kauppi et al (US Publication 20050098924). As to claim 1, 10, and 16 Kauppi discloses an injected molded product including a foil 501, first injection molded part 503 and a second injection molded part 504 (paragraphs 38-40). The first molded part 503 can have color and consist of several differently colored areas or patches with metal flakes, dyes mixed within the polymer resin (embedded) (paragraph 39). Therefore, the first material can be a first patch of color and the second material can be the different colored patch. Kauppi discloses that the decorative pattern can be used to authenticate the product (paragraph 25). The molded product can be used as a cover for electronic components such as a mobile telecommunication device (paragraph 43 and claim 15). The cover for a mobile telecommunication device will read on an enclosing means surrounding the electronic device as the cover will enclose the electronic device on multiple sides. It should be noted that claim 1 is a product by process claim in that it defines how the enclosure was formed. For purposes of examination, product-by-process claims are not limited to the manipulation of the recited steps, only the structure implied by the steps. See MPEP 2113. In the present case, the recited steps imply the structure of an enclosure that has a pattern, and the reference discloses such a product. It should be noted that any pattern that is formed will read on the claimed term random pattern as any pattern could be considered a random pattern As to claim 2, Kauppi discloses that the decorative pattern can be used to authenticate the product (paragraph 25). As to claim 3, Kauppi discloses that metallic flakes (pigments) which can be used as either the first or second colorant (property). As to claim 4, Kauppi discloses that the materials can be different colors or metal flakes and therefore these materials will have different absorption properties (paragraph 43). As to claims 5 and 20, Kauppi discloses that the molded article can comprises metal flakes (particulate) and that can be the second material instead of a colorant. As to claims 6, 7, 15, and 19, Kauppi discloses that the layers can be made of fluorescent dye (which can be the first material instead of a colorant) or contain secret security codes not visible under normal conditions and therefore use an x-ray or other machine to read the code (paragraphs 39 and 50). It should be noted that claims 8 and 9 are product by process claims in that it defines how the enclosure was formed. For purposes of examination, product-by-process claims are not limited to the manipulation of the recited steps, only the structure implied by the steps. See MPEP 2113. In the present case, the recited steps imply the structure of an enclosure that has a pattern with different properties, and the reference discloses such a product. As to claim 11, Kauppi discloses that the molded article has a surface texture as all articles contain a surface texture. It should be noted that any texture, smooth glossy, matte, rough would read on the pattern having a surface texture. As to claim 12, Kauppi discloses that the materials can be different colors or metal flakes and therefore these materials will have different absorption properties as different colors/materials will have different absorption properties and therefore will have two absorption properties (paragraph 43). As to claim 13, Kauppi discloses that the first molded part 503 can have color and consist of several differently colored areas or patches with metal flakes, dyes mixed within the polymer resin (embedded) (paragraph 39). Therefore, the first material can be a first patch of color and the second material can be the different colored patch. As to claim 14, Kauppi discloses that the molded article can comprises metal flakes (particulate) and that can be the second material instead of a colorant (paragraph 43). As to claims 17 and 18, Kauppi discloses that the first molded part 503 can have color and consist of several differently colored areas or patches with metal flakes, dyes mixed within the polymer resin (embedded) (paragraph 39). The different colors will be a different dye content/pigment content. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to CHRISTOPHER M POLLEY whose telephone number is (571)270-5734. The examiner can normally be reached Monday through Friday from 8am till 4:30 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, Mark Ruthkosky can be reached at 5712721291. 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 M POLLEY/Primary Examiner, Art Unit 1785
Read full office action

Prosecution Timeline

Jul 16, 2024
Application Filed
Mar 11, 2026
Non-Final Rejection — §102, §112, §Other (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
73%
Grant Probability
99%
With Interview (+26.8%)
2y 10m
Median Time to Grant
Low
PTA Risk
Based on 613 resolved cases by this examiner. Grant probability derived from career allow rate.

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