Prosecution Insights
Last updated: April 18, 2026
Application No. 18/788,999

LIQUID CARTRIDGE

Non-Final OA §103
Filed
Jul 30, 2024
Examiner
ZIMMERMANN, JOHN P
Art Unit
2853
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Brother Kogyo Kabushiki Kaisha
OA Round
1 (Non-Final)
83%
Grant Probability
Favorable
1-2
OA Rounds
2y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allow Rate
598 granted / 724 resolved
+14.6% vs TC avg
Strong +20% interview lift
Without
With
+19.7%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
32 currently pending
Career history
756
Total Applications
across all art units

Statute-Specific Performance

§103
76.8%
+36.8% vs TC avg
§102
15.3%
-24.7% vs TC avg
§112
5.0%
-35.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 724 resolved cases

Office Action

§103
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 . Priority Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). The certified copy has been received. Information Disclosure Statement The Information Disclosure Statement (IDS) submitted on 30 July 2024 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the Information Disclosure Statement has been considered by the Examiner. 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. This application currently names joint inventors. In considering patentability of the claims the Examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the Examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 1-14, 17, & 19-21 are rejected under 35 U.S.C. 103 as being unpatentable over Miyashita et al. (US 2016/0332451 A1) in view of Sasaki et al. (US 5,975,330 A). As related to independent claim 1, Miyashita et al. teaches a liquid cartridge comprising: a housing that has a cylindrical portion (Miyashita et al – Figures 2A & 2B, shown below); and a first valve mechanism at least partially accommodated in the cylindrical portion (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, shown below), wherein the housing is blow molded with air blown from an air nozzle (Miyashita et al. – Page 3, Paragraph 33). While one of ordinary skill in the art before the effective filing date of the claimed invention would understand the process of blow molding, Miyashita et al. does not specifically teach the method of blow molding with air blown from an air nozzle. However, Sasaki et al. teaches a liquid cartridge comprising: a housing that has a cylindrical portion (Sasaki et al – Figures 1(a) & 1(c), shown below); and a first valve mechanism at least partially accommodated in the cylindrical portion (Sasaki et al. – Column 14, Lines 55-59; Column 14, Lines 31-62 and Figure 1(a), Reference #106, shown below), and specifically teaches wherein the housing is blow molded with air blown from an air nozzle (Sasaki et al. – Column 15, Line 3 – Column 16, Line 21). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to specify the method of blow molding of Miyashita et al. to be that of Sasaki et al. in an effort to provide with specificity the method of manufacturing a blow molded ink container [i.e. housing] (Sasaki et al. – Column 15, Lines 2-16). PNG media_image1.png 183 412 media_image1.png Greyscale PNG media_image2.png 234 328 media_image2.png Greyscale PNG media_image3.png 220 319 media_image3.png Greyscale PNG media_image4.png 298 332 media_image4.png Greyscale PNG media_image5.png 414 322 media_image5.png Greyscale Continuing with claim 1, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach at least a part of an inner surface of the cylindrical portion is a transfer surface to which an outer peripheral surface of a mold is transferred, the first valve mechanism includes; a seal member that defines a first through hole and is in contact with the transfer surface; a valve positioned in the cylindrical portion and configured to open and close the first through hole; and a biasing member configured to bias the valve toward the seal member, and the seal member includes a first seal portion in contact with the transfer surface and a second seal portion configured to contact with the valve (Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to independent claim 21, the combination of Miyashita et al. and Sasaki et al. remains for the reasons indicated above and also teaches a manufacturing method for a liquid cartridge (Sasaki et al. – Column 15, Line 3 – Column 16, Line 21) the liquid cartridge including; a housing that has a cylindrical portion (Miyashita et al – Figures 2A & 2B, shown above); and a first valve mechanism at least partially accommodated in the cylindrical portion (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, shown above), the manufacturing method comprising: blow-molding the housing with air blown from an air nozzle, and in the blow-molding, at least a part of an inner surface of the cylindrical portion is a transfer surface to which an outer peripheral surface of a mold is transferred (Sasaki et al. – Column 15, Line 3 – Column 16, Line 21 and Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above), and inserting the first valve mechanism into the cylindrical portion, wherein the first valve mechanism includes; a seal member that defines a first through hole and is in contact with the transfer surface; a valve positioned in the cylindrical portion and configured to open and close the first through hole; and a biasing member configured to bias the valve toward the seal member, and the seal member includes a first seal portion in contact with the transfer surface and a second seal portion configured to contact the valve (Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to dependent claim 2, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the outer peripheral surface of the mold is an outer peripheral surface of the air nozzle (Sasaki et al. – Column 15, Line 3 – Column 16, Line 21). As related to further dependent claim 3, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the liquid cartridge further comprising a support member that has a cylindrical shape, is accommodated in the cylindrical portion, and accommodates the valve and the biasing member therein, wherein the support member includes a contact portion in contact with the seal member (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 4, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the cylindrical portion that extends in a first direction, and the contact portion is in contact with the seal member in one direction in the first direction (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #28, #20, #30, & #23, shown above). As related to further dependent claim 5, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the seal member includes: a first portion having the first seal portion, and a second portion having the second seal portion and extending form the first portion in an other direction opposite to the one direction (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #28, #20, #30, & #23, shown above). As related to further dependent claim 6, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the first valve mechanism defines a second through hole and includes a contact member [i.e. joint member] in contact with the seal member, and the contact member is in contact with an inner peripheral surface of the first portion (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #28, #20, #30, & #23, shown above). As related to further dependent claim 7, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the first valve mechanism defines a second through hole and includes a contact member in contact with the seal member (Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 8, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the contact member is in contact with the seal member in an other direction opposite to the one direction (Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 9, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the seal member has a first portion having the first seal portion, and the contact member is in contact with an inner peripheral surface of the first portion (Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 10, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the contact member is bonded or welded to the transfer surface (Sasaki et al. – Column 13, Line 58 – Column 14, Line 21 and Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 11, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach at least a part of the inner peripheral surface of the support member is a first guide surface configured to guide the biasing member in a first direction in which the cylindrical portion extends (Miyashita et al. – Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 12, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach at least a part of the inner peripheral surface of the support member is a second guide surface configured to guide the valve in the first direction in which the cylindrical portion extends (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 13, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the second guide surface is a single surface in the first direction (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 14, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the support member is in pressure contact with at least a part of the inner surface of the cylindrical portion (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). As related to further dependent claim 17, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the housing includes a chamber configured to store liquid therein and an atmosphere communication port configured to communicate with the chamber and an outside (Sasaki et al. – Column 7, Lines 33-44; Column 8, Line 66 – Column 9, Line 5; Column 13, Line 58 – Column 14, Line 21; and Figure 1(a), Reference #105, shown above). As related to further dependent claim 19, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the housing includes a chamber configured to store liquid therein and an atmosphere communication port configured to communicate with the chamber and an outside (Sasaki et al. – Column 13, Line 58 – Column 14, Line 21 and Figure 1(a), Reference #105, shown above). As related to further dependent claim 20, the combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to teach the housing includes a chamber configured to store liquid therein and a protrusion that protrudes from an outer surface of the housing, and an internal space of the protrusion communicates with the chamber (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above). Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over the combination of Miyashita et al. (US 2016/0332451 A1) and Sasaki et al. (US 5,975,330 A) in further view of Hattori et al. (US 6,719,415 B1). The combination of Miyashita et al. and Sasaki et al. remains as applied above but does not specifically teach the cylindrical portion has a tapered surface. However, Hattori et al. teaches a liquid cartridge comprising: a housing which is blow molded, that has a cylindrical portion (Hattori et al. – Column 1, Lines 13-15 and Figures 2, 3, & 14, Reference #230, shown below); and a first valve mechanism at least partially accommodated in the cylindrical portion (Hattori et al. – Figure 2, Reference #260b, shown below); and specifically teaches the cylindrical portion has a tapered surface that defines an internal space such that the internal space gradually narrows in an other direction opposite to one direction in a first direction in which the cylindrical portion extends, and the support member is in contact with the tapered surface (Hattori et al. – Column 40, Lines 21-50 and Figure 14, Reference #267, shown below). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the cylindrical portion of the combination of Miyashita et al. and Sasaki et al. with the cylindrical portion of Hattori et al. in an effort to provide a sealing portion which better seals the first valve system (Hattori et al. – Column 40, Lines 21-50). PNG media_image6.png 454 516 media_image6.png Greyscale PNG media_image7.png 406 478 media_image7.png Greyscale PNG media_image8.png 360 468 media_image8.png Greyscale Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over the combination of Miyashita et al. (US 2016/0332451 A1) and Sasaki et al. (US 5,975,330 A) in further view of Umeda (US 2002/0196312 A1). The combination of Miyashita et al. and Sasaki et al. remains as applied above and continues to the valve includes a first valve configured to contact with the first portion (Miyashita et al. – Page 2, Paragraph 24 and Figures 1 & 2B, Reference #27, #28, #20, #30, #21, #23, & #26, shown above) but does not specifically teach a second valve configured to contact with the second portion. However, Umeda teaches a liquid cartridge comprising: a housing which is blow molded, that has a cylindrical portion (Umeda – Page 5, Paragraph 68 and Figures 14 & 15A-15C, shown below); and a first valve mechanism at least partially accommodated in the cylindrical portion (Umeda – Figures 14 & 15A-15C, shown below); and specifically teaches the valve includes a first valve configured to contact the first portion and a second valve configured to contact with the second portion (Umeda – Page 8, Paragraph 92 – Page 9, Paragraph 93 and Figures 14 & 15A-15C, shown below). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the valve of the combination of Miyashita et al. and Sasaki et al. with the valve comprising two valves of Umeda in an effort to provide a sealing portion which better seals the valve system and prevents leaking (Umeda – Page 9, Paragraph 93). PNG media_image9.png 444 688 media_image9.png Greyscale PNG media_image10.png 378 698 media_image10.png Greyscale Claim 18 is rejected under 35 U.S.C. 103 as being unpatentable over the combination of Miyashita et al. (US 2016/0332451 A1) and Sasaki et al. (US 5,975,330 A) in further view of Ishizawa et al. (US 2002/0196312 A1). The combination of Miyashita et al. and Sasaki et al. remains as applied above but does not specifically teach a semipermeable membrane. However, Ishizawa et al. teaches a liquid cartridge comprising: a housing that has a cylindrical portion (Ishizawa et al. – Figures 6 & 22, Reference #24 & #71, shown below); and a first valve mechanism at least partially accommodated in the cylindrical portion (Ishizawa et al. – Page 19, Paragraphs 352-357 and Figure 22, Reference #123, shown below) with an atmosphere communication port (Ishizawa et al. – Page 11, Paragraphs 206-207 and Figure 5, Reference #62, shown below) and specifically teaches the housing includes a semipermeable membrane [i.e. water repellent film] that closes the atmosphere communication port, blocks passage of liquid and allows passage of air (Ishizawa et al. – Page 11, Paragraphs 206-207 and Figure 5, Reference #62 & #63, shown below. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the atmosphere communication port of Miyashita et al. and Sasaki et al. with the atmosphere communication port having semipermeable membrane of Ishizawa et al. in an effort to provide an atmosphere communication port which allows the atmosphere to pass through and blocking passage of ink or liquid (Ishizawa – Page 11, Paragraph 207). PNG media_image11.png 566 418 media_image11.png Greyscale PNG media_image12.png 670 434 media_image12.png Greyscale PNG media_image13.png 326 728 media_image13.png Greyscale Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Barinaga et al. (US 5,856,840 A) teaches a liquid cartridge having a housing which is molded and a number of valves. Miyashita et al. (US 2012/0200647 A1) teaches a liquid cartridge having a housing which is blow molded and has valves and seals. MAESHIMA (US 2020/0122472 A1) teaches a liquid cartridge having a valve mechanism a cylindrical portion of housing with tapered walls and an air vent with a valve. MAESHIMA (US 2020/0122473 A1) teaches a liquid cartridge having a valve mechanism a cylindrical portion of housing with tapered walls and an air vent with a valve. Examiner's Note: Examiner has cited particular Figures & Reference Numbers, Columns, Paragraphs and Line Numbers in the references as applied to the claims above for the convenience of the applicant. Although the specified citations are representative of the teachings of the art and are applied to the specific limitations within the individual claim, other passages and figures may apply as well. It is respectfully requested from the applicant in preparing responses, to fully consider the references in their entirety as potentially teaching all or part of the claimed invention, as well as the context of the passage as taught by the prior art or disclosed by the Examiner. Any inquiry concerning this communication or earlier communications from the Examiner should be directed to JOHN P ZIMMERMANN whose telephone number is (571)270-3049. The Examiner can normally be reached Monday-Thursday 0700-1730 EST. 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, Ricardo Magallanes can be reached at (571) 272-5960. 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. /John P Zimmermann/Primary Examiner, Art Unit 2853
Read full office action

Prosecution Timeline

Jul 30, 2024
Application Filed
Apr 02, 2026
Non-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

1-2
Expected OA Rounds
83%
Grant Probability
99%
With Interview (+19.7%)
2y 3m
Median Time to Grant
Low
PTA Risk
Based on 724 resolved cases by this examiner. Grant probability derived from career allow rate.

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