Prosecution Insights
Last updated: August 15, 2026
Application No. 18/789,416

MULTI-PIECE GOLF CLUB HEAD

Non-Final OA §101§103§112
Filed
Jul 30, 2024
Priority
Dec 16, 2020 — CIP of 12/121,780 +2 more
Examiner
PASSANITI, SEBASTIANO
Art Unit
3711
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Taylor Made Golf Company, Inc.
OA Round
1 (Non-Final)
83%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allowance Rate
1432 granted / 1725 resolved
+13.0% vs TC avg
Strong +16% interview lift
Without
With
+15.6%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 9m
Avg Prosecution
32 currently pending
Career history
1759
Total Applications
across all art units

Statute-Specific Performance

§101
1.3%
-38.7% vs TC avg
§103
39.2%
-0.8% vs TC avg
§102
18.9%
-21.1% vs TC avg
§112
19.0%
-21.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1725 resolved cases

Office Action

§101 §103 §112
DETAILED ACTION This Office action is responsive to the following communication received: 07/30/2024 - Application papers received, including Power of Attorney and IDS (5 statements); and 10/24/2024 – IDS. 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 . Continuation Data This application is a CON of 17/505,511 10/19/2021 PAT 12569727 which is a CIP of 17/389,167 07/29/2021 ABN which is a CIP of 17/124,134 12/16/2020 PAT 12121780. Drawings The drawings were received on 07/30/2024. The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they do not include the following reference sign(s) mentioned in the description: The reference numerals 4230A, 4230B, 4230C, and 4230D, described in paragraph [00218] of the specification, do not appear in the drawings. The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they include the following reference character(s) not mentioned in the description: The reference numerals 930A, 930B, 930C, and 930D, appearing in FIG. 26, are absent from the specification. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Information Disclosure Statement The IDS, received 07/30/2024, and including 13 pages, contains a citation, the relevance of which to the claimed invention is not readily understood. Specifically, Citation No. 23, identified as USPN RE41577, with a patent date of August 24, 2010 and a patentee named McLean et al, is titled “High Power Density Fuel Cell Stack Using Micro Structured Components”. This citation has been ‘considered’ only to the extent that the USPN, patent date and name of patentee match the PTO records. The IDS papers, received 07/30/2024, repeat the citation of two U.S. Applications under Non-Patent Literature Documents, including “U.S. Application No. 17/124,134 filed on December 16, 2020” along with “U.S. Patent Application No. 17/006,561, filed August 28, 2020”. In order to prevent confusion or duplicate printing during any post-allowance processing, an occurrence of one of the duplicate citations for each U.S. Application has been lined-through. Specification The lengthy specification has not been checked to the extent necessary to determine the presence of all possible minor errors. Applicant’s cooperation is requested in correcting any errors of which applicant may become aware in the specification. The specification is objected to as failing to provide proper antecedent basis for the claimed subject matter. See 37 CFR 1.75(d)(1) and MPEP § 608.01(o). Applicant should point to where, in the originally-filed disclosure, support is provided for the claimed subject matter identified hereinbelow. No new matter should be added. Correction of the following is required: In claim 1 – the recitation of the relative thicknesses of the second and third pieces, namely that “a thickness of the second piece along the bond joint is greater than a thickness of the third piece along the bond joint” is absent from the specification. In addition, while the specification makes general references to continuous fibers and short fibers, the specification is silent as to the specific makeup of the “the second piece is made of a first fiber-reinforced polymeric material comprising a first polymer matrix and short fibers embedded in the first polymer matrix”. In claim 4 – the recitation of the language contrasting the length between the continuous and short fibers, namely “wherein the continuous fibers of the second fiber-reinforced polymeric material are longer than the short fibers of the first fiber-reinforced polymeric material” is not described in the specification. In claims 10-15 and 18-19 – the recitation of the language directed towards the various configurations and features associated with the “seam”. Currently, the specification includes a single mention of “seam” in paragraph [0111] of the specification, yet offers no further description with respect to any of the arrangements for the seam, as more specifically set forth in each of claims 10-15 and 18-19. In claims 10, 12, 16 and 18-19 – the language associated with the various configurations and features associated with the “first portion” and the “second portion” is absent from the specification. Currently, the specification includes a single mention of each of “first portion” and “second portion” in paragraph [0006] of the specification, yet offers no further description with respect to any of the details associated with the first portion and the second portion, as more specifically set forth in each of claims 10, 12, 16 and 18-19. In claim 17 – the language “first elevation” and the “second elevation”. Status of Claims Claims 1-20 are pending. FOLLOWING IS AN ACTION ON THE MERITS: Claim Rejections - 35 USC § 112(b) 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. As to claim 1, lines 14, 16-17, and 20-21, the meaning of “first piece” and “second piece” is not discernible. While the claim states that the first piece “defines at least a portion of the forward portion, the second piece defines at least a portion of the heel portion, the toe portion, the sole portion, and the rearward portion”, the specification reveals that the first piece comprises “a ring”, or comprises “a strike face”, or comprises “a cast cup”, or comprises “an upper cup piece of a cast cup”. The specification further states that the second piece comprises “a cast cup”, or comprises “a ring” (i.e., throughout specification paragraphs [0007] – [0017]). While the specification is intended as an aid in understanding the claim language and while limitations from the specification are not to be imported into the claims (see MPEP 2111.01), the fact that the language “first piece” and “second piece” have been accorded so many different definitions makes it difficult to understand what exactly the scope of the claim is. As to claims 2-9, these claims share the indefiniteness of claim 1. As to claim 10, and considering the comments for claim 1 hereinabove, the language adds a confusing collection of terms and phrases that further cloud the scope of the claim. The club head already comprises a forward portion and a rearward portion and has already been defined as having a first piece, a second piece and a third piece. Now, the added recitations of the “first portion” and the “second portion” along with a “rearward part and a “forward part” appear to redefine what the separate parts of the body are. An effort should be made to simplify and to better organize and convey the various parts that makeup the club head, consistent with the language used in the specification. As to claims 11-19, these claims share the indefiniteness of claim 10, which depends from claim 1. As to claim 20, are the “at least one first material”, the “at least one second material” and the “at least one third material” associated with the first piece, the second piece and the third piece of the club head? Since the first piece, the second piece and the third piece together account for a total mass of the driver-type golf club head, as per claim 1, it seems that the entirety of the at least one first material, the at least one second material and the at least one third material, which are correlated with respect to one another and with respect to the total mass of the driver-type golf club head, as per claim 20, are somehow related to the first piece, the second piece and the third piece. Clarification is requested. Double Patenting - Statutory A rejection based on double patenting of the “same invention” type finds its support in the language of 35 U.S.C. 101 which states that “whoever invents or discovers any new and useful process... may obtain a patent therefor...” (Emphasis added). Thus, the term “same invention,” in this context, means an invention drawn to identical subject matter. See Miller v. Eagle Mfg. Co., 151 U.S. 186 (1894); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Ockert, 245 F.2d 467, 114 USPQ 330 (CCPA 1957). A statutory type (35 U.S.C. 101) double patenting rejection can be overcome by canceling or amending the claims that are directed to the same invention so they are no longer coextensive in scope. The filing of a terminal disclaimer cannot overcome a double patenting rejection based upon 35 U.S.C. 101. Claims 1-20 are provisionally rejected under 35 U.S.C. 101 as claiming the same invention as that of claims 1-20, respectively, of copending Application No. 19/464,339 (reference application). This is a provisional statutory double patenting rejection since the claims directed to the same invention have not in fact been patented. The instant claims 1-20 are identical to claims 1-20, respectively, of the copending ‘339 application. No further explanation is deemed necessary. 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 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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. The Supreme Court in KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007) identified a number of rationales to support a conclusion of obviousness which are consistent with the proper "functional approach" to the determination of obviousness as laid down in Graham. The key to supporting any rejection under 35 U.S.C. 103 is the clear articulation of the reason(s) why the claimed invention would have been obvious. The Supreme Court in KSR noted that the analysis supporting a rejection under 35 U.S.C. 103 should be made explicit. In Ball Aerosol v. Ltd. Brands, 555 F.3d 984, 89 USPQ2d 1870 (Fed. Cir. 2009), the Federal Circuit offered additional instruction as to the need for an explicit analysis. The Federal Circuit explained that the Supreme Court’s requirement for an explicit analysis does not require record evidence of an explicit teaching of a motivation to combine in the prior art. PNG media_image1.png 18 19 media_image1.png Greyscale "[T]he analysis that "should be made explicit" refers not to the teachings in the prior art of a motivation to combine, but to the court’s analysis. . . . Under the flexible inquiry set forth by the Supreme Court, the district court therefore erred by failing to take account of 'the inferences and creative steps,' or even routine steps, that an inventor would employ and by failing to find a motivation to combine related pieces from the prior art." Ball Aerosol, 555 F.3d at 993, 89 USPQ2d at 1877. PNG media_image1.png 18 19 media_image1.png Greyscale The Federal Circuit’s directive in Ball Aerosol was addressed to a lower court, but it applies to Office personnel as well. When setting forth a rejection, Office personnel are to continue to make appropriate findings of fact as explained in MPEP § 2141 and § 2143, and must provide a reasoned explanation as to why the invention as claimed would have been obvious to a person of ordinary skill in the art at the time of the invention. This requirement for explanation remains even in situations in which Office personnel may properly rely on intangible realities such as common sense and ordinary ingenuity. PNG media_image1.png 18 19 media_image1.png Greyscale I. EXEMPLARY RATIONALES PNG media_image1.png 18 19 media_image1.png Greyscale Exemplary rationales that may support a conclusion of obviousness include: PNG media_image1.png 18 19 media_image1.png Greyscale (A) Combining prior art elements according to known methods to yield predictable results; PNG media_image1.png 18 19 media_image1.png Greyscale (B) Simple substitution of one known element for another to obtain predictable results; PNG media_image1.png 18 19 media_image1.png Greyscale (C) Use of known technique to improve similar devices (methods, or products) in the same way; PNG media_image1.png 18 19 media_image1.png Greyscale (D) Applying a known technique to a known device (method, or product) ready for improvement to yield predictable results; PNG media_image1.png 18 19 media_image1.png Greyscale (E) "Obvious to try" – choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success; PNG media_image1.png 18 19 media_image1.png Greyscale (F) Known work in one field of endeavor may prompt variations of it for use in either the same field or a different one based on design incentives or other market forces if the variations are predictable to one of ordinary skill in the art; PNG media_image1.png 18 19 media_image1.png Greyscale (G) Some teaching, suggestion, or motivation in the prior art that would have led one of ordinary skill to modify the prior art reference or to combine prior art reference teachings to arrive at the claimed invention. 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 1-3 and 7-9 are rejected under 35 U.S.C. 103 as being unpatentable over US PUBS 2018/0154224 to Bovee et al (hereinafter referred to as “Bovee”) in view of US PUBS 2019/0046845 to Greensmith et al (hereinafter referred to as “Greensmith”) and also USPN 9,908,014 to Wester et al (hereinafter referred to as “Wester”). As to claim 1, Bovee shows a driver-type golf club head (100; FIGS. 1A-1F), comprising: a forward portion (adjacent numeral 106), comprising a strike face (109); a rearward portion (adjacent numeral 110), opposite the forward portion; a crown portion; a sole portion, opposite the crown portion (440); a heel portion; a toe portion, opposite the heel portion (FIG. 1A); and a body that comprises a first piece, a second piece, and a third piece (i.e., the club head may comprise multiple pieces; paragraph [0002]); wherein: a volume of the driver-type golf club head is between 390 cubic centimeters (cc) and 600 cc (i.e., paragraph [0003]); the first piece, the second piece, and the third piece are bonded together via an adhesive (i.e., paragraphs [0059] and [0114]); the first piece defines at least a portion of the forward portion, the second piece defines at least a portion of the heel portion, the toe portion, the sole portion, and the rearward portion, and the third piece defines at least a portion of the crown portion (i.e., crown insert); the second piece is bonded to the third piece along a bond joint (FIG. 4B); a thickness of the second piece along the bond joint is greater than a thickness of the third piece along the bond joint (i.e., FIG. 5A; noting dimension 468 of the third piece vs. dimension 462 of the second piece; and paragraphs [0121] and [0143]). Bovee differs from the claimed invention in that Bovee does not explicitly detail the exact, claimed arrangement of what makes up the first piece and the second piece, and does not specifically address the claimed requirement that “the first piece is formed separately relative to the second and the third piece, and the second piece is formed separately relative to the third piece”. Initially, it is noted that the language “formed separately” connotes a product-by-process limitation. See MPEP 2113: "[E]ven though product-by-process claims are limited by and defined by the process, determination of patentability is based on the product itself. The patentability of a product does not depend on its method of production. If the product in the product-by-process claim is the same as or obvious from a product of the prior art, the claim is unpatentable even though the prior product was made by a different process." In re Thorpe, 777 F.2d 695, 698, 227 USPQ 964, 966 (Fed. Cir. 1985).” Here, the final product in Bovee captures the elements combined by the claims (i.e., a first piece including a forward portion; a second piece including a rearward portion; and a third piece including a crown portion). In any event, Bovee hints at forming separate club head portions that are subsequently joined to provide a completed golf club head (i.e., see paragraphs [0002], [0097] and [0105]). Moreover, the teaching reference to Greensmith shows it to be old in the art to construct a hollow golf club head from multiple parts that are joined together to produce a completed golf club head (as opposed to the use of a single casting method). See paragraph [0208] – [0209] and [0220], [0226] and [0245] – [0246] in Greensmith. Separately fabricating club head parts enables the skilled artisan to more selectively control the material make-up of various parts and thus enabling the mechanical properties (e.g., modulus, density, weight) of distinct parts of the club head to be integrated for enhanced club head performance. In view of the teachings in Bovee and Greensmith and along with the above reasoning, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Bovee by providing that the club head is formed of a first piece, a second piece and a third piece, that are subsequently assembled to form a completed club head, with there being a reasonable expectation of success that separately forming club head parts would have provided the skilled artisan with an opportunity to customize the various club head sections in terms of density, strength, resilience, and overall mass distribution. Bovee also lacks an explicit disclosure of “the second piece is made of a first fiber-reinforced polymeric material comprising a first polymer matrix and short fibers embedded in the first polymer matrix; and the third piece is made of a second fiber-reinforced polymeric material comprising a second polymer matrix and continuous fibers embedded in the second polymer matrix”. Wester teaches that the selection of short fibers for the club head body and continuous fibers for the crown insert is based upon the selection of a matrix or resin and the particular manufacturing process (i.e., see paragraphs [0231] – [0233]), which assists in providing additional strength to the different pieces of the club head. In view of the teaching in Wester, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Bovee by using a polymeric material and short fibers for the second piece (i.e., at least a club head body portion) and by using a polymeric material and continuous fibers for the third piece (i.e., at least the crown insert portion), the motivation being to take advantage of the added strength imparted to the first and second pieces through the incorporation of the specific fiber selection and to facilitate any differences in the manufacturing processes associated with each of the different types of fiber selections. Bovee also lacks an explicit disclosure of “a total mass of the driver-type golf club head is between 185 grams (g) and 210 g”. Greensmith teaches that a driver-type club head is usually sized to provide a club head mass of between 145 grams and 260 grams (i.e., paragraph [0091]) when combined with a volume size of the club head and moves on to discuss that the weight of the club head may be adjusted to provide desirable adjustability of the location of the center of gravity and MOI properties (i.e., see paragraphs [0215] – [00216]. In view of the teachings in Greensmith, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Bovee to include a total mass between 185 grams and 210 grams in order to provide a total weight arrangement which, together with the claimed volume requirement, provides a club head having an optimal weight distribution so as to maximize the MOI and locate the center of gravity for enhanced club head performance. As to claim 2, Bovee shows the third piece overlaps the second piece along the bond joint. See FIGS. 5A and 5B, wherein the third piece (i.e., the crown insert 442) overlaps the second piece (i.e., at least a portion of the forward crown portion 450). As to claim 3, in Bovee, the second piece is interior of the third piece along the bond joint. Again, see FIGS. 5A and 5B, noting that the forward crown portion (450) is interior of the crown insert (442). As to claim 7, the second piece in Bovee comprises a recessed ledge; and the third piece is bonded to the recessed ledge of the second piece along the bond joint. See FIGS. 5A-9B depicting various arrangements of a recessed ledge to accommodate the crown insert. As to claim 8, the bond joint in Bovee extends along the heel portion, the toe portion, and a skirt portion between the crown portion and the sole portion. FIG. 4B shows that the bond joint (i.e., where the crown insert meets the top portion of the crown portion) extends along the toe, the heel and the skirt portions. As to claim 9, Bovee shows an opening in the rearward portion; and the driver-type golf club head further comprises a weight at least partially within the opening of the second piece (i.e., see FIG. 1B and paragraph [0069]). Claims 4-5 are rejected under 35 U.S.C. 103 as being unpatentable over US PUBS 2018/0154224 to Bovee et al (hereinafter referred to as “Bovee”) in view of US PUBS 2019/0046845 to Greensmith et al (hereinafter referred to as “Greensmith”) and also in view of USPN 9,908,014 to Wester et al (hereinafter referred to as “Wester”), and also in view of US PUBS 2016/0184662 to Barelmann. As to claims 4-5, Bovee, as modified by Greensmith and Wester, lacks an explicit description of “wherein the continuous fibers of the second fiber-reinforced polymeric material are longer than the short fibers of the first fiber-reinforced polymeric material” (claim 4) and lacks an explicit description of “wherein each one of the short fibers of the first fiber-reinforced polymeric material has a length between 0.5 millimeters (mm) and 2.0 mm” (claim 5). Here, Barelmann teaches that continuous and short fibers are both known in the manufacture of club head parts, with continuous long fibers available with a length of at least 10 millimeters, and with short fibers typically sized with a length of at least 0.5 mm to 2.0 mm (i.e., see paragraph [0312]). In view of the teaching in Barelmann, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Bovee by providing an appropriate combination of continuous and short fibers, and suitably sized in order to take advantage of fiber lengths commonly known in the golf club art for enhancing the strength of parts incorporating polymeric materials. Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over US PUBS 2018/0154224 to Bovee et al (hereinafter referred to as “Bovee”) in view of US PUBS 2019/0046845 to Greensmith et al (hereinafter referred to as “Greensmith”) and also in view of USPN 9,908,014 to Wester et al (hereinafter referred to as “Wester”), and also in view of US PUBS 2009/0131195 to Tavares. Bovee, as modified by Greensmith and Wester, lacks an explicit teaching of “wherein a density of the first fiber reinforced polymeric material of the second piece is more than a density of the second fiber-reinforced polymeric material of the third piece”. Tavares shows it to be old in the art to provide different portions of a club head with polymeric materials of different densities in order to provide a desirable weight distribution (i.e., see paragraphs [0025] – [0026] and claim 7 in Tavares). In view of the teaching in Tavares, it would have been obvious to one of ordinary skill in the art and before the effective filing date of the claimed invention to have modified the club head in Bovee by including polymeric materials of different densities for each of the first piece and the second piece identified hereinabove in order to provide a weight distribution that promotes a desirable center of gravity location for enhanced club head performance. For example, including a polymeric material of lesser density for the third piece (i.e., for the crown insert portion) as compared to the second piece (i.e., at least a portion of the club head body) would have served to lower the center of gravity of the club head. Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over US PUBS 2018/0154224 to Bovee et al (hereinafter referred to as “Bovee”) in view of US PUBS 2019/0046845 to Greensmith et al (hereinafter referred to as “Greensmith”) and also USPN 9,908,014 to Wester et al (hereinafter referred to as “Wester”) and also in view of US PUBS 2010/0203983 to Stites. As to claim 20, Bovee, as modified by Greensmith and Wester, does not explicitly teach “wherein: the driver-type golf club head is made from at least one first material, having a density between 0.9 g/cc and 3.5 g/cc, at least one second material, having a density between 3.6 g/cc and 5.5 g/cc, and at least one third material, having a density between 5.6 g/cc and 20.0 g/cc; the at least one first material has a first mass no more than 55% of the total mass of the driver-type golf club head and no less than 25% of the total mass of the driver-type golf club head; the at least one second material has a second mass no more than 65% of the total mass of the driver-type golf club head and no less than 20% of the total mass of the driver-type golf club head; and the at least one third material has a third mass equal to the total mass of the driver-type golf club head less the first mass of the at least one first material and the second mass of the at least one second material”. Selecting different materials for different portions of the club head body in order to efficiently customize a club head (i.e., providing a desired weight distribution, locating a center of gravity in a desired location, and/or manipulating the moment of inertia of the club head) has already been disclosed as being known in the art, as further taught by Stites. Specifically, see paragraphs [0042], [0043], [0057], [0059], and [0060] in Stites, which provide added guidance for the skilled artisan in selecting different materials for the different portions of the club head body, with Stites noting in paragraph [0043] that "[T]he different materials in the respective sections may affect the overall properties of the golf club head body (e.g., weight distribution) and, therefore, may be used to manipulate the location of the center of gravity of the club head body (e.g., shift the center of gravity in a particular direction). Additionally, the different materials may be used to manipulate the moment of inertia of the club head body (e.g., move the weight of the golf club head body to a particular position to increase the moment of inertia). Thereby, the club may be optimized for a particular purpose". Moreover, the selection of a known material on the basis of its suitability for its intended use has been determined to be within the level of one of ordinary skill in the art. See also In re Leshin, 277 F.2d 197, 125 USPQ 416 (CCPA 1960) (selection of a known plastic to make a container of a type made of plastics prior to the invention was held to be obvious); Ryco, Inc. V. Ag-Bag Corp., 857 F.2d 1418, 8 USPQ2d 1323 (Fed. Cir. 1988) (Claimed agricultural bagging machine, which differed from a prior art machine only in that the brake means were hydraulically operated rather than mechanically operated, was held to be obvious over the prior art machine in view of references which disclosed hydraulic brakes for performing the same function, albeit in a different environment.). With consideration of the combination of the further teachings in Stites, and the above reasoning, one of ordinary skill in the art and before the effective filing date of the claimed invention would have found it obvious to have selected a material of lesser or greater density for the various portions of the club head in Bovee (i.e., for the face or front portion, the rear portion and/or the crown insert portion), with there being a reasonable expectation of success that selection of a known material having a known density, and construction of the various parts of the club head with materials of different densities, would have enabled the skilled artisan to customize the weight distribution of the club head and enhance the performance characteristics of the club head Further References of Interest The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. FIGS. 1 and 2 in Rice show a separate cup-shaped front portion along with a central club head body portion joined along a common seam. Igarashi describes a seam along with forward and rearward portions of a club head are connected. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SEBASTIANO PASSANITI whose telephone number is (571)272-4413. The examiner can normally be reached 9:00AM-5:00PM Mon-Fri. 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, Nicholas Weiss can be reached at (571)-270-1775. 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. SEBASTIANO PASSANITI Primary Examiner Art Unit 3711 /SEBASTIANO PASSANITI/Primary Examiner, Art Unit 3711
Read full office action

Prosecution Timeline

Jul 30, 2024
Application Filed
Jul 29, 2026
Non-Final Rejection mailed — §101, §103, §112 (current)

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Patent 12691368
Tabletop shooting game
3y 4m to grant Granted Jul 28, 2026
Patent 12691341
GOLF CLUB HEADS AND METHODS TO MANUFACTURE GOLF CLUB HEADS
1y 0m to grant Granted Jul 28, 2026
Patent 12685909
MULTI-COMPONENT GOLF CLUB HEAD
3y 10m to grant Granted Jul 21, 2026
Patent 12678680
GOLF TRAINING AID AND METHOD
3y 9m to grant Granted Jul 14, 2026
Patent 12678675
GOLF CLUB ALIGNMENT DEVICE
3y 4m to grant Granted Jul 14, 2026
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 (+15.6%)
1y 9m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 1725 resolved cases by this examiner. Grant probability derived from career allowance rate.

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