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 .
Election/Restrictions
Applicant’s election without traverse of group I (claims 1-17) in the reply filed on February 12, 2026 is acknowledged. Claims 18-20 are withdrawn from consideration.
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.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Currently, no claim limitation is being interpreted as invoking 35 U.S.C. 112(f).
Claim Rejections - 35 USC § 102
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 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, 4-5, 7-13 and 15-17 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by EP3636969 to Clausen (Clausen). This document was cited on an IDS and a copy thereof filed with the application. Therefore, a copy has not been included with this Office Action.
Regarding claim 1, Clausen discloses a control valve (1) for a closed-loop fluid system ([0002]), comprising: a valve body (2) to connect with a fluid hose of the closed-loop fluid system ([0052]); an internal valve component (7) movable from a first position (the closed position) to a second position (the position opened by tool 40; see [0049]), wherein the internal valve component functions as a one-way valve when in the first position ([0021] and [0045]; the valve serves as a check valve in the closed position), and allows fluid to flow through the fluid hose into or through the valve body when in the second position ([0049]); and one or more O-rings (16 and 25) fitted to the internal valve component to provide a fluid seal when in one or both of the first position and the second position (Figs. 2-5).
Regarding claim 4, Clausen discloses the control valve is positioned downstream of a fluid reservoir (the reservoir of the radiator; the valve is positioned between a supply line and return line of the system and is downstream of the reservoir) of the closed-loop fluid system.
Regarding claim 5, Clausen discloses the control valve directs fluid flow in a single direction into the fluid hose of the closed-loop fluid system when in the first position (flow is limited to one direction when the valve is in the check valve position).
Regarding claim 7, Clausen discloses the valve body and internal valve component comprise a sleeve and insert arrangement, wherein the internal valve component is configured to slip into the valve body (Fig. 2; valve body 2 forms a sleeve and valve element 7 forms an insert which slides into the body).
Regarding claim 8, Clausen discloses the internal valve component comprises one or more passthroughs (36) that become aligned with one or more corresponding passages within the valve body when the internal valve component is in one or more of the first position and the second position ([0048]).
Regarding claim 9, Clausen discloses the internal valve component comprises a barrier (33) that obstructs a passage of the valve body when the internal valve component is in the first position ([0048]).
Regarding claim 10, Clausen discloses the internal valve component comprises a plurality of channels that include a venting channel (venting; see [0021]) to allow air to escape the closed-loop fluid system via the control valve, a filling channel (channel for fluid from the supply line; see [0052]) to enable entry of fluid into the closed-loop fluid system via the control valve, and a draining channel (channel for draining, see [0049]) to enable fluid to exit the closed-loop fluid system via the control valve.
Regarding claim 11, Clausen discloses a flow of fluid through one or more of the plurality of channels is based on a position of the internal valve component within the valve body (the position of the valve element determines which path fluid can take through the valve body).
Regarding claim 12, Clausen discloses each channel from among the plurality of channels corresponds with one or more passthroughs of the internal valve component (the channels correspond to at least one of passthroughs 10, 13, 14, and 36).
Regarding claim 13, Clausen discloses the internal valve component comprises a set of interface fittings that correspond with each channel from among the plurality of channels, and wherein the set of interface fittings protrude from the valve body to enable connection (see Fig. 2 and [0036]-[0040] which describe a number of interface fittings [snap connections] which protrude from the valve body).
Regarding claim 15, Clausen discloses the closed-loop fluid system comprises a cooling system (radiator) to circulate coolant through one or more components.
Regarding claim 16, Clausen discloses the one or more O-rings seated upon the internal valve component include at least a first O-ring (16) and a second O-ring (25) positioned to create a seal around a passthrough (13) of the internal valve component and a corresponding passage (10) of the valve body.
Regarding claim 17, Clausen discloses the valve body further comprises a flange to engage with a fluid filling system (see Fig. 1, the ends at 3 and 4 can be considered flanges and they connect to the fluid filling system).
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over Clausen.
Regarding claim 14, Clausen discloses the control valve for the closed-loop fluid system of claim 1 (see above), but does not specify the valve body of the control valve is integrated into a fluid reservoir of the closed-loop fluid system. However, there are only two options (either the valve body is integrated into the reservoir or the valve body is separate from the reservoir). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to integrate the valve body into the reservoir of the radiator, since such a change requires only selecting one of a small number of identified, predictable solutions with a reasonable expectation of success. Further, integrating the valve body into the reservoir of the radiator helps to protect the valve from possible damage or outside contamination.
Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Clausen in view of US Patent Application Publication 2013/0139911 to Wilson et al. (Wilson).
Regarding claim 6, Clausen discloses the control valve for the closed-loop fluid system of claim 1 (see above), and further discloses the valve body comprises a generally cylindrical shape (Fig. 1-2), but does not disclose a pair of opposing barbs extending radially from the valve body to interface with the fluid hose of the closed-loop fluid system. Clausen does disclose opposing connections to interface with the supply and return of the radiator (inlet 3 and outlet 4, respectively). Wilson teaches a vent system which includes a hose barb (122) to interface with a hose. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have included hose barbs at inlet 3 and outlet 4 of Clausen as taught by Wilson such that hoses of the fluid system can be quickly and easily attached to the valve.
Allowable Subject Matter
Claims 2-3 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims.
The following is a statement of reasons for the indication of allowable subject matter: the cited documents do not disclose “set of snap features integrated upon a surface of the valve body and the internal valve component to secure the internal valve component in the first position for fluid fill and in the second position for fluid circulation through the closed-loop fluid system.” While the use of snap fittings in known in the art and disclosed by Clausen, the snap fittings serve to connect the valve components rather than to secure the internal valve component in the first position for fluid fill and in the second position for fluid circulation through the close-loop fluid system. Clausen teaches away from such an arrangement by having “all intermediate positions” of the valve being available. Therefore, the examiner finds no evidence that one of ordinary skill in the art would modify the cited document to include the claimed set of snap features. Claim 3 depends from claim 2 and is allowable for the same reasons.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure and claimed invention.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to NICOLAS A ARNETT whose telephone number is (571)270-5062. The examiner can normally be reached M- F, 8AM - 3PM.
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/NICOLAS A ARNETT/Primary Examiner, Art Unit 3753 May 7, 2026
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