Prosecution Insights
Last updated: April 19, 2026
Application No. 18/827,063

ELECTRONIC DEVICE

Non-Final OA §103
Filed
Sep 06, 2024
Examiner
IMMANUEL, BAMIDELE ADEFOLARIN
Art Unit
2845
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Apple Inc.
OA Round
1 (Non-Final)
66%
Grant Probability
Favorable
1-2
OA Rounds
3y 3m
To Grant
84%
With Interview

Examiner Intelligence

Grants 66% — above average
66%
Career Allow Rate
245 granted / 373 resolved
-2.3% vs TC avg
Strong +18% interview lift
Without
With
+18.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
32 currently pending
Career history
405
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
62.2%
+22.2% vs TC avg
§102
22.5%
-17.5% vs TC avg
§112
13.0%
-27.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 373 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 . Information Disclosure Statement The information disclosure statement (IDS) submitted on 12/02/2025 was filed in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being 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 text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. 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. Claims 1-7, 9-11, and 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Trotta et al. (US 20180026377) in view of Rothkopf et al. (US 20220413446). Regarding claim 1: Trotta et al disclose in Figs. 6A and 6B) a wearable electronic device (600), comprising: a sidewall housing (601) defining: an internal volume (accommodating 609, 607 and 611); and a securement band (603), the sidewall housing (601s) including a radio-frequency (RF)-transparent window (defined by the 601s); rear cover (601b) coupled to the sidewall housing (601s), the rear cover (601b) comprising metal (Para. 0054, Lines 10-14); an antenna resonator (607) disposed in the internal volume (accommodating 609, 607 and 611) adjacent the RF-transparent window (601s). Trotta et al. are silent on a band slot configured to receive the securement band, the RF transparent window defining the band slot and a conductor electrically coupling the rear cover to the antenna resonator. Rothkopf et al. disclose (in Fig. 5) a band slot (504) configured to receive a securement band (551-555) and (in Fig. 21B) a conductor (2150) electrically coupling a rear cover (the bottom portion of 601) to an antenna resonator (2134). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to apply the teachings of Rothkopt and make Trotta’s wearable electronic device with a band slot configured to receive the securement band and a conductor electrically coupling the rear cover to the antenna resonator for the benefit improving inductive power transfer efficiency for particular operational conditions (Para. 0210, Lines 11-12). The modified Trotta does not specifically disclose the RF transparent window defining the band slot. However, Trotta teaches in Par. [0055] “ In other embodiments, the entire sidewall 601s of the housing 601 may be formed of a material transparent for the mm-wave RF signals”. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to apply the teachings of Trotta and make the modified Trotta’s wearable electronic device with the RF transparent window defining the band slot, in order to allow RF signals transmitted or received by the antenna resonator pass though the sidewall housing (see par. [0053]). Regarding claim 2: Trotta et al. do not explicitly disclose the rear cover defines an external surface and an internal surface; and the conductor electrically couples the internal surface to the antenna resonator. Rothkopf et al. disclose the rear cover (the bottom portion of 601) defines an external surface and an internal surface (See Fig. 21B); and the conductor (2150) electrically couples the internal surface to the antenna resonator (2134). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the rear cover defines an external surface and an internal surface; and the conductor electrically couples the internal surface to the antenna resonator as taught by Rothkopf et al. into the device of Trotta et al. for the benefit improving inductive power transfer efficiency for particular operational conditions (Para. 0210, Lines 11-12). Regarding claim 3: Trotta et al. do not explicitly disclose the wearable electronic device further comprises an antenna feed point electrically coupled to the internal surface; and the conductor is coupled to the antenna feed point. Rothkopf et al. disclose the wearable electronic device (in Figs. 21A and 21B) further comprises an antenna feed point (2142) electrically coupled to the internal surface (along the bottom surface of 601); and the conductor (2150) is coupled to the antenna feed point (2142). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the wearable electronic device further comprises an antenna feed point electrically coupled to the internal surface; and the conductor is coupled to the antenna feed point as taught by Rothkopf et al. into the device of Trotta et al. for the benefit improving inductive power transfer efficiency for particular operational conditions (Para. 0210, Lines 11-12). Regarding claim 4: Trotta et al. disclose the sidewall housing (601) comprises a conductive material (Para. 0054, Lines 10-14). Regarding claim 5: Trotta et al. disclose a non-conductive split (defined by 601s) electrically isolating the rear cover (601b) from the sidewall housing (601t). Regarding claim 6: Trotta et al. disclose the non-conductive split (defined as the split, 601s) comprises an RF transparent material (Para. 0050, Lines 14-16) and defines an external surface of the wearable electronic device (600). Trotta does not specifically disclose the non-conductive split comprises plastic. However, it is well known in the art to use a durable dielectric material such as plastic for RF windows. Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the non-conductive split as a plastic due to its suitability as RF transparent material. Furthermore, the selection of a known material based on its suitability for its intended use supported a prima facie obviousness determination in Sinclair & Carroll Co. v.Interchemical Corp., 325 U.S. 327, 65 USPQ 297 (1945). Regarding claim 7: Trotta et al. disclose the RF-transparent window (defined by 601s) extends through a thickness of the sidewall housing (601). Regarding claim 9: Trotta et al. disclose the antenna resonator (607) is coupled to the RF-transparent window (defined by 601s). Regarding claim 10: Trotta et al. do not explicitly disclose the conductor comprises a flat electrical cable. Rothkopf et al. disclose the conductor (2150) comprises a flat electrical cable (See Fig. 21A). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the conductor comprises a flat electrical cable as taught by Rothkopf et al. into the device of Trotta et al. for the benefit of achieve a device with a small form factor (Para. 0071, Lines 4-9). Regarding claim 11: Trotta as modified are silent on that the flat electrical cable includes a thickness less than about 75 microns. However, it is well known in the art the thickness of an electrical cable is selected based on the required characteristics of the electronic device and its components. Therefore, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to implement a thickness less than about 75 microns to provide impedance matching especially since the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 17: Trotta et al. disclose an antenna assembly (in Figs. 6A and 6B), comprising: a rear cover (601b) of an electronic device (600); a sidewall housing (601t) of the electronic device (600); a non-conductive housing portion (601s) disposed between the rear cover (601b) and the sidewall housing (601t); an antenna resonator (607) coupled to the sidewall housing (601t) within the electronic device (600). Trotta et al. do not explicitly disclose an electrical connector electrically coupling the rear cover to the antenna resonator. Rothkopf et al. disclose (in Fig. 21B) an electrical connector (2150) coupling the conductive cover (the bottom portion of 601) to the antenna resonator (2134). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement an electrical conductor coupling the conductive cover to the antenna resonator as taught by Rothkopf et al. into the device of Trotta et al. for the benefit improving inductive power transfer efficiency for particular operational conditions (Para. 0210, Lines 11-12). Regarding claim 18: Trotta et al. disclose the rear cover (601b) comprises metal; the sidewall housing (601s and 601t) comprises a conductive material (601t) and defines an RF-transparent window (defined by 601s) extending through a thickness of the sidewall housing (601); and the antenna resonator (607) is coupled to the RF-transparent window (defined by 601s). Regarding claim 19: Trotta et al. do not explicitly disclose the antenna assembly further comprises an antenna interposer coupled to the rear cover within the electronic device; and the electrical connector comprises a flat electrical cable coupled to the antenna interposer. Rothkopf et al. disclose the antenna assembly (2130) further comprises an antenna interposer (2140) coupled to the rear cover (along the bottom surface of 601) within the electronic device (2100); and the electrical connector (2150) comprises a flat electrical cable coupled to the antenna interposer (2150). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the antenna assembly further comprises an antenna interposer coupled to the rear cover within the electronic device; and the electrical connector comprises a flat electrical cable coupled to the antenna interposer as taught by Rothkopf et al. into the device of Trotta et al. for the benefit improving inductive power transfer efficiency for particular operational conditions (Para. 0210, Lines 11-12). Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Trotta et al. (US 20180026377) in view of Rothkopf et al. (US 20220413446) as applied to claim 17 and further in view of Merz et al. (US 20120176754). Regarding claim 20: Trotta as modified do not explicitly disclose the antenna interposer comprises a stamped stainless-steel interposer at least partially gold-plated and welded to the rear cover. Merz et al. disclose the antenna interposer (166) comprises a stamped stainless-steel interposer at least partially gold-plated and welded (via 164) to the rear cover (12-1; Para. 0047, Lines 6-8; Para. 0055, Lines 19-21). Accordingly, it would have been an obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the antenna interposer comprises a stamped stainless-steel interposer at least partially gold-plated and welded to the rear cover as taught by Merz et al. into the modified device of Trotta for the benefit of increasing the antenna bandwidth considering the conductive materials of the antenna interposer welded of the rear cover amounting to increasing or expanding the ground plane's physical size. Claims 12, and 14-15 are rejected under 35 U.S.C. 103 as being unpatentable over Crowley et al. (US 20210392422) in view of Rothkopf et al. (US 20220413446). Regarding claim 12: Crowley et al. disclose (in Figs. 1A-1D) an electronic device (200/300), comprising: a conductive sidewall housing (202/302) defining an internal volume (Para. 0007, Lines 1-4); a conductive cover (230/330, see Par. [0066]) coupled to the sidewall housing (202/302) and defining the internal volume (Para. 0007, Lines 1-4; Para. 0066, Lines 13-15); an antenna resonator (354) disposed in the internal volume and coupled to the conductive sidewall housing (302); a non-conductive split (334) electrically isolating the conductive sidewall housing (302) from the conductive cover (330). Crowley et al. do not explicitly disclose an electrical conductor coupling the conductive cover to the antenna resonator. Rothkopf et al. disclose (in Fig. 21B) an electrical conductor (2150) coupling the conductive cover (the bottom portion of 601) to the antenna resonator (2134). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement an electrical conductor coupling the conductive cover to the antenna resonator as taught by Rothkopf et al. into the device of Crowley et al. for the benefit improving inductive power transfer efficiency for particular operational conditions (Para. 0210, Lines 11-12). Regarding claim 14: Crowley et al. disclose the conductive sidewall housing (302), the conductive cover (330), and the non-conductive split (334) define an external surface of the electronic device (300). Regarding claim 15: Crowley et al. disclose a display assembly (312) coupled to the conductive sidewall housing (302) opposite the conductive cover (330 ). Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over Crowley et al. (US 20210392422) in view of Rothkopf et al. (US 20220413446) as applied to claim 1, and further in view of Bloom et al. (US 20220085843). Regarding claim 8: Crowley as modified do not explicitly disclose the RF-transparent window comprises epoxy. Bloom et al. disclose (in Fig. 11) the RF-transparent window (1111) comprises epoxy (Para. 0042, Lines 5-8; Para. 0128, Lines 3-6). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the RF-transparent window extends through a thickness of the sidewall housing comprising epoxy and the antenna resonator is coupled to the RF-transparent window as taught by Bloom et al. into the modified device of Crowley for the benefit of allowing sufficient transmission of radio waves that the component is considered to be transparent to radio frequencies (Para. 0039, Lines 3-5). Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Crowley et al. (US 20210392422) in view of Rothkopf et al. (US 20220413446) as applied to claim 1, and further in view of Trotta et al. (US 20180026377). Regarding claim 13: Crowley as modified do not explicitly disclose the conductive sidewall housing includes an RF-transparent window extending through a thickness of the conductive sidewall housing; and the antenna resonator is coupled to the RF-transparent window. Trotta et al. disclose the conductive sidewall housing (601) includes an RF-transparent window (defined by 601s) extending through a thickness of the conductive sidewall housing (601); and the antenna resonator (607) is coupled to the RF-transparent window (defined by 601s). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to implement the conductive sidewall housing includes an RF-transparent window extending through a thickness of the conductive sidewall housing; and the antenna resonator is coupled to the RF-transparent window as taught by Trotta et al. into the modified device of Crowley for the benefit of allowing sufficient transmission of radio waves to external devices (Para. 0053, Lines 11-15). Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Crowley et al. (US 20210392422) in view of Rothkopf et al. (US 20220413446) as applied to claim 12, and further in view of Bloom et al. (US 20220085843). Regarding claim 16: Crowley as modified disclose the non-conductive split (334) comprises plastic (Para. 0070, Lines 11-12). Crowley as modified do not explicitly disclose the RF-transparent window comprises epoxy. Bloom et al. disclose using a thermoset composite material as in an RF-transparent window (1111; Para. 0128, Lines 3-6). Accordingly, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention and an obvious matter of design consideration to apply the teachings of Bloom and implement the RF-transparent window in Crowley comprising epoxy due to its properties in high mechanical strength and transparency. Furthermore, it has been held to be within the general skill of a worker in the art to select a known material on the basis of its suitability for the intended use as a matter of obvious design choice. In re Leshin, 227 F.2d 197, 125 USPQ 416 (CCPA 1960). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to BAMIDELE A. IMMANUEL whose telephone number is (571)272-9988. The examiner can normally be reached General IFP Schedule: Mon.-Fri. 8AM - 7PM (Hoteling). 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, Dimary Lopez can be reached at 5712707893. 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. /BAMIDELE A IMMANUEL/Examiner, Art Unit 2845 /DIMARY S LOPEZ CRUZ/Supervisory Patent Examiner, Art Unit 2845
Read full office action

Prosecution Timeline

Sep 06, 2024
Application Filed
Oct 24, 2024
Response after Non-Final Action
Feb 25, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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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
66%
Grant Probability
84%
With Interview (+18.5%)
3y 3m
Median Time to Grant
Low
PTA Risk
Based on 373 resolved cases by this examiner. Grant probability derived from career allow rate.

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