Prosecution Insights
Last updated: April 19, 2026
Application No. 18/835,979

CONTROLLER-MANAGED CHARGING CURRENT WITHIN THERMAL BUDGET

Non-Final OA §102§103§112
Filed
Aug 05, 2024
Examiner
JUNG, ANDREW J
Art Unit
2175
Tech Center
2100 — Computer Architecture & Software
Assignee
Google LLC
OA Round
1 (Non-Final)
58%
Grant Probability
Moderate
1-2
OA Rounds
3y 1m
To Grant
95%
With Interview

Examiner Intelligence

Grants 58% of resolved cases
58%
Career Allow Rate
80 granted / 139 resolved
+2.6% vs TC avg
Strong +37% interview lift
Without
With
+37.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
9 currently pending
Career history
148
Total Applications
across all art units

Statute-Specific Performance

§101
6.2%
-33.8% vs TC avg
§103
53.4%
+13.4% vs TC avg
§102
11.4%
-28.6% vs TC avg
§112
22.0%
-18.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 139 resolved cases

Office Action

§102 §103 §112
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 The instant application claims priority to PCT/US2023/078643 filed on November 3, 2023. Information Disclosure Statement The information disclosure statements (IDS) submitted on August 5, 2024 and April 25, 2025 are in compliance with the provisions of 37 CFR 1.97 and have been considered by the examiner. 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. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 5 and 14 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 pre-AIA the applicant regards as the invention. Regarding claim 5, the claim recites the limitation “… causing the battery to cease charging for a period of time, generating, by the handheld computing device, a graphical user interface, wherein the graphical user interface indicates that the handheld computing device is still charging.” It is unclear why the GUI would incorrectly indicate that the device is still charging when the device has ceased to charge (for a period of time), and Applicant’s specification does not provide any additional description of such feature. It is unclear to the Examiner whether the claim includes a typo. Therefore, for purposes of examination, the Examiner construes the limitation to mean “… causing the battery to cease charging for a period of time, generating, by the handheld computing device, a graphical user interface, wherein the graphical user interface indicates that the handheld computing device is Regarding claim 14, the claim recites similar limitation as corresponding claim 5 and is rejected for similar reasons as claim 5 using similar rationale. Appropriate correction is required. Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1-4, 6-7, 9-13, 15-17, and 19-20 are rejected under 35 U.S.C. 102(a)(1) and (a)(2) as being anticipated by SPORCK (Pub No.: US 20150229155 A1), hereafter SPORCK. Regarding claim 1, SPORCK teaches: A method comprising: obtaining, by a controller of a handheld computing device, a present temperature of an outer surface of the computing device while a battery of the handheld computing device is being charged (SPORCK [0016] teaches controlling a skin temperature of an electronic device, such as a handheld mobile device, so that the temperature of the casing does not exceed a threshold, where [0018] teaches thermal sensor circuits (“Temp Sensors”) 150 configured to sense temperature of the case to control the skin temperature, where thermal sensor 150 is coupled to battery charger circuit 110 to control current in the battery charger); determining, by the controller and based on the present temperature of the outer surface of the handheld computing device and a target temperature of the outer surface of the handheld computing device, a charging current for the battery and system of the handheld computing device; and causing, by the controller, the battery to charge with the determined charging current (SPORCK [0018] also teaches sensing skin temperature using a thermal sensor 150 and couple signals, such as a voltage, to battery charger 110 to set a current limit, which controls a maximum current in the battery charger, where reducing a current limit may reduce a maximum current flowing to battery 150 or to PMIC 111 and downstream components, for example, and reduce power dissipation in battery charger 150 to reduce the skin temperature; see also [0019-0021] & Fig. 2-3). Regarding claim 11, the claim recites similar limitation as corresponding claim 1 and is rejected for similar reasons as claim 1 using similar teachings and rationale. SPORCK also teaches: A handheld computing device, comprising a battery (SPORCK Fig. 1 battery 102); a display (SPORCK Fig. 1 display 103); and one or more processors configured (SPORCK Fig. 1 processor 112; [0017] also teaches electronic device 100 including data processors). Regarding claim 15, the claim recites similar limitation as corresponding claim 1 and is rejected for similar reasons as claim 1 using similar teachings and rationale. SPORCK also teaches A non-transitory computer-readable medium, encoded with instructions that, when executed, cause one or more processors of a handheld computing device (SPORCK [0017] teaches electronic device 100 including at least one processor, which executes instructions stored on memory). Regarding claim 2, SPORCK teaches the elements of claim 1 as outlined above. SPORCK also teaches wherein the controller of the computing device is a proportional-integral-derivative controller, wherein the proportional- integral-derivative controller determines a clamp for one of a maximum charging current or minimum charging current for the battery and system of the handheld computing device (SPORCK claim 3 teaches the battery charger circuit comprises a comparator, which reduces the maximum current in the battery charging circuit; claim 8 teaches the battery charger circuit comprises an analog-to-digital converter reduces the maximum current in the battery charger circuit when the digital representation of the first voltage meets the digital representation of the threshold). Regarding claim 3, SPORCK teaches the elements of claim 1 as outlined above. SPORCK also teaches wherein causing the battery to charge further comprises causing the battery to charge via a power transmitter (SPORCK [0019] teaches battery charger may receive power from an external power source to charge the battery, and [0028-0030] & Fig. 8 teach battery charger provides power, where USB cable includes power supply voltage). Regarding claim 4, SPORCK teaches the elements of claim 1 as outlined above. SPORCK also teaches: obtaining, by the controller, a plurality of temperatures over a period of time of the outer surface of the handheld computing device while the battery of the handheld computing device is being charged; determining, by the controller and based on the plurality of temperatures of the outer surface, that the temperature of the outer surface of the handheld computing device has reached a predetermined thermal threshold while the battery is charging with at least a minimum charging current (SPORCK [0025] teaches the system attempts to maintain a constant case (or skin) temperature by adjusting the current limit down and up based on a sensed temperature of the case. For example, as illustrated in plots 501 and 502, initially a current limit may be set high and the case temperature begins to increase over time period t1. When the temperature of the case increases above Tc (a center temperature within a window defined by a maximum temperature Tmax and minimum temperature, Tmin) the current limit is reduced. In this example, the temperature continues to increase at the new current limit value during t2. Accordingly, the current limit is reduced again. The temperature begins to decrease during t3 until the temperature drops below Tmin. In one embodiment, after a first reduction, an additional reduction happens after a timer expiration (e.g., 2 seconds). After the temperature drops below Tmin, the current limit may be increased, which causes the temperature to increase again. In this manner, the algorithm may ensure the temperature does not increase above Tmax); determining, by the controller, whether the handheld computing device is connected to a power source or is within a predetermined proximity with a power transmitter; and based on determining that the handheld computing device is connected to the power source or is within the predetermined proximity with a power transmitter, causing, by the controller, the battery to cease charging for a period of time (SPORCK [0023] teaches an example circuit for adjusting a current limit in a battery charger, where a thermistor 451 in a thermal sensor 450 and resistor 452 are coupled to an input of an analog-to-digital converter (ADC) 411 on a battery charger IC 410 (i.e. the input voltage of the power source is known, which is seen as determining whether the power source is connected). Another input of ADC 411 is coupled to a reference voltage. ADC 411 receives a voltage from thermal sensor 450 and converts the voltage into a digital representation of the voltage (e.g., digital bits). An output of ADC 411 may be coupled to a digital comparator 412. Digital comparator 412 receives the digital representation of the thermal sensor voltage from ADC 411 and a digital representation of a threshold, where when the thermal sensor voltage meets a particular threshold, the digitized voltage increases above the digital threshold and digital comparator 412 produces an output signal to input current control circuit 430 to change an input current limit. Accordingly, when a temperature on the case increases to a threshold, a maximum input current in the battery charger is reduced to reduce the temperature of the case; see [0025] as taught above, where current limit reduction continues to increase (which would at one point fully limit the current for charging) if the case temperature does not decrease below a threshold, where the current limit happens after a timer expiration). Regarding claim 6, SPORCK teaches the elements of claim 1 as outlined above. SPORCK also teaches: clamping, by the controller, the determined charging current at a minimum/maximum charge current (SPORCK [0018] teaches reducing a maximum current flowing to battery 150 or to PMIC 111 and downstream components; [0031] also teaches setting a maximum for the sensed current). Regarding claim 7, SPORCK teaches the elements of claim 6 as outlined above. SPORCK also teaches causing, by the controller, the battery to charge at a variable charging current, wherein the variable charging current is based on a monotonic relationship between the variable charging current and the present temperature of the outer surface of the handheld computing device (see SPORCK [0023] & [0025] as taught above in claim 4). Regarding claim 9, SPORCK teaches the elements of claim 1 as outlined above. SPORCK also teaches wherein the present temperature is a composite of a plurality of temperatures from one or more temperature sensors (SPORCK [0027] teaches thermal sensors 650A-C are arranged between an interior surface of case 630 and an upper surface of heat spreaders 620 to sense the temperature of the case; [0028] teaches multiple thermal sensors 750-754 may be arranged to sense the temperature of a case 701 at different locations (e.g., proximate to different heat producing ICs) and monitored to reduce system power, and the battery charger may monitor the voltage from the thermal sensor for an extended time period, but periodically iterate through the other thermal sensors to make sure one of the others has not also increased above the threshold). Regarding claim 10, SPORCK teaches the elements of claim 1 as outlined above. SPORCK also teaches: obtaining, by the controller, a plurality of temperatures of the outer surface of the handheld computing device while the battery of the handheld computing device is being charged (see SPORCK [0023] & [0025] as taught above in claim 4; see also [0027-0028] as taught above in claim 9), wherein determining the charging current comprises determining a minimum or maximum charging current based on the plurality of temperatures; and causing the battery to charge with a charging current at least that of the minimum charging current and at most that of the maximum charging current (see SPORCK [0023] & [0025] as taught above in claim 4). Regarding claim 12, the claim recites similar limitation as corresponding claim 2 and is rejected for similar reasons as claim 2 using similar teachings and rationale. Regarding claim 13, the claim recites similar limitation as corresponding claim 4 and is rejected for similar reasons as claim 4 using similar teachings and rationale. Regarding claim 16, the claim recites similar limitation as corresponding claim 6 and is rejected for similar reasons as claim 6 using similar teachings and rationale. Regarding claim 17, the claim recites similar limitation as corresponding claim 7 and is rejected for similar reasons as claim 7 using similar teachings and rationale. Regarding claim 19, the claim recites similar limitation as corresponding claim 9 and is rejected for similar reasons as claim 9 using similar teachings and rationale. Regarding claim 20, the claim recites similar limitation as corresponding claim 10 and is rejected for similar reasons as claim 10 using similar teachings and rationale. 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. Claims 5 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over SPORCK (Pub. No.: US A1) in view of MITTAL (Pub. No.: US 20250124336 A1), hereafter MITTAL. Regarding claim 5, SPORCK teaches the elements of claim 4 as outlined above. SPORCK does not appear to explicitly teach: based on causing the battery to cease charging for a period of time, generating, by the handheld computing device, a graphical user interface, wherein the graphical user interface indicates that the handheld computing device is not charging; and outputting, for display and by a display of the handheld computing device, the graphical user interface. However, the combination of SPORCK and MITTAL teaches based on causing the battery to cease charging for a period of time, generating, by the handheld computing device, a graphical user interface, wherein the graphical user interface indicates that the handheld computing device is not charging; and outputting, for display and by a display of the handheld computing device, the graphical user interface (in light of 112(b) rejection of claim 5 above, MITTAL [0080] teaches notifying via GUI a battery management decision (e.g. stopping battery charging) for mitigating issues associated with the battery system failure). Accordingly, it would have been obvious to a person having ordinary skill in the art at the time of the effective filing of the invention, having the teachings of SPORCK and MITTAL before them, to include MITTAL’s GUI notification in SPORCK’s skin temperature controlling system. One would have been motivated to make such a combination in order to mitigate issues associated with the battery system failure as taught by MITTAL ([0080]), which would result in notifying users of temperature exceeding a threshold in SPORCK’s system. Regarding claim 14, the claim recites similar limitation as corresponding claim 5 and is rejected for similar reasons as claim 5 using similar teachings and rationale. Claims 8 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over SPORCK in view of SANTOS (Pub. No.: US 20080103634 A1), hereafter SANTOS. Regarding claim 8, SPORCK teaches the elements of claim 1 as outlined above. SPORCK teaches: […] a plurality of temperatures of the outer surface of the computing device (SPORCK [0028] teaches multiple thermal sensors 750-754 may be arranged to sense the temperature of a case 701 at different locations (e.g., proximate to different heat producing ICs) and monitored to reduce system power, where battery charger 710 may iteratively sense a voltage from each thermal sensor by changing the select input of MUX 760). SPORCK does not appear to explicitly teach wherein the present temperature is an average of a plurality of temperatures of the outer surface of the computing device. However, SANTOS teaches the limitation (SANTOS [0034] teaches an average temperature from thermal sensors coupled to the memory device's case or outer packaging is collected). Accordingly, it would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention, having the teachings of SPORCK and SANTOS before them, to include SANTOS’s collecting the average temperature of the thermal sensors in SPORCK’s skin temperature controlling system. One would have been motivated to make such a combination to provide a more consistent temperature reading of the entire system. Regarding claim 18, the claim recites similar limitation as corresponding claim 8 and is rejected for similar reasons as claim 8 using similar teachings and rationale. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: YANG (US 20210313820 A1) – “Charging method and device, device to be charged, storage medium, and chip system” relates to reducing a charging current by ΔI if the temperature of the device to be charged is greater than a first threshold value. FRIED (EP 3991788 A1) – “Estimating the temperature of a housing of a device” relates to estimating the temperature of an external portion of a medical device. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANDREW J JUNG whose telephone number is 571-270-3779. The examiner can normally be reached on Monday through Friday from 9am to 5pm. 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, David Wiley can be reached on 571-272-4150. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /ANDREW J JUNG/Supervisory Patent Examiner, Art Unit 2175
Read full office action

Prosecution Timeline

Aug 05, 2024
Application Filed
Jan 12, 2026
Non-Final Rejection — §102, §103, §112 (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
58%
Grant Probability
95%
With Interview (+37.3%)
3y 1m
Median Time to Grant
Low
PTA Risk
Based on 139 resolved cases by this examiner. Grant probability derived from career allow rate.

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