Prosecution Insights
Last updated: October 01, 2026
Application No. 18/845,910

WIRELESS POWER TRANSFER

Final Rejection §102§103§112
Filed
Sep 11, 2024
Priority
Mar 29, 2022 — EU 22165064.1 +1 more
Examiner
AMRANY, ADI
Art Unit
2836
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Koninklijke Philips N.V.
OA Round
2 (Final)
56%
Grant Probability
Moderate
3-4
OA Rounds
1y 0m
Est. Remaining
74%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allowance Rate
776 granted / 1380 resolved
-11.8% vs TC avg
Strong +18% interview lift
Without
With
+18.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
30 currently pending
Career history
1413
Total Applications
across all art units

Statute-Specific Performance

§101
1.5%
-38.5% vs TC avg
§103
55.7%
+15.7% vs TC avg
§102
24.4%
-15.6% vs TC avg
§112
16.8%
-23.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1380 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 . Response to Arguments Applicant's arguments filed March 3, 2026, have been fully considered but they are not persuasive. Schwartz discloses using two thresholds to create three maximum signal level values (see fig 8; par 67-71). The art rejection is updated to cite to this disclosure as well. The §112(d) rejection of claims 8 and 27 is maintained. The Applicant does not address or respond to the substance of the rejection. Claim Objections Claim 19 is objected to because there is no antecedent basis in the claim for the limitation of “the function”. Claim 19 recites that the maximum signal level “is a variable that varies” – it does not use the same “function” language as in claim 1. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(d): (d) REFERENCE IN DEPENDENT FORMS.—Subject to subsection (e), a claim in dependent form shall contain a reference to a claim previously set forth and then specify a further limitation of the subject matter claimed. A claim in dependent form shall be construed to incorporate by reference all the limitations of the claim to which it refers. Claims 8 and 27 are rejected under 35 U.S.C. 112(d) as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, or for failing to include all the limitations of the claim upon which it depends. Claim 8 does not further limit claim 7 because it is descriptive of what the equivalent series resistance and minimum equivalent series resistance are “indicative of”. There is no narrowing structure or functionality in the claim. The description of information that can be inferred from the resistance values is not further limiting. The same analysis applies to claim 27 – it does not further limit claim 26. Applicant may cancel the claim(s), amend the claim(s) to place the claim(s) in proper dependent form, rewrite the claim(s) in independent form, or present a sufficient showing that the dependent claim(s) complies with the statutory requirements. 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. Claims 1, 3-9, 11-12, 16-20, 22-27, 30, 35-37, 39-40 and 42-43 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Schwartz (US 2021/0167637). With respect to claim 1, Schwartz discloses a device (fig 1-5, 8, item 12; par 17-48, 67-71) comprising: an output resonance circuit (shown in fig 2), wherein the output resonance circuit comprises a transmitter coil (36) and at least one capacitor (70); a driver circuit (61), wherein the driver circuit is arranged to generate a drive signal for the output resonance circuit so as to generate a signal; a measurer circuit (90, 92), wherein the measurer circuit is arranged to measure a loading parameter (par 19, 30, 33, the Q factor is a “loading parameter”, as defined by the Applicant’s specification – see par 33 and claim 3), wherein the loading parameter indicates of a loading of the transmitter coil during a time interval when there is no power transfer (this limitation only describes what the loading parameter “indicates” – it does not define how/when/why it is measured in the first place); a determiner circuit (par 30, “to determine whether a foreign object is present” and “take suitable action (e.g., by transmitting power at a restricted level that is lower than the level permitted in the absence of detecting the foreign object, by halting power transmission, etc.”), wherein the determiner circuit is arranged to determine a maximum signal level for the signal during power transfer in response to the loading parameter (the maximum is either the restricted level or zero/off); wherein the maximum signal level is a function of the loading factor (fig 8; par 67-71); wherein the function provides an output value having a range of at least three signal levels (par 69 power level 2; par 70 power level 1; par 71 no power); and wherein the driver circuit is arranged to constrain the drive signal such that the signal does not exceed the maximum signal level during power transfer (par 30, last sentence, as quoted above). Schwartz discloses a wireless power transmitter that senses the loading parameter of its resonant circuit. The specification defines the quality (Q) factor, such as disclosed by Schwartz, as a loading parameter (par 33). The transmitter then determines (through a “determiner circuit”) if the Q-factor indicates the presence of a large foreign object, a medium/small foreign object, or no object. This results in three distinct maximum signal levels. Power transfer levels are “constrained” for at least two of the maximum signal levels (par 70-71). With respect to claim 3, Schwartz discloses the loading parameter comprises a quality factor parameter (par 30), wherein the quality factor parameter indicates a quality factor of the output resonance circuit (via the location of the sensors 90, 92). With respect to claim 4, Schwartz discloses the loading parameter is a self-inductance parameter (par 38-40), wherein the self-inductance parameter indicates of a self-inductance of the transmitter coil. Schwartz discloses that temperature, aging and other effects can cause a drift in the Q-factor. Therefore, measurements are taken during use, including that of the inductance. This is interpreted as the “self-inductance” of the coil 36. With respect to claim 5, Schwartz discloses the determiner circuit is arranged to determine the maximum signal level in response to a measured value of the loading parameter relative to a value of the loading parameter for a reference positioning of the power receiver (par 30, the baseline value). With respect to claim 6, Schwartz discloses the driver circuit is arranged to determine a maximum transmitter coil current corresponding to the maximum signal level, wherein the driver circuit is arranged to control the drive signal so as to maintain a transmitter coil current below a maximum transmitter coil current (par 32). Schwartz discloses that the inverter controls its output current and that the presence of a foreign object determines the maximum (constrained) power that can be output. First, this output power can be zero. Thus, the Schwartz inverter would provide no current and the claim is anticipated. Second, if the output is not zero, it is known that power equals current times voltage. Any regulation of the output power (to keep it below the restricted level) would inherently include regulation/control over current and/or voltage. With respect to claim 7, Schwartz discloses the loading parameter comprises an equivalent series resistance of the transmitter coil (par 30), wherein the driver circuit is arranged to determine the maximum transmitter coil current (par 32) in response to the equivalent series resistance of the transmitter coil relative to a minimum expected equivalent series resistance for the power receiver and power transmitter arrangement. Schwartz discloses that the loading parameter (Q-factor) is determined by sensing the voltage and current of the transmitter coil. Through Ohm’s Law (V=IR), the resistance of the coil is given by voltage divided by current. This equivalent series resistance is inherently included in the measurements, even if the reference does not explicitly solve for it (and only uses Q-factor or self-inductance). The claim only broadly recites that the maximum transmitter coil determination is “in response to” the equivalent series resistance relative to that of the entire system/arrangement. “in response to” does not explicitly set forth that the driver circuit must know these values or that it uses them in a specific manner. As noted above (and not rebutted by the Applicant), resistance are inherently found in the circuit – any measurement values and control is inherently affected by this resistance. Rewriting the resistance as an “equivalent series resistance” (instead of the as-presented resistance) does not change this analysis – the “equivalent” is just a shorthand (a way to take many electrical components and redraw them as one resistance). With respect to claim 8, Schwartz discloses the equivalent series resistance is taken over time and would include a “minimum” expected value at least once during its lifetime. What these values are “indicative of” is not further limiting to the device of claim 7. With respect to claim 9, Schwartz discloses a receiver circuit (40; par 26-27), wherein the receiver circuit is arranged to receive an indication of the minimum expected equivalent series resistance from the power receiver. The Schwartz receiver circuit is “arranged to receive” any information that is sent to it from the power receiver. The name or substance of the signal being communicated does not further narrow the structure of the receiver circuit itself. Furthermore, the power receiver isn’t claimed – thus, there is no signal to be received from the power receiver. Lastly, the claim describes that the receiver circuit is arranged to receive “an indication” of another value. The ability to infer information from other information does not further limit the structure of the transmitter or its receiver circuit. With respect to claim 11, Schwartz discloses wherein the minimum expected equivalent series resistance is self-inductance dependent (through Ohm’s Law – the resistance is a function of the voltage/current on/through the coil – which is defined by its inductance), wherein the determiner circuit is arranged to determine a self-inductance parameter (par 38-40), wherein the self-inductance indicates of a self-inductance of the transmitter coil (par 38-40), wherein the determiner circuit is arranged to determine the minimum expected equivalent series resistance as a function of the self-inductance (par 38-40 – the resistance and self-inductance are repeatedly sensed/calculated – this includes any time in which a minimum value would be present). With respect to claim 12, Schwartz discloses the power transmitter further comprises a receiver circuit (40; see art rejection of claim 9), wherein the receiver circuit is arranged to receive an indication of a reference minimum expected equivalent series resistance from the power receiver (see art rejection of claim 9 – the name of the signal the receiver circuit is “arranged to receive” does not further limit its structure), wherein the reference minimum expected equivalent series resistance is a minimum equivalent series resistance for a transmitter coil of a reference transmitter coupled to a power receiver coil of the power receiver (not further limiting – this limitation describes the reference minimum – it has no effect on the structure of the receiver circuit), wherein the determiner circuit is arranged to determine the minimum expected equivalent series resistance in response to the reference minimum expected equivalent series resistance (par 27, 30). Schwartz discloses that communication is required “to control wireless power transfer” (par 27). This includes the measurements take on the transmitter side (voltage, current) to determine resistance during power transfer. Thus, the resistance determination comes after (i.e. in response to) the communication (and any “indications” that are included in it) With respect to claim 16, Schwartz discloses the determiner circuit is arranged to determine the equivalent series resistance of the transmitter coil in response to a decay rate for a free running oscillation of the output resonance circuit (par 30). The claim does not recite creating a decay effect (transmitting power and then abruptly stopping it to create a decaying effect in the resonance circuit). The claim is an apparatus claim that is defining the structure of the determining circuit to determine the equivalent series resistance of the transmitter coil. The “when” is not further limiting to the structure of the determiner circuit. Schwartz discloses its determiner circuit operates constantly (at all times). This would include during any decay. Schwartz also discloses measurements during a decay in figure 3 (par 34). With respect to claim 17, Schwartz discloses the determiner circuit is arranged to determine the equivalent series resistance of the transmitter coil (par 30) in response to a measured resonance frequency of the resonance circuit (see par 40 – resonance frequency and series resistance have a distinct relationship and one can be calculated “in response to” the other). With respect to claim 18, Schwartz discloses the determiner circuit is arranged to determine the equivalent series resistance of the transmitter coil (par 30) in response to a measured quality factor of the resonance circuit (par 40 – same analysis as in claim 17 for the frequency). With respect to claims 19 and 22-27, 30, and 35-37, Schwartz discloses the apparatus necessary to complete the recited method steps, as discussed above in the art rejections of claims 1, 3-8, 11, and 16-18, respectively. With respect to claim 20, Schwartz discloses the apparatus/method of claim 19 is carried out autonomously, i.e. with a computer program (par 21). With respect to claims 39 and 42, Schwartz discloses the maximum signal level is a discrete function of the loading parameters (fig 8; par 69-71 – there are three discrete values). With respect to claim 40 and 43, Schwartz discloses the maximum signa level is independent of whether a foreign object is detected (par 68-70) – it is possible that there is no object or an object that only has a small amount of metal. 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 2, 4, 10, 21, 23 and 29 are rejected under 35 U.S.C. 103 as being unpatentable over Schwartz in view of Shahsavari (US 2019/0081516). With respect to claims 2, 4, 21, and 23, Schwartz discloses measuring/computing the quality factor to determine the presence of a foreign object (par 30). Schwartz also appears to anticipate the limitation of measuring/computing the self-inductance of the coil/inductor. Schwartz does not expressly disclose measuring/computing the coupling factor between the transmitter/receiver coils. Shahsavari discloses that quality factor, coupling factor and self-inductance are all known measurements/parameters used to determine the presence of a foreign object (par 39). Schwartz and Shahsavari are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with foreign object detection. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to replace or combine the Schwartz Q-factor with any of the other parameters (k, inductance), as taught by Shahsavari. The motivation for doing so would have been to use known equivalent methods to detect the foreign object. With respect to claims 10 and 29, Schwartz and Shahsavari combine to disclose wherein that the minimum expected equivalent series resistance is dependent on a coupling factor (the current and voltage through the coil is dependent on the coupling between transmitter/receiver, which is a measure of the efficiency of power transfer and how much current the receiver is drawing), wherein the determiner circuit is arranged to determine a coupling factor between the transmitter coil and a power receiver coil of the power receiver (Shahsavari discloses determining a coupling factor – all coupling factors are between the transmitter/receiver coils), wherein the determiner circuit is arranged to determine the minimum expected equivalent series resistance as a function of the coupling factor (the coupling factor is a unitless parameter that expresses the level [between 0 and 1] of the strength of coupling [i.e. efficient] between transmitter and receiver coils. Any measure of resistance on the transmitter side would obviously be a function of the receiver [which is its construction/impedance and its proximity to the transmitter] and the coupling factor). Claims 12-15 and 31-34 are rejected under 35 U.S.C. 103 as being unpatentable over Schwartz in view of Jung (US 10,848,011). The art rejection of claim 12 is an alternative rejection, giving the “arranged to receive” language more patentable weight to indicate actual functionality. This is done because corresponding method claim 31 positively recites “receiving an indication” and the same art can be applied against (what appears to be) the intended language of claim 12. With respect to claim 12, Schwartz discloses the power transmitter further comprises a receiver circuit (40; see art rejection of claim 9), but does not expressly disclose receiving an indication of the reference minimum expected equivalent resistance from the power receiver. Jung discloses a wireless power transmitter (fig 2) with foreign object detection comprising a receiver circuit (not illustrated, but evidenced by the transmitter’s ability to communicate data with the receiver, as discussed below), wherein the receiver circuit is arranged to receive an indication of a reference minimum expected value from the power receiver (col. 9, lines 5-15; PR is the received reference value), wherein the reference minimum expected value is a minimum equivalent value for a transmitter coil of a reference transmitter coupled to a power receiver coil of the power receiver (col. 9, lines 30-40 – PR is found through experimentation with a reference transmitter), wherein the determiner circuit is arranged to determine the minimum expected equivalent value in response to the reference minimum expected value (col. 9 – Jung sets PR as the threshold. Thus, it is “in response” to itself). Jung discloses a wireless power transmitter foreign object detection procedure in which the transmitter receives an expected threshold value from the receiver. Jung discloses the threshold is a power value – but the primary reference, Schwartz, already discloses that it is known to use the equivalent series resistance (see art rejection of claim 7). Furthermore, both power and resistance are calculated using the same values (voltage across and current through the transmitter coil). The combination relies on using Jung’s communication for the Schwartz resistance threshold – it is not required to use Jung’s power threshold and modify it. Schwartz and Jung are analogous to the claimed invention because they are from the same field of endeavor, namely wireless power transmitters with foreign object detection. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to modify Schwartz to have its reference threshold value communicated from the receiver (and to be based on a reference transmitter), as taught by Jung. The motivation for doing so would have been to enable the transmitter to adjust its threshold in response to interactions with different receivers. With respect to claim 13, the combination teaches the determiner circuit is arranged to determine the minimum expected equivalent series resistance in response to a compensation of the reference minimum expected equivalent series resistance for a difference between a series resistance of the power transmitter coil relative to a reference series resistance of the transmitter coil of the reference transmitter. Jung teaches receiving the reference threshold. Schwartz discloses using the reference threshold as the expected minimum. Thus, the “compensation” is zero. With respect to claim 14, Schwartz discloses the determiner circuit is arranged to determine the minimum expected equivalent series resistance as a function of the reference minimum expected equivalent series resistance and a self-inductance for the transmitter coil relative to a self-inductance of a power transmitter coil of the reference transmitter (par 30, 38-40). Schwartz discloses using both series resistance and self-inductance values. Thus, its expected threshold value is “a function of” both of them. The claim only broadly recites “as a function of” without reciting how the two values are actually used to create a third “expected” value. With respect to claim 15, Schwartz discloses the determiner circuit is arranged to determine a contribution of material of the power receiver to the equivalent series resistance of the transmitter coil (par 30 would include measurements affected by the presence and composition of the receiver) as a function of a contribution of material of the power receiver to an equivalent series resistance of the reference transmitter coil (“as a function of” is descriptive of how information can be inferred from other information – it does not recite any actual method steps to be carried out), wherein the determiner circuit is arranged to determine a frequency of the drive signal relative to a reference frequency of the reference transmitter (par 39-40 and through Jung’s teaching of basing the threshold on an experimental transmitter – see Jung col. 9, lines 30-40). With respect to claims 31-34, Schwartz and Jung combine to disclose the apparatus that corresponds to the recited method steps, and the references are analogous, as discussed above in the art rejections of claims 12-15, respectively. Claims 28, 38 and 41 are rejected under 35 U.S.C. 103 as being unpatentable over Schwartz. With respect to claim 28, Schwartz does not expressly disclose receiving an indication of the minimum expected equivalent series resistance from the power receiver. Schwartz does disclose communication with the receiver. Therefore, at the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to configure the Schwartz transmitter to receive additional information, including an “indication” of the minimum expected equivalent series resistance. There is no use for this information in claim 28, other than to receive it. Claim 27 only introduces what the minimum expected is “indicative of”. Receiving unused information would have been within the level of one of ordinary skill in the art, given the fact that Schwartz places importance on communication between transmitter and receiver. With respect to claim 38 and 41, Schwartz discloses the maximum signal level is a discrete function of the load parameters (fig 8; par 67-71) but does not expressly disclose it is a continuous function. At the time of the earliest priority date of the application, it would have been obvious to one skilled in the art to duplicate the Schwartz thresholds. Schwartz already discloses that one threshold may be duplicated into two (par 67-68). Thus, the reference sets forth the motivation for adding more threshold. The motivation for doing so would have been to sense more types of objects and provide more accurate power levels. With a sufficiently high number of thresholds, the Schwartz function becomes “continuous”. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADI AMRANY whose telephone number is (571)272-0415. The examiner can normally be reached Monday - Friday, 8am-7pm. 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, Taelor Kim can be reached at 5712722800 x36. 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. /ADI AMRANY/Primary Examiner, Art Unit 2836
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Prosecution Timeline

Sep 11, 2024
Application Filed
Jan 14, 2026
Non-Final Rejection mailed — §102, §103, §112
Mar 03, 2026
Response Filed
Aug 27, 2026
Final Rejection mailed — §102, §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
56%
Grant Probability
74%
With Interview (+18.0%)
3y 1m (~1y 0m remaining)
Median Time to Grant
Moderate
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