Prosecution Insights
Last updated: July 17, 2026
Application No. 18/911,373

Check Valve for Refrigeration Systems

Non-Final OA §102§103§112
Filed
Oct 10, 2024
Priority
Oct 11, 2023 — provisional 63/589,406 +1 more
Examiner
REID, MICHAEL ROBERT
Art Unit
3753
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Parker-Hannifin Corporation
OA Round
2 (Non-Final)
79%
Grant Probability
Favorable
2-3
OA Rounds
6m
Est. Remaining
98%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allowance Rate
541 granted / 685 resolved
+9.0% vs TC avg
Strong +20% interview lift
Without
With
+19.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
40 currently pending
Career history
719
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
65.9%
+25.9% vs TC avg
§102
7.9%
-32.1% vs TC avg
§112
17.7%
-22.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 685 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 Amendment This action is responsive to the amendment dated 4/15/2026. The previous drawing objections have been withdrawn due to applicant’s replacement figures submitted on 4/15/2026. The previous claim objections have been withdrawn due to applicant’s amendment. The previous 112(f) interpretation for the term “coupling features” remains. Any new ground(s) of rejection below have been made due to applicant’s amendment. This action is Final. 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 11-14 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 applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 11 recites that the “stem further includes a flanged distal end”. However, claim 10 has been amended to recite the stem having a flanged distal end (see line 5). It is unclear in claim 11 how many flanged distal end(s) are intending to be claimed. Claims 12-14 are rejected due to their dependency on claim 11. Claim Rejections - 35 USC § 102 The text of those sections of Title 35, U.S. Code 102 not included in this action can be found in a prior Office action. Claim(s) 1-5 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Hutchings (U.S. 2,206,356). Hutchings discloses an assembly comprising: a tube (6, 8, etc.) having a first port and a second port (at the left and right ends); a sleeve (13) fixedly disposed within the tube; a stem (11, 16) disposed, and axially movable, within the sleeve, wherein the stem has a flanged distal end having an outer diameter that is larger than an inner diameter of the sleeve (best shown in fig. 2, as the area of 20 and 16 is wider in order to contact 15), and a rim (17) formed at a proximal end thereof; a spring (21) mounted around the stem and axially interposed between the sleeve and the rim of the stem; and a seal (20) mounted to the stem, wherein: refrigerant is configured to be received at the first port to push the stem in a distal direction, compressing the spring, thereby preventing the stem from moving in the distal direction beyond a particular axial position, while allowing refrigerant to flow to the second port (fig. 3, further, to the extent that the applicant recites “refrigerant”, this is an intended use of a material worked upon which has not been given patentable weight See MPEP2115), and as pressure level at the first port is reduced, the spring is configured to push the stem in a proximal direction until the seal reaches the sleeve, thereby preventing the stem from moving further in the proximal direction, and blocking refrigerant flow to the first port (fig. 2). Regarding claim 2, Hutchings further discloses wherein the stem has a cylindrical portion (11), the flanged distal end, and an annular groove (the narrow groove portion that receives 20) interposed between the cylindrical portion and the flanged distal end, wherein the seal is mounted in the annular groove (figs. 2 and 3). Regarding claim 3, Hutchings further discloses wherein the stem has a blind cavity (12) and one or more circumferential slots (19) formed in the cylindrical portion, wherein refrigerant is configured to be received at the first port to flow through the blind cavity, pushing the stem in the distal direction, then laterally outward through the one or more circumferential slots, then around the flanged distal end to the second port (fig. 3). Regarding claim 4, Hutchings further discloses wherein the sleeve comprises a tapered end (see the area of 15 showing a taper from 12 leading to the left) that facilitates inserting. Regarding claim 5, Hutchings further discloses wherein an outer diameter of the flanged distal end is smaller than an inner diameter of the tube such that refrigerant is configured to be discharged from the one or more circumferential slots to flow through an annular gap formed between the flanged distal end and the tube (fig. 3). Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code 103 not included in this action can be found in a prior Office action. Claim(s) 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Wynn (U.S. 4,129,145). Hutchings discloses the claimed invention and further discloses the spring resting on the rim (fig. 3) but does not appear to disclose the sleeve having an annular groove formed in a proximal end with a distal end of the spring received in the annular groove of the sleeve. Wynn teaches it was known to have a sleeve with an annular groove formed in an end (groove 20 formed by shoulder 18) with a spring received in the groove of the sleeve (fig. 1B-1C). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the sleeve of Hutchings by having the sleeve have an annular groove formed in a proximal end with a distal end of the spring received in the annular groove of the sleeve as taught by Wynn in order to more securely receive the spring in the sleeve and prevent unwanted radial movement of the spring which could lead to damage or breaking of the spring, increasing the longevity of the device. Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Salisbury (U.S. 3,001,546). Hutchings discloses the claimed invention but does not appear to disclose the spring coiled in increasing outer diameter in the distal direction such that coils closer to the rim have a smaller diameter compared to coils closer to the sleeve. Salisbury teaches it was known to have a check valve with a spring (36) with coils that have a smaller diameter towards a rim (near 30) as compared to coils closer to a sleeve (equivalent structure at 20)(notice the coils narrowing in diameter as the coils extend from 20 to 30). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the spring of Hutchings such that the spring increases in outer diameter in the distal direction such that coils closer to the rim have a smaller diameter compared to coils closer to the sleeve as taught by Salisbury in order to provide an equivalent functioning spring but can be a shorter overall length for a more compact overall assembly and have better buckling resistance. Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Qiu (U.S. 2010/0096028). Hutchings discloses the claimed invention but does not appear to disclose wherein the seal is a first seal, wherein the sleeve has an annular groove, and wherein the assembly further comprises: a second seal disposed in the annular groove of the sleeve such that the second seal is configured to seal between an exterior surface of the sleeve and an interior surface of the tube. Qiu teaches it was known in the art to have a similar valve with a sleeve that has a similar “first seal” (26) and wherein the sleeve (1) has an annular groove (the groove for 101), and wherein the assembly further comprises: a second seal (101) disposed in the annular groove of the sleeve such that the second seal is configured to seal between an exterior surface of the sleeve and an interior surface of the tube (fig. 6). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify Hutchings such that the sleeve has an annular groove and seal disposed in the annular groove such that the second seal is configured to seal between an exterior surface of the sleeve and an interior surface of the tube as taught by Qiu in order to provide a better seal between the tube and sleeve to prevent unwanted leakage and maintain the fluid in the desired area of the valve. Claim(s) 10-14, and 18, claims 11-14 as far as they are definite, is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings. Hutchings discloses a method comprising: providing a tube (6, 8, etc.); providing a sleeve (13) of a check valve (figs. 2-3), wherein the sleeve has a cylindrical cavity (within the sleeve); inserting a stem (11, 16) in the cylindrical cavity such that the stem is axially movable within the sleeve (figs. 2-3), wherein the stem has an annular groove (the groove that receives seal 20) and a flanged distal end having an outer diameter that is larger than an inner diameter of the sleeve such that the stem is inserted proximal end first through the sleeve (best shown in fig. 2, as the area of 20 and 16 is wider in order to contact 15); mounting a spring (21) around the stem such that a distal end of the spring rests against the sleeve (fig. 3), forming a rim (17) at a proximal end of the stem such that a proximal end of the spring rests against the rim (fig. 3); mounting a seal (20) in the annular groove of the stem, wherein the stem is capable of sliding in a proximal direction until the seal contacts the sleeve (fig. 2); and mounting the check valve inside the tube such that the sleeve of the check valve is fixedly position within the tube (figs. 2 and 3). Hutchings is silent as to the rim being formed after inserting the stem and mounting the spring around the stem. However, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify Hutchings such that the rim is formed in any order, including after inserting the stem and mounting the spring without affecting the resultant product, since it has been held that the selection of an order of performing process steps to be within the level of ordinary skill in the art in the absence of new or unexpected results. In re Gibson, 39 F.2d 975, 5 USPQ 230 (CCPA 1930). See MPEP2144.04. Regarding claim 11, Hutchings as modified further discloses wherein inserting the stem in the cylindrical cavity of the sleeve comprises: inserting a cylindrical portion (11) of the stem in the cylindrical cavity of the sleeve, wherein the stem further includes a flanged distal end (the left end), wherein the annular groove is interposed between the cylindrical portion and the flanged distal end (figs 2-3). Regarding claim 12, Hutchings as modified further discloses forming the stem to have a blind cavity (12) and one or more circumferential slots (19) in the cylindrical portion. Regarding claim 13, Hutchings as modified further discloses wherein the sleeve comprises a tapered end (see the area of 15 showing a taper from 12 leading to the left), wherein mounting the check valve inside the tube comprises: inserting the sleeve into the tube, wherein the tapered end operates as a lead-in chamfer that facilitates insertion of the sleeve into the tube (figs. 2-3, as the sleeve is within the tube). Regarding claim 14, Hutchings as modified further discloses forming the flanged distal end of the stem such that an outer diameter of the flanged distal end is smaller than an inner diameter of the tube (figs. 2-3). Regarding claim 18, Hutchings as modified further discloses after mounting the check valve within the tube, forming respective coupling features (such as the threading as shown in figs. 2-3) in a proximal end and a distal end of the tube to facilitate coupling the tube to a refrigeration system (see figs. 2-3). The examiner further notes that this forming of the coupling features can occur at any step, including before or after mounting the check valve within the tube, without affecting the resultant product and especially as it has been held that selection of an order of performing process steps has been held to be within the level of ordinary skill in the art in the absence of new or unexpected results. In re Gibson, 39 F.2d 975, 5 USPQ 230 (CCPA 1930). See MPEP2144.04. Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Wynn. Hutchings as modified discloses the claimed invention and further discloses the spring resting on the rim (fig. 3) but does not appear to disclose the sleeve having an annular groove formed in a proximal end with a distal end of the spring received in the annular groove of the sleeve. Wynn teaches it was known to have a sleeve with an annular groove formed in an end (groove 20 formed by shoulder 18) with a spring received in the groove of the sleeve (fig. 1B-1C). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the sleeve of Hutchings by having the sleeve have an annular groove formed in a proximal end with a distal end of the spring received in the annular groove of the sleeve as taught by Wynn in order to more securely receive the spring in the sleeve and prevent unwanted radial movement of the spring which could lead to damage or breaking of the spring, increasing the longevity of the device. Claim(s) 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Salisbury. Hutchings as modified discloses the claimed invention but does not appear to disclose the spring coiled in increasing outer diameter in the distal direction such that coils closer to the rim have a smaller diameter compared to coils closer to the sleeve. Salisbury teaches it was known to have a check valve with a spring (36) with coils that have a smaller diameter towards a rim (near 30) as compared to coils closer to a sleeve (equivalent structure at 20)(notice the coils narrowing in diameter as the coils extend from 20 to 30). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify the spring of Hutchings such that the spring increases in outer diameter in the distal direction such that coils closer to the rim have a smaller diameter compared to coils closer to the sleeve as taught by Salisbury in order to provide an equivalent functioning spring but can be a shorter overall length for a more compact overall assembly and have better buckling resistance. Claim(s) 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Qiu (U.S. 2010/0096028). Hutchings as modified discloses the claimed invention but does not appear to disclose wherein the seal is a first seal, wherein the sleeve has an annular groove, and wherein the method further comprises: mounting a second seal disposed in the annular groove of the sleeve such that the second seal is configured to seal between an exterior surface of the sleeve and an interior surface of the tube. Qiu teaches it was known in the art to have a similar valve with a sleeve that has a similar “first seal” (26) and wherein the sleeve (1) has an annular groove (the groove for 101), and wherein the assembly further comprises: a second seal (101) disposed in the annular groove of the sleeve such that the second seal is configured to seal between an exterior surface of the sleeve and an interior surface of the tube (fig. 6). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify Hutchings such that the sleeve has an annular groove and seal disposed in the annular groove such that the second seal is configured to seal between an exterior surface of the sleeve and an interior surface of the tube as taught by Qiu in order to provide a better seal between the tube and sleeve to prevent unwanted leakage and maintain the fluid in the desired area of the valve. Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hutchings in view of Sonsterod (U.S. 5,409,088). Hutchings as modified discloses the claimed invention but does not appear to disclose wherein forming the rim comprises using a rolling forming process to form the rim. Sonsterod teaches it was known in the art to form a rim by using a rolling forming process (forming end portion 46 by rolling, see col. 3, ll. 59-63, which forms a similar resultant shape as that of Hutchings). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify Hutchings by having the rim formed by a rolling forming process as taught by Sonsterod in order to have the rim formed by a process known for forming such a rim that is conventional and relatively easy to manufacture in such a manner. Allowable Subject Matter Claims 9 and 15 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. Response to Arguments Applicant’s arguments with respect to claim(s) 1-20 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Applicant’s amendment has required further search and/or consideration and/or revision of the rejection. As such, the Qiu reference is no longer being used as the primary reference. Hutchings (or Hutchings as modified) as enumerated above has now been used to address the applicant’s amended claims. 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 MICHAEL R REID whose telephone number is (313)446-4859. The examiner can normally be reached on Monday-Friday 9am-5pm est. 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 supervisors can be reached by phone. Craig Schneider can be reached at 571-272-3607, or Ken Rinehart can be reached at 571-272-4881. 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 Patent Center. Status information for published applications may be obtained from Patent Center. Status information for unpublished applications is available through Patent Center for authorized users only. Should you have questions about access to Patent Center, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). 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) Form at https://www.uspto.gov/patents/uspto-automated- interview-request-air-form. /MICHAEL R REID/ Primary Examiner, Art Unit 3753
Read full office action

Prosecution Timeline

Oct 10, 2024
Application Filed
Jan 20, 2026
Non-Final Rejection mailed — §102, §103, §112
Apr 15, 2026
Response Filed
May 05, 2026
Final Rejection mailed — §102, §103, §112
Jul 01, 2026
Response after Non-Final Action

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

2-3
Expected OA Rounds
79%
Grant Probability
98%
With Interview (+19.5%)
2y 3m (~6m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 685 resolved cases by this examiner. Grant probability derived from career allowance rate.

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