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 .
Claim Rejections - 35 USC § 102
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claim(s) 2, 8, 9, 13, 14, 18, and 21 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Yang et al. (US 2020/0161211 A1).
Re. claims 2 and 14: Yang discloses an electronic device, comprising:
a printed circuit board (9) with one or more integrated circuits (91) mounted on a first surface (top surface) of the printed circuit board;
a heat sink (2) configured to be coupled to a surface (top surface) of a first integrated circuit (91); and
a spring apparatus that includes:
a central portion (center of 11) that has an aperture, wherein one or more integrated circuits (91) are mounted to a first surface (top surface) of a printed circuit board (9) within the aperture; (see fig. 1-3; para. 0028-0032)
a first spring arm (first 12) that is disposed on a first side of the central portion and includes a first through-hole (120) for a first fastener (8); and (see fig. 1, 3; para. 0032, 0039)
a second spring arm (second 12) that is disposed on a second side of the central portion and includes a second through-hole (120) for a second fastener (8). see fig. 1, 3; para. 0032, 0039)
Re. claims 8 and 18: Yang discloses wherein the first spring arm (first 12) extends from the first side of the central portion at a first point (121A) through which a longitudinal axis of the leaf spring passes. (see fig. 3, 4)
Re. claim 9: Yang discloses wherein the second spring arm (second 12 opposite the first 12) extends from the second side of the central portion at a second point (second 121A) through which the longitudinal axis of the leaf spring passes. (see fig. 3, 4)
Re. claims 13 and 21: Yang discloses the first spring arm (first 12) causes the heat sink (2) to exert a first compressive force against the first integrated circuit (91) via the first fastener (first 8); and (see fig. 1, 3, 4; para. 0014, 0039-0040)
the second spring arm (second 12) causes the heat sink to exert a second compressive force against the first integrated circuit via the second fastener (second 8). (see fig. 1, 3, 4; para. 0014, 0039-0040)
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.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claim(s) 3 and 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yang et al. as applied to claim 1 above, and further in view of Deeney (US 6,549,418 B1)
Re. claims 3 and 15: Yang fails to disclose:
wherein the first integrated circuit is mounted to a second surface of the printed circuit board.
However, Deeney discloses:
wherein the first integrated circuit (48, 49, 50, 51) is mounted to a second surface (circuits are mounted to both sides of the PCB) of the printed circuit board. (see fig. 2, 3; col. 4)
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to provide integrated circuits and leaf springs to both sides of the PCB of Yang as taught by Deeney. One of ordinary skill would have been motivated to do this in order to have a high density of IC devices on a single circuit board. (Deeney col. 1 ln. 63 – col. 2 ln. 23)
Allowable Subject Matter
Claims 4-7, 10-12, 16-17, and 19-20 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims.
The following is a statement of reasons for the indication of allowable subject matter:
Re. claims 4 and 16: the limitations of “one or more other integrated circuits are mounted to the first surface of the printed circuit board within the second aperture” in combination with the remaining limitations in the claim cannot be found in the prior art.
Re. claims 10 and 19: the limitations of “a first bending axis that passes through the first side and that is substantially perpendicular to a longitudinal axis of the leaf spring that passes through the first through-hole and the second through-hole; and a second bending axis that passes through the second side and that is substantially perpendicular to the longitudinal axis of the leaf spring” in combination with the remaining limitations in the claim cannot be found in the prior art. Yang’s bending axes are parallel to the longitudinal axis rather than perpendicular as claimed.
Re. claims 11 and 20: the limitations of “wherein the first spring arm has a first resistance to a bending moment, the second spring arm has a second resistance to the bending moment, and the central portion has a third resistance to the bending moment that is greater than both the first resistance and the second resistance” in combination with the remaining limitations in the claim cannot be found in the prior art. Yang fails to disclose the relative resistance to any bending moment.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Laurent et al. (US 2019/0104610 A1) disclose a spring assembly on opposite sides of a printed circuit board for cooling an electronic device. Olson (US 5,818,695) discloses a spring clip for pressing a heat sink against a heat generating device.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADAM B DRAVININKAS whose telephone number is (571)270-1353. The examiner can normally be reached Monday - Friday 9a-6p MT.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, JAYPRAKASH (JP) N GANDHI can be reached at 571-272-3740. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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September 30, 2026
/ADAM B DRAVININKAS/ Primary Examiner, Art Unit 2841
