Prosecution Insights
Last updated: August 17, 2026
Application No. 18/990,598

HANDHELD APPLIANCE FOR STEAMING GARMENTS WITH RETRACTABLE WATER RESERVOIR

Final Rejection §103§112
Filed
Dec 20, 2024
Examiner
NGUYEN, UYEN T
Art Unit
3732
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Hamilton Beach Brands Inc.
OA Round
2 (Final)
40%
Grant Probability
At Risk
3-4
OA Rounds
1y 3m
Est. Remaining
76%
With Interview

Examiner Intelligence

Grants only 40% of cases
40%
Career Allowance Rate
119 granted / 300 resolved
-30.3% vs TC avg
Strong +36% interview lift
Without
With
+36.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
39 currently pending
Career history
348
Total Applications
across all art units

Statute-Specific Performance

§101
3.4%
-36.6% vs TC avg
§103
47.8%
+7.8% vs TC avg
§102
14.2%
-25.8% vs TC avg
§112
31.4%
-8.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 300 resolved cases

Office Action

§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 . Claim Objections Claim 20 is objected to because of the following informalities: In claim 20, lines 14-15, “that is less than the first position” is read as “that is less than the first distance”. Appropriate correction is required. Specification The specification is objected to as failing to provide proper antecedent basis for the claimed subject matter. See 37 CFR 1.75(d)(1) and MPEP § 608.01(o). Correction of the following is required: The specification does not teach “the second distance is between about 30 and 60 percent of the first distance” in claim 3 and “an area of the second portion is between about 30 and 60 percent of an area of the first portion” in claim 12. The original specification describes “as much as 30 to 60 percent of the reservoir 14 may overlie the collar 30 and the lower end of the housing 12”, which means the second distance is between 40 to 70 percent of the first distance as the second distance is from the lower end of the water reservoir to the housing. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. Claims 3 and 12 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Claim 3 recites “the second distance is between about 30 and 60 percent of the first distance”, which is not described in the specification. The specification only describes “when the reservoir 14 is fully retracted, more than half of the reservoir 14 may overlie the collar 30 and the lower end of the housing 12 (i.e., as much as 30 to 60 percent of the reservoir 14 may overlie the collar 30 and the lower end of the housing” (para. [00037]), which means the second distance is between 40 to 70 percent of the first distance as the second distance is from the lower end of the water reservoir to the housing. Claim 12 recites “an area of the second portion is between about 30 and 60 percent of an area of the first portion”, which is not described in the specification. The specification only describes “when the reservoir 14 is fully retracted, more than half of the reservoir 14 may overlie the collar 30 and the lower end of the housing 12 (i.e., as much as 30 to 60 percent of the reservoir 14 may overlie the collar 30 and the lower end of the housing” (para. [00037]). 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 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 1-6, 8-9, 11-15, 17-18 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Spoida (US 3805425) in view of Ediger (US 2021/0310182). Regarding claim 1, Spoida teaches a steaming appliance, comprising: a housing (fig. 1, casing 3,4); a steam generation unit (fig. 1, steam generator 5) mounted in the housing, the steam generation unit including a plate (fig. 1, plate 43) with at least one exhaust hole (fig. 1, outlets 42) positioned to exhaust steam from the housing; a pump (fig. 1, pump 6) mounted in the housing and fluidly connected with the steam generation unit; and a water reservoir (fig. 1, water tank 2) detachably mounted to the housing and fluidly connected with the pump; wherein the steam generation unit is configured to convert water pumped from the water reservoir to the steam generation unit to steam that is expelled through the at least one exhaust hole (fig. 1); and wherein the water reservoir is mounted to the housing so as to be movable relative to the housing between an extended position and a retracted position (fig. 1, by adjusting the water tank relative to the screw cap). Spoida does not teach the extended position is an extended operating position and the retracted position is a retracted storage position. However, in the same field of endeavor, Ediger teaches the water reservoir is mounted to the housing so as to be movable relative to the housing between an extended operating position (fig. 1), in which a lower end of the water reservoir extends a first distance from the housing, and a retracted storage position (fig. 2), in which the lower end of the water reservoir extends a second distance from the housing that is less than the first distance. It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine Spoida with a collapsible water reservoir as taught by Ediger so that the water reservoir can move relative to the housing between the extended operating position and the retracted storage position for the benefit of providing convenience in storage and travelling (Ediger, para. [0005]). Regarding claim 2, the modified structure Spoida-Ediger teaches a first portion of the water reservoir overlies the housing in the extend position (Ediger, fig. 1), a second portion of the water reservoir overlies the housing in the retracted position, and the second portion is larger than the first portion (Ediger, fig. 2 shows a second portion of the water reservoir overlies the ring surface 106 of the housing in the retracted position; the second portion is larger than the first portion in the extended position as shown in fig. 1). Regarding claim 3, the modified structure Spoida-Ediger does not teach the second distance is between about 30 and 60% of the first distance. However, as the Applicant does not provide that the particular range, i.e. “the second distance is between about 30 and 60% of the first distance”, is critical, it would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine the modified structure Spoida-Ediger with the second distance is between about 30% and 60% of the first distance for the benefit of providing different sizes of the water reservoir in operating and storage positions, since discovering the optimum or workable ranges of sizes of the water reservoir involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 4, the modified structure Spoida-Ediger teaches the water reservoir rotates relative to the housing during movement from the extended to the retracted position (Spoida in view of Ediger, the water reservoir can be pushed and twisted at the same time during movement from the extended to the retracted position). Regarding claim 5, the modified structure Spoida-Ediger does not clearly teach the water reservoir rotates between about 70 and 140 degrees in moving from the extended position to the retracted position. However, as there are plurality screw threads at the connection between the neck of the water tank and the housing, it would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to choose an extended position and a retracted position, in which the water reservoir rotates between about 70 and 140 degrees in moving from the extended position to the retracted position, which depends on how the user handles the appliance in the storage position. Regarding claim 6, the modified structure Spoida-Ediger teaches the housing includes a collar (Spoida, fig. 1, cap 56), and wherein the collar includes a radially-outward projection (Spoida, fig. 1, screw threads of the cap 56), and wherein the water reservoir on an inner surface thereof includes a track (Spoida, fig. 1, grooves to receive screw threads of the cap 56) that receives the radially-outward projection. PNG media_image1.png 410 470 media_image1.png Greyscale Regarding claim 8, the modified structure Spoida-Ediger teaches the track includes an upper run (Spoida, fig. 1, upper threads of the neck) and a lower run (Spoida, fig. 1, lower threads of the neck), and wherein the upper run extends substantially circumferentially to provide a locking location for projection (Spoida, fig. 1). Regarding claim 9, the modified structure Spoida-Ediger teaches the lower run of the track extends axially and circumferentially from the upper run (Spoida, fig. 1). Regarding claim 11, Spoida teaches a steaming appliance, comprising: a housing (fig. 1, casing 3,4); a steam generation unit (fig. 1, steam generator 5) mounted in the housing, the steam generation unit including a plate (fig. 1, plate 43) with at least one exhaust hole (fig. 1, outlets 42) positioned to exhaust steam from the housing; a pump (fig. 1, pump 6) mounted in the housing and fluidly connected with the steam generation unit; and a water reservoir (fig. 1, water tank 2) detachably mounted to the housing and fluidly connected with the pump; wherein the steam generation unit is configured to convert water pumped from the water reservoir to the steam generation unit to steam that is expelled through the at least one exhaust hole (fig. 1); and wherein the water reservoir is mounted to the housing so as to be movable relative to the housing between an extended position and a retracted position (fig. 1, by adjusting the water tank relative to the screw cap). Spoida does not teach the extended position is an extended operating position and the retracted position is a retracted storage position. However, in the same field of endeavor, Ediger teaches the water reservoir is mounted to the housing so as to be movable relative to the housing between an extended operating position (fig. 1), in which a first portion of the water reservoir circumferentially overlies the housing (fig. 1, the ringed neck extension 111 overlies a portion of the ring surface 106 of the housing), and a retracted storage position (fig. 2), in which a second portion of the water reservoir overlies the housing (fig. 2), the second portion being larger than the first portion. It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine Spoida with a collapsible water reservoir as taught by Ediger so that the water reservoir can move relative to the housing between the extended operating position and the retracted storage position for the benefit of providing convenience in storage and travelling (Ediger, para. [0005]). Regarding claim 12, the modified structure Spoida-Ediger does not teach an area of the first portion is between about 30 and 60% of an area of the second portion. However, as the Applicant does not provide that the particular range, i.e. “an area of the first portion is between about 30 and 60% of an area of the second portion”, is critical, it would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine the modified structure Spoida-Ediger with an area of the first portion is between about 30 and 60% of an area of the second portion for the benefit of providing different sizes of the water reservoir in operating and storage positions, since discovering the optimum or workable ranges of sizes of the water reservoir involves only routine skill in the art. In re Aller, 105 USPQ 233. Regarding claim 13, the modified structure Spoida-Ediger teaches the water reservoir rotates relative to the housing during movement from the extended to the retracted position (Spoida in view of Ediger, the water reservoir can be pushed and twisted at the same time during movement from the extended to the retracted position). Regarding claim 14, the modified structure Spoida-Ediger does not clearly teach the water reservoir rotates between about 70 and 140 degrees in moving from the extended position to the retracted position. However, as there are plurality screw threads at the connection between the neck of the water tank and the housing, it would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to choose an extended position and a retracted position, in which the water reservoir rotates between about 70 and 140 degrees in moving from the extended position to the retracted position, which depends on how the user handles the appliance in the storage position. Regarding claim 15, the modified structure Spoida-Ediger teaches the housing includes a collar (Spoida, fig. 1, cap 56), and wherein the collar includes a radially-outward projection (Spoida, fig. 1, screw threads of the cap 56), and wherein the water reservoir on an inner surface thereof includes a track (Spoida, fig. 1, grooves to receive screw threads of the cap 56) that receives the radially-outward projection. Regarding claim 17, the modified structure Spoida-Ediger teaches the track includes an upper run (Spoida, fig. 1, upper threads of the neck) and a lower run (Spoida, fig. 1, lower threads of the neck), and wherein the upper run extends substantially circumferentially to provide a locking location for projection (Spoida, fig. 1). Regarding claim 18, the modified structure Spoida-Ediger teaches the lower run of the track extends axially and circumferentially from the upper run (Spoida, fig. 1). Regarding claim 20, Spoida teaches a steaming appliance, comprising: a housing (fig. 1, casing 3,4); a steam generation unit (fig. 1, steam generator 5) mounted in the housing, the steam generation unit including a plate (fig. 1, plate 43) with at least one exhaust hole (fig. 1, outlets 42) positioned to exhaust steam from the housing; a pump (fig. 1, pump 6) mounted in the housing and fluidly connected with the steam generation unit; and a water reservoir (fig. 1, water tank 2) detachably mounted to the housing and fluidly connected with the pump; wherein the steam generation unit is configured to convert water pumped from the water reservoir to the steam generation unit to steam that is expelled through the at least one exhaust hole (fig. 1); and wherein the water reservoir is mounted to the housing so as to be rotatable relative to the housing between an extended position and a retracted position (fig. 1, by adjusting the water tank relative to the screw cap). Spoida does not teach the extended position is an extended operating position and the retracted position is a retracted storage position. However, in the same field of endeavor, Ediger teaches the water reservoir is mounted to the housing so as to be movable relative to the housing between an extended operating position (fig. 1), in which a lower end of the water reservoir extends a first distance from the housing, and a retracted storage position (fig. 2), in which the lower end of the water reservoir extends a second distance from the housing that is less than the first distance. It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine Spoida with a collapsible water reservoir as taught by Ediger so that the water reservoir can move relative to the housing between the extended operating position and the retracted storage position for the benefit of providing convenience in storage and travelling (Ediger, para. [0005]). Claims 7 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Spoida (US 3805425) and Ediger (US 2021/0310182), as applied to claim 6 and 15 above, and further in view of Metzger (US 1033187). Regarding claim 7, the modified structure Spoida-Ediger does not teach the radially-outward projection is a spring-loaded button. However, in the same field of fastening device, Metzger teaches the radially-outward projection is a spring-loaded button (fig. 3, leaf spring 17). It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to modify the screw thread connection between the neck of the water tank and the cap of the housing of the modified structure Spoida-Ediger with the leaf spring received in the channel as taught by Metzger for the benefit of providing locking connection between the neck of the water tank and the cap of the housing with flexibility, easier maintenance and less damage risk to components. Regarding claim 16, the modified structure Spoida-Ediger does not teach the radially-outward projection is a spring-loaded button. However, in the same field of fastening device, Metzger teaches the radially-outward projection is a spring-loaded button (fig. 3, leaf spring 17). It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to modify the screw thread connection between the neck of the water tank and the cap of the housing of the modified structure Spoida-Ediger with the leaf spring received in the channel as taught by Metzger for the benefit of providing locking connection between the neck of the water tank and the cap of the housing with flexibility, easier maintenance and less damage risk to components. Claims 10 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Spoida (US 3805425) and Ediger (US 2021/0310182), as applied to claims 1 and 11 above, and further in view of Lin (US 2025/0154715). Regarding claim 10, the modified structure Spoida-Ediger does not teach the water reservoir is transparent. However, in the same field of endeavor, Lin teaches the water reservoir is transparent (para. [0086]). It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine the water reservoir of the modified structure Spoida-Ediger with a transparent material as taught by Lin for the benefit of allowing the user to view the water level in the water reservoir (Lin, para. [0086]). Regarding claim 19, the modified structure Spoida-Ediger does not teach the water reservoir is transparent. However, in the same field of endeavor, Lin teaches the water reservoir is transparent (para. [0086]). It would have been obvious to one of the ordinary skilled in the art before the effective filing date of the invention to combine the water reservoir of the modified structure Spoida-Ediger with a transparent material as taught by Lin for the benefit of allowing the user to view the water level in the water reservoir (Lin, para. [0086]). Response to Arguments Applicant’s arguments, dated 05/04/2026, with respect to the specification objections and 35 U.S.C 112(a) rejections have been fully considered but are not persuasive. The objections and rejections are maintained. Applicant’s arguments, dated 05/04/2026, with respect to the rejections of claims under 35 U.S.C 102/103 have been fully considered but are moot because the new ground of rejection does not rely on combination of references applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Applicant argues that the prior art does not teach the amended limitations. However, this argument is not commensurate with the rejected claims, as the limitations have not been previously presented. Thus, the amended limitations have been addressed as analyzed above. 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 UYEN THI THAO NGUYEN whose telephone number is (571)272-8370. The examiner can normally be reached Monday-Friday 9 AM-6 PM 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 supervisor, Khoa Huynh can be reached at 571-272-4888. 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. /UYEN T NGUYEN/Primary Examiner, Art Unit 3732
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Prosecution Timeline

Dec 20, 2024
Application Filed
Feb 04, 2026
Non-Final Rejection mailed — §103, §112
May 04, 2026
Response Filed
Jul 14, 2026
Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
40%
Grant Probability
76%
With Interview (+36.5%)
2y 11m (~1y 3m remaining)
Median Time to Grant
Moderate
PTA Risk
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