Prosecution Insights
Last updated: October 02, 2026
Application No. 19/020,259

REFRIGERATOR

Non-Final OA §103
Filed
Jan 14, 2025
Priority
Jan 05, 2024 — RE 10-2024-0002506 +2 more
Examiner
MARONEY, JENNA M
Art Unit
Tech Center
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
64%
Grant Probability
Moderate
1-2
OA Rounds
1y 0m
Est. Remaining
85%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allowance Rate
338 granted / 524 resolved
+4.5% vs TC avg
Strong +20% interview lift
Without
With
+20.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
25 currently pending
Career history
545
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
47.0%
+7.0% vs TC avg
§102
21.1%
-18.9% vs TC avg
§112
29.5%
-10.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 524 resolved cases

Office Action

§103
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 Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statement (IDS) submitted on 14 January, 2025, 22 July, 2025, and 20 March, 2026 are being considered by the examiner. Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: “coupling member” of the refrigerator, described in claims 1, 3-4, and 15. “coupling member” of the thermoelectric module, described in claim 12. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. 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. Claim(s) 1-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over BANG (US 2006/0185711 A1 – published 24 August, 2006),in view of PARK (US 5,522,216 A – published 4 June, 1996). As to claim 1, BANG discloses a refrigerator comprising: a main body (100); a storage room inside the main bod (102; par. 39); a thermoelectric module including: a module plate(210) including an element mounting portion (212) a heat dissipation sink (250; par. 55) on a first side of the module plate figure 6), a cooling sink (240; par. 55) on a second side of the module plate(figure 6), a thermoelectric element (230; par. 55) positioned in the element mounting portion (figure 4; par. 64) such that a first surface of the thermoelectric contacts the heat dissipation sink (figure 6; par. 64) and a second surface of the thermoelectric element contacts the cooling sink (figure 6; par. 64); and a coupling member(260; figure 6; par. 60-61 and 65) penetrating the module plate of the thermoelectric module to couple the thermoelectric module to a surface of the main body (figure 6). However, BANG does not expressly disclose wherein the coupling of the thermoelectric module is to an upper surface of the main body. PARK, however, is within the field of endeavor provided a refrigerator (abstract). PARK teaches wherein a thermoelectric module(90; col. 5, lines 6-8) can be positioned on various plates of the refrigerator, including an upper surface of the refrigerators main body (figure 3a-3d). PARK recognizing doing so enables flexibility in the design of the refrigerator by varying the location of the coupling of the thermoelectric module based on application thereof (col.8, lines 17-20; col. 8, lines 31-34). Therefore, it would have been obvious to one having ordinary skill within the art, prior to the date the invention was effectively filed, to modify BANG, in view of the teachings of PARK to positioning the thermoelectric module coupled at an upper surface of the main body based on these reasons and an obvious matter of design choice (MPEP §2144.04 – VI(C)). As to claim 2, BANG, as modified, further discloses wherein the main body includes: an inner case (110), an outer case (120) coupled to an outer side of the inner case (figure 6), and a connecting frame between the inner and outer case (190). As to claim 3, BANG, as modified, further discloses wherein the coupling member is coupled to the connecting frame (figure 6). As to claim 4, BANG, as modified, further discloses wherein the coupling member penetrates the outer base to be coupled to the connecting frame (figure 6). As to claim 5, BANG, as modified, further discloses wherein the connecting frame includes an installation opening connecting the storage room to the outside (opening when the thermoelectric module, and connected components are not positioned within the hole of 190). As to claim 6, BANG, as modified, further discloses wherein at least one portion of the thermoelectric module is positioned inside the installation opening (figure 6). As to claim 7, BANG, as modified to include connection to the upper surface (see rejection of claim 1), further discloses wherein the module plate(210) includes a wing portion(214) supported on the surface of the main body (figure 6). As to claim 8, BANG, as modified, further discloses wherein the module plate (210) includes a plate base(see annotated figure 6) configured to support the heat dissipation sink. PNG media_image1.png 810 678 media_image1.png Greyscale Annotated Figure 6 As to claim 9, BANG, as modified, further discloses wherein the wing portion(214) is stepped relative to the plate base (figure 4), and the module plate includes a connecting portion (210a) connecting the plate base to the wing portion (figure 4). As to claim 10, BANG, as modified, further discloses wherein the main body includes: an inner case (110), an outer case (120) coupled to an outer side of the inner case (figure 6), a connecting frame between the inner and outer case (220), and the connecting frame includes a middle support(224) protruding to support an end of the plate base of the module plate (see annotated figure 6). As to claim 11, BANG, as modified, further discloses wherein the main body includes: an inner case (110), an outer case (120) coupled to an outer side of the inner case (figure 6), a connecting frame between the inner and outer case (220), and the connecting frame comprises a sink end support protruding to support an end of the cooling sink(240). PNG media_image2.png 810 558 media_image2.png Greyscale Annotated Figure 6A As to claim 12, BANG, as modified, further discloses wherein the thermoelectric module includes a coupling member (260) penetrating the heat dissipation sink (figure 6), the module plate, and the cooling sink to couple the heat dissipation sink and the cooling sink to the module plate (figure 4 and 6). As to claim 13, BANG, as modified, further discloses wherein the thermoelectric module includes a sink insulator (190) between the module plate (210) and the cooling sink (240), as shown in figure 6. As to claim 14, BANG, as modified, does not further disclose the requirements of claim 14. However, PARK further teaches a heat dissipation duct (duct form between 39 and 30; figure 5) coupled to the thermoelectric module (figure 5) and configured to dissipate heat form the heat dissipation sink (col. 6, lines 50-52; col. 10, lines 31-33). Providing such establishes a desired airflow path, and thereby, enables dissipation of heat from the heat dissipation sink. Therefore, it would have been obvious to one having ordinary skill within the art, prior to the date the invention was effectively filed, to modify BANG, in view of the teachings of PARK, to include the heat dissipation duct for establishing a desired airflow path. As to claim 15, BANG, as modified to include the heat dissipation duct (see rejection of claim 14), teaches the heat dissipation duct is coupled tot eh thermoelectric module by the coupling member, in view of the duct being formed along an external side of the outer case (as taught by PARK) and the thermoelectric module being coupled to the outer case ( figure 6). As such, the combination yields the requirements set forth by the claim. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JENNA M MARONEY whose telephone number is (571)272-8588. The examiner can normally be reached Monday - Friday 7AM to 4PM, 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, Len Tran can be reached at (571) 272-1184. 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. /JENNA M MARONEY/Primary Examiner, Art Unit 3763 8/21/2026 JENNA M. MARONEY Primary Examiner Art Unit 3763
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Prosecution Timeline

Jan 14, 2025
Application Filed
Aug 25, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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COMPACTED THERMOCHEMICAL HEAT STORAGE BODIES
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Patent 12743059
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Patent 12736281
METHOD FOR GENERATING REFRIGERATION FOR A CARBON MONOXIDE COLD BOX
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3y 1m to grant Granted Sep 01, 2026
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
64%
Grant Probability
85%
With Interview (+20.3%)
2y 9m (~1y 0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 524 resolved cases by this examiner. Grant probability derived from career allowance rate.

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