Prosecution Insights
Last updated: October 01, 2026
Application No. 19/023,020

LIQUID EJECTION USING THERMALLY LOADED AIR SPRING

Non-Final OA §102§103
Filed
Jan 15, 2025
Priority
May 24, 2024 — provisional 63/651,727
Examiner
KAYES, SEAN PHILLIP
Art Unit
Tech Center
Assignee
Apple Inc.
OA Round
1 (Non-Final)
70%
Grant Probability
Favorable
1-2
OA Rounds
10m
Est. Remaining
92%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allowance Rate
730 granted / 1046 resolved
+9.8% vs TC avg
Strong +22% interview lift
Without
With
+22.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
35 currently pending
Career history
1062
Total Applications
across all art units

Statute-Specific Performance

§101
1.2%
-38.8% vs TC avg
§103
42.8%
+2.8% vs TC avg
§102
29.7%
-10.3% vs TC avg
§112
19.4%
-20.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1046 resolved cases

Office Action

§102 §103
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 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, 7, 8, 9, 13, 15, 16, and 17 are rejected under 35 U.S.C. 102a1 as being anticipated by Arndt (US 20200064215). With regard to claim 1 Arndt discloses an electronic device (abstract), comprising: a housing (104, 105) having an opening (figures 1, 2); one or more electronic components (abstract) disposed within a first cavity adjacent to the opening (abstract, figures 1, 2) and exposed to an environment external to the housing via the opening (abstract); a heating element (heater – abstract) disposed within a second cavity adjacent to the first cavity (106-1, 106-2; abstract paragraphs 17, figures 2, 3a); and processing circuitry (paragraph 17) configured to: determine that the opening is occluded (presence of water – abstract, paragraph 17; the current specification states “an internal volume of the port within which the pressure sensor, speaker and/or microphone is disposed, can become occluded by environmental aggressors such as a liquid, a portion of a user's skin, or a piece of clothing at or near the port, all of which can alter the performance of the sensor.” Thus it follows detecting intrusion of water into the system would reasonably convey occlusion); and activate the heating element to eject a liquid through the opening to the environment by increasing a gas pressure within the second cavity based at least in part on a change in temperature in the second cavity by heating at least a portion of a gas volume inside the second cavity with the heating element (abstract – “eject a liquid through the opening”. You cannot eject something without force. An object stays at rest or keeps moving at a constant speed in a straight line unless an outside force acts on it – Newton’s first law. Thus, there must be a pressure differential to induce ejection.) With regard to claim 7 Arndt discloses the electronic device of claim 1, further comprising a gel layer (abstract, claim 1) positioned inside the first cavity and disposed on at least a portion of the one or more electronic components (figure 1, abstract, claim 1). With regard to claim 8 Arndt discloses the electronic device of claim 1, wherein the heating element comprises one or more layers of a conductive foil disposed on one or more walls of the second cavity (302-1, 302-2 figure 1, abstract figure 3a.) With regard to claim 9 Arndt discloses the electronic device of claim 1, wherein the heating element comprises one or more wire bonds (205 figure 2; paragraph 20). With regard to claim 13 Arndt discloses a smart watch (paragraph 21, 23), comprising: a housing having an opening (104, 105 figure 2); one or more electronic components disposed within a first cavity adjacent to the opening and exposed to an environment external to the housing via the opening (abstract, paragraphs 17-21, figure 2); a heating element (heater – abstract) disposed within a second cavity (106-1, 106-2; abstract paragraphs 17, figures 2, 3a) adjacent to the first cavity (figures 1, 2) and configured to heat at least a portion of a gas volume inside the second cavity to cause an increase in a gas pressure within the second cavity based at least in part on a change in temperature in the second cavity (abstract, paragraph 17), wherein the opening is occluded by a liquid (abstract, paragraph 17), and wherein the liquid is displaced by the increase in the gas pressure from the second cavity to the first cavity (abstract, paragraph 17; the presence of liquid would increase the forces compared to an alternative situation). With regard to claim 15 Arndt discloses the smart watch of claim 13, further comprising a gel layer positioned inside the first cavity and disposed on at least a portion of the one or more electronic components (figure 1, abstract, claim 1). With regard to claim 16 Arndt discloses the smart watch of claim 13, wherein the heating element comprises one or more layers of a conductive foil disposed on one or more walls of the second cavity (302-1, 302-2 figure 1, abstract figure 3a.) With regard to claim 17 Arndt discloses the smart watch of claim 13, wherein the heating element comprises one or more wire bonds (205 figure 2; paragraph 20). 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 20 is rejected under 35 U.S.C. 103 as being unpatentable over Arndt (US 20200064215) in view of Werner (US 10165694).With regard to claim 20 Arndt discloses an electronic device, comprising: a housing (104, 105 figure 2); one or more electronic components disposed within a cavity adjacent to the opening and exposed to an environment external to the housing via the opening (abstract, paragraph 17); a heating element (abstract, paragraph 17) disposed within the cavity and configured to heat at least a portion of a gas pocket formed inside a shape of the heating element to cause an increase in a pressure within the gas pocket based at least in part on a change in temperature in the gas pocket (106-1, 106-2; abstract paragraphs 17, figures 2, 3a); and a gel layer (gel – abstract) positioned inside the cavity and disposed on at least a portion of the one or more electronic components (gel at least partially fills the lid and covers the sensor). Arndt does not disclose the claimed: gel covering the heating element, wherein at least a portion of the gel layer expands in response to the change in temperature in the gas pocket to cause an increase in pressure in the cavity to cause displacement of an occluding liquid at the opening; and a particulate protection element having an opening and arranged on at least a portion of the housing. Arndt teaches heat conducting gel claim 7. Werner teaches using particulate protection element having an opening and arranged on at least a portion of the housing – abstract. Werner improves protection against environmental concerns. It 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 to configure Arndt’s system to comprise gel covering the heating element, wherein at least a portion of the gel layer expands in response to the change in temperature in the gas pocket to cause an increase in pressure in the cavity to cause displacement of an occluding liquid at the opening; and a particulate protection element having an opening and arranged on at least a portion of the housing, as taught by Arndt and Werner. The use of protection element achieves improvements in environmental concerns are taught by Werner. Arndt teaches a conductive gel, but the gel would be most effective if in contact with the heating element. Further, most every substance expands when heated. Few exceptions exist such as frozen water, but not liquid water. It is unlikely the gel in the prior art is the type to not expand, but even in the event it was, it would still have been obvious to use a gel that expands with temperature for the clear advantage of providing structural support and consistent volume control during the heating process. A gel that shrinks when heated would be very problematic as it would defeat the water protection purpose. Given the lack of disclosure on the subject in Arndt it would be a very strange choice to choose a rare material that breaks the function or purpose of the material selection. Allowable Subject Matter Claims 2, 3, 4, 5, 6, 10, 11, 12, 14, 18, and 19 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. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SEAN KAYES whose telephone number is (571)272-8931. The examiner can normally be reached 10-6. 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, Renee Luebke can be reached at 571-272-2009. 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. /SEAN KAYES/Primary Patent Examiner, Art Unit 2831
Read full office action

Prosecution Timeline

Jan 15, 2025
Application Filed
Mar 23, 2026
Response after Non-Final Action
Sep 10, 2026
Non-Final Rejection mailed — §102, §103 (current)

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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
70%
Grant Probability
92%
With Interview (+22.3%)
2y 6m (~10m remaining)
Median Time to Grant
Low
PTA Risk
Based on 1046 resolved cases by this examiner. Grant probability derived from career allowance rate.

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