Prosecution Insights
Last updated: October 02, 2026
Application No. 19/076,186

Liquid Discharge Head, Liquid Discharge Device, And Method Of Manufacturing Liquid Discharge Head

Non-Final OA §103§112
Filed
Mar 11, 2025
Priority
Mar 12, 2024 — JP 2024-037715
Examiner
SHENDEROV, ALEXANDER D
Art Unit
Tech Center
Assignee
Seiko Epson Corporation
OA Round
1 (Non-Final)
90%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 90% — above average
90%
Career Allowance Rate
808 granted / 896 resolved
+30.2% vs TC avg
Moderate +6% lift
Without
With
+6.2%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 7m
Avg Prosecution
22 currently pending
Career history
900
Total Applications
across all art units

Statute-Specific Performance

§101
2.1%
-37.9% vs TC avg
§103
46.7%
+6.7% vs TC avg
§102
28.3%
-11.7% vs TC avg
§112
16.6%
-23.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 896 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 . Priority Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). The certified copy has been filed on 4/22/25, the requirements 35 U.S.C. 119 (a)-(d) are met. Information Disclosure Statement The references cited on a Form PTO 1449 have been considered. Specification The specification has been checked to the extent necessary to determine the presence of all possible minor errors. However, the applicant's cooperation is requested in correcting any errors of which applicant may become aware in the specification. 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 12-14 and 16 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. Specifically, Claim 12 recites, and its dependent Claim 13 incorporates, inter alia, “a surface of the protective layer on the one side in the third boundary region is located on the one side rather than surfaces of the protective layer on the one side in the first boundary region and the second boundary region”. Similarly, Claim 14 recites, and its dependent Claim 16 incorporates, inter alia, “a surface of the protective layer on the other side in the first boundary region is located on the one side rather than a surface of the protective layer on the other side in the second boundary region”. The claims are generally narrative and indefinite, failing to conform with current U.S. practice. They appear to be a literal translation into English from a foreign document and are replete with grammatical and idiomatic errors. 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. Claim(s) 1-4, 6-7 and 17-18 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yazaki et al. (U.S. 2014/0118447 A1) in view of Murata et al. (U.S. 2005/0275694 A1). Yazaki et al. disclose the following claimed limitations: Regarding independent Claim 1, a liquid discharge head (Title) comprising: a piezoelectric body (30, §0021 and Figs. 1-2); a pressure chamber (10, §0022 and Fig. 2) substrate provided with a plurality of pressure chambers (10, §0022 and Fig. 2) arranged in an arrangement direction, which is a direction intersecting an extending direction of the pressure chamber, the pressure chamber being configured to apply pressure to a liquid stored inside when the piezoelectric body is driven; a first electrode (20, §0021 and Figs. 1-2) provided on one side of a lamination direction, which is a direction intersecting the extending direction and the arrangement direction, with respect to the piezoelectric body; a second electrode (40, §0021 and Figs. 1-2) provided on another side of the lamination direction, which is a side opposite to the one side, with respect to the piezoelectric body; and a protective layer (80, §0034 and Figs. 1A-B) provided on the other side with respect to the piezoelectric body in a boundary region, which is a boundary between a first region and a second region, in the extending direction when the first region is set to a region where the piezoelectric body overlaps the second electrode in the lamination direction, and the second region is set to a region where the piezoelectric body is present and the second electrode is not present in the lamination direction. Regarding Claim 2, wherein the piezoelectric body contains lead zirconate titanate (§0027). Regarding Claim 7, wherein the boundary region includes a first boundary region, a second boundary region that is closer to the first region than the first boundary region in the extending direction, and a third boundary region that is closer to the second region than the first boundary region in the extending direction (Figs. 1-2). Regarding Claim 17, a liquid discharge device comprising: the liquid discharge head (Title). Regarding independent Claim 18, a method of manufacturing a liquid discharge head (Title), the liquid discharge head including a piezoelectric body (30, §0021 and Figs. 1-2) and a first electrode (20, §0021 and Figs. 1-2) provided on one side of a lamination direction with respect to the piezoelectric body, the method comprising: a first step of forming a second electrode (40, §0021 and Figs. 1-2) on another side of the lamination direction, which is a side opposite to the one side, with respect to the piezoelectric body (§0046 and Fig. 3B); a second step of removing the second electrode in a second region by etching such that an end portion of the second electrode in an extending direction, which is a direction intersecting the lamination direction, is located at a boundary region when a region where the piezoelectric body overlaps the second electrode in the lamination direction is set to a first region, a region where the piezoelectric body is present and the second electrode is not present in the lamination direction is set to the second region, and a region which is a boundary between the first region and the second region in the extending direction is set to the boundary region (§0046 and Figs. 3B-C); a third step of forming a protective layer on the other side of the piezoelectric body and the second electrode (§0074 and Fig. 6C); and a fourth step of removing the protective layer in the first region and the second region by etching (§0074 and Fig. 7A). Yazaki et al. do not disclose the following claimed limitations: Regarding independent Claim 1, wherein the protective layer is made of the same material as the piezoelectric body. Regarding Claim 2, wherein the protective layer contains lead zirconate titanate (§0027). Please note, however, that in the combination, the protective layer being made of the same material as the piezoelectric body, the material containing lead zirconate titanate. Regarding Claim 3, wherein a (100) orientation degree of the protective layer is lower than a (100) orientation degree of the piezoelectric body. However, increasing a (100) orientation degree of the piezoelectric body (known to enhance its piezoelectric properties and Young’s modulus) is typically achieved by additional operations, such as forming an orientation control layer prior to formation of the piezoelectric body (see e.g. Sumi et al., U.S. 2006/0232639 A1, e.g. §0052). This additional operation would be unnecessary for the protective layer. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to omit this unnecessary step in manufacturing the liquid discharge head of Yazaki et al. to reduce cost and improve yield. Please note that omitting this unnecessary step in manufacturing the liquid discharge head of Yazaki et al. would result in a (100) orientation degree of the protective layer being lower than a (100) orientation degree of the piezoelectric body. Regarding Claim 4, wherein a Young's modulus of the protective layer is higher than a Young's modulus of the piezoelectric body. However, increasing a (100) orientation degree of the piezoelectric body (known to enhance its piezoelectric properties and decrease Young’s modulus) is typically achieved by additional operations, such as forming an orientation control layer prior to formation of the piezoelectric body (see e.g. Sumi et al., U.S. 2006/0232639 A1, e.g. §0052). This additional operation would be unnecessary for the protective layer. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to omit this unnecessary step in manufacturing the liquid discharge head of Yazaki et al. to reduce cost and improve yield. Please note that omitting this unnecessary step in manufacturing the liquid discharge head of Yazaki et al. would result in a Young's modulus of the protective layer being higher than a Young's modulus of the piezoelectric body. Regarding Claim 6, wherein a piezoelectric constant of the protective layer is smaller than a piezoelectric constant of the piezoelectric body. However, increasing a (100) orientation degree of the piezoelectric body (known to enhance its piezoelectric properties and decrease Young’s modulus) is typically achieved by additional operations, such as forming an orientation control layer prior to formation of the piezoelectric body (see e.g. Sumi et al., U.S. 2006/0232639 A1, e.g. §0052). This additional operation would be unnecessary for the protective layer. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to omit this unnecessary step in manufacturing the liquid discharge head of Yazaki et al. to reduce cost and improve yield. Please note that omitting this unnecessary step in manufacturing the liquid discharge head of Yazaki et al. would result in a piezoelectric constant of the protective layer is smaller than a piezoelectric constant of the piezoelectric body. Regarding Claim 17, a control section that controls a discharge operation of discharging a liquid from the liquid discharge head. Regarding independent Claim 18, wherein the protective layer is made of the same material as the piezoelectric body. Murata et al. disclose the following claimed limitations: Regarding independent Claim 1, wherein the protective layer over an electrode is made of the same material as the body under the electrode (§0078). It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to apply the same materials of Murata et al. to the liquid discharge head of Yazaki et al. to ensure strong joining forces of the layers and therefore reliable protection. Please note that applying the same materials of Murata et al. to the liquid discharge head of Yazaki et al. would result in the protective layer being made of the same material as the piezoelectric body. Regarding Claim 17, a control section (74, §0103 and Fig. 6) that controls a discharge operation of discharging a liquid from the liquid discharge head. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to apply the control section of Murata et al. to the liquid discharge head of Yazaki et al. to ensure proper control of a discharge operation. Regarding independent Claim 18, wherein the protective layer over an electrode is made of the same material as the body under the electrode (§0078). It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to apply the same materials of Murata et al. to the liquid discharge head of Yazaki et al. to ensure strong joining forces of the layers and therefore reliable protection. Please note that applying the same materials of Murata et al. to the liquid discharge head of Yazaki et al. would result in the protective layer being made of the same material as the piezoelectric body. Claim(s) 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yazaki et al. (U.S. 2014/0118447 A1) in view of Murata et al. (U.S. 2005/0275694 A1) as applied to Claim 1 above, and further in view of Shimada (U.S. 2010/0079558 A1). Yazaki et al. and Murata et al., in combination, disclose the following claimed limitations: Regarding Claim 5, all limitations of Claim 1 (from which this Claim depends). Yazaki et al. and Murata et al. do not disclose the following claimed limitations: Regarding Claim 5, wherein a thickness of the protective layer in the lamination direction is thinner than a thickness of the piezoelectric body in the lamination direction. Shimada discloses the following: Regarding Claim 5, wherein a thickness of the piezoelectric body in the lamination direction is 1,000 nm (§0029). It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to apply the thickness of the piezoelectric body of Shimada to the liquid discharge head of Yazaki et al. to ensure appropriate actuation. Please note that applying thickness of the piezoelectric body of Shimada to the liquid discharge head of Yazaki et al. (who teach a thickness of the protective layer in the lamination direction of 25 nm, §0070) would result in a thickness of the protective layer in the lamination direction is thinner than a thickness of the piezoelectric body in the lamination direction. Claim(s) 8, 10-11 and 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Yazaki et al. (U.S. 2014/0118447 A1) in view of Murata et al. (U.S. 2005/0275694 A1) as applied to Claim 1 above, and further in view of Shimada (U.S. 2010/0079558 A1). Yazaki et al. and Murata et al., in combination, disclose the following claimed limitations: Regarding Claim 8, all limitations of Claim 7 (from which this Claim depends). Yazaki et al. and Murata et al. do not disclose the following claimed limitations: Regarding Claim 8, wherein the second electrode has a first layer, and a second layer provided on the other side of the first layer. Regarding Claim 10, wherein in the first boundary region, the first layer is present and the second layer is not present in the lamination direction, in the second boundary region, the first layer and the second layer are present in the lamination direction, and in the third boundary region, neither the first layer nor the second layer is present in the lamination direction. Regarding Claim 11, wherein a thickness of the piezoelectric body in the lamination direction in the third boundary region is thinner than a thickness of the piezoelectric body in the lamination direction in the first boundary region and the second boundary region. Regarding Claim 15, wherein a thickness of the piezoelectric body in the lamination direction in the second region is thinner than a thickness of the piezoelectric body in the lamination direction in the second boundary region. Shimada discloses the following: Regarding Claim 8, wherein the second electrode has a first layer (17, §029 and Fig. 2B), and a second layer (17, §029 and Fig. 2B) provided on the other side of the first layer. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to apply the layers of Shimada to the liquid discharge head of Yazaki et al. to ensure reliable connection of the second electrode to the control structure driving the liquid discharge head. Regarding Claims 10-11 and 15, sloped portions at the periphery of second electrode (§0010-0017, 0037, 0043 and Figs. 2C, 4B-C, 5). It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to apply the slopes of Shimada to the liquid discharge head of Yazaki et al. so that the resistance against the deformation of the piezoelectric element during driving can be made even, to improve durability by suppressing stress concentration during displacement. Please note that applying the slopes of Shimada to the liquid discharge head of Yazaki et al. would result in meeting the respective limitations of Claims 10-11 and 15 as follows: Regarding Claim 10, wherein in the first boundary region, the first layer is present and the second layer is not present in the lamination direction, in the second boundary region, the first layer and the second layer are present in the lamination direction, and in the third boundary region, neither the first layer nor the second layer is present in the lamination direction. Regarding Claim 11, wherein a thickness of the piezoelectric body in the lamination direction in the third boundary region is thinner than a thickness of the piezoelectric body in the lamination direction in the first boundary region and the second boundary region. Regarding Claim 15, wherein a thickness of the piezoelectric body in the lamination direction in the second region is thinner than a thickness of the piezoelectric body in the lamination direction in the second boundary region. Allowable Subject Matter Claim 9 is 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: the primary reason for indicating allowable subject matter of claim 9 is the inclusion of the limitations of a liquid discharge head including wherein at least a part of the protective layer is interposed between the first layer and the second layer in the lamination direction. It is this limitation found in the claims, as it is claimed in the combination of that has not been found, taught or suggested by prior art of record, which makes these claims allowable over the prior art. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ALEXANDER D SHENDEROV whose telephone number is (571)270-7049. The examiner can normally be reached M-F 9-5. 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, Douglas X Rodrigues can be reached at (571) 431-0716. 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. /ALEXANDER D SHENDEROV/ Examiner, Art Unit 2853 /JASON S UHLENHAKE/ Primary Examiner, Art Unit 2853
Read full office action

Prosecution Timeline

Mar 11, 2025
Application Filed
Sep 03, 2026
Non-Final Rejection mailed — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12746754
APPARATUS FOR MANUFACTURING DISPLAY DEVICES
2y 3m to grant Granted Sep 29, 2026
Patent 12734819
LIQUID SUPPLY DEVICE, LIQUID JETTING SYSTEM, PRINTING SYSTEM, AND LIQUID CIRCULATION METHOD
2y 6m to grant Granted Sep 15, 2026
Patent 12734812
PRINTING APPARATUS
2y 6m to grant Granted Sep 15, 2026
Patent 12728653
LIQUID EJECTION DEVICE
3y 0m to grant Granted Sep 08, 2026
Patent 12728644
LIQUID EJECTION HEAD
2y 5m to grant Granted Sep 08, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

1-2
Expected OA Rounds
90%
Grant Probability
96%
With Interview (+6.2%)
1y 7m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 896 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month