Prosecution Insights
Last updated: October 02, 2026
Application No. 19/088,004

ELECTRONIC DEVICE

Non-Final OA §103
Filed
Mar 24, 2025
Priority
Apr 19, 2024 — CN 202410473636.1
Examiner
BRITTINGHAM, NATHANIEL P
Art Unit
Tech Center
Assignee
Innolux Corporation
OA Round
1 (Non-Final)
74%
Grant Probability
Favorable
1-2
OA Rounds
1y 1m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allowance Rate
350 granted / 472 resolved
+14.2% vs TC avg
Strong +17% interview lift
Without
With
+16.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
7 currently pending
Career history
486
Total Applications
across all art units

Statute-Specific Performance

§101
1.7%
-38.3% vs TC avg
§103
60.2%
+20.2% vs TC avg
§102
17.8%
-22.2% vs TC avg
§112
14.0%
-26.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 472 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. Specification The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed. The following title is suggested: Electronic Device for Heating Liquid Crystal Material with Reflected Infrared Light. 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. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. 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: “a reflective polarizing element” in claim 1; “An infrared reflective element” in claim 1; “a light modulation element” in claim 1. Applicant figure 1 shows each of these elements. Applicant specification [0034] teaches, “the reflective polarizing element 1 may comprise, for example, a polarizer with reflective function.” Applicant specification [0040] teaches, “the infrared light reflective element 4 may comprise a low emissivity glass 41 (Low-E glass).” Applicant specification [0047] teaches, “In one embodiment of the present disclosure, as shown in FIG. 2A and FIG. 2B, the infrared light reflective element 4 comprises: a low emissivity glass 41; and a first cholesterol panel 42 disposed opposite to the low emissivity glass 41, wherein the low emissivity glass 41 is disposed between the first cholesterol panel 42 and the light modulation element 3.” Applicant specification [0036] teaches, “the light modulation element 3 may comprise: a first substrate 31; a second substrate 32 disposed opposite to the first substrate 31; and a light modulation layer 33 disposed between the first substrate 31 and the second substrate 32.” Applicant specification [0037] teaches, “the light modulation element comprise a liquid crystal material 331 and a dye material.” [0038] teaches, “the light modulation element 3 may comprise a sealing element S 1, which may disposed surrounding the light modulation layer 33.” 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. Allowable Subject Matter Claims 9-16 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: the closest prior art does not detail each and every limitation of these dependent claims. Regarding claim 9, the closest related art includes Han et al. (US 20170351138 A1), Seo et al. (US 20160154155 A1), and O’Keeffe et al. (US 20160026061 A1). The closest related art does not detail each and every limitation of claim 9. Claim 10 is objected to as dependent upon claim 9. Regarding claim 11, the closest related art includes Han et al. (US 20170351138 A1), Seo et al. (US 20160154155 A1), and O’Keeffe et al. (US 20160026061 A1). The closest related art does not detail each and every limitation of claim 11. Claim 12 is objected to as dependent upon claim 11. Regarding claim 13, the closest related art includes Han et al. (US 20170351138 A1) and Seo et al. (US 20160154155 A1). The closest related art does not detail each and every limitation of claim 13. Claims 14-16 are objected to as dependent upon claim 13. 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. Claims 1, 4, and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1). Regarding claim 1, Han teaches an electronic device (Title, [0016], Fig. 1, Liquid crystal Device), comprising: a reflective polarizing element (Fig. 1, [0028], a second uni-direction infrared reflection film 150); an infrared light reflective element ([0028], Fig. 1, a first uni-direction infrared reflection film 140) disposed opposite to the reflective polarizing element (Fig. 1, first uni-direction infrared reflection film 140 is disposed opposite to second uni-direction infrared reflection film 150 as shown); and a light modulation element ([0027], Fig. 1, liquid crystal layer 130 along with CF substrate 110 and TFT array substrate 120). Han does not teach a quarter wave plate disposed between the reflective polarizing element and the infrared light reflective element and therefore does not teach a light modulation element disposed between the quarter wave plate and the infrared light reflective element. Seo teaches an electronic device (Title, [0016], Fig. 1, Liquid crystal Display 10), comprising: A polarizing plate (Fig. 1, a first polarizing plate 100) which further includes a quarter wave plate (Fig. 3, [0030], “the phase difference layer 130 may be a quarter wave plate (QWP) having a λ/4 plate property”). Modifying Han’s electronic device with Seo’s device such that second uni-direction infrared reflection film 150 includes a quarter wave plate located on the bottom side of Han’s reflection film 150 will arrive at the limitations of a quarter wave plate disposed between the reflective polarizing element and the infrared light reflective element as Seo’s quarter waveplate phase difference layer 130 will be between Han’s first and second uni-direction infrared reflection films 140 and 150. This will also result in the limitation of a light modulation element disposed between the quarter wave plate and the infrared light reflective element. Han’s liquid crystal layer 130, which is disposed between first and second uni-direction infrared reflection films 140 and 150, as Han modified with Seo results in Seo’s quarter wave plate located on the bottom side of Han’s reflection film 150 which in turn will lead to Han’s liquid crystal layer 130 disposed between the quarter wave plate and the first uni-direction infrared reflection film 140. It would have been obvious to one skilled in the art, before the effective filing date of the invention, to modify Han with Seo, such that Han’s display device include a quarter wave plate as Seo teaches this allows a display to convert linearly polarized light into circularly polarized light which advantageously allows a display panel to exhibit a high luminance property (Seo, [0030]). Regarding claim 4, Han teaches the electronic device of claim 1, wherein a reflectivity of the infrared light reflective element to light with wavelengths between 780 nm and 3000 nm is greater than or equal to 70% (Fig. 3 and [0031] teach a scenario wherein infrared light, which falls within the claimed range, running into the uni-direction infrared reflection film encounters complete internal reflection thereby meeting the reflectivity of greater than or equal to 70%). Regarding claim 17, Han teaches the light modulation element comprises a liquid crystal material capable of switching between the transmitting state and the scattering state ([0027], Fig. 1, liquid crystal layer 130). Claims 2 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1), as applied to claim 1, and further in view of Jung et al. (US 20170032751 A1). Regarding claim 2, Han teaches wherein the light modulation element comprises: a first substrate (Fig. 1, CF substrate 110 and TFT array substrate 120); a second substrate disposed opposite to the first substrate (Fig. 1, TFT array substrate 120); and a light modulation layer disposed between the first substrate and the second substrate and comprising a liquid crystal material (Fig. 1, liquid crystal layer 130). Han does not teach the light modulation layer includes a dye-material. In an analogous art, Jung teaches an LCD wherein the light modulation layer includes a dye-material ([0087-0089], “The liquid crystal layer may further include dichroic dye mixed with the liquid crystal material”). Jung [0087-0088] teaches an advantage of liquid crystal material including dichroic dye is the dye allows for display of a color without the need for a color filter. Therefore, it would have been obvious to one skilled in the art before the effective filing date of the invention to modify Han and Seo with Jung such that the liquid crystal layer includes a dichroic dye as Jung teaches this allows an LCD to display color without the need for an extra color filter layer (Jung, [0087-0088]). Regarding claim 18, Han teaches the light modulation element comprises a liquid crystal material (Fig. 1, liquid crystal layer 130). Han does not teach the light modulation layer includes a dye-material. In an analogous art, Jung teaches an LCD wherein the light modulation layer includes a dye-material ([0087-0089], “The liquid crystal layer may further include dichroic dye mixed with the liquid crystal material”). Jung [0087-0088] teaches an advantage of liquid crystal material including dichroic dye is the dye allows for display of a color without the need for a color filter. Therefore, it would have been obvious to one skilled in the art before the effective filing date of the invention to modify Han and Seo with Jung such that the liquid crystal layer includes a dichroic dye as Jung teaches this allows an LCD to display color without the need for an extra color filter layer (Jung, [0087-0088]). Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1), as applied to claim 1, and further in view of Cui et al. (US 20180011513 A1). Regarding claim 3, Han and Seo are not relied upon for teaching the claim limitations. Cui teaches an electronic device wherein an angle is included between a transmitting axis of the reflective polarizing element and a fast axis of the quarter wave plate, and the angle is greater than 0° and less than 45° or the angle is greater than 45° and less than 90° ([0049]). It would have been obvious to one skilled in the art before the effective filing date of the invention to modify Han and Seo with Cui as Cui allows a device with dual screens such that a user can select a reflective screen that reduces energy consumption of a mobile display device (Cui, [0023]). Claims 5 and 7-8 are rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1), as applied to claim 1, and further in view of O’Keeffe et al. (US 20160026061 A1). Regarding claim 5, Han teaches the electronic device of claim 1, wherein the infrared light reflective element comprises a low emissivity film (See fig. 3 wherein uni-direction infrared reflection film can have total internal reflection thereby making it low-emissivity). Han does not state the light reflective element is made of glass however O’Keeffe teaches display device wherein an infrared reflection layer can be made of glass ([0324], “infrared reflecting glass”). It would have been obvious to one skilled in the art, before the effective filing date of the invention to modify Han and Seo with O’Keeffe as this amounts to simple substitution of one known element for another to obtain predictable results. See MPEP 2143, rationale (B). Han and Seo contain a device which differed from the claimed device by the substitution of infrared reflective film with infrared glass. Substituting glass with film is well-known in the art as both Han and O’Keeffe teach the use of infrared reflective material on a display device. One of ordinary skill in the art could have substituted infrared reflective film with infrared reflective glass and the results of the substitution would have been predictable as the use of both film and glass are well-known as evidenced by the teachings of Han and O’Keeffe. Regarding claim 7, Han, Seo, and O’Keeffe teach a low emissivity glass (O’Keeffe, [0324], “infrared reflecting glass”). O’Keeffe further teaches the electronic device of claim 5, wherein a transmittance of the low emissivity glass light with wavelengths between 380 nm and 760 nm is between 50% and 90% ([0324], “solar glass (i.e. infrared absorbing/reflecting glass) … An example of a solar glass is green glass that has a visible light transmittance of 75% (or more) and absorbs about 35% of infrared in the wavelength band 0.9 to 1.3 micron.”). It would have been obvious to one skilled in the art, before the effective filing date of the invention to modify Han and Seo with O’Keeffe as this amounts to simple substitution of one known element for another to obtain predictable results. See MPEP 2143, rationale (B). Han, and Seo contain a device which differed from the claimed device by the substitution of infrared reflective film with infrared glass. Substituting glass with film is well-known in the art as both Han and O’Keeffe teach the use of infrared reflective material on a display device. One of ordinary skill in the art could have substituted infrared reflective film with infrared reflective glass and the results of the substitution would have been predictable as the use of both film and glass are well-known as evidenced by the teachings of Han and O’Keeffe. Regarding claim 8, O’Keeffe teaches wherein the low emissivity glass comprises a coating layer used to reflect at least part of light with wavelengths between 780 nm and 3000 nm ([0324], teaches glass laminate and solar glass (i.e. infrared absorbing/reflecting glass)). Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1), and O’Keeffe et al. (US 20160026061 A1), as applied to claim 5, and further in view of Wang et al. (US 20230176427 A1). Regarding claim 6, Han, Seo, and O’Keeffe teach a low emissivity glass, however, they are not relied upon for teaching the remaining claim limitations. Wang teaches a low emissivity film, wherein a transmittance of the low emissivity film to light with wavelengths between 780 nm and 3000 nm is between 5% and 35% ([0018], “The low-emissivity film is provided with a surface emissivity lower than 0.25 and a reflectivity greater than 80% to an infrared ray.” Note this means the infrared emissivity is less than 20% thereby meeting the claim limitations). It would have been obvious to one skilled in the art, before the effective filing date of the invention to modify Han, Seo, and O’Keeffe with Wang so that a display has a low emissivity glass as this allows a display to improve heat insulation performance (Wang, [0071]). Claim 19 is rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1), as applied to claim 1, and further in view of Satou et al. (US 20250264753 A1). Regarding claim 19, Han and Seo are not relied upon for teaching the claim limitations. Satou teaches an optical element that comprises an anti-UV coating layer ([0049], “ultraviolet shielding layer is a transparent film that contains an ultraviolet absorber or an ultraviolet light diffusing agent”). The combination of Han, Seo, and Wang will result in the limitation of the reflective polarizing element is disposed between the optical element and the light modulation element. Satou [0049] teaches the ultraviolet (UV) shielding layer is intended to prevent external light or sunlight from entering the display. Therefore, Satou’s UV shielding layer will be placed on or above Han’s second uni-direction infrared reflection film 150 resulting in Han’s reflection film 150 being disposed between Satou’s UV shielding layer and Han’s liquid crystal layer 130/CF substrate 110/TFT array substrate 120. It would have been obvious to one skilled in the art, before the effective filing date of the invention to modify Han and Seo with Satou to provide an ultraviolet (UV) shielding layer as Satou teaches this layer “prevents the display function layer from becoming cloudy due to sunlight or the like” (Satou, [0049]). Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Han et al. (US 20170351138 A1) in view of Seo et al. (US 20160154155 A1), as applied to claim 1, and further in view of Tanaka et al. (US 20160085002 A1). Regarding claim 20, Han teaches the electronic device of claim 1 comprising the reflective polarizing element (Fig. 1, [0028], a second uni-direction infrared reflection film 150). Han does not teach wherein the reflectivity of the reflective polarizing element to light with wavelengths between 780 nm and 3000 nm is between 5% and 50%. In an analogous art, Tanaka teaches an infrared film wherein a reflectivity of the reflective polarizing element to light with wavelengths between 780 nm and 3000 nm is between 5% and 50% ([0012], “wherein the transmittance at the center reflective wavelengths of the respective infrared reflective layers is no more than 50% and, furthermore, the reflectance is at least 30%.”). It would have been obvious to one skilled in the art, before the effective filing date of the invention to modify Han and Seo with Tanaka as to provide an infrared film with reflectivity of at least 30% as Tanaka teaches this provides an effective heat transmission or heat-shielding performance (Tanaka, Abstract). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 12038640 B1, Chen teaches at Col. 5, lines 1-27 and figure 6 an infrared light bead 15 emits infrared light which is used to head a liquid crystal layer 121 of a display panel 12 so that the display panel 12 can operate in a low-temperature environment. Any inquiry concerning this communication or earlier communications from the examiner should be directed to NATHAN P BRITTINGHAM whose telephone number is (571)270-7865. The examiner can normally be reached Monday-Thursday, 10 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, Benjamin Lee can be reached at (571) 272-2963. 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. /NATHAN P BRITTINGHAM/Primary Examiner, Art Unit 2629
Read full office action

Prosecution Timeline

Mar 24, 2025
Application Filed
Sep 24, 2026
Non-Final Rejection mailed — §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
74%
Grant Probability
91%
With Interview (+16.8%)
2y 7m (~1y 1m remaining)
Median Time to Grant
Low
PTA Risk
Based on 472 resolved cases by this examiner. Grant probability derived from career allowance rate.

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