Prosecution Insights
Last updated: April 18, 2026
Application No. 19/094,199

ELECTRONIC DEVICE INCLUDING FLEXIBLE DISPLAY AND METHOD FOR OPERATING THE SAME

Non-Final OA §DP
Filed
Mar 28, 2025
Examiner
SIMPSON, LIXI CHOW
Art Unit
2625
Tech Center
2600 — Communications
Assignee
Samsung Electronics Co., Ltd.
OA Round
1 (Non-Final)
74%
Grant Probability
Favorable
1-2
OA Rounds
2y 7m
To Grant
82%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allow Rate
625 granted / 850 resolved
+11.5% vs TC avg
Moderate +9% lift
Without
With
+9.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
15 currently pending
Career history
865
Total Applications
across all art units

Statute-Specific Performance

§101
3.0%
-37.0% vs TC avg
§103
45.0%
+5.0% vs TC avg
§102
32.0%
-8.0% vs TC avg
§112
13.5%
-26.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 850 resolved cases

Office Action

§DP
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 03/28/2025 and 10/31/2025 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. Claims 1-20 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-20 of U.S. Patent No. 12,288,486. Although the claims at issue are not identical, they are not patentably distinct from each other because the patent claims include all of the limitations of the instant application claims, respectively. The patent claims also include additional limitations. Hence, the instant application claims are generic to the species of invention covered by the respective patent claims. As such, the instant application claims are anticipated by the patent claims and are therefore not patentably distinct therefrom. (See Eli Lilly and Co. v. Barr Laboratories Inc., 58 USPQ2D 1869, "a later genus claim limitation is anticipated by, and therefore not patentably distinct from, an earlier species claim", In re Goodman, 29 USPQ2d 2010, "Thus, the generic invention is 'anticipated' by the species of the patented invention" and the instant "application claims are generic to species of invention covered by the patent claim, and since without terminal disclaimer, extant species claims preclude issuance of generic application claims"). The following is the correspondence between the Instant Application Claims and the Patent Claims: Instant Application Claims: Patent Claims: Claim 1 Claims 1 and 2 Claim 2 Claim 1 Claim 3 Claim 1 Claim 4 Claim 2 Claim 5 Claim 3 Claim 6 Claim 4 Claim 7 Claim 5 Claim 8 Claim 6 Claim 9 Claim 7 Claim 10 Claim 8 Claim 11 Claims 1 and 2, or 12 and 13 Claim 12 Claim 2 or 13 Claim 13 Claim 3 or 14 Claim 14 Claim 5 Claim 15 Claim 6 or 16 Claim 16 Claims 1 and 2, or 12 and 13 Claim 17 Claim 2 or 13 Claim 18 Claim 3 or 14 Claim 19 Claim 5 Claim 20 Claim 6 or 16 Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Ito et al. (US 2023/0070598) discloses an electronic device comprising a first housing a second housing, a first sensor for detecting the whether the electronic device is rotated and a second sensor for detecting whether the first housing is moved with respect to the second housing. Sirpal et al. (US 2012/0084694) discloses an electronic device comprising a plurality of housings and operable to display image in either portrait mode or landscape mode based on a position sensor. Any inquiry concerning this communication or earlier communications from the examiner should be directed to LIXI CHOW SIMPSON whose telephone number is (571)272-7571. The examiner can normally be reached Mon-Fri 7:00am-3:00pm. 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, William Boddie can be reached at 517-272-0666. 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. /LIXI C SIMPSON/Primary Examiner, Art Unit 2625
Read full office action

Prosecution Timeline

Mar 28, 2025
Application Filed
Dec 26, 2025
Non-Final Rejection — §DP
Apr 01, 2026
Response Filed

Precedent Cases

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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
74%
Grant Probability
82%
With Interview (+9.0%)
2y 7m
Median Time to Grant
Low
PTA Risk
Based on 850 resolved cases by this examiner. Grant probability derived from career allow rate.

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