Prosecution Insights
Last updated: April 19, 2026
Application No. 19/107,697

SYSTEM AND METHOD FOR DELIVERING COOLING WATER TO SUBMERGED DATA PROCESSING EQUIPMENT

Non-Final OA §103§112
Filed
Feb 28, 2025
Examiner
JALALI, AMIR A.
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Orca Connex AS
OA Round
1 (Non-Final)
78%
Grant Probability
Favorable
1-2
OA Rounds
2y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 78% — above average
78%
Career Allow Rate
332 granted / 424 resolved
+10.3% vs TC avg
Strong +22% interview lift
Without
With
+21.8%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
33 currently pending
Career history
457
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
57.7%
+17.7% vs TC avg
§102
28.4%
-11.6% vs TC avg
§112
10.2%
-29.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 424 resolved cases

Office Action

§103 §112
Email Communication Applicant is encouraged to authorize the Examiner to communicate via email by filing form PTO/SB/439 either via USPS, Central Fax, or EFS-Web. See MPEP 502.01, 502.02, 502.03. DETAILED ACTION Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statement filed 02/28/2025 has been fully considered and is attached hereto. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the “electrical connection” in Claim 29, “a control system” in Claim 36 must be shown or the features canceled from the claims. No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended”. If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Objections Claims 24, 39-41 are objected to because of the following lack of antecedent informalities: ● In Claim 24, Lines 8 and 14, “at least one computing device” should be changed to read - - the at least one computing device - -. ● In Claim 39, Line 6, “a computing device” should be changed to read - - the computing device - -. ● In Claim 40, Line 8, “a data center” should be changed to read - - the data center - -. ● In Claim 41, Lines 1 and 3, “at least one computing device” should be changed to read - - the at least one computing device - -. Appropriate correction is required. 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. Claim 30 is rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention. With respect to Claim 30, The term "around" in claim 30 is a relative term which renders the claim indefinite. The term "around" is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. Examiner suggest that the phrase “around” be excluded from the claims language. See; MPEP 2173.05(b)(III). 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 of this title, 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 24-43 are rejected under 35 U.S.C. § 103 as being unpatentable over Sheldon-Coulson et al (US 2019/0353139) Fig 66 in view of Fig 54. Regarding Claim 24, Sheldon-Coulson (In Fig 66) discloses a system (1100) for cooling at least one computing device (1138) using water (water, ¶ 976, II. 1-8), the system (1100) comprising: a body of water (water, ¶ 976, II. 1-8) defining a first waterline (1101), (Figs 66, 67); a structure (1102) at least partially submerged in the body of water (water, ¶ 976, II. 1-8) and comprising: an internal volume (internal volume accommodating 1127/1129/1136/1138), (Fig 66) of water (water, ¶ 1003, II. 1-5) defining a second waterline (1136), (Fig 66); a container (1129) at least partially submerged in the internal volume of water (water, ¶ 1003, II. 1-5) and comprising at least one computing device (1138) configured to generate heat in use (Fig 66); an inlet pipe (1103/1104) configured with a pump (pump, ¶ 189, II. 1-6) to move water from the body of water (water, ¶ 976, II. 1-8) to the internal volume of water (water, ¶ 1003, II. 1-5); and a flow path of water (water, ¶ 1003, II. 1-5) across the container (1129) towards the at least one outlet (Fig 66); wherein the second waterline (1136) is at a height above the first waterline (1101) to drive the flow path to provide cooling of the container (1129) and at least one computing device (1138) therein (level 1136 varies above and below level 1101 depending on over pressure present in buoy 1102 and water levels rising in response to approaching wave crest), (¶ 169, II. 1-5), (Fig 66), however Sheldon-Coulson Fig 66 does not disclose wherein at least one outlet configured to drain water from the internal volume of water to the body of water. Instead, Sheldon-Coulson (In Fig 54) teaches wherein at least one outlet (951) configured to drain water (water, ¶ 944, II. 1-11) from the internal volume (945) of water (water, ¶ 944, II. 1-11) to the body of water (927), (¶ 944, II. 1-11), (Fig 54). It would have been obvious to an ordinary skilled person in the art before the effective filling date of the claimed invention to modify Sheldon-Coulson Fig 66 with Fig 54 with at least one outlet being configured to drain water from the internal volume of water to the body of water to benefit from capturing the energy of ocean waves and converts it into electrical power in an efficient manner (Sheldon-Coulson ¶ 5, II. 9-12). Examiner Note; Claim limitation “wherein the second waterline is at a height above the first waterline” in Claim 1 does not distinguish the limitation from prior art disclosures, as Sheldon-Coulson level 1136 varies above and below level 1101 depending on over pressure present in buoy 1102 and water levels rising in response to approaching wave crest (Sheldon-Coulson, ¶ 169, II. 1-5). Regarding Claim 25, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the structure (1102) is or is part of a boat or a ship or an offshore platform or a floating structure (¶ 5, II. 9-12), (Fig 66). Regarding Claim 26, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the structure (1102) defines an internal space (internal space accommodating 1127/1129/1136/1138), wherein the internal volume of water (water, ¶ 1003, II. 1-5) and the container (1129) are in the internal space (internal space accommodating 1127/1129/1136/1138) and wherein the internal space (internal space accommodating 1127/1129/1136/1138) is sealed such that the environment within the internal space (internal space accommodating 1127/1129/1136/1138) can be controlled (¶ 240, II. 1-5, ¶ 557, II. 1-7). Regarding Claim 27, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) does not disclose wherein the at least one outlet comprises at least one flow control device configured to control the flow of water from the internal volume of water to the body of water. Instead, Sheldon-Coulson (In Fig 54) further teaches wherein the at least one outlet (951) comprises at least one flow control device (ballast-control valve, ¶ 944, II. 1-11 ) configured to control the flow of water (water, ¶ 944, II. 1-11) from the internal volume (945) of water (water, ¶ 944, II. 1-11) to the body of water (927), (¶ 944, II. 1-11), (Fig 54). It would have been obvious to an ordinary skilled person in the art before the effective filling date of the claimed invention to modify Sheldon-Coulson Fig 66 with Fig 54 with the at least one outlet comprises at least one flow control device configured to control the flow of water from the internal volume of water to the body of water to benefit from capturing the energy of ocean waves and converts it into electrical power in an efficient manner (Sheldon-Coulson ¶ 5, II. 9-12). Regarding Claim 28, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the container (1129) comprises a heat exchanger (1127) configured to remove heat from the computing device (1138), wherein the flow path of water (water, ¶ 1003, II. 1-5) across the container (1129) is at least partially across the heat exchanger (1127), (Fig 66). Regarding Claim 29, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the container (1129) comprises at least one electrical connection (connectors, ¶ 475, II. 1-6) for receiving power and/or data communications (¶ 475, II. 1-6), wherein the at least one electrical connection (connectors, ¶ 475, II. 1-6) is located on a portion of the container not submerged in water (water, ¶ 1003, II. 1-5), (Fig 66). Regarding Claim 30, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the inlet pipe (1103/1104) is between 20m and 200m long, or between 50m and 150m long, or between 75m and 125m long or around 100m long (¶ 577, II. 1-3). Regarding Claim 31, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the inlet pipe (1103/1104) is configured to move water (water, ¶ 976, II. 1-8) from a depth (d) in the body of water (water, ¶ 976, II. 1-8) which is deeper than the draught of the structure (1102), (Fig 66). Regarding Claim 32, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the inlet pipe (1103/1105) is telescopic and is configured to move between a collapsed configuration and an expanded configuration (¶ 925, II. 3-6). Regarding Claim 33, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the inlet pipe (1103/1105) is arranged to deliver water (water, ¶ 976, II. 1-8) to the internal volume (internal volume accommodating 1127/1129/1136/1138) above the second waterline (1136), (Fig 66). Regarding Claim 34, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the inlet pipe (1103/1105) is arranged to deliver water (water, ¶ 976, II. 1-8) to the internal volume (internal volume accommodating 1127/1129/1136/1138) in an upper half of the internal volume (internal volume accommodating 1127/1129/1136/1138), (Fig 66). Regarding Claim 35, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the height (h) of the second waterline (1136) above the first waterline (1101) is between 1cm and 1m, or between 1cm and 10cm, or between 4cm and 8cm, or between 5cm and 6cm (level 1136 varies above and below level 1101 depending on over pressure present in buoy 1102 and water levels rising in response to approaching wave crest (¶ 169, II. 1-5). Regarding Claim 36, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the system (1100) further comprising a control system (control system, ¶ 638, II. 4-10) configured to control the pumping of water (water, ¶ 976, II. 1-8) through the inlet pipe (1103/1105) and the draining of water (water, ¶ 976, II. 1-8) through the at least one outlet (129), such that the second waterline is maintained at a height above the first waterline, (¶ 189, II. 6-13, ¶ 638, II. 410), (Fig 66). Regarding Claim 37, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the inlet pipe (1103/1105) is configured to move water (water, ¶ 976, II. 1-8) from a depth (d) in the body of water (water, ¶ 976, II. 1-8) where the temperature of the water (water, ¶ 976, II. 1-8) is less than at the surface of the body of water (water, ¶ 976, II. 1-8), (naturally in ocean water temperature drops as depth of water increases), (Fig 66). Regarding Claim 38, Sheldon-Coulson Fig 66 in view of Fig 54 discloses the limitations of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses wherein the structure (1102) is partially opaque or fully opaque (closed-cell foam material, ¶ 847, 5-10). Regarding Claim 39, Sheldon-Coulson (In Fig 66) discloses a system (1100) for cooling a computing device (1138) using water (water, ¶ 976, II. 1-8), the system (1100) comprising: a body of water (water, ¶ 976, II. 1-8) defining a first waterline (1101); a structure (1102) at least partially submerged in the body of water (water, ¶ 976, II. 1-8) and comprising: an internal volume (internal volume accommodating 1127/1129/1136/1138), (Fig 66) of water (water, ¶ 1003, II. 1-5) defining a second waterline (1136), (Fig 66); a computing device (1138) configured to generate heat in use and at least partially submerged in the internal volume of water (water, ¶ 1003, II. 1-5); an inlet pipe (1103,1104) configured with a pump (pump, ¶ 189, II. 1-6) to move water (water, ¶ 976, II. 1-8) from the body of water (water, ¶ 976, II. 1-8) to the internal volume of water (water, ¶ 1003, II. 1-5), (Fig 66); and a flow path of water (water, ¶ 1003, II. 1-5) across the computing device (1138) towards the outlet (Fig 66); wherein the second waterline (1136) is at a height above the first waterline (1101) to drive the flow path to provide cooling of the computing device (level 1136 varies above and below level 1101 depending on over pressure present in buoy 1102 and water levels rising in response to approaching wave crest), ( ¶ 169, II. 1-5), however Sheldon-Coulson Fig 66 does not disclose wherein an outlet configured to drain water from the internal volume of water to the body of water. Instead, Sheldon-Coulson (In Fig 54) teaches wherein an outlet (951) configured to drain water (water, ¶ 944, II. 1-11) from the internal volume (945) of water (water, ¶ 944, II. 1-11) to the body of water (927), (¶ 944, II. 1-11), (Fig 54). It would have been obvious to an ordinary skilled person in the art before the effective filling date of the claimed invention to modify Sheldon-Coulson Fig 66 with Fig 54 with an outlet being configured to drain water from the internal volume of water to the body of water to benefit from capturing the energy of ocean waves and converts it into electrical power in an efficient manner (Sheldon-Coulson ¶ 5, II. 9-12). Regarding Claim 40, Sheldon-Coulson (In Fig 66) discloses a system (1100) for cooling a data center (data centers, ¶ 512, II. 1-7) using water (water, ¶ 976, II. 1-8), the system (1100) comprising: a body of water (water, ¶ 976, II. 1-8) defining a first waterline (1101), (Fig 66); a structure (1102) at least partially submerged in the body of water (water, ¶ 976, II. 1-8) and comprising: an internal volume (internal volume accommodating 1127/1129/1136/1138), (Fig 66) of water (water, ¶ 1003, II. 1-5) defining a second waterline (1136), (Fig 66); a plurality of containers (1129) each at least partially submerged in the internal volume of water (water, ¶ 1003, II. 1-5) and together comprising a data center (data centers, ¶ 512, II. 1-7) configured to generate heat in use; an inlet pipe (1103,1104) configured with a pump (pump, ¶ 189, II. 1-6) to move water (water, ¶ 976, II. 1-8) from the body of water (water, ¶ 976, II. 1-8) to the internal volume of water (water, ¶ 1003, II. 1-5); and a flow path of water (water, ¶ 1003, II. 1-5) across the plurality of containers (1129) towards the at least one outlet (Fig 66); wherein the second waterline (1136) is at a height above the first waterline (1101) to drive the flow path to provide cooling of the plurality of containers (1129) and the data center (data centers, ¶ 512, II. 1-7) therein (Fig 66), (level 1136 varies above and below level 1101 depending on over pressure present in buoy 1102 and water levels rising in response to approaching wave crest), ( ¶ 169, II. 1-5), however Sheldon-Coulson Fig 66 does not disclose wherein at least one outlet configured to drain water from the internal volume of water to the body of water. Instead, Sheldon-Coulson (In Fig 54) teaches wherein at least one outlet (951) configured to drain water (water, ¶ 944, II. 1-11) from the internal volume (945) of water (water, ¶ 944, II. 1-11) to the body of water (927), (¶ 944, II. 1-11), (Fig 54). It would have been obvious to an ordinary skilled person in the art before the effective filling date of the claimed invention to modify Sheldon-Coulson Fig 66 with Fig 54 with at least one outlet being configured to drain water from the internal volume of water to the body of water to benefit from capturing the energy of ocean waves and converts it into electrical power in an efficient manner (Sheldon-Coulson ¶ 5, II. 9-12). Regarding Claim 41, Sheldon-Coulson Fig 66 in view of Fig 54 discloses limitation of Claim 24, however Sheldon-Coulson (In Fig 66) further discloses a method of cooling at least one computing device (1138) using water (water, ¶ 976, II. 1-8), the method comprising the steps of: providing a system (1100) for cooling at least one computing device (1138 ), pumping (¶ 189, II. 1-6) water (water, ¶ 976, II. 1-8) from the body of water (water, ¶ 976, II. 1-8) to the internal volume (internal volume accommodating 1127/1129/1136/1138) of water (water, ¶ 1003, II. 1-5) to maintain the second waterline (1136) at a height above the first waterline (1101), (level 1136 varies above and below level 1101 depending on over pressure present in buoy 1102 and water levels rising in response to approaching wave crest), ( ¶ 169, II. 1-5) ; and maintaining a flow path of water (water, ¶ 1003, II. 1-5) across the container (1129) by draining water (water, ¶ 1003, II. 1-5) from the internal volume (internal volume accommodating 1127/1129/1136/1138) to the body of water (water, ¶ 976, II. 1-8) via the at least one outlet, however Sheldon-Coulson as modified does not disclose wherein at least one outlet drain water from internal volume to the body of water. Instead, Sheldon-Coulson (In Fig 54) teaches wherein at least one outlet (951) drain water (water, ¶ 944, II. 1-11) from internal volume (945) to the body of water (927), (¶ 944, II. 1-11), (Fig 54). It would have been obvious to an ordinary skilled person in the art before the effective filling date of the claimed invention to modify Sheldon-Coulson Fig 66 with Fig 54 with at least one outlet being draining water from the internal volume of water to the body of water to benefit from capturing the energy of ocean waves and converts it into electrical power in an efficient manner (Sheldon-Coulson ¶ 5, II. 9-12). Regarding Claim 42, Sheldon-Coulson Fig 66 in view of Fig 54 discloses limitation of Claim 41, however Sheldon-Coulson (In Fig 66) further discloses wherein the step of pumping water comprises pumping (¶ 189, II. 1-6) water (water, ¶ 976, II. 1-8) from a depth deeper than the draught of the structure (1102), (Fig 66). Regarding Claim 43, Sheldon-Coulson Fig 66 in view of Fig 54 discloses limitation of Claim 41, however Sheldon-Coulson (In Fig 66) wherein the step of pumping (¶ 189, II. 1-6) water (water, ¶ 976, II. 1-8) comprises pumping water from a depth in the body of water (water, ¶ 976, II. 1-8) where the water temperature is lower than at the surface of the body of water (water, ¶ 976, II. 1-8), (naturally in ocean water temperature drops as depth of water increases), (Fig 66). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure; High Power Density Server with Hybrid Thermal Management US 2023/0180428, Ocean Current Power Generation US 2016/0356261, Inertial Water Column Energy Converter US 10,634,113, Wave Energy Converter US 12,320,321. Other pertinent art made of record are on form PTO-892 notice of reference cited. Any inquiry concerning this communication or earlier communications from the examiner should be directed to AMIR JALALI whose telephone number is (303)297-4308. The examiner can normally be reached on Monday - Friday 8:30am - 5:00pm, Mountain Time. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Jayprakash Gandhi can be reached on 571-272-3740. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /AMIR A JALALI/Primary Examiner, Art Unit 2835
Read full office action

Prosecution Timeline

Feb 28, 2025
Application Filed
Jan 06, 2026
Non-Final Rejection — §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
78%
Grant Probability
99%
With Interview (+21.8%)
2y 4m
Median Time to Grant
Low
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