Prosecution Insights
Last updated: April 19, 2026
Application No. 19/257,336

LIQUID MEMS COOLING SYSTEM

Final Rejection §103§112
Filed
Jul 01, 2025
Examiner
PAPE, ZACHARY
Art Unit
2835
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Frore Systems Inc.
OA Round
2 (Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
2y 5m
To Grant
92%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
792 granted / 1094 resolved
+4.4% vs TC avg
Strong +20% interview lift
Without
With
+19.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
33 currently pending
Career history
1127
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
46.5%
+6.5% vs TC avg
§102
27.9%
-12.1% vs TC avg
§112
19.7%
-20.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1094 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 . 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, 502.05. Examiner’s Notes At least claims 1 and 16 have been granted an effective filing date of 4/3/2025 as these claims are supported by the provisional application filed on that date. Claim 17 does not have the correct status identifier. In the interest of compact prosecution, claim 17 is considered to have the status identifier “(Withdrawn – Currently Amended)” Applicant should also note that claim 17, Lines 4-5, 14 recite, “the inlet” which is incorrect. It appears it should be changed to read, “the at least one inlet”. Specification The objection to the specification is withdrawn in view of the amendment to the title. Claim Objections Claims 1-8, 15-16 are objected to because of the following informalities: Claim 1, Line 6 recites, “the inlet” which is incorrect. It appears it should be changed to read, “the at least one inlet”. Claim 1, Line 16 recites, “the inlet” which is incorrect. It appears it should be changed to read, “the at least one inlet”. Claim 1, Line 16 recites, “the inlet” which is incorrect. It appears it should be changed to read, “the at least one inlet”. Claim 1, Line 7 recites, “the outlet” which is incorrect. It appears it should be changed to read, “the at least one outlet”. Claim 6, Line 6 recites, in two instances, “the inlet” which is incorrect. It appears it should be changed to read, “the at least one inlet”. Claim 16, Line 15 recites, “the inlet” which is incorrect. It appears it should be changed to read, “the at least one inlet”. Claims 2-5, 7-8, 15 are objected to since they depend from claim 1 and inherit the deficiencies therein. Appropriate correction is required. 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: Limitations of claim 8 Limitations of claim 9 must be shown or the feature(s) canceled from the claim(s). 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 the 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 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. Claim 8-9, 11-14, 21 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. Claim 8 recites, “each of the plurality of jet channels has a first portion coupled to the manifold, a second portion at a first nonzero angle from the first portion, and a third portion coupled to the manifold and oriented at a second nonzero angle from the second portion, the third portion being coupled with the at least one outlet” which is unclear. The drawings do not appear to show these limitations and while the written description does appear to address this limitation in ¶ 0022, there is not enough context here to provide an understanding for the claim. Para ¶ 0045 of the written description does also use the word, “nonzero” however this is in regards to how the inlet manifold channels and outlet manifold channels are oriented with respect to the jet channel. Claim 9 recites, “a manifold coupled to the at least one inlet and the at least one outlet; and a plurality of adjacent cells, each of the plurality of adjacent cells including a plurality of jet channels coupled to the manifold” which is unclear. Figs 7A, 7B of the drawings are believed to be pertinent. Here, it is disclosed that each cell (701) has its own manifold (740), not that one manifold serves a plurality of cells, as claimed. In view of Figs 7A, 7B, it appears that claim 9 could be amended to recite A liquid cooling system, comprising: at least one inlet; at least one outlet; a plurality of manifolds coupled to the at least one inlet and the at least one outlet; and a plurality of adjacent cells, each of the plurality of adjacent cells including a plurality of jet channels coupled to a respective one of the plurality of s, the plurality of jet channels being microchannels, a portion of each of the plurality of jet channels being proximate to a heat-generating structure, the plurality of jet channels being configured such that a boundary layer in a liquid at a surface of a jet channel of the plurality of jet channels is not substantially developed within at least the portion of the jet channel proximate to the heat-generating structure, the plurality of jet channels being configured to receive fluid from the at least one inlet through the respective one of the plurality of manifolds and to provide the fluid through the respective one of the plurality of manifolds to the at least one outlet; wherein the plurality of manifolds includeeach of the plurality of manifolds including the outer manifold; wherein at least one of the plurality of jet channels or the plurality of manifolds is configured to compensate for heating of the liquid in the liquid cooling system. The above proposal clarifies that there is a manifold for each cell as shown in Figs 7A, 7B. For the purposes of examination, claim 9 will be considered as written by the Applicant. Claims 11-14, 21 depend from claim 9 and thus inherit the deficiencies therein. Applicant must either amend the claims or clarify their scope. 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claims 9, 11-13, 21, as best understood by the Examiner, are rejected under 35 U.S.C. 103 as being unpatentable over Zhou (US 11,239,137) in view of Li et al. (US 9,434,029 – hereinafter, “Li”) and further in view of Kang (US 2014/0268571). With respect to claim 9, Zhou teaches (In Fig 4C) a liquid cooling system, comprising: at least one inlet (66); at least one outlet (62); a manifold (50) coupled to the at least one inlet and the at least one outlet; and a plurality of adjacent cells (22), each of the plurality of adjacent cells including a plurality of jet channels (22, Col. 10, ll. 8-9, “fluid microchannels 22 of the plurality of jet impingement fin assemblies”) coupled to the manifold (The cells form jet channels that are fluidically coupled to 50), the plurality of jet channels being microchannels (Col. 10, ll. 8, “fluid microchannels 22”), a portion of each of the plurality of jet channels being proximate to a heat-generating structure (48), the plurality of jet channels (22) being configured to receive fluid from the at least one inlet (66) through the manifold (56b of 50) and to provide the fluid through the manifold to the at least one outlet (62, via 56a); wherein the manifold includes a central shaft (21) for each of the plurality of adjacent cells, the central shaft being coupled to the inlet and through which the liquid passes (Liquid enters the inlet (66), passes through the manifold 50 and then passes into the shaft (21)), wherein each of the plurality of jet channels is configured to carry the liquid from the central shaft (21) to an outer manifold (56a) or from the outer manifold to the central shaft, the manifold including the outer manifold (56a, Col. 8, ll. 35-37, “That is, the example cooling manifold 50 may be manufactured to include an inlet cavity 56b and an outlet cavity 56a” where the inlet cavity is a cavity designed to spread the liquid to the shafts (21) and the outlet cavity is a cavity designed to collect the liquid upon the liquid exiting the cells 22). Zhou fails to specifically teach or suggest the plurality of jet channels being configured such that a boundary layer in a liquid at a surface of a jet channel of the plurality of jet channels is not substantially developed within at least the portion of the jet channel proximate to the heat-generating structure and wherein at least one of the plurality of jet channels or the manifold is configured to compensate for heating of the liquid in the liquid cooling system. Li, however, teaches a plurality of jet channels (105, 105’, 107), the plurality of jet channels being configured such that a boundary layer in a liquid at a surface of a jet channel of the plurality of jet channels is not substantially developed within at least the portion of the jet channel proximate to the heat-generating structure (Applicant, at ¶ 0033 defines a not substantially developed boundary layer as, at least in part, a boundary layer which is thinned, “Jet channels 130 are configured such that a boundary layer in a liquid at a surface of a jet channel is not substantially developed within at least the portion of the jet channel proximate to heat-generating structure 102. For example, the boundary layer may have apertures therein, be thinned, and/or not be present in the portion of the jet channel proximate to heat- generating structure 102.” (emphasis added), and Li, at Col. 2, ll. 34-40 recites that the boundary layer within the jet channels are “very thin” (“The fluid that is in contact with the heater plate 109, may travel only a few hundred microns before exiting into the ambient, since the dimensions of individual incoming micro channel jets 105, 105′ and the outgoing micro channel jets 107 of the micro channel jet array 102 are on the order of microns in size, thus keeping the thermal boundary layer very thin.” (emphasis added)) thus Li discloses a very thin boundary layer within the entirety of the jet channel and thus also within at least the portion of the jet channel proximate to the heat-generating structure, meeting the limitation.). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Li with that of Zhou such that, in Zhou the plurality of jet channels being configured such that a boundary layer in a liquid at a surface of a jet channel of the plurality of jet channels is not substantially developed within at least the portion of the jet channel proximate to the heat-generating structure, as taught by Li, since doing so would increase heat transfer between the walls of the jet channels and the fluid passing therethrough. With respect to the limitations which required wherein at least one of the plurality of jet channels or the manifold is configured to compensate for heating of the liquid in the liquid cooling system, Kang teaches a manifold which is configured to compensate for heating of a liquid in a liquid cooling system (¶ 0006, “the manifold elements may be made of a thermally insulating or otherwise low thermal conductivity material”). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Kang with that of Zhou, such that at least one of the plurality of jet channels or the manifold is configured to compensate for heating of the liquid in the liquid cooling system, as taught by Kang, since doing so would allow for the manifold of Chang to be relatively inexpensive and specially tailored to corresponding heat generating components (Kang: ¶ 0006). With respect to claim 11, Zhou further teaches wherein the plurality of jet channels (22) is oriented radially from the central shaft (20) to the outer manifold (56a, see Fig 4C). With respect to claims 12-13, Zhou further teaches wherein the liquid cooling system (24) has a hexagonal footprint (Col. 5, ll. 24-28, “In other embodiments, the array of fins 24 extend radially from the inner terminating surface 26 or from the impingement receiving portion 20 to form different irregular and regular outer perimeter shapes, such as a hexagonal, rectangular, circular, and the like.”) wherein the cooling system is one of a plurality of cooling systems having the hexagonal footprint and configured with sides that are adjacent (See Fig 4C which shows multiple cooling systems (24) which have adjacent sides and which, as per col. 5, ll. 24-28, could be hexagonal in nature). With respect to claim 21, Zhou further teaches an inlet plenum (60) coupled with the manifold (50) and providing the plurality of jet channels in each of the plurality of adjacent cells with the fluid from the inlet plenum through the central shaft of the manifold (Fluid flows from the inlet (66) into the plenum (60) into the manifold (50) and into the central shaft (21)); and an outlet plenum (58) coupled with the manifold (50) and receiving the fluid from the plurality of jet channels of the plurality of adjacent cells through the outer manifold (Fluid flows from the outlets of the jet channels into the manifold (50) and into the outlet plenum (58) before exiting the outlet (62)). Claim 14, as best understood by the Examiner, is rejected under 35 U.S.C. 103 as being unpatentable over Zhou in view of Li in view of Kang and further in view of Brunschwiler et al. (US 2009/0234705 – hereinafter, “Brunschwiler”). With respect to claim 14, Zhou as modified by Li and Kang teaches the limitations of claim 13 as per above but fails to specifically teach or suggest at least one of a width or height of the central shaft may be varied between individual cooling systems for at least one of to compensate for heating of the liquid as the liquid travels through the cooling system or based on hot spots in the heat-generating structure. Brunschwiler, however, teaches using different nozzle diameters to allow for increased flow at location of hot spots (¶ 0039, “By utilizing the different nozzle diameters to allow increased flow at the location of hot spots 56”). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to combine the teachings of Brunschwiler with that of Zhou as modified by Li and Kang, such that, in Kang at least one of a width or height of the central shaft (Nozzle shaft 21) may be varied between individual cooling systems for at least one of to compensate for heating of the liquid as the liquid travels through the cooling system or based on hot spots in the heat-generating structure, as suggested by Brunschwiler, since doing so would allow for the cooling systems of Kang to have shafts which can deliver more coolant to hot spot regions of the heat generating structure thus providing for better overall cooling of the heat generating structure by the cooling systems. Allowable Subject Matter Claims 1-7, 15-16, pending correction of the above-mentioned claim objections, are allowed. The following is an examiner’s statement of reasons for allowance: With respect to claims 1-7, 15, the allowability resides in the overall structure of the device as recited in independent claim 1 and at least in part because claim 1 recites, “a manifold including a plurality of inlet manifold channels coupled to the at least one inlet and a plurality of outlet manifold channels coupled to the at least one outlet, the plurality of inlet manifold channels having a first pitch proximate to the inlet, the plurality of outlet manifold channels having a second pitch proximate to the outlet, the first pitch being greater than the second pitch… the plurality of jet channels having a first jet channel pitch proximate to the inlet and a second jet channel pitch less than the first jet channel pitch proximate to the at least one outlet”. The aforementioned limitations in combination with all remaining limitations of claim 1 are believed to render said claim 1 and all claims dependent therefrom patentable over the art of record. With respect to claim 16, the allowability resides in the overall structure of the device as recited in independent claim 16 and at least in part because claim 16 recites, “the inlet manifold including a plurality of inlet manifold channels having a first pitch, the outlet manifold including a plurality of outlet manifold channels having a second pitch less than the first pitch…the plurality of jet channels having a first jet channel pitch proximate to the inlet and a second jet channel pitch less than the first jet channel pitch proximate to the at least one outlet”. The aforementioned limitations in combination with all remaining limitations of claim 16 are believed to render said claim 16 patentable over the art of record. See pp. 14-16 of the Applicant’s remarks dated 3/10/2026. Any comments considered necessary by applicant must be submitted no later than the payment of the issue fee and, to avoid processing delays, should preferably accompany the issue fee. Such submissions should be clearly labeled “Comments on Statement of Reasons for Allowance.” Response to Arguments With respect to the Applicant’s remarks to the drawings that Figs 2F-2G, 4B, 4C show the limitations of claim 8 (Present remarks pages 11-12) the Examiner respectfully disagrees. None of the cited figures show that the jet channels (230, 430C, 430D) have a first portion coupled to the manifold, a second portion at a first nonzero angle from the first portion, and a third portion coupled to the manifold and oriented at a second nonzero angle from the second portion, as required by claim 8. The cited figures only appear to show the jet channels as a horizontal channel, not as a channel which has two perpendicular portions connected to a horizontal portion (As required by claim 8). Applicant suggests that a portion of the manifold inlet channel can be considered part of the jet channel (“the manifold inlet channel (and arguably a portion of the corresponding jet channel) is perpendicular to plane and directs flow substantially perpendicular to the jet channels 230”) however the Examiner respectfully disagrees with this. As per ¶ 0045 of the written description, the inlet manifold channel 250 and the outlet manifold channels 260 are substantially perpendicular to the jet channel 230. How can the inlet manifold channel and the outlet manifold channels be substantially perpendicular to the jet channels if portions of the jet channels are also vertical? Accordingly, the drawing objection is maintained. With respect to the Applicant’s remarks to the 112 rejection to claim 8 (Present remarks pages 12-13) the Examiner respectfully disagrees. None of the cited figures (2F-2G, 4B, 4C, see the above response to arguments with respect to the drawing objection) nor any of the written description passages thereto are believed to properly describe the limitations of claim 8 which requires that the jet channels include two vertical portions which are perpendicular to the shown horizontal channels (230). Accordingly, the Examiner is unable to understand this claim in the context of the specification. Accordingly, the 112(b) rejection to claim 8 is maintained. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZACHARY M PAPE whose telephone number is (571)272-2201. The examiner can normally be reached M-F: 9am - 6pm 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, Jayprakash N Gandhi can be reached at 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 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. /ZACHARY PAPE/Primary Examiner, Art Unit 2835
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Prosecution Timeline

Jul 01, 2025
Application Filed
Dec 04, 2025
Non-Final Rejection — §103, §112
Mar 09, 2026
Applicant Interview (Telephonic)
Mar 09, 2026
Examiner Interview Summary
Mar 10, 2026
Response Filed
Mar 23, 2026
Final Rejection — §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
72%
Grant Probability
92%
With Interview (+19.9%)
2y 5m
Median Time to Grant
Moderate
PTA Risk
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