Prosecution Insights
Last updated: October 02, 2026
Application No. 19/309,195

ICE PROTECTION SYSTEMS FOR AIRCRAFT FUELED BY HYDROGEN

Non-Final OA §103
Filed
Aug 25, 2025
Priority
Sep 02, 2022 — continuation of 12/397,915
Examiner
CHABREYRIE, RODOLPHE ANDRE
Art Unit
3741
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
General Electric Company
OA Round
3 (Non-Final)
85%
Grant Probability
Favorable
3-4
OA Rounds
1y 3m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 85% — above average
85%
Career Allowance Rate
227 granted / 266 resolved
+15.3% vs TC avg
Strong +22% interview lift
Without
With
+22.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
20 currently pending
Career history
280
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
53.9%
+13.9% vs TC avg
§102
21.1%
-18.9% vs TC avg
§112
22.1%
-17.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 266 resolved cases

Office Action

§103
DETAILED ACTION This is in response to Applicant’s Request for Continued Examination filed on 08/20/2026 and amendment on 08/20/2026 amending Claims 1, 9, and 13; and cancelling Claim 18-19. Claims 1-17, and 20 are examined. A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 08/20/2026 has been entered. 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. Claims 1-2 are rejected under 35 U.S.C. 103 as being unpatentable over Terwilliger (US 2023/0258130) in view of Carousso (US 1,703,612). Regarding Claim 1: Terwilliger discloses a gas turbine engine (20; Fig. 1) comprising: a core air passage (see annotated figure ‘130) for air (see annotated figure ‘130) to flow therethrough in an airflow direction (see annotated figure ‘130), the air including oxygen (air includes oxygen); a combustor (502; Fig. 5) located in the core air passage and fluidly coupled to a hydrogen fuel source (508; Fig. 5) to receive hydrogen fuel ([0059]) and to combust the hydrogen fuel producing combustion gases (see annotated figure ‘130) including water vapor (water extracted to 524); a steam line (see annotated figure ‘130) fluidly coupled to the core air passage at a position (see annotated figure ‘130) downstream of the combustor relative to the airflow direction to receive a portion of the combustion gases (see annotated figure ‘130); an external surface (external surfaces of wings, lips, nacelle of the aircraft, “Abstract”) of an aircraft (“aircraft”, Abstract), the external surface having air flow over the external surface as the aircraft operates (airflow over wings, lips, nacelle ); and a conduit (see annotated figure ‘130) distinct (see annotated figure ‘130, wherein the conduit can for example be conduit in the heat exchanger 520, or the core air passage can be interpreted as stopping before the heat exchanger 520 and thus conduit being downstream of where the core air passage stopped is distinct from the passage) from the core air passage and fluidly coupled to the steam line (see annotated figure ‘130) to receive the combustion gases and to have the combustion gases flow therethrough, the conduit being thermally coupled to an exhaust-air surface (see annotated figure ‘130 wherei a surface between exhaust gases and external air 522 exists) to heat the exhaust-air surface (heat exchange is present on the exhaust-air surface) as the combustion gases flow through the conduit, wherein the combustion gases heating the exhaust-air surface (see annotated figure ‘130) receiving external air (522; Fig. 5) and results in a condensed byproduct (water in 524; Fig. 5), and wherein the conduit is fluidly coupled to a heat exchanger (524; Fig. 5) and directs the condensed byproduct to the heat exchanger (524; Fig. 5). Terwilliger is silent regarding the exhaust-air surface being the external surface. However, Carousso teaches an aircraft (aircraft Fig. 1) having a steam line (line 15; Fig. 1 carries exhaust gases with water vapor) fluidly coupled to a core air passage (air passage of engine 11; Fig. 1) at a position (see position of line 15 coming out from 11; Fig. 1) downstream of a combustor chamber (combustion chamber of 11; Fig. 1) to receive a portion of the combustion gases (exhaust gas in 15); and a conduit (conduit passing through 12 and 13; Fig. 1) fluidly coupled to the steam line (see Fig. 1) to receive the combustion gases and to have the combustion gases flow therethrough (see Fig. 1), conduit being thermally coupled to an exhaust-air surface (surface of wings 12 and 13; Fig. 1) to heat the exhaust-air surface as the combustion gases flow through the conduit (see Fig. 1), wherein the exhaust-air surface is an external surface (surface of wings 12 and 13; Fig. 1). It would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Terwilliger, to have the exhaust-air surface being the external surface, as taught by Carousso. Such a modification would enable to provide an anti-icing system to the aircraft, as recognized by Carousso (see Col. 1 L. 15-28). PNG media_image1.png 1104 816 media_image1.png Greyscale Regarding Claim 2: Terwilliger in view of Carousso teaches all the limitations of Claim 1, as stated above, and Carousso further teaches an airfoil (12, 13; Fig. 1) having a leading edge (Col. 1 L. 15-28), the external surface being the leading edge of the airfoil. Claims 3-5 are rejected under 35 U.S.C. 103 as being unpatentable over Terwilliger (US 2023/0258130) in view of Carousso (US 1,703,612), and further in view of Digeos (US 2022/0212809) Regarding Claim 3: Terwilliger in view of Carousso teaches all the limitations of claim 1, as stated above, and is silent regarding a nacelle defining an inlet, the nacelle including a lip having an outer surface, the outer surface of the lip being the external surface. However, Digeos teaches a nacelle (“nacelle” [0050]) defining an inlet (102; Fig. 1), the nacelle including a lip (102a; Fig. 1) having an outer surface (122; Fig. 2), the outer surface of the lip being the external surface to be heated for anti-icing ([0012]). It would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Terwilliger in view of Carousso, to have regarding a nacelle defining an inlet, the nacelle including a lip having an outer surface, the outer surface of the lip being the external surface, as taught by Digeos. Such a modification would enable to reduce ice accumulation on the nacelle, as recognized by Digeos ([0012]). Regarding Claim 4: Terwilliger in view of Carousso and Digeos teaches all the limitations of Claim 3, as stated above, and Digeos further teaches the lip includes a cavity (120; Fig. 2), the cavity being the conduit (see Fig. 2). Regarding claim 5: Terwilliger in view of Carousso and Digeos teaches all the limitations of Claim 3, as stated above, and Carousso further teaches the conduit is a coil (see Fig. 2) thermally coupled to the outer surface. Claims 6-8 are rejected under 35 U.S.C. 103 as being unpatentable over Terwilliger (US 2023/0258130) in view of Carousso (US 1,703,612), and further in view of Prather (US 2016/0097323) Regarding Claim 6: Terwilliger in view of Carousso teaches all the limitations of Claim 1, as stated above, but is silent regarding a splitter separating an inlet from a bypass airflow passage, the splitter including a lip having an outer surface, the outer surface of the lip being the external surface. However, Prather teaches a splitter (38; Fig. 1) separating an inlet (inlet through 24; Fig. 1) from a bypass airflow passage (106; Fig. 1), the splitter including a lip (44; Fig. 2) having an outer surface (42; Fig. 2), the outer surface of the lip being the external surface (see Fig. 2). It would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified Terwilliger in view of Carousso, to have a splitter separating an inlet from a bypass airflow passage, the splitter including a lip having an outer surface, the outer surface of the lip being the external surface, as taught by Prather. Such a modification would enable to reduce ice accumulation on the splitter, as recognized by Prather ([0017]). Regarding Claim 7: Terwilliger in view of Carousso and Prather teaches all the limitations of Claim 6, as stated above, and Prather further teaches the lip includes a cavity (56; Fig. 2), the cavity being the conduit (Fig. 2). Regarding claim 8: Terwilliger in view of Carousso and Prather teaches all the limitations of Claim 6, as stated above, and Carousso further teaches the conduit is a coil (see Fig. 2) thermally coupled to the outer surface. Allowable subject matter Regarding Claims 9 -17 and 20: Claims 9 -17 and 20 are allowed. The following is a statement of reasons for the indication of allowable subject matter: Prior art fails to teach “a first steam line fluidly coupled to the core air passage upstream of the heat exchanger relative to the airflow direction to receive a first portion of the combustion gases, the first steam line to deliver the water vapor from the core air passage to an ice protection system thermally coupled to an external surface of an aircraft” (for Claim 9)“an ice protection system, the at least one nozzle being a part of the ice protection system; and a controller configured to activate the ice protection system to discharge the condensed water from the at least one nozzle.” (for Claim 13). Response to Arguments Applicant’s remarks filed 08/20/2026 with respect to Claims 1 have been considered but are not persuasive for the following reasons: Applicant’s Representative asserts that the Prior Art of record fails to teach the conduit being distinct from the core air passage. However, the claim language does not forbid interpreting the core air passage as stooping before heat exchanger 520 and the conduit to start where the passage stopped, or to interpret the conduit as starting inside the heat exchanger 520 and thus to have the conduit and passage distinct. Consequently, the Prior Art of record teaches the conduit being distinct from the core air passage. Pertinent Prior Art The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Please see notice of references cited. 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 extension fee 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 date of this final action. Contact Information Any inquiry concerning this communication or earlier communications from the examiner should be directed to RODOLPHE ANDRE CHABREYRIE whose telephone number is (571)272-3482. The examiner can normally be reached on 8:30-18:30. 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, Steven Crabb can be reached on (571) 270-5095. 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. /RODOLPHE ANDRE CHABREYRIE/Primary Examiner, Art Unit 3761
Read full office action

Prosecution Timeline

Show 1 earlier event
Feb 13, 2026
Non-Final Rejection mailed — §103
May 07, 2026
Response Filed
Jun 03, 2026
Final Rejection mailed — §103
Jul 27, 2026
Response after Non-Final Action
Aug 20, 2026
Request for Continued Examination
Aug 21, 2026
Response after Non-Final Action
Sep 09, 2026
Examiner Interview (Telephonic)
Sep 15, 2026
Non-Final Rejection mailed — §103 (current)

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

3-4
Expected OA Rounds
85%
Grant Probability
99%
With Interview (+22.0%)
2y 4m (~1y 3m remaining)
Median Time to Grant
High
PTA Risk
Based on 266 resolved cases by this examiner. Grant probability derived from career allowance rate.

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