Prosecution Insights
Last updated: August 17, 2026
Application No. 19/420,378

SOLE STRUCTURE FOR ARTICLE OF FOOTWEAR

Non-Final OA §103
Filed
Dec 15, 2025
Priority
Jan 02, 2019 — provisional 62/787,628 +4 more
Examiner
SMITH, HALEY ANNE
Art Unit
3732
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Nike Inc.
OA Round
1 (Non-Final)
57%
Grant Probability
Moderate
1-2
OA Rounds
1y 10m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 57% of resolved cases
57%
Career Allowance Rate
133 granted / 235 resolved
-13.4% vs TC avg
Strong +58% interview lift
Without
With
+58.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 6m
Avg Prosecution
31 currently pending
Career history
269
Total Applications
across all art units

Statute-Specific Performance

§101
3.3%
-36.7% vs TC avg
§103
47.5%
+7.5% vs TC avg
§102
23.9%
-16.1% vs TC avg
§112
20.2%
-19.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 235 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 . 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. Claim(s) 1-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Cortez et al. (US 2016/0120263) in view of Connell et al. (US 2018/0213886). Regarding Claim 1, Cortez et al. teaches a sole structure (10) for an article of footwear (12), the sole structure comprising: a foam element (18) extending from a forefoot region (30) to a heel region (28) and having an upper surface (54) and a lower surface (56) formed on an opposite side of the foam element from the upper surface (fig. 1 shows the upper surface (54) opposite the lower surface (56); paragraph [0090] teaches “The second resilient midsole layer 18 may be a polymer foam material”); a first columnar fluid-filled chamber (74B) (fig. 1 does not show the fluid filled chamber, however paragraph [0095] teaches “additional bladder elements can be placed in the recesses 74B, 74C,” and as the recess is columnar a bladder element placed therein would also clearly be columnar. For clarity, the first columnar bladder will herein be referred to as (74B)); and a posterior fluid-filled chamber (16) disposed closer to a heel region of the sole structure than the first columnar fluid-filled chamber (fig. 1 shows the posterior fluid filled chamber being disposed closer to a heel region of the sole structure than the first columnar fluid filled chamber) and including a first leg (26A) extending along one of a medial side of the sole structure and a lateral side of the sole structure, a second leg (26B) extending along the other of the medial side of the sole structure and the lateral side of the sole structure (fig. 1 shows the first (26A) and second (26B) legs extending along the medial and lateral sides of the sole structure, respectively), and an arcuate segment (24) extending between and connecting the first leg and the second leg (fig. 1 shows the arcuate segment (24) extending between and connecting the first (26A) and second (26B) legs), one of the first leg and the second leg being aligned with the first columnar fluid-filled chamber across a width of the sole structure (fig. 2 shows the second leg (26B) being aligned with the first columnar fluid filled chamber (74B) across a width of the sole structure). Cortez et al. does not teach wherein the first columnar fluid-filled chamber includes a proximal end attached to the lower surface of the foam element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that the first columnar fluid-filled chamber includes a proximal end attached to the lower surface of the foam element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end so as to ensure the first columnar fluid filled chamber stays in place and allows for proper cushioning of the wearer’s foot. Regarding Claim 2, Cortez et al. teaches all of the limitations of the sole structure of Claim 1, as discussed in the rejections above. Cortez et al. further teaches wherein the one of the first leg (26B) and the second leg is longer than the other of the first leg and the second leg (26A) (figs. 2 and 20 show the second lateral leg (26B) being longer than the first leg (26A)). Regarding Claim 3, Cortez et al. teaches all of the limitations of the sole structure of Claim 2, as discussed in the rejections above. Cortez et al. further teaches wherein the other of the first leg and the second leg (26A) includes a distal end (48A) that opposes the first columnar fluid-filled chamber (74B) (figs. 1 and 2 show the distal end (48A) of the first leg (26A) opposing the first columnar fluid filled chamber (74B)). Regarding Claim 4, Cortez et al. teaches all of the limitations of the sole structure of Claim 3, as discussed in the rejections above. Cortez et al. further teaches wherein the distal end (48A) of the other of the first leg and the second leg (26A) is spaced apart from the first columnar fluid-filled chamber (74B) (figs. 1 and 2 how the distal end (48A) of the first leg (26A) being spaced from the first columnar fluid filled chamber (74B)). Regarding Claim 5, Cortez et al. teaches all of the limitations of the sole structure of Claim 1, as discussed in the rejections above. Cortez et al. does not teach a second columnar fluid-filled chamber disposed between the first columnar fluid-filled chamber and an anterior end of the sole structure. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end). Connell et al. further teaches a second columnar fluid-filled chamber (124) disposed between the first columnar fluid-filled chamber (126, 128) and an anterior end of the sole structure (fig. 22 shows the second columnar fluid filled chamber (124) disposed between the first chamber (126, 128) and the anterior end of the sole). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that the sole structure further includes a second columnar fluid-filled chamber disposed between the first columnar fluid-filled chamber and an anterior end of the sole structure so as to allow tailored cushioning for the wearer in different regions of the foot. Regarding Claim 6, Cortez et al. teaches all of the limitations of the sole structure of Claim 5, as discussed in the rejections above. Cortez et al. further teaches a third columnar fluid-filled chamber disposed adjacent to the second columnar fluid-filled chamber (fig. 1 does not show the third fluid filled chamber, however paragraph [0095] teaches “additional bladder elements can be placed in the recesses 74B, 74C,” and as the recess is columnar a bladder element placed therein would also clearly be columnar. For clarity, the third columnar bladder will herein be referred to as (74C)). Regarding Claim 7, Cortez et al. teaches all of the limitations of the sole structure of Claim 6, as discussed in the rejections above. Cortez et al. further teaches wherein the first columnar fluid-filled chamber (74B) is disposed along one of the medial side of the sole structure and the lateral side of the sole structure and the third columnar fluid-filled chamber (74C) is disposed along the other of the medial side of the sole structure and the lateral side of the sole structure (fig. 1 shows the first (74B) and second (74C) columnar fluid filled bladder is disposed along the medial and lateral sides, respectively, of the sole). Cortez et al. does not teach wherein the second columnar fluid-filled chamber is disposed along one of the medial side of the sole structure and the lateral side of the sole structure. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end), and a second columnar fluid-filled chamber (124) disposed between the first columnar fluid-filled chamber (126, 128) and an anterior end of the sole structure (fig. 22 shows the second columnar fluid filled chamber (124) disposed between the first chamber (126, 128) and the anterior end of the sole), and a third columnar fluid-filled chamber (122) disposed adjacent to the second columnar fluid-filled chamber (fig. 22 shows the third chamber (122) disposed adjacent the second chamber (124)). Connell et al. further teaches wherein the first columnar fluid-filled chamber and the second columnar fluid-filled chamber are disposed along one of the medial side of the sole structure and the lateral side of the sole structure (fig. 22 shows the first (126, 128) and second (124) chambers being disposed along one of the medial and lateral sides of the sole structure) and the third columnar fluid-filled chamber is disposed along the other of the medial side of the sole structure and the lateral side of the sole structure (fig. 22 shows the third chamber (122) being disposed along the other of the medial and the lateral side of the sole structure). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that the second columnar fluid-filled chamber is disposed along one of the medial side of the sole structure and the lateral side of the sole structure so as to allow specific cushioning to correct for pronation or supination of the wearer’s foot. Regarding Claim 8, Cortez et al. teaches all of the limitations of the sole structure of Claim 7, as discussed in the rejections above. Cortez et al. further teaches wherein a distal end (48B) of the one of the first leg and the second leg (26B) opposes the third columnar fluid-filled chamber (74C) (fig. 1 shows the distal end (48B) of the second leg (26B) opposing the third columnar fluid filled chamber (74C)). Regarding Claim 9, Cortez et al. teaches all of the limitations of the sole structure of Claim 6, as discussed in the rejections above. Cortez et al. does not teach wherein at least one of the first columnar fluid-filled chamber, the second columnar fluid-filled chamber, and the third columnar fluid-filled chamber includes a first fluid-filled chamber stacked on top of a second fluid-filled chamber, the first fluid- filled chamber being fluidly isolated from the second fluid-filled chamber. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end), and a second columnar fluid-filled chamber (124) disposed between the first columnar fluid-filled chamber (126, 128) and an anterior end of the sole structure (fig. 22 shows the second columnar fluid filled chamber (124) disposed between the first chamber (126, 128) and the anterior end of the sole), and a third columnar fluid-filled chamber (122) disposed adjacent to the second columnar fluid-filled chamber (fig. 22 shows the third chamber (122) disposed adjacent the second chamber (124)). Connell et al. further teaches wherein at least one of the first columnar fluid-filled chamber (126, 128), the second columnar fluid-filled chamber, and the third columnar fluid-filled chamber includes a first fluid-filled chamber stacked on top of a second fluid-filled chamber, the first fluid- filled chamber being fluidly isolated from the second fluid-filled chamber (fig. 22 shows the first columnar fluid filled chamber including a first and second stacked chamber, the chambers being fluidly isolated from one another; paragraph [0164] teaches “the third fluid-filled chamber 126 may include the same or different pressure as the fourth fluid-filled chamber 128 and may likewise be fluidly isolated from the fourth fluid-filled chamber 128.”). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that at least one of the first columnar fluid-filled chamber, the second columnar fluid-filled chamber, and the third columnar fluid-filled chamber includes a first fluid-filled chamber stacked on top of a second fluid-filled chamber, the first fluid- filled chamber being fluidly isolated from the second fluid-filled chamber so as to allow the first and second chambers to be inflated to different pressures therein providing a unique cushioning profile for the wearer (paragraph [0164] teaches “the third fluid-filled chamber 126 may include the same or different pressure as the fourth fluid-filled chamber 128 and may likewise be fluidly isolated from the fourth fluid-filled chamber 128.”). Regarding Claim 10, Cortez et al. teaches all of the limitations of the sole structure of Claim 1, as discussed in the rejections above. Cortez et al. further teaches wherein the arcuate segment (24) extends along a posterior end of the sole structure (fig. 1 shows the arcuate segment (24) extending along a posterior end of the sole; paragraph [0089] teaches “the heel portion 24 supported at the peripheral region 22 at the heel region 28”). Regarding Claim 11, Cortez et al. teaches a sole structure (10) for an article of footwear (12), the sole structure comprising: a foam element (18) extending from a forefoot region (30) to a heel region (28) and having an upper surface (54) and a lower surface (56) formed on an opposite side of the foam element from the upper surface (fig. 1 shows the upper surface (54) opposite the lower surface (56); paragraph [0090] teaches “The second resilient midsole layer 18 may be a polymer foam material”); a first columnar fluid-filled chamber (74B) (fig. 1 does not show the fluid filled chamber, however paragraph [0095] teaches “additional bladder elements can be placed in the recesses 74B, 74C,” and as the recess is columnar a bladder element placed therein would also clearly be columnar. For clarity, the first columnar bladder will herein be referred to as (74B)); and a posterior fluid-filled chamber (16) disposed closer to a heel region of the sole structure than the first columnar fluid-filled chamber (fig. 1 shows the posterior fluid filled chamber being disposed closer to a heel region of the sole structure than the first columnar fluid filled chamber) and including a first leg (26A) extending along one of a medial side of the sole structure and a lateral side of the sole structure, a second leg (26B) extending along the other of the medial side of the sole structure and the lateral side of the sole structure (fig. 1 shows the first (26A) and second (26B) legs extending along the medial and lateral sides of the sole structure, respectively), and an arcuate segment (24) extending between and connecting the first leg and the second leg (fig. 1 shows the arcuate segment (24) extending between and connecting the first (26A) and second (26B) legs), one of the first leg and the second leg extending in a direction toward an anterior end of the sole structure past at least a portion of the first columnar fluid-filled chamber (fig. 2 shows the second leg (26B) extending towards the anterior end and past the first columnar fluid filled chamber (74B)). Cortez et al. does not teach wherein the first columnar fluid-filled chamber includes a proximal end attached to the lower surface of the foam element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that the first columnar fluid-filled chamber includes a proximal end attached to the lower surface of the foam element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end so as to ensure the first columnar fluid filled chamber stays in place and allows for proper cushioning of the wearer’s foot. Regarding Claim 12, Cortez et al. teaches all of the limitations of the sole structure of Claim 11, as discussed in the rejections above. Cortez et al. further teaches wherein the one of the first leg (26B) and the second leg is longer than the other of the first leg and the second leg (26A) (figs. 2 and 20 show the second lateral leg (26B) being longer than the first leg (26A)). Regarding Claim 13, Cortez et al. teaches all of the limitations of the sole structure of Claim 12, as discussed in the rejections above. Cortez et al. further teaches wherein the other of the first leg and the second leg (26A) includes a distal end (48A) that opposes the first columnar fluid-filled chamber (74B) (figs. 1 and 2 show the distal end (48A) of the first leg (26A) opposing the first columnar fluid filled chamber (74B)). Regarding Claim 14, Cortez et al. teaches all of the limitations of the sole structure of Claim 13, as discussed in the rejections above. Cortez et al. further teaches wherein the distal end (48A) of the other of the first leg and the second leg (26A) is spaced apart from the first columnar fluid-filled chamber (74B) (figs. 1 and 2 how the distal end (48A) of the first leg (26A) being spaced from the first columnar fluid filled chamber (74B)). Regarding Claim 15, Cortez et al. teaches all of the limitations of the sole structure of Claim 11, as discussed in the rejections above. Cortez et al. does not teach a second columnar fluid-filled chamber disposed between the first columnar fluid-filled chamber and the anterior end of the sole structure. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end). Connell et al. further teaches a second columnar fluid-filled chamber (124) disposed between the first columnar fluid-filled chamber (126, 128) and an anterior end of the sole structure (fig. 22 shows the second columnar fluid filled chamber (124) disposed between the first chamber (126, 128) and the anterior end of the sole). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that the sole structure further includes a second columnar fluid-filled chamber disposed between the first columnar fluid-filled chamber and an anterior end of the sole structure so as to allow tailored cushioning for the wearer in different regions of the foot. Regarding Claim 16, Cortez et al. teaches all of the limitations of the sole structure of Claim 15, as discussed in the rejections above. Cortez et al. further teaches a third columnar fluid-filled chamber disposed adjacent to the second columnar fluid-filled chamber (fig. 1 does not show the third fluid filled chamber, however paragraph [0095] teaches “additional bladder elements can be placed in the recesses 74B, 74C,” and as the recess is columnar a bladder element placed therein would also clearly be columnar. For clarity, the third columnar bladder will herein be referred to as (74C)). Regarding Claim 17, Cortez et al. teaches all of the limitations of the sole structure of Claim 16, as discussed in the rejections above. Cortez et al. further teaches wherein the first columnar fluid-filled chamber (74B) is disposed along one of the medial side of the sole structure and the lateral side of the sole structure and the third columnar fluid-filled chamber (74C) is disposed along the other of the medial side of the sole structure and the lateral side of the sole structure (fig. 1 shows the first (74B) and second (74C) columnar fluid filled bladder is disposed along the medial and lateral sides, respectively, of the sole). Cortez et al. does not teach wherein the second columnar fluid-filled chamber is disposed along one of the medial side of the sole structure and the lateral side of the sole structure. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end), and a second columnar fluid-filled chamber (124) disposed between the first columnar fluid-filled chamber (126, 128) and an anterior end of the sole structure (fig. 22 shows the second columnar fluid filled chamber (124) disposed between the first chamber (126, 128) and the anterior end of the sole), and a third columnar fluid-filled chamber (122) disposed adjacent to the second columnar fluid-filled chamber (fig. 22 shows the third chamber (122) disposed adjacent the second chamber (124)). Connell et al. further teaches wherein the first columnar fluid-filled chamber and the second columnar fluid-filled chamber are disposed along one of the medial side of the sole structure and the lateral side of the sole structure (fig. 22 shows the first (126, 128) and second (124) chambers being disposed along one of the medial and lateral sides of the sole structure) and the third columnar fluid-filled chamber is disposed along the other of the medial side of the sole structure and the lateral side of the sole structure (fig. 22 shows the third chamber (122) being disposed along the other of the medial and the lateral side of the sole structure). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that the second columnar fluid-filled chamber is disposed along one of the medial side of the sole structure and the lateral side of the sole structure so as to allow specific cushioning to correct for pronation or supination of the wearer’s foot. Regarding Claim 18, Cortez et al. teaches all of the limitations of the sole structure of Claim 17, as discussed in the rejections above. Cortez et al. further teaches wherein a distal end (48B) of the one of the first leg and the second leg (26B) opposes the third columnar fluid-filled chamber (74C) (fig. 1 shows the distal end (48B) of the second leg (26B) opposing the third columnar fluid filled chamber (74C)). Regarding Claim 19, Cortez et al. teaches all of the limitations of the sole structure of Claim 16, as discussed in the rejections above. Cortez et al. does not teach wherein at least one of the first columnar fluid-filled chamber, the second columnar fluid-filled chamber, and the third columnar fluid-filled chamber includes a first fluid-filled chamber stacked on top of a second fluid-filled chamber, the first fluid- filled chamber being fluidly isolated from the second fluid-filled chamber. Attention is drawn to Connell et al. which teaches an analogous article of footwear. Connell et al. teaches a sole structure (14b) for an article of footwear (10b), the sole structure comprising: an element (42) extending from a forefoot region (16) to a heel region (20) and having an upper surface and a lower surface formed on an opposite side of the element from the upper surface (Fig. 16 shows the element (42) extending from the forefoot (16) to a heel (20) region and having an upper and an opposite lower surface); a first columnar fluid-filled chamber (126, 128) including a proximal end attached to the lower surface of the element and a distal end formed on an opposite side of the first columnar fluid-filled chamber than the proximal end (fig. 16 shows the chamber (126, 128) having a proximal end attached to the lower surface of the element (42) and a distal end opposite the proximal end), and a second columnar fluid-filled chamber (124) disposed between the first columnar fluid-filled chamber (126, 128) and an anterior end of the sole structure (fig. 22 shows the second columnar fluid filled chamber (124) disposed between the first chamber (126, 128) and the anterior end of the sole), and a third columnar fluid-filled chamber (122) disposed adjacent to the second columnar fluid-filled chamber (fig. 22 shows the third chamber (122) disposed adjacent the second chamber (124)). Connell et al. further teaches wherein at least one of the first columnar fluid-filled chamber (126, 128), the second columnar fluid-filled chamber, and the third columnar fluid-filled chamber includes a first fluid-filled chamber stacked on top of a second fluid-filled chamber, the first fluid- filled chamber being fluidly isolated from the second fluid-filled chamber (fig. 22 shows the first columnar fluid filled chamber including a first and second stacked chamber, the chambers being fluidly isolated from one another; paragraph [0164] teaches “the third fluid-filled chamber 126 may include the same or different pressure as the fourth fluid-filled chamber 128 and may likewise be fluidly isolated from the fourth fluid-filled chamber 128.”). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Cortez et al. to include the teachings of Connell et al. such that at least one of the first columnar fluid-filled chamber, the second columnar fluid-filled chamber, and the third columnar fluid-filled chamber includes a first fluid-filled chamber stacked on top of a second fluid-filled chamber, the first fluid- filled chamber being fluidly isolated from the second fluid-filled chamber so as to allow the first and second chambers to be inflated to different pressures therein providing a unique cushioning profile for the wearer (paragraph [0164] teaches “the third fluid-filled chamber 126 may include the same or different pressure as the fourth fluid-filled chamber 128 and may likewise be fluidly isolated from the fourth fluid-filled chamber 128.”). Regarding Claim 20, Cortez et al. teaches all of the limitations of the sole structure of Claim 11, as discussed in the rejections above. Cortez et al. further teaches wherein the arcuate segment (24) extends along a posterior end of the sole structure (fig. 1 shows the arcuate segment (24) extending along a posterior end of the sole; paragraph [0089] teaches “the heel portion 24 supported at the peripheral region 22 at the heel region 28”). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to HALEY A SMITH whose telephone number is (571)272-6597. The examiner can normally be reached Monday - Thursday 7:00 am - 5:00 pm. 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, Khoa Huynh can be reached at (571)272-4888. 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. /HALEY A SMITH/Primary Examiner, Art Unit 3732
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Prosecution Timeline

Dec 15, 2025
Application Filed
Jun 23, 2026
Non-Final Rejection mailed — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

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Prosecution Projections

1-2
Expected OA Rounds
57%
Grant Probability
99%
With Interview (+58.5%)
2y 6m (~1y 10m remaining)
Median Time to Grant
Low
PTA Risk
Based on 235 resolved cases by this examiner. Grant probability derived from career allowance rate.

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