Obviousness

Obviousness Analysis (35 U.S.C. § 103)

This analysis evaluates whether the inventions claimed in U.S. Patent 10,512,385 would have been obvious to a Person Having Ordinary Skill in the Art (PHOSITA) at the time the invention was made, by combining the teachings of the prior art references cited during prosecution.

Independent Claim 1

Claim Summary: A dishwasher with two racks: a top rack with a tiered bottom creating an "effective inclination angle," and a second rack below it with a non-tiered, flat bottom that is inclined at an angle matching and parallel to the top rack.

Proposed Combination of References:

• Primary Reference: U.S. Patent 8,287,660 (Kendrick), which is explicitly cited in the '385 patent's specification (Description, FIG. 7) as disclosing a "first dish rack...having a bottom wall tiered to form multiple levels...defining an effective inclination angle."
• Secondary Rationale: General engineering principles and knowledge in the art regarding dishwasher rack design, as exemplified by concepts in U.S. Patent 2,910,207 (Tulleners).

Analysis:
A PHOSITA would begin with the tiered upper rack taught by Kendrick ('660). The '385 patent itself identifies this reference as disclosing the first key element of claim 1. The tiered structure of Kendrick creates an overall slope or "effective inclination angle" designed to improve space utilization and drainage.

The inventive step in claim 1 lies in combining this tiered upper rack with a second, non-tiered rack below it that has a bottom wall inclined at a matching, parallel angle. While none of the cited references explicitly shows this exact combination, it can be argued as an obvious design choice.

The motivation to combine these features arises from a desire to optimize the entire washing volume. A PHOSITA would recognize two well-known problems in dishwasher design:

1. Poor Drainage: Water can pool on the bottoms of inverted cups and glasses, a problem that angling the items helps solve, as generally taught by Tulleners ('207).
2. Inefficient Space Utilization: Racks must be designed to accommodate the maximum number and variety of dishes without interference.

Starting with Kendrick's sloped upper rack, a PHOSITA would naturally consider the design of the rack below it. To improve drainage for items in that lower rack, inclining its bottom surface would be a logical and well-understood step. The motivation to make the lower rack's inclination parallel to the upper rack's effective angle is driven by the need for spatial efficiency and predictable clearance. A parallel arrangement creates a consistent vertical distance between the two racks, which maximizes the usable space for items of a certain height and ensures that the spray arm located between the racks (such as middle spray assembly 28C in FIG.7) has consistent clearance and provides uniform water coverage to the underside of the upper rack and the tops of items in the lower rack.

Therefore, combining Kendrick's tiered rack with a flat, sloped lower rack that mirrors the upper rack's angle would be an obvious modification to a skilled artisan seeking to improve drainage and spatial efficiency throughout the entire dishwasher tub.

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Independent Claims 13 and 17

Claim Summary (Claim 13 & 17): These claims describe a movable dish rack with a specially contoured wire bottom designed to hold glasses at an incline. The bottom structure features inclined portions to "cradle" the glasses and a "contoured" or "curved" portion that serves two purposes: (1) it acts as a stop to prevent the glasses from sliding, and (2) it serves as a mounting point for a spray tube that is carried with the rack and sprays water into the interior of the angled glasses.

Proposed Combination of References:

• Primary Reference: U.S. Patent 2,910,207 (Tulleners), which teaches using wire supports to hold glassware at an angle to facilitate drainage.
• Secondary Reference: U.S. Patent 4,064,887 (Constant), which teaches a spray arm system integrated into a movable upper dish rack, including a docking mechanism to supply it with water.

Analysis:
A PHOSITA addressing the known problem of ineffective cleaning and drying of glassware would be aware of two key solutions from the prior art:

1. Angling Glassware: Tulleners ('207) discloses arranging wire tines to support glasses at an angle, which improves the drainage of water and cleaning solution. This directly teaches the concept of creating inclined supports within a rack to hold glasses.
2. Dedicated Sprayers: Constant ('887) teaches the benefits of a dedicated sprayer for an upper rack. The '385 patent itself notes that with glasses oriented downwards, general sprayers may provide insufficient water to their interiors. Constant shows it is known to integrate a sprayer directly with a movable rack to improve cleaning in that specific zone.

The motivation to combine these two known concepts is strong and direct. A PHOSITA, recognizing that the angled orientation taught by Tulleners ('207) can shield the interior of glasses from the main spray arms, would be motivated to add a dedicated sprayer to target these shielded areas. The solution of adding a rack-mounted sprayer is taught by Constant ('887).

The specific geometry described in claims 13 and 17—where a single "contoured" wireform both supports the base of the glass and serves as a mounting point for the spray tube—can be seen as an obvious implementation of this combined concept. In designing a wire rack, it is a standard practice to make components multifunctional to save space and material. A skilled rack designer, tasked with placing a spray tube (from Constant) adjacent to a row of angled glasses (from Tulleners), would find it an efficient and logical design choice to shape the wire support to both prevent the glass from sliding and to provide a secure mounting location for the tube. This would be considered routine design optimization rather than a non-obvious inventive leap.

Therefore, the combination of angling glasses for drainage (Tulleners '207) and adding a dedicated, rack-mounted sprayer for targeted cleaning (Constant '887) would have rendered the inventions of claims 13 and 17 obvious to a person of ordinary skill in the art.