Obviousness

Obviousness Analysis of U.S. Patent No. 11,389,026 under 35 U.S.C. § 103

A person having ordinary skill in the art (POSA) in the field of kitchen appliance design, as of the priority date of July 15, 2019, would have found the inventions claimed in U.S. Patent No. 11,389,026 to be obvious in view of combinations of existing prior art references. The motivation for such combinations would stem from a desire to enhance cooking versatility, efficiency, and user convenience in countertop cooking appliances.

The primary references for an obviousness combination include:

• US6917017B2 to Heartware Home Products, Inc. (published July 12, 2005): Titled "Counter-top cooker having multiple heating elements," this patent teaches a countertop cooking appliance with a plurality of heating elements configured for selective energization to cook various food items using different cooking modes.
• US9526402B2 (published December 27, 2016): Titled "Dual convection oven," this patent describes an oven with two separate cooking chambers and convection capabilities, inherently including fans for air circulation in each compartment.
• US20190200843A1 (published July 4, 2019): Titled "Air fryer and method for operating the same," this application discloses an air fryer that utilizes a fan to circulate heated air for cooking, often incorporating removable baskets with perforated bases.

A POSA would also be aware of general design principles and other prior art, such as:

• US20090126580A1 to Prince Castle, Inc. (published May 21, 2009): This patent application, titled "Removable Divider For Food Warming Apparatus," teaches the concept of removable components or dividers within a food appliance.
• US8519299B2 (published August 27, 2013): Titled "Air flow distribution device for an oven," this patent demonstrates the general concept of designing specific features for optimizing airflow within an oven.

Obviousness of Independent Claim 1

Independent Claim 1 describes a cooking system with a housing having first and second internal compartments, two independently removable cooking containers that form a continuous outer surface with the housing when inserted, and independently operable first and second heating elements and fans for their respective cooking volumes.

A POSA would have been motivated to combine the features of US6917017B2 and US9526402B2, further informed by US20190200843A1.

1. Housing with first and second internal compartments: US9526402B2 explicitly teaches a "dual convection oven," which by definition includes two separate cooking compartments. The concept of multiple cooking compartments in a single housing is well-established in the art.
2. First and second removable cooking containers forming a continuous outer surface: The general concept of removable cooking containers is taught by various prior art, such as in US20090126580A1, which describes a "removable divider" in a food warming apparatus. The design choice to make these containers "removably receivable" within the compartments to "close off an opening" and form a "continuous outer surface with the housing" is an obvious aesthetic and functional optimization for a countertop appliance, aimed at improving user experience, ease of cleaning, and integrated appearance, known to any POSA.
3. Independently operable first and second heating elements: US6917017B2 teaches a "counter-top cooker having multiple heating elements" that can be "selectively energize[d]" to enable cooking various food items in different modes. A dual oven, as taught by US9526402B2, would inherently include separate heating elements for each compartment, and a POSA would recognize the benefit of independent control for simultaneous, distinct cooking operations.
4. First and second fans in fluid communication with cooking volumes: US9526402B2, being a "dual convection oven," inherently includes fans to circulate heated air within each compartment. The explicit teaching of "hot air fryer" technology in US20190200843A1 further reinforces the use of fans for circulating heated air in cooking systems.

Motivation for Combination (Claim 1): A POSA would be motivated to combine the concept of a countertop cooker with multiple, independently operable heating elements (US6917017B2) with a dual convection oven (US9526402B2) to create a more versatile appliance capable of simultaneous cooking in separate compartments. The inclusion of fans, as found in convection ovens and air fryers (US20190200843A1), would be an obvious choice to enable efficient and modern cooking methods like air frying in each independent zone. The design of removable containers with a continuous outer surface is a routine consideration for aesthetic integration and ease of cleaning in such appliances.

Obviousness of Independent Claim 11

Independent Claim 11 details a cooking system with a housing having two internal cooking compartments for removable containers, forming a continuous outer surface. Each compartment includes a heating assembly (fan and heating element) that is independently operable and programmable for simultaneous cooking in separate modes. The containers are horizontally coplanar and have perforated bases.

This claim is also rendered obvious by combining US6917017B2, US9526402B2, and US20190200843A1.

1. Housing with two internal cooking compartments and removable containers forming a continuous outer surface: As discussed for Claim 1, US9526402B2 teaches dual compartments, and removable containers are known (US20090126580A1). The continuous outer surface is an obvious design choice for countertop appliances.
2. First and second heating assemblies (fan and heating element) independently operable and programmable for separate cooking modes: US9526402B2 teaches a "dual convection oven," which by its nature includes both heating elements and fans in each compartment. US6917017B2 expressly teaches "multiple heating elements" that are "selectively energize[d]" and can be used for "different cooking modes," directly anticipating independent operability and programming for distinct cooking modes.
3. First and second cooking containers substantially horizontally coplanar: The arrangement of two side-by-side compartments, as implied by a "dual oven" (US9526402B2), would naturally lead to a horizontally coplanar arrangement for ergonomic and spatial efficiency on a countertop. This is a common design for dual-zone appliances.
4. First and second cooking containers have respective first and second perforated bases: Perforated bases are a standard feature in air frying baskets and other convection cooking inserts to facilitate optimal air circulation around food, as clearly taught in air fryer technologies like US20190200843A1.

Motivation for Combination (Claim 11): A POSA would combine the independently operable multiple heating elements of a countertop cooker (US6917017B2) with the dual convection capabilities of an oven (US9526402B2) to create a highly functional countertop appliance. The further integration of air frying elements, such as fans and perforated bases (US20190200843A1), along with programmable independent operation, would address the market demand for versatile and efficient multi-zone cooking. The horizontally coplanar arrangement and continuous outer surface are obvious design implementations for a compact and user-friendly product.

Obviousness of Independent Claim 16

Independent Claim 16 describes a cooking system with a housing for two independently removable cooking containers, each defining a cooking volume. The containers engage with channels inside the housing to define respective air ducts and form a continuous outer surface. Independently operable heating elements and fans circulate air through the cooking volumes.

This claim is also rendered obvious by combining US6917017B2, US9526402B2, US20190200843A1, and further informed by general knowledge of airflow design in ovens (US8519299B2).

1. Housing with first and second independently removable cooking containers defining cooking volumes, forming a continuous outer surface: As previously established for Claims 1 and 11, dual compartments are taught by US9526402B2, removable containers by US20090126580A1, and a continuous outer surface is an obvious design choice for aesthetics and user experience.
2. Containers configured to engage with first and second respective channels inside the housing to define first and second respective air ducts: The detailed description of US11389026 itself describes how an insert cooperates with the cooking container to define an air duct. The concept of creating specific channels or clearances to guide airflow for efficient heat distribution is a well-known engineering practice in convection ovens and air fryers. For example, US8519299B2 teaches an "air flow distribution device for an oven". A POSA, seeking to optimize the circulation of heated air in a dual convection cooking system (US9526402B2 combined with US20190200843A1), would naturally design the components, including the containers and the housing, to create such defined air ducts.
3. First and second independently operable heating elements: Taught by US6917017B2 and implied by US9526402B2 for independent control in a dual oven.
4. First and second independently operable fans configured to circulate air through the cooking volumes: Taught by US9526402B2 (dual convection oven) and US20190200843A1 (air fryer). The independent operability of fans would logically follow from the independent operability of heating elements to support distinct cooking modes in each compartment.

Motivation for Combination (Claim 16): To improve upon existing multi-compartment cooking devices, a POSA would combine the independent heating capabilities of a multi-element countertop cooker (US6917017B2) with the convection (fan-driven) features of a dual oven (US9526402B2). To optimize the performance of such a dual convection system, particularly for air frying capabilities (US20190200843A1), a POSA would consider and implement known airflow design principles, such as creating specific air ducts or channels within the cooking containers and housing (US8519299B2), to ensure uniform and efficient circulation of heated air in each independent cooking volume. This combination addresses the need for a versatile, independently controlled, and high-performance multi-zone countertop cooking appliance.