Obviousness

Under 35 U.S.C. § 103, an invention is considered obvious if the differences between the claimed invention and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art (PHOSITA). The analysis involves identifying the scope and content of the prior art, ascertaining the differences between the prior art and the claims at issue, and resolving the level of ordinary skill in the pertinent art. A crucial aspect is demonstrating a motivation to combine the prior art references with a reasonable expectation of success.

A PHOSITA in the field of countertop cooking appliances, as of the July 15, 2019, priority date, would have been familiar with various cooking technologies, including convection ovens, air fryers, and multi-zone cooking devices, as well as standard engineering principles for heat transfer, airflow management, and control system design. The motivation to combine existing technologies would be driven by a desire to enhance functionality, versatility, and user convenience in kitchen appliances.

Obviousness of Independent Claim 1

Independent Claim 1 defines a cooking system with a housing having two internal compartments separated by a dividing wall, each compartment receiving a removable cooking container that completely closes its opening. The system includes independent heating elements and independent fans for each compartment, with each fan in fluid communication with its respective cooking volume.

This claim would have been obvious through a combination of:

• US Patent 6,917,017 B2 to Heartware Home Products, Inc. (hereinafter "Heartware")
• General knowledge of air fryer technology and convection oven design as of July 2019
• Common engineering practices in cooking appliance design

Reasoning for Combination:

1. Housing with Dual Internal Compartments and Dividing Wall: Heartware discloses a "Counter-top cooker having multiple heating elements for independent operation". A PHOSITA would understand that "multiple heating elements" in a single countertop appliance for "independent operation" would necessitate distinct cooking zones or internal compartments. The most straightforward and practical way to create and separate these independent cooking zones within a single housing is by incorporating a dividing wall, a basic structural design choice. The patent itself describes a housing with "a first internal compartment 28a and a second internal compartment 28b, separated from one another at least in part by a divider or wall 130."

2. Removable Cooking Containers Completely Closing Openings: The use of removable cooking containers (e.g., pots, baskets) that are received within internal compartments and designed to effectively close off an opening to retain heat was a well-established and pervasive practice in various cooking appliances (e.g., toaster ovens, slow cookers, and early air fryers) prior to 2019. This design choice is fundamental for user convenience (e.g., easy cleaning, serving) and maintaining thermal efficiency during cooking.

3. Independently Operable First and Second Heating Elements: Heartware explicitly teaches "multiple heating elements for independent operation" within its countertop cooker. This directly anticipates the requirement for independent heating elements and their independent operability within separate cooking zones, allowing different foods to be cooked simultaneously at different temperatures or with varied heating profiles.

4. First and Second Fans in Fluid Communication with Respective Cooking Volumes: By July 2019, air fryer technology, which employs fans to circulate hot air (convection) for rapid, even cooking, and crisping, was widely known and commercially successful. A PHOSITA would be strongly motivated to incorporate this highly desirable "convective heating element" functionality into each independent cooking compartment of a multi-zone countertop cooker (as taught by Heartware). Given the independent heating elements, it would be an obvious design choice to include a dedicated fan (an "air movement mechanism") for each compartment to ensure independent and optimal convection airflow within each cooking volume. This would establish efficient fluid communication between each fan and its respective cooking volume, thereby improving cooking performance and offering diverse cooking modes. Integrating fans into heating compartments for convection was a well-understood engineering task, leading to a reasonable expectation of success.

Therefore, Independent Claim 1 would have been obvious to a PHOSITA at the time of the invention.

Obviousness of Independent Claim 12

Independent Claim 12 describes a cooking system similar to Claim 1, emphasizing that the first and second internal cooking compartments are "horizontally coplanar" and that the first and second heating assemblies (comprising a fan and heating element) are independently operable and "programmable to simultaneously cook food in separate cooking modes."

This claim would have been obvious through a combination of:

• US Patent 6,917,017 B2 to Heartware
• General knowledge of air fryer technology and standard control system design for multi-zone appliances

Reasoning for Combination:

1. Housing with Dual Internal Compartments (horizontally coplanar) and Dividing Wall: As established with Claim 1, Heartware teaches a "Counter-top cooker having multiple heating elements" for independent operation, implying separate cooking compartments. For a countertop appliance, arranging such compartments side-by-side, making them "horizontally coplanar," is a common, space-efficient, and aesthetically pleasing design choice. A dividing wall is a natural structural element to define these distinct, coplanar compartments.

2. Removable Cooking Containers: As noted above, removable cooking containers are a standard feature for convenience and thermal efficiency in countertop cooking appliances.

3. First and Second Heating Assemblies (Fan + Heating Element) Configured to Cook Food: Heartware provides the "multiple heating elements". The addition of a fan to a heating element to create a "heating assembly" for convection cooking (air frying) was a well-established practice by 2019. A PHOSITA would be motivated to integrate this popular and effective cooking method into each independent compartment of a multi-zone cooker to improve cooking speed, evenness, and offer crisping capabilities desired by consumers.

4. Heating Assemblies Independently Operable to Independently Cook Food: Heartware explicitly teaches "multiple heating elements for independent operation". Extending this independent operation to a "heating assembly" (heating element + fan) in each compartment is a logical and obvious step for a PHOSITA when incorporating convection functionality into a multi-zone cooker.

5. Programmable to Simultaneously Cook Food in Separate Cooking Modes: Given that each heating assembly (heating element and fan) is independently operable, providing a control system that allows for simultaneous programming for different cooking modes (e.g., different temperatures, times, or even different types of convection cycles) in each compartment is a conventional application of control technology. Consumers desire the ability to cook multiple dishes concurrently, each with its own optimal settings, making such programmability an obvious feature to implement for a PHOSITA in appliance design. The patent itself describes a control panel with inputs for selecting modes and setting time/temperature, and a processor to control operation. This type of control system for independently operating elements is standard.

Therefore, Independent Claim 12 would have been obvious to a PHOSITA at the time of the invention.

Obviousness of Independent Claim 18

Independent Claim 18 describes a cooking system with first and second independently removable cooking containers separated by a dividing wall, where the containers are configured to "engage with first and second respective channels inside the housing to define first and second respective air ducts therein." It also includes independent heating elements and independent fans configured to circulate air through the respective cooking volumes.

This claim would have been obvious through a combination of:

• US Patent 6,917,017 B2 to Heartware
• General knowledge of air fryer technology and convection oven design principles
• Common engineering features for optimizing airflow in cooking appliances

Reasoning for Combination:

1. Housing with Dual Internal Compartments (separated by dividing wall) and Independently Removable Cooking Containers: This element is obvious for the same reasons as discussed for Claim 1, primarily supported by Heartware's teaching of a "Counter-top cooker having multiple heating elements for independent operation", combined with the well-known practice of using removable containers in cooking appliances.

2. Containers Engaging with Channels to Define Respective Air Ducts: The concept of creating specific airflow paths or "air ducts" within a cooking appliance, separate from the primary cooking volume, is a known technique in convection cooking and air frying to ensure uniform heat distribution and efficient circulation. Many convection ovens and air fryers utilize internal structures, baffles, or even specially designed inserts/containers that create defined spaces for air movement. The engagement of a cooking container with "channels inside the housing" to create an air duct is a common engineering solution for guiding airflow and optimizing convection efficiency. The patent's description clarifies how the insert and container "cooperate to properly position the insert within the interior 38 such that the blocking wall 52 of the insert 50 is offset from the back wall 62 of the cooking container 32. This clearance...defines an air duct 74". This mechanical arrangement for controlling airflow is an optimization that a PHOSITA would routinely consider when designing an efficient convection cooking system.

3. Independently Operable First and Second Heating Elements: As detailed for Claim 1, Heartware explicitly teaches "multiple heating elements for independent operation".

4. Independently Operable First and Second Fans Configured to Circulate Air Through Respective Cooking Volumes: As detailed for Claim 1, the integration of independent fans into a multi-compartment cooker with independent heating, for the purpose of convection cooking (air frying), would be an obvious design choice for a PHOSITA seeking to enhance cooking performance and versatility. The goal of circulating air through the cooking volumes to achieve convection is inherent to air fryer design, and providing independent fans for independent compartments is a logical extension.

Therefore, Independent Claim 18 would have been obvious to a PHOSITA at the time of the invention.