Invalidity dossier
US 10240957
Thermal airflow sensor
Current assignee: Astemo Ltd
Added 9/24/2026, 11:16:16 PM
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Patent summary
Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.
I'll search for this patent number in the specified sources.
Let me run additional targeted searches to check for any litigation or CAFC activity, and to confirm the bibliographic record.
Let me do one final check specifically for any appellate proceedings.
US Patent 10,240,957 — Analyst Summary
Sourcing note: I could not locate this patent in a live USPTO PatentCenter/PAIR query or confirm it in any CAFC 2026 docket through the searches I ran. No Federal Circuit appeal, IPR, or other 2026 appellate activity involving 10,240,957 surfaced — so I cannot report any CAFC 2026 proceeding, and you should treat that as "none found," not as a verified negative. The bibliographic and textual details below come from the patent's own Google Patents record (https://patents.google.com/patent/[US10240957B2](/patent/US10240957B2)/en), which matches the authoritative full text supplied. I did not substitute or auto-correct any identifier; I note two spelling artifacts that appear literally in the record ("AI wiring," apparently for Al wiring, and "Aautomotive") without correcting them.
Bibliographic Data
| Field | Value |
|---|---|
| Patent number | US 10,240,957 B2 |
| Title | Thermal airflow sensor |
| Application no. | 15/979,301 |
| Inventors | Ryosuke Doi; Hiroshi Nakano; Keiji Hanzawa |
| Original assignee | Hitachi Automotive Systems, Ltd. |
| Current assignee | Astemo Ltd (per record; reassignment of 2021-03-25 records change of name to HITACHI ASTEMO, LTD.) |
| Filing date | 2018-05-14 |
| Issue/grant date | 2019-03-26 |
| Priority date | 2012-06-29 (JP 2012-146286) |
| Anticipated expiration | 2033-06-10 |
| Status | Active |
| Continuity | Continuation of 15/495,268 (issued as US 10,001,394), which is a continuation of 14/410,713 (issued as US 9,664,546), a §371 national stage of PCT/JP2013/065912 |
| Claims | 2 total (both independent-form; claim 1 independent, claim 2 dependent on claim 1) |
Note on claim count: The record lists "Claims (2)" and identifies claim 1 as "The invention claim is:" — so there is one independent claim (claim 1); claim 2 is a dependent claim. I flag this because your prompt asked for "each independent claim," and the documents show only claim 1 as independent.
Abstract (as issued)
A thermal airflow sensor includes a semiconductor device, a protective film a bonding wire, and a resin. The resin covers over a part of the semiconductor device so that the bonding wire is covered with the resin and the region including a thin-wall portion is exposed. The protective film is not covered with the resin and has an outer peripheral edge located outside the thin-wall portion.
(The missing punctuation after "protective film" is reproduced literally from the record.)
Plain-Language Overview of the Claims
Claim 1 — the independent claim. A thermal airflow sensor (e.g., an automotive intake-air mass-flow sensor) comprising:
- a semiconductor device with a thin-wall portion (a thin membrane/diaphragm, e.g., silicon with a back-side cavity) carrying a heating resistor and resistance temperature detectors;
- a protective film formed on the semiconductor surface such that the heating resistor is exposed (left uncoated so it can contact the airflow being measured);
- a bonding wire electrically connected to the semiconductor device;
- a resin (mold resin) covering part of the semiconductor device — specifically enough that the bonding wire is covered, while the region including the thin-wall portion is left exposed;
- the key limitation: the protective film has multiple slits located between the resin-covered region and the thin-wall portion.
Why it matters (from the spec): during partial-exposure resin molding, the insertion die presses on the sensor surface, and if the pressing load is insufficient, mold resin can leak through a gap toward the fragile thin wall and corrupt the sensing area. The slits act as traps/barriers that stop leaking mold resin before it reaches the thin-wall portion, and they also decouple the protective film covering the diaphragm from the film under the resin so that resin-shrinkage stress does not propagate to the thin-wall edge (FIGS. 5–12, especially FIG. 9).
Claim 2 — dependent on claim 1. Adds a resistor formed over the semiconductor substrate, and requires that the slits be formed so as to expose that resistor. In other words, the slit arrangement is configured to leave the additional resistor exposed (the spec's fifth embodiment, FIG. 14 — e.g., exposing a temperature sensor for thermal responsiveness while still using multi-staggered slits to block resin leakage).
Points of Uncertainty / Caveats
- No CAFC 2026 docket entry found. My searches returned no Federal Circuit case, appeal number, or opinion referencing 10,240,957 in 2026. I cannot confirm one exists; absence of results is not proof of absence.
- No USPTO litigation/PTAB record confirmed for this patent in my results (the record shows only routine maintenance-fee and name-change legal events, plus a 4th-year maintenance fee paid 2022-09-14).
- Assignee naming inconsistency in the sources. Google Patents shows "Current Assignee: Astemo Ltd" while the legal-event entry says "HITACHI ASTEMO, LTD." I have reported both as they appear rather than harmonizing them.
- Two textual artifacts ("AI wiring," "Hitachi Aautomotive Systems") appear literally in the family/citation tables and are reproduced without correction per the strict-ID rule.
If you need a hard confirmation of any 2026 appellate activity, that would require a direct PACER/CM-ECF docket query on the Federal Circuit and a USPTO PatentCenter/PTAB-Portal look-up, which my search tooling here did not surface.
Generated 9/28/2026, 11:33:13 PM
Cases on file (0)
Specific litigation cases in our database that name US patent 10240957. The free-form analysis below may also discuss cases beyond this list.
No cases on file mention this patent. Upload a CSV or add a case manually in Admin → Manage litigation cases.
Litigation summary
Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.
I'll search for litigation involving US patent 10240957 across patent litigation databases.
Let me try more targeted searches on litigation databases.
No litigation found so far. Let me search litigation-specific databases directly.
Litigation Search Report: U.S. Patent No. 10,240,957
Patent identified: U.S. Patent No. 10,240,957 B2 — "Thermal airflow sensor"
- Application No. 15/979,301; filed May 14, 2018; granted March 26, 2019
- Priority date: June 29, 2012 (JP 2012-146286)
- Inventors: Ryosuke Doi, Hiroshi Nakano, Keiji Hanzawa
- Original assignee: Hitachi Automotive Systems, Ltd.; current assignee: Astemo Ltd. (Hitachi Astemo, Ltd.)
- Part of a continuation family: US 9,664,546 B2; US 10,001,394 B2; US 10,240,957 B2; US 11,391,611 B2
Finding
No litigation involving U.S. Patent No. 10,240,957 was found.
I searched for district court actions, Federal Circuit appeals, ITC proceedings, and PTAB/post-grant challenges directed to this specific patent. My searches returned no matching case records — no plaintiff, defendant, jurisdiction, case number, or filing date could be identified for this patent.
Basis and Caveats
Please treat this as a best-efforts negative finding, not an affirmative certification of non-litigation, for the following reasons:
Search limitations. My available search returned no results specifically tying this patent number to any court docket. I was unable to query PACER, Docket Alarm, CourtListener, or the Unified Patents litigation portal directly with a docket-level search, and a direct docket lookup returned no accessible records. I therefore could not exhaustively confirm the absence of litigation across all venues.
A note on the number. Per the instruction to interpret identifiers literally, I searched the exact number 10,240,957. I did not fold in results for visually similar but distinct patents (e.g., related family member numbers such as 10,001,394 or 11,391,611, or unrelated numbers that resemble "10240957"), so as not to contaminate the result.
What the record does show. The Google Patents page for this patent lists only its prosecution/family events (filing, grant, assignment to Hitachi Astemo, maintenance-fee payment) and a single "Cited By" entry — US 2019/0178694 A1, a later publication by the same assignee (Hitachi Automotive Systems). It reflects no adverse proceedings. Astemo/Hitachi is an operating sensor supplier for automotive OEMs, not a known asserting entity, which is consistent with a patent that has seen little or no enforcement activity.
Recommendation
To definitively confirm or rule out litigation, direct docket-level verification is advisable:
- Unified Patents Litigation Portal — https://portal.unifiedpatents.com/litigation/caselist (query by patent number 10240957)
- Docket Alarm — https://www.docketalarm.com (patent-based search)
- CourtListener / RECAP — https://www.courtlistener.com
- USPTO PTAB (PTActs) and USPTO Assignment records for any post-grant challenges or ownership transfers that might accompany enforcement
If, after those lookups, no docket appears, the correct statement is: as of April 26, 2026, no litigation involving U.S. Patent No. 10,240,957 is known.
Generated 9/28/2026, 11:33:20 PM
Proceedings on file (0)
All PTAB activity →AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.
No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.
PTAB challenges
AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.
I'll check the structured block (which returned no proceedings) against live sources before answering.
PTAB / AIA Trial Landscape — US 10,240,957 B2 ("Thermal airflow sensor")
Bottom line up front: The structured "PTAB proceedings on file" block from the USPTO Open Data Portal returns zero AIA trial proceedings for US 10,240,957. Independent web searches (Google Patents/PTAB literature, PTAB petition documents, PTAB docket aggregators) surfaced no IPR, PGR, or CBM naming this patent, its application number 15/979,301, or any of its family members. I found no proceedings to report — the substantive sections below are therefore populated as findings of absence, not as invented content.
Proceedings overview
Total AIA trial proceedings on US 10,240,957: 0 (0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution denials). The patent stands wholly unexamined by the Board: claims 1 and 2 are UNTESTED, the patent is in force (4th-year maintenance fee paid 2022-09-14, anticipated expiration 2033-06-10 per the ODP record), and a defendant facing assertion today has no PTAB record, no FWD, no estoppel map, and no free invalidating "kill" to point to. The defensive posture is the opposite of the "hardened patent" or "claims already canceled" scenarios — this is an open, un-litigated-at-the-Board patent, which cuts both ways (see Strategic summary).
Proceedings
None. There are no AIA trial proceedings to itemize.
Because the required per-proceeding template would be fabricated if filled in, here is the negative finding with its evidentiary basis:
No proceedings identified — search record
- Structured source (canonical): USPTO ODP "PTAB proceedings on file" block for US 10,240,957 — empty / returns no AIA trial proceedings as of the most recent ingest.
- Independent checks performed 2026-09-28: searches keyed to the patent number ("10240957", "10,240,957"), to the application number (15/979,301), and to the family members (US 9,664,546; US 10,001,394; US 11,391,611) returned no petitions, institution decisions, FWDs, or appeal dockets.
- Notable false positives / noise (explicitly not this patent):
- A PTAB petition document citing an "'957 Patent" whose application is 15/043,287 (Stephen N. Hardy, display cooling) — a different patent that merely shares the trailing digits "957." Do not map its proceedings onto this patent.
- Tax-record, Czech research-registry, and EU patent-bulletin hits for the string "10240957" — unrelated numerical coincidences.
- Confidence: Moderate-to-high that no IPR/PGR/CBM exists. The absence from ODP plus absence from public petition/docket literature is strong, but I cannot rule out a very recently filed petition not yet indexed. Per the framing of this task, the default is "no PTAB activity on file."
There is therefore no judge panel, no petition grounds, no institution decision, no FWD, no settlement, and no Federal Circuit appeal to report. I will not speculate about any of those.
Strategic summary
Claim status. US 10,240,957 issued 2019-03-26 with a slim claim set: claim 1 (independent — thermal airflow sensor comprising a semiconductor device with a thin-wall portion carrying a heating resistor and resistance temperature detectors, a protective film formed so the heating resistor is exposed, a bonding wire, a resin covering part of the semiconductor device so the bonding wire is covered and the thin-wall region is exposed, wherein the protective film has multiple slits between the resin-covered region and the thin-wall portion) and claim 2 (dependent — a resistor formed over the semiconductor substrate, the slits formed so as to expose the resistor). Both claims are UNTESTED by the Board. Nothing is canceled; nothing is confirmed. Note the claim set here is materially narrower than the disclosure (the specification's five embodiments, the slit/stagger concepts, polyimide materials, and Al-wiring corrosion discussion are largely unclaimed), which matters for both infringement and invalidity analysis.
Estoppel landscape. With no IPR instituted, § 315(e)(2) estoppel is a non-issue — no petitioner is estopped from anything, and there is no PTAB record that could be used to narrow the universe of available prior-art grounds. For a defendant currently asserted against, the entire § 102/§ 103 prior-art space is available, subject only to the ordinary district-court rules (e.g., IPR estoppel does not apply, and In re Packard-type printed-publication limits do not arise). Practically, this means an IPR filed now would face a clean slate: no prior panel findings, no claim-construction record, and no risk that an earlier petition's grounds are foreclosed. That is a genuine offensive opportunity for a defendant.
Pattern signals. No petitioner has filed — let alone filed multiple times — against this patent. The patent owner (originally Hitachi Automotive Systems, Ltd., now Hitachi Astemo, Ltd. following the 2021-01-01 name change, per the ODP assignment record) is a large operating company, not a non-practicing entity, and has not appeared as a PTAB patent owner in any proceeding on this patent. There is no defensive aggregator (e.g., Unified Patents) anywhere in the chain of this patent on the record I reviewed. The prosecution citations (JP3610484B2, US20040025585A1, JP2009270930A, US20100077851A1, US20110023597A1, US20110107832A1, US20120060599A1, US20120240674A1, US20140159174A1, US20150122050A1, US20150330820A1, and others) are examiner/IDS citations only — they are not IPR grounds and carry no estoppel effect, but they are a ready-made starting point for a validity challenge.
Recommended next steps
- No PTAB activity exists — say it plainly. There is no Final Written Decision to link, no canceled claim to quote, and no § 315(e)(2) estoppel to exploit. Any representation that claims 1–2 have been invalidated or sustained would be false.
- The absence is itself a signal. This is a 2013-priority patent in a crowded, high-volume art unit (thermal airflow meters for automotive intake systems — G01F1/684 et seq.) with many large competitors. That it has attracted zero IPRs suggests either (a) it has never been asserted in a way that justified the ~$500K+ cost of a Board trial, or (b) prospective defendants have resolved disputes without Board involvement. Before filing anything, confirm the litigation/assertion history with a district-court docket sweep (Hitachi Astemo and predecessor Hitachi Automotive Systems as plaintiff, and as defendant in counterclaim posture), since PTAB filings typically follow infringement suits.
- If you are a defendant, treat this as a green field, not a shield. The dispositive questions are whether the "multiple slits between the region covered with the resin and the thin-wall portion" limitation (claim 1) reads on your accused device, and whether prior art discloses multiple slits (plural) in a protective film arranged between the mold-resin boundary and the diaphragm. The plurality requirement is the most plausible invalidity and non-infringement fulcrum — a single slit or a continuous protective film may fall outside the literal claim, while art showing nested or staggered slits could invalidate it.
- Deadline math if you do file an IPR: under §§ 315(b)/311(c), a § 315(b) one-year bar runs from service of an infringement complaint; institution decision is due within 6 months of petition filing; trial must conclude with an FWD within 12 months of institution (extendable to 18 for good cause, § 316(a)(11)). With no competing proceeding, there is no § 315(a)(2) or § 325(d) overlap to manage.
- Verify before relying. Confirm the empty ODP result directly against PTAB E2E / the Board's public search (https://developer.uspto.gov/ptab-api/ and https://ptacts.uspto.gov) and re-run on the family members (US 9,664,546, US 10,001,394, US 11,391,611) — the family is the practical place where a challenge would historically have landed, since all four share the same 2012-06-29 priority.
Generated 9/28/2026, 11:33:30 PM
Ownership chain (1)
Asserters network →Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.
2021-01-01 · recorded 2021-03-25 · reel 056299/0447 · Change of Name
Hitachi Automotive Systems, Ltd.Hitachi Astemo, Ltd.
internal reorg
Assignment history
Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.
I'll research the assignment record for US 10,240,957, starting with the USPTO Assignment Center and cross-referencing the legal events already in the record.
Let me dig into the specific assignment records and check for any 2025 name-change recording, plus verify the inventors and assignment-center entries.
Let me check for litigation/NPE signals and confirm whether a 2025 name-change assignment exists.
I hit the search-step limit before completing direct Assignment-Center and litigation checks. Below is what the available records support, with limitations flagged explicitly.
Inventors
| Inventor | Employer at filing (as determinable) |
|---|---|
| Ryosuke Doi | Hitachi Automotive Systems, Ltd. (assignee on the underlying JP/US filings; a third-party patent-leaderboard profile lists 49 patents under his name at Hitachi Automotive Systems) |
| Hiroshi Nakano | Hitachi Automotive Systems, Ltd. (recurring inventor on Hitachi Automotive Systems thermal-flow-meter patents, e.g. EP 2,280,251 / EP 2,482,050) |
| Keiji Hanzawa | Hitachi Automotive Systems, Ltd. (co-inventor on numerous Hitachi/Hitachi Automotive Systems flow-sensor filings) |
Pattern note: All three are long-tenured Hitachi/Hitachi Automotive Systems thermal-flow-sensor inventors; the same three names recur across the continuation family (US 10,001,394, US 11,391,611). I found no evidence of the trio departing the original assignee within 12 months of filing — the departure-for-shadow-entity pattern that sometimes precedes a portfolio fire-sale is not present here. Caveat: employer is inferred from assignee/inventor records, not from a personnel filing; I could not retrieve an express employment declaration.
Original assignee
Hitachi Automotive Systems, Ltd. (Hitachinaka-shi, Ibaraki, Japan) is the entity named on the issued patent.
- Product/shipping status: Yes — an operating Tier-1 automotive supplier that manufactures thermal airflow (mass air flow) sensors as OEM engine-intake hardware. This patent's own FIG. 15 shows the sensor installed in an intake pipe, and the claims are directed to a producible sensor package, so the claims read on a commercially shipped product line (Hitachi/Astemo mass air flow sensors for combustion-engine management).
- Primary line of business: Automotive components — powertrain, chassis, and sensor systems.
- Current status: Operating. Hitachi Automotive Systems was combined with Keihin, Showa, and Nissin Kogyo in the January 2021 management integration to form Hitachi Astemo, Ltd.; the company was renamed Astemo, Ltd. effective April 1, 2025 (announced 2025-02-20) and relocated its registered headquarters from Hitachinaka to Chiyoda, Tokyo. Ownership shifted in October 2023 to a JV among Hitachi, Ltd., Honda Motor Co., and JIC Capital. No bankruptcy, dissolution, or asset-sale event appears in any record I reviewed.
Assignment timeline
The authoritative full text supplies exactly one recorded post-issuance assignment in its Legal Events table. I was not able to open the Assignment Center record directly (my live queries to assignmentcenter.uspto.gov / assignment.uspto.gov returned no hit), so the reel/frame below is taken from the Google Patents legal-events entry and should be verified against Assignment Center for the correspondent-of-record field, which was not exposed in any source I could reach.
- 2021-01-01 (executed) / recorded 2021-03-25 — Reel 056299/0447
- Conveyance: Change of Name
- Assignor: Hitachi Automotive Systems, Ltd.
- Assignee: Hitachi Astemo, Ltd.
- Correspondent: Not retrievable from the sources available to me. (This is the field you most wanted; I flag it as a gap rather than guess at it.)
- Context: Internal reorg — a pure name change implementing the January 2021 management integration; no change in beneficial ownership and no third party introduced.
Two important qualifications:
- Google Patents' "Current Assignee" field for this patent reads "Astemo Ltd," reflecting the 2025 Hitachi Astemo → Astemo, Ltd. renaming. No separate reel/frame recording of that 2025 name change appears in the authoritative Legal Events table for this patent. Either it was recorded against a different member of the family, or it simply is not reflected here; I could not confirm a second record.
- The pre-grant chain is prosecution continuity only, not assignments: PCT/JP2013/065912 → US 14/410,713 (§371) → US 15/495,268 (cont.) → US 15/979,301 (cont., this patent). Those are application-parent links on Google Patents, not USPTO assignment reels.
Bottom line: If the Assignment Center truly holds only the single 2021 change-of-name entry, that is itself the finding — a patent that never left its originating corporate family. Verify the correspondent there directly.
Timeline diagram
timeline
title Ownership of US 10240957
2012 : Filed by Hitachi Automotive Systems
2019 : Patent issued
2021 : Name change to Hitachi Astemo Ltd
2025 : Renamed Astemo Ltd
NPE / troll-pattern signals
- Shell-entity transfer — not present. The only recorded transfer (Reel 056299/0447, 2021-03-25) runs Hitachi Automotive Systems → Hitachi Astemo, Ltd., an operating Tier-1 auto supplier, via a Change of Name conveyance rather than an assignment of right. No "IP/Patents/Licensing/Holdings/Ventures" entity, no registered-agent address, no single-purpose LLC on the chain.
- Known asserter in the chain — not present. Neither Hitachi Automotive Systems, Hitachi Astemo, nor Astemo, Ltd. matches any of the listed NPEs (Acacia, Marathon, IV, IPNav, Wi-LAN/Conversant, Vringo, Pendrell, Round Rock, etc.). No such entity appears in any reel.
- Repeat correspondent across the chain — unclear. With only one recorded event and the correspondent field unretrievable from my sources, I cannot assess recurrence. This is the single weakest-evidence item and the reason the correspondent should be pulled directly from Assignment Center.
- Cascading transfers — not present. There is one recorded event across the patent's life; there is no chain of LLCs and no sub-24-month cascade.
- Pre-litigation transfer — not present. No infringement suit naming US 10,240,957 surfaced in any search, and the sole transfer predates any hypothetical suit by years and was intra-group.
- Bankruptcy fire-sale — not present. No Chapter 7/11 proceeding involving Hitachi Automotive Systems, Hitachi Astemo, or Astemo, Ltd. found; the corporate events are a merger-integration (2021) and capital restructuring (2023), neither a liquidation.
- Privateering — not present. No indication the patent was pushed to an NPE to assert against competitors; the family has stayed with the operating supplier.
- Defensive aggregator (anti-NPE) — not present. The chain does not terminate at RPX, AST, LOT, Unified Patents, or OIN.
Verdict
Insufficient data. The ownership record is not really a chain at all: the only recorded event is a Change of Name at Reel 056299/0447 (executed 2021-01-01, recorded 2021-03-25) moving the patent from Hitachi Automotive Systems, Ltd. to Hitachi Astemo, Ltd., with no beneficial transfer and no introduction of a third party. With only an intra-group renaming on record, the enumerated NPE signals are uniformly absent, and the patent remains with a large operating auto supplier — but because I could not open the Assignment Center directly, could not retrieve the correspondent of record, and found no litigation to confirm a non-assertion posture, the honest call is insufficient data rather than an affirmative "non-NPE" finding.
Verify directly at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (patent number search for 10,240,957), cross-checked at https://assignment.uspto.gov/patent/index.html.
Generated 9/28/2026, 11:33:39 PM
Prior art
Earlier patents, publications, and products that may anticipate or render the claims unpatentable.
I'll research the prior art citations for US 10,240,957. Let me pull details on the key cited references.
Let me gather details on the remaining cited references.
Prior-Art Analysis — US 10,240,957 B2
Building on the prior sections. The bibliographic record and the litigation/CAFC "none found" results were established earlier. This section addresses only the new task: the prior-art references cited on the face of US 10,240,957 and their § 102 relevance. The claim construction from the earlier "Plain-Language Overview" is adopted unchanged.
Identifier discipline: I analyzed the exact number 10,240,957. I did not fold in family members (US 9,664,546 / 10,001,394 / 11,391,611) or look-alike numbers. All citations below are reproduced literally from the patent's "Patent Citations" tables, including the artifacts "AI wiring" and "Hitachi Aautomotive Systems" — reproduced without correction.
1. Scope / what is actually cited
The record lists Citations (13) and a merged Patent Citations (14) table (the 14th is CN101713676A, the CN family member of US20100077851A1), plus one Non-Patent Citation (the PCT International Search Report dated 2013-07-16). The references of record are:
| # | Citation | Priority date | Pub. date | Assignee/Inventor | Title |
|---|---|---|---|---|---|
| 1 | JP3610484B2 | 1999-08-10 | 2005-01-12 | 株式会社日立製作所 | Thermal air flow meter |
| 2 | US20040025585A1 | 2002-05-10 | 2004-02-12 | Koji Seki | Flow sensor and method of manufacturing the same |
| 3 | JP2009270930A | 2008-05-07 | 2009-11-19 | Denso Corp | Thermal flow sensor |
| 4 | US20100077851A1 | 2008-09-30 | 2010-04-01 | Hitachi Automotive Systems, Ltd. | Air Flow Meter |
| 5 | CN101713676A | 2008-09-30 | 2010-05-26 | 日立汽车系统株式会社 | Air flow meter |
| 6 | US20110023597A1 | 2009-07-30 | 2011-02-03 | Hitachi Automotive Systems, Ltd. | Thermal flow meter |
| 7 | US20110107832A1 | 2009-11-06 | 2011-05-12 | Hitachi Automotive Systems, Ltd. | Thermal Type Fluid Flow Sensor and Fabricating Method |
| 8 | JP2011119500A | 2009-12-04 | 2011-06-16 | Denso Corp | Sensor device, and method of manufacturing the same |
| 9 | US20120060599A1 | 2010-09-09 | 2012-03-15 | Hitachi Automotive Systems, Ltd. | Thermal Type Air Flow Meter |
| 10 | JP2011050787A | 2010-12-17 | 2011-03-17 | Sansei R&D:Kk | Game machine |
| 11 | US20120240674A1 | 2011-03-25 | 2012-09-27 | Hitachi Automotive Systems, Ltd. | Thermal fluid flow sensor and method of manufacturing the same |
| 12 | US20140159174A1 | 2011-07-13 | 2014-06-12 | Hitachi Aautomotive Systems, Ltd. | Flowmeter |
| 13 | US20150122050A1 | 2012-04-06 | 2015-05-07 | Hitachi Automotive Systems, Ltd. | Flow sensor |
| 14 | US20150330820A1 | 2012-12-17 | 2015-11-19 | Hitachi Automotive Systems, Ltd. | Physical Quantity Sensor |
Statutory-date framework (critical): US 10,240,957 has a priority date of 2012-06-29 — i.e., before the AIA first-to-file date of 2013-03-16. The applicable statute is therefore pre-AIA 35 U.S.C. § 102, under which:
- References published before 2012-06-29 are § 102(a)/(b) art.
- References published after 2012-06-29 but having an earlier effective U.S. filing date may be § 102(e) art (secret prior art) only where the statutory conditions for a § 371/national-stage or published-application date are met.
- A reference whose effective date is after 2012-06-29 is not § 102 art at all against the '957 claims (items 14, and possibly portions of 12 on this basis).
2. Reference-by-reference analysis
JP3610484B2 — "Thermal air flow meter" (Patent Document 1 of the '957 spec)
- Full citation: JP 3610484 B2; priority 1999-08-10; published 2005-01-12; 株式会社日立製作所.
- Description: The "Patent Document 1" expressly identified in the '957 background. It provides an organic protective film over the surface of the flow-sensor element to improve the reliability of the thin-wall portion formed by removing part of the silicon substrate from its back side; the peripheral part of the diaphragm section of the electrical insulating film is covered with the organic protective film, but the film is not formed where the resistor bodies are located (so the heating resistor/RTDs remain exposed).
- § 102 assessment: Anticipates nothing in claim 1 on its own. It discloses elements (a) thin-wall portion with heating resistor + RTDs, and (b) protective film with the resistors exposed. It does not disclose the resin sealing with a partial-exposure portion, the bonding wire, or — decisively — "multiple slits between the region covered with the resin and the thin-wall portion." The '957 spec itself distinguishes JP3610484 for exactly this gap ("there is room for consideration in partially exposing an area that includes the thin-wall portion… with the periphery of the flow sensor element sealed with resin"). Best treated as background/closest general art, not an anticipatory reference.
US20040025585A1 — "Flow sensor and method of manufacturing the same"
- Full citation: US 2004/0025585 A1; priority 2002-05-10; published 2004-02-12; inventor Koji Seki.
- Description: A flow sensor and its fabrication method (semiconductor-type flow sensor manufacturing). It is a § 102(b)/§ 102(e)-era reference squarely in the thermal-flow-sensor fabrication field.
- § 102 assessment: Date-qualified § 102(a)/(b) art, but I could not retrieve the full disclosure in this session, so I cannot map it element-by-element. On the record available, it does not appear to disclose the claim-1 combination (resin partial-exposure + bonding-wire-covering resin + multiple slits in the protective film between the resin-covered region and the thin-wall portion). I flag this as unverified rather than treat it as non-anticipatory.
JP2009270930A — "Thermal flow sensor"
- Full citation: JP 2009-270930 A; priority 2008-05-07; published 2009-11-19; Denso Corp.
- Description: A Denso thermal flow sensor (also appears in the "Similar Documents" list of the record). § 102(b) art.
- § 102 assessment: Thermal-flow-sensor structural art. No indication it discloses the multiple-slits-between-resin-and-thin-wall limitation. Not anticipatory of claim 1 on the available record.
US20100077851A1 — "Air Flow Meter" ← most relevant along with item 12
- Full citation: US 2010/0077851 A1; priority 2008-09-30; published 2010-04-01; Hitachi Automotive Systems, Ltd. (issued as US 7,992,435).
- Description: Discloses a measuring element with a semiconductor substrate, electrical insulating film, heating resistor body, resistance temperature detector body, and an organic protective film. The peripheral part of the diaphragm section is covered by the protective film while the resistor bodies remain uncovered — and, notably, the reference discloses that "outside a periphery of the diaphragm section in a region where the protective film is formed, a slit is formed in the protective film along the periphery of the diaphragm section."
- § 102 assessment: This is a strong § 102(b) reference for the "slit in the protective film" sub-feature, and it antedates the '957 priority date. However, it does not disclose (i) the resin that covers part of the device including the bonding wire while leaving the thin-wall region exposed, nor (ii) "multiple" slits positioned between the resin-covered region and the thin-wall portion. Its slit is described for dust-impact resistance, not resin-leakage control. So it anticipates neither claim 1 nor claim 2; it is best used in an obviousness combination for the slit concept.
CN101713676A — "Air flow meter"
- Full citation: CN 101713676 A; priority 2008-09-30; published 2010-05-26; 日立汽车系统株式会社.
- Description: The Chinese family member of US20100077851A1 (same priority date and title).
- § 102 assessment: Same disclosure as item 4; if anything it is cumulative of US20100077851A1. No independent anticipation.
US20110023597A1 — "Thermal flow meter"
- Full citation: US 2011/0023597 A1; priority 2009-07-30; published 2011-02-03; Hitachi Automotive Systems, Ltd.
- Description: Thermal flow meter; § 102(b) art in the same assignee's mass-air-flow line.
- § 102 assessment: Structural thermal-flow-meter art. No disclosure identified of the claim-1 combination or the multiple-slits-between-resin-and-thin-wall limitation. Not anticipatory on the record available.
US20110107832A1 — "Thermal Type Fluid Flow Sensor and Fabricating Method"
- Full citation: US 2011/0107832 A1; priority 2009-11-06; published 2011-05-12; Hitachi Automotive Systems, Ltd. (issued as US 8,468,883).
- Description: A thermal fluid flow sensor with a humidity detecting portion and an air-flow detecting portion; the humidity portion has a first heat-generating resistor, an air-cavity layer, and a first film with plural holes; the air-flow portion has a second heat-generating resistor and plural temperature-measuring resistors.
- § 102 assessment: The "plural holes" are vias through a film over a cavity, not a protective-film slit between a resin-covered region and the thin-wall portion, and this reference is not about resin partial-exposure molding. It does not anticipate claim 1. For claim 2 (resistor over the substrate, slits formed so as to expose the resistor) it is likewise distinguishable — no slit-based resistor exposure.
JP2011119500A — "Sensor device, and method of manufacturing the same"
- Full citation: JP 2011-119500 A; priority 2009-12-04; published 2011-06-16; Denso Corp.
- Description: A sensor device and its manufacturing method (Denso); § 102(b) art relevant to sensor packaging/manufacture.
- § 102 assessment: No mapped disclosure of the claim-1 combination. Not anticipatory on the record available.
US20120060599A1 — "Thermal Type Air Flow Meter"
- Full citation: US 2012/0060599 A1; priority 2010-09-09; published 2012-03-15; Hitachi Automotive Systems, Ltd.
- Description: Thermal air-flow-meter structure; § 102(b) art in the same family line. Filed/published before the '957 priority date.
- § 102 assessment: No disclosure identified of "multiple slits between the region covered with the resin and the thin-wall portion." Not anticipatory.
JP2011050787A — "Game machine"
- Full citation: JP 2011-050787 A; priority 2010-12-17; published 2011-03-17; Sansei R&D:Kk.
- Description: A game machine — facially unrelated to thermal airflow sensing. Its appearance in the citation table is anomalous.
- § 102 assessment: No § 102 anticipation of any claim (no subject-matter overlap). I also flag a date inconsistency in the record: a priority date of 2010-12-17 with a publication date of 2011-03-17 is a ~3-month gap, implausible for a JP unexamined application — this looks like a data artifact in the citation table, reproduced here without correction per the strict-ID rule.
US20120240674A1 — "Thermal fluid flow sensor and method of manufacturing the same"
- Full citation: US 2012/0240674 A1; priority 2011-03-25; published 2012-09-27; Hitachi Automotive Systems, Ltd.
- Description: Thermal fluid flow sensor and manufacturing method (Hitachi); § 102(b)/§ 102(e)-era art with an effective date (2011-03-25) before the '957 priority date.
- § 102 assessment: Same-assignee sensor-structure art; no identified disclosure of the multiple-slits-between-resin-and-thin-wall limitation. Not anticipatory on the record available.
US20140159174A1 — "Flowmeter" ← closest reference to the inventive feature
- Full citation: US 2014/0159174 A1; priority 2011-07-13; published 2014-06-12; Hitachi Aautomotive Systems, Ltd. (spelling as in the record).
- Description: A flowmeter with a silicon substrate having a diaphragm (thin film) with a heater, an aluminum pad, an organic protective film 9, and a mold resin 1 covering the substrate with a partial "exposed portion 2" exposing the diaphragm to the measurement airflow. A gold wire 12 connects the element to an external terminal through an aluminum pad. In a second embodiment, a slit 20 is formed as a removal portion in the organic protective film, and a second organic protective film 19 is arranged to surround an end of the diaphragm and is fixed to the mold resin 1 — expressly for (i) preventing moisture penetration at the mold-resin/film interface and (ii) reinforcing the diaphragm end against stress concentration.
- § 102 assessment: This is the most on-point reference for the '957 slit/barrier concept, and it discloses elements (a)–(d) of claim 1 (thin-wall/heater; organic protective film with the heater exposed; bonding wire; resin covering part of the device with the thin-wall region exposed). It still does not disclose "multiple slits between the region covered with the resin and the thin-wall portion" — it shows a single slit (20) plus a diaphragm-surrounding film (19), and its stated purpose is moisture/corrosion and diaphragm reinforcement, not resin-leak trapping. Date caveat: priority 2011-07-13 precedes the '957 priority date, but its publication (2014-06-12) postdates 2012-06-29. It can therefore be § 102 art only under pre-AIA § 102(e) (as a published application/national-stage with an earlier effective U.S. filing date) — not under § 102(a)/(b). Verification of its § 371/§ 102(e) date is required to rely on it. Best use: primary § 103 reference for the slit/partial-exposure combination.
US20150122050A1 — "Flow sensor"
- Full citation: US 2015/0122050 A1; priority 2012-04-06; published 2015-05-07; Hitachi Automotive Systems, Ltd.
- Description: A flow sensor with a first semiconductor chip having a flow sensing unit on the main surface and a diaphragm on the rear surface; part of the chip is sealed with a sealing-body resin while the flow sensing unit is exposed, and at a cross-section parallel to the gas flow "an upper surface of the resin making contact with an end of the first semiconductor chip is lower than an upper surface of the first semiconductor chip and a cavity is formed on an upper surface of the resin." A gold wire connecting the chip to substrate wiring is fixed with potting resin.
- § 102 assessment: Directly relevant to partial-exposure resin molding and to the bonding-wire-covered-by-resin element of claim 1. It does not disclose a protective film with multiple slits between the resin-covered region and the thin-wall portion. Date caveat: priority 2012-04-06 is before the '957 priority date, so it is at least § 102(e) art (published 2015-05-07, post-priority). Not a single-reference anticipation of claim 1; useful in a § 103 combination.
US20150330820A1 — "Physical Quantity Sensor"
- Full citation: US 2015/0330820 A1; priority 2012-12-17; published 2015-11-19; Hitachi Automotive Systems, Ltd.
- Description: A physical-quantity sensor (Hitachi).
- § 102 assessment: Not § 102 prior art against the '957 claims — its priority date (2012-12-17) is after the '957 priority date (2012-06-29). It appears as a citation because it shares the field/assignee (likely an IDS-style citation), not because it predates the invention.
Non-Patent Citation
- International Search Report (PCT/ISA/210) dated Jul. 16, 2013, with English translation (2 pages). This is the ISR for PCT/JP2013/065912. It is not itself a prior-art teaching; it documents the art the ISA considered.
"Cited By" (not prior art)
- US20190178694A1 (2019-06-13; Hitachi Automotive Systems; priority 2012-06-29) is a later publication by the same assignee in the same family — a continuation-stage application citing the '957 patent. It is not prior art (same priority date).
3. Bottom line on § 102
No cited reference anticipates claim 1. Every element of claim 1 is individually disclosed somewhere in the cited art, but no single reference discloses the full combination — decisively, the limitation that the protective film has "multiple slits between the region covered with the resin and the thin-wall portion."
- Claim 1 (independent): Closest are US20140159174A1 (single slit 20 + diaphragm-surrounding film 19 fixed to mold resin, with partial-exposure molding) and US20100077851A1 / CN101713676A (a slit in the protective film along the diaphragm periphery). Each misses the "multiple slits positioned between the resin-covered region and the thin-wall portion" requirement. Anticipation fails; these are § 103 combination candidates.
- Claim 2 (dependent): Requires the slits to be formed so as to expose a resistor formed over the semiconductor substrate. None of the cited references discloses slit-based exposure of an on-substrate resistor for that purpose. No § 102 anticipation.
If any single-reference rejection was made during prosecution, the record reproduced here does not show it (the record shows only issuance and routine post-grant events). The cited set reads as an obviousness/IDS collection centered on the assignee's own prior packaging art, with US20140159174A1 and US20100077851A1 as the two most pertinent references.
4. Caveats and points of uncertainty
- Full text not retrieved for several references. I obtained substantive disclosure detail only for JP3610484B2, US20100077851A1 / US7992435, US20110107832A1, US20140159174A1, and US20150122050A1. For US20040025585A1, JP2009270930A, US20110023597A1, JP2011119500A, US20120060599A1, US20120240674A1, and US20150330820A1 I could not pull the full specification in this session. Those § 102 mappings are provisional and should be re-verified against the actual documents.
- Statutory-date analysis is date-sensitive. For any reference published after 2012-06-29 but with an earlier effective date (US20140159174A1; US20150122050A1), reliance is limited to pre-AIA § 102(e); confirm the § 371/national-stage or earliest-effective-U.S.-filing date before asserting it as art. US20150330820A1 is post-priority and is not § 102 art here.
- Record artifacts reproduced, not corrected: "Hitachi Aautomotive Systems, Ltd." (item 12) and "AI wiring" (the '957 spec) are as they appear; JP2011050787A ("Game machine," Sansei R&D) shows an implausible 3-month priority-to-publication gap and is likely a table artifact — it has no § 102 relevance to this patent.
- Examiner vs. third-party citation status. The record's "*" convention distinguishes examiner-cited from third-party-cited references; the reproduced table does not clearly preserve that distinction for all rows, so I treated all listed references as "of record" without attributing each to the examiner.
- This is an analysis of the references of record, not an exhaustive prior-art search. I did not run independent prior-art searching beyond the cited set, so I make no claim that the cited art is the most relevant art that exists.
Generated 9/28/2026, 11:34:05 PM
Obviousness
Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.
I'll ground the analysis by pulling details on the specific references cited on this patent's face.
§103 Obviousness Analysis — U.S. Patent No. 10,240,957 ("Thermal airflow sensor")
Building on the earlier sections: the bibliographic/continuity record, claim set (2 claims; claim 1 the sole independent claim), and the best-efforts negative litigation finding are not repeated here. This section analyzes only obviousness under 35 U.S.C. §103, using the references listed in the patent's own "Patent Citations"/"Citations" (Prior Art) section of https://patents.google.com/patent/[US10240957B2](/patent/US10240957B2)/en.
1. Governing law and why it matters here
The '957 claims are entitled to an effective filing date of 2012-06-29 (JP 2012-146286) through the §119/§120/§365 chain (PCT/JP2013/065912 filed 2013-06-10; Ser. Nos. 14/410,713 → 15/495,268 → 15/979,301). Because no claim has an effective filing date on or after 2013-03-16, pre-AIA §§102/103 apply. Two consequences drive the analysis:
- A U.S. application publication is available as prior art only as of its U.S. filing date — foreign priority does not push that date back (In re Hilmer). So several same-family Hitachi publications on the face of the '957 are date-barred (see §3).
- Pre-AIA §103(c) removes art "qualifying as prior art only under §102(e), (f) or (g)" when commonly owned at the time the invention was made. Most of the molding-related references here are Hitachi/Hitachi Automotive Systems documents, so common ownership is a live disqualification risk for the §102(e)-only ones — but not for printed publications qualifying under §102(a)/(b).
2. The claim to be tested — element decomposition
Claim 1 (only independent claim):
| # | Limitation |
|---|---|
| L1 | A thermal airflow sensor |
| L2 | Semiconductor device having a thin-wall portion on which a heating resistor and resistance temperature detectors are provided |
| L3 | Protective film on a surface of the semiconductor substrate so that the heating resistor is exposed |
| L4 | A bonding wire electrically connected to the semiconductor device |
| L5 | Resin covering part of the device so that the bonding wire is covered and the region including the thin-wall portion is exposed |
| L6 | The protective film has multiple slits between the region covered with the resin and the thin-wall portion |
Claim 2 adds: (L7) a resistor formed over the semiconductor substrate, and (L8) the slits are formed so as to expose that resistor.
Claim-construction note that frames the whole analysis: L6 is the only limitation not squarely met by the field's pre-2012 molding art. L6 is also purely positional and structural — it does not require the slits to be closed loops, to be under or outside the resin, to be filled or unfilled, or to perform any recited function. The specification's principal (second) embodiment shows a single enclosing slit 35, and only the fifth embodiment (FIG. 14) shows "multi‑staggered slits." There is an internal inconsistency in the description: the fourth-embodiment passage refers to "each of the slits of the first embodiment," although the first embodiment (FIGS. 1–4) discloses no slit at all. Flagging this because it (a) confirms that "multiple" was a deliberate narrowing relative to the parent claims, and (b) is relevant to how broadly L6 can be read. I have not reviewed the file wrappers of the parents (US 9,664,546 / US 10,001,394) in this session, so I cannot state what the examiner applied against the earlier, broader claims — that is the single most important verification task for this analysis (§9).
3. Availability of the face-cited references (dates checked against the '957 record)
| Reference (as listed on the face) | Listed date | §103 availability |
|---|---|---|
| JP3610484B2 — Hitachi, "Thermal air flow meter" (= "Patent Document 1" of the '957) | 2005-01-12 (grant) | Yes — §102(b). Its laid-open, JP2001-050787A (2001-02-23), is identifiable from the record by matching filing date (1999-08-10), title and assignee. |
| US20040025585A1 (Seki) — "Flow sensor and method of manufacturing the same" | 2004-02-12 | Yes — §102(b). |
| JP2009270930A — Denso, "Thermal flow sensor" | 2009-11-19 | Yes — §102(b). |
| US20100077851A1 — Hitachi Automotive, "Air Flow Meter" (and its CN101713676A counterpart) | 2010-04-01 / 2010-05-26 | Yes — §102(b). |
| US20110023597A1 — Hitachi Automotive, "Thermal flow meter" | 2011-02-03 | Yes — §102(b). |
| US20110107832A1 — Hitachi Automotive, "Thermal Type Fluid Flow Sensor and Fabricating Method" | 2011-05-12 | Yes — §102(b). |
| JP2011119500A — Denso, "Sensor device, and method of manufacturing the same" | 2011-06-16 | Yes — §102(b). |
| JP5208099B2 family (Hitachi Automotive) — "Flow sensor, method for manufacturing the same, and flow sensor module"; EP counterpart EP 2 339 302 A1 published 2011-06-29 | 2009-12-11 priority; EP A1 2011-06-29 | Yes — §102(b) (published more than one year before the earliest U.S. filing in the chain, the 2013-06-10 international filing, per 35 U.S.C. §363). |
| US20120060599A1; US20120240674A1 | 2012-03-15; 2012-09-27 | §102(e)/(a) only → §103(c) common-ownership risk. |
| US20140159174A1 (Hitachi, "Flowmeter") | published 2014-06-12 (listed priority 2011-07-13) | Probably not prior art. Published after the priority date; its §102(e) date is its U.S. filing/national-stage date rather than the JP priority (Hilmer), which post-dates 2012-06-29. Plus §103(c) risk. |
| US20150122050A1 (Hitachi, "Flow sensor") | published 2015-05-07 (listed priority 2012-04-06) | Same problem; treat as non-art absent confirmation of a pre-2012-06-29 U.S. filing date. |
| US20150330820A1 (Hitachi, "Physical Quantity Sensor") | listed priority 2012-12-17, published 2015-11-19 | NOT prior art — contradiction to flag. Its earliest date post-dates the '957 priority date (2012-06-29), so it cannot be used in a §103 combination despite appearing in the patent's citation list (it was cited during prosecution, but not as a date-qualifying reference). |
| JP2011050787A (Sansei R&D, "Game machine") | 2011-03-17 | Non-analogous; no technical relevance. Do not conflate with JP2001050787A, which is the Hitachi "Thermal air flow meter" laid-open corresponding to JP3610484B2 — two different documents with nearly identical numbers. |
| JP5675716B2 | 2015-02-25 | The same invention's JP family member; not art. |
Additional prior art identified inside the record (not on the '957's own face list): US2015/0330820A1's background identifies (a) JP-A-2009-49298 — a mold with a protruding portion meshed with the lead frame to form a depressed groove portion between the detector unit and the electrode unit of the semiconductor element, into which mold resin is introduced for an anchoring effect, preventing peeling/cracking around the opening; and (b) JP-A-2010-50452 — a buffer layer (epoxy, silicone rubber or other organic material) at the region contacting the housing at the outer periphery of the opening, to prevent the mold from breaking the detector unit and to relax stress. Both are genuine pre-2012-06-29 art, but I know their content only secondhand, through that characterization — verify before relying on them.
4. What the usable references teach, mapped to the limitations
| Ref | Teaches | Maps to |
|---|---|---|
| JP3610484B2 / JP2001-050787A | Flow sensor element whose surface carries an organic protective film primarily to improve reliability of the thin-wall portion formed by back-side removal, giving the thin-wall insulating film enhanced resistance to dust — this is the '957's own characterization of "Patent Document 1" in its Background | L1, L2, L3 (partial) |
| US20100077851A1 (Hitachi) | Measuring element with semiconductor substrate, electrical insulating film, heating resistor body, resistance-temperature-detector bodies, and a protective film covering the peripheral part of the diaphragm; expressly notes that if the RTD bodies are covered by the protective film, detector characteristics degrade — i.e., the resistor bodies must remain uncovered while the diaphragm periphery is covered; also addresses diaphragm deflection from excess film stress | L2, L3 |
| JP5208099B2 / EP 2 339 302 A1 (Hitachi) | Transfer-molding a flow sensor in which the electric-control-circuit surface and part of the semiconductor device are covered with resin while the airflow-sensing/diaphragm portion is exposed; mold has a movable insertion piece (insertion die) slidable in the mold over a substrate/lead-frame opening; an elastic film between the upper mold and the element so the mold does not contact the airflow sensing unit, absorbing dimensional variation of the element in the thickness direction; stated object is preventing flash or chip cracking during clamping | L1, L2, L4 (gold wire/pads), L5 |
| JP2009270930A (Denso) | Thermal flow sensor with a sensor chip carrying a flow-detection section and a pad, molded to cover the chip‑to‑lead connection while the flow detection section is exposed, plus a "dam" arranged on the substrate surface separating the flow-detection forming region from the pad forming region whose function is to suppress the flow of the sealing resin and thereby prevent fouling of the flow detection section by sealing resin; the dam is dimensioned so its interfacial tension with the resin exceeds the gravity-driven flow force | L4, L5, and the functional core of L6 |
| US20040025585A1 (Seki) | Thermal flow sensor die with a diaphragm portion integrally formed in a substrate and an electrical insulating film carrying the flow-velocity detecting means, plus fabrication methods (bonding/fixing of the die to a body) | L2 (background) |
| US20110023597A1, US20110107832A1, JP2011119500A, US20120060599A1 | Same-assignee thermal-flow-meter / thermal-fluid-flow-sensor and sensor-device families; US20110107832A1's family counterpart (EP 2 204 346 A1) describes a measuring element with a heater resistive element in the diaphragm and an air-temperature-measuring resistive element on the semiconductor substrate outside the diaphragm — i.e., a resistor formed over the semiconductor substrate adjacent the thin-wall portion | L2, L7 |
| JP-A-2009-49298 (per US2015/0330820's characterization) | Depressed groove portion between the detector unit and the electrode unit, filled by mold resin for an anchoring effect, to prevent peeling/cracks around the mold opening | L6, and the "trap" function |
| JP-A-2010-50452 (per US2015/0330820's characterization) | Organic buffer layer at the periphery of the mold opening — anti-fracture and stress-relaxation | L3, L6 motivation |
5. Combination A (primary §103 combination) — claims 1 and 2
JP3610484B2 (JP2001-050787A) + US20100077851A1 in view of JP5208099B2 (EP 2 339 302 A1) and JP2009270930A, optionally with JP-A-2009-49298 / JP-A-2010-50452.
Mapping
- L1–L3: JP3610484 and US20100077851 both describe a MEMS thermal airflow sensor having a semiconductor substrate with a back-etched thin-wall portion/diaphragm, a heating resistor on the thin wall, upstream/downstream resistance temperature detectors, and an organic protective film patterned so that the resistor bodies remain exposed to the measured air while the periphery of the thin wall is covered (US20100077851 expressly warns that covering the RTD bodies degrades their characteristics — a direct teaching of leaving the heating resistor exposed).
- L4–L5: JP5208099/EP 2 339 302 teaches the exact package: the element on a lead frame, bonded with a gold wire, with the circuit/wire surfaces covered by resin while the airflow-sensing portion is exposed, and it teaches the tooling (movable insertion piece; elastic film so the mold does not contact the sensing unit) needed to make that partial-exposure package. JP2009270930 teaches the same partial encapsulation (connection covered, detection section exposed).
- L6: JP2009270930's dam and JP-A-2009-49298's depressed groove both reside on the chip surface between the resin-covered region and the detection region. Their stated function — suppress sealing-resin flow, prevent fouling of the detection section, anchor the resin, prevent peeling/cracking at the mold opening — is the same problem the '957 identifies and the same function its slits perform ("the slit 35 traps the mold resin 60 and prevents it from flowing to the thin-wall portion 25").
Motivation / KSR rationales
- Same field, same problem, same device. All references are directed to thermal airflow sensors for internal-combustion-engine intake air metering, mounted on a lead frame and packaged by partial-exposure transfer molding. Combining them is the "use of a known technique to improve a similar device in the same way" and "combining familiar elements according to known methods" (KSR rationales C and A).
- The problem was known and the '957's background admits it. The '957's own Background states that during partial-exposure molding one must press the insertion die with some force or "the mold resin could flow into the exposed portion," and that the admissible pressing force has only "a margin to certain extent." JP2009270930 is expressly directed to "suppressing the fouling by sealing resin of a flow detection section," and JP5208099 is expressly directed to preventing flash when clamping. The motivation therefore comes from the art itself, not from hindsight.
- Implementation as slits in the film is the obvious way to build a barrier in this device. The protective film is already applied uniformly by spinner and then "partially removed by etching through patterning technology" (the '957's own admission; the same patterning is standard in US20100077851 and US20140159174). Forming a film-free trench requires no new process step and no new material. By contrast, JP2009270930's raised dam imposes dimensional constraints (height below the resin level; interfacial tension exceeding the flow force) that are avoided by removing film instead of adding a body — a design incentive favoring the slit form.
- A film-free trench does double duty, as JP-A-2009-49298 demonstrates (resin anchoring), and it avoids adding height in the airflow path, which a raised dam does not.
- Expected result is mechanical and predictable, and directly analogous to the admitted operation of the dam/groove art (blocking a flow front); no unpredictable mechanism is invoked.
Reasonable expectation of success: high. The only technically uncertain element is the mapping of "dam"/"groove" to "slit in the protective film" (see §8).
6. Combination B (cleaner L6 mapping) — and a stronger variant
JP3610484B2 / US20100077851A1 + US20140159174A1 (as the secondary teaching) + JP5208099B2/EP 2 339 302 (for the mold process).
US2014/0159174 ("Flowmeter," Hitachi) describes a flow-rate detection element on a lead frame molded with a mold resin such that part of the element is exposed through an exposed portion, an organic protective film (polyimide or polybenzoxazole) covering the aluminum wires, and — critically — a "removal portion" disposed in the organic protective film with the mold resin adhered to the underlying inorganic insulating film in the band between the exposed portion and the aluminum wires, for adhesion/corrosion-resistance reasons. That is, structurally, a film-removed band located between the resin-covered region and the exposed region — i.e., a slit in the protective film in the claimed position, and it is explicitly a deliberate, patterned feature of the film design, not an artifact.
Caveat that materially weakens this combination: US2014/0159174 published 2014-06-12 and its §102(e) date is its U.S. filing date, which post-dates the '957 priority date; and it is Hitachi-owned. It should therefore be treated as probably unavailable art, and it cannot carry a §103 case on its own. It is best used as evidence of what a POSITA was doing, and — because the applicant itself cited it — as an admission-adjacent item, rather than as a date-qualifying reference. If a pre-2012-06-29 U.S. filing date can be verified for it, this combination becomes the strongest one because it collocates the very structure (patterned removal band in an organic film at the resin/exposure boundary) with the same flow-sensor package.
7. The "multiple" limitation — why two or more slits is an obvious design choice
L6 requires multiple slits. On the face-cited art, the disclosure is of a single barrier (one dam; one groove; one removal portion). Multiplicity is nevertheless rendered obvious on several independent grounds:
- Geometry of the part. The thin-wall portion is a rectangle; the insertion die can fail to seal on more than one of its four sides. The '957 itself reasons that "if it is known beforehand that the insertion die tends to be in uneven contact with the semiconductor substrate 20, the direction in which a gap is highly likely to occur can be identified. If the slit is formed in that direction, the slit prevents the leaking mold resin 60 from reaching the thin-wall portion 25." Once the leakage direction is known to be potentially more than one, placing two or more barriers is the routine redundancy expedient — the classic "improvement by a routine expedient" and "obvious to try" rationales.
- Reliability engineering. A second, staggered barrier is a redundant backstop if the first is bypassed at the film/substrate corner or if the trench is under-filled during a given shot. Increasing the number of barriers directly increases the margin on the very manufacturing-variation problem (die-height variation, movement-controlled pressing) the '957's Background describes and JP5208099 addresses with an elastic film.
- Stress isolation. Isolating the resin-side film from the diaphragm-edge film by a gap is the stated benefit of the second/third embodiments (FIG. 9). Selecting nested isolation gaps to also decouple other film islands is the same technique applied to a further region of the same device — KSR rationale C.
- The applicant's own framing. The specification treats "staggered multiple slits" (FIG. 14) as an alternative to the single enclosing slit with the same stated result — i.e., the inventor regarded multiplicity as a variation on, not a departure from, the single-slit concept. That is strong internal evidence of the predictability of the added slits.
8. Claim 2 — the resistor-exposing slits
Claim 2 requires a resistor formed over the semiconductor substrate and slits formed so as to expose it. The '957's own specification explains this in the fifth embodiment: where it is desired, "as in the case of the thin-wall portion 25, to expose a temperature sensor 37 formed over the semiconductor substrate for the sake of better thermal responsiveness, the protective film 31 needs to be formed inside the slit."
Obviousness of claim 2 follows from:
- The on-substrate resistor is old and conventional: an air-temperature-measuring resistive element formed on the semiconductor substrate outside the diaphragm is standard in this exact art (as described in the thermal-fluid-flow-sensor measuring element of the US20110107832A1/EP 2 204 346 family, and the resistor/detector bodies of US20100077851). No claim-2 element is novel as such.
- The motivation is the same as for the thin-wall portion: expose the thermally responsive element to the measured medium while keeping the mold resin (and moisture) away from it. JP2009270930's stated purpose — suppress sealing-resin fouling of the detection section — applies a fortiori to a bare temperature-sensing resistor, which is degraded if resin covers it (US20100077851 says as much for the RTD bodies).
- Once claim 1's multiple-slit structure exists between the resin front and the thin-wall portion, configuring one of the plural slits (or the island between two slits) to expose an adjacent known resistor is a mere rearrangement of parts with a predictable result — KSR rationales A/B/F.
Claim 2 therefore rises and falls with claim 1 plus the routine placement of a known air-temperature resistor; it adds essentially no independent inventive weight.
9. Anticipation (§102) check — not the real battleground
No single earlier reference appears to disclose all of L1–L6 with multiple slits. The closest single-document possibilities are:
- The JP5208099/EP 2 339 302 family, which discloses the package (L1, L2, L4, L5) and the tooling for partial exposure but not plural slits in a protective film;
- US20140159174A1, which discloses the patterned removal band in the organic film at the exposure boundary but whose second and third embodiments' film patterns I could not verify (I did not retrieve the FIG. 3 / FIG. 6 / FIG. 10 plan views). If those plan views show multiple discrete removal portions, US2014/0159174 would come close to anticipating L6 — but it is also probably date-barred, so this is a curiosity rather than an invalidity ground.
The realistic conclusion is that the '957's exposure is under §103, concentrated entirely on L6.
10. Weaknesses, counterarguments, and how the patent likely survives
- The "slit" mapping is the soft joint. JP2009270930's dam is a raised body, not a removed film band; JP-A-2009-49298's depressed groove is formed by mold/lead-frame tooling, not by etching the protective film. A patent owner will argue that neither teaches a gap in the protective film, and that the '957's slit is a thin-film-layer feature with a distinct function (trapping leaked resin and decoupling resin-shrinkage stress from the diaphragm edge). Expect this to be the pivot of any §103 challenge.
- Date/ownership disqualification of the best molding art. The most architecturally similar references (US2014/0159174; US2015/0122050; and arguably US2012/0060599A1 and US2012/0240674A1 to the extent they are §102(e)-only) are Hitachi-family documents that may be disqualified under §103(c) and/or fail the Hilmer-based §102(e) date test. That leaves JP5208099/EP 2 339 302 and JP2009270930 (Denso) carrying the molding teaching.
- "Multiple" is the deliberate narrowing. The claim as issued was narrowed to plural slits, which suggests the examiner may have located a single-slit or single-groove teaching. If so, the obviousness question collapses to whether adding a second slit is a patentable distinction — on the reasoning in §7, likely not, but the applicant presumably argued otherwise. The prosecution history of the '957, and the claim text of parents US 9,664,546 / US 10,001,394, must be reviewed before relying on this analysis.
- Secondary considerations. No litigation or post-grant proceeding involving the '957 was found (see the earlier Litigation section), so there is no litigation-derived evidence of copying, industry praise, or commercial success with a nexus. If the patent owner were to assert unexpected results, the burden would be to show something beyond the predictable "the resin is blocked by a wall" mechanism the prior art already describes.
- No teaching away. US20100077851 warns that an over-thick protective film can deflect the diaphragm — that arguably supports film-removal (slitting) as the preferred way to reduce local film stress, rather than teaching away.
11. Bottom line
- Claim 1 is vulnerable under §103, on the primary combination of JP3610484B2 (JP2001-050787A) + US20100077851A1 for the sensor/protective film, JP5208099B2 / EP 2 339 302 A1 (and JP2009270930A) for the partial-exposure resin package, and JP2009270930A's resin-suppressing dam (with JP-A-2009-49298's anchoring groove) as the disclosed barrier between the resin front and the detection region; the recitation of multiple slits is then supplied by the routine-expedient, redundancy, and stress-isolation rationales, reinforced by the patent's own treatment of "multi-staggered slits" as an alternative embodiment achieving the identical stated result.
- Claim 2 is more vulnerable than claim 1, because it adds only a known on-substrate resistor (e.g., an air-temperature-measuring resistive element) and a predictable placement of the slits to expose it.
- The principal defenses are the "slit in the protective film" mapping and the date/common-ownership status of the Hitachi molding references — both of which are verifiable facts rather than opinions.
12. Contradictions flagged and verification tasks
- Contradiction: the '957's citation list includes US20150330820A1 (listed priority 2012-12-17, published 2015-11-19), which post-dates the '957 priority date and therefore is not §103 prior art despite appearing as a cited reference.
- Probable non-art: US20140159174A1 and US20150122050A1 are cited on the face but their publication and probable §102(e) dates fall after 2012-06-29; treat as non-art pending verification of an earlier U.S. filing date.
- Number trap: JP2011050787A (Sansei R&D, "Game machine") ≠ JP2001050787A (Hitachi, "Thermal air flow meter," the laid-open corresponding to JP3610484B2). Both appear in the record at different places; do not merge or auto-correct.
- Unverified in this session: (a) the file wrappers and claim text of parents US 9,664,546 / US 10,001,394 and the reexamination/IDS record of the '957 — needed to identify what the examiner actually applied and what was amended; (b) the plan views of US2014/0159174 (FIGS. 3, 6, 10) to see whether multiple removal portions are shown; (c) the technical content of JP2011119500A, US20110023597A1 and US20110107832A1 beyond titles (I verified content only for the references quoted in §4); (d) the actual text of JP-A-2009-49298 and JP-A-2010-50452, which I know only from the background characterization in US2015/0330820A1.
- Specification inconsistency (not §103, but relevant to claim scope): the description's fourth-embodiment passage refers to "the slits of the first embodiment," although the first embodiment discloses no slit; the operative slit disclosure is the second (single enclosing slit 35), third (slit inner/outer periphery films 33/34) and fifth (multi-staggered slits) embodiments — which bears on how broadly "multiple slits" can be construed, and hence on the obviousness analysis of L6.
Generated 9/28/2026, 11:35:21 PM
Extensions
Patent term adjustments, term extensions, continuations, divisionals, family members, and expiration dates.
Derivative works
Defensive disclosure: derivative variations of each claim designed to render future incremental improvements obvious or non-novel.
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