Poidevin7. Baldwin claim 21 depends on claim 20 and recites that the heating assembly includes
a heating element to charge the phase change material and a heat transfer element to distribute
heat from the heating element to the phase change material during charging of the phase change
material. Baldwin claim 22 recites that the heat transfer element is disposed between the heating
element and the phase change material. Baldwin claim 23 specifies that the heat transfer element
is a thermally conductive metal foil.
Frohlich recognizes that Marney does not disclose a heat transfer element that is a
thermally conductive metal foil, disposed between a heating element and the phase change
material. Frohlich relies on Le Poidevin which describes the missing heat transfer element. Le
Poidevin shows, in figure 2 a heater assembly 8, with a heating element 9, and a heat transfer
element 11 made of thermally conductive aluminum foil disposed between the heating element 9
and the layer of phase change material 7. Frohlich argues that it would have been obvious to
modify Marney with Le Poidevin’s heat transfer element, since the heat transfer element
distributes heat evenly from the heating element to the phase change material. Indeed, Le
Poidevin suggests the same and states that the aluminum foil layer(s) “assist in achieving an
even distribution of the heat derived from the heating element layer 9, throughout the device
when being heated from the source of electrical energy, and during the subsequent emission of
heat from the device” (Frohlich Ex. 2012, page 1, lines 93-99).
Baldwin argues that Frohlich provides no motivation for combining Marney and Le
Poidevin. However, Frohlich did provide a statement of motivation - that adding the heat
transfer foil layer to the Marney device would serve to distribute heat evenly from the heating
7 GB 2160965, published 2 January 1986 (Frohlich Ex. 2012).
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