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Tony Stark was mortally wounded by an improvised explosive device. To save Stark from getting shrapnel near his heart, Ho Yinsen implanted a device

 

Tony Stark was mortally wounded by an improvised explosive device. To save Stark from getting shrapnel near his heart, Ho Yinsen implanted a device into Stark's chest using an electromagnet and a car battery, a feat that that saved his life. Later, Stark used the model for the Arc Reactor to replace the car battery with a stronger and more portable power source. Stark assigned his invention to Stark Enterprises and instructed his patent attorneys to file a patent application. During prosecution of the application, the patent examiner initially rejected the claims stating that electromagnets are well known in the art. Further, the examiner states that a PHOSITA would be aware of the portability and power of the Arc Reactor since it has been well documented in its own patent application published publicly more than one year prior to the filing of this new application. Under which patentability requirement did the patent examiner reject the claims?

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