Prosecution Insights
Last updated: April 19, 2026
Application No. 16/949,965

METHOD FOR ELECTRICALLY CONNECTING TO WINDOW HEATER OF VEHICULAR LIFTGATE WINDOW ASSEMBLY

Final Rejection §103
Filed
Nov 23, 2020
Examiner
KIRKWOOD, SPENCER HAMMETT
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Magna Mirrors Of America Inc.
OA Round
4 (Final)
51%
Grant Probability
Moderate
5-6
OA Rounds
4y 0m
To Grant
64%
With Interview

Examiner Intelligence

Grants 51% of resolved cases
51%
Career Allow Rate
121 granted / 238 resolved
-19.2% vs TC avg
Moderate +13% lift
Without
With
+13.0%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
44 currently pending
Career history
282
Total Applications
across all art units

Statute-Specific Performance

§101
1.1%
-38.9% vs TC avg
§103
61.0%
+21.0% vs TC avg
§102
15.5%
-24.5% vs TC avg
§112
19.8%
-20.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 238 resolved cases

Office Action

§103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Response to Amendments The amendments filed 07/17/2025 have been entered. Accordingly claims 1-20 remain pending. Response to Arguments Applicant firstly argues (page 10-11): With respect to the rejection of independent claim 1, Applicant submits that Baum, either alone or in combination with 4Runner and/or any other prior art of record, does not disclose, suggest or render obvious the presently claimed invention. To establish a prima facie case of obviousness, three basic criteria must be met. First, there must be some suggestion or motivation either in the references themselves or in the knowledge generally available to one of ordinary skill in the art to modify the reference or combine the reference teachings. Second, there must be a reasonable expectation of success. Finally, the prior art reference or references when combined must teach or suggest all the claimed limitations. Baum discloses a window with heating conductors and a wiper device, with conducting strips 12, 13 for the wiper extending around a perimeter edge region of the window panel and extending inboard of where a seal is disposed against the window when the window is closed. Conducting strips 31, 32 for the heating conductors are disposed inboard of conducting strips 12, 13 and entirely inboard of the seal. No part of any conducting strip 12, 13, 31, 32 extends across the seal to outboard of the seal. Moreover, the electrical connection to the conducting strips is made inboard of the seal such that cable 19 is needed to connect from the window to the wiring of the vehicle. In rejecting claim 1, the Office Action (at pages 5 and 6) acknowledges that "Baum is silent regarding the bus bar extending outboard of the perimeter region of the inner surface of the glass window panel" and alleges that 4Runner cures the deficiencies of Baum. Applicant respectfully traverses. Specifically, the Office Action at pages 5 and 6 states that 4Runner discloses "the busbar (c) extending outboard of the perimeter region of the inner surface of the glass window panel." However, claim 1 recites establishing busbars inboard of the perimeter region and establishing busbar connecting portions that extend from the busbars and across the perimeter region to the outboard region. "All words in a claim 61203780.1 must be considered in judging the patentability of that claim against the prior art."In re Wilson, 424 F.2d 1382, 1385, 165 USPQ 494, 496 (CCPA 1970); MPEP 2143.03. In sharp contrast to what is claimed herein, 4Runner is merely a collection of photographs allegedly representing the public sale and availability of Toyota 4Runner model years 1996-2002 beginning in the year 1995. Setting aside the fact that the Office Action yet again fails to even establish that the photographs of 4Runner are even prior art, 4Runner, at best, discloses busbars (c) along sides of the window panel and a busbar covering (d) along the busbar at the bottom of the window panel. See annotated Figure 4 and annotated Figure 5 at page 7 of the Office Action and reproduced below. The Office Action labels a seal (a) of 4Runner in annotated Figure 5 and the Office Action states at page 5 "covering v of busbar c resides below window seal as shown in figure 5" (emphasis added). Applicant respectfully traverses. 4Runner does not disclose or suggest a "covering v of busbar c." The statement "covering v to seal area at bottom" was added to the re-annotated photograph and is not at all part of the photographs of 4Runner. In other words, it is not clear that the photographs of 4Runner show such a covering and, to the extent that the photos of 4Runner are even prior art to the presently claimed invention, the addition of the term "covering v" is clearly not part of 4Runner and is clearly not prior art to the present claims and is clearly added using impermissible hindsight reconstruction of the prior art using the present claims as a template. However Examiner respectfully disagrees because the rear window and features thereof the secondary 4Runner reference is of the factory type window manufactured before the present applications priorities, proof is provided by newly supplied supporting reference Bullard NPL (shown below), having publication older than present applications priority date with shared structure to prior 4Runner reference, the covering to busbar is also present. The combination of 4Runner is in modification to the hatch/hinged operation window of Baum, 4Runner modification provides obviousness that the seal occupies space across busbar so that the bus bar connecting portion may be outboard the seal defined viewing area in hatch or rollup operated windows, the busbar covering obvious to cover electrical components at window closed/operational state. Applicant is reminded that the test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference; nor is it that the claimed invention must be expressly suggested in any one or all of the references. Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981). Therefore the rejection is maintained. PNG media_image1.png 200 400 media_image1.png Greyscale PNG media_image2.png 200 400 media_image2.png Greyscale Applicant secondly argues (page 11-12): Moreover, even if 4Runner does show the "covering v of busbar c," and because the window panel of 4Runner is a sliding window1 that moves from the closed position in annotated Figure 5 toward an opened position by moving downward, any busbar covering that may reside below the window seal (a) would never be in a position to contact or cross the seal (a) as the window moves between opened and closed positions. In other words, such a covering would in its entirety always be below the seal irrespective of window position. However Examiner respectfully disagrees because that the cover V of the bus bar if 4Runner is aligned to the seal of the rear window frame when the window is in the closed position and is then removed from seal area when the window is open, the secondary art 4Runner is applied in view of the primary reference Baum providing a hinged glass assembly. As disclosed above, the secondary reference need not provide every element alone and instead make obvious the bodily incorporation of a seal aligned to a busbar covering while the window is shut in view of a hinged window operation. Therefore the rejection is maintained. Applicant thirdly argues (page 12-13): The alleged teaching of 4Runner (which is merely some photographs of rear vertically sliding windows that may or may not even be the same window) of "the busbar (c) extending outboard of the perimeter region of the inner surface of the glass window panel" merely teaches a conventional busbar at the ends of traces of the heater grid and thus fails to disclose or even remotely suggest the claimed busbar connecting portions. That is, at least because 4Runner teaches the busbar (c) extending across the seal (a) and the covering (v) extending entirely beneath the seal (a), 4Runner fails to disclose or suggest establishing busbar connecting portions that electrically connect to the respective busbars and extend from the respective busbars inboard of the perimeter region and across the perimeter region of the inner surface of the glass window panel to an outboard region of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel, and the busbar connecting portions extend transverse to the respective busbars, as claimed (collectively and in combination with the other claim elements). In fact, annotated Figure 4 at page 7 of the Office Action (reproduced above) clearly shows that the busbar (c) is the only element that extends across the seal (a) and the busbar (c) does not change directions or extend transverse to the busbars, and thus 4Runner does not disclose or even remotely suggest busbar connecting portions that electrically connect to respective busbars and that extend from the respective busbars inboard of the perimeter region and across the perimeter region of the inner surface of the glass window panel to an outboard region of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel, with the busbar connecting portions extending transverse to the respective busbars, as claimed (collectively and in combination with the other claim elements). However Examiner respectfully disagrees for the reasons in providing combinations and prior art relevancy/combination as already disclosed above. In regards to the present amendments 4Runner provides transverse portions as cited to in the action and newly cited reference 1A auto provides transverse connection to the busbar in a manner that matches the drawings of the present application as applied to a hatch glass system. Therefore the rejection is maintained. Applicant fourthly argues (page 13-14): Moreover, one of ordinary skill in the art, armed with the likes of Baum, would not look to the sliding window panel of 4Runner, and certainly would not modify Baum in the manner set forth in the Office Action. Baum discloses a hinged window that makes electrical connection to conducting strips via a cable that connects to a respective plug inboard of a window seal and that extends around the seal for connection to the vehicle. The window of Baum itself does not extend past the window seal and therefore offers no outboard portion at which an electrical connection could be made. In stark contrast, 4Runner (in cited part) at best discloses a vertically sliding window that has a heater grid. Even if such a combination were made, it still fails to arrive at the presently claimed invention for at least the reasons set forth above. However Examiner respectfully disagrees because of the reasons of combinations as set forth above and in the action. Applicant fifthly argues (page 14): Further, Applicant respectfully submits that the Office Action's citation to 4Runner is insufficient to support a prima facie case of obviousness. That is, the Office Action appears to allege that the claimed method for providing electrical connection to a window heater outside of a sealing area of a vehicular rear liftgate window assembly is obvious over the prior art, where the prior art cited includes photographs of the public sale of Toyota 4Runner model years 1996-2002 beginning in the year 2002. However, to support the rejection, the Office Action merely annotates photographs that allegedly show features of the cited vehicle without providing any evidence that the pictures in fact represent what was on sale or publicly available on the 4Runner model. That is, Figures 4-6 bare no marking that in anyway indicates the images are representative of the purported 4Runner model, and the Office Action fails to provide any citation to the source of the images. Moreover, Figure 4 appears to represent a listing on Amazon.com for "Heated Back Tailgate Window Back Glass Compatible With Toyota 4Runner 1996- 2002 Models," (emphasis added) and thus at best shows features of a window compatible with the Toyota 4Runner 1996-2002 model years, but that is not necessarily representative of the window publicly available for sale with the original Toyota 4Runner 1996-2002 model years. Without including dates of when the compatible window was actually sold or disclosed, photographs of such a compatible window are not properly cited as prior art. Accordingly, Applicant respectfully submits that the Office Action fails to provide sufficient evidence of a previous public use, sale activity, or other availability of the claimed invention to the public. See MPEP 2133.03(b)(IV)(B). However Examiner respectfully disagrees because even reproduced windows would necessitate connections at the locations outboard the seal area to fit OEM window frames. Additionally a rear window and frame of a 2nd gen Toyota 4 Runners has been added that was originally posted prior to the priority date of the present application and shares the same structural layout, further teaching that the prior reference 4Runner has structure with priority beating that of the present application. Therefore the rejection is maintained. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1, 4 and 6-11 are rejected under 35 U.S.C. 103 as being unpatentable over Baum (US 4,415,196 A) in view of (96-02 Toyota 4Runner Rear Tailgate Glass NPL, herein after referred to as 4Runner) and 1A auto (NPL). Regarding claim 1, Baum discloses (Fig-3-4) a method for providing electrical connection to a window heater outside of a sealing area of a vehicular rear liftgate window assembly, the method comprising: providing a glass window panel (30) configured to be pivotally mounted (mount holes 2 of pivoting hinge 3, see figure 3 and 4) at a rear portion of a vehicle (vehicle 5, any vehicle position anticipated “A window formed by a glass pane for use as a window for a vehicle” (abstract) rear of vehicle depicted in figure 3) so as to be pivotable between a closed position (window 30 closed to seals 24 as shown in figure 3), where the glass window panel is disposed at a rear opening of the vehicle (opening in view of hinge 3) and against a seal (24) that circumscribes the rear opening of the vehicle (circumscribing seal as nature of providing sealing), and an opened position (via hinge 3), where the glass window panel is raised to a generally horizontal orientation (see figure 3 necessitating an increasingly horizontal positioning with actuation of hinge 3); establishing a window heater (traces 33, bus bar 31/32) at a central region of an inner surface of the glass window panel (heating traces 33 at central region of window 30, see figure 4), the window heater comprising a plurality of electrically conductive traces (33) established at the central region of the inner surface of the glass window panel inboard of a perimeter region (12) of the inner surface of the glass window panel; establishing busbars (12/13 and 31/32) at the inner surface of the glass window panel inboard of the perimeter region (as shown in figure 4) and at respective terminal ends (where busbars end at terminals 16/tongue 17, see figure 2) of the plurality of electrically conductive traces; establishing a pair of busbar connecting portions (plurality of connecting terminals 16, see figure 2) at the inner surface of the glass window panel, wherein the busbar connecting portions electrically connect to the respective busbars (nature of busbar connection portions), electrically connecting electrical connectors to the busbar connecting portions (nature of busbar connectors), wherein the electrical connectors are configured to electrically connect to a power source (nature of vehicles trace element window heaters, electrical connectors 18) of the vehicle when the glass window panel is pivotally mounted at the vehicle (via hinge 3, see figure 3); and wherein the perimeter region of the inner surface of the glass window panel comprises a sealing region (region contacting seal 24) that contacts a seal (24) at the vehicle when the glass window panel is pivotally mounted at the vehicle and when the glass window panel is in the closed position (as shown in figure 3). Baum is silent regarding the busbar connecting portion extend from the respective busbars inboard of the perimeter region and across the perimeter region of the inner surface of the glass window panel to an outboard region of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel and wherein the busbar connecting portions extend transverse to the respective busbars and at the outboard region of the inner surface of the glass window panel connect to electrical connectors. However 4Runner teaches the busbar connecting portion (at tab t, solder s where they connect below covered busbar C, see re-annotated fig 6, covered busbar C at transverse section may also be considered a busbar connecting portion as no heater traces are applied thereat) extend from the respective busbars (C) inboard of the perimeter region (compare shape of busbar clearly shown in re-annotated fig-4 to re-annotated fig-5 that shows the curved top of busbar within perimeter of tailgate seal therearound) and across the perimeter region of the inner surface of the glass window panel (where bus bar along bottom is covered by V, see re-annotated figure 4) to an outboard region (where tabs t and solder s exist below cover V, see re-annotated fig-6) of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel (as shown between figures 4 and 5) and wherein the busbar connecting portions extend transverse to the respective busbars (either at transverse section of covered busbar C being the busbar connection portion or at the transverse section where T and S are in electrical connection below C, see re-annotated figures 4 and 6) and at the outboard region of the inner surface of the glass window panel connect to electrical connectors (where electrical connector T exists below sealing area V, see re-annotated figures 4 and 6). The advantage of the busbar connecting portion extend from the respective busbars inboard of the perimeter region and across the perimeter region of the inner surface of the glass window panel to an outboard region of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel and wherein the busbar connecting portions extend transverse to the respective busbars and at the outboard region of the inner surface of the glass window panel connect to electrical connectors, is to eliminate the visibility of electrical connectors from the area of window visible, see figures 4-5-6 providing tabs t soldered s directly to glass without additional wiring exposed to visible area inboard of seal. Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum and 4Runner before him or her, to modify the hinged hatch opening window having exposed wiring and seal hidden busbar of Baum to include the seal passing busbar with outer permitter seal hidden wiring of 4Runner because providing busbar connections at an outboard location of window seal, eliminates the wiring from view through the exposed central portion of the window. PNG media_image3.png 322 624 media_image3.png Greyscale PNG media_image4.png 531 720 media_image4.png Greyscale PNG media_image5.png 780 1208 media_image5.png Greyscale Additionally 1A auto teaches (Fig-A re-annotated below) the busbar connector extending transversely from the general center of the busbar. The advantage of the busbar connector extending transversely from the general center of the busbar, is to evenly distribute heating energy to busbar of a lifting glass hatch rear window as shown in figure below. Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as already modified and A1 auto before him or her, to modify the lift glass seal passing perimeter busbar connection of Baum, to include the lift glass central to traces/busbar transvers busbar connector of A1 auto, because providing a busbar connector to a central location of a busbar reduces voltage drop along busbar as opposed to end mounting the busbar connector to busbar. PNG media_image6.png 961 1443 media_image6.png Greyscale Regarding claim 4, Baum as modified teaches the method of claim 1, Baum as already modified teaches wherein establishing the pair of busbar connecting portions comprises establishing first and second busbar connecting portions (plurality of connectors 16/17, see figure 2), and wherein establishing the first and second busbar connecting portions comprises (i) establishing an outboard portion (outboard being outside seal a of 4Runner, see modification of 4Runner providing busbar/connections running under sealing area a) of the first busbar connecting portion at a first outboard region (region outboard of seal where connector placement has already been modified by 4runner as detailed above) of the inner surface of the glass window panel outboard of the perimeter region of the inner surface of the glass window panel, and (ii) establishing an outboard portion of the second busbar connecting portion at a second outboard region of the inner surface of the glass window panel outboard of the perimeter region of the inner surface of the glass window panel (see 4Runner with both tabs t of both bus bars (Fig-4-6) being outside of the seal contact area (seal a on glass, see figure 5) via continuation of busbar/connections leading to tabs t). Regarding claim 6, Baum as modified teaches the method of claim 4, Baum as already modified teaches wherein electrically connecting electrical connectors to the busbar connecting portions comprises (i) electrically connecting a positive electrical connector (first instance of connector 18, see figure 2) at the first busbar connecting portion (connections as shown in figure 2) at the first outboard region of the inner surface of the glass window panel (in view of the on window interior path of bus bar under seal of the already modifying 4Runner) and (ii) electrically connecting a negative electrical connector (second instance of connector 18, see figure 2) at the second busbar connecting portion at the second outboard region of the inner surface of the glass window panel (in view of the on window interior path of bus bar under seal of the already modifying 4Runner). Regarding claim 7, Baum as modified teaches the method of claim 4, Baum as already modified teaches wherein the outboard portion of the first busbar connecting portion extends upward toward an upper region of the inner surface of the glass window panel (Outboard regions as already modified by 4runner, Baum provides placing connectors of busbar relative to top hinge 3, see figure 3), and wherein the outboard portion of the second busbar connecting portion extends upward toward the upper region of the inner surface of the glass window panel (as disclosed above, busbars run upwards to provide connections proximate side of window having hinges and 4runner as already modifying provides busbars to outboard region beyond seal), and wherein the electrical connectors are electrically connected to the first and second busbar connecting portions at the upper region of the inner surface of the glass window panel (see figure 3 providing connection of busbar at upper and inner portion of window). Regarding claim 8, Baum as modified teaches the method of claim 1, Baum as already modified teaches wherein the busbar connecting portions are established at the inner surface of the glass window panel and extend upward toward an upper region of the outboard region of the inner surface of the glass window panel (Outboard regions as already modified by 4runner, Baum provides placing connectors of busbar relative to top hinge 3, see figure 3), and wherein the electrical connectors are electrically connected to the busbar connecting portions at the upper region of the outboard region of the inner surface of the glass window panel (as disclosed above, busbars run upwards to provide connections proximate side of window having hinges and 4runner as already modifying provides busbars to outboard region beyond seal). Regarding claim 9, Baum as modified teaches the method of claim 1, Baum as already modified teaches wherein electrically connecting electrical connectors to the busbar connecting portions comprises soldering the electrical connectors to the busbar connecting portions (solder connection “Each connector 16 has a base portion which may be soldered or otherwise mounted on a conducting strip (see FIG. 2)” (column 4-5, lines 66-3)). Regarding claim 10, Baum as modified teaches the method of claim 1, Baum as already modified teaches wherein the electrical connectors comprise tab-type connectors (Tongue/tab 17 of Baum, see tab t connections of 4runner figure 6). Regarding claim 11, Baum as modified teaches the method of claim 1, Baum as already modified teaches wherein the electrical connectors comprise snap-type connectors (see press release snap tab of tab connectors, 4Runner figure 6). Claims 5 is rejected under 35 U.S.C. 103 as being unpatentable over Baum in view of 4Runner and 1A auto and in further view of Gold (US 4,997,396). Regarding claim 5, Baum as modified teaches the method of claim 4, Baum as already modified teaches wherein the first outboard region of the inner surface of the glass window panel is at an opposite side of glass window panel from the second outboard region of the inner surface of the glass window panel (see figure 1 providing bilateral split window in relation to busbars and connectors thereof), and wherein the busbars and the plurality of electrically conductive traces of the window heater are established at the central region of the inner surface of the glass window panel (busbars c and traces b inside window seal a, see figure 1). Baum as already modified is silent regarding the busbar and electrical connectors being between the first outboard region and the second outboard region. However Gold teaches (Fig-1-3) the busbar (20) and electrical connectors (42) being between the first outboard region and the second outboard region (see figures 1 and 3 providing electrical connectors 42 having proximity to vertical busbar 20 with traces 18 therebetween). The advantage of providing the electrical connector in proximity to the busbar, is to limit the busbar dimensions relative to height of traces (see figures 1 and 3 providing vertical busbar 20 limited to height of traces with connector 42 proximate to size limited busbar). Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as already modified and Gold before him or her, to modify the busbar having outboard of window seal heating connectors of Baum, with the minimally sized busbar height relative to traces of Gold, because providing the busbars relative to height of traces reduces the necessary size of busbar height to area required by traces. Claims 2 and 3 are rejected under 35 U.S.C. 103 as being unpatentable over Baum in view of 4Runner and 1A auto and in further view of Baranski (US 2011/0233182). Regarding claim 2, Baum as modified teaches the method of claim 1, Baum as already modified teaches further comprising disposing a protective covering (v of 4Runener) element at each of the busbar connecting portions at the perimeter region (see the protective covering v of 4runner over portion of busbar/connection where seal a contacts v between figures 4 and 5) Additionally Baranski teaches tape covering to heater components of a window (protection and discreate visibility of heater components provided by tape or frit type overlay “The discrete electrically conductive layer in FIG. 4 also comprises an optional outer protective layer 43. As the layer does not affect the capacitive function of the capacitor 40, it may be omitted if desired. However, the use of such a protective layer has several advantages. Firstly, the layer offers protection from abrasion of the electrically conductive layer 42 during cleaning of the window. Secondly, if a layer matching the obscuration band print present around the edge of the vehicle window (the ceramic printed material 45 shown in FIG. 4) is provided, the discrete electrically conductive layer becomes effectively invisible to a viewer looking at the busbar region from both inside and outside a vehicle. Preferably, the outer protective layer 43 has a thickness in the range 40 to 100 .mu.m, and may comprise an adhesive layer and a thin polymer film layer, such as KAPTON (polyamide tape available from DuPont), for example, AKAFLEX products, available from August Krempel Soehne GmbH+Co. KG, or flat cable tapes available from GTS Flexible Materials Ltd. Alternatively, the outer protective layer 43 may be formed from an additional printed ceramic material, matching the obscuration band on the heated vehicle window.” [0065]). The advantage of providing covering to heating components of a window is to provide protection and visual aesthetics, see citation to [0065] above. Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as modified and Baranski before him or her, to modify the busbar system of Baum with the protective window covering (tape/adhesive) features of Baranski, because the window covering provides protection and visual aesthetics. Regarding claim 3, Baum as modified teaches the method of claim 2, Baum as already modified teaches wherein disposing the protective covering element comprises adhesively (see tape and adhesive of already modified by Baranski [0065] claim 2) attaching a protective tape (“tape” Baranski [0065]) to the inner surface of the glass window panel and over a portion of each of the busbar connecting portions at the perimeter region of the inner surface of the glass window panel (see protection material v as modified by 4Runner figure 4). Claims 12-14 and 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over Baum in view of 4Runner and 1A auto and in further view of Palajac (US 5,741,043). Regarding claim 12, Baum as modified teaches the method of claim 1, Baum as already modified is silent regarding wherein the glass window panel has a non-light-transmitting coating established at the outboard region at least where the busbar connecting portions are established. However Palajac teaches (Fig-3) wherein the glass window panel (12) has a non-light-transmitting coating (frit 26) established at the outboard region at least where the busbar connecting portions (busbar ends of traces 28, see figure 3) are established (“the ceramic frit layer 26 or coating covers and conceals a region of the inner surface 20 adjacent the peripheral edge 22 inward and preferably forms a continuous strip about the entire perimeter of the glass panel 12.” (column 4, lines 49-62)). The advantage of the glass window panel has a non-light-transmitting coating established at the outboard region at least where the busbar connecting portions are established, is to enhance the visual appearance of a window having heater busbars “When viewed from the outer side, the transparent thickness of the glass panel 12 backed up by the opaque ceramic frit layer 26 provides an appearance of depth and richness which blends well with the surrounding painted or glass areas on the vehicle 14. As illustrated, the inner surface of the glass panel 12 also includes a conventional arrangement 28 for supplying an electrical current to the window assembly 10 for defrosting the glass panel 12.” (column 4, lines 49-62). Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as already modified and Palajac before him or her, to modify the undisclosed window fritting of Baum, with the window fritting of Palajac, because providing window fritting enhances visual appearance of windows having heater busbars. Regarding claim 13, Baum as modified teaches the method of claim 12, Baum as as already modified teaches wherein the non-light-transmitting coating circumscribes a transparent region of the glass window panel (as already modified by Palajac, emphasis added -“the ceramic frit layer 26 or coating covers and conceals a region of the inner surface 20 adjacent the peripheral edge 22 inward and preferably forms a continuous strip about the entire perimeter of the glass panel 12.” (column 4, lines 49-62)), and wherein the plurality of electrically conductive traces of the window heater are established at the central region of the inner surface of the glass window panel at the transparent region (normal to automotive windows to provide the defogging traces 33 to transparent portion, see figure 4). Regarding claim 14, Baum (Fig-2-3-4) discloses a method for providing electrical connection to a window heater outside of a sealing area of a vehicular rear liftgate window assembly, the method comprising: providing a glass window panel (1) configured to be pivotally mounted (via hinge 3) at a rear portion of a vehicle (any position of vehicle window anticipated “glass panes for use as a window for a vehicle having capability of swiveling or tilting about an axis are known in the prior art. By and large, in this adaptation, the windows are used as a rear window, but in special cases, for example, in agricultural, utility and like vehicles, the window may be used as a front window or windshield.” (column 1, lines 15-29)) so as to be pivotable between a closed position (nature of window hatches having hinges 3), where the glass window panel is disposed at a rear opening (area defined by vehicle body 5, see figure 3) of the vehicle and against the seal (24) that circumscribes the rear opening (circumscribed as nature of sealed openings) of the vehicle, and an opened position (window pivoted upward, via hinge 3), where the glass window panel is raised to a generally horizontal orientation (as permitted by hinge 3); establishing a window heater (busbar 31/32 and traces 33, see figure 4) at a central region (area inside window seal 24, see figure 3 and 4) of an inner surface (side opposite exterior hinges 3, see figure 3 and 4) of the glass window panel, the window heater comprising a plurality of electrically conductive traces (33) established at the central region of the inner surface of the glass window panel inboard of a perimeter region (region contacting seal 24, see figure 3 and 4) of the inner surface of the glass window panel; establishing a first busbar (31) at the inner surface of the glass window panel inboard of the perimeter region (as shown figures 3 and 4) and at first terminal ends (where busbars end at electrical connector 16 /tongue 17, see figure 2) of the plurality of electrically conductive traces (see figure 4 providing traces 33 joining busbars 31-32); establishing a second busbar (32) at the inner surface of the glass window panel inboard of the perimeter region (as shown figures 3 with 4) and at second terminal ends (where busbars end at terminals 16/tongue 17, see figure 2) of the plurality of electrically conductive traces (see figure 4 providing traces 33 joining busbars 31-32); establishing a first busbar connecting portion (first busbar portion of 31 leading to terminal 16, see figure 4) at the inner surface of the glass window panel (see figure 4 providing detailed connecting portion 16 in view of figures 3 and 4 showing positioning of connecting portion relative window having extended busbar thereto), wherein the first busbar connecting portion electrically connects to the first busbar (nature of first busbar connecting portion, see figure 2) and extends from the first busbar establishing a second busbar connecting portion (second busbar portion of 32 leading to electrical connector 16, see figure 4) at the inner surface of the glass window panel (see figure 4 providing detailed connecting portion 16 in view of figures 3 and 4 showing positioning of connecting portion relative window having extended busbar thereto), wherein the second busbar connecting portion electrically connects to the second busbar (nature of second busbar connecting portion, see figure 2) and extends from the second busbar electrically connecting a positive electrical connector (18) at the first busbar connecting portion (18 connecting to tongue 17 of positive electrical connector 16, see figure 2) electrically connecting a negative electrical connector (18 connecting to tongue 17 of positive electrical connector 16, see figure 2) at the second busbar connecting portion wherein the positive and negative electrical connectors are configured to electrically connect to a power source of the vehicle when the glass window panel is pivotally mounted at the vehicle (nature of trace heaters of vehicle windows); and wherein the perimeter region of the inner surface of the glass window panel comprises a sealing region (sealing region of window in contact to seal 24, see figure 3) that contacts a seal (24) at the vehicle when the glass window panel is pivotally mounted at the vehicle and when the glass window panel is in the closed position (as shown in figure 3). Baum is silent regarding wherein the glass window panel has a non-light-transmitting coating established at the first and second outboard regions at least where the first and second busbar connecting portions are established. However Palajac teaches the glass window panel (12) has a non-light-transmitting coating (26) established at the first and second outboard regions at least where the first and second busbar connecting portions (busbar ends of traces 28, see figure 3) are established (“the ceramic frit layer 26 or coating covers and conceals a region of the inner surface 20 adjacent the peripheral edge 22 inward and preferably forms a continuous strip about the entire perimeter of the glass panel 12.” (column 4, lines 49-62)). The advantage of the glass window panel has a non-light-transmitting coating established at the first and second outboard regions at least where the first and second busbar connecting portions are established, is to enhance the visual appearance of a window having heater busbars “When viewed from the outer side, the transparent thickness of the glass panel 12 backed up by the opaque ceramic frit layer 26 provides an appearance of depth and richness which blends well with the surrounding painted or glass areas on the vehicle 14. As illustrated, the inner surface of the glass panel 12 also includes a conventional arrangement 28 for supplying an electrical current to the window assembly 10 for defrosting the glass panel 12.” (column 4, lines 49-62). Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as already modified and Palajac before him or her, to modify the undisclosed window fritting of Baum, with the window fritting of Palajac, because providing window fritting enhances visual appearance of the windows having heater busbars. Baum is silent regarding the first and second busbar connecting portions extends across the perimeter region of the inner surface of the glass window panel to a first outboard region of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel, connecting the positive and negative electrical connectors at the first and second outboard region, and wherein the first busbar connecting portion extends transverse of the first busbar; and wherein the second busbar connecting portion extends transverse of the second busbar; the first busbar connecting portion extends from the first busbar inboard of the perimeter region, the second busbar connecting portion extends from the second busbar inboard of the perimeter region. However 4runner teaches the first and second busbar connecting portions (at tab t, solder s where they connect below covered busbar C, see re-annotated fig 6, covered busbar C at transverse section may also be considered a busbar connecting portion as no heater traces are applied thereat) extends across the perimeter region (perimeter as defined by seal contact area V) of the inner surface of the glass window panel to a first outboard region (area outside V) of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel, connecting the positive and negative electrical connectors (of tabs t, connecting busbars with traces therebetween as shown in figures) at the first and second outboard region (regions of instances of t), and wherein the first busbar connecting portion extends transverse of the first busbar (either at transverse section of covered busbar C being the busbar connection portion or at the transverse section where T and S are in electrical connection below C, see re-annotated figures 4 and 6); and wherein the second busbar connecting portion extends transverse of the second busbar (either at transverse section of covered busbar C being the busbar connection portion or at the transverse section where T and S are in electrical connection below C, see re-annotated figures 4 and 6); the first busbar connecting portion extends from the first busbar inboard of the perimeter region (where first busbar crosses seal area indicated by V), the second busbar connecting portion extends from the second busbar inboard of the perimeter region (where second busbar crosses seal area indicated by V), The advantage of the first and second busbar connecting portions extends across the perimeter region of the inner surface of the glass window panel to a first outboard region of the inner surface of the glass window panel that is outboard of the perimeter region of the inner surface of the glass window panel, connecting the positive and negative electrical connectors at the first and second outboard region, and wherein the first busbar connecting portion extends transverse of the first busbar; and wherein the second busbar connecting portion extends transverse of the second busbar; the first busbar connecting portion extends from the first busbar inboard of the perimeter region, the second busbar connecting portion extends from the second busbar inboard of the perimeter region, is to eliminate the visibility of electrical connectors from the area of window visible, see re-annotated figures 4-5-6 providing tabs t soldered s directly to glass without additional wiring exposed to visible area inboard of seal. Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum and 4Runner before him or her, to modify the hinged hatch opening window having exposed wiring and seal hidden busbar of Baum to include the seal passing busbar portion with outer permitter seal hidden wiring of 4Runner because providing busbar connections at an outboard location of window seal, eliminates the wiring from view through the exposed central portion of the window. Additionally 1A auto teaches the busbar connector extending transversely from the general center of the busbar. The advantage of the busbar connector extending transversely from the general center of the busbar, is to evenly distribute heating energy to busbar of a lifting glass hatch rear window. Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as already modified and A1 auto before him or her, to modify the lift glass seal passing perimeter busbar connection of Baum, to include the lift glass central to traces/busbar transvers busbar connector of A1 auto, because providing a busbar connector to a central location of a busbar reduces voltage drop along busbar as opposed to end mounting the busbar connector to busbar. Regarding claim 17, Baum as modified teaches the method of claim 14, Baum as already modified teaches wherein the first outboard region of the inner surface of the glass window panel is at an opposite side of the glass window panel from the second outboard region of the inner surface of the glass window panel (see left right symmetry of busbars and traces of Baum in view of the outboard modification as already provided by 4Runner), and wherein the first and second busbars and the plurality of electrically conductive traces of the window heater are established at the central region of the inner surface of the glass window panel between the first outboard region and the second outboard region (as shown in figure 4 in view of figure 3, the busbars 31/32 and traces 33 are located inboard of seal 24 centrally). Regarding claim 18, Baum as modified teaches the method of claim 14, Baum as already modified teaches wherein the first busbar connecting portion extends upward toward an upper region (see busbar 31 extending upwards, figure 4) of the first outboard region (as already modifying 4runner provides a connection of busbar under the sealing element to the outboard region) of the inner surface of the glass window panel (inner surface of window mounts busbar/connectors as shown in figure 3), and wherein the positive electrical connector (18) is electrically connected to the first busbar connecting portion at the upper region (as shown in figure 3) of the first outboard region (outboard region as already modified by 4Runner) of the inner surface of the glass window panel (inner surface window mounting as shown in figure 3), and wherein the second busbar connecting portion (32) extends upward toward an upper region (see busbar 32 extending upwards, figure 4) of the second outboard region (as already modifying 4runner provides a connection of busbar under the sealing element to the outboard region) of the inner surface of the glass window panel (inner surface of window mounts busbar/connectors as shown in figure 3), and wherein the negative electrical connector (18) is electrically connected to the second busbar connecting portion at the upper region (as shown in figure 3) of the second outboard region (outboard region as already modified by 4Runner) of the inner surface of the glass window panel (inner surface window mounting as shown in figure 3). Regarding claim 19, Baum as modified teaches the method of claim 14, Baum as already modified teaches wherein electrically connecting the positive electrical connector to the first busbar connecting portion comprises soldering (solder connection “Each connector 16 has a base portion which may be soldered or otherwise mounted on a conducting strip (see FIG. 2)” (column 4-5, lines 66-3)) the positive electrical connector (16) to the first busbar connecting portion (see figure 2), and wherein electrically connecting the negative electrical connector (16) to the second busbar connecting portion comprises soldering the negative electrical connector to the second busbar connecting portion (solder connection “Each connector 16 has a base portion which may be soldered or otherwise mounted on a conducting strip (see FIG. 2)” (column 4-5, lines 66-3)). Regarding claim 20, Baum as modified teaches the method of claim 14, Baum as already modified teaches wherein the non-light-transmitting coating circumscribes a transparent region of the glass window panel (as already modified by Palajac (“the ceramic frit layer 26 or coating covers and conceals a region of the inner surface 20 adjacent the peripheral edge 22 inward and preferably forms a continuous strip about the entire perimeter of the glass panel 12.” (column 4, lines 49-62)), and wherein the plurality of electrically conductive traces of the window heater are established at the inner surface of the glass window panel at the transparent region (as shown in figure 4). Claims 15 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Baum in view of 4Runner and 1A auto and Palajac and in further view of Baranksi. Regarding claim 15, Baum as modified teaches the method of claim 14, Baum as already modified teaches further comprising disposing a first protective covering element (4Runner provides covering element c to bus bar at sealing portion a as already modified by the single side busbar and connection system of 4Runner, see figures 4 and 5) at the first busbar connecting portion at the perimeter region (permitter region as necessitated to extend connections away from window to vehicle, see the figures of 4Runner) and disposing a second protective covering element at the second busbar connecting portion (in view of two connecting portions respectively of first and second busbar being extended to a perimeter of the window beyond seal zone, see figure 4 of 4Runner) at the perimeter region to limit the seal contacting the first and second busbar connecting portions (as provided by the seal cover v of 4Runner with permitter region tabs t, see figure 4) when the glass window panel is pivotally mounted at the vehicle and when the glass window panel is in the closed position (see covering over sealing area of busbar figure as modified by 4Runner in view of the seal perimeter of the pivotal liftgate glass of Baum). Additionally Baranski teaches tape covering to heater components of a window (protection and discreate visibility of heater components provided by tape or frit type overlay “The discrete electrically conductive layer in FIG. 4 also comprises an optional outer protective layer 43. As the layer does not affect the capacitive function of the capacitor 40, it may be omitted if desired. However, the use of such a protective layer has several advantages. Firstly, the layer offers protection from abrasion of the electrically conductive layer 42 during cleaning of the window. Secondly, if a layer matching the obscuration band print present around the edge of the vehicle window (the ceramic printed material 45 shown in FIG. 4) is provided, the discrete electrically conductive layer becomes effectively invisible to a viewer looking at the busbar region from both inside and outside a vehicle. Preferably, the outer protective layer 43 has a thickness in the range 40 to 100 .mu.m, and may comprise an adhesive layer and a thin polymer film layer, such as KAPTON (polyamide tape available from DuPont), for example, AKAFLEX products, available from August Krempel Soehne GmbH+Co. KG, or flat cable tapes available from GTS Flexible Materials Ltd. Alternatively, the outer protective layer 43 may be formed from an additional printed ceramic material, matching the obscuration band on the heated vehicle window.” [0065]) The advantage of providing covering to heating components of a window is to provide protection and visual aesthetics, see citation to [0065] above. Before the effective filing date of the claimed invention, it would have been obvious to one of ordinary skill in the art, having the teachings of Baum as modified and Baranski before him or her, to modify the busbar system of Baum with the protective window covering (tape/adhesive) features of Baranski, because the window covering provides protection and visual aesthetics. Regarding claim 16, Baum as modified teaches the method of claim 15, Baum as already modified teaches wherein disposing the first and second protective covering elements comprises (i) adhesively attaching a first protective tape to the inner surface of the glass window panel and over a portion of the first busbar connecting portion at the perimeter region of the inner surface of the glass window panel (as already modified by Baranski, providing protection or visual aesthetics in covering heater components is obvious [0065]) and (ii) adhesively attaching a second protective tape to the inner surface of the glass window panel and over a portion of the second busbar connecting portion at the perimeter region of the inner surface of the glass window panel (as already modified by Baranski, providing protection or visual aesthetics in covering heater components is obvious [0065]). Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Spencer H Kirkwood whose telephone number is (469)295-9113. The examiner can normally be reached 12:00 am - 9:00 pm Eastern. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Steven Crabb can be reached on (571) 270-5095. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /Spencer H. Kirkwood/Examiner, Art Unit 3761 /STEVEN W CRABB/Supervisory Patent Examiner, Art Unit 3761
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Prosecution Timeline

Nov 23, 2020
Application Filed
Jan 12, 2024
Non-Final Rejection — §103
Apr 19, 2024
Response Filed
Jun 24, 2024
Final Rejection — §103
Oct 02, 2024
Notice of Allowance
Dec 27, 2024
Response after Non-Final Action
Jan 14, 2025
Response after Non-Final Action
Apr 16, 2025
Non-Final Rejection — §103
Jul 17, 2025
Response Filed
Oct 20, 2025
Final Rejection — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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