Prosecution Insights
Last updated: August 18, 2026
Application No. 17/413,071

METHOD FOR ESTIMATING THE ATTITUDE OF A VEHICLE

Final Rejection §103
Filed
Jun 11, 2021
Priority
Dec 12, 2018 — EU PCT/EP2018/084590 +1 more
Examiner
LE, HAILEY R
Art Unit
3648
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Volvo Group
OA Round
6 (Final)
80%
Grant Probability
Favorable
7-8
OA Rounds
0m
Est. Remaining
90%
With Interview

Examiner Intelligence

Grants 80% — above average
80%
Career Allowance Rate
138 granted / 172 resolved
+28.2% vs TC avg
Moderate +10% lift
Without
With
+10.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
30 currently pending
Career history
211
Total Applications
across all art units

Statute-Specific Performance

§101
6.9%
-33.1% vs TC avg
§103
58.7%
+18.7% vs TC avg
§102
15.9%
-24.1% vs TC avg
§112
17.8%
-22.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 172 resolved cases

Office Action

§103
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 . Examiner’s Note For applicant’s benefit, portions of the cited reference(s) have been cited to aid in the review of the rejection(s). While every attempt has been made to be thorough and consistent within the rejection it is noted that the PRIOR ART MUST BE CONSIDERED IN ITS ENTIRETY, including disclosures that teach away from the claims. See MPEP 2141.02 VI. “The use of patents as references is not limited to what the patentees describe as their own inventions or to the problems with which they are concerned. They are part of the literature of the art, relevant for all they contain.” In re Heck, 699 F.2d 1331, 1332-33, 216 USPQ 1038, 1039 (Fed. Cir. 1983) (quoting In re Lemelson, 397 F.2d 1006, 1009, 158 USPQ 275, 277 (CCPA 1968)). A reference may be relied upon for all that it would have reasonably suggested to one having ordinary skill in the art, including non-preferred embodiments. Merck & Co. v.Biocraft Laboratories, 874 F.2d 804, 10 USPQ2d 1843 (Fed. Cir.), cert. denied, 493 U.S. 975 (1989). See also Upsher-Smith Labs. v. Pamlab, LLC, 412 F.3d 1319, 1323, 75 USPQ2d 1213, 1215 (Fed. Cir. 2005) See MPEP 2123. Response to Amendment Applicant’s amendment filed 26 May, 2026 is acknowledged and has been entered. Claim objection(s) regarding claim(s) 1 and 6 have been overcome in view of the amendment to the claim(s). Response to Arguments Applicant’s argument filed 26 May, 2026 has been fully considered but is not persuasive because: Applicant’s argument: “Applicant respectfully submits that Kundak fails to disclose or suggest "obtaining ... a GNSS heading of at least one of the first antenna and the second antenna using the GNSS, by computing a direction of movement of the at least one of the first antenna and the second antenna from a plurality of temporally successive GNSS measurements as the vehicle is moving and not turning," as recited by amended claim 1. Kundak instead uses "attitude aiding sensors 132" that are "implemented as inertial aiding sources or inertial navigation sensors (INS)" to obtain heading information. Kundak, 00018. Applicant further respectfully submits that Kundak's inertial sensors provide a heading of the vehicle, not a "GNSS heading" of the antennas computed from "temporally successive GNSS measurements" as amended claim 1 recites. Applicant's review of Kundak did not locate any disclosure of obtaining a GNSS heading of the antennas by computing a direction of movement from GNSS measurements while the vehicle is moving and not turning. Because Kundak does not disclose or suggest obtaining a GNSS heading of the antennas, Applicant further respectfully submits that Kundak also fails to disclose or suggest "calculating... an integer ambiguity fix corresponding to a relative position vector between the first and second antenna using the obtained GNSS heading," as recited by amended claim 1. Applicant respectfully notes that the inventive subject matter of claim 1 uses the obtained GNSS heading and the known separation between the antennas to back-calculate the integer ambiguity fix. Applicant respectfully submits that Kundak, which relies on inertial sensor measurements rather than a GNSS heading, does not teach or suggest this approach. In addition, Applicant respectfully submits that because Kundak does not disclose or suggest obtaining a GNSS heading of the antennas or using that GNSS heading to calculate the relative position vector, Kundak also fails to disclose or suggest "determining... the attitude of the vehicle, including validating candidate values of the attitude obtained from GNSS carrier phase measurements from the GNSS by analysing residuals in respect of the relative position vector, thereby validating the calculated integer ambiguity fix," as recited by amended claim 1. Applicant respectfully notes that the claimed "relative position vector" is one derived from the obtained GNSS heading, and Kundak's residual analysis is performed with respect to a different relative position vector (i.e., one that is not based on a GNSS heading of the antennas). Applicant further respectfully notes that Kundak discloses in paragraph 0027 determining "attitude residuals (R3) which comprise the difference between estimated Euler angles and the Euler angles as measured by the attitude aiding sensors 132" (i.e., the inertial sensors). Kundak, 0027. However, Kundak provides no disclosure of what the "estimated Euler angles" are or how they are obtained, and in particular does not disclose that they are obtained from GNSS carrier phase measurements as amended claim 1 recites. Applicant also respectfully submits that Willis does not cure the deficiencies of Kundak. Applicant respectfully notes that Willis is directed to calibrating inertial sensors using GNSS data to determine when a vehicle is traveling straight. See Willis, 0176. Applicant further respectfully notes that Willis explicitly states that its computation "is not actually concerned with the heading, merely the standard deviation" of GPS heading data points. See Willis, 0221-0222. Applicant respectfully submits that Willis does not teach or suggest obtaining a GNSS heading of the antennas by computing a direction of movement from temporally successive GNSS measurements, or using such a GNSS heading to calculate an integer ambiguity fix. Finally, Applicant respectfully submits that even if one were to combine Kundak and Willis, a person of ordinary skill in the art would be motivated to use Willis's teachings to improve calibration of Kundak's inertial sensors (i.e., the purpose of Willis), not to replace the inertial sensors with GNSS-based heading determination. Applicant further respectfully submits that there is nothing in either reference that would suggest obtaining a GNSS heading of the antennas and using it to back-calculate an integer ambiguity fix as recited by amended claim 1. Applicant respectfully submits that Kundak and Willis thus fail to teach or suggest all features of claims 1 and 14.” Examiner’s response: In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). KUNDAK discloses that a plurality of residuals calculated from the differenced carrier phase measurements and the attitude aiding measurements and the baseline length and further based on comparing the plurality of residuals to a plurality of thresholds; and when the resolved integer values are selected, outputting the resolved integer values to an attitude and heading calculator [0052]. WILLIS expressly teaches that its GNSS location subsystem supplies heading, along with position and speed. It cannot calculate standard deviation without first obtaining the heading values. Therefore, “is not actually concerned with the heading” does not mean that WILLIS lacks or fails to obtain the GNSS heading. With respect to Applicant’s argument that “if one were to combine Kundak and Willis, a person of ordinary skill in the art would be motivated to use Willis's teachings to improve calibration of Kundak's inertial sensors (i.e., the purpose of Willis), not to replace the inertial sensors with GNSS-based heading determination […] there is nothing in either reference that would suggest obtaining a GNSS heading of the antennas and using it to back-calculate an integer ambiguity fix”, the Examiner respectfully disagrees. KUNDAK requires attitude aiding measurements comprising Euler angles from an on-board inertial navigation aiding sensors or from another attitude aiding source [0036], for the calculation of float ambiguity values. KUNDAK does not limit its system to INS for these attitude aiding measurements. KUNDAK discloses that the attitude aiding measurements may be generated by onboard inertial measurement sensors […] or other attitude aiding sensors [0036]. Moreover, KUNDAK discloses GNSS receivers. WILLIS cures KUNDAK’s deficiency by teaching a calculation of GPS heading using similar GNSS receivers as those disclosed by KUNDAK. Claim Objections Claim(s) 1 and 14 are objected to, as markings of amendment to the claim(s) appear to refer to the claim set that was filed on 04 October, 2024, and not to the most recent claim set that was filed on 16 January, 2026. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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. Claim(s) 1-7, 9, 14, and 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kundak et al. (US 2017/0192103 A1 previously cited “KUNDAK”), in view of Willis et al. (US 2011/0202225 A1 previously cited “WILLIS”). Regarding claim 1, KUNDAK discloses (Examiner’s note: What KUNDAK does not disclose is ) a method for estimating an attitude of a vehicle (a vehicle orientation detection system 100 [0006]) using a global navigation satellite system (GNSS) (system 100 includes a GNSS receiver system 105 that comprises two or more GNSS receivers [0014]) having a plurality of satellites (the GNSS receivers 102-1, 102-2 begin tracking a satellite signal from at least one satellite 101 [0015]), comprising: baseline length data 134 (which may be stored in a memory) that describes a surveyed distance 102 between the antenna 103-1 and 103-2 [0018]) calculating, by the computer (an on-board computing device comprising a processor and a memory [0042]), an integer ambiguity fix corresponding to a relative position vector between the first and second antenna using the obtained calculating a plurality of float ambiguity values with associated covariance values as a function of the differenced carrier phase measurements, the attitude aiding measurements and the baseline length [0052]) and determining, by the computer, the attitude of the vehicle, including validating candidate values of the attitude obtained from GNSS carrier phase measurements from the GNSS by analysing residuals in respect of the relative position vector, thereby validating the calculated integer ambiguity fix by analysing residuals in respect of the relative position vector (selecting a first integer candidate array from the set of integer candidate arrays as resolved integer values as a function of a plurality of residuals calculated from the differenced carrier phase measurements and the attitude aiding measurements and the baseline length and further based on comparing the plurality of residuals to a plurality of thresholds; and when the resolved integer values are selected, outputting the resolved integer values to an attitude and heading calculator [0052]) KUNDAK further discloses receiving attitude aiding measurements […] from one or more on-board aiding sources [0052]. In a same or similar field of endeavor, WILLIS teaches that the simplest way to determine if the trajectory of the vehicle is straight, is to calculate the standard deviation of the variance of the vehicle heading for several consecutive GPS samples and compare it with a threshold value. If the measured heading variance is less than a preset threshold variance, it can be said that the vehicle is traveling in a straight line [0176]. The heading estimates from the GPS unit are only valid if the vehicle has a non-zero velocity [0177]. Furthermore, WILLIS teaches Locator Location subsystem 5 provides information on such things as the coordinates (latitude and longitude), speed, elevation, time, heading, and other geo-spatial information for Locator 10 system. The Location subsystem 5 is connected to its antenna 8 [0056]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of KUNDAK to include the teachings of WILLIS, because doing so would improve robustness and reliability of the detection system, as recognized by WILLIS. Furthermore, doing so would detect when a vehicle took aggressive evasive action, thereby generating reports of such incidents. In addition, both of the prior art references, KUNDAK and WILLIS, teach features that are directed to analogous art and they are directed to the same field of endeavor, that is, vehicle navigation systems. Regarding claim 2, KUNDAK/ WILLIS discloses wherein the determining the attitude of the vehicle includes analysing integer residuals (selecting a first integer candidate array from the set of integer candidate arrays as resolved integer values as a function of a plurality of residuals calculated from the differenced carrier phase measurements and the attitude aiding measurements and the baseline length and further based on comparing the plurality of residuals to a plurality of thresholds; and when the resolved integer values are selected, outputting the resolved integer values to an attitude and heading calculator [KUNDAK 0052], cited and incorporated in the rejection of claim 1). Regarding claim 3, KUNDAK/ WILLIS discloses the method of claim 2, wherein the determining the attitude of the vehicle includes applying a threshold that is dependent on expected noisiness of measurements (the threshold values are set based on how sensitive an application is to getting to the wrong answer so that both the values and priorities are defined accordingly [KUNDAK 0029]). Regarding claim 4, KUNDAK/ WILLIS discloses the method of claim 3, wherein determining the attitude of the vehicle includes requiring that the threshold be met for a number of consecutive samples (the residuals for the resolved integers are recalculated at every new epoch with new carrier phase measurements, and residuals are saved in the memory. If a certain number of past residuals (z-k out of z) in the memory no longer satisfy the specified subset of thresholds, then the resolved integers are deleted and operation is switched to Mode M1. If they continue to satisfy the specified subset of thresholds, then the resolved integers are maintained and operation in Mode M3 is maintained [KUNDAK 0033]). Regarding claim 5, KUNDAK/ WILLIS discloses the method of claim 1, wherein detecting that the vehicle is moving and not turning comprises estimating a movement speed of the vehicle (the heading estimates from the GPS unit are only valid if the vehicle has a non-zero velocity [WILLIS 0177], cited and incorporated in the rejection of claim 1). Regarding claim 6, KUNDAK, as modified, discloses the method according to claim 1, In a same or similar field of endeavor, WILLIS teaches that turning error compensation calculation needs to know the angular velocity (turn rate) and the angular acceleration (turn rate over time) of the vehicle, to perform the required calculations; these can be obtained from a gyroscope [0372]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of KUNDAK to include the teachings of WILLIS, because doing so would ensure that the obtained measurements would be accurate, thereby improving robustness and reliability of the detection system, as recognized by WILLIS. Furthermore, doing so would detect when a vehicle took aggressive evasive action, thereby generating reports of such incidents. Regarding claim 7, KUNDAK/ WILLIS discloses the method of claim 1, further comprising storing a calculated integer ambiguity fix (calculating a plurality of float ambiguity values with associated covariance values as a function of the differenced carrier phase measurements, the attitude aiding measurements and the baseline length [KUNDAK 0052], cited and incorporated in the rejection of claim 1). The Examiner further noted that the citation as disclosed by KUNDAK implies that ambiguity values are stored. Regarding claim 9, KUNDAK/ WILLIS discloses the method of claim 1, further comprising defining a search space for possible candidate values of the attitude and evaluating all possible candidates within the search space with respect to the relative position vector (Initialization Logic 115 functions to restrict the search space over which integer estimation logic 116 operates using the baseline length data 133 [KUNDAK 0020]). Regarding claim 14, KUNDAK discloses a vehicle (a vehicle orientation detection system 100 [0006]) comprising: a first antenna and a second antenna having a separation to each other, wherein the separation is equal to a constant d (baseline length data 134 (which may be stored in a memory) that describes a surveyed distance 102 between the antenna 103-1 and 103-2 [0018]) and wherein the first and second antennas are configured to receive signals from a global navigation satellite system (GNSS) (system 100 includes a GNSS receiver system 105 that comprises two or more GNSS receivers [0014]) having a plurality of satellites (the GNSS receivers 102-1, 102-2 begin tracking a satellite signal from at least one satellite 101 [0015]) and a movement estimation device comprising a computer (an on-board computing device comprising a processor and a memory [0042]) configured to: calculate an integer ambiguity fix corresponding to a relative position vector between the first and second antenna using the obtained calculating a plurality of float ambiguity values with associated covariance values as a function of the differenced carrier phase measurements, the attitude aiding measurements and the baseline length [0052]) determine the attitude of the vehicle, including validate candidate values of the attitude obtained from GNSS carrier phase measurements from the GNSS by analysing residuals in respect of the relative position vector, thereby validating the calculated integer ambiguity fix (selecting a first integer candidate array from the set of integer candidate arrays as resolved integer values as a function of a plurality of residuals calculated from the differenced carrier phase measurements and the attitude aiding measurements and the baseline length and further based on comparing the plurality of residuals to a plurality of thresholds; and when the resolved integer values are selected, outputting the resolved integer values to an attitude and heading calculator [0052]) KUNDAK further discloses receiving attitude aiding measurements […] from one or more on-board aiding sources [0052]. In a same or similar field of endeavor, WILLIS teaches that the simplest way to determine if the trajectory of the vehicle is straight, is to calculate the standard deviation of the variance of the vehicle heading for several consecutive GPS samples and compare it with a threshold value. If the measured heading variance is less than a preset threshold variance, it can be said that the vehicle is traveling in a straight line [0176]. The heading estimates from the GPS unit are only valid if the vehicle has a non-zero velocity [0177]. Furthermore, WILLIS teaches Locator Location subsystem 5 provides information on such things as the coordinates (latitude and longitude), speed, elevation, time, heading, and other geo-spatial information for Locator 10 system. The Location subsystem 5 is connected to its antenna 8 [0056]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of KUNDAK to include the teachings of WILLIS, because doing so would improve robustness and reliability of the detection system, as recognized by WILLIS. Furthermore, doing so would detect when a vehicle took aggressive evasive action, thereby generating reports of such incidents. Regarding claim 17, KUNDAK/ WILLIS discloses the method of claim 1, wherein the separation is square to the attitude of the vehicle (on an aircraft where antenna 103-1 and 103-2 are mounted on opposite wings [KUNDAK 0029]). Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over KUNDAK, in view of WILLIS, and further in view of Parikh et al (“Implementation of a Least Mean Square Approach for a Low-Cost Short Baseline Attitude Determination”, cited in Applicant IDS “PARIKH”). Regarding claim 8, KUNDAK/ WILLIS discloses the method of claim 7, In a same or similar field of endeavor, PARIKH teaches performing static test to analyze attitude for the case where the platform is stationary, using the direct method and LMS estimation [pg. 823]. The integer ambiguities are resolved during system initialization process while the platform is stationary [pg. 820] which are used in attitude estimation [pg. 821]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify KUNDAK to include the teachings of PARIKH, because doing so would improve accuracy of GPS-based attitude determination, as recognized by PARIKH. In addition, both of the prior art references, KUNDAK and PARIKH, teach features that are directed to analogous art and they are directed to the same field of endeavor, that is, usage of GPS antennas for attitude determination. Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over KUNDAK, in view of WILLIS, and further in view of Kindo et al. (US 2016/0313738 A1 previously cited “KINDO”). Regarding claim 16, KUNDAK/ WILLIS discloses the vehicle of claim 14, In a same or similar field of endeavor, KINDO teaches that the speed sensor is a detector to detect the speed of the vehicle V. The speed sensor may be, for example, a wheel speed sensor that is provided at a wheel of the vehicle V, a drive shaft to rotate integrally with the wheel or the like and that detects the rotational speed of the wheel is used. The speed sensor sends the detected vehicle speed information (wheel speed information), to the ECU 10 [0034]. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify KUNDAK to include the teachings of KINDO because doing so would accurately detect current state of the vehicle, thereby enabling system functions and further processing, as recognized by KINDO. In addition, both of the prior art references, KUNDAK and KINDO, teach features that are directed to analogous art and they are directed to the same field of endeavor, that is, vehicle navigation and systems. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Whitehead (US 2007/0075896 A1 previously cited) is considered pertinent art for the disclosure overall, and in particular the details of a method and system for determining at least one attitude angle of a rigid body. The method comprising: receiving a plurality of Global Navigation Satellite System (GNSS) satellite signals with a plurality of antennas; establishing at least one pair of antennas such that each antenna of the plurality of antennas is included in at least one antenna pair; computing single- or double-difference phases corresponding to one or more GNSS satellites for each of the pairs of antennas; and constructing a single Differential Carrier Phase Attitude (DCPA) equation based on known geometry constraints of each of the pairs of antennas. The method also includes determining a solution for the DCPA equation based on a cost function, the solution yielding at least one integer ambiguity value and the at least one attitude angle. 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 HAILEY R LE whose telephone number is (571)272-4910. The examiner can normally be reached 9:00 AM - 5:00 PM EST. 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, VLADIMIR MAGLOIRE can be reached at (571) 270-5144. 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. /Hailey R Le/Examiner, Art Unit 3648 July 26, 2026 /VLADIMIR MAGLOIRE/Supervisory Patent Examiner, Art Unit 3648
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Prosecution Timeline

Show 19 earlier events
Jan 29, 2025
Response after Non-Final Action
Jan 29, 2025
Response after Non-Final Action
Nov 19, 2025
Response after Non-Final Action
Jan 16, 2026
Request for Continued Examination
Feb 10, 2026
Response after Non-Final Action
Feb 25, 2026
Non-Final Rejection mailed — §103
May 26, 2026
Response Filed
Jul 29, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

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Expected OA Rounds
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