Prosecution Insights
Last updated: April 19, 2026
Application No. 17/724,842

Winged Agricultural Implement with Steerable Transport Wheels

Non-Final OA §103
Filed
Apr 20, 2022
Examiner
SCOVILLE, BLAKE E
Art Unit
3671
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Elmer'S Welding & Manufacturing Ltd.
OA Round
2 (Non-Final)
73%
Grant Probability
Favorable
2-3
OA Rounds
3y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allow Rate
95 granted / 130 resolved
+21.1% vs TC avg
Strong +28% interview lift
Without
With
+27.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
30 currently pending
Career history
160
Total Applications
across all art units

Statute-Specific Performance

§103
41.5%
+1.5% vs TC avg
§102
30.6%
-9.4% vs TC avg
§112
25.3%
-14.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 130 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 Arguments Applicant’s arguments, see Remarks pages 3-5, filed 8/7/2025, with respect to the rejection(s) of claim 1 under Redekop have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of Hulicsko (US 8291994). Allowable Subject Matter Claim 2-3, 11, 14 objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. The following is an examiner’s statement of reasons for allowance: Regarding claim 2, the idea of winged agricultural implements with steerable transport wheels is known in the art. For example, Redekop and Hulicsko (prior art of record) both present designs of agricultural frames with steerable transport wheels. However, neither of these references, nor any other reference, provide adequate teaching to position the wheel axis parallel to the axis of the wing frame. In view of the prior art of record, any obvious combination to make the axis of rotation of the wheel oriented parallel to the longitudinal axis of the wing frame as currently claimed would require improper hindsight reasoning. Hulicsko functions in a way that it would render the machine unsatisfactory for its intended purpose to modify the wheel axis to be parallel with the axis of the wing frame. For these reasons, the claim is allowable. Regarding claim 11, no reference of record, nor any other reference, provide adequate teaching to include a bracing arrangement defined as a four-bar linkage with an input device measuring angles of adjacent pairs of linkages of the four-bar linkage. In view of the prior art of record, any obvious combination to include a bracing arrangement as claimed would require improper hindsight reasoning. For this reason, the claim is allowable. Regarding claim 14, no reference of record, nor any other reference, provide adequate teaching to include a control linkage and input linkage to automatically control the steering of the transport wheels as claimed. In view of the prior art of record, any obvious combination to include the linkages as claimed would require improper hindsight reasoning. For this reason, the claim is allowable. Any comments considered necessary by applicant must be submitted no later than the payment of the issue fee and, to avoid processing delays, should preferably accompany the issue fee. Such submissions should be clearly labeled “Comments on Statement of Reasons for Allowance.” Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claim(s) 1, 4-10, 12-13, 15-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hulicsko (US 8291994) in further view of Hahn (prior art of record). Regarding claims 1 and 6, Hulicsko discloses an agricultural implement for use with a towing vehicle arranged for towing the implement frame across ground in a forward working direction of the towing vehicle (Figs 1-4), the implement comprising: a center frame including a hitch member arranged for towing connection to the towing vehicle for movement across the ground in the forward working direction (center frame 3); two wing frames, each wing frame being elongate along a longitudinal axis of the wing frame between an inner end and an outer end of the wing frame (wing frames 11L/11R with longitudinal axes along IRA/ORA/ERA); the wing frames being pivotally coupled at the inner ends of the wing frames at laterally spaced apart positions on the center frame (pivotally coupled at point 14/VA); each wing frame being pivotal relative to the center frame between a field frame position in which the longitudinal axes of the wing frames extend laterally outwardly in opposing directions from the center frame and a range of transport positions in which the longitudinal axes of the wing frames extend generally rearward from the center frame, the range of transport frame positions including a neutral transport frame position in which the longitudinal axis of the wing frame is oriented in the forward working direction of the center frame (field position depicted in Fig 1; neutral transport position depicted in Fig 3, but there is range of transport positions as the rear wheels 51 are steerable by actuators 55); a transport wheel supported on each wing frame so as to be arranged to support the wing frame for rolling movement along the ground in at least the range of transport frame positions (steerable outer wheels 51 support the frame in a range of transport positions in Fig 3 and Fig 4); each transport wheel being pivotal relative to the wing frame about an upright steering axis through a range of wheel positions including a neutral transport wheel position in which an axis of the wheel is oriented perpendicularly to the longitudinal axis of the wing frame for rolling movement in the forward working direction when the wing frames are in the neutral transport frame positions (col 6, lines 46-48; neutral transport wheel position depicted in Fig 3 with the wheel axis perpendicular to the axis of the wing frame); each transport wheel being pivotal about the upright steering axis from the neutral transport wheel position in either one of two opposing steering directions (col 6, lines 48-50; the wing wheel pivotal outward; the wheel appears to be capable of being pivoted in either direction left or right); and steering actuator (55). While Hulicsko discloses the wing wheels rotating outward (col 6, lines 55-62), Hulicsko also discloses the wheel actuators 55 operative to pivot the wing wheels about the vertical axis (col 6, lines 48-50). Hulicsko is silent on the concept of actively steering the wing wheels in both directs as claimed in claim 1. However, Hahn discloses a similar agricultural utility vehicle (Figs 1-2) and teaches the use of a control system that is connected to steerable rear wheels in either direction (claim 1) (Hahn; para [0028], lines 9-11). Hahn further teaches and an input device associated with a towed implement that provides input to the controller representative of a deflection angle (claim 6) (control unit 34; steerable wheels 28 with actuator 50; input device 32 and/or 42 is considered to be associated with the implement to provide input to the controller indicative of the steering angle and/or inclination angle). Hulicsko and Hahn are considered analogous to the claimed invention because they are in the same field of endeavor of towed agricultural vehicle control. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Hulicsko to incorporate the teachings of Hahn and combined the use of a control system and input device as a steer angle sensor and/or inclination angle sensor to control the wing wheels to pivot in either direction. One would have made this combination to better control the steering of the towed implement in different travelling situations with less complication (Hahn; para [0008], lines 1-5). Regarding claim 4, Hulicsko fails to specifically disclose the steerable wheels comprising a separate locking member arranged to fix an orientation of the wheels. However, Applicant’s specification states the steering actuator can be used as the sole means of locking the steerable wheel (Specification; pg 13, lines 3-5). In this case, Hulicsko’s steering actuator 55 is considered to act as the locking member to fix an orientation of each transport wheel in any position. Regarding claim 5, Redekop discloses the implement wherein the steering actuators of the transport wheels of the two wing frames are actuatable so as to steer the transport wheels in a common direction of rotation from the respective neutral transport wheel positions of the transport wheels (Fig 4). Regarding claim 7, the combination of Hulicsko and Hahn discloses the implement wherein the controller is operable in a forward automated mode in which the controller is arranged to actuate the steering actuators of the transport wheels in a direction corresponding to steering of the wing frames towards the neutral transport frame positions when the central frame is displaced across the ground in the forward working direction (Hahn; travel selector lever 44; “forward travel”; para [0029], lines 21-25; “any desired steering angle”; para [0033], lines 14-16; it is considered obvious to make the steering of the wing frames of the combination toward the neutral transport frame positions). Regarding claim 8, the combination of Hulicsko and Hahn discloses the implement wherein the controller is operable in a reverse automated mode in which the controller is arranged to actuate the steering actuators of the transport wheels in a direction corresponding to steering of the wing frames towards the neutral transport frame positions when the central frame is displaced rearwardly across the ground opposite to the forward working direction (Hahn; travel selector lever 44; “reverse travel”; para [0029], lines 21-25; “any desired steering angle”; para [0033], lines 14-16; it is considered obvious to make the steering of the wing frames of the combination toward the neutral transport frame positions when traveling in reverse). Regarding claim 9, the combination of Hulicsko and Hahn discloses the implement wherein the controller is arranged to actuate the steering actuators of both transport wheels by a variable amount that is proportional to the deflection angle (Hahn; input device 32 is considered to be a steering angle sensor which is indicative of the deflection angle). Regarding claim 10, the combination of Hulicsko and Hahn discloses the implement wherein the input device of each wing frame is arranged to measure an angle of the wing frame relative to the center frame (Hahn; input device 42 is considered to be an inclination angle sensor which is indicative of the angle of the lateral inclination; para [0029], lines 13-17). Regarding claim 12, the combination of Hulicsko and Hahn discloses the implement wherein the input device is an electronic sensor and wherein the controller is a programmable controller arranged to receive input from the electronic sensor as an electronic signal and actuate the steering actuators in response to the electronic signal from the sensors (Hahn; steer angle sensor 32 and inclination angle sensor 42; controller 32 receives data from the sensors; para [0029], lines 17-19). Regarding claim 13, the combination of Hulicsko and Hahn discloses the implement wherein the steering actuators comprise hydraulic actuators, wherein the input devices are hydraulic devices, and wherein the controller is arranged to receive input from the hydraulic device as a flow of hydraulic fluid, and actuate the steering actuators in response to the flow of hydraulic fluid from the input devices (the steering actuators of the combination are considered to be hydraulic as Hulicsko discloses other hydraulic components; col 6, lines 31-37; Hahn also teaches a hydraulic system; abstract; it is considered obvious for the combination to use hydraulic devices as the input devices to communicate with the controller). Regarding claim 15, the combination of Hulicsko and Hahn discloses the implement wherein the steering actuators are arranged for connection to a controllable output of the towing vehicle such that the steering actuators can be manually operated by an operator of the towing vehicle using controls of the towing vehicle (claim language is broad; there would have to be some kind of controllable output of the vehicle to control the actuators of the machine; this control would have to have some kind of manual input). Regarding claim 16, the combination of Hulicsko and Hahn fails to specifically disclose the implement wherein each transport wheel is pivotal about the upright steering axis through a range of more than 90 degrees. However, Hulicsko states the wings, and transport wheels in this case, can move at least 65 deg outward (col 6, lines 62-65). As stated earlier, Hahn teaches the rear wheels to be steerable in both directions for the purpose of better controlling the steering of the towed implement in different travelling situations with less complication. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have further modified the combination to include pivoting the transport wheel at least 65 deg in the other direction for the purpose put forth by Hahn. Doing so would make the transport wheel of the combination pivotal about the upright steering axis through a range of more than 90 deg. For clarification, 65 deg in one direction and 65 deg in the other direction would result in a total range of 130 degrees. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Carrick (US 5154240) discloses a folding implement with similar structure to the claimed invention. Any inquiry concerning this communication or earlier communications from the examiner should be directed to BLAKE SCOVILLE whose telephone number is (571)270-7654. The examiner can normally be reached M-F 10:30-6 (ET). 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, Christopher Sebesta can be reached at (571) 272-0547. 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. /BLAKE E SCOVILLE/ Examiner, Art Unit 3671 /CHRISTOPHER J SEBESTA/ Supervisory Patent Examiner, Art Unit 3671
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Prosecution Timeline

Apr 20, 2022
Application Filed
Apr 30, 2025
Non-Final Rejection — §103
Aug 07, 2025
Response Filed
Mar 05, 2026
Non-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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Prosecution Projections

2-3
Expected OA Rounds
73%
Grant Probability
99%
With Interview (+27.6%)
3y 3m
Median Time to Grant
Moderate
PTA Risk
Based on 130 resolved cases by this examiner. Grant probability derived from career allow rate.

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