Prosecution Insights
Last updated: May 29, 2026
Application No. 17/733,316

WORK CART CHARGING

Non-Final OA §103
Filed
Apr 29, 2022
Priority
Apr 29, 2021 — provisional 63/181,687 +1 more
Examiner
KOUSAR, SADIA
Art Unit
2859
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Milwaukee Electric Tool Corporation
OA Round
3 (Non-Final)
65%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
75%
With Interview

Examiner Intelligence

Grants 65% of resolved cases
65%
Career Allowance Rate
75 granted / 116 resolved
-3.3% vs TC avg
Moderate +10% lift
Without
With
+10.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
29 currently pending
Career history
157
Total Applications
across all art units

Statute-Specific Performance

§101
2.0%
-38.0% vs TC avg
§103
88.3%
+48.3% vs TC avg
§102
6.6%
-33.4% vs TC avg
§112
2.9%
-37.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 116 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 page 6, filed 04/24/2026, with respect to the rejection(s) of claim(s) 1 under 35 USC § 103 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 Therefore, the rejection has been withdrawn.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 Uehlein-Proctor et al. (US 2009/0102420), herein after Uehlein-Proctor, and Lee et al. (US 2004/0129746), herein after Lee. The applicant's arguments regarding the rejection in office action mailed on 01/29/2026 are persuasive. Thus, this action is made Non-Final. 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, 2, 21, 23-24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Uehlein-Proctor (US 2009/0102420, and Lee (US 2004/0129746). Regarding claim 1, Uehlein-Proctor discloses a charging module (400, paragraph [0081]) configured to be removably coupled to a mobile work cart (the charger 400 can include mounting receptacles 428 for securing the charger 400 to a work cart, paragraph [0090]), the charging module comprising: a housing (402, fig. 12)having a first end, a second end opposite the first end, a front side, and a rear side opposite the front side, the housing defining a cavity in at least the front side, the housing further including a charging bay located within the cavity, the charging bay being configured to removably receive a battery pack to electrically connect the battery pack to the charging module (battery 200 is removably supported in a battery chamber, paragraph [0101]; see the annotated fig. I); PNG media_image1.png 859 975 media_image1.png Greyscale Annotated fig. I Although Uehlein-Proctor discloses the mounting receptacle to mount the charging module on the cart (paragraph [0090]), however, Uehlein-Proctor does not explicitly disclose a clamp coupled to the rear side of the housing, the clamp including a handle portion and an arm, the clamp being movable relative to the housing along a direction toward or away from the rear side between a deployed position and a retracted position, the clamp being biased toward the retracted position; wherein in the housing defines a recess in the rear side, and wherein when the clamp is in the retracted position the arm is received within the recess. Lee discloses Integrated Retractable Belt Clip (abstract) to secure the device to any object. Lee discloses a clamp coupled to the rear side of the housing, the clamp including a handle portion and an arm (the clip 26 with the portion 27, fig. 3), the clamp being movable relative to the housing along a direction toward or away from the rear side between a deployed position and a retracted position, the clamp being biased toward the retracted position (The belt clip includes a clip arm that is connected to the housing. The clip arm moves between a retracted position and a deployed position. The clip arm is flush with the housing in the retracted position. The clip arm is elevated above the housing in the deployed position, paragraph [0011]); wherein in the housing defines a recess (25 in the housing, figs. 3-5), and wherein when the clamp is in the retracted position the arm is received within the recess (The depression has a depth sufficient so that when the engagement member is in the retracted position, the clip arm is received within the depression to such an extent that an external surface of the clip arm is substantially flush with adjacent surfaces of the housing, paragraph [0013]). It would have been obvious to one of the ordinary skills in the art, before the effective filing date of the claimed invention, to modify Uehlein-Proctor’s battery charger mount to include a well-known mounting clip as taught by Lee, in order to stably mount the battery charger over the cart, and preventing unintended movement or dislodgement of the battery module during transport or operation of the cart. Regarding claim 2, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Uehlein-Proctor further discloses a task light pivotably coupled to the housing at the first end (a charge indicator at the housing, (paragraph [0092])). It would have been obvious to one of the ordinary skills in the art, before the effective filing date of the claimed invention, to modify Uehlein-Proctor’s battery charger mount to include a well-known mounting clip as taught by Lee, in order to stably mount the battery charger over the cart, and preventing unintended movement or dislodgement of the battery module during transport or operation of the cart. Regarding claim 21, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Lee discloses wherein the handle portion and the arm are flush with the surrounding surface of the housing when the clamp is in the retracted position (The depression has a depth sufficient so that when the engagement member is in the retracted position, the clip arm is received within the depression to such an extent that an external surface of the clip arm is substantially flush with adjacent surfaces of the housing, paragraph [0013]). Regarding claim 23, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Uehlein-Proctor further discloses wherein the charging bay is configured to receive the battery pack in a direction that is transverse to a longitudinal direction of the arm (the battery 200 is received in transverse direction, fig. 12). Regarding claim 24, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Uehlein-Proctor further discloses wherein the charging bay is configured to removably receive a 12-Volt post-type battery pack and/or an 18-Volt rail-type battery pack (the battery 200 can include two or more battery cells 208 where each battery cells having a nominal voltage of 4 volts and the battery module 200 with three battery cells can fulfil the claim limitation, paragraph [0066]-[0067]). Claim(s) 3, 5, 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Uehlein-Proctor (US 2009/0102420), and Lee (US 2004/0129746) as applied to claim 1 above, and further in view of Fry et al. (US 2015/0171632), herein after Fry. Regarding claim 3, Uehlein-Proctor in view of Lee discloses the charging module of claim 2. However, they are silent wherein the charging module is configured to supply power to the battery pack to recharge the battery pack in a first mode, and wherein the charging module is configured to draw power from the battery pack to activate the task light in a second mode. Fry discloses wherein the charging module is configured to supply power to the battery pack to recharge the battery pack in a first mode (The power device 10 is operable to charge the battery 14 and the battery packs 86, 90 in the AC mode and the DC mode, paragraph [0059], fig. 13), and wherein the charging module is configured to draw power from the battery pack to activate the task light in a second mode (the battery 14 is not charged in the standalone mode. However, the battery 14 (a) provides DC power to the inverter 246, which is inverted and provided to AC peripheral devices coupled to the AC power output connector 202, (b) provides DC power to the first DC output connector 194 and to the second DC output 198 to power DC peripheral devices coupled to the DC power output connectors 194, 198, paragraph [0061]). It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Uehlein-Proctor’s module in view of Lee to charge and discharge the battery though only one module as taught by Fry, in order to have the simple design and implement, requiring fewer components and a less intricate wiring scheme compared to systems with multiple modules or a distributed architecture. This can lead to a quicker development process and reduced manufacturing costs. Regarding claim 5, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Pickens discloses one battery receptacle on the charging bay. However, Becker and Pickens is silent about the charging bay has two battery receptacles on accommodate two different types of the batteries. Fry discloses wherein the charging bay (power device 1800, fig. 24) comprises a first battery receptacle and a second battery receptacle, wherein the battery pack is a battery pack of a first type (1804 battery pack in the first battery receptacle, paragraph [0087];fig. 24A), wherein the first battery receptacle is configured to removably receive the battery pack of the first type (paragraph [0087]), and wherein the second battery receptacle is configured to receive a battery pack of a second type different from the first type (the second battery packs 1808 in the second battery receptacle, fig. 24; both the batteries are different types). It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Uehlein-Proctor’s module in view of Lee to charge different types of the battery simultaneously as taught by Fry, in order to consolidating charging needs into one module reduces the number of chargers and cables you need, leading to a more organized and clutter-free space. Regarding claim 7, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. However, Uehlein-Proctor and Lee are silent about wherein the charging bay is a first charging bay and wherein the charging module further comprises a second charging bay located within the cavity adjacent the first charging bay. Fry discloses wherein the charging bay is a first charging bay and wherein the charging module further comprises a second charging bay located within the cavity adjacent the first charging bay (see the annotated fig III). PNG media_image2.png 866 975 media_image2.png Greyscale Annotated fig. III It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Uehlein-Proctor’s module in view of Lee to have multiple charging bay in a cavity as taught by Fry, in order to consolidating charging needs into one module reduces the number of chargers and cables you need, leading to a more organized and clutter-free space. Claim(s) 4 is/are rejected under 35 U.S.C. 103 as being unpatentable over Uehlein-Proctor (US 2009/0102420), and Lee (US 2004/0129746) as applied to claim 1 above, and further in view of Phillips et al. (US 11,223,227), herein after Phillips. Regarding claim 4, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. However, Uehlein-Proctor and Lee are silent about the charging module further comprising a permanent magnet affixed to the rear side of the housing. Phillips discloses the charging module further comprising a permanent magnet affixed to the rear side of the housing (Alternatively, or additionally, the holder 22 may comprise one or more mechanisms configured to temporarily secure the battery 20 such as, but not limited to, magnets, Col. 4, lines 59-61). It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Uehlein-Proctor’s module in view of Lee to have a magnet at the rear side of the housing as taught by Phillips, in order to secure the battery pack on the charging cart as desired for the application. Claim(s) 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Uehlein-Proctor (US 2009/0102420), and Lee (US 2004/0129746) as applied to claim 1 above, and further in view of Michaels (US 2020/0083724). Regarding claim 6, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. However, Uehlein-Proctor and Lee are silent about wherein the arm is a first arm and the clamp further comprises a second arm, each arm being located at an opposite end of the handle portion and extending perpendicular to the handle portion and parallel to each other. Michaels discloses wherein the arm is a first arm and the clamp further comprises a second arm, each arm being located at an opposite end of the handle portion and extending perpendicular to the handle portion and parallel to each other (see the annotated fig. IV). PNG media_image3.png 963 897 media_image3.png Greyscale Annotated fig. IV It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Uehlein-Proctor’s module in view of Lee to have two arms clamp as taught by Michaels, in order to have a more stable and secure grip of the charging module over the working cart. Claim(s) 8, 22 is/are rejected under 35 U.S.C. 103 as being unpatentable over Uehlein-Proctor (US 2009/0102420), and Lee (US 2004/0129746) as applied to claim 1 above, and further in view of Pickens et al. (US 9,831,695), herein after Pickens. Regarding claim 8, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Uehlein-Proctor further discloses an electrical input receptacle 410 (fig. 12). However, they are silent about the input port is Universal Synchronous Bus (USB) port. Pickens discloses the charging module further comprising a Universal Synchronous Bus (USB) port positioned in the front side of the housing (the battery pack battery pack receptacle/adapter 520 may include one or more (e.g., 1, 2, 3, 4, etc.) USB connection ports 250; Col. 6, lines 34-35). It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Uehlein-Proctor’s module in view of Lee to have the charging module to charge the battery as taught by Pickens, in order to charge the battery and use to maintain a smooth workflow by ensuring devices and equipment are always powered and ready for use. Regarding claim 22, Uehlein-Proctor in view of Lee discloses the charging module of claim 1. Uehlein-Proctor and Lee do not disclose that the charging bay is configured to receive the battery pack in a direction that is parallel to a longitudinal direction of the arm. Pickens discloses the charging bay is configured to receive the battery pack in a direction that is parallel to a longitudinal direction of the arm (the charging bay 520 can accommodate the battery in various direction with respect to the coupling portion, e.g. fig. 5 shows that the battery pack receive in parallel to longitudinal direction with respect to coupling portion 510). It would have been obvious to one of the ordinary skills in the art, before the effective filing date of the claimed invention, to modify Uehlein-Proctor’s module in view of Lee to have the charging module to charge the battery in a particular dimension as taught by Pickens, in order to charge the battery in a parallel direction with the support ensures durability, security, and space-saving by keeping the unit stable. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SADIA KOUSAR whose telephone number is (571)272-3386. The examiner can normally be reached M-Th 7:30am-5:30pm. 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, Julian Huffman can be reached at (571) 272-2147. 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. SADIA . KOUSAR Examiner Art Unit 2859 /JULIAN D HUFFMAN/ Supervisory Patent Examiner, Art Unit 2859
Read full office action

Prosecution Timeline

Apr 29, 2022
Application Filed
Aug 11, 2025
Non-Final Rejection mailed — §103
Oct 31, 2025
Response Filed
Jan 29, 2026
Final Rejection mailed — §103
Apr 22, 2026
Applicant Interview (Telephonic)
Apr 24, 2026
Response after Non-Final Action
May 08, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12620821
POWER SUPPLY EQUIPMENT
3y 8m to grant Granted May 05, 2026
Patent 12611946
SINGLE-PHASE AND THREE-PHASE HYBRID FILTER SYSTEM FOR AN ELECTRIC CHARGER
3y 10m to grant Granted Apr 28, 2026
Patent 12580391
SYSTEM FOR CHARGING VEHICLE BATTERY USING MOTOR DRIVING SYSTEM
3y 9m to grant Granted Mar 17, 2026
Patent 12573859
Battery Pack, System, Operation Status Transmission Method And Program
4y 10m to grant Granted Mar 10, 2026
Patent 12556011
CHARGING PILE WITH PERMANENTLY-HORIZONTAL CHARGING BLOCK AND CHARGING DEVICE HAVING THE SAME
3y 8m to grant Granted Feb 17, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

3-4
Expected OA Rounds
65%
Grant Probability
75%
With Interview (+10.3%)
3y 2m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 116 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month