Prosecution Insights
Last updated: April 19, 2026
Application No. 17/733,316

WORK CART CHARGING

Final Rejection §103
Filed
Apr 29, 2022
Examiner
KOUSAR, SADIA
Art Unit
2859
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Milwaukee Electric Tool Corporation
OA Round
2 (Final)
63%
Grant Probability
Moderate
3-4
OA Rounds
3y 1m
To Grant
73%
With Interview

Examiner Intelligence

Grants 63% of resolved cases
63%
Career Allow Rate
69 granted / 109 resolved
-4.7% vs TC avg
Moderate +9% lift
Without
With
+9.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
46 currently pending
Career history
155
Total Applications
across all art units

Statute-Specific Performance

§101
2.7%
-37.3% vs TC avg
§103
55.9%
+15.9% vs TC avg
§102
30.1%
-9.9% vs TC avg
§112
9.6%
-30.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 109 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 filed 10/31/2025 have been fully considered but they are not persuasive. The applicant argues on page 5, “ Becker teaches an elongated slot 654 of adjustable width and not a recess defined in a housing that receives an arm of a clamp.” The examiner respectfully disagrees. Becker discloses the main body portion 652 includes an elongated slot 654, which is dimensioned to receive wall portion (Col. 10, lines 7–9). Note that practically the slot 654 receives almost the whole portion of the wall 655 in order to tightly insert the device in the cart. If the slot accommodates a small portion of the wall, then the device would not have enough support to carry the device 602 on a cart. The applicant further argues that on page 6, Becker discloses a data collection device to facilitate the consumer and retailer and modification of it with the battery pack would render Becker's invention inoperable for its intended purpose. The examiner respectfully disagrees. Becker discloses a portable data collection device which works with the rechargeable battery 806 (col. 12, lines 23-25). It is very necessary to have fully charged rechargeable batteries to maintain a smooth work flow. Thus, the base reference can be modified with the battery packs to charge the extra batteries in order to use it later time. The applicant arguments are not persuasive; thus, THIS ACTION IS MADE 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, 8, and 21-24 is/are rejected under 35 U.S.C. 103 as being unpatentable over Becker et al. (US 6,168,079), herein after Becker, and Pickens et al. (US 9,831,695), herein after Pickens. Regarding claim 1, Becker discloses a module (650, fig. 13) configured to be removably coupled to a mobile work cart (C, fig. 13), the module comprising: a housing 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 (see annotated fig. I), PNG media_image1.png 916 975 media_image1.png Greyscale Annotated fig. I a clamp coupled to the rear side of the housing, the clamp including a handle portion and an arm (see annotated fig. II), PNG media_image2.png 884 770 media_image2.png Greyscale Annotated fig. II 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 ( Docking member is adapted to be hanged from a thin wall portion W of cart C; Col. 10, lines 4-5, fig. 13A the arrow sign shows deployed and retracted position); wherein in the housing defines a recess (slot 654, fig. 13A) in the rear side, and wherein when the clamp is in the retracted position the arm is received within the recess (654 received the arm 655, fig. 13A). However, Becker is silent about the module is a charging module, and 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. Pickens discloses a charging module(520, fig. 3) and the housing further including a charging bay located within the cavity (520 include on the font portion 510, fig. 3; the battery pack receptacle/adapter 520 may be positioned in a pocket, clipped to a pocket, part of a pocket, positioned inside a utility bag, part of a wall of a utility bag (e.g., a side-wall, an end-wall, etc.), container, case, box, cooler, etc. as desired, Col. 7, lines- 4-7), the charging bay being configured to removably receive a battery pack to electrically connect the battery pack to the charging module (The at least one battery pack adapter is configured to removably couple with a particular type of battery pack used for a cordless device; Col. 5, lines 29-31). It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Becker’s module 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 2, Becker in view of Pickens discloses the charging module of claim 1. Pickens further discloses the charging module further comprising a task light pivotably coupled to the housing at the first end (2930 is connected to one end of housing to accommodate lightning element, Col. 15, lines 35-37). It would have been obvious to one of ordinary skill in the art, before the effective filing date of claimed invention to modify Becker’s module 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 8, Becker in view of Pickens discloses the charging module of claim 1. Pickens further 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 Becker’s module 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 21, Becker in view of Pickens discloses the charging module of claim 1. Becker further 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 (fig. 13 A shows that the handle and arm are flush towards 657; see the response to argument section). It would have been obvious to one of the ordinary skills in the art, before the effective filing date of claimed invention to modify Becker’s module to have the charging module to charge the battery as taught by Pickens, in order to charge the battery and use it to maintain a smooth workflow by ensuring devices and equipment are always powered and ready for use. Regarding claim 22, Becker in view of Pickens discloses the charging module of claim 1. 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 Becker’s module 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. Regarding claim 23, Becker in view of Pickens discloses the charging module of claim 1. Pickens discloses the charging bay is configured to receive the battery pack in a direction that is transverse to a longitudinal direction of the arm (fig. 12 shows the transverse to a longitudinal direction of the battery pack with respect to the 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 Becker’s module 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. Regarding claim 24, Becker in view of Pickens discloses the charging module of claim 1. Pickens 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 packs may have different voltages, such as 12V, 18V, 24V, etc; Col. 1 line 18). It would have been obvious to one of the ordinary skills in the art, before the effective filing date of claimed invention to modify Becker’s module to have the charging module to charge the battery as taught by Pickens, in order to charge the battery and use it to maintain a smooth workflow by ensuring devices and equipment are always powered and ready for use. Claim(s)3, 5, 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Becker (US 6,168,079), and Pickens (US 9,831,695) as applied to claims 1, 2 above, and further in view of Fry et al. (US 2015/0171632), herein after Fry. Regarding claim 3, Becker in view of Pickens 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 Becker’s module in view of Pickens 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, Becker in view of Pickens 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 Becker’s module in view of Pickens 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, Becker in view of Pickens discloses the charging module of claim 1. However, Becker and Pickens is 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_image3.png 866 975 media_image3.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 Becker’s module in view of Pickens 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 Becker (US 6,168,079), and Pickens (US 9,831,695) as applied to claim 1 above, and further in view of Phillips et al. (US 11,223,227), herein after Phillips. Regarding claim 4, Becker in view of Pickens discloses the charging module of claim 1. However, Becker and Pickens is 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 Becker’s module in view of Pickens 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 Becker (US 6,168,079), and Pickens (US 9,831,695) as applied to claim 1 above, and further in view of Michaels (US 2020/0083724). Regarding claim 6, Becker in view of Pickens discloses the charging module of claim 1. However, Becker and Pickens is 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_image4.png 963 897 media_image4.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 Becker’s module in view of Pickens 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. Conclusion THIS ACTION IS MADE FINAL. 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 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 05, 2025
Non-Final Rejection — §103
Oct 31, 2025
Response Filed
Jan 16, 2026
Final Rejection — §103 (current)

Precedent Cases

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

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Prosecution Projections

3-4
Expected OA Rounds
63%
Grant Probability
73%
With Interview (+9.4%)
3y 1m
Median Time to Grant
Moderate
PTA Risk
Based on 109 resolved cases by this examiner. Grant probability derived from career allow rate.

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