Prosecution Insights
Last updated: July 17, 2026
Application No. 17/827,176

HEATED GEAR WIRELESS CHARGING

Non-Final OA §103§112
Filed
May 27, 2022
Priority
May 28, 2021 — provisional 63/194,273
Examiner
ECKARDT, ADAM MICHAEL
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
MILWAUKEE ELECTRIC TOOL Corporation
OA Round
3 (Non-Final)
66%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 66% — above average
66%
Career Allowance Rate
119 granted / 181 resolved
-4.3% vs TC avg
Strong +41% interview lift
Without
With
+40.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
28 currently pending
Career history
217
Total Applications
across all art units

Statute-Specific Performance

§103
94.4%
+54.4% vs TC avg
§102
2.4%
-37.6% vs TC avg
§112
3.1%
-36.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 181 resolved cases

Office Action

§103 §112
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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 5/1/2026 has been entered. Response to Arguments Applicant’s arguments, filed 5/1/2026, with respect to 35 U.S.C 112(b) for claims 1 regarding the recitation of “wherein the power supply provides power to the heater to preheat the heater” have been fully considered and are moot in light of the recent amendments to the claims. The rejection of 1/6/2026 has been withdrawn because the claims were cancelled. Applicant’s arguments, filed 5/1/2026, with respect to the rejection(s) of amended claim(s) 12, 18, and new claim 24 under 35 USC 103 have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration and due to the amendments of 5/1/2026, a new ground(s) of rejections are made. Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: “an energy storage element coupled to the garment body and configured to store charge” in claims 12, 13, 15, 16, 18, and 24 is being interpreted as item 230 which are per par. 42 is battery packs, battery cells, capacitors, etc. “an illumination member that is configured to be illuminated” in claims 12, 18, 21, and 24 is being interpreted as items illumination member 940 and 1705 which are per fig. 11b and 19 is a light. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 18, 19, and 24-28 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Regarding claim 18, the examiner is unclear which illumination member the second receiver is “configured to…illuminate an illumination member of the device”. The examiner is unclear if the first or second illumination members are meant to be illuminated by the second receiver. Claims 19 are also rejected due to their dependence to one or more of the above rejected independent claims. Claim 24 recites the limitation " and the device ". There is insufficient antecedent basis for this limitation in the claim. Regarding claim 24, since the examiner is unclear what device the applicant is referring to in the recitation of “and the device”. The examiner interprets the applicant intends to reference the system referred to in the preamble. Claims 25-28 are also rejected due to their dependence to one or more of the above rejected independent claims. 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim(s) 12 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of US 7716013 B2 Orth Regarding claim 12, Tyson teaches, except where struck through, A heated garment comprising: a garment body (100); a heater (165) coupled to the garment body (figs. 1 and 12) (130); a receiver (145) coupled to the garment body and configured to wirelessly receive power (par. 114); an energy storage element (140) coupled to the garment body and configured to store charge provided to the receiver (145); and a controller (155) configured to selectively provide power from the energy storage element to the heater (165) (par. 128 teaches the controller controlling heating zones); a display configured to indicate a status of the heated garment (par. 127 teaches control button 175 containing one or more color LEDS which indicate the status of jacket 100); and a first illumination member (par. 127 teaches control button 175 containing one or more color LEDS which indicate the status of jacket 100, fig. 1 teaches control button 175 being on the lower right side of jacket 100 which therefore directs light away from the garment body) The difference between the prior art and the claimed invention is that Tyson does not teach: and a first illumination member provided on an end of a first sleeve of coupled to the garment body; and a second illumination member provided on an end of a second sleeve of the garment body.. Orth teaches host products including a jacket 38b with a first illumination member (light performance module 40c) provided on an end of a first sleeve of coupled to the garment body (column 4 lines 36 to 45). Therefore, It would have been obvious to one having ordinary skill in the art at the time the invention was made to rearrange control button 175 containing one or more color LEDS of Tyson, since it have been held that a mere rearrangement of element without modification of the operation of the device involves only routine skill in the art. One would have been motivated to rearrange the location of control button 175 of Tyson to a sleeve of a jacket 130 of Tyson as taught by Orth per column 4 lines 20 to 63 where light performance module 40c is located on the sleeve of jacket 38b for the purpose of also functioning as a reading light (Orth column 4 line 41). Tyson in view of Orth discloses the claimed invention except for the duplication of a second illumination member provided on an end of a second sleeve of the garment body. It would have been obvious to one having ordinary skill in the art at the time the invention was made to duplicate the first illumination member provided on an end of a first sleeve of coupled to the garment body, since it have been held that a mere duplication of working parts of a device involves only routine skill in the art. One would have been motivated to duplicate a first illumination member provided on an end of a first sleeve of coupled to the garment body to also be provided on the second sleeve jacket 130 of Tyson to create a second reading light (Orth column 4 line 41). Regarding claim 16, Tyson teaches: further comprising: an audible transducer configured to indicate a charge level of the energy storage element (par. 128 teaches replacing visual indicators with hepatic or audible indicators). Claim(s) 13 and 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of US 7716013 B2 Orth in view of US20190067979A1 van der Sluys. Regarding claim 13, Tyson does not teach further comprising: a wireless charging element coupled to the garment body at a first location in the garment body and including a transmitter configured to selectively receive power from the energy storage element and to wirelessly charge an electronic device when the electronic device is near the transmitter. van der Sluys teaches, further comprising: a wireless charging element (300a through 300C) coupled to the garment body (clothing item 510) at a first location (container 520A through 520C) in the garment body and including a transmitter (coil 210, coil 320, coils 1020A and B) configured to selectively receive power from the energy storage element and to wirelessly charge an electronic device when the electronic device is near the transmitter (par. 27, and 36 through 38 teach charging one or more electronic devices capable of being wirelessly charged, it would be obvious to one of ordinary skill in the art to charge a head covering providing said head covering is capable of being charged wirelessly. See 112(b) above). Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to modify the device in the Tyson reference, to include a wireless charging element and second transmitter, as suggested and taught by van der Sluys in the jacket 100 of Tyson for the purpose of providing a space to store and charge electronic devices capable of being wirelessly charged (van der Sluys par. 36-37). Regarding claim 17, Tyson does not teach further comprising: one or more light emitting diodes ("LEDs") coupled to the garment body and configured to be selectively illuminated by the controller van der Sluys teaches, further comprising: one or more light emitting diodes ("LEDs") coupled to the garment body and configured to be selectively illuminated by the controller (par. 44 teaches the use of lights to represent a charging level on the power source of van der Sluys and an LED is a subset of lights). Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to modify the device in the Tyson reference, to include a visual indicator of one or more lights, as suggested and taught by van der Sluys, for the purpose of indicating a charge level (par. 44 van der Sluys). Claim(s) 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of US20190067979A1 van der Sluys in view of EP3694078A1 Burns. Regarding claim 18, Tyson teaches, except where struck through, A heated garment comprising: a garment body (100); a heater (165) coupled to the garment body (figs. 1 and 12)(130); a receiver (145) coupled to the garment body and configured to wirelessly receive power (par. 114); an energy storage element (140) coupled to the garment body and configured to store charge provided to the receiver (145); and a controller (155) configured to: selectively provide power from the energy storage element to the heater (165)(par. 128 teaches the controller controlling heating zones),external to the heated garment and includes a second receiver configured to wirelessly receive power from the transmitter to illuminate an illumination member of the device. Tyson does not teach a transmitter coupled to the garment body and configured to wirelessly transmit power from the energy storage element to a device…nor… a controller configured to: selectively provide power from the energy storage element to the transmitter, wherein the device is external to the heated garment and includes a second receiver configured to wirelessly receive power from the transmitter to illuminate an illumination member of the device. van der Sluys teaches, a transmitter (coil 210, coil 320, coils 1020A and B) coupled to the garment body (clothing item 510) and configured to wirelessly transmit power from the energy storage element to a device (par. 27, and 36 through 38 teach charging one or more electronic devices capable of being wirelessly charged, it would be obvious to one of ordinary skill in the art to charge a head covering providing said head covering is capable of being charged wirelessly)…and… a controller configured to: selectively provide power from the energy storage element to the transmitter (par. 27) . Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to modify the device in the Tyson reference, to include a transmitter coupled to the garment body and configured to wirelessly transmit power from the energy storage element to a device…and… a controller configured to: selectively provide power from the energy storage element to the transmitter, as suggested and taught by van der Sluys in the jacket 100 of Tyson for the purpose of providing a space to store and charge electronic devices capable of being wirelessly charged (van der Sluys par. 36-37). Burns teaches, wherein the device is external to the heated garment and includes a second receiver (fig. 10B teaches a receiving coils Rx charging coil positioned in the middle back of a garment) configured to wirelessly receive power from the transmitter to illuminate an illumination member of the device (par. 121 to 123 teaches receiving coil Rx is configured to provide power, therefore, it is anticipated that receiving coil Rx is also configured to provide power to illuminate an illumination member ); Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to combine the device in the Tyson reference, to include the second receiver and second power supply, as suggested and taught by Burns, to wirelessly charge a garment on a hanger from two locations while traveling. Claim(s) 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of US20190067979A1 van der Sluys in view of EP3694078A1 Burns in view of US20240343333A1 Fuschs in view of US 20180048178 A1 Leabman. Regarding claim 19, It has been held that the recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647. The structure of the system of claim 18 of which claim 19 depends does not depend upon the desired shape of the illumination member i.e. a flashlight nor where on the body the illumination member and wireless charger are desired to be worn. Tyson does not teach wherein the garment body is worn on the hand of a user and the device is a flashlight. van der Sluys teaches that it is known to place a wireless transmitter and receiver in any location where charging is desired per figs. 5a, 5b, 6, 7, and 8. Fuschs teaches, wherein the garment body is worn on the hand of a user (par. 101 and 102 teach placing heating elements as loads in footwear, jackets, pants, shoes, and/or gloves, boots, shoes, and/or other footwear worn by the user). Fuschs teaches a known technique that is applicable to place heating elements in footwear, jackets, pants, shoes, and/or gloves. One of ordinary skill in the art would have been capable of applying this known technique to a known device (method, or product) that was ready for improvement and the results would have been predictable to one of ordinary skill in the art. Therefore, it would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to place a heating element in a glove. The results would have been predictable, because it allows power transfer from a vehicle to garment to allow a user to charge a garment, be it footwear, jackets, pants, shoes, and/or gloves while driving. Leabman teaches, the device is a flashlight (par. 525 teaches coupling a flashlight to an inductive receiver) . Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to modify the device in the Tyson reference, such that the device is a flashlight, as suggested and taught by Leabman, for the purpose of providing power transfer between a lighting device such as a flashlight and a receiver (Leabman par. 525) . One of ordinary skill in the art would have been capable of applying this known technique to a known device (method, or product) that was ready for improvement and the results would have been predictable to one of ordinary skill in the art. Therefore, it would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to use a flashlight as a load where the transmitter is in a glove. The results would have been predictable, because the art of van der Sluys teaches placing a wireless transmitter and receiver in any location where charging is required, Fuschs teaches placing transmitters and loads in a variety of worn articles of clothing, and Leabman teaches a wireless load as being a flashlight. Claim(s) 24, 27, and 28 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of EP3694078A1 Burns. Regarding claim 24, Tyson teaches, except where struck through, A system comprising: a power supply (140) including a first transmitter; a heated garment (100) including: a garment body (100), a heater (165) coupled to the garment body (figs. 1 and 12) (130), a first receiver (145) coupled to the garment body (par. 114) and configured to wirelessly receive power from the power supply (145), an energy storage element (140) coupled to the garment body and configured to store charge provided to the first receiver (145), and a controller (155) configured to selectively provide power from the energy storage element to the heater (165) (par. 128 teaches the controller controlling heating zones); The difference between the prior art and the claimed invention is that Tyson does not teach: a second transmitter configured to provide power from the energy storage element to a device external to the heated garment…nor… and the device including: a second receiver configured to wirelessly receive power from the energy storage element; and an illumination member that is illuminated when the second receiver receives power from the energy storage element. Burns teaches a second transmitter (1013) configured to provide power from the energy storage element to a device external to the heated garment (page 16 teaches “The second garment shown in Fig. 10B shows a receiver coil 303 which is located in the back portion second garment 211. The receiver coil 303 is located in the back portion of the second garment 211so that when the user is wearing the second garment 211 and is seated in the seat 1001 there is good overlap between the transmitter coils 1013 in the seat 1001 and the receiver coils 303 in the second garment 211. This therefore enables the second garment 211 to be wirelessly charged via the seat 1001”)…and… and the device including: a second receiver (fig. 10B teaches a receiving coil Rx charging coil positioned in the middle back of a garment) configured to wirelessly receive power from the energy storage element (page 16 teaches “The second garment shown in Fig. 10B shows a receiver coil 303 which is located in the back portion second garment 211. The receiver coil 303 is located in the back portion of the second garment 211so that when the user is wearing the second garment 211 and is seated in the seat 1001 there is good overlap between the transmitter coils 1013 in the seat 1001 and the receiver coils 303 in the second garment 211. This therefore enables the second garment 211 to be wirelessly charged via the seat 1001”); Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to modify the device in the Tyson reference, to include a second transmitter and second receiver , as suggested and taught by Burns in the jacket 100 of Tyson enables the second garment 211 to be wirelessly charged via the seat 1001 (Burns page 16). Regarding “an illumination member that is illuminated when the second receiver receives power from the energy storage element”, Burns teaches in an alternative embodiment of fig. 8, a power source 830 with a light, aka illumination member, that is capable of representing a charging level (par. 44). Therefore, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention to add the light from the alternative embodiment of Burns to the second receiver of fig. 10b of Burns for the purpose of representing a charging level (par. 44). Regarding claim 27, It has been held that the recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647. The structure of the system of claim 24 of which claim 27 depends does not depend upon the article of clothing it is placed into. Tyson teaches, wherein the device is a head covering (Tyson teaches wirelessly charging a garment per claim 1, and par. 5 to 7, Tyson further teaches that a garment can mean a hat which is a head covering, therefore, it would be obvious to one of ordinary skill in the art to charge a head covering providing said head covering is capable of being charged wirelessly). Regarding claim 28, It has been held that the recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647. The structure of the system of claim 24 of which claim 28 depends does not depend upon the article of clothing it is placed into. Tyson teaches, wherein the device is a safety vest (Tyson teaches wirelessly charging a garment per claim 1, and par. 5 to 7, Tyson further teaches that a garment can mean a vest, therefore, it would be obvious to one of ordinary skill in the art to charge a vest providing said head covering is capable of being charged wirelessly). Claim(s) 25 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of EP3694078A1 Burns in view of US 20180048178 A1 Leabman. Regarding claim 25, It has been held that the recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647. The structure of the system of claim 24 of which claim 25 depends does not depend upon the desired shape of the illumination member i.e. a flashlight. The difference between the prior art and the claimed invention is that Tyson does not teach: wherein the device is a flashlight. Leabman teaches, the device is a flashlight (par. 525 teaches coupling a flashlight to an inductive receiver) . Therefore, it would have been obvious before the effective date of the claimed invention to one of ordinary skill in the art to modify the device in the Tyson reference, such that the device is a flashlight, as suggested and taught by Leabman, for the purpose of providing power transfer between a lighting device such as a flashlight and a receiver (Leabman par. 525) . One of ordinary skill in the art would have been capable of applying this known technique to a known device (method, or product) that was ready for improvement and the results would have been predictable to one of ordinary skill in the art. Therefore, it would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to use a flashlight as a load where the transmitter is in a glove. Claim(s) 26 is/are rejected under 35 U.S.C. 103 as being unpatentable over US20200383395A1 Tyson in view of EP3694078A1 Burns in view of US 20180048178 A1 Leabman in view of US20240343333A1 Fuschs. Regarding claim 26, It has been held that the recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647. The structure of the system of claim 24 and 25 of which claim 26 depends does not depend upon the desired shape of the illumination member i.e. a flashlight nor where on the body the illumination member and wireless charger are desired to be worn. The difference between the prior art and the claimed invention is that Tyson does not teach: wherein the garment body is worn on a hand of a user. Fuschs teaches wherein the garment body is worn on a hand of a user (par. 101 and 102 teach placing heating elements as loads in footwear, jackets, pants, shoes, and/or gloves, boots, shoes, and/or other footwear worn by the user). Fuschs teaches a known technique that is applicable to place heating elements in footwear, jackets, pants, shoes, and/or gloves. One of ordinary skill in the art would have been capable of applying this known technique to a known device (method, or product) that was ready for improvement and the results would have been predictable to one of ordinary skill in the art. Therefore, it would have been obvious to one of ordinary skill in the art as of the effective filing date of the claimed invention to place a heating element in a glove. The results would have been predictable, because it allows power transfer from a vehicle to garment to allow a user to charge a garment, be it footwear, jackets, pants, shoes, and/or gloves while driving. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ADAM M ECKARDT whose telephone number is (313)446-6609. The examiner can normally be reached 6 a.m to 2:00 p.m EST Monday to Friday. 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, Edward Landrum can be reached at (571) 272-5567. 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. ADAM MICHAEL. ECKARDT Assistant Examiner Art Unit 3761 /ADAM M ECKARDT/ Examiner, Art Unit 3761 /WOODY A LEE JR/ Primary Examiner, Art Unit 3761
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Prosecution Timeline

May 27, 2022
Application Filed
Jul 10, 2025
Non-Final Rejection mailed — §103, §112
Oct 08, 2025
Response Filed
Jan 06, 2026
Final Rejection mailed — §103, §112
May 01, 2026
Request for Continued Examination
May 06, 2026
Response after Non-Final Action
Jun 23, 2026
Non-Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
66%
Grant Probability
99%
With Interview (+40.8%)
3y 6m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 181 resolved cases by this examiner. Grant probability derived from career allowance rate.

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