Prosecution Insights
Last updated: July 17, 2026
Application No. 18/062,693

ASSEMBLY COMPOSED OF A STEERING WHEEL HAVING AN ELECTRODE AND OF AN EVALUATION UNIT, THE EVALUATION UNIT BEING BETTER PROTECTED AGAINST SURGE VOLTAGE COUPLED IN FROM THE ELECTRODE AND BEING PROVIDED FOR CAPACITIVE TOUCH DETECTION, AND ASSOCIATED MOTOR VEHICLE

Final Rejection §103
Filed
Dec 07, 2022
Priority
Apr 22, 2021 — DE 10 2021 110 300.2 +1 more
Examiner
WEN, KEVIN GUANHUA
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Preh GmbH
OA Round
2 (Final)
60%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allowance Rate
103 granted / 172 resolved
-10.1% vs TC avg
Strong +37% interview lift
Without
With
+37.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
49 currently pending
Career history
259
Total Applications
across all art units

Statute-Specific Performance

§103
99.5%
+59.5% vs TC avg
§102
0.2%
-39.8% vs TC avg
§112
0.3%
-39.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 172 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 . Status of the Claims Claims 1, 5, 7, and 13 are amended. Claims 2-4, 6, 8-12, and 14-15 are as previously presented. Therefore, claims 1-15 are currently pending and have been considered below. Response to Amendment The amendment filed on March 30, 2026 has been entered. Applicant’s amendment overcomes the previously set-forth issue with the Specification’s Abstract length and the objection to claim 13. Response to Arguments Applicant's arguments filed on 03/30/2026 have been fully considered but they are not persuasive. Applicant argues that Poslowsky does not disclose where the connection between the electrode and the steering wheel core is high resistance during measurement and low resistance in the event of an overvoltage to discharge the overvoltage via the steering wheel core to the first ground connection. It is the Examiner’s position that this argument is true but not persuasive as claims 1 and 13 are rejected under U.S.C. 103 and a singular reference does not need to meet all of applicant’s limitations. It is instead the combination of references that must meet all of applicant’s limitations and the Examiner has used Lee to meet this changing resistance between the connection of the electrode and steering wheel core. Applicant argues that Okayama does not disclose where the evaluation electronics are electrically connected to a second ground connection and that the steering wheel core is electrically connected to a first ground connection, where the two ground connections are spatially separate from one another. It is the Examiner’s position that this argument is true but not persuasive as the rejection does not rely on Okayama alone to meet the entirety of the applicant’s stated limitation. Instead, it is the combination of Poslowsky with Okayama. Poslowsky discloses where the steering wheel core is electrically connected to a first ground connection, Page 19, Para. 3, “steering wheel core 7th directly to ground ( GND )”, and an evaluation electronic electrically connected to a second ground connection, Page 18, Para. 1, “control device 20th also with a second pole GND , especially a second pole GND a DC voltage source”. Poslowsky Fig. 4 further shows that the two grounds GND connected to A2 and GND connected to A4 are spatially separate from one another and also electrically connected to each other. It is the Examiner’s position that Poslowsky alone discloses the two spatially separated ground connections between the steering wheel core and evaluation electronics, however Okayama is presented to further show that if both devices were connected to the same ground that duplicating the ground is also known. Okayama then is used to show that even in the case where the steering wheel core and control device or evaluation electronics are both connected to the same GND in Poslowsky that duplicating the GND so that each of the devices go to a different GND is possible. It is the Examiner’s position that it would be obvious to duplicate GND as expanding a user’s design choices, where in the end the structure would still have grounding, as stated by Okayama, Para. 0149, “provided with a single unified ground terminal, or may be provided with three or more ground terminals. The number of sensor electrodes and the number of ground terminals provided do not necessarily need to be the same.”. Applicant argues that Lee does not disclose the claimed arrangement of a high resistance during normal operation and a low resistance during an overvoltage event. Applicant also argues that Lee does not disclose a connection between the electrode and steering wheel core and a discharge of overvoltage to the first ground connection via the steering wheel core. It is the Examiner’s position that applicant’s argument about the high resistance during normal operation and low resistance during an overvoltage event is not persuasive since Lee discloses the varistor which includes these features. Regarding the secondary argument, it is the Examiner’s position that this argument is true but not persuasive as the rejection relies on Poslowsky for these features. Poslowsky discloses the electrode and steering wheel core connection and where the steering wheel core is connected to a ground. The Examiner then uses Lee to show that a varistor can be used in an electrical connection to a steering wheel and this would apply to the configuration in Poslowsky, where the steering wheel core would be connected to a varistor and then to an electrode. Regarding the overvoltage to ground, Poslowsky discloses where the steering wheel core is connected to a ground and since the applicant’s claim limitations do not state what happens to voltage during when a measuring potential is applied, the Examiner’s position is that voltage goes to ground in both the normal operation and overvoltage event. As a result, the varistor in Lee placed within the steering wheel circuit of Poslowsky in either case of high or low resistance would still direct voltage to ground. Applicant argues that there is not a sufficient reasons as to why one of ordinary skill in the art would combine Lee’s varistor into Poslowsky as the Lee is directed toward a headlamp and Poslowsky is directed toward a capacitive sensing architecture. It is the Examiner’s position that this argument is not persuasive as Lee discloses benefits to using a varistor in allowing a specific reference voltage to be set for the circuit, where this benefit can be applied to an electrical circuit used in conjunction with a steering wheel like with Poslowsky, as stated by Lee, Page 4, Para. 6 from end, “In the present invention, the varistor 16 may be a zinc oxide varistor, for use as overvoltage protection for the head lamp 14, and the rated value for the headlamp bulb 14 a varistor (16) has been considered a specific reference voltage (rated voltage and the voltage of the headlamp on the boundary value)”. The Examiner suggests a potential amendment clarifying that when the connection is high-resistance when a measuring potential is applied at the electrode side that it hinders or blocks a current flow, support is found from applicant’s Spec Para. 0008. This would mean that the flow between the electrode and steering wheel core is kept within the connection and where during an overvoltage situation is where voltage goes to ground. This amendment would then overcome the prior art documents as it is currently assumed that both high and low resistance connections lead to the ground connection. Priority Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). The certified copy has been filed in parent Application No. DE10 2021 110 300.2, filed on 04/22/2021. Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. 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: “evaluation electronics” in Claim 1 and 13 The generic placeholder is “electronics” and the functional language attributed the “electronics” includes: “configured to apply an electrical measuring potential”. 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. Reference is made to the Specification filed on 12/07/2022. Regarding the evaluation electronics, on Page 11, “the evaluation unit is conductively connected to one or more electrodes for capacitive detection of a touch on the steering wheel.”, where the evaluation electronics is assumed consist of electrodes for capacitive detection 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 § 103 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. Claims 1, 3, and 11-12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A). Regarding claim 1, Poslowsky discloses an arrangement for a motor vehicle comprising a steering wheel (Page 1, last Para., “a heating device for a steering wheel of a vehicle”), having an electrode (Page 17, Para. 2, “a capacitive sensor electrode 4th”), and evaluation electronics (Page 17, last Para., “a control device 20th which is set up both to control a heating function and to control a sensor function”), and which are electrically conductively connected to the electrode for capacitive detection of a touch on the steering wheel (Page 5, Para. 3, “The sensor device of a sensor and heating device according to the invention is particularly preferably designed to detect the presence of a human hand in a gripping area of a steering wheel, in particular to detect an approach and / or a removal of a human hand to the steering wheel or away from the steering wheel and / or to Detecting a touch of the steering wheel with a human hand”, where the control device 20 is connected to the sensor or capacitive sensor), wherein the steering wheel has a steering wheel rim and an electrically conductive steering wheel core (Page 5, Para. 2 from end, “an elongated wire or a thread-like conductor, which can in particular be arranged around a core of a steering wheel rim”) for fixing to a steering wheel shaft (Page 15, last Para., “steering column module, the steering wheel-side part in a functional installation state of the steering wheel assembly in a vehicle is movable relative to the part on the vehicle body, in particular rotatable in relation to the part on the vehicle body, in particular about an axis of rotation of a steering shaft”, where the steering shaft would be connected to the wheel core with the sensor), wherein the steering wheel core is electrically conductively connected to a first ground connection via a first ohmic resistor (Page 19, Para. 3, “steering wheel core 7th directly to ground ( GND ), for example as in 2 shown via the connecting cable 50”, where the resistor is shown by 13-5, Page 19, last Para., “several individual, mutually insulated conductor tracks 13-1 , 13-2 , 13-3 , 13-4 , 13-5 and 13-6 having, electrically connected to each other.”), wherein the evaluation electronics are configured to apply an electrical measuring potential to the electrode for a touch detection, wherein the touch detection detects a touch on the steering wheel rim on the basis of a change in a measuring capacitance formed between the electrode and the steering wheel core (Page 4, last Para., “a capacitive coupling of the combined heating and sensor element with an environment of the heating and sensor element and / or with a reference electrode, in particular with a reference electrode on which a defined Potential is applied, can be applied or is applied, to detect and in particular to evaluate a change in this capacitive coupling and / or a variable characterizing this capacitive coupling and / or the change in this capacitive coupling.”, and Page 4, Para. 2 from end, “Capacitive sensor devices for detecting the presence of a capacitively active actuating means in a detection area of the sensor device are known in principle from the prior art, also for steering wheels of vehicles, in particular for detecting a human hand in a gripping area of a steering wheel”). Poslowsky does not disclose: where the evaluation electronics are to be protected against an electrical overvoltage; wherein the evaluation electronics are furthermore electrically conductively connected to a second ground connection, wherein the first ground connection and the second ground connection are arranged spatially separate from one another and are electrically conductively connected via a ground path; and a connection, which is provided between the electrode and the steering wheel core and wherein the connection has an overvoltage discharge element, wherein the connection is a high-resistance when a measuring potential is applied on an electrode side and wherein the connection is a low-resistance in an event of an overvoltage on the electrode side, to discharge the overvoltage to the first ground connection via the steering wheel core. However, Okayama discloses, in the similar field of steering wheels with electrical systems (Abstract, “A measurement device includes: a first cover electrode provided on a steering wheel”), where there can be two ground connections, where the first ground and second ground connections are connected to each through a ground path (Para. 0149, “In such cases, steering wheel cover 110 may be provided with two ground terminals, one for each first cover electrode 11 and second cover electrode 12, may be provided with a single unified ground terminal, or may be provided with three or more ground terminals.”, where Fig. 19 shows that the electrodes 11 and 12 are separate and that would mean the two ground connections are spatially separate; where the ground path is the unified terminal that would lead to two ground locations). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground terminal of the steering wheel in Poslowsky to include two ground terminals as taught by Okayama. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use any amount of ground terminals depending on a user’s design choices, where in the end the structure would still have grounding, as stated by Okayama, Para. 0149, “provided with a single unified ground terminal, or may be provided with three or more ground terminals. The number of sensor electrodes and the number of ground terminals provided do not necessarily need to be the same.”. Further, Lee discloses, in the similar field of steering wheels and electrical systems (Page 2, Para. 4, “operation is controlled by the switching of the multi-function switch provided on one side of the steering wheel.”), where the electrical system can be protected against electrical overvoltage through a varistor (Page 4, Para. 6 from end, “In the present invention, the varistor 16 may be a zinc oxide varistor, for use as overvoltage protection for the head lamp 14, and the rated value for the headlamp bulb 14 a varistor (16) has been considered a specific reference voltage (rated voltage and the voltage of the headlamp on the boundary value), the voltage is to be divided is used.”), where there is a connection to the varistor that would have a high resistance during regular use and a low resistance during overvoltage (Page 4, Para. 5 from end, “For example, as shown in Figure 2, when the voltage of the control being designed so as to have less than the reference voltage of 13.2V 13.2V or more is applied to the voltage, the current does not flow current can be allowed to flow only when a varistor is applied.”, where the definition of a varistor is that a high resistance is provided during regular use and where a low resistance is provided during overvoltage, “When a small voltage is applied across the electrodes, only a tiny current flows, caused by reverse leakage through the diode junctions. When a large voltage is applied, the diode junction breaks down due to a combination of thermionic emission and electron tunneling, resulting in a large current flow.”, from https://en.wikipedia.org/wiki/Varistor). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground connection to the electrode in modified Poslowsky to include the varistor as taught by Lee. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use the varistor to protect the system from overvoltage, where this would allow for a specific reference voltage to be determined for the system, as stated by Lee, Page 4, Para. 6 from end, “In the present invention, the varistor 16 may be a zinc oxide varistor, for use as overvoltage protection for the head lamp 14, and the rated value for the headlamp bulb 14 a varistor (16) has been considered a specific reference voltage (rated voltage and the voltage of the headlamp on the boundary value)”. Regarding claim 3, modified Poslowsky teaches the apparatus according to claim 1, as set forth above, discloses wherein the steering wheel core is furthermore connected to the second ground connection via a capacitor (Poslowsky, Fig. 4, where the ground GND connection is connected to the steering wheel core through a capacitor, Page 18, Para. 2 from end, 1 to 5 each through corresponding capacitors shown in dashed lines with C1 to C6 are denoted, are represented symbolically and via which in each case when the associated switching device S1 , S2 , S3 , S4 , S5 or. S6”; where the teaching of Okayama would have a second ground connection, where the connection can be duplicated from Poslowsky to then also include a capacitor). Regarding claim 11, modified Poslowsky teaches the apparatus according to claim 1, as set forth above, discloses wherein the electrode is formed by a heating wire of a steering wheel heating device (Poslowsky, Page 7, last Para., “The use of a combined heating and sensor element both as an electrical heating element and as a capacitive sensor electrode requires an electrical connection of the heating and sensor element to a voltage source, in particular a current flow through the heating and sensor element, in order to operate the heating device, in particular to generate heat through it, especially a closed circuit. In contrast, to operate a combined sensor and heating device as a sensor device, ie to use the heating and sensor element as a capacitive sensor electrode, an all-pole electrical separation of the heating and sensor element from the voltage supply is required, ie an electrical separation of the heating and sensor element from both poles of the associated voltage source. For this purpose, at least two switching devices are required, which can be opened and closed accordingly.”, where the heating device includes an electrode that would be connected to the heating device through the heating wire, where an electrode is a conductor and would be integrated into the heating wire used to connect to the heating device). Regarding claim 12, modified Poslowsky teaches the apparatus according to claim 1, as set forth above, discloses wherein the evaluation electronics and the overvoltage discharge element are arranged outside the steering wheel (Poslowsky, Fig. 1, the evaluation electronics are 20, where it is located away from the steering wheel 3; teaching from Lee, Page 4, Para. 6 from end, “In the present invention, the varistor 16 may be a zinc oxide varistor, for use as overvoltage protection for the head lamp 14, and the rated value for the headlamp bulb 14 a varistor (16) has been considered a specific reference voltage (rated voltage and the voltage of the headlamp on the boundary value), the voltage is to be divided is used.”, where the varistor is located away from the head lamp 13 that would include the steering wheel). Claims 2 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Kitzenmaier (DE 102019213392 A1). Regarding claim 2, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein the overvoltage discharge element is a diode. However, Kitzenmaier discloses, in the similar field of overvoltage devices (Page 6, Para. 1, “The coupling element 2 can also be a protective element against electrostatic overvoltages against ground GND”), where the overvoltage discharge element is a diode (Page 6, Para. 1, “a protective element against electrostatic overvoltages against ground GND or device ground, such as an ESD protection diode or a varistor, with the smallest possible capacitance.”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the varistor in modified Poslowsky to be a diode as taught by Kitzenmaier. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able achieve the same end result of protecting the system against overvoltage, as stated by Kitzenmaier, Page 6, Para. 2, “an electrostatic protection element can also be arranged, such as, for example, a varistor with the smallest possible capacitance. The power and / or data line to the electronics can have a second coupling element 6thinclude, such as a diode, a protective diode, an ESD diode, a varistor, another protective element against electrostatic overvoltages or overvoltages in general”. Claims 4, 8, 13, and 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Singh et al. (US 20210001913 A1, hereinafter Singh). Regarding claim 4, modified Poslowsky teaches the apparatus according to claim 3, as set forth above. Modified Poslowsky does not disclose: wherein a second ohmic resistor is connected in parallel with the capacitor, wherein a resistance on the second ohmic resistor is greater than a resistance on the first ohmic resistor. However, Singh discloses, in the similar field of steering wheels with electrical systems (Abstract, “A delay unit for use in a steering wheel system”), where resistors can be connected in parallel and where a second resistance of the second resistor is greater than the resistance of the first resistor (Para. 0022, “The third resistor 34 and the second resistor 30 are in parallel with each other. The third resistor 34 has a resistance value greater than the second resistor 30 so as to facilitate a discharge from the capacitor 24 to ground.”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the resistor connected to the ground from modified Poslowsky to include a parallel second resistor with a greater resistance as taught by Singh. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use a higher resistance to facilitate a discharge to the ground, as stated by Singh, Para. 0022, “The third resistor 34 has a resistance value greater than the second resistor 30 so as to facilitate a discharge from the capacitor 24 to ground.”. Regarding claim 8, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein the first ground connection and the second ground connection area arranged to have a minimum spatially distance of 0.5 m from one another. However, Singh discloses where there are multiple ground connections that are spatially separated at least within the meter range (Para. 0030, “a first diode 28 configured to direct a discharge from the capacitor 24 to a ground… The third resistor 34 has a resistance value greater than the second resistor 30 so as to facilitate a discharge from the capacitor 24 to ground.”, and Fig. 2, where the ground connections are shown to be spatially separated; Fig. 1, where each of the electrical devices is shown, with a device on the steering wheel and devices within the engine of the car, where the distance between the engine to the steering wheel is within the meter range). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the first and second ground connection in modified Poslowsky to be spatially separated as taught by Singh. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to protect each electrical device through having individual grounding, as stated by Singh, Para. 0033, “Further the voltage regulator 36 cooperates with the second resistor 30 so as to help direct a discharge from the capacitor 24 to ground.”. Regarding the specific separation distance, it has been held that mere changes in size are obvious modifications to make. In Gardner v. TEC Syst., Inc., 725 F.2d 1338, 220 USPQ 777 (Fed. Cir. 1984), cert. denied, 469 U.S. 830, 225 USPQ 232 (1984). It is the Examiner’s position that the dimensions of the vehicle could be altered so that the ground connections are movable within the meter range, where the separation would still be within the meter range and the end result of grounding each electrical device would still be the same. As a result, the specific dimensions of the grounding would be a mere matter of user design choice. Regarding claim 15, modified Poslowsky teaches the apparatus according to claim 8, as set forth above, discloses wherein the first ground connection and the second ground connection are electrically conductively connected with a low resistance (RM) via the ground path (Teaching from Lee, Page 4, Para. 5 from end, “For example, as shown in Figure 2, when the voltage of the control being designed so as to have less than the reference voltage of 13.2V 13.2V 13.2V or more is applied to the voltage, the current does not flow current can be allowed to flow only when a varistor is applied.”, where the definition of a varistor is that a high resistance is provided during regular use and where a low resistance is provided during overvoltage, “When a small voltage is applied across the electrodes, only a tiny current flows, caused by reverse leakage through the diode junctions. When a large voltage is applied, the diode junction breaks down due to a combination of thermionic emission and electron tunneling, resulting in a large current flow.”, from https://en.wikipedia.org/wiki/Varistor, where the ground connections would have a low resistance path when overvoltage occurs due to the varistor having a low resistance). Regarding claim 13, Poslowsky discloses a motor vehicle (Page 11, Para. 2, “a motor vehicle is designed with a steering wheel-side part and a vehicle-body-side part”), comprising: an arrangement, wherein the arrangement further comprise: a steering wheel (Page 1, last Para., “a heating device for a steering wheel of a vehicle”), having an electrode (Page 17, Para. 2, “a capacitive sensor electrode 4th”), and evaluation electronics (Page 17, last Para., “a control device 20th which is set up both to control a heating function and to control a sensor function”), which are electrically conductively connected to the electrode for capacitive detection of a touch on the steering wheel (Page 5, Para. 3, “The sensor device of a sensor and heating device according to the invention is particularly preferably designed to detect the presence of a human hand in a gripping area of a steering wheel, in particular to detect an approach and / or a removal of a human hand to the steering wheel or away from the steering wheel and / or to Detecting a touch of the steering wheel with a human hand”, where the control device 20 is connected to the sensor or capacitive sensor), wherein the steering wheel has a steering wheel rim and an electrically conductive steering wheel core (Page 5, Para. 2 from end, “an elongated wire or a thread-like conductor, which can in particular be arranged around a core of a steering wheel rim”) for fixing to a steering wheel shaft (Page 15, last Para., “steering column module, the steering wheel-side part in a functional installation state of the steering wheel assembly in a vehicle is movable relative to the part on the vehicle body, in particular rotatable in relation to the part on the vehicle body, in particular about an axis of rotation of a steering shaft”, where the steering shaft would be connected to the wheel core with the sensor), wherein the steering wheel core is electrically conductively connected to a first ground connection via a first ohmic resistor (Page 19, Para. 3, “steering wheel core 7th directly to ground ( GND ), for example as in 2 shown via the connecting cable 50”, where the resistor is shown by 13-5, Page 19, last Para., “several individual, mutually insulated conductor tracks 13-1 , 13-2 , 13-3 , 13-4 , 13-5 and 13-6 having, electrically connected to each other.”), wherein the evaluation electronics are configured to apply an electrical measuring potential to the electrode for a touch detection, wherein the touch detection detects a touch on the steering wheel rim on the basis of a change in a measuring capacitance formed between the electrode and the steering wheel core (Page 4, last Para., “a capacitive coupling of the combined heating and sensor element with an environment of the heating and sensor element and / or with a reference electrode, in particular with a reference electrode on which a defined Potential is applied, can be applied or is applied, to detect and in particular to evaluate a change in this capacitive coupling and / or a variable characterizing this capacitive coupling and / or the change in this capacitive coupling.”, and Page 4, Para. 2 from end, “Capacitive sensor devices for detecting the presence of a capacitively active actuating means in a detection area of the sensor device are known in principle from the prior art, also for steering wheels of vehicles, in particular for detecting a human hand in a gripping area of a steering wheel”). Poslowsky does not disclose: where the evaluation electronics are to be protected against an electrical overvoltage and wherein the evaluation electronics are furthermore electrically conductively connected to a second ground connection, wherein the first ground connection and the second ground connection are arranged spatially separate from one another and are electrically conductively connected via a ground path; and a connection, which is provided between the electrode and the steering wheel core and wherein the connection has an overvoltage discharge element, wherein the connection is a high-resistance when a measuring potential is applied on an electrode side and wherein the connection is a low-resistance in an event of an overvoltage on the electrode side to discharge the overvoltage to the first ground connection via the steering wheel core, wherein a conductive ground path between the first ground connection and the second ground connection is formed at least partially by at least one of: a body shell and a frame of the motor vehicle. However, Okayama discloses, in the similar field of steering wheels with electrical systems (Abstract, “A measurement device includes: a first cover electrode provided on a steering wheel”), where there can be two ground connections, where the first ground and second ground connections are connected to each through a ground path (Para. 0149, “In such cases, steering wheel cover 110 may be provided with two ground terminals, one for each first cover electrode 11 and second cover electrode 12, may be provided with a single unified ground terminal, or may be provided with three or more ground terminals.”, where Fig. 19 shows that the electrodes 11 and 12 are separate and that would mean the two ground connections are spatially separate; where the ground path is the unified terminal that would lead to two ground locations). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground terminal of the steering wheel in Poslowsky to include two ground terminals as taught by Okayama. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use any amount of ground terminals depending on a user’s design choices, where in the end the structure would still have grounding, as stated by Okayama, Para. 0149, “provided with a single unified ground terminal, or may be provided with three or more ground terminals. The number of sensor electrodes and the number of ground terminals provided do not necessarily need to be the same.”. Further, Lee discloses, in the similar field of steering wheels and electrical systems (Page 2, Para. 4, “operation is controlled by the switching of the multi-function switch provided on one side of the steering wheel.”), where the electrical system can be protected against electrical overvoltage through a varistor (Page 4, Para. 6 from end, “In the present invention, the varistor 16 may be a zinc oxide varistor, for use as overvoltage protection for the head lamp 14, and the rated value for the headlamp bulb 14 a varistor (16) has been considered a specific reference voltage (rated voltage and the voltage of the headlamp on the boundary value), the voltage is to be divided is used.”), where there is a connection to the varistor that would have a high resistance during regular use and a low resistance during overvoltage (Page 4, Para. 5 from end, “For example, as shown in Figure 2, when the voltage of the control being designed so as to have less than the reference voltage of 13.2V 13.2V 13.2V or more is applied to the voltage, the current does not flow current can be allowed to flow only when a varistor is applied.”, where the definition of a varistor is that a high resistance is provided during regular use and where a low resistance is provided during overvoltage, “When a small voltage is applied across the electrodes, only a tiny current flows, caused by reverse leakage through the diode junctions. When a large voltage is applied, the diode junction breaks down due to a combination of thermionic emission and electron tunneling, resulting in a large current flow.”, from https://en.wikipedia.org/wiki/Varistor). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground connection to the electrode in modified Poslowsky to include the varistor as taught by Lee. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use the varistor to protect the system from overvoltage, where this would allow for a specific reference voltage to be determined for the system, as stated by Lee, Page 4, Para. 6 from end, “In the present invention, the varistor 16 may be a zinc oxide varistor, for use as overvoltage protection for the head lamp 14, and the rated value for the headlamp bulb 14 a varistor (16) has been considered a specific reference voltage (rated voltage and the voltage of the headlamp on the boundary value)”. Furthermore, Singh discloses where the conductive ground path between two different ground connections is formed by the frame and body shell of the motor vehicle (Fig. 1, where the electrical components 14 and 18 are shown within the engine compartment of the motor vehicle, where the electrical path in Fig. 2 that includes ground connections would then be within the frame of the motor vehicle and connected to the body shell). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground connection in modified Poslowsky to be within the frame and body shell of the motor vehicle as taught by Singh. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to include a power source within the motor vehicle, where there is enough space for the electrical connections to be made, as stated by Singh, Para. 0015, “The horn switch 16a completes an electrical connection from a power source 18 to a semiconductor switch 20. The semiconductor switch 20 is configured to electrically couple the horn 14 to the power source 18”. Claims 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Fujita et al. (JP 2009071708 A, hereinafter Fujita). Regarding claim 5, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein a resistance on the first ohmic resistor is in a range of 500 Ω to 10 kΩ. However, Fujita discloses, in the similar field of capacitance sensors for human contact (Page 2, Para. 2, “A touch sensor that detects contact or non-contact of a human body based on a change in capacitance of an electrode”), where the resistance of a resistor is in the range of 500 Ω to 10 kΩ (Page 12, Para. 5, “In FIG. 8, the capacitance of the capacitor Cs is 12 pF, the resistance R is 10 kΩ, the capacitance of the capacitor Ca is 0.1 μF”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the first resistor in modified Poslowsky to have the resistance value as taught by Fujita. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use resistance values to influence the charging voltage of the capacitor, where these values can be controlled by a user depending on their design needs, as stated by Fujita, Page 12, last Para., “charging voltage Va of the capacitor Ca attenuates with the passage of time t during which the switch is kept on, as shown in FIG. This relationship can be expressed as the following formula (1). Va = Vcc × e ^ (− (ON time of switch SW2) / (Ca × R))”. Claims 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Inseong (KR 200355389 Y1). Regarding claim 6, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein the overvoltage on the electrode side is conducted to the first ground connection via the steering wheel shaft. However, Inseong discloses, in the similar field of steering wheels with electrical systems (Page 1, Para. 2, “a steering wheel for the vehicle comprising a steering wheel and the vehicle body fixed portion”), where the ground connection is done via the steering wheel shaft (Page 4, Para. 5 from end, “The ground wire 28 is connected to the shaft 110, the other power line is drawn and connected to the temperature sensor 30”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground connection to the electrode from modified Poslowsky to have the ground connection be done via the steering wheel shaft as taught by Inseong. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to ground the steering wheel to the vehicle body, where this is possible through the connection of the ground via the steering wheel shaft, as stated by Inseong, Page 4, Para. 4-5, “The steering wheel shaft 110 is fixed to connect the vehicle body fixing part body 16 of the vehicle body fixing part 108 through the clock portion 102 and the handle rotating part body 14. The ground wire 28 is connected to the upper end of the steering wheel shaft 110.”. Claims 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Temming et al. (CN 109937398 A, hereinafter Temming). Regarding claim 7, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein a resistance on the first ohmic resistor is formed substantially by a contact resistance in a region of a bearing of the steering wheel shaft. However, Temming discloses, in the similar field of steering wheels with electrical systems (Page 2, Para. 4, “operating element integrated in the steering wheel or the steering wheel surface”), where the resistance of a resistor can be formed through contact resistance of a bearing (Page 2, last Para., “control device comprises using a resistor having a touch surface, the resistance is pressure sensitive and connected with the bearing structure. the bearing structure is concave or bulge has a three dimensional surface, wherein the touch sensor has a shape formed such that in the assembled state, at least a portion of the touch surface of the forming of the contacts”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the steering wheel shaft in modified Poslowsky to include the bearing with contact resistance resistor as taught by Temming. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use a resistor that is pressure sensitive, which can allow a user to alter the resistance depending on the pressure applied to the bearing, as stated by Temming, Page 2, last Para., “control device comprises using a resistor having a touch surface, the resistance is pressure sensitive and connected with the bearing structure. the bearing structure is concave or bulge has a three dimensional surface”. Claims 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Singh et al. (US 20210001913 A1, hereinafter Singh) and Otake et al. (US 20200313590 A1, hereinafter Otake). Regarding claim 9, modified Poslowsky teaches the apparatus according to claim 8, as set forth above. Modified Poslowsky does not disclose: wherein the first ground connection and the second ground connection are electrically conductively connected with a potential equalization, and thereby defining a common ground potential via the ground path. However, Otake discloses, in the similar field of steering wheels with electrical systems (Para. 0006, “electric power steering apparatus”), where multiple ground connections can be connected to a common ground potential, where this would mean that there is potential equalization (Para. 0058, “In this embodiment, it is assumed that the potentials of the grounds GNDl and GND2 of the microcomputers 401 and 402 are independent from each other…In case of systems having a common ground potential, there arises no critical problem substantially, even if a difference occurs in power supply currents”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the first and second ground connections in modified Poslowsky to have a common ground potential as taught by Otake. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to prevent problems when there is a different in power supply currents to the different electrical devices within the system, as stated by Otake, Para. 0058, “In case of systems having a common ground potential, there arises no critical problem substantially, even if a difference occurs in power supply currents”. Claims 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Steinberger et al. (DE 202005003893 U1, hereinafter Steinberger). Regarding claim 10, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein the first ground connection and the second ground connection are each formed by a disconnectable electromechanical connecting device. However, Steinberger discloses, in the similar field of steering wheels with electrical systems (Abstract, “a steering wheel, and heating units (4, 5) integrated into the cover.”), where electrical systems can include plugs to allow for detachability (Page 2, Para. 2 from end, “steering wheel cover or the heating elements arranged thereon detachably formed. hereby the battery can be removed for charging. Between the steering wheel cover and the power line connected to the battery can be a detachable plug connection be provided.”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the ground connections in modified Poslowsky to include a disconnectable plug as taught by Steinberger. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to allow for the steering wheel with capacitance system to be removed fully, so that safety is improved in allowing for the system to not be tangled, as stated by Steinberger, Page 4, Para. 5, “heating elements arranged thereon 4 and 5 advantageously via a detachable plug connection 19 connected. This has the advantage that the battery 14 for example, for the purpose of loading can be removed. In addition, this is advantageous in terms of safety”. Claims 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poslowsky (DE 102019124293 A1) in view of Okayama (US 20210061355 A1) and Lee (KR 20060092007 A) in further view of Jang et al. (WO 2019221333 A1, hereinafter Jang). Regarding claim 14, modified Poslowsky teaches the apparatus according to claim 1, as set forth above. Modified Poslowsky does not disclose: wherein the overvoltage discharge element is any one of: a transient absorption Zener diode and a transient voltage suppressor diode. However, Jang discloses, in the similar field of overvoltage protection devices (Page 3, Para. 4, “overvoltage protection device”), where the overvoltage element can be a transient absorption Zener diode and a transient voltage suppressor (Page 3, Para. 4, “an overvoltage protection device including a varistor, a transient voltage suppressor (TVS), a metal oxide varistor (MOV), and a zener diode.”). It would have been obvious for one of ordinary skill in the art before the effective filling date of the claimed invention to have modified the overvoltage varistor in modified Poslowsky to be a zener diode or a transient voltage suppressor as taught by Jang. One of ordinary skill in the art would have been motivated to make this modification in order to gain the advantage of being able to use different overvoltage devices that are all able to achieve the same end result, where the selection of a specific device would be dependent on a user’s specific design needs, as stated by Jang, Page 4, Para. 5 from end, “an overvoltage protection device including a varistor, a transient voltage suppressor (TVS), a metal oxide varistor (MOV), a zener diode, and the like.”. 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 KEVIN GUANHUA WEN whose telephone number is (571)272-9940 and whose email is kevin.wen@uspto.gov. The examiner can normally be reached Monday-Friday 10:00 am - 6:00 pm. 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, Ibrahime Abraham can be reached on 571-270-5569. 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. /KEVIN GUANHUA WEN/Examiner, Art Unit 3761 06/08/2026 /IBRAHIME A ABRAHAM/Supervisory Patent Examiner, Art Unit 3761
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Prosecution Timeline

Dec 07, 2022
Application Filed
Nov 28, 2025
Non-Final Rejection mailed — §103
Mar 30, 2026
Response Filed
Jun 16, 2026
Final Rejection mailed — §103 (current)

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