Prosecution Insights
Last updated: April 19, 2026
Application No. 18/148,159

Coupling Mechanism for a Modular System

Final Rejection §102§103
Filed
Dec 29, 2022
Examiner
MCMAHON, MATTHEW R
Art Unit
3678
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Milwaukee Electric Tool Corporation
OA Round
2 (Final)
57%
Grant Probability
Moderate
3-4
OA Rounds
3y 5m
To Grant
99%
With Interview

Examiner Intelligence

Grants 57% of resolved cases
57%
Career Allow Rate
414 granted / 725 resolved
+5.1% vs TC avg
Strong +53% interview lift
Without
With
+53.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
28 currently pending
Career history
753
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
39.2%
-0.8% vs TC avg
§102
31.4%
-8.6% vs TC avg
§112
25.1%
-14.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 725 resolved cases

Office Action

§102 §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 1-20 are pending in the application. In Applicant’s most-recent response filed 11 February 2026, claims 1, 9, 17, and 20 were amended. These amendments have been entered. Drawings The drawings were received on 11 February 2026. These drawings are acceptable. Claim Interpretation – Functional Language From the outset, it should be noted that some of the language in the claims is functional in nature. For example, the language related to a “coupling structure”, including its “ribs”, is functional in nature and limited patentable weight is given to this section of the claim. Additionally, Examiner notes that while features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. Apparatus claims cover what a device is, not what a device does and thus, a prior art device must only be capable of performing the stated function in order to read on the functional limitation. In this instance, the prior art discloses every structural limitation of the claim and thus this limitation fails to distinguish the claimed apparatus from that of the prior art. Please see MPEP 2114. [Examiner notes that this section of the Office Action does not constitute a rejection or objection, but is merely meant to indicate the manner in which the claims have been interpreted by the Examiner.] Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claims 1-2, 9, 13, and 16 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Scroggie (US Patent 8,936,420). Re Claim 1: Scroggie discloses a coupling mechanism (210; see the embodiment of Figs. 7-9) configured to mechanically engage and disengage a coupling structure (234), the coupling mechanism comprising: a housing (212) defining a lower surface; a projection (224) extending downward from the lower surface of the housing; and a plurality of arms (230) extending away from the projection, the plurality of arms (230) configured to detachably couple the coupling mechanism (210) with ribs (for example, as shown for the opposing edges of acceptance opening 232 of attachment panel 234; see note above related to this functional recitation) of the coupling structure (234), the plurality of arms coupled to the projection such that the arms actuate between: an engagement position (see Fig. 8) in which the plurality of arms extend upward and away from the projection (specifically, at the hook structure 275; see arrow in annotated Fig. 8 below); a disengagement position (see Fig. 7) in which the plurality of arms extend downward and away from the projection (specifically, at the hook structure 275; see arrow in annotated Fig. 8 below); and a locked position (see Fig. 9) between the engagement position and the disengagement position, wherein when the arms (230) are in the locked position (see Fig. 9) the ribs (for example, as shown for the opposing edges of acceptance opening 232 of attachment panel 234) are between the arms (230; specifically, at the lower portion of the wing elements 230, shown below the attachment panel 234) and the housing (212) to thereby couple the coupling mechanism to the coupling structure. PNG media_image1.png 558 1283 media_image1.png Greyscale Re Claim 2: Scroggie discloses a coupling mechanism (210; Figs. 7-9), further comprising a tension mechanism (comprised of folding legs 228) that, when actuated, releases the arms (230) from the locked position thereby permitting the arms to pivot into the disengagement position. Re Claim 9: Scroggie discloses a coupling mechanism (10; see the embodiment of Figs. 1-4) configured to mechanically engage and disengage a coupling structure, the coupling mechanism comprising: a housing (14) defining a lower surface; a projection (22) extending downward from the lower surface of the housing; and a plurality of arms (30), each of which extend away from the projection from an inner end closest to the projection to an opposing outer surface (at shoulder stop 38) furthest from the projection, the plurality of arms (30) configured to detachably couple the coupling mechanism (210) with ribs (for example, as shown for the opposing edges of acceptance opening 32 of attachment panel 34; see note above related to this functional recitation) of the coupling structure (234), the plurality of arms actuating between an engagement position (see Fig. 4) in which a first outer surface of a first arm of the plurality of arms defines a first distance (see “D1” in annotated Fig. 4 below) from the lower surface, a disengagement position (see Fig. 2) in which the first outer surface of the first arm defines a second distance (see “D2” in annotated Fig. 4 below) greater than the first distance, and a locked position (see Fig. 3) in which the first outer surface of the first arm defines a third distance (see “D3” in annotated Fig. 4 below) greater than the first distance and less than the second distance, wherein when the arms (30) are in the locked position (see Fig. 3) the ribs (for example, as shown for the opposing edges of acceptance opening 32 of attachment panel 34) are between the arms (30; specifically, at the lower portion of the wing elements 30, shown below the attachment panel 34) and the housing (14) to thereby couple the coupling mechanism to the coupling structure. PNG media_image2.png 357 1277 media_image2.png Greyscale Re Claim 13: Scroggie discloses a coupling mechanism (10; Figs. 1-3), further comprising a tension mechanism (comprised of folding legs 28) that, when actuated, releases the arms (30) from the locked position thereby permitting the arms to pivot into the disengagement position. Re Claim 16: Scroggie discloses a coupling mechanism (10; Figs. 1-3), the arms (30) are arranged around the projection (22) symmetrically with respect to each other. 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. Claims 3-5, 14-15, and 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over Scroggie (US Patent 8,936,420), as applied to claims 1-2, 9, 13, and 16 above, and further in view of Heflin (US Patent 6,652,206). Re Claim 3: Scroggie, as discussed above, discloses a coupling mechanism significantly as claimed except for further comprising a button that extends upward from an upper surface of the housing opposite the lower surface, the button actuating the tension mechanism. Heflin teaches the use of a coupling mechanism (see Figs. 1-5) comprising a housing (14) defining a lower surface (18A, 18B; Fig. 1); a projection (90) extending downward from the lower surface of the housing; a plurality of arms (54, 74) extending away from the projection, the arms coupled to the projection such that the arms actuate at least between a locked position (see Fig. 4) and a disengagement position (see Fig. 4); and a tension mechanism (comprised of bent arms 50, 70) that, when actuated releases the arms from the locked position thereby permitting the arms to pivot into the disengagement position; and further comprising a button (94) that extends upward from an upper surface (16) of the housing (14) opposite the lower surface, the button (94) actuating the tension mechanism, for the purpose of actuating the tension mechanism independent of the housing. PNG media_image3.png 509 710 media_image3.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the device of Scroggie, with a reasonable expectation of success, such that it further comprises a button that extends upward from an upper surface of the housing opposite the lower surface, the button actuating the tension mechanism, as taught by Heflin, for the purpose of actuating the tension mechanism independent of the housing. Re Claims 4-5: Scroggie, as discussed above, discloses a coupling mechanism significantly as claimed and further wherein the tension mechanism biases the arms to remain in the locked position until the tension mechanism is actuated (i.e. disengaged). Scroggie fails to explicitly disclose further comprising a button coupled to the projection, the button actuating the tension mechanism (as is required by claim 4); such that the tension mechanism biases the arms to remain in the locked position until the button is actuated (as is required by claim 5). Heflin teaches the use of a coupling mechanism (see Figs. 1-5) comprising a housing (14) defining a lower surface (18A, 18B; Fig. 1); a projection (90) extending downward from the lower surface of the housing; a plurality of arms (54, 74) extending away from the projection, the arms coupled to the projection such that the arms actuate at least between a locked position (see Fig. 4) and a disengagement position (see Fig. 4); and a tension mechanism (comprised of bent arms 50, 70) that, when actuated releases the arms from the locked position thereby permitting the arms to pivot into the disengagement position; and further comprising a button (94) coupled to the projection, the button actuating the tension; and wherein the tension mechanism biases the arms to remain in the locked position (see Fig. 5) until the button (94) is actuated, for the purpose of actuating the tension mechanism independent of the housing. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the device of Scroggie, with a reasonable expectation of success, such that it further comprises a button coupled to the projection, the button actuating the tension mechanism (as is required by claim 4); such that the tension mechanism biases the arms to remain in the locked position until the button is actuated (as is required by claim 5), as taught by Heflin, for the purpose of actuating the tension mechanism independent of the housing. Re Claims 14-15: Scroggie, as discussed above, discloses a coupling mechanism significantly as claimed except for further comprising a button that extends upward from an upper surface of the housing opposite the lower surface, the button actuating the tension mechanism (as is required by claim 14); and/or a button coupled to the projection, the button actuating the tension mechanism (as is required by claim 15). Heflin teaches the use of a coupling mechanism (see Figs. 1-5) comprising a housing (14) defining a lower surface (18A, 18B; Fig. 1); a projection (90) extending downward from the lower surface of the housing; a plurality of arms (54, 74) extending away from the projection, the arms coupled to the projection such that the arms actuate at least between a locked position (see Fig. 4) and a disengagement position (see Fig. 4); and a tension mechanism (comprised of bent arms 50, 70) that, when actuated releases the arms from the locked position thereby permitting the arms to pivot into the disengagement position; and further comprising a button (94) that extends upward from an upper surface (16) of the housing (14) opposite the lower surface, the button (94) actuating the tension mechanism; and/or a button (94) coupled to the projection (90), the button actuating the tension mechanism, for the purpose of actuating the tension mechanism independent of the housing. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the device of Scroggie, with a reasonable expectation of success, such that it further comprises a button that extends upward from an upper surface of the housing opposite the lower surface, the button actuating the tension mechanism (as is required by claim 14); and/or a button coupled to the projection, the button actuating the tension mechanism (as is required by claim 15), as taught by Heflin, for the purpose of actuating the tension mechanism independent of the housing. Re Claim 17: Scroggie discloses a coupling system (see the embodiment of Figs. 7-9) comprising: an object (for example, 270); and a coupling mechanism (210) coupled to the object, the coupling mechanism comprising: a housing (212) defining a lower surface facing away from the object (270); a projection (224) extending downward from the lower surface of the housing; a plurality of arms (230) extending away from the projection, the plurality of arms (230) configured to detachably couple the coupling mechanism (210) with ribs (for example, as shown for the opposing edges of acceptance opening 232 of attachment panel 234; see note above related to this functional recitation) of the coupling structure (234), the plurality of arms coupled to the projection such that the arms actuate between a disengagement position (see Fig. 7) in which the plurality of arms extend downward and away from the projection (specifically, at the hook structure 275; see arrow in annotated Fig. 8 above), and a locked position (see Fig. 9) in which the plurality of arms extend laterally away from the projection (see arrow in annotated Fig. 9 above), wherein when the arms (230) are in the locked position (see Fig. 9) the ribs (for example, as shown for the opposing edges of acceptance opening 232 of attachment panel 234) are between the arms (230; specifically, at the lower portion of the wing elements 230, shown below the attachment panel 234) and the housing (212) to thereby couple the coupling mechanism to the coupling structure. Scroggie fails to explicitly disclose a button that, when actuated, permits the plurality of arms to transition from the locked position to the disengagement position. Heflin teaches the use of a coupling mechanism (see Figs. 1-5) comprising a housing (14) defining a lower surface (18A, 18B; Fig. 1); a projection (90) extending downward from the lower surface of the housing; a plurality of arms (54, 74) extending away from the projection, the arms coupled to the projection such that the arms actuate at least between a locked position (see Fig. 4) and a disengagement position (see Fig. 4); and a tension mechanism (comprised of bent arms 50, 70) that, when actuated releases the arms from the locked position thereby permitting the arms to pivot into the disengagement position; and further comprising a button (94) that, when actuated, permits the plurality of arms to transition from the locked position to the disengagement position, for the purpose of actuating the tension mechanism independent of the housing. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the device of Scroggie, with a reasonable expectation of success, such that it further comprises a button that, when actuated, permits the plurality of arms to transition from the locked position to the disengagement position, as taught by Heflin, for the purpose of actuating the tension mechanism independent of the housing. Re Claim 18: Scroggie, as modified above in view of Heflin, discloses a coupling mechanism significantly as claimed except it does not explicitly disclose wherein the plurality of arms define a plurality of outer surfaces that collectively circumferentially extend at least 270 degrees around the projection. Examiner notes that it has been held that the optimization of proportions in a prior art device is a design consideration within the skill of the art. In re Reese, 290 F.2d 839, 129 USPQ 402 (CCPA 1961). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the device of Scroggie, with a reasonable expectation of success, such that the plurality of arms define a plurality of outer surfaces that collectively circumferentially extend at least 270 degrees around the projection, for the purpose of, for example, ensuring an adequate engagement with an object to be connected, and since such a modification would amount to a design consideration within the skill of the art. Re Claim 19: Scroggie further discloses a coupling mechanism (210; Figs. 7-9), further comprising a tension mechanism (comprised of folding legs 228) that, when actuated, releases the arms (230) from the locked position thereby permitting the arms to pivot into the disengagement position. Re Claim 20: Heflin further teaches wherein the button (94) is coupled to the projection (90), the button (94) actuating the tension mechanism. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the device of Scroggie, with a reasonable expectation of success, such that the button is coupled to the projection, the button actuating the tension mechanism, as taught by Heflin, for the purpose of actuating the tension mechanism independent of the housing. Claims 6-8 and 10-12 are rejected under 35 U.S.C. 103 as being unpatentable over Scroggie (US Patent 8,936,420). Re Claim 6: Scroggie, as discussed above for claim 1, discloses a coupling mechanism significantly as claimed except wherein the plurality of arms comprising at least four arms extending away from the projection and circumferentially surrounding the projection. Examiner notes that it has been held that duplicating the components of a prior art device is a design consideration within the skill of the art. In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960) [see MPEP 2144.04]. In addition, it has been held that mere duplication of essential working parts of a device involves only routine skill in the art. In re Regis Paper Co. v. Bemis Co., 193 USPQ 8. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the device of Scroggie, with a reasonable expectation of success, such that the plurality of arms comprising at least four arms extending away from the projection and circumferentially surrounding the projection, for the purpose of, for example, ensuring an adequate engagement with an object to be connected, and since such a modification would amount to a design consideration within the skill of the art. Re Claim 7: Scroggie, as discussed above for claim 1, discloses a coupling mechanism significantly as claimed except wherein the plurality of arms define a plurality of outer surfaces that collectively circumferentially extend at least 250 degrees around the projection. Examiner notes that it has been held that the optimization of proportions in a prior art device is a design consideration within the skill of the art. In re Reese, 290 F.2d 839, 129 USPQ 402 (CCPA 1961). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the device of Scroggie, with a reasonable expectation of success, such that the plurality of arms define a plurality of outer surfaces that collectively circumferentially extend at least 250 degrees around the projection, for the purpose of, for example, ensuring an adequate engagement with an object to be connected, and since such a modification would amount to a design consideration within the skill of the art. Re Claim 8: Scroggie, as modified above for claim 7, discloses a coupling mechanism significantly as claimed except wherein the plurality of arms comprising at least four arms extending away from the projection and circumferentially surrounding the projection. Examiner notes that it has been held that duplicating the components of a prior art device is a design consideration within the skill of the art. In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960) [see MPEP 2144.04]. In addition, it has been held that mere duplication of essential working parts of a device involves only routine skill in the art. In re Regis Paper Co. v. Bemis Co., 193 USPQ 8. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the device of Scroggie, with a reasonable expectation of success, such that the plurality of arms comprising at least four arms extending away from the projection and circumferentially surrounding the projection, for the purpose of, for example, ensuring an adequate engagement with an object to be connected, and since such a modification would amount to a design consideration within the skill of the art. Re Claim 10: Scroggie, as discussed above for claim 9, discloses a coupling mechanism significantly as claimed except wherein the plurality of arms define a plurality of outer surfaces that collectively circumferentially extend at least 270 degrees around the projection. Examiner notes that it has been held that the optimization of proportions in a prior art device is a design consideration within the skill of the art. In re Reese, 290 F.2d 839, 129 USPQ 402 (CCPA 1961). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the device of Scroggie, with a reasonable expectation of success, such that the plurality of arms define a plurality of outer surfaces that collectively circumferentially extend at least 270 degrees around the projection, for the purpose of, for example, ensuring an adequate engagement with an object to be connected, and since such a modification would amount to a design consideration within the skill of the art. Re Claim 11: Scroggie, as modified above for claim 10, discloses a coupling mechanism significantly as claimed except wherein the plurality of arms comprising at least four arms extending away from the projection and circumferentially surrounding the projection. Examiner notes that it has been held that duplicating the components of a prior art device is a design consideration within the skill of the art. In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960) [see MPEP 2144.04]. In addition, it has been held that mere duplication of essential working parts of a device involves only routine skill in the art. In re Regis Paper Co. v. Bemis Co., 193 USPQ 8. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the device of Scroggie, with a reasonable expectation of success, such that the plurality of arms comprising at least four arms extending away from the projection and circumferentially surrounding the projection, for the purpose of, for example, ensuring an adequate engagement with an object to be connected, and since such a modification would amount to a design consideration within the skill of the art. Re Claim 12: Scroggie further discloses a coupling mechanism (10; Figs. 1-3), further comprising a tension mechanism (comprised of folding legs 28) that, when actuated, releases the arms (30) from the locked position thereby permitting the arms to pivot into the disengagement position. Response to Arguments Applicant's arguments filed 11 February 2026 have been fully considered but they are not persuasive for at least the following reasons: Regarding independent claims 1 and 17, Applicant has argued that Scroggie fails to disclose the newly added language of the claim related to the position of the “plurality of arms” in relation to the “ribs” and the “housing” when in the “locked position”. Specifically, Applicant has argued that since the hook structures 275 of the arms 230 of Scroggie are located above the attachment panel 234, that the “ribs” cannot be located between the arms and the housing, as recited in the claim. However, as discussed in the prior art rejection above, it is the ”wing elements 230”, as a whole, of Scroggie that are considered to read on the claimed “plurality of arms”, not only the “hook structures 275”. The hook structures 275 are a part of the “wing elements 230”, but they do not constitute the entirety of the wing elements. Since at least the lower portion of the wing elements 230 is located below the attachment panel, the attachment panel 234 is, in fact, located between the arms 230 and the housing 212. Applicant is reminded that, although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). In this case, the claim does not require that an entirety of the “plurality of arms” must be located on an opposing sides of the “ribs” from the “housing”. Rather, given the scope of the claim limitation only at least a portion of the “plurality of arms” must be located in such a manner for the “ribs” to be located between the arms and the housing to satisfy the claim limitation. Accordingly, since at least a lower portion of the arms 230 is located below the attachment panel 234 and since the housing 212 is located above the attachment panel 234, the claim limitation is properly met by the structure of Scroggie. Regarding independent claim 9, Applicant has similarly argued that Scroggie fails to disclose the newly added language in the final paragraph of the claim related to the position of the “plurality of arms” in relation to the “ribs” and the “housing” when in the “locked position”. Examiner notes that Applicant has repeated the same argument used for claim 1 regarding the structure shown in Fig. 9, even though claim 9 was rejected in view of the embodiment of Figs. 1-4. Even still, Applicant’s argument is not persuasive for the same reasons discussed above, since in the locked position (see Fig. 4) of the embodiment of Figs. 1-4, the lower portion of the arms 30 is located below the attachment panel 34. Therefore the attachment panel 34 can be said to be located “between” the arms 30 and the housing 14. For at least these reasons Applicant’s arguments are not persuasive and the prior art rejections have not been overcome. 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 MATTHEW R MCMAHON whose telephone number is (571)270-3067. The examiner can normally be reached Mon-Fri 9am-5pm. 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, Amber Anderson can be reached at (571) 270-5281. 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. /MATTHEW R MCMAHON/Primary Examiner, Art Unit 3678
Read full office action

Prosecution Timeline

Dec 29, 2022
Application Filed
Nov 05, 2025
Non-Final Rejection — §102, §103
Feb 11, 2026
Response Filed
Feb 25, 2026
Final Rejection — §102, §103 (current)

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Expected OA Rounds
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