Prosecution Insights
Last updated: April 19, 2026
Application No. 18/155,472

SYSTEM AND METHOD FOR A SMART RAIL TARGET

Final Rejection §103
Filed
Jan 17, 2023
Examiner
DAVISON, LAURA L
Art Unit
3993
Tech Center
3900
Assignee
Milo Range
OA Round
2 (Final)
32%
Grant Probability
At Risk
3-4
OA Rounds
2y 4m
To Grant
68%
With Interview

Examiner Intelligence

Grants only 32% of cases
32%
Career Allow Rate
191 granted / 587 resolved
-27.5% vs TC avg
Strong +35% interview lift
Without
With
+35.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 4m
Avg Prosecution
33 currently pending
Career history
620
Total Applications
across all art units

Statute-Specific Performance

§101
1.6%
-38.4% vs TC avg
§103
39.0%
-1.0% vs TC avg
§102
20.1%
-19.9% vs TC avg
§112
34.1%
-5.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 587 resolved cases

Office Action

§103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Response to Amendment The amendment filed on November 20, 2025, has been entered. Claims 1-20 remain pending in the application. Applicant’s amendments to the specification have overcome the objection previously set forth in the non-final Office action mailed August 22, 2025. 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 1-4, 6-7, and 10-13 are rejected under 35 U.S.C. 103 as being unpatentable over Ghani (US Patent Pub. 2018/0202775, hereinafter Ghani) in view of Billington et al. (US Patent No. 2018/0164082, hereinafter Billington), Hinton (US Patent Pub. 2019/0316885, hereinafter Hinton), and Wikipedia, “Inductive charging” article (hereinafter Wikipedia). Regarding claim 1, Ghani discloses a system for a smart rail target (Figs. 1-4; ¶ 50) comprising: a rail (104); a car device (motorized target trolley 105) configured for being mounted to and moving along the rail (104), the car device (105) including: an electric motor (“motorized,” ¶ 50) configured for providing motive force to the car device (¶ 50); and a rechargeable energy storage device configured for providing electrical energy to the electric motor (“target trolley is battery operated, and charges at the charging station through contacts 113a, b,” ¶ 51); and a lane controller charging station (charging station 109) connected to the rail (104) and including a charging node (contact 113b, Fig. 2) configured for charging the rechargeable energy storage device when the car device (105) abuts the lane controller charging station (¶ 51). Ghani does not explicitly teach a metal material of the rail, a plurality of traction wheels driven by the motor, and a charging transmitter as the charging node for wirelessly charging the rechargeable energy storage device in spite of contaminants in air and on surfaces around the station. However, with respect to the metal material of the rail, Billington teaches that metal was known in the art of target systems to be the preferred material for such rails (“rail 18 may be made from steel or more preferably stainless steel,” ¶ 31). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select metal as taught by Billington for the material of Ghani’s rail, in order to ensure that the rail is functional and durable. With respect to the traction wheels, Hinton teaches a similar smart rail target (automated target manipulation system 500, Figs. 7-8; ¶¶ 40, 44) comprising a car device (carriage 504) configured for being mounted to and moving along a rail (502), the car device (504) including a plurality of traction wheels (516) configured for moving the car device (504) along the rail (504), and an electric motor (518) configured for providing motive force to the traction wheels (“the motor 518 could drive the wheels 516, thereby moving the carriage 504 along the track 502,” ¶ 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 modify the invention of Ghani to include traction wheels driven by the electric motor, as taught by Hinton, in order to accomplish the movement of the motorized car device along the rail as intended by Ghani. With respect to the wireless charging transmitter, Wikipedia teaches that inductive charging, including a charging station (“induction chargers,” pg. 1, second paragraph) with a charging transmitter (“induction coil,” id.) for wireless charging was a known solution for charging a rechargeable energy storage device (“battery,” id.), and has the advantage of a providing protected connections with “no corrosion when the electronics are enclosed” (pg. 2, Advantages, first bullet). The wireless inductive charging terminal thus described is understood to be inherently capable of charging the battery in spite of contaminants in air and on surfaces around the charging station. One of ordinary skill in the art would have recognized that this inherent advantage of wireless inductive charging terminals would be helpful in the context of a shooting range where airborne contaminants are common. Therefore, 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 invention of Ghani by replacing the contact charging node of Ghani with a wireless inductive charging transmitter for wireless charging as taught by Wikipedia, which is configured for wirelessly charging the rechargeable energy storage device in spite of contaminants in air and on surfaces around the station, in order to provide protected connections to improve reliability and durability of the charging node. Regarding claim 2, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 1. Wikipedia teaches the charging transmitter includes a first metal coil configured for creating a magnetic field (pg. 2, second paragraph). Wikipedia further teaches the device to be charged includes a charging portion including a second metal coil configured for using the magnetic field to create an electric current useful for recharging the rechargeable energy storage device (id.). When modifying the charging station of Ghani to use inductive charging as taught by Wikipedia, as discussed above, it would have been obvious to one of ordinary skill in the art to also modify the car device to include a charging portion with a second metal coil as taught by Wikipedia, in order to provide the protected connections discussed above. Regarding claim 3, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 1. Ghani further teaches the lane controller charging station (109, Fig. 2) further includes a mechanical stop (i.e., the rear wall of the charging station 109) for providing a proper location for the car device to stop to be recharged (see Fig. 2, the rear wall of the charging station 109 understood to abut the forward end of the car device when the car device is at the proper location for recharging). Regarding claim 4, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 1. Ghani further discloses a mounting feature (mounting clip 108, Fig. 1, ¶ 49) configured for suspending a shooting range target (103). Ghani does not teach that the mounting feature is configured for controlling rotation of the target. However, Hinton further teaches a mounting feature (rotary target support 506, Fig. 8) configured for suspending a shooting range target and controlling rotation of the shooting range target (¶ 41). Hinton teaches that rotation of the target advantageously permits rotation between firing and non-firing positions, or between “shoot” and “don’t shoot” faces of the target (¶¶ 41-42). Therefore, 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 invention of Ghani by configuring the mounting feature to control rotation of the target, as taught by Hinton, in order to enhance training sessions by providing practice in reacting to the sudden appearance of the target and distinguishing between friend or foe scenarios (Hinton, ¶ 42). Regarding claim 6, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 1. Ghani does not explicitly teach that the car device includes a computerized car device controller. However, Billington further teaches a car device (target carrier 12) including a computerized car device controller controlling operations of the car device (“a translation motor and motion controller to control the motion of … the target carrier 12 … located in the target carrier 12,” ¶ 44). Billington teaches that the controller is useful for adjusting the shooting distance between the car device and the user (¶¶ 6, 54). Therefore, 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 invention of Ghani by providing the car device with a computerized car device controller as taught by Billington, in order to facilitate adjustment of the shooting distance. Regarding claim 7, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 6. Billington further teaches the computerized car device controller is in wireless communication with other system components (¶ 54). Therefore, when modifying Ghani to include a computerized car device controller as taught by Billington as discussed above, it would have been obvious to one of ordinary skill in the art to configure the computerized car device controller to be in wireless communication with the lane controller charging station, e.g., to facilitate efficient battery management.1 Regarding claim 10, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 1. Ghani teaches the lane controller charging station further includes a lane indicator facia (overhead game display 110, Fig. 1) comprising a computerized display (¶¶ 44, 61). Regarding claim 11, Ghani discloses a system for a smart rail target (Figs. 1-4; ¶ 50) comprising: a rail (104); a car device (motorized target trolley 105) configured for being mounted to and moving along the rail (104), the car device (105) including: an electric motor (“motorized,” ¶ 50) configured for providing motive force to the car device (¶ 50); a rechargeable energy storage device configured for providing electrical energy to the electric motor (“target trolley is battery operated, and charges at the charging station through contacts 113a, b,” ¶ 51); and a mounting feature (mounting clip 108, Fig. 1, ¶ 49) configured for suspending a shooting range target (103); a lane controller charging station (charging station 109) connected to the rail (104) and including a charging node (contact 113b, Fig. 2) configured for charging the rechargeable energy storage device when the car device (105) abuts the lane controller charging station (¶ 51); a shooting stall (players’ stand 101, Figs. 1-2) configured for a user to occupy during operation of a computerized range simulation (¶ 47); and a computerized control panel (“keyboard (or a dedicated control box)” and “setup screen,” ¶ 47) disposed upon the shooting stall (101) and configured for enabling the user to control the operation of the computerized range simulation (including selecting “certain game parameters such as the target type, target size, target distance, number of players per game, the ammunition type, and the number of shots per player,” ¶ 47). Ghani does not explicitly teach a metal material of the rail, a plurality of traction wheels driven by the motor, a rotating function of the mounting feature, a computerized car device controller configured as part of the car device, and a charging transmitter as the charging node for wirelessly charging the rechargeable energy storage device in spite of contaminants in air and on surfaces around the station. However, with respect to the metal material of the rail and the computerized car device controller, Billington teaches a similar system for a smart rail target (Fig. 1) comprising a metal rail (“rail 18 may be made from steel or more preferably stainless steel,” ¶ 31) and a car device (target carrier 12) including a computerized car device controller controlling operations of the car device (“a translation motor and motion controller to control the motion of … the target carrier 12 … located in the target carrier 12,” ¶ 44), which is useful for adjusting the shooting distance between the car device and the user (¶¶ 6, 54). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select metal as taught by Billington for the material of Ghani’s rail, in order to ensure that the rail is functional and durable; and by providing the car device with a computerized car device controller as taught by Billington, in order to facilitate adjustment of the shooting distance. With respect to the traction wheels of the car device and the rotating function of the mounting feature, Hinton teaches a similar smart rail target (automated target manipulation system 500, Figs. 7-8; ¶¶ 40, 44) comprising a car device (carriage 504) configured for being mounted to and moving along a rail (502), the car device (504) including a plurality of traction wheels (516) configured for moving the car device (504) along the rail (504); an electric motor (518) configured for providing motive force to the traction wheels (“the motor 518 could drive the wheels 516, thereby moving the carriage 504 along the track 502,” ¶ 44); and a mounting feature (rotary target support 506, Fig. 8) configured for suspending a shooting range target and controlling rotation of the shooting range target (¶¶ 41-42). Therefore, 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 invention of Ghani by including traction wheels driven by the electric motor, as taught by Hinton, in order to accomplish the movement of the motorized car device along the rail as intended by Ghani; and by configuring the mounting feature to control rotation of the target, as also taught by Hinton, in order to enhance training sessions by providing practice in reacting to the sudden appearance of the target and distinguishing between friend or foe scenarios (Hinton, ¶ 42). With respect to the wireless charging transmitter, Wikipedia teaches that inductive charging, including a charging station (“induction chargers,” pg. 1, second paragraph) with a charging transmitter (“induction coil,” id.) for wireless charging was a known solution for charging a rechargeable energy storage device (“battery,” id.), and has the advantage of a providing protected connections with “no corrosion when the electronics are enclosed” (pg. 2, Advantages, first bullet). The wireless inductive charging terminal thus described is understood to be inherently capable of charging the battery in spite of contaminants in air and on surfaces around the charging station. One of ordinary skill in the art would have recognized that this inherent advantage of wireless inductive charging terminals would be helpful in the context of a shooting range where airborne contaminants are common. Therefore, 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 invention of Ghani by replacing the contact charging node of Ghani with a wireless inductive charging transmitter for wireless charging as taught by Wikipedia, which is configured for wirelessly charging the rechargeable energy storage device in spite of contaminants in air and on surfaces around the station, in order to provide protected connections to improve reliability and durability of the charging node. Regarding claim 12, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 11. Wikipedia teaches the charging transmitter includes a first metal coil configured for creating a magnetic field (pg. 2, second paragraph). Wikipedia further teaches the device to be charged includes a charging portion including a second metal coil configured for using the magnetic field to create an electric current useful for recharging the rechargeable energy storage device (id.). When modifying the charging station of Ghani to use inductive charging as taught by Wikipedia, as discussed above, it would have been obvious to one of ordinary skill in the art to also modify the car device to include a charging portion with a second metal coil as taught by Wikipedia, in order to provide the protected connections as discussed above. Regarding claim 13, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 11. Billington further teaches the computerized car device controller is in wireless communication with other system components (¶ 54). Therefore, when modifying Ghani to include a computerized car device controller as taught by Billington as discussed above, it would have been obvious to one of ordinary skill in the art to configure the computerized car device controller to be in wireless communication with the lane controller charging station, e.g., to facilitate efficient battery management. Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Ghani, Billington, Hinton, and Wikipedia, in further view of Knight (US Patent No. RE30,013, hereinafter Knight). Regarding claim 5, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 1. Ghani does not teach first and second electric motors for respectively providing first and second motive force to first and second portions of the traction wheels. However, Knight teaches that it was known in the target art to provide first and second electric motors configured for respectively providing first and second motive forces to first and second portions of a plurality of traction wheels (“driven wheels 25 and 27 … are driven by two two-speed electric motors 29,” col. 4:26-31). Therefore, 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 invention of Ghani by providing first and second electric motors as taught by Knight for respectively providing first and second motive forces to first and second portions of the plurality of traction wheels, as suggested by Knight, since this involves only the simple substitution of one known configuration of wheels and motors for driving a target car device for another known configuration of wheels and motors for driving a target car device, to yield predictable results. Claims 8-9 and 14-17 are rejected under 35 U.S.C. 103 as being unpatentable over Ghani, Billington, Hinton, and Wikipedia, in further view of Tejada et al. (US Patent No. 9,360,283, hereinafter Tejada). Regarding claims 8 and 14, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claims 6 and 13, respectively. Ghani, Billington, Hinton, and Wikipedia do not explicitly teach a computerized rangemaster controller in wireless communication with the computerized car device controller. However, Tejada teaches a similar smart rail target system (Fig. 2) comprising a car device (track module 68) with a computerized car device controller (processor 38, Fig. 5, operably connected to motor controller within track module 68, col. 6:7-34) and a computerized rangemaster controller (range master’s display 80, Figs. 8 and 11) in wireless communication (col. 4:20-30) with the computerized car device controller (38) and providing computerized control to a local rangemaster (“the range safety officer will select a drill using range master display 80 and server 50 will coordinate the drill sequence,” col. 4:41-43; see also col. 11:32-65). Therefore, 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 invention of Ghani to include a computerized rangemaster controller as taught by Tejada in wireless communication with the computerized car device controller, in order to facilitate selection of drills and monitoring of progress by a range safety officer. Regarding claim 9, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 6. Ghani, Billington, Hinton, and Wikipedia do not teach a remote computerized server device in wireless communication with the computerized car device controller and providing access to a plurality of computerized range simulations. However, Tejada further teaches a remote computerized server device (server 50, Fig. 8; col. 4:20-30) in wireless communication with the computerized car device controller (38) and providing access to a plurality of candidate computerized range simulations (“server 50 is responsible for coordinating a predefined drill by sending commands to target modules 30,” col. 8:51-53; see col. 8:51-9:4; see also Fig. 8, showing server 50 including database 61 with drill repository 58). Tejada teaches that this arrangement facilitates the selection of a drill from “a selectable list of available drills” (col. 11:59). Therefore, 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 invention of Ghani to include a remote computerized server device as taught by Tejada in wireless communication with the computerized car device controller and providing access to a plurality of candidate computerized range simulations, as also taught by Tejada, in order to facilitate selection of drills from a list of available drills. Regarding claim 15, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 14. Tejada further teaches the computerized rangemaster controller includes programming to provide shot scoring to the user (“may optionally show hit locations on each target,” col. 11:40-42; and “a means to print or email a report showing drill results by shooter together with consolidated scoring information such as average score, low score, high score …” col. 11:59-62). Regarding claim 16, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 14. The limitation “a virtual instructor feature” is interpreted in view of Applicant’s specification to mean “visual text” or “audible voice instructing through specified courses of fire” (¶ 72). Ghani does not explicitly teach such a virtual instructor feature. However, Hinton further teaches that the system includes “display of instructions” (¶ 46), including “projecting and displaying stationary and moving images, for example instructions” (¶ 47). The instructions displayed by the system to the shooter are considered to be “a virtual instructor feature” as claimed. 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 invention of Ghani by programming the computerized rangemaster controller to provide a virtual instructor feature as taught by Hinton to the user, in order to instruct the user with respect to a training scenario. Regarding claim 17, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 14. Tejada further teaches a remote computerized server device (server 50, Fig. 8; col. 4:20-30) in wireless communication with the computerized car device controller (38) and providing access to a plurality of candidate computerized range simulations (“server 50 is responsible for coordinating a predefined drill by sending commands to target modules 30,” col. 8:51-53; see col. 8:51-9:4; see also Fig. 8, showing server 50 including database 61 with drill repository 58). Tejada teaches that this arrangement permits the range safety officer to choose a drill from “a selectable list of available drills” (col. 11:59). Therefore, when modifying Ghani to include a computerized rangemaster controller as taught by Tejada, it would have been obvious to one of ordinary skill in the art to also include a remote computerized server device as taught by Tejada in wireless communication with the computerized car device controller and providing access to a plurality of candidate computerized range simulations, as also taught by Tejada, in order to facilitate selection of drills by the local rangemaster. Claims 18 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Ghani, Billington and Wikipedia. Regarding claim 18, Ghani discloses a method for a smart rail target (Figs. 1-4; ¶ 50), the method comprising: within a lane of a gun range, suspending a rail (104); mounting a car device (motorized target trolley 105) to the rail (104), wherein the car device (105) includes a rechargeable energy storage device (“target trolley is battery operated, and charges at the charging station through contacts 113a, b,” ¶ 51) and is configured for moving forward and backward along the rail (104) and is further configured for suspending a shooting range target (103); mounting a lane controller charging station (charging station 109) to a first end of the rail (104), wherein the charging station includes a charging node (contact 113b, Fig. 2) configured for wirelessly charging the car device (105); and when the rechargeable energy storage device has a low state of charge, moving the car device (105) to the first end of the rail (104) and wirelessly charging the car device (¶ 51). Ghani does not explicitly teach a metal material of the rail and a charging transmitter as the charging node. However, with respect to the metal material of the rail, Billington teaches that metal was known in the art of target systems to be the preferred material for such rails (“rail 18 may be made from steel or more preferably stainless steel,” ¶ 31). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select metal as taught by Billington for the material of Ghani’s rail, in order to ensure that the rail is functional and durable. With respect to the wireless charging transmitter, Wikipedia teaches that inductive charging, including a charging station (“induction chargers,” pg. 1, second paragraph) with a charging transmitter (“induction coil,” id.) for wireless charging was a known solution for charging a rechargeable energy storage device (“battery,” id.), and has the advantage of a providing protected connections with “no corrosion when the electronics are enclosed” (pg. 2, Advantages, first bullet). The wireless inductive charging terminal thus described is understood to be inherently capable of charging the battery in spite of contaminants in air and on surfaces around the charging station. One of ordinary skill in the art would have recognized that this inherent advantage of wireless inductive charging terminals would be helpful in the context of a shooting range where airborne contaminants are common. Therefore, 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 invention of Ghani by replacing the contact charging node of Ghani with a wireless inductive charging transmitter for wireless charging as taught by Wikipedia, which is configured for wirelessly charging the rechargeable energy storage device in spite of contaminants in air and on surfaces around the station, in order to provide protected connections to improve reliability and durability of the charging node. Regarding claim 19, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 18. Ghani further discloses, within a computerized processor (game computer 1004, Fig. 10), operating a computerized range simulation (based on selected game parameters including “target distance,” ¶ 47) configured for selectively controlling the car device (to move the trolley 105 to the user-selected target distance, ¶ 50). Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Ghani, Billington and Wikipedia, in further view of Hinton. Regarding claim 20, the modified Ghani teaches the claimed invention substantially as claimed, as set forth above for claim 19. Ghani further discloses that selectively controlling the car device (105) includes controlling movement of the car device along the metal rail (¶ 50). Ghani does not explicitly disclose controlling rotation of the shooting range target. However, Hinton teaches a similar method for a smart rail target (automated target manipulation system 500, Figs. 7-8; ¶¶ 40, 44) comprising a car device (carriage 504) configured for being mounted to and moving along a rail (502), including a step of controlling rotation of a shooting range target (¶ 41). Hinton teaches that rotation of the target advantageously permits rotation between firing and non-firing positions, or between “shoot” and “don’t shoot” faces of the target (¶¶ 41-42). Therefore, 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 invention of Ghani by controlling rotation of the target, as taught by Hinton, in order to enhance training sessions by providing practice in reacting to the sudden appearance of the target and distinguishing between friend or foe scenarios (Hinton, ¶ 42). Response to Arguments Applicant's arguments filed November 20, 2025, have been fully considered but they are not persuasive. Applicant argues that none of the references, considered individually, teaches use of a wireless charging transmitter in the context of shooting range equipment. This argument is not persuasive because one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). In response to Applicant’s argument that the Wikipedia article on inductive charging is non-analogous art, it has been held that a prior art reference must either be in the field of the inventor’s endeavor or, if not, then be reasonably pertinent to the particular problem with which the inventor was concerned, in order to be relied upon as a basis for rejection of the claimed invention. See In re Oetiker, 977 F.2d 1443, 24 USPQ2d 1443 (Fed. Cir. 1992). In this case, the Wikipedia article on inductive charging is reasonably pertinent to the battery charging problem confronting the inventor (see, e.g., Applicant’s specification at ¶43). One of ordinary skill in the art, seeking to improve upon the battery charging capabilities of a smart rail target, would reasonably have consulted common reference materials on the subject of battery charging, including the Wikipedia article on inductive charging. In response to Applicant’s remarks regarding secondary considerations such as commercial success and long-felt but unsolved need, Applicant has provided no objective evidence in the present record to support the assertion of commercial success or long-felt but unresolved need. “An applicant who is asserting commercial success to support its contention of nonobviousness bears the burden of proof in establishing commercial success.” MPEP § 716.03. Likewise, “[e]stablishing long-felt need requires objective evidence that an art recognized problem existed in the art for a long period of time without solution.” See MPEP § 716.04. As explained in MPEP § 2145, “arguments presented by applicant cannot take the place of factually supported objective evidence. See, e.g., In re Schulze, 346 F.2d 600, 602, 145 USPQ 716, 718 (CCPA 1965); In re De Blauwe, 736 F.2d 699, 705, 222 USPQ 191, 196 (Fed. Cir. 1984).” Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). 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 Laura L. Davison whose telephone number is (571)270-0189. The examiner can normally be reached Monday - Friday, 8:00 a.m. - 4:00 p.m. ET. 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, Eileen Lillis can be reached at (571)272-6928. 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. /Laura Davison/Primary Examiner, Art Unit 3993 1 See Wikipedia, “Battery management system,” cited here as evidence of the state of the art.
Read full office action

Prosecution Timeline

Jan 17, 2023
Application Filed
Aug 20, 2025
Non-Final Rejection — §103
Nov 20, 2025
Response Filed
Dec 22, 2025
Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12599823
Portable Disc Sport Training Apparatus
2y 5m to grant Granted Apr 14, 2026
Patent RE50845
ELECTRIC MOTOR DEVICE FOR PEDAL ASSIST BICYCLES
2y 5m to grant Granted Mar 31, 2026
Patent RE50727
FOOD CUTTING DEVICE
2y 5m to grant Granted Jan 06, 2026
Patent RE50701
Table Tennis Top And Material
2y 5m to grant Granted Dec 16, 2025
Patent RE50673
ACTUATOR FOR SHIFT-BY-WIRE SYSTEM
2y 5m to grant Granted Nov 25, 2025
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
32%
Grant Probability
68%
With Interview (+35.4%)
2y 4m
Median Time to Grant
Moderate
PTA Risk
Based on 587 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

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

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

Free tier: 3 strategy analyses per month