Prosecution Insights
Last updated: April 19, 2026
Application No. 18/174,146

HOROLOGICAL MECHANISM FOR ACTUATING A FLEXIBLE HAND

Non-Final OA §103§112
Filed
Feb 24, 2023
Examiner
HWANG, MATTHEW DANIEL
Art Unit
2831
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Montres Breguet S A
OA Round
3 (Non-Final)
83%
Grant Probability
Favorable
3-4
OA Rounds
3y 0m
To Grant
89%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allow Rate
98 granted / 118 resolved
+15.1% vs TC avg
Moderate +6% lift
Without
With
+6.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
47 currently pending
Career history
165
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
41.0%
+1.0% vs TC avg
§102
18.2%
-21.8% vs TC avg
§112
33.4%
-6.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 118 resolved cases

Office Action

§103 §112
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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 2026-01-08 has been entered. Claim Interpretation Claim 1 recites that a hand will perform two “circular revolutions.” However, Figs. 11A-11B of the specification depicting these revolutions (244, 246) show that the paths of the revolutions share a center but also intersect. Circles of different radii cannot share a center and intersect, so at least one of the revolutions is not a circle. The term “circular” is therefore interpreted loosely to include shapes like a circle (see 112(b) rejection below). Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-18 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. The term “circular” in claim 1 is a relative term which renders the claim indefinite. The term “circular” is not defined by the claim, the specification does not provide a standard for ascertaining the requisite degree, and one of ordinary skill in the art would not be reasonably apprised of the scope of the invention. Figs. 11A-11B depict the two successive revolutions (244, 246) sharing a center but also intersecting at an edge. Circles of different radii cannot share a center and also intersect, so “circular” in claim 1 is understood to not strictly, literally, mean “circular.” As a result, the term is indefinite because different persons of ordinary skill in the art may have conflicting opinions on whether a shape is close enough to be considered “circular” or not. Claim 18 recites “the angular rotation equal to one half” in lines 11-12 without antecedent basis. The limitation has been read as -a second angular rotation equal to one half-. Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1 and 3-5 are rejected under 35 U.S.C. 103 as being obvious over Stranczl (US 2015/0109891). Regarding claim 1, Stranczl teaches in one embodiment (Figs. 2B-2C, 4, 7B) a flexible hand actuation mechanism (11) to which a disk (12) of a horological movement ([0004]) applies a first angular rotation (Fig. 1) to drive a flexible hand, the flexible hand actuation mechanism (11) comprising a first cannon (2) and a second cannon (4) connected to a point (6) of the flexible hand via flexible arms (5) of a flexible hand (1), the first and second cannons being distant from each other when the flexible hand is in a non-stressed free state (Fig. 2A, [0021]), an operating position wherein the flexible hand has a defined shape and length being a stressed position (Figs. 2B-2C) wherein the first cannon and the second cannon are coaxial about an exit axis (D), the first cannon being fitted with a first defined prestress angle, and the second cannon being fitted with a second defined prestress angle of opposite direction to the first defined prestress angle of the first cannon (Fig. 1 shows the cannons angled oppositely with respect to the horizon, while Figs. 2B-2C show the cannons angled oppositely with respect to the vertical), the actuation mechanism being arranged to actuate the flexible hand such that the flexible hand changes shape and length by varying the angular position of the second cannon with respect to the first cannon by pivoting about the exit axis ([0022]-[0023]), each of the flexible arms of the flexible hand performing the angular rotation ([0063]: “2 revolutions”) applied by the disk (12) of the horological movement to the actuation mechanism (11), the angular rotation applied by the disk of the horological movement being modulated by an additional angle ([0063]: “0.2 revolutions”) by the actuation mechanism, said additional angle, applied to the flexible arms of the flexible hand in opposite directions ([0068]: the additional angle (alpha) widens/narrows the shape formed by the flexible arms), determining the change of shape and length of the flexible hand over two immediately successive circular revolutions ([Fig. 7B, 0019]: “trajectory over two revolutions,” and [0071]: “the trajectory of tip 6…on…concentric circles”) such that the point of said flexible hand describes two mutually different paths (see the paths of 6 depicted in Figs. 1 and 7), the shape and length variation (Figs. 2B-2C) being performed for a rotation by an angle applied to an entry of said actuation mechanism by a geartrain of the horological movement. Following the path drawn in Fig. 1, the point 6 of 1 varies by ΔL over 2 revolutions as the point moves from a longer length (Fig. 2B) to a shorter length (Fig. 2C). Stranczl discloses in another embodiment (Fig. 9) the actuation mechanism further comprising a cam follower finger (7, [0054]: “stylus”) which contacts a profile of a cam (14, [0054]) to determine the change of shape and length of the flexible hand [0054], the flexible hand performing the two successive circular revolutions, which are non-identical (Fig. 7B and [0071]), while the cam follower finger travels along the profile of the cam along the entire profile thereof ([0054]: “a stylus 7 arranged to follow a cam path”). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have combined the finger and cam from Stranczl’s Fig. 9 embodiment with the mechanism of Stranczl’s Fig. 4 embodiment. One of ordinary skill in the art would have been motivated to make this combination because a cam would help guide the hand and prevent the hand from accidentally deviating from its intended trajectory ([0054]). Regarding claim 3, Stranczl teaches the actuation mechanism according to claim 1, wherein the disk (12, Fig. 4) of the horological movement which applies the angular rotation to the actuation mechanism must perform two complete revolutions ([0063]: “2 revolutions”) so that the cam follower finger travels along the entire profile of the cam and the point of the flexible hand describes a path corresponding to two non-identical complete revolutions (Fig. 9 and [0054]). Regarding claims 4-5, Stranczl teaches (Fig. 9) the actuation mechanism according to claims 1 and 3, respectively, wherein the cam follower finger (7) is held against the profile of the cam (14) thanks to a mechanical tension induced by the stressed fitting of the flexible hand (1). Fig. 9 shows that the hand comprising the stylus is tensioned against the cam. See also [0033] and [0054]. Claims 6-14 and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Stranczl in view of Bifrare (US 2021/0011433) Regarding claims 6-9, Stranczl discloses the actuation mechanism of claims 1 and 3-5, respectively. Stranczl does not show the mechanism comprising at least one rotary planetary wheel-holding frame which is driven in rotation by the angular rotation of the disk of the horological movement and which bears the cam follower finger. Bifrare teaches (Figs. 2 and 7) a flexible hand actuation mechanism (title) comprising a planetary wheel-holding frame ([0014]) which is driven in rotation by a disk (92) of a horological movement (900) and which bears a cam follower finger ([0045]: “feeler”). The frame and the disk both revolve—they therefore perform/apply angular rotations. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have combined Bifrare’s planetary wheel-holding frame with Stranczl’s mechanism. One of ordinary skill in the art would have been motivated to make this combination to “break up some of the monotony of the displays” ([0007] of Bifrare). Regarding claims 10-13, Stranczl in view of Bifrare discloses the mechanism according to claims 6-9, respectively, wherein the cam is fixed ([0023] of Bifrare). Regarding claim 14, Stranczl in view of Bifrare discloses (Bifrare, Fig. 2) the actuation mechanism according to claim 10, wherein the planetary wheel-holding frame bears a first solar wheel set ([0047] of Bifrare: “input differential”) and a second solar wheel set ([0048]: “output differential”) arranged coaxially (912, 914 are coaxial) with respect to each other, the first solar wheel set consisting of a first solar pinion ([0047]: “sun pinion of the input differential”) and a first solar wheel (solar wheel sets by definition have a solar wheel), and the second solar wheel set consisting of a second solar pinion ([0049]: “sun pinion of the output differential”) and a second solar wheel (solar wheel sets by definition have a solar wheel), the first solar pinion meshing with a planetary wheel borne ([0047]: “a first planet of the input differential”) by the planetary wheel-holding frame and which bears the cam follower finger ([0045]: planets…which each have an off-center wheeler”), said planetary wheel meshing with an intermediate wheel ([0047]: “second toothing 21”) which itself meshes with the second solar pinion (Fig. 2 shows 21 meshing with 41, which [0047] discloses as the second solar pinion), the actuation mechanism also comprising a first cannon-pinion (2) and a second cannon-pinion (4) arranged coaxially with respect to each other, the first cannon (2) of the flexible hand (1) being fastened to the first cannon-pinion, and the second cannon (4) of the flexible hand (1) being fastened to the second cannon-pinion. Regarding claim 17, Stranczl in view of Bifrare discloses the mechanism according to claims 6, wherein the cam is mobile ([0044] of Bifrare). Response to Arguments Applicant's arguments filed 2025-12-17 have been fully considered but they are not persuasive. Applicant argues that [0051] of Stranczl discloses replacing first or second pipes with a cam, which would prevent Stranczl from meeting the limitation of first and second cannons. However, the cam of [0051] is different from the cam shown in Fig. 9, as discussed in the rejection above. Fig. 9 of Stranczl shows a cam (14) as well as the original two cannons (2, 4). Applicant argues that the cam in Fig. 9 discloses only making successive identical revolutions. However, Stranczl’s teaching of a cam for a finger of the flexible hand is non-limiting ([0054] says that the embodiment of Fig. 9 is simply an “example” and that any stressing means 12 may “include” the cam). As such, one of ordinary skill in the art would have found it obvious to have combined the cam of Fig. 9 with the successive non-identical revolutions of Stranczl’s other embodiment(s) by including the cam with the stressing means of Fig. 4 to guide the hand into performing the trajectory disclosed in Fig. 7B. Allowable Subject Matter Claims 15-16 and 18 would be allowable if rewritten to overcome the rejection(s) under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), 2nd paragraph, set forth in this Office action and to include all of the limitations of the base claim and any intervening claims. The following is a statement of reasons for the indication of allowable subject matter: regarding claim 15, the prior art does not show or suggest a second solar wheel meshing with a first cannon-pinion rotating by a second solar angle equal to θ 1 - ϕ θ 1 2 * 2 , and a first solar wheel meshing with a second cannon-pinion rotating by a first solar wheel angle equal to θ 1 + ϕ θ 1 2 * 2 , with θ 1 being an angular rotation applied by a disk of a horological movement and ϕ ( θ 1 2 ) being an additional angle applied by a flexible hand actuation mechanism, in combination with the other limitations. Regarding claim 16, the prior art does not show or suggest a solar disk driving a second cannon-pinion rotating by a second cannon-pinion angle of θ 1 - ϕ θ 1 2 * 2 and the second cannon-pinion driving a first cannon-pinion by a first cannon-pinion angle of θ 1 + ϕ θ 1 2 * 2 , with θ 1 being an angular rotation applied by a disk of a horological movement and ϕ ( θ 1 2 ) being an additional angle applied by a flexible hand actuation mechanism, in combination with the other limitations. Regarding claim 18, the prior art does not show or suggest a rotating cam rotating by a second angular rotation equal to one half of a first angular rotation performed by a planetary wheel-holding frame, and a second planetary wheel consequently rotating with the frame by the first angular rotation about an exit axis while rotating about itself by a rotating angle of rotation determined so as to modulate rotation of two flexible arms of a flexible hand by an additional angle so that the flexible hand changes length and shape, in combination with the other limitations. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Matthew Hwang whose telephone number is (571)272-1191. The examiner can normally be reached M-F from 10-6 PM PT. 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, Renee Luebke can be reached on 571-272-2009. 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 DANIEL HWANG/Examiner, Art Unit 2833 /renee s luebke/Supervisory Patent Examiner Art Unit 2833
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Prosecution Timeline

Feb 24, 2023
Application Filed
Apr 14, 2023
Response after Non-Final Action
Jun 24, 2025
Non-Final Rejection — §103, §112
Aug 27, 2025
Response Filed
Sep 12, 2025
Final Rejection — §103, §112
Dec 17, 2025
Response after Non-Final Action
Jan 08, 2026
Request for Continued Examination
Jan 23, 2026
Response after Non-Final Action
Mar 03, 2026
Non-Final Rejection — §103, §112 (current)

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

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Prosecution Projections

3-4
Expected OA Rounds
83%
Grant Probability
89%
With Interview (+6.1%)
3y 0m
Median Time to Grant
High
PTA Risk
Based on 118 resolved cases by this examiner. Grant probability derived from career allow rate.

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