Prosecution Insights
Last updated: May 29, 2026
Application No. 18/199,458

LIFT STEERING SYSTEMS AND METHODS

Non-Final OA §103
Filed
May 19, 2023
Priority
Apr 05, 2019 — provisional 62/830,176 +1 more
Examiner
MCFARLAND, KATHLEEN MAVOURNEEN
Art Unit
3635
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Oshkosh Corporation
OA Round
2 (Non-Final)
59%
Grant Probability
Moderate
2-3
OA Rounds
6m
Est. Remaining
73%
With Interview

Examiner Intelligence

Grants 59% of resolved cases
59%
Career Allowance Rate
86 granted / 145 resolved
+7.3% vs TC avg
Moderate +14% lift
Without
With
+13.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
22 currently pending
Career history
183
Total Applications
across all art units

Statute-Specific Performance

§103
90.7%
+50.7% vs TC avg
§102
4.8%
-35.2% vs TC avg
§112
3.5%
-36.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 145 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 . Acknowledgment is made of the amendment filed January 21, 2026. The application has been updated accordingly. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over Ahern et al. (2015/0246684) hereinafter Ahern, in view of Rushton et al. (2020/0277175) hereinafter Rushton. Ahern discloses: Claim 1: A lift device, comprising: a base (Fig. 1; 116) including: a first wheel (Fig. 8; 808) and a second wheel (Fig. 8; 810) laterally spaced from the first wheel; and a third wheel (Fig. 8; 812) and a fourth wheel (Fig. 8; 814) laterally spaced from the third wheel, wherein the third wheel and the fourth wheel are both in a fixed steering orientation (Para. [0046]); a retractable lift mechanism (Fig. 1; 100) having a first end coupled to the base (Fig. 1; 116); a platform (Fig. 1; 113, Para. [0030]) coupled to and supported by a second end of the retractable lift mechanism (Fig. 1; 102, Para. [0030]); and a steering system (Fig. 2; 200) including: a first actuator (Fig. 7; 414 left) coupled to the first wheel and configured to independently control a steering direction of the first wheel (Para. [0046]); and a second actuator (Fig. 7; 414 right) coupled to the second wheel and configured to independently control a steering direction of the second wheel (Para. [0046]). Ahern fails to disclose an electric actuator. However, Rushton discloses an electric actuator (Fig. 1; 8, Para. [0054]). 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 lift device of Ahern to include the electric actuator, as taught by Rushton, with a reasonable expectation of success because it would provide a more precise and compact actuator. Claim 2: Ahern and Rushton disclose the lift device of claim 1, wherein the first electric actuator (Rushton - Fig. 1; 8, Para. [0054]) is coupled to a first end of a first tie rod (Ahern - Fig. 4; 442 via 200, depicted on the left in Fig. 7) and a second end of the first tie rod is coupled to a first flange (Ahern - Fig. 4; 408), and wherein the first flange is coupled to the first wheel (Ahern - Fig. 4; 105). Claim 3: Ahern and Rushton disclose the lift device of claim 2, wherein the second electric actuator (Rushton - Fig. 1; 8, Para. [0054]) is coupled to a first end of a second tie rod (Ahern - Fig. 4; 442 via 200, depicted on the right in Fig. 7) and a second end of the second tie rod is coupled to a second flange (Ahern - Fig. 4; 408), and wherein the second flange is coupled to the second wheel (Ahern - Fig. 4; 105). Claim 4: Ahern discloses the lift device of claim 3, wherein the first tie rod and the second tie rod both define an arcuate shape (Fig. 4; 442 is depicted as having an arcuate shape). Claim 5: Ahern discloses the lift device of claim 1, but fails to disclose wherein the retractable lift mechanism includes a linear actuator configured to transition the retractable lift mechanism between a stowed position and a deployed position. However, Rushton discloses a linear actuator (Fig. 1; 8, Para. [0054]). 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 lift device of Ahern to include the linear actuator, as taught by Rushton, with a reasonable expectation of success because it would provide a more precise and compact actuator. Claim 6: Ahern discloses the lift device of claim 5, wherein the retractable lift mechanism is a scissor lift mechanism (Fig. 4). Claim 7: Ahern discloses the lift device of claim 1, wherein a battery is mounted to the base and supplies electrical power to the first electric actuator and the second electric actuator (Para. [0027]). Claim 8: Ahern discloses a lift device, comprising: a base (Fig. 1; 116) including two front wheels (Fig. 8; 808, 810) and two rear wheels (Fig. 8; 812, 814), the two rear wheels being in a fixed orientation relative to the base (Para. [0046]), and the two front wheels being spaced from the two rear wheels in a longitudinal direction (Fig. 8; 808, 810 are spaced longitudinally from 812, 814); a retractable lift mechanism (Fig. 1; 100) having a first end coupled to the base (Fig. 1; 116); a platform (Fig. 1; 113, Para. [0030]) coupled to and supported by a second end of the retractable lift mechanism (Fig. 1; 102, Para. [0030]); and a steering system (Fig. 2; 200) including: a first actuator (Fig. 7; 414 left) coupled to a first front wheel of the two front wheels and configured to independently control a steering direction of the first front wheel (Para. [0046]); and a second actuator (Fig. 7; 414 right) coupled to a second front wheel of the two front wheels and configured to independently control a steering direction of the second front wheel (Para. [0046]), wherein the first actuator and the second actuator extend generally along the longitudinal direction (Fig. 4; 414 extends generally along the longitudinal direction). Ahern fails to disclose an electric actuator. However, Rushton discloses an electric actuator (Fig. 1; 8, Para. [0054]). 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 lift device of Ahern to include the electric actuator, as taught by Rushton, with a reasonable expectation of success because it would provide a more precise and compact actuator. Claim 9: Ahern and Rushton disclose the lift device of claim 8, wherein the first electric actuator (Rushton - Fig. 1; 8, Para. [0054]) is coupled to a first end of a first tie rod (Ahern - Fig. 4; 442 via 200, depicted on the left in Fig. 7) and a second end of the first tie rod is coupled to a first flange (Ahern - Fig. 4; 408), and wherein the first flange is coupled to the first front wheel (Ahern - Fig. 4; 105). Claim 10: Ahern and Rushton disclose the lift device of claim 9, wherein the second electric actuator (Rushton - Fig. 1; 8, Para. [0054]) is coupled to a first end of a second tie rod (Ahern - Fig. 4; 442 via 200, depicted on the right in Fig. 7) and a second end of the second tie rod is coupled to a second flange (Ahern - Fig. 4; 408), and wherein the second flange is coupled to the second front wheel (Ahern - Fig. 4; 105). Claim 11: Ahern discloses the lift device of claim 10, wherein the first tie rod and the second tie rod both define an arcuate shape (Fig. 4; 442 is depicted as having an arcuate shape). Claim 12: Ahern discloses the lift device of claim 8, but fails to disclose wherein the retractable lift mechanism includes a linear actuator configured to transition the retractable lift mechanism between a stowed position and a deployed position. However, Rushton discloses a linear actuator (Fig. 1; 8, Para. [0054]). 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 lift device of Ahern to include the linear actuator, as taught by Rushton, with a reasonable expectation of success because it would provide a more precise and compact actuator. Claim 13: Ahern discloses the lift device of claim 8, wherein the retractable lift mechanism is a scissor lift mechanism (Fig. 1; 100). Claim 14: Ahern discloses the lift device of claim 8, wherein a battery is mounted to the base and supplies electrical power to the first electric actuator and the second electric actuator (Para. [0027]). Claim 15: Ahern discloses a lift device, comprising: a base including two steerable wheels (Fig. 8; 808, 810, Para. [0046]) and two fixed wheels held in a forward-aligned orientation (Fig. 8; 812, 814, Para. [0046]); a retractable lift mechanism (Fig. 1; 100) having a first end coupled to the base (Fig. 1; 116); a platform (Fig. 1; 113, Para. [0030]) coupled to and supported by a second end of the retractable lift mechanism (Fig. 1; 102, Para. [0030]); and a steering system (Fig. 2; 200) including: a first independent steering subsystem including a first actuator (Fig. 7; 414 left) coupled to a first wheel of the two steerable wheels and configured to control a steering direction of the first wheel (Para. [0046]); and a second independent steering subsystem including a second actuator (Fig. 7; 414 right) coupled to a second wheel of the two steerable wheels and configured to control a steering direction of the second wheel (Para. [0046]). Ahern fails to disclose an electric linear actuator. However, Rushton discloses electric linear actuators (Fig. 1; 8, Para. [0054]). 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 lift device of Ahern to replace actuators with electric linear actuator, as taught by Rushton, with a reasonable expectation of success because it would provide a more precise and compact actuator. Claim 16: Ahern and Rushton disclose the lift device of claim 15, wherein the first electric linear actuator (Rushton - Fig. 1; 8, Para. [0054]) is coupled to a first end of a first tie rod (Ahern - Fig. 4; 442 via 200, depicted on the left in Fig. 7) and a second end of the first tie rod is coupled to a first flange (Ahern - Fig. 4; 408), and wherein the first flange is coupled to the first wheel (Ahern - Fig. 4; 105). Claim 17: Ahern and Rushton disclose the lift device of claim 16, wherein the second electric linear actuator (Rushton - Fig. 1; 8, Para. [0054]) is coupled to a first end of a second tie rod (Ahern - Fig. 4; 442 via 200, depicted on the right in Fig. 7) and a second end of the second tie rod is coupled to a second flange (Ahern - Fig. 4; 408), and wherein the second flange is coupled to the second wheel (Ahern - Fig. 4; 105). Claim 18: Ahern and Rushton disclose the lift device of claim 15, wherein the retractable lift mechanism includes a third electric linear actuator configured to transition the retractable lift mechanism between a stowed position and a deployed position (Rushton - Fig. 1; 8, Para. [0054]). Claim 19: Ahern discloses the lift device of claim 15, wherein the retractable lift mechanism is a scissor lift mechanism (Fig. 1; 100). Claim 20: Ahern and Rushton disclose the lift device of claim 15, wherein a battery is mounted to the base and supplies electrical power (Ahern - Para. [0027]) to the first linear actuator and the second electric linear actuator (Rushton - Fig. 1; 8, Para. [0054]). Response to Arguments Applicant’s arguments with respect to claims 1-20 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Kathleen M. McFarland whose telephone number is (571)272-9139. The examiner can normally be reached Monday-Friday 8:00am-4:00pm. 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, Brian Mattei can be reached at (571) 270-3238. 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. /Kathleen M. McFarland/Examiner, Art Unit 3635 Kathleen M. McFarland Examiner Art Unit 3635 /BRIAN D MATTEI/Supervisory Patent Examiner, Art Unit 3635
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Prosecution Timeline

May 19, 2023
Application Filed
Oct 23, 2025
Non-Final Rejection mailed — §103
Jan 21, 2026
Response Filed
May 07, 2026
Non-Final Rejection mailed — §103 (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

2-3
Expected OA Rounds
59%
Grant Probability
73%
With Interview (+13.6%)
3y 6m (~6m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 145 resolved cases by this examiner. Grant probability derived from career allowance rate.

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