DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application is being examined under the AIA first to invent provisions. 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 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.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 2/17/2026 has been entered.
Claim Rejections - 35 USC § 103
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claim(s) 16, 18, 19, 20, 25, 27, 28, 29, and 30 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kawaguchi (U.S. P.G. Publication No. 2020/0269900 A1; “Kawaguchi”) in view of Aktas et al. (U.S. Patent No. 11,180,177 B1; “Aktas”) and Fox et al. (U.S. Patent No. 9,114,798 B1; “Fox”).
Kawaguchi discloses:
Regarding claim 16:
A vehicle steering wheel (10) comprising:
a central part (20) such as a steering wheel hub (20);
a movable structure (¶ 59, “folding grips”) comprising at least a portion of a rim (30) mounted so as to pivot with respect to the central part between (FIG. 6A-6B depict the pivoting movement; see also FIG. 8A-8B),
a driving position wherein the vehicle can be steered by a driver (FIG. 6A, 8A depicts such a driving position);
and at least one retracted position (FIG. 6B, 8B depicts a retracted position);
an actuator (60) for pivoting the movable structure between the driving position and the retracted position (¶ 59);
a movement transmission mechanism (70, 69, 55, 50) for transmitting movement between the actuator and the movable structure (¶ 60),
wherein the steering wheel comprises a torque limiter (friction clutch 70; FIG. 7F; see also ¶ 61) arranged to limit the torque transmitted to the movable structure (per MPEP § 2114, functional claim language that is not limited to a specific structure covers all devices that are capable of performing the recited function. Therefore, if the prior art discloses a device that can inherently perform the claimed function, a rejection under 35 U.S.C. 102 and/or 35 U.S.C. 103 may be appropriate. See In re Translogic Technology, Inc., 504 F.3d 1249, 1258, 84 USPQ2d 1929, 1935-1936 (Fed. Cir. 2007) (The claims were drawn to multiplexer circuit. The patent at issue claimed "coupled to" and "coupled to receive" between various portions of the circuitry. In reference to the claim phrase "input terminals ‘coupled to receive’ first and second input variables," the court held that "the claimed circuit does not require any specific input or connection … [a]s such, ‘coupled to’ and ‘coupled to receive’ are clearly different … [a]s shown in [the figures of the] patent, input terminals … only need to be ‘capable of receiving’ an input variable for the multiplexer circuit as claimed". Therefore, the specification supported the claim construction "that ‘coupled to receive’ means ‘capable of receiving.’"); furthermore, per MPEP § 2112, “[w]here applicant claims a composition in terms of a function, property or characteristic and the composition of the prior art is the same as that of the claim but the function is not explicitly disclosed by the reference, the examiner may make a rejection under both 35 U.S.C. 102 and 103,” here, the term “torque limiter” and the aforementioned claim limitation as a whole are not limited to a specific structure and covers all devices that are capable of limiting the transmission of torque to the movable structure; furthermore, Kawaguchi discloses a “friction clutch” (¶ 61) the definition of which is “a clutch in which connection is made through sliding friction” (“Friction clutch.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/friction%20clutch. Accessed 14 Mar. 2025.); therefore, the aforementioned claim limitation is an inherent characteristic of the Kawaguchi’s torque limiter 70 because it is a “friction clutch” which is capable of slipping beyond a predetermined torque as dictated by the friction coefficient of its sliding friction surfaces i.e. capable of limiting the torque transmitted to the movable structure; as such, Kawaguchi’s friction clutch 70 is capable of limiting torque transmitted to the movable structure).
However, while Kawaguchi’s torque limiter is arranged to interrupt torque transmission and temporarily decouple the actuator from the movable structure beyond a torque between the actuator and the movable structure such that torque is not transmitted during disengagement ( “friction clutch” ¶ 61; the definition of which is “a clutch in which connection is made through sliding friction” (“Friction clutch.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/friction%20clutch. Accessed 14 Mar. 2025.); therefore, the aforementioned claim limitation is an inherent characteristic of the Kawaguchi’s torque limiter 70 because it is a “friction clutch” which is capable of slipping i.e. disengaging the coupling between the two sliding friction surfaces, as dictated by the friction coefficient of its sliding friction surfaces i.e. capable of disengaging the actuator from the movable structure), it does not expressly disclose the torque limiter arranged to disengage beyond a predetermined torque to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly and the movable structure pivots between the driving position and the retracted position, and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim.
Aktas teaches a torque limiter (25, 18, 60, 62A; FIG. 9) arranged to disengage beyond a predetermined torque (col. 8 ll. 29-33, “a user can apply a force to the rim structure 4 that is sufficient to cause cam 25 to disengage from the detent notch 62, thereby permitting rotation of rim structure 4 relative to base structure 2”; col. 8 ll. 40-45, “When protrusion 60 of cam 25 is in engagement with second detent notch 62A, a user can apply a force sufficient to cause rotation of cam 25 out of engagement with detent notch 62A to thereby permit rotation of rim structure 4 in a second direction away from second utility 45 position 4C back toward the driving position 4A) to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly (col. 8 ll. 27-33, “the engagement of protrusion 60 in detent notch 62 provides a retaining detent force that tends to retain the rim structure 4 in first utility position 4B (FIG. 1). However, a user can apply a force to the rim structure 4 that is sufficient to cause cam 25 to disengage from the detent notch 62, thereby permitting rotation of rim structure 4 relative to base structure 2” thereby indicating that the “retaining detent force” is less than what could cause damage to the device i.e. to avoid damage due to excessive torque) when the driver holds the at least a portion of the rim firmly (col. 8, ll. 27-33, 40-45) and the movable structure pivots between the driving position (4A or 4B in FIG. 1) and the retracted position (4C in FIG. 1), and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim (col. 8, ll. 27-33, 40-45).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi such that the torque limiter arranged to disengage beyond a predetermined torque, as taught by Aktas, to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly when the driver holds the at least a portion of the rim firmly and the movable structure pivots between the driving position and the retracted position, and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim.
Regarding claim 19, Kawaguchi teaches the limitations of claim 16, see above, but does not expressly disclose that the torque limiter comprises at least one first recess, and at least one protrusion arranged to be lodged in the first recess when the torque limiter is engaged, and be dislodged from the first recess when the torque limiter is disengaged.
Fox teaches a torque limiter (60; FIG. 8) comprising at least one first recess (52c; FIG. 11), and at least one protrusion (62) arranged to be lodged in the first recess when the torque limiter is engaged (depicted in FIG. 8; col. 6, l. 64 – col. 7, l. 5), and be dislodged from the first recess when the torque limiter is disengaged (col. 7, ll. 6-12, “When resistance to movement, or excess loading, is present in reduction gear train 50, however, and sufficient torque is generated by electric motor 40, the force of clutch spring 63 is overcome and the first ends of clutch pins 62 traverse the ramps 52b of the projections 52a and slip from gap to gap on the side of pinion gear 52”) to protect transmission elements from excessive torque (col. 6, 27-33).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi to include that the torque limiter comprises at least one first recess, and at least one protrusion arranged to be lodged in the first recess when the torque limiter is engaged, and be dislodged from the first recess when the torque limiter is disengaged, as taught by Fox, to protect transmission elements from excessive torque.
Regarding claim 18, Kawaguchi as modified above does not expressly disclose that the predetermined torque between the actuator and the movable structure is equal to or higher than 0.9 Nm.
Where the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation. In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955) (Claimed process which was performed at a temperature between 40°C and 80°C and an acid concentration between 25% and 70% was held to be prima facie obvious over a reference process which differed from the claims only in that the reference process was performed at a temperature of 100°C and an acid concentration of 10%.); see also Peterson, 315 F.3d at 1330, 65 USPQ2d at 1382 ("The normal desire of scientists or artisans to improve upon what is already generally known provides the motivation to determine where in a disclosed set of percentage ranges is the optimum combination of percentages."); see also Merck & Co. Inc. v. Biocraft Lab. Inc., 874 F.2d 804, 10 USPQ2d 1843 (Fed. Cir.), cert. denied, 493 U.S. 975 (1989); In re Kulling, 897 F.2d 1147, 14 USPQ2d 1056 (Fed. Cir. 1990); and In re Geisler, 116 F.3d 1465, 43 USPQ2d 1362 (Fed. Cir. 1997); Smith v. Nichols, 88 U.S. 112, 118-19 (1874) (a change in form, proportions, or degree "will not sustain a patent"); In re Williams, 36 F.2d 436, 438 (CCPA 1929) ("It is a settled principle of law that a mere carrying forward of an original patented conception involving only change of form, proportions, or degree, or the substitution of equivalents doing the same thing as the original invention, by substantially the same means, is not such an invention as will sustain a patent, even though the changes of the kind may produce better results than prior inventions."). See also KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 416 (2007) (identifying "the need for caution in granting a patent based on the combination of elements found in the prior art."); see also In re Antonie, 559 F.2d 618, 195 USPQ 6 (CCPA 1977. Here, Fox aims to protect the transmission elements from excessive torque by disengaging the torque limiter beyond an excessive level of torque i.e. the predetermined torque (col. 6, ll. 27-33 in Fox). As such, it would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify Kawaguchi as modified above such that the predetermined torque between the actuator and the movable structure is equal to or higher than 0.9 Nm since it has been held that where the general conditions of a claim are disclosed in the prior art (col. 6, ll. 27-33 in Fox), discovering the optimum or workable ranges involves only routine skill in the art. See MPEP § 2144.05.
Regarding claim 20:
The vehicle steering wheel according to claim 19, wherein the torque limiter further comprises a second recess (FIG. 11 in Fox depicts multiple recesses 52c circumferentially adjacent to each other), adjacent to the first recess, and the protrusion is arranged to be lodged again into the second recess after having been dislodged from the first recess (col. 7, ll. 18-22 in Fox , “When resistance to movement, or excess loading, is no longer sufficiently present in reduction gear train 50, clutch pins 62 will cease to traverse the ramps 52b of the projections 52a and 20thereafter reside in gaps 52c under the influence of clutch spring 63”; in an overloading event, the protrusion 62 traverses the first gap 52c i.e. first recess upon rotation, traverses the ramp 52b, and lands on the adjacent gap 52c i.e. the second recess)
Regarding claim 25:
The vehicle steering wheel according to claim 19, wherein the transmission mechanism further comprises an additional plate (64a in Fox) arranged to limit an axial movement of the torque limiter (col. 6, ll. 56-59 in Fox, “Slip clutch 60 is bookended by a pair of thrust washers 64a, 64c that are retained in fixed positions along the length of clutch support shaft 61 by side housing 32 and main housing 31, respectively.”).
Regarding claim 27:
The vehicle steering wheel according to claim 16, wherein the transmission mechanism comprises: a drive plate rigidly connected to the actuator (one of the clutch plates depicted in FIG. 7F; 51 in FIG. 8-10 in Fox), a toothed input member (depicted in FIG. 8A-8B; 52 in Fox) arranged to be driven by the actuator via the torque limiter (actuator 60 drives gears as depicted in FIG. 8A-8B in Fox; actuator 40 drives input member 52), the toothed input member being arranged to directly or indirectly rotate the movable structure into the retracted position thereof (depicted in FIG. 8A-8B in Fox).
Regarding claim 28:
The vehicle steering wheel according to claim 27, wherein: a first recess is arranged in either the toothed input member or the drive plate (FIG. 10-11 in Fox depict recess 52c in toothed member 52), and a protrusion is arranged on the other one of the toothed input member and the drive plate (FIG. 9 in Fox depicts the protrusion 62 in the drive plate 51).
Regarding claim 29, Kawaguchi does not expressly disclose a device for blocking or locking the torque limiter in or adjacent a predetermined position of the movable structure, for example the driving position.
Aktas teaches a device for blocking or locking a torque limiter (60, 62, 62A, 68A, 68B; FIG. 98) in or adjacent a predetermined position of a movable structure (4), for example a driving position (4A in FIG. 1; col. 6, ll. 1-11) for the purpose of preventing free play or looseness when in a manual driving i.e. non-autonomous mode (col. 7, ll. 28-66).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi as modified above to provide a device for blocking or locking the torque limiter in or adjacent a predetermined position of the movable structure, for example the driving position, as taught by Aktas, for the purpose of preventing free play or looseness when in a manual driving i.e. non-autonomous mode.
Kawaguchi as modified above further discloses:
Regarding claim 30:
The vehicle steering wheel according to claim 16 in combination with a vehicle (¶ 3, “vehicle”).
Claim(s) 16, 19, 21, 22, and 23 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kawaguchi in view of Aktas and Richard (U.S. Patent No. 4,702,122; “Richard”).
Kawaguchi discloses:
Regarding claim 16:
A vehicle steering wheel (10) comprising:
a central part (20) such as a steering wheel hub (20);
a movable structure (¶ 59, “folding grips”) comprising at least a portion of a rim (30) mounted so as to pivot with respect to the central part between (FIG. 6A-6B depict the pivoting movement; see also FIG. 8A-8B),
a driving position wherein the vehicle can be steered by a driver (FIG. 6A, 8A depicts such a driving position);
and at least one retracted position (FIG. 6B, 8B depicts a retracted position);
an actuator (60) for pivoting the movable structure between the driving position and the retracted position (¶ 59);
a movement transmission mechanism (70, 69, 55, 50) for transmitting movement between the actuator and the movable structure (¶ 60),
wherein the steering wheel comprises a torque limiter (friction clutch 70; FIG. 7F; see also ¶ 61) arranged to limit the torque transmitted to the movable structure (per MPEP § 2114, functional claim language that is not limited to a specific structure covers all devices that are capable of performing the recited function. Therefore, if the prior art discloses a device that can inherently perform the claimed function, a rejection under 35 U.S.C. 102 and/or 35 U.S.C. 103 may be appropriate. See In re Translogic Technology, Inc., 504 F.3d 1249, 1258, 84 USPQ2d 1929, 1935-1936 (Fed. Cir. 2007) (The claims were drawn to multiplexer circuit. The patent at issue claimed "coupled to" and "coupled to receive" between various portions of the circuitry. In reference to the claim phrase "input terminals ‘coupled to receive’ first and second input variables," the court held that "the claimed circuit does not require any specific input or connection … [a]s such, ‘coupled to’ and ‘coupled to receive’ are clearly different … [a]s shown in [the figures of the] patent, input terminals … only need to be ‘capable of receiving’ an input variable for the multiplexer circuit as claimed". Therefore, the specification supported the claim construction "that ‘coupled to receive’ means ‘capable of receiving.’"); furthermore, per MPEP § 2112, “[w]here applicant claims a composition in terms of a function, property or characteristic and the composition of the prior art is the same as that of the claim but the function is not explicitly disclosed by the reference, the examiner may make a rejection under both 35 U.S.C. 102 and 103,” here, the term “torque limiter” and the aforementioned claim limitation as a whole are not limited to a specific structure and covers all devices that are capable of limiting the transmission of torque to the movable structure; furthermore, Kawaguchi discloses a “friction clutch” (¶ 61) the definition of which is “a clutch in which connection is made through sliding friction” (“Friction clutch.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/friction%20clutch. Accessed 14 Mar. 2025.); therefore, the aforementioned claim limitation is an inherent characteristic of the Kawaguchi’s torque limiter 70 because it is a “friction clutch” which is capable of slipping beyond a predetermined torque as dictated by the friction coefficient of its sliding friction surfaces i.e. capable of limiting the torque transmitted to the movable structure; as such, Kawaguchi’s friction clutch 70 is capable of limiting torque transmitted to the movable structure).
However, while Kawaguchi’s torque limiter is arranged to interrupt torque transmission and temporarily decouple the actuator from the movable structure beyond a torque between the actuator and the movable structure such that torque is not transmitted during disengagement ( “friction clutch” ¶ 61; the definition of which is “a clutch in which connection is made through sliding friction” (“Friction clutch.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/friction%20clutch. Accessed 14 Mar. 2025.); therefore, the aforementioned claim limitation is an inherent characteristic of the Kawaguchi’s torque limiter 70 because it is a “friction clutch” which is capable of slipping i.e. disengaging the coupling between the two sliding friction surfaces, as dictated by the friction coefficient of its sliding friction surfaces i.e. capable of disengaging the actuator from the movable structure), it does not expressly disclose the torque limiter arranged to disengage beyond a predetermined torque to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly and the movable structure pivots between the driving position and the retracted position, and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim.
Aktas teaches a torque limiter (25, 18, 60, 62A; FIG. 9) arranged to disengage beyond a predetermined torque (col. 8 ll. 29-33, “a user can apply a force to the rim structure 4 that is sufficient to cause cam 25 to disengage from the detent notch 62, thereby permitting rotation of rim structure 4 relative to base structure 2”; col. 8 ll. 40-45, “When protrusion 60 of cam 25 is in engagement with second detent notch 62A, a user can apply a force sufficient to cause rotation of cam 25 out of engagement with detent notch 62A to thereby permit rotation of rim structure 4 in a second direction away from second utility 45 position 4C back toward the driving position 4A) to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly (col. 8 ll. 27-33, “the engagement of protrusion 60 in detent notch 62 provides a retaining detent force that tends to retain the rim structure 4 in first utility position 4B (FIG. 1). However, a user can apply a force to the rim structure 4 that is sufficient to cause cam 25 to disengage from the detent notch 62, thereby permitting rotation of rim structure 4 relative to base structure 2” thereby indicating that the “retaining detent force” is less than what could cause damage to the device i.e. to avoid damage due to excessive torque) when the driver holds the at least a portion of the rim firmly (col. 8, ll. 27-33, 40-45) and the movable structure pivots between the driving position (4A or 4B in FIG. 1) and the retracted position (4C in FIG. 1), and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim (col. 8, ll. 27-33, 40-45).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi such that the torque limiter arranged to disengage beyond a predetermined torque, as taught by Aktas, to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly when the driver holds the at least a portion of the rim firmly and the movable structure pivots between the driving position and the retracted position, and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim.
Regarding claim 19, Kawaguchi teaches the limitations of claim 16, see above, but does not expressly disclose that the torque limiter may comprise at least one first recess, and at least one protrusion arranged to be lodged in the first recess when the torque limiter is engaged, and be dislodged from the first recess when the torque limiter is disengaged.
Richard teaches a torque limiter (22, 40, 58, 68; FIG. 2) comprising at least one first recess (recesses defined between teeth 56), and at least one protrusion (68) arranged to be lodged in the first recess when the torque limiter is engaged (col. 3, ll. 26-32), and be dislodged from the first recess when the torque limiter is disengaged (col. 3, 37-40) to protect transmission elements from excessive torque (col. 3, 37-42).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi to include that the torque limiter comprises at least one first recess, and at least one protrusion arranged to be lodged in the first recess when the torque limiter is engaged, and be dislodged from the first recess when the torque limiter is disengaged, as taught by Richard, to protect transmission elements from excessive torque.
Kawaguchi as modified above further teaches the following:
Regarding claim 21:
The vehicle steering wheel according to claim 19, wherein: the first recess is a groove extending radially (FIG. 2 in Richard depicts the groove/recess between the teeth 56 extending radially inward), and the protrusion is a rib (68 in Richard) that projects and extends radially (depicted in FIG. 2 in Richard), arranged to fit into the groove (col. 3, ll. 26-42 in Richard) .
Regarding claim 22:
The vehicle steering wheel according to claim 19, wherein: the first recess is a notch (FIG. 2 in Richard depicts the teeth 56 having a recess/notch therebetween), and the torque limiter also comprises a first leaf spring (64, 66 in Richard), extending radially so as to form the protrusion (at 68 in Richard), and arranged to engage with the notch.
Regarding claim 23:
The vehicle steering wheel according to claim 19, wherein the first recess is an opening (FIG. 2 in Richard depicts the teeth 56 having a recess/opening therebetween), the protrusion is a pin (68 in Richard) arranged at a distal end of an axis of rotation of the torque limiter (FIG. 2 in Richard depicts the pin 68 as being the most radially outward portion of the torque limiter from the axis of rotation alpha), and the torque limiter comprises a portion made of a flexible material (leaf spring 64, 66 in Richard) and arranged between the pin and the axis of rotation of the torque limiter (FIG. 2 in Richard depicts the leaf spring 64, 66 extending radially between the axis alpha and pin 68).
Claim(s) 16, 19, 24, and 26 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kawaguchi in view of Aktas and Rouleau et al. (U.S. P.G. Publication No. 2022/0212712 A1; “Rouleau”).
Regarding claim 16:
A vehicle steering wheel (10) comprising:
a central part (20) such as a steering wheel hub (20);
a movable structure (¶ 59, “folding grips”) comprising at least a portion of a rim (30) mounted so as to pivot with respect to the central part between (FIG. 6A-6B depict the pivoting movement; see also FIG. 8A-8B),
a driving position wherein the vehicle can be steered by a driver (FIG. 6A, 8A depicts such a driving position);
and at least one retracted position (FIG. 6B, 8B depicts a retracted position);
an actuator (60) for pivoting the movable structure between the driving position and the retracted position (¶ 59);
a movement transmission mechanism (70, 69, 55, 50) for transmitting movement between the actuator and the movable structure (¶ 60),
wherein the steering wheel comprises a torque limiter (friction clutch 70; FIG. 7F; see also ¶ 61) arranged to limit the torque transmitted to the movable structure (per MPEP § 2114, functional claim language that is not limited to a specific structure covers all devices that are capable of performing the recited function. Therefore, if the prior art discloses a device that can inherently perform the claimed function, a rejection under 35 U.S.C. 102 and/or 35 U.S.C. 103 may be appropriate. See In re Translogic Technology, Inc., 504 F.3d 1249, 1258, 84 USPQ2d 1929, 1935-1936 (Fed. Cir. 2007) (The claims were drawn to multiplexer circuit. The patent at issue claimed "coupled to" and "coupled to receive" between various portions of the circuitry. In reference to the claim phrase "input terminals ‘coupled to receive’ first and second input variables," the court held that "the claimed circuit does not require any specific input or connection … [a]s such, ‘coupled to’ and ‘coupled to receive’ are clearly different … [a]s shown in [the figures of the] patent, input terminals … only need to be ‘capable of receiving’ an input variable for the multiplexer circuit as claimed". Therefore, the specification supported the claim construction "that ‘coupled to receive’ means ‘capable of receiving.’"); furthermore, per MPEP § 2112, “[w]here applicant claims a composition in terms of a function, property or characteristic and the composition of the prior art is the same as that of the claim but the function is not explicitly disclosed by the reference, the examiner may make a rejection under both 35 U.S.C. 102 and 103,” here, the term “torque limiter” and the aforementioned claim limitation as a whole are not limited to a specific structure and covers all devices that are capable of limiting the transmission of torque to the movable structure; furthermore, Kawaguchi discloses a “friction clutch” (¶ 61) the definition of which is “a clutch in which connection is made through sliding friction” (“Friction clutch.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/friction%20clutch. Accessed 14 Mar. 2025.); therefore, the aforementioned claim limitation is an inherent characteristic of the Kawaguchi’s torque limiter 70 because it is a “friction clutch” which is capable of slipping beyond a predetermined torque as dictated by the friction coefficient of its sliding friction surfaces i.e. capable of limiting the torque transmitted to the movable structure; as such, Kawaguchi’s friction clutch 70 is capable of limiting torque transmitted to the movable structure).
However, while Kawaguchi’s torque limiter is arranged to interrupt torque transmission and temporarily decouple the actuator from the movable structure beyond a torque between the actuator and the movable structure such that torque is not transmitted during disengagement ( “friction clutch” ¶ 61; the definition of which is “a clutch in which connection is made through sliding friction” (“Friction clutch.” Merriam-Webster.com Dictionary, Merriam-Webster, https://www.merriam-webster.com/dictionary/friction%20clutch. Accessed 14 Mar. 2025.); therefore, the aforementioned claim limitation is an inherent characteristic of the Kawaguchi’s torque limiter 70 because it is a “friction clutch” which is capable of slipping i.e. disengaging the coupling between the two sliding friction surfaces, as dictated by the friction coefficient of its sliding friction surfaces i.e. capable of disengaging the actuator from the movable structure), it does not expressly disclose the torque limiter arranged to disengage beyond a predetermined torque to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly and the movable structure pivots between the driving position and the retracted position, and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim.
Aktas teaches a torque limiter (25, 18, 60, 62A; FIG. 9) arranged to disengage beyond a predetermined torque (col. 8 ll. 29-33, “a user can apply a force to the rim structure 4 that is sufficient to cause cam 25 to disengage from the detent notch 62, thereby permitting rotation of rim structure 4 relative to base structure 2”; col. 8 ll. 40-45, “When protrusion 60 of cam 25 is in engagement with second detent notch 62A, a user can apply a force sufficient to cause rotation of cam 25 out of engagement with detent notch 62A to thereby permit rotation of rim structure 4 in a second direction away from second utility 45 position 4C back toward the driving position 4A) to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly (col. 8 ll. 27-33, “the engagement of protrusion 60 in detent notch 62 provides a retaining detent force that tends to retain the rim structure 4 in first utility position 4B (FIG. 1). However, a user can apply a force to the rim structure 4 that is sufficient to cause cam 25 to disengage from the detent notch 62, thereby permitting rotation of rim structure 4 relative to base structure 2” thereby indicating that the “retaining detent force” is less than what could cause damage to the device i.e. to avoid damage due to excessive torque) when the driver holds the at least a portion of the rim firmly (col. 8, ll. 27-33, 40-45) and the movable structure pivots between the driving position (4A or 4B in FIG. 1) and the retracted position (4C in FIG. 1), and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim (col. 8, ll. 27-33, 40-45).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi such that the torque limiter arranged to disengage beyond a predetermined torque, as taught by Aktas, to avoid damage to the steering wheel from excessive torque beyond the predetermined torque when the driver holds the at least a portion of the rim firmly when the driver holds the at least a portion of the rim firmly and the movable structure pivots between the driving position and the retracted position, and wherein the predetermined torque corresponds to torque generated by driver resistance to pivoting the rim.
Regarding claim 19, Kawaguchi teaches the limitations of claim 16, see above, but does not expressly disclose that the torque limiter may comprise at least one first recess, and at least one protrusion arranged to be lodged in the first recess when the torque limiter is engaged, and be dislodged from the first recess when the torque limiter is disengaged.
Rouleau teaches a torque limiter (68; FIG. 4) comprising at least one first recess (recesses defined between teeth 124), and at least one protrusion (122) arranged to be lodged in the first recess when the torque limiter is engaged (¶¶ 27, 31), and be dislodged from the first recess when the torque limiter is disengaged (¶¶ 27, 31) to protect transmission elements from excessive torque (¶ 33).
It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify, with a reasonable expectation of success, Kawaguchi to include that the torque limiter comprises at least one first recess, and at least one protrusion arranged to be lodged in the first recess when the torque limiter is engaged, and be dislodged from the first recess when the torque limiter is disengaged, as taught by Rouleau, to protect transmission elements from excessive torque.
Kawaguchi as modified above further teaches the following:
Regarding claim 24:
The vehicle steering wheel according to claim 19, wherein the transmission mechanism further comprises second leaf springs (74 in Rouleau) arranged to urge the protrusion into the first recess (¶ 27, 31).
Regarding claim 26:
The vehicle steering wheel according to claim 16, wherein the torque limiter comprises two discs (discs in FIG. 7F; 114, 118 in Rouleau) each comprising a planar friction surface and arranged facing one another at the planar friction surfaces thereof (the surfaces that face each other as seen in FIG. 7F; ¶ 34 describes a “plurality of friction clutch plates” which have planar friction surfaces) , and at least one pressure spring arranged to urge the two discs against one another (via 74 in Rouleau; ¶ 27, 31 in Rouleau).
Response to Arguments
Applicant’s amendments to the claims filed 2/17/2026 have been fully considered and have required a new grounds of rejection is made in view of Kawaguchi in view of Aktas, described supra.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
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/DANIEL D YABUT/Primary Examiner, Art Unit 3656