Prosecution Insights
Last updated: October 04, 2026
Application No. 18/338,402

AIRCRAFT TOWING SYSTEM AND METHOD FOR TOWING AN AIRCRAFT

Non-Final OA §103
Filed
Jun 21, 2023
Priority
Jun 22, 2022 — EU 22305907.2
Examiner
BREWER, JACK ROBERT
Art Unit
3663
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Tld Europe
OA Round
3 (Non-Final)
50%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 50% of resolved cases
50%
Career Allowance Rate
4 granted / 8 resolved
-2.0% vs TC avg
Strong +67% interview lift
Without
With
+66.7%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
26 currently pending
Career history
55
Total Applications
across all art units

Statute-Specific Performance

§101
4.1%
-35.9% vs TC avg
§103
66.2%
+26.2% vs TC avg
§102
9.1%
-30.9% vs TC avg
§112
19.2%
-20.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 8 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 . 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 08/19/2026 has been entered. Response to Amendment The amendment filed on 08/19/2026 has been entered. Claims 1, 3, 6-9, and 11-15 remain pending in the application. Claims 1, 6-7, 11, and 13 have been presently amended. Claims 2, 4-5, and 10 have been previously canceled. Applicant’s amendments to the claims have overcome each and every objection and rejection under 35 USC 112(b) set forth in the Final Office Action Mailed 05/26/2026. 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. Claims 1, 3, 6-9, and 11-15 are rejected under 35 U.S.C. 103 as being unpatentable over Dow et al. (US 20110015816 A1) in view of Lehnertz et al. (DE 102018251774 A1) and Connor et al. (US 20160264255 A1). Regarding claim 1, Dow teaches an aircraft towing system for an airport having at least one towing zone in which an aircraft is likely to be towed, the towing system comprising: at least one tow-tractor configured to be operated remotely by means of a wireless connection and suitable for towing the aircraft ([0024], [0026], and [0050], where a UGV, i.e. tow-tractor, is controlled by a remote control center (RCC)), at least one control device intended to be connected to the tow-tractor using the wireless connection and able to control said tow-tractor ([0024], [0041], and Fig. 1, where the RCC communicates wirelessly with the UGV), and at least one first sensor intended to be positioned in the towing zone, this or these first sensors being independent of the tow-tractor and being able to supply information about elements likely to be encountered by the aircraft and/or the tow-tractor during the operation of towing the aircraft using the tow-tractor ([0043], where the first sensor is a radar field sensor that allows “a UGV path to be monitored for obstacles beyond its onboard vision sensor ranges”), the control device being further configured to collect the information supplied by the at least one first sensor and exploit it in controlling the tow-tractor to tow the aircraft ([0043-0044], where the data provided by the asset tracking radar subsystem (ATRS) is used to update the GUI the RCC uses to control a UGV); wherein the control device has a human/machine interface so as to allow said tow-tractor to be controlled by an operator from said control device ([0038], where the RCC has a GUI that allows an operator to “operate a UGV via remote control”); wherein the at least one tow-tractor comprises at least one second sensor able to detect an obstacle lying in its path ([0046] and [0050]) and wherein the control device is further configured to collect the information supplied by the at least one second sensor and exploit it in controlling a tow-tractor to tow the aircraft ([0134] and see Figs. 4B-4D, where the UGV sends sensor data, and short range vehicle guidance, and other sensor data to the RCC and/or a remote RCC operator); wherein the control device comprises a display system able to supply a display ([0038]). Dow does not teach wherein the at least one first sensor is a sensor able to supply an image of at least part of the towing zone. In the same field of endeavor, Lehnertz teaches an airport sensor system wherein the at least one first sensor is a sensor able to supply an image of at least part of the towing zone ([0022], where the environmental sensor is a sensor able to supply an image, such as a video sensor). It would have been obvious to one of ordinary skill in the art at the effective date of filing to modify Dow’s first sensor to comprise an image sensor based on a reasonable expectation of success and motivation, as taught by Lehnertz, of better “monitoring the environment of the motor vehicle using an airport infrastructure environment sensor system”, thus allowing for “at least partially automated control of a lateral and longitudinal guidance of the motor vehicle” ([0012]). One of ordinary skill in the art would further recognize that including other first sensors, such as image sensors, would convey additional advantages as opposed to the first sensor being exclusively a radar field sensor, such as enhanced detection or unique forms of operation depending on the type of sensor and per the needs of the skilled artisan. Although Dow teaches that the display system supplies a display including images ([0038] and [0127], where the GUI that is displayed is images), the prior combination does not teach that the display includes the image or images supplied by the at least one first sensor, and the information supplied by the at least one second sensor, wherein the display system is configured to present the image from the at least one first sensor and the information from the at least one second sensor simultaneously to provide a unified situational awareness view for the operator. In the same field of endeavor, Connor teaches a display system providing a display including, at least in part, the image or images supplied by the at least one first sensor, and the information supplied by the at least one second sensor ([0012], [0052-0053], and [0068], where a composite image is produced from multiple image sensors not limited to cameras, and “may be transmitted to the displays of an air traffic controller [or] a remote operator…”; [0061], where the sensors include both sensors onboard the vehicle, i.e. the at least one second sensor onboard the tow-tractor, and “components… [that] may be located off of the vehicle”, i.e. the at least one first sensor), wherein the display system is configured to present the image from the at least one first sensor and the information from the at least one second sensor simultaneously to provide a unified situational awareness view for the operator ([0012], [0052-0053], and [0061], where a “composite video image” is generated from sensors that “may be located off of the vehicle” and that are on the vehicle, and are displayed for “an air traffic controller [or] a remote operator…” as seen in Fig. 5). It would have been obvious to one of ordinary skill in the art at the effective date of filing to modify the prior combination with the teachings of Connor based on a reasonable expectation of success and motivation, as taught by Connor, of ensuring that obstacles and important features can still be detected even when a singular sensor may not be able to detect or distinguish them ([0005]). This additionally ensures that any graphical objects generated on HUDs, which are generated in Dow, are generated accurately as “in order for a HUD to display representations of features or obstacles as synthetic graphical objects, image sensors on the vehicle must be able to detect those features and obstacles” (Connor, [0009]). Regarding claim 3, Lehnertz teaches wherein said at least one first sensor is selected from: an optical camera working in the visible or in the infrared and an imager of the LIDAR type ([0022]). Regarding claim 6, Dow teaches wherein the control device is configured to combine the images supplied by the first sensor in order to supply a display of the elements likely to be encountered by the aircraft and/or the tow-tractor on the towing zone during the towing operation ([0061-0062] and see Figs. 4B-4D, where the first sensor data is combined with data from the UGV to generate the RCC GUI). Lehnertz further teaches that the airport sensor system comprises a plurality of first sensors configured to be installed on the towing zone ([0021]). Regarding claim 7, Dow teaches wherein the at least one first sensor is configured to be installed fixedly in the towing zone ([0045], where the radar field sensor is fixedly installed to monitor a mounting plane). Regarding claim 8, Dow does not teach wherein the, or at least one, first sensor is fitted to a mobile vehicle. In the same field of endeavor, Lehnertz teaches wherein the, or at least one, first sensor is fitted to a mobile vehicle ([0025-0026]). It would have been obvious to one of ordinary skill in the art at the effective date of filing to fit the first sensor to a mobile vehicle based on a reasonable expectation of success and motivation to allow the detection range of the first sensor to dynamically adjust for different desired circumstances. This allows the sensor to move to busy or otherwise important locations that may not otherwise be in its detection range if it were stationary, thereby increasing the efficiency and accuracy of the system. Regarding claim 9, Lehnertz teaches wherein said mobile vehicle is selected from an airport vehicle and a dedicated, advantageously autonomous, mobile vehicle ([0025-0026]). Regarding claim 11, Dow teaches wherein the control device is able to control the tow-tractor autonomously on the basis of at least the information supplied by the first sensor or sensors ([0031], where the UGV autonomously performs a mission and can update its course based on detections made by the ATRS sensor). Regarding claim 12, Dow teaches an airport equipped with an aircraft towing system according to Claim 1 ([0047] and see Figs. 4A-4D). Regarding claim 13, Dow teaches the system of claim 1. While Dow does not explicitly teach the positive manipulative steps of supplying, installing, and arranging, it teaches: at least one tow-tractor configured to be operated remotely by means of a wireless connection and suitable for towing the aircraft ([0024], [0026], and [0050], where a UGV, i.e. tow-tractor, is controlled by a remote control center (RCC)), which is inherently supplied; at least one control device connected to the tow-tractor using the wireless connection and able to control said tow-tractor ([0024], [0041], and Fig. 1, where the RCC communicates wirelessly with the UGV), which is inherently installed; and at least one first sensor arranged in the towing zone able to supply information about elements likely to be encountered by the aircraft and/or the tow-tractor during the operation of towing the aircraft using the tow-tractor, the each first sensor being independent of the tow-tractor ([0043] and Figs. 4A-4D, where the first sensor is a radar field sensor that allows “a UGV path to be monitored for obstacles beyond its onboard vision sensor ranges”), wherein the control device is further configured to collect the information supplied by the at least one first sensor and exploit it in controlling the tow-tractor to tow the aircraft ([0043-0044], where the data provided by the asset tracking radar subsystem (ATRS) is used to update the GUI the RCC uses to control a UGV); wherein the control device has a human/machine interface so as to allow said tow-tractor to be controlled by an operator from said control device ([0038], where the RCC has a GUI that allows an operator to “operate a UGV via remote control”); wherein the at least one tow-tractor comprises at least one second sensor able to detect an obstacle lying in its path ([0046] and [0050]) and wherein the control device is further configured to collect the information supplied by the at least one second sensor and exploit it in controlling a tow-tractor to tow the aircraft ([0134] and see Figs. 4B-4D, where the UGV sends sensor data, and short range vehicle guidance, and other sensor data to the RCC and/or a remote RCC operator); and wherein the control device comprises a display system able to supply a display ([0038]). Lehnertz further teaches wherein the at least one first sensor is a sensor able to supply an image of at least part of the towing zone ([0022], where the environmental sensor is a sensor able to supply an image, such as a video sensor). Connor further providing a display including, at least in part, the image or images supplied by the at least one first sensor, and the information supplied by the at least one second sensor ([0012], [0052-0053], and [0068], where a composite image is produced from multiple image sensors not limited to cameras, and “may be transmitted to the displays of an air traffic controller [or] a remote operator…”; [0061], where the sensors include both sensors onboard the vehicle, i.e. the at least one second sensor onboard the tow-tractor, and “components… [that] may be located off of the vehicle”, i.e. the at least one first sensor), wherein the display system is configured to present the image from the at least one first sensor and the information from the at least one second sensor simultaneously to provide a unified situational awareness view for the operator ([0012], [0052-0053], and [0061], where a “composite video image” is generated from sensors that “may be located off of the vehicle” and that are on the vehicle, and are displayed for “an air traffic controller [or] a remote operator…” as seen in Fig. 5). Regarding claim 14, Dow does not teach wherein equipping the towing zone with at least one first sensor is achieved by deploying at least one mobile vehicle having said at least one first sensor, the mobile vehicle being selected from an airport vehicle and a dedicated autonomous mobile vehicle. In the same field of endeavor, Lehnertz teaches an airport sensor system that comprises at least one mobile vehicle having said at least one first sensor ([0025-0026], the mobile vehicle being selected from an airport vehicle and a dedicated autonomous mobile vehicle ([0025-0026]). A skilled artisan would have been able to modify the system of Dow by having the first sensor be comprised in a mobile vehicle. Although Lehnertz does not explicitly teach the method of deploying at least one mobile vehicle, such a method is implicit to the disclosure of Lehnertz as there is no other way for the environmental sensor, when it is arranged on a mobile vehicle, to be able to perform its disclosed functionality unless the vehicle is deployed. It would have been obvious to one of ordinary skill in the art at the effective date of filing to fit the first sensor to a mobile vehicle based on a reasonable expectation of success and motivation to allow the detection range of the first sensor to dynamically adjust for different desired circumstances. This allows the sensor to move to busy or otherwise important locations that may not otherwise be in its detection range if it were stationary, thereby increasing the efficiency and accuracy of the system. Regarding claim 15, Dow teaches a method for towing aircraft comprising the following steps: identifying the aircraft that is to be towed in a towing zone equipped with at least one first sensor able to supply information about elements likely to be encountered by the aircraft and/or a tow-tractor during an operation of towing the aircraft ([0044] and [0134], where the ATRS uses its radar sensor to collect positional data on objects; [0025-0026], where data on aircraft is obtained so as to direct a UGV to perform docking with the identified aircraft), identifying a tow-tractor configured to be operated remotely by means of a wireless connection and suitable for towing the aircraft ([0135] and [0140], where the RCC identifies a UGV and its position so as to remotely control it), remotely controlling the tow-tractor identified for towing the aircraft from a control device connected to the tow-tractor using the wireless connection, the control device collecting the information supplied by the at least one first sensor and exploiting it or them in controlling the tow-tractor ([0131] and [0134], where the RCC sends the UGV waypoints so as to navigate to and control a specific aircraft), the first sensor being arranged in the towing zone and being suitable for supplying information about elements likely to be encountered by the aircraft and/or the tow-tractor during the operation of towing the aircraft using the tow-tractor, the or each first sensor being independent of the tow-tractor ([0043]); wherein the control device has a human/machine interface so as to allow said tow-tractor to be controlled by an operator from said control device ([0038], where the RCC has a GUI that allows an operator to “operate a UGV via remote control”); wherein the at least one tow-tractor comprises at least one second sensor able to detect an obstacle lying in its path ([0046] and [0050]) and wherein the control device is further configured to collect the information supplied by the at least one second sensor and exploit it in controlling a tow-tractor to tow the aircraft ([0134] and see Figs. 4B-4D, where the UGV sends sensor data, and short range vehicle guidance, and other sensor data to the RCC and/or a remote RCC operator); and wherein the control device comprises a display system able to supply a display ([0038]). Dow does not teach wherein the at least one first sensor is a sensor able to supply an image of at least part of the towing zone. In the same field of endeavor, Lehnertz teaches an airport sensor system wherein the at least one first sensor is a sensor able to supply an image of at least part of the towing zone ([0022], where the environmental sensor is a sensor able to supply an image, such as a video sensor). It would have been obvious to one of ordinary skill in the art at the effective date of filing to modify Dow’s first sensor to comprise an image sensor based on a reasonable expectation of success and motivation, as taught by Lehnertz, of better “monitoring the environment of the motor vehicle using an airport infrastructure environment sensor system”, thus allowing for “at least partially automated control of a lateral and longitudinal guidance of the motor vehicle” ([0012]). One of ordinary skill in the art would further recognize that including other first sensors, such as image sensors, would convey additional advantages as opposed to the first sensor being exclusively a radar field sensor, such as enhanced detection or unique forms of operation depending on the type of sensor and per the needs of the skilled artisan. Although Dow teaches that the display system supplies a display including images ([0038] and [0127], where the GUI that is displayed is images), the prior combination does not teach that the display includes the image or images supplied by the at least one first sensor, and the information supplied by the at least one second sensor, wherein the display system is configured to present the image from the at least one first sensor and the information from the at least one second sensor simultaneously to provide a unified situational awareness view for the operator. In the same field of endeavor, Connor teaches a display system providing a display including, at least in part, the image or images supplied by the at least one first sensor, and the information supplied by the at least one second sensor ([0012], [0052-0053], and [0068], where a composite image is produced from multiple image sensors not limited to cameras, and “may be transmitted to the displays of an air traffic controller [or] a remote operator…”; [0061], where the sensors include both sensors onboard the vehicle, i.e. the at least one second sensor onboard the tow-tractor, and “components… [that] may be located off of the vehicle”, i.e. the at least one first sensor), wherein the display system is configured to present the image from the at least one first sensor and the information from the at least one second sensor simultaneously to provide a unified situational awareness view for the operator ([0012], [0052-0053], and [0061], where a “composite video image” is generated from sensors that “may be located off of the vehicle” and that are on the vehicle, and are displayed for “an air traffic controller [or] a remote operator…” as seen in Fig. 5). It would have been obvious to one of ordinary skill in the art at the effective date of filing to modify the prior combination with the teachings of Connor based on a reasonable expectation of success and motivation, as taught by Connor, of ensuring that obstacles and important features can still be detected even when a singular sensor may not be able to detect or distinguish them ([0005]). This additionally ensures that any graphical objects generated on HUDs, which are generated in Dow, are generated accurately as “in order for a HUD to display representations of features or obstacles as synthetic graphical objects, image sensors on the vehicle must be able to detect those features and obstacles” (Connor, [0009]). Response to Arguments Applicant’s arguments, filed 08/19/2026, with respect to the rejection of claims 1, 13, and 15 under 35 USC 103 have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground of rejection is made over Dow in view of Lehnertz and Connor as Connor “recognize[s] a need to fuse fixed/mobile imaging data with onboard tractor obstacle data into a single operator display” as argued by applicant (see Page 9 of applicant’s remarks). Applicant further argues that the combination of Dow and Lehnertz, as relied upon for the present and previous rejections under 35 USC 103, is improper. These arguments, detailed below, are unpersuasive. In response to applicant's argument that the examiner's conclusion of obviousness regarding the previous combination of Dow and Lehnertz is based upon improper hindsight reasoning, it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin, 443 F.2d 1392, 170 USPQ 209 (CCPA 1971). Applicant’s disclosure is not relied upon for any cited teachings or motivation in the present rejection. Rather, regarding the present combination, the motivation is only gleaned from the teachings of Lehnertz and knowledge that one of ordinary skill in the art would possess. In response to applicant’s argument that there is no teaching, suggestion, or motivation to combine Dow and Lehnertz, the examiner recognizes that obviousness may be established by combining or modifying the teachings of the prior art to produce the claimed invention where there is some teaching, suggestion, or motivation to do so found either in the references themselves or in the knowledge generally available to one of ordinary skill in the art. See In re Fine, 837 F.2d 1071, 5 USPQ2d 1596 (Fed. Cir. 1988), In re Jones, 958 F.2d 347, 21 USPQ2d 1941 (Fed. Cir. 1992), and KSR International Co. v. Teleflex, Inc., 550 U.S. 398, 82 USPQ2d 1385 (2007). In this case, the motivation, as taught by Lehnertz and as stated above, is to better “monitor the environment of the motor vehicle using an airport infrastructure environment sensor system”, thus allowing for “at least partially automated control of a lateral and longitudinal guidance of the motor vehicle” ([0012]). It is additionally recognized that one of ordinary skill in the art would contain the knowledge of additional advantages conveyed from comprising image sensors with the at least one first sensors, such as enhanced detection in circumstances when an singular radar field sensor may otherwise fail. In response to applicant's argument that the combination is nonanalogous 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, both Dow and Lehnertz are in the same field of applicant’s invention in that they are airport sensor systems that allow for the automated operation of airport vehicles. Conclusion The following prior art made of record and not relied upon by the examiner is considered pertinent to applicant’s disclosure: Ziv Av et al. (US 20230053453 A1) Any inquiry concerning this communication or earlier communications from the examiner should be directed to JACK R BREWER whose telephone number is (571)272-4455. The examiner can normally be reached 10AM-6PM. 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, Angela Ortiz can be reached at 571-272-1206. 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. /JACK R BREWER/Examiner, Art Unit 3663 /ANGELA Y ORTIZ/Supervisory Patent Examiner, Art Unit 3663
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Prosecution Timeline

Jun 21, 2023
Application Filed
Dec 05, 2025
Non-Final Rejection mailed — §103
Mar 04, 2026
Response Filed
May 26, 2026
Final Rejection mailed — §103
Aug 19, 2026
Request for Continued Examination
Aug 20, 2026
Response after Non-Final Action
Sep 18, 2026
Non-Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
50%
Grant Probability
99%
With Interview (+66.7%)
2y 3m (~0m remaining)
Median Time to Grant
High
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