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 .
Amendments to claims 1, 2, 8, 9, 12, 14-16, and 18, filed 12 February 2026 have been entered into the above-identified application. Claims 1-22 are currently pending.
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) 1-3, 5-9, 11-19, and 21-22 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bauer (U.S. 8,454,375) in view of Meyer (U.S. 11,801,785).
Regarding claim 1, Bauer teaches a vehicle body closure system for a service port or storage compartment formed in the body, the vehicle body closure system comprising: a door (6) coupled to the vehicle body (column 3 line 66-column 3 line 1 describes the closure device on a vehicle) for movement between an open position (fig 1) and a closed position (fig 4); a seal (12) provided between the vehicle body and the door (seal 12 seals the door 6 against the vehicle body via receiving cup 5), wherein the seal (12) is sized to require compression for the door (6) to assume the closed position (described in column 4 lines 60-33 as the seal being pressed); a powered closure device including a motor (19) and a rotary output (17), the powered closure device operable for electrical energization in a powered mode of the closure system to release the door from the closed position (described in column 5, lines 7-10), wherein the powered closure device also provides a powered mode for closing the door (described in column 7, lines 52-59); and a backup release mechanism (Bowden cable, described in column 6, lines 60-64) separate from the powered closure device and operable in a manual mode of the closure system (described in column 6, lines 60-64), without electrical energization of the powered closure device (Bowden cable releases door 6 without motor 19), to release the door (6) from the closed position wherein the door is locked closed automatically by a drive connection including an intermediate linkage (21) through which the powered closure device moves the door (drive connection closes door 6, described in column 7, lines 52-59), and wherein the drive connection is maintained and not interrupted when releasing the door via the backup release mechanism (Bowden cable, described in column 6, lines 60-64 does not disable motor 19, but instead moves linkage to open door 6).
Bauer teaches pulling a cable to release the linkage from a locked position (described in column 6, lines 60-64) but does not teach that the linkage is over-center to lock it in place.
Meyer teaches a similar vehicle body closure system where linkage 100A is over-center in a locked position (as taught in column 12, lines 47-52, the linkage assembly is rotated over-center into a locked position against a stop 108A as seen in fig 5B).
Bauer and Meyer are considered to be analogous to the claimed invention because they are in the same field of vehicle body closure systems. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bauer to incorporate the teachings of Meyer and provide an over-center linkage to keep the closure in the locked position against a stop. Doing so would allow the linkage to establish positive closing pressure against the door and thereby cinch the door closed.
Regarding claim 2, the combination of Bauer and Meyer teaches the vehicle body closure of claim 1. Bauer and Meyer further teach wherein the backup release mechanism is operable by pulling a cable to release the intermediate linkage (21 Bauer) of the drive connection from the locked position (as described in column 6, lines 60-64 of Bauer, the Bowden cable pulls the linkage elements out of their anti-rotation position, the locked position as taught by the combination of Bauer and Meyer above).
Regarding claim 3, the combination of Bauer and Meyer teaches the vehicle body closure of claim 1. Bauer further teaches wherein the door (6) is coupled to the vehicle body (via receiving cup 5) through a gooseneck hinge (14).
Regarding claim 5, the combination of Bauer and Meyer teaches the vehicle body closure of claim 1. Bauer further teaches wherein the door (6) selectively covers and prevents access to a charge port configured for receiving a charging cable (via plug 41).
Regarding claim 6, the combination of Bauer and Meyer teaches the vehicle body closure of claim 1. Bauer further teaches wherein the door (6) selectively covers and prevents access to a storage compartment provided in the vehicle body (receiving cup 5 stores the plug-in coupler).
Regarding claim 7, the combination of Bauer and Meyer teaches the vehicle body closure of claim 1. Bauer and Meyer further teach wherein, in a second powered mode of the closure system, the powered closure device is operable to cinch the door (6 Bauer) into the closed position (6 Bauer is locked into a position where linkages 21, 22, and 24 are in an anti-rotation position to prevent the manual opening of the door 6, as taught by the combination of Bauer and Meyer above, the linkage assembly is rotated over-center into a locked position).
Regarding claim 8, the combination of Bauer and Meyer teaches the vehicle body closure of claim 1. Bauer and Meyer further teach wherein the backup release mechanism (Bowden cable, described in column 6, lines 60-64 of Bauer) is operable to toggle the intermediate linkage (21 Bauer) over-center from the locked position into an unlocked position by manual movement of a cam on which the stop that defines the lock position is provided (Bowden cable, described in column 6, lines 60-64 of Bauer does not disable motor 19, but instead moves linkage to open door 6. Linkage 21 acts as a cam with the assembly over-center in the locked position against the stop, as per the combination above).
Regarding claim 9, Bauer teaches a vehicle service port closure system of a vehicle body in which a service port is formed to provide access for replenishment of an energy storage device, the vehicle service port closure system comprising: a door (6) coupled to the vehicle body (column 3 line 66-column 3 line 1 describes the closure device on a vehicle) for movement between an open position (fig 1) and a closed position (fig 4), wherein the open position of the door (6) exposes the service port (1) for replenishment of the energy storage device (as seen in figs 1 and 2); a seal (12) provided between the vehicle body and the door (seal 12 seals the door 6 against the vehicle body via receiving cup 5), wherein the seal (12) is sized to require compression for the door (6) to assume the closed position (described in column 4 lines 60-33 as the seal being pressed); a powered closure device including a motor (19) and a rotary output (17), the powered closure device operable for electrical energization in a powered mode of the service port closure system to release the door from the closed position (described in column 5, lines 7-10), where the powered closure device is coupled to the door (6) via a drive connection including an intermediate linkage (21); and a backup release mechanism (Bowden cable, described in column 6, lines 60-64) separate from the powered closure device and operable in a manual mode of the vehicle service port closure system (described in column 6, lines 60-64), without electrical energization of the powered closure device (Bowden cable releases door 6 without motor 19), to release the door (6) from the closed position while maintaining the drive connection between the rotary output (17) of the powered closure device and the door (6, Bowden cable, described in column 6, lines 60-64 does not disable motor 19, but instead moves linkage to open door 6).
Bauer teaches pulling a cable to release the linkage from a locked position (described in column 6, lines 60-64) but does not teach that the linkage is over-center to lock it in place.
Meyer teaches a similar vehicle body closure system where linkage 100A is over-center in a locked position (as taught in column 12, lines 47-52, the linkage assembly is rotated over-center into a locked position against a stop 108A as seen in fig 5B). The combination of Bauer and Meyer then teaches a stop (108A Bauer) against which the intermediate linkage (21 Meyer) is abutted in the locked position, wherein the backup release mechanism is operable to toggle the intermediate linkage (21 Bauer) over-center from the locked position into an unlocked position (Bowden cable, described in column 6, lines 60-64 does not disable motor 19, but instead moves linkage 21 to open door 6. Linkage 21 is over-center in the locked position against the stop, as per the combination above).
Bauer and Meyer are considered to be analogous to the claimed invention because they are in the same field of vehicle body closure systems. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bauer to incorporate the teachings of Meyer and provide an over-center linkage to keep the closure in the locked position against a stop. Doing so would allow the linkage to establish positive closing pressure against the door and thereby cinch the door closed.
Regarding claim 11, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 9. Bauer further teaches wherein the service port selectively exposed by the door (6) is a charge port (1) configured for receiving a charging cable (via plug 41).
Regarding claim 12, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 9. Bauer and Meyer further teach wherein the backup release mechanism is operable by pulling a cable to release the intermediate linkage (21 Bauer) of the drive connection from the locked position (as described in column 6, lines 60-64, of Bauer the Bowden cable pulls the linkage elements out of their anti-rotation position, column 12, lines 47-52 of Meyer teaches the linkage assembly is rotated over-center into a locked position against a stop, as per the combination above).
Regarding claim 13, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 9. Bauer further teaches wherein the door (6) is coupled to the vehicle body (via receiving cup 5) through a gooseneck hinge (14).
Regarding claim 14, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 9. Bauer and Meyer further teach wherein in a second powered mode of the closure system, the powered closure device is operable to cinch the door (6 Bauer) into the closed position (6 Bauer is locked into a position where linkages 21, 22, and 24 are in an anti-rotation position to prevent the manual opening of the door 6, column 12, lines 47-52 of Meyer teaches the linkage assembly is rotated over-center into a locked position against a stop per the combination above).
Regarding claim 15, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 9. Bauer and Meyer further teach wherein the backup release mechanism is operable to toggle the intermediate linkage (21 Bauer) over-center from the locked position into the unlocked position (as described in column 6, lines 60-64 of Bauer, the Bowden cable pulls the linkage elements out of their anti-rotation position, or over-center to an unlocked position according to the combination above) by manual movement of a cam on which the stop that defines the locked position is provided (linkage 21 of Bauer acts as a cam with the assembly over-center in the locked position against the stop, as per the combination above).
Regarding claim 16, Bauer teaches a vehicle service port closure system of a vehicle body in which a service port is formed to provide access for replenishment of an energy storage device, the vehicle service port closure system comprising: a door (6) coupled to the vehicle body (column 3 line 66-column 3 line 1 describes the closure device on a vehicle) for movement between an open position (fig 1) and a closed position (fig 4), wherein the open position of the door (6) exposes the service port (1) for replenishment of the energy storage device (as seen in figs 1 and 2); a seal (12) provided between the vehicle body and the door (seal 12 seals the door 6 against the vehicle body via receiving cup 5), wherein the seal (12) is sized to require compression for the door (6) to assume the closed position (described in column 4 lines 60-33 as the seal being pressed); a powered closure device coupled through an intermediate linkage (21) to the door (6)) and operable for electrical energization in a first mode of the vehicle service port closure system to keep the door (6) into the closed position.
Bauer teaches pulling a cable to release the linkage from a locked position (described in column 6, lines 60-64 where linkages 22 and 24 are in an anti-rotation position to prevent the manual opening of the door 6) but does not teach that the linkage is over-center to cinch it in place.
Meyer teaches a similar vehicle body closure system where linkage 100A is over-center in a locked position (as taught in column 12, lines 47-52, the linkage assembly is rotated over-center into a locked position against a stop 108A as seen in fig 5B causing positive pressure to cinch the door into the closed position, passively maintaining the door in the closed position with the seal compressed).
Bauer and Meyer are considered to be analogous to the claimed invention because they are in the same field of vehicle body closure systems. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Bauer to incorporate the teachings of Meyer and provide an over-center linkage to keep the closure in the locked position against a stop. Doing so would allow the linkage to establish positive closing pressure against the door and thereby cinch the door closed.
Regarding claim 17, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 16. Bauer and Meyer further teach wherein the intermediate linkage (21 Bauer) alone, without any additional latching or locking mechanism, is responsible for holding the door locked in the closed position (linkages 21 Bauer as taught by the combination above, are held in an over-center configuration to hold the door in the closed position).
Regarding claim 18, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 16. Bauer and Meyer further teach wherein the backup release mechanism is operable by pulling a cable to manually cam the intermediate linkage with the stop (Bowden cable, described in column 6, lines 60-64 of Bauer does not disable motor 19, but instead moves linkage to open door 6. Linkage 21 acts as a cam with the assembly over-center in the locked position against the stop, as per the combination above).
Regarding claim 19, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 16. Bauer further teaches wherein the door (6) is coupled to the vehicle body (via receiving cup 5) through a gooseneck hinge (14).
Regarding claim 21, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 16. Bauer further teaches wherein the energy storage device is a rechargeable battery pack and the service port is a charge port (1) configured for receiving a charging cable (via plug 41).
Regarding claim 22, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 16. Bauer further teaches wherein the powered closure device is operable in a second mode to drive the door (6) into the open position (fig 3) through the intermediate linkage (21, described in column 5, lines 7-10).
Claim(s) 4, 10, and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Bauer (U.S. 8,454,375) in view of Meyer (U.S. 11,801,785) as applied to claims 1, 9, and 16 above, and further in view of Sun (U.S. 11,913,264).
Regarding claim 4, the combination of Bauer and Meyer teaches the vehicle body closure system of claim 1. Bauer and Meyer are silent as to the door (6) selectively covering and preventing access to a fuel filler configured for receiving a fuel nozzle.
Sun teaches a similar vehicle body closure system with intermediate linkage where the door covers and prevents access to a fuel filler configured for receiving a fuel nozzle (100 of Sun is described as a refueling port or charging port flip cover assembly).
Bauer, Meyer, and Sun are considered to be analogous to the claimed invention because they are in the same field of vehicle body closure systems. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified the combination of Bauer and Meyer to incorporate the teachings of Sun and provide a door for selectively covering and preventing access to a fuel filler configured for receiving a fuel nozzle. Doing so would expand the applications of the door of Bauer to be utilized on vehicles with fuel fillers as well.
Regarding claim 10, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 9. Bauer and Meyer are silent as to the service port selectively exposed by the door (6) being a fuel filler configured for receiving a fuel nozzle.
Sun teaches a similar vehicle service port closure system with intermediate linkage where the door covers and prevents access to a fuel filler configured for receiving a fuel nozzle (100 of Sun is described as a refueling port or charging port flip cover assembly).
Bauer, Meyer, and Sun are considered to be analogous to the claimed invention because they are in the same field of vehicle service port closure systems. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified the combination of Bauer and Meyer to incorporate the teachings of Sun and provide a door for selectively covering and preventing access to a fuel filler configured for receiving a fuel nozzle. Doing so would expand the applications of the door of Bauer to be utilized on vehicles with fuel fillers as well.
Regarding claim 20, the combination of Bauer and Meyer teaches the vehicle service port closure system of claim 16. Bauer and Meyer are silent as to the energy storage device being a fuel tank and the service port is a fuel filler configured for receiving a fuel nozzle.
Sun teaches a similar vehicle service port closure system with intermediate linkage where the energy storage device is a fuel tank and the service port is a fuel filler configured for receiving a fuel nozzle (100 of Sun is described as a refueling port or charging port flip cover assembly).
Bauer, Meyer, and Sun are considered to be analogous to the claimed invention because they are in the same field of vehicle service port closure systems. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified the combination of Bauer and Meyer to incorporate the teachings of Sun and provide a door for selectively covering and preventing access to a fuel filler configured for receiving a fuel nozzle. Doing so would expand the applications of the door of Bauer to be utilized on vehicles with fuel fillers as well.
Response to Arguments
Applicant's arguments filed 12 February 2026 have been fully considered but they are not persuasive. Applicant has amended independent claims 1, 9, and 16, to recite that the intermediate linkage is toggled over-center into contact with a stop to define a locked position. with a linkage assembly that is toggled over-center to contact a stop to define a locked position. While Bauer alone teaches a locked position in regards to the linkage assembly, it does not teach the linkage assembly over-center so as to cinch the door into place against the seal. One of ordinary skill in the art would be likely to combine the teachings of Bauer and Meyer so as to cinch the door assembly into place in the locked position, to ensure integrity of the seal. Therefore, the combination of prior art teaches the claimed invention.
Applicant’s amendments have overcome the claim objection from the non-final office action and the claim objection has been withdrawn.
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to Susan M Heschel whose telephone number is (571)272-6621. The examiner can normally be reached Monday-Friday 8:00 am-4:00 pm.
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, Daniel Troy can be reached at (571)270-3742. 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.
/SUSAN M. HESCHEL/Examiner, Art Unit 3637
/Muhammad Ijaz/Primary Examiner, Art Unit 3631
Prosecution Insights