Prosecution Insights
Last updated: April 19, 2026
Application No. 18/358,736

HEAD RESTRAINT FOR A VEHICLE SEAT

Final Rejection §103
Filed
Jul 25, 2023
Examiner
ABRAHAM, TANIA
Art Unit
3636
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Jaguar Land Rover Limited
OA Round
2 (Final)
72%
Grant Probability
Favorable
3-4
OA Rounds
2y 9m
To Grant
89%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allow Rate
586 granted / 813 resolved
+20.1% vs TC avg
Strong +17% interview lift
Without
With
+17.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
32 currently pending
Career history
845
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
39.7%
-0.3% vs TC avg
§102
34.0%
-6.0% vs TC avg
§112
23.4%
-16.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 813 resolved cases

Office Action

§103
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 . Response to Arguments Applicant's arguments filed 18-Sep-25 have been fully considered but they are not persuasive. The rejection , presently under 35 USC 103. Applicant argues that the reference to Veine does not teach the head support pivot adjustment being dependent on the vertical adjustment of the head restraint (pp 9-10). However, Veine does disclose that the head support is capable of being pivoted by the height adjustment (described as “translation”) of the head restraint (¶ [0021]), wherein a user or a mechanical device can control the movement; and Venice discloses that the head support rotation initiated by the seatback adjustment (fig. 10) operates similarly to the head support rotation dependent on the height adjustment in figures 3-5 (¶ 31). It has been determined that these disclosures combined render obvious the subject matter of claim 1. Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. 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. Claim(s) 1-16 and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Veine (US 2012/0280547). Claim 1- Veine teaches a head restraint (10) for a vehicle seat having a seatback (12), the head restraint comprising: a head support (16); a head restraint mounting assembly (18) for mounting the head restraint to the seatback, the head restraint mounting assembly comprising a first mounting stem (the assembly 18 is an arch-shaped bar comprising a pair of opposing vertical stems coupled by a crossbar), wherein the head support is pivotably mounted to the head restraint mounting assembly (at the crossbar); and an actuating cable (64) configured to control pivoting of the head support about a pivot axis (the pivot axis is defined by the upper crossbar of the support member 18); wherein the head support is configured to pivot in dependence on changes in a vertical position of the restraint relative to the seatback (¶ 21). Venice states (¶ 21) that the head support can be rotated and translated via the mounting assembly (support members 18), wherein rotation occurs during translation and wherein this adjustment can be achieved manually or by a mechanism. Venice teaches that the head support comprising the actuating cable (fig. 10) operates like the head support in figures 3-5 (¶ 31), wherein the head support movement is actuated by adjustment of a seat component (¶ 32). Venice’s teaching (¶ 31) would suggest to a person of ordinary skill that the head restraint comprising an actuating cable could be configured to control the pivoting of the head support via the height adjustment of the mounting assembly (18). Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the head support actuated by a cable to be pivotable according to the height position, in order to provide an automatic positioning of the head restraint. Claim 2- Veine teaches the head restraint as claimed in claim 1, wherein the actuating cable (64) is fastened to the head support at a first anchor point which is offset vertically from the pivot axis (fig. 10 shows an end of the cable 64 is anchored by the wedge 68 which is located below the crossbar of the support member 18, and an intermediate portion of the cable is anchored by the lever arm 62 above the crossbar). Claim 3- Veine teaches the head restraint as claimed in claim 1, wherein the head restraint mounting assembly (18) comprises a crossmember which defines the pivot axis (as previously explained). Claim 4- Veine teaches the head restraint as claimed in claim 1, comprising a spring member (28) for biasing the head support towards an unusable position (¶ 23, 31). Claim 5- Veine teaches the head restraint as claimed in claim 1, wherein the actuating cable (64) is disposed at least partially inside the first mounting stem (fig. 10). Claim 6- Veine teaches the head restraint as claimed in claim 1, comprising a pivot locking mechanism (70, 72) operable to inhibit or restrict pivoting movement of the head support about the pivot axis (¶ 32). Claim 7- Veine teaches the head restraint as claimed in claim 6, wherein the pivot locking mechanism (70, 72) is operable to lock the head support in a predetermined orientation relative to the head restraint mounting assembly (¶ 32), wherein a release mechanism (66) is provided for releasing the pivot locking mechanism (¶ 32). Claim 8- Veine teaches a seat assembly comprising a seatback (12), a lower seat portion (not shown), and the head restraint (10) as claimed in claim 1, wherein the actuating cable (64) is attached to a second anchor point (defined by the release mechanism 66) disposed on the seatback or the lower seat portion (¶ 31-32). Claim 9- Veine teaches the seat assembly as claimed in claim 8, wherein a height of the head restraint (10) is adjustable relative to the seatback (figs. 3-5), the actuating cable (64) being operable to pivot the head support based at least in part on the height of the head restraint (Veine discloses that the head support is pivoted when at its maximum height in the head restraint design position, fig. 3). Claim 10- Veine teaches the seat assembly as claimed in claim 8, wherein the seatback (12) is pivotable relative to the lower seat portion (according to the seat recline or seat folding operations disclosed, ¶ 32), the actuating cable being operable to pivot the head support based at least in part on a pivot angle of the seatback relative to the lower seat portion (Veine discloses changing the angle of the seatback via a recline or folding mechanism actuates the cable for pivoting the head support, ¶ 32). Claim 11- Veine teaches a seat assembly comprising a seatback (12), a lower seat portion (not shown), and the head restraint as claimed in claim 1, wherein the seat assembly comprises a pivot control actuator (release mechanism 66) for actuating the actuating cable (64) to control pivoting of the head support about the pivot axis (¶ 31-32). Claim 12- Veine teaches a vehicle (¶ 1) comprising the seat assembly according to claim 8. Claim 13- Veine teaches a seat assembly comprising a seatback (12), a lower seat portion (not shown) and a head restraint, the head restraint comprising: a head support (16); a head restraint mounting assembly (18) for mounting the head restraint to the seatback, the head restraint mounting assembly comprising a first mounting stem (the assembly 18 is an arch-shaped bar comprising a pair of opposing vertical stems coupled by a crossbar), wherein the head support is pivotably mounted to the head restraint mounting assembly (at the crossbar); and an actuating cable (64) configured to control pivoting of the head support about a pivot axis (the pivot axis is defined by the upper crossbar of the mounting assembly 18); wherein the pivot axis is disposed proximal to an end of the head support which is disposed adjacent to the seatback (figs. 1-2 show the upper crossbar of the assembly 18 is proximal to the lower end of the head support 16), wherein the actuating cable is attached to the head support at a first anchor point which is offset vertically from the pivot axis (fig. 10 shows an end of the cable 64 is anchored by the wedge 68 which is located below the crossbar of the support member 18, and an intermediate portion of the cable is anchored by the lever arm 62 above the crossbar), and is attached to a second anchor point (defined by the release mechanism 66) disposed on the seatback or the lower seat portion (¶ 31-32), and wherein the head support is configured to pivot in dependence on changes in a vertical position of the restraint relative to the seatback (¶ 21). Venice states (¶ 21) that the head support can be rotated and translated via the mounting assembly (support members 18), wherein rotation occurs during translation and wherein this adjustment can be achieved manually or by a mechanism. Venice teaches that the head support comprising the actuating cable (fig. 10) operates like the head support in figures 3-5 (¶ 31), wherein the head support movement is actuated by adjustment of a seat component (¶ 32). Venice’s teaching (¶ 31) would suggest to a person of ordinary skill that the head restraint comprising an actuating cable could be configured to control the pivoting of the head support via the height adjustment of the mounting assembly (18). Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the head support actuated by a cable to be pivotable according to the height position, in order to provide an automatic positioning of the head restraint. Claim 14- Veine teaches the seat assembly as claimed in claim 13, wherein a height of the head restraint (10) is adjustable relative to the seatback (figs. 3-5), the actuating cable (64) being operable to pivot the head support based at least in part on the height of the head restraint (Veine discloses that the head support is pivoted when at its maximum height in the head restraint design position, fig. 3). Claim 15- Veine teaches the seat assembly as claimed in claim 13, wherein a height of the head restraint is adjustable relative to the seatback by relative movement of the first mounting stem with respect to the seatback (Veine discloses the mounting assembly 18, including the first stem, is withdrawn into the seatback, ¶ 32), wherein the actuating cable (64) is operable to pivot the head support based at least in part on the height of the head restraint (Veine discloses that the head support is pivoted when at its maximum height in the head restraint design position, fig. 3), and wherein pivoting of the head support with respect to the first mounting stem toward a deployed position (design position, fig. 3) is independent of relative movement between the seatback and the lower seat portion (Veine discloses that a user can manually raise and pivot the head support from the stowed position shown in fig. 5, ¶ 32). Claim 16- Veine teaches the seat assembly as claimed in claim 15, wherein the head restraint comprises a pivot locking mechanism (70, 72) operable to inhibit or restrict pivoting movement of the head support about the pivot axis (¶ 32), wherein the pivot locking mechanism is operable to lock the head support in a predetermined orientation relative to the head restraint mounting assembly (¶ 32), wherein the predetermined orientation corresponds to the deployed position (design position) of the head support (fig. 3). Claim 20- Veine teaches a vehicle (¶ 1) comprising the seat assembly as claimed in claim 13. Allowable Subject Matter Claims 17-19 are allowed. 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 TANIA ABRAHAM whose telephone number is (571)272-2635. The examiner can normally be reached 9 am - 5:30 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, DAVID DUNN can be reached at 571-272-6670. 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. /T.A/Examiner, Art Unit 3636 /DAVID R DUNN/Supervisory Patent Examiner, Art Unit 3636
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Prosecution Timeline

Jul 25, 2023
Application Filed
Jun 14, 2025
Non-Final Rejection — §103
Sep 18, 2025
Response Filed
Oct 02, 2025
Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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

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Prosecution Projections

3-4
Expected OA Rounds
72%
Grant Probability
89%
With Interview (+17.3%)
2y 9m
Median Time to Grant
Moderate
PTA Risk
Based on 813 resolved cases by this examiner. Grant probability derived from career allow rate.

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