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 .
Response to Amendment
The Amendment filed 1/29/2026 has been entered. Claims 1-2, 6-17 and 19-24 remain pending in the application. Applicant’s amendments to the Claims have overcome every objection and 112(b) rejection previously set forth in the Non-Final Office Action mailed 11/4/2025. Examiner further acknowledges citation of “Crashworthiness design of vehicle side door beams under low-speed pole side impacts” and where this Non-Patent Literature was cited. The reference has been considered.
Claim Rejections - 35 USC § 102
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claims 1-2, 11, 14 and 21-23 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Harrington (US 2023/0302880).
Regarding claim 1, Harrington discloses a vehicle side door assembly (12, Fig. 3; para. [0028]), comprising a first beam (32, Fig. 3 & 6); a second beam (30, Fig. 3 & 6); and a bolster (14, Fig. 3 & 6) spanning from the first beam (32, Fig. 3 & 6) to the second beam (30, Fig. 3 & 6), the bolster (14, Fig. 3 & 6; para. [0036]) directly attached (F1, F2; Fig. 3) to both the first beam and the second beam using a plurality of mechanical fasteners (F1, F2; Fig. 3) that extend through the bolster to engage the first beam or the second beam.
Regarding claim 2, Harrington further discloses wherein the first beam (32, Fig. 3) is a vertically upper beam (para. [0033], lines 4-7), and the second beam (30, Fig. 3) is a vertically lower beam (vertically lower in reference to the ground in a general orientation of the side door 12), wherein at least one of the mechanical fasteners (F2) extends through a first aperture (on end 54, Fig. 3-8; para. [0050]) in the bolster into the vertically upper beam (32, Fig. 3), and at least one the mechanical fasteners (F1) extends through a second aperture (60, Fig. 3-8; para. [0048], lines 1-3) in the bolster into the vertically lower beam (30, Fig. 3).
Regarding claim 11, Harrington further discloses a side door inner panel (22, Fig. 2; para. [0030]) and a side door outer panel (20, Fig. 2), wherein the first beam (32, Fig. 2), the second beam (30, Fig. 2), and the bolster (14, Fig. 2) are disposed between the side door inner panel (22, Fig. 2; [0046], lines 1-4) and the side door outer panel (20, Fig. 2).
Regarding claim 14, Harrington further discloses a snap-fit feature (para. [0045], F1, F2) of the bolster (14, Fig. 3 & 6) configured to snap-fit the bolster to the first beam (32, Fig. 3 & 6) or the second beam (30, Fig. 3 & 6; para. [0043], lines 1-3).
Regarding claim 21, Harrington discloses a vehicle side door assembly, comprising an upper beam (32, Fig. 3); a lower beam (30, Fig. 3); a bolster (14, Fig. 3) spanning from the upper beam (32, Fig. 3) to the lower beam (30, Fig. 3) such that a portion of the bolster (14 end of 54/F2, Fig. 3 & 6) vertically overlaps with the upper beam and another portion of the bolster (14 end of 52/F1, Fig. 3 & 6) vertically overlaps with the lower beam; and a snap-fit feature (para. [0045], F1, F2) of the bolster configured to snap-fit the bolster to the upper beam or the lower beam (F1, Fig. 6-8).
Regarding claim 22, Harrington further discloses a first mechanical fastener (F2, Fig. 3-8) that extends through a first aperture (on end 54, Fig. 3-8; para. [0050]) in the bolster and into the upper beam (32, Fig. 5), and a second mechanical fastener (F1, Fig. 3-8) that extends through a second aperture (60, Fig. 3-8; para. [0048], lines 1-3) in the bolster and into the lower beam (30, Fig. 5).
Regarding claim 23, Harrington further discloses wherein the first (on end 54 of bolster 14, Fig. 3 & 6) and second (60 on end 52 of bolster 14, Fig. 3 & 6) apertures are defined by polymer-based portions (14; para. [0037], lines 7-9) of the bolster (para. [0037], lines 1-5; entire member 14 including 50, 52, 54 is a unitary, homogenous element of a polymer-based material).
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.
Claims 1-2, 11 and 14-15 are rejected under 35 U.S.C. 103 as being unpatentable over Huttsell et al (US Patent No. 7,857,375) in view of Harrington (US 2023/0302880).
Regarding claim 1, Huttsell et al discloses a vehicle side door assembly (102, Fig. 1-2; column 4, lines 5-14), comprising a first beam (116, Fig. 1-2; column 4, lines 43-59); a second beam (114, Fig. 1-2); and a bolster (150, Fig. 1-2; column 6, lines 10-18) spanning from the first beam (116, Fig. 2) to the second beam (114, Fig. 2). However, Huttsell et al does not expressly disclose the bolster directly attached to both the first beam and the second beam using a plurality of mechanical fasteners that extend through the bolster to engage the first beam or the second beam.
Harrington teaches a vehicle side door assembly (12, Fig. 3; para. [0028]) having a bolster (14, Fig. 3 & 6; para. [0036]) directly attached (F1, F2; Fig. 3) to both the first beam (32, Fig. 3 & 6) and the second beam (30, Fig. 3 & 6) using a plurality of mechanical fasteners (F1, F2; Fig. 3) that extend through the bolster (on end 54, Fig. 3-8; para. [0050] and 60, Fig. 3-8; para. [0048], lines 1-3) to engage the first beam (32, Fig. 3 & 6) or the second beam (30, Fig. 3 & 6) in the analogous field of the claimed invention of vehicle side door reinforcement devices.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the side door assembly of Huttsell et al by incorporating the type of bolster fastening as taught by Harrington. Doing so would securely connect the bolster to first and second reinforcement beams in a side door assembly.
Regarding claim 2, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 1 above, and Huttsell et al in view of Harrington further discloses wherein the first beam (Huttsell et al -116, Fig. 1-2) is a vertically upper beam (Huttsell et al - column 4, lines 43-59), and the second beam (Huttsell et al - 114, Fig. 1-2) is a vertically lower beam (Huttsell et al - column 4, lines 43-59), wherein at least one of the mechanical fasteners (Harrington - F2) extends through a first aperture (Harrington - on end 54, Fig. 3-8; para. [0050]) in the bolster into the vertically upper beam (Harrington - 32, Fig. 3), and at least one of the mechanical fasteners (Harrington - F1) extends through a second aperture (Harrington - 60, Fig. 3-8; para. [0048], lines 1-3) in the bolster into the vertically lower beam (Harrington - 30, Fig. 3).
Regarding claim 11, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 1 above, and Huttsell et al further discloses a side door inner panel (108, 104, Fig. 1 & 5-6; column 4, lines 16-18) and a side door outer panel (106, 107, Fig. 1 & 5-6; column 4, lines 15-16), wherein the first beam (116, Fig. 1 & 5-6), the second beam (114, Fig. 1 & 5-6), and the bolster (150, Fig. 1 & 5-6) are disposed between the side door inner panel (108, Fig. 1 & 5-6) and the side door outer panel (106, Fig. 1 & 5-6).
Regarding claim 14, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 1 above, and Harrington further discloses a snap-fit feature (para. [0045], F1, F2) of the bolster (14, Fig. 3 & 6) configured to snap-fit the bolster to the first beam (32, Fig. 3 & 6) or the second beam (30, Fig. 3 & 6; para. [0043], lines 1-3).
Regarding claim 15, Huttsell et al discloses a method of managing loads within a vehicle side door (collision absorption system 100, Fig. 1; column 4, lines 1-14), comprising receiving a load at a side door of a vehicle (column 3, lines 62-65); and distributing at least some of the load through a bolster (150, Fig. 1-2; column 6, lines 10-18) that spans between a first beam (116, Fig. 2; column 4, lines 43-59) and a second beam (114, Fig. 2) of the side door (102, Fig. 1; column 4, lines 5-14) and the bolster (150, Fig. 2) mechanically fastened directly to both the first beam (116 at 186, Fig. 2-3) and the second beam (114 at 187, Fig. 2-4) using a plurality of mechanical fasteners (181-183, Fig. 1-4; column 7, lines 60-67). Braces (186 & 187, Fig. 2-4) are part of the bolster (150, Fig. 2-4) therefore forming a direct attachment (fastened directly) to both beams (column 6, lines 15-18 and column 8, lines 1-3). However, Huttsell et al does not expressly disclose the bolster snap-fit directly to at least one of the first beam or the second beam.
Harrington teaches a vehicle side door assembly (12, Fig. 3; para. [0028]) where the bolster is snap-fit (para. [0045], F1, F2) directly to at least one of the first beam (32, Fig. 3 & 6) or the second beam (30, Fig. 3 & 6; para. [0043], lines 1-3) in the analogous field of the claimed invention of vehicle side door reinforcement devices.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the side door assembly of Huttsell et al by incorporating the type of bolster fastening as taught by Harrington. Doing so would provide a convenient way to connect the bolster to first and second impact beams in a side door assembly.
Claims 6-8, 10, 17 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Huttsell et al (US Patent No. 7,857,375) in view of Harrington (US 2023/0302880) further in view of Yagishita et al (US Patent No. 5,934,730).
Regarding claim 6, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 1 above. However, Huttsell et al in view of Harrington does not expressly disclose wherein the bolster has an inboard side having an array of inboard pockets and an outboard side having an array of outboard pockets.
Regarding claim 10, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 1 above. However, Huttsell et al in view of Harrington does not expressly disclose wherein the bolster has an inboard side having a grid of inboard ribs and an outboard side having an array of outboard ribs.
Regarding claim 17, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 15 above. However, Huttsell et al in view of Harrington does not expressly disclose wherein the bolster includes an array of inboard pockets on an inboard side of the bolster and an outboard array of pockets on an outboard side of the bolster.
Regarding claim 19, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 15 above. However, Huttsell et al in view of Harrington does not expressly disclose wherein the bolster has an inboard side having a grid of inboard ribs and an outboard side having a grid of outboard ribs.
Yagishita et al teaches a vehicle side door energy absorbing bolster (44, Fig. 22-26) wherein the bolster (44, Fig. 22-26) has an inboard side (1st energy absorbing portion 45, Fig. 22-26) having an inboard grid of ribs (47-50, Fig. 22-26) and array of pockets (hollow chambers formed by rib walls 47-50, Fig. 22-26) and an outboard side (2nd energy absorbing portion 46, Fig. 22-26) having an outboard grid of ribs (47-50, 48A, 50A, Fig. 22-26) and array of pockets (hollow chambers formed by rib walls 47-50, 48A, 50A, Fig. 22-26) in the analogous field of the claimed invention of vehicle side door reinforcement devices.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the bolster of Huttsell et al in view of Harrington to include the inboard and outboard ribs and pockets as taught by Yagishita et al. Doing so would enhance the door inner panel to absorb collision energy (column 10, lines 55-56) and would allow adjustment of the total energy absorption amount by having different arrays of pockets (column 10, lines 62-67 to column 11, lines 1-2).
Regarding claim 7, Huttsell et al in view of Harrington further in view of Yagishita et al discloses all of the claimed limitations of the invention as claimed in claim 6 above and Yagishita et al further discloses wherein the inboard pockets (hollow chambers in 45, Fig. 22-26) and the outboard pockets (hollow chambers in 46, Fig. 22-26) have a rectangular profile (Fig. 22-26).
Regarding claim 8, Huttsell et al in view of Harrington further in view of Yagishita et al discloses all of the claimed limitations of the invention as claimed in claim 6 above including the bolster having an array of inboard pockets (Yagishita et al - hollow chambers in 45, Fig. 22-26) and an array of outboard pockets (Yagishita et al - hollow chambers in 46, Fig. 22-26). Huttsell et al further discloses the bolster (150, Fig. 2-3 & 5-6) having a first bolster section (152, Fig. 2-3 & 5-6), a second bolster section (154, Fig. 2-3 & 5-6), and the first bolster section (152, Fig. 2-3 & 5-6) spaced a distance (via tapered portion 153, Fig. 2-3 & 5-6; column 6, lines 58-67) from the second bolster section (154, Fig. 2-3 & 5-6).
Claims 12 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Huttsell et al (US Patent No. 7,857,375) ) in view of Harrington (US 2023/0302880) further in view of Boettcher (US 2021/0138881).
Regarding claim 12, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 1 above and wherein the bolster (Huttsell et al - 150, Fig. 1-2) is a polymer-based material (Huttsell et al - column 7, lines 28-30; all plastics are polymers). However, Huttsell et al in view of Harrington does not expressly disclose wherein the first beam and the second beam are a metal or metal alloy.
Regarding claim 16, Huttsell et al in view of Harrington discloses all of the claimed limitations of the invention as claimed in claim 15 above wherein the bolster (150, Fig. 1-2) is polymer-based (column 7, lines 28-30; all plastics are polymers). However, Huttsell et al in view of Harrington does not expressly disclose that the first and second beams are a metal or metal alloy.
Boettcher teaches a door (58, Fig. 8) wherein the first beam (20/46 upper, Fig. 8) and the second beam (20/46 lower, Fig. 8) are a metal or metal alloy (2, Fig. 1A, aluminum alloy; [0021], lines 1-3) in the analogous field of the claimed invention of vehicle side door reinforcement devices.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the reinforcement beams of Huttsell et al in view of Harrington by substituting the first and second metal alloy beams as taught by Boettcher. Doing so would provide a material that has a high enough strength to meet impact performance requirements for door beams and is light weight thereby increasing fuel efficiency ([0020], lines 8-11).
Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Huttsell et al (US Patent No. 7,857,375) in view of in view of Harrington (US 2023/0302880) further in view of Boettcher (US 2021/0138881) as applied to claim 12 above, and further in view of Schmidt (US 2004/0113455).
Regarding claim 13, Huttsell et al in view of Harrington further in view of Boettcher discloses all of the claimed limitations of the invention as claimed in claim 12 above. However, Huttsell et al in view of Harrington further in view of Boettcher does not expressly disclose wherein the bolster is nylon.
Schmidt teaches a vehicle side door energy absorber wherein the bolster (24, Fig. 1-2) is made of nylon material ([0031], line 3; [0023], line 3; [0024], line 6) in the analogous field of the claimed invention of vehicle side door reinforcement devices.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the polymer-based bolster of Huttsell et al in view of Harrington further in view of Boettcher to include the polymer-based nylon material as taught by Schmidt. Doing so would enhance energy absorption and impact resistance and provide an environmental insulating barrier incorporated into the vehicle door assembly ([0023], lines 9-12).
Claim 24 is rejected under 35 U.S.C. 103 as being unpatentable over Harrington (US 2023/0302880) in view of Schmidt (US 2004/0113455).
Regarding claim 24, Harrington discloses all of the claimed limitations of the invention as claimed in claim 22 above, including wherein the first (on end 54 of bolster 14, Fig. 3 & 6) and second (60 on end 52 of bolster 14, Fig. 3 & 6) apertures are defined by polymer-based portions (14; para. [0037], lines 7-9) of the bolster (para. [0037], lines 1-5). However, Harrington does not expressly disclose nylon-based portions of the bolster.
Schmidt teaches a vehicle side door energy absorber wherein the bolster (24, Fig. 1-2) is made of nylon material ([0031], line 3; [0023], line 3; [0024], line 6) in the analogous field of the claimed invention of vehicle side door reinforcement devices.
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the polymer-based bolster of Harrington by substituting the polymer-based nylon material as taught by Schmidt. Doing so would enhance energy absorption and impact resistance and provide an environmental insulating barrier incorporated into the vehicle door assembly ([0023], lines 9-12).
Allowable Subject Matter
Claim 9 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims.
The following is a statement of reasons for the indication of allowable subject matter:
The primary reason for indication of allowable subject matter in claim 9 is the inclusion of the limitations “wherein first and second grids of inboard ribs respectively define the first and second arrays of inboard pockets, wherein first and second grids of outboard ribs define the first and second arrays of outboard pockets, and further comprising a connecting arm that connects the first bolster section to the second bolster section, the connecting arm lacking rib-defined cavities”. The closest prior art of Huttsell et al (US Patent No. 7,857,375) discloses a connecting arm (153 tapered portion between 152 & 154, Fig. 2-3 & 5-6; column 6, lines 58-67) that connects the first bolster section (152, Fig. 2-3 & 5-6) to the second bolster section (154, Fig. 2-3 & 5-6); however, Huttsell et al does not disclose the connecting arm as defined by applicant’s claim 9 and Figure 5. Applicant’s connecting arm joins the first bolster section spaced a distance from the second bolster section in which each bolster includes separate and distinct arrays of pockets on the inboard side and separate and distinct arrays of pockets on the outboard side to help absorb loads applied to the side door. Such limitations, in combination with the rest of the limitations of the claim, are not disclosed or suggested by the prior art of record.
Response to Arguments
Applicant's arguments filed 1/29/2026 have been fully considered but they are not persuasive. Applicant’s arguments with respect to claims 1, 2 and 15 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. The prior art of Harrington (US 2023/0302880) discloses a bolster (14, Fig. 3 & 6; para. [0036]) with direct attachment (F1, F2; Fig. 3), using a plurality of mechanical fasteners (F1, F2; Fig. 3) that extend through a first aperture (on end 54, Fig. 3-8; para. [0050]) in the bolster into the upper beam (32, Fig. 3), and through a second aperture (60, Fig. 3-8; para. [0048], lines 1-3) in the bolster into the lower beam (30, Fig. 3), as well as a snap-fit feature (para. [0045], F1, F2) to snap-fit the bolster to the first beam (32, Fig. 3 & 6) or second beam (30, Fig. 3 & 6; para. [0043], lines 1-3). Applicant’s amended claims are directed to claiming mechanical fasteners, snap-fit fastening, and fasteners through openings to connect a bolster to vehicle side door beams. Such ways of connecting elements are notoriously well known in the art and are functional equivalents for various known benefits. Fastening means (including bolts, screws, nuts, rivets, welds, anchors, clips, snap-fit, etc.) are interchangeable as they serve a functional similarity to connect parts. Such use of one type of fastener for another would be obvious to one of ordinary skill in the art and does not constitute a step forward.
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.
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/DLE/
/AMY R WEISBERG/Supervisory Patent Examiner, Art Unit 3612