DETAILED ACTION
This Office Action is in response to the Supplemental Amendment filed on 28 August 2026 in response to the RCE filed on 29 July 2026.
Response to Arguments
Applicant’s arguments and amendments with respect to the 112 rejection have been fully considered and are persuasive. The 112 rejection of Claim 19 has been withdrawn.
Applicant’s arguments and amendments with respect to the Prior Art rejections have been considered but are moot because the amendment(s) have necessitated a new ground(s) of rejection [see rejection below].
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 9-17, 30, 32 and 34-36 are rejected under 35 U.S.C. 103 as being unpatentable over US Patent # 12,289,079 to Schuit [with an effective filing date of 03 August 2015] in view of US Patent # 9,893,677 to Liu.
Regarding claim 9, Schuit teaches a mounting system for solar modules (Column 30, Line 35), the system comprising: a pair of mounting rails (Column 30, Line 37), each rail configured to support a plurality of solar modules (Column 30, Line 38) in a first row (Column 30, Line 38) along an interior portion of each of the solar modules in the first row (Column 30, Lines 41-42); a single mounting rail [at least one additional mounting rail (Column 30, Line 45)] configured to support a second row of solar modules (Column 30, Lines 45-46); and a skip rail splice [edge splice (Column 30, Line 50)] configured to connect a first solar module in the first row to a first solar module in the second row (Column 30, Lines 50-51). Schuit does not recite a first mounting rail positioned under a first half of the interior portion of each of the solar modules in the first row or a second mounting rail positioned under a second half of the interior portion of the solar modules in the second row. However, Liu teaches in Figure 16 [annotated below], a first mounting rail (24) positioned under a first half of an interior portion of each solar module (17 and 17”) in a first row (A), and wherein a second mounting rail (24’) is positioned under a second half of an the interior portion of the solar modules (17 and 17”) in the first row (A); wherein a third mounting rail (24”) is positioned under a second half of each solar module (17’) in a second row (B); and a skip rail splice (18) is configured to connect a top edge of a first solar module (17”) in the first row (A) to a bottom edge of a first solar module (17’) in the second row (B). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Schuit with Liu and have a reasonable expectation of success because the arrangement of Liu evenly supports the solar modules.
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Regarding claim 10, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches the first mounting rail is parallel to the second mounting rail (Column 30, Lines 40-41), and wherein the second mounting rail is further parallel to the single mounting rail (Colum 29, Lines 51-54).
Regarding claim 11, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches the first mounting rail, the second mounting rail, and the single mounting rail are parallel to a bottom edge [first edge] of the first row of solar modules (Column 29, Lines 61-63).
Regarding claim 12, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Liu teaches in Figure 16 [annotated above], the skip rail splice (18) is further configured to connect two solar modules (17 and 17”) in the first row (A) to two solar module (17’ and 17”’) in the second row (B). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Schuit with Liu and have a reasonable expectation of success because Liu teaches the skip rail splice ties together the solar modules (Column 10, Lines 17-18).
Regarding claim 13, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Liu teaches in Figure 16 [annotated above], the skip rail splice (18) is further configured to connect one solar module (17) in the first row (A) to two solar module (17’ and 17”’) in the second row (B). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Schuit with Liu and have a reasonable expectation of success because Liu teaches the skip rail splice ties together the solar modules (Column 10, Lines 17-18).
Regarding claim 14, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches one or more clamps (Column 31, Line 15) to attach a solar module in the first row to one or more of the first mounting rail and the second mounting rail (Column 31, Lines 15-16).
Regarding claim 15, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches one or more mounts [attached (Column 30, Line 37)] configured to attach one or more of the first mounting rail, the second mounting rail, and the single mounting rail to a roof surface (Column 30, Line 37 and Column 31, Lines 13-14).
Regarding claim 16, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches in Figure 44, the solar modules in the first row [East-West] are arranged in portrait orientation along the pair of mounting rails, and wherein the solar modules in the second row are arranged in portrait orientation along the single mounting rail.
Regarding claim 17, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches in Figure 44, the solar modules in the first row [North-South] are arranged in landscape orientation along the pair of mounting rails, and wherein the solar modules in the second row are arranged in landscape orientation along the single mounting rail.
Regarding claim 30, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Liu teaches in Figure 16 [annotated above], the skip rail splice (18) is further configured to connect two solar modules (17 and 17”) in the first row (A) to one solar module (17’) in the second row (B). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Schuit with Liu and have a reasonable expectation of success because Liu teaches the skip rail splice ties together the solar modules (Column 10, Lines 17-18).
Regarding claim 32, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches the edge splice is laterally displaced (Column 30, Line 52) from the pair of mounting rails and from the single mounting rail (Column 30, Lines 50-53).
Regarding claim 34, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches the single mounting rail is positioned along an interior portion of each of the solar modules in the second row (Column 30, Lines 46-49).
Regarding claim 35, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Liu teaches in Figure 16 [annotated above], the single mounting rail (24”) is positioned along an interior portion of each of the solar modules (17’ and 17”’) in the second row (B). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine Schuit with Liu and have a reasonable expectation of success because Liu teaches
Regarding claim 36, Schuit in view of Liu teach a mounting system for solar modules. Furthermore, Schuit teaches in Figure 44, a length of the first edge of one of the solar modules in the first row is different [it is translated one panel width to the right] than a length of a first edge of one of the solar modules in the second row.
Claims 18, 19 and 31 are rejected under 35 U.S.C. 103 as being unpatentable over US Patent # 12,289,079 to Schuit in view of US Patent # 9,893,677 to Liu in further view of US Patent Application Publication # 2014/0026946 to West et al.
Regarding claim 18, Schuit in view of Liu teach a mounting system for solar modules but they only show mounting the solar modules in a single orientation, not portrait in the first row and landscape in the second row. However, West teaches that PV modules can be oriented in either portrait or landscape orientation (Paragraph 0253). It would have been obvious to one of ordinary skill in the art to combine the mounting device of Schuit in view of Liu with the attachment apparatus of West with a reasonable expectation of success because West teaches it would have been obvious to mount the PV modules in portrait orientation instead of landscape (Paragraph 0253). In the instant case, an array with portrait oriented solar modules would take up less space horizontally than an array with landscape oriented modules, thus being able to customize the array based on the size of the roof and maximize energy output of the array given the size of the roof.
Regarding claim 19, Schuit in view of Liu teach a mounting system. Furthermore, Liu teaches in Figure 16 [annotated above], the first solar module (17) and the second solar module (17’) connected by the skip rail splice (18) are respectively at an end of the first row (A) and the second row (B), and further comprising a second skip rail splice (52) [splice (Column 10, Line 52)]. Liu does not teach the second skip rail splice connects a top edge of a third solar module in the first row to a bottom edge of a fourth solar module in the second row. However, West teaches in Figure 31, a second skip rail splice (50bb) configured to connect a top edge of a third solar module (211B) in a first row to a bottom edge of a fourth solar module (211C) in a second row, wherein the third solar module (211B) and the fourth solar module (211C) are respective in a middle of the first row and the second row. It would have been obvious to one of ordinary skill in the art to combine the mounting device of Schuit in view of Liu with the attachment apparatus of West with a reasonable expectation of success because the array of West has more modules than that of Liu, thus being able to produce more power.
Regarding claim 31, Schuit in view of Liu teach a mounting system for solar modules but they only show mounting the solar modules in a single orientation, not landscape in the first row and portrait in the second row. However, West teaches that PV modules can be oriented in either portrait or landscape orientation (Paragraph 0253). It would have been obvious to one of ordinary skill in the art to combine the mounting device of Schuit in view of Liu with the attachment apparatus of West with a reasonable expectation of success because West teaches it would have been obvious to mount the PV modules in portrait orientation instead of landscape (Paragraph 0253). In the instant case, an array with portrait oriented solar modules would take up less space horizontally than an array with landscape oriented modules, thus being able to customize the array based on the size of the roof and maximize energy output of the array given the size of the roof.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANDREW J TRIGGS whose telephone number is (571)270-3657. The examiner can normally be reached Mon-Thurs 6am-2pm EST.
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/ANDREW J TRIGGS/Primary Examiner, Art Unit 3635
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