Prosecution Insights
Last updated: April 19, 2026
Application No. 18/518,485

EMERGENCY FLOTATION DEVICE USING COMPRESSED GAS

Final Rejection §112
Filed
Nov 23, 2023
Examiner
POLAY, ANDREW
Art Unit
3615
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Sea Ark Technologies Ltd.
OA Round
4 (Final)
74%
Grant Probability
Favorable
5-6
OA Rounds
2y 5m
To Grant
95%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allow Rate
654 granted / 881 resolved
+22.2% vs TC avg
Strong +21% interview lift
Without
With
+21.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
42 currently pending
Career history
923
Total Applications
across all art units

Statute-Specific Performance

§101
1.2%
-38.8% vs TC avg
§103
37.0%
-3.0% vs TC avg
§102
28.6%
-11.4% vs TC avg
§112
28.6%
-11.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 881 resolved cases

Office Action

§112
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 . Claim amendments were received from Applicant on 12 Nov 2025. Claims 38, 39, 42-48 are amended. Claims 38-48 are pending. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the “facing member” must be shown or the feature(s) canceled from the claim(s).(The scope of these parts is not clear and should be separately labeled.) No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Specification The specification is objected to as failing to provide proper antecedent basis for the claimed subject matter. See 37 CFR 1.75(d)(1) and MPEP § 608.01(o). “Facing member” does not appear in the specification. Claim Rejections - 35 USC § 112b The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 38-44 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim limitation “facing member” invokes 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. However, the written description fails to disclose the corresponding structure, material, or acts for performing the entire claimed function and to clearly link the structure, material, or acts to the function. The term “facing member” is not in the specification. Therefore, the claim is indefinite and is rejected under 35 U.S.C. 112(b) or pre-AIA 35 U.S.C. 112, second paragraph. Applicant may: (a) Amend the claim so that the claim limitation will no longer be interpreted as a limitation under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph; (b) Amend the written description of the specification such that it expressly recites what structure, material, or acts perform the entire claimed function, without introducing any new matter (35 U.S.C. 132(a)); or (c) Amend the written description of the specification such that it clearly links the structure, material, or acts disclosed therein to the function recited in the claim, without introducing any new matter (35 U.S.C. 132(a)). If applicant is of the opinion that the written description of the specification already implicitly or inherently discloses the corresponding structure, material, or acts and clearly links them to the function so that one of ordinary skill in the art would recognize what structure, material, or acts perform the claimed function, applicant should clarify the record by either: (a) Amending the written description of the specification such that it expressly recites the corresponding structure, material, or acts for performing the claimed function and clearly links or associates the structure, material, or acts to the claimed function, without introducing any new matter (35 U.S.C. 132(a)); or (b) Stating on the record what the corresponding structure, material, or acts, which are implicitly or inherently set forth in the written description of the specification, perform the claimed function. For more information, see 37 CFR 1.75(d) and MPEP §§ 608.01(o) and 2181. Response to Arguments Applicant's arguments filed 12 Nov 2025 have been fully considered but they are not persuasive. Applicant argues that “facing member” does not invoke 112f because “by defining the position of the member within the device structure, as clearly shown in Fig. 1 of the drawings, constitutes a clear structural limitation.” Examiner disagrees that the term “facing member” is defined by the drawing nor that the scope elements that make up the structure of a “facing member” clear. Definitions can be articulated, like in the dictionary. Definitions that cannot be articulated are not definitions that can form a claim boundary within the scope of 112b. If the definition is “any means facing” or “any member for facing” or “any structure for facing” it’s interpreted under 112f and must have the corresponding structure in the specification in order to be definite. Applicant’s alternative argument “that the term "facing member" is self-explanatory; defines primarily the position of the member in the device, as is evident from its literal meaning” is not a definition. Like the Emperor’s New Clothes, a suggestion that a PHOSITA could find the definition is not persuasive evidence of the definition. Evidence that the Examiner is attempting to apply art to an ambiguous claim is evidence that Examiner is applying MPEP 2173.06 (103 and 112b rejections should both be made) but is not persuasive evidence that evidence that the claim language is sufficiently clear for 112b purposes. The Examiner maintains the rejection. Allowable Subject Matter Claims 45-48 are 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. Applicant may also wish to file a CON (See MPEP 1895) if Applicant wished to further define the features in the specification with a higher level of abstraction. Conclusion THIS ACTION IS MADE FINAL. 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 ANDREW POLAY whose telephone number is (408)918-9746. The examiner can normally be reached M-F 9-5 Pacific. 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, Joe Morano can be reached at 5712726684. 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. /ANDREW POLAY/Primary Examiner, Art Unit 3615 2 Dec 2025
Read full office action

Prosecution Timeline

Nov 23, 2023
Application Filed
Apr 03, 2024
Non-Final Rejection — §112
Oct 08, 2024
Response Filed
Nov 01, 2024
Final Rejection — §112
Apr 07, 2025
Response after Non-Final Action
Jul 28, 2025
Request for Continued Examination
Aug 01, 2025
Response after Non-Final Action
Aug 09, 2025
Non-Final Rejection — §112
Nov 12, 2025
Response Filed
Dec 02, 2025
Final Rejection — §112 (current)

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

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Prosecution Projections

5-6
Expected OA Rounds
74%
Grant Probability
95%
With Interview (+21.1%)
2y 5m
Median Time to Grant
High
PTA Risk
Based on 881 resolved cases by this examiner. Grant probability derived from career allow rate.

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