Prosecution Insights
Last updated: April 19, 2026
Application No. 18/521,645

RECLINING DEVICE FOR VEHICLE SEAT

Final Rejection §102
Filed
Nov 28, 2023
Examiner
NELSON JR, MILTON
Art Unit
3636
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Hyundai Transys Inc.
OA Round
2 (Final)
85%
Grant Probability
Favorable
3-4
OA Rounds
2y 2m
To Grant
90%
With Interview

Examiner Intelligence

Grants 85% — above average
85%
Career Allow Rate
1555 granted / 1839 resolved
+32.6% vs TC avg
Moderate +6% lift
Without
With
+5.7%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 2m
Avg Prosecution
31 currently pending
Career history
1870
Total Applications
across all art units

Statute-Specific Performance

§101
1.1%
-38.9% vs TC avg
§103
26.9%
-13.1% vs TC avg
§102
30.3%
-9.7% vs TC avg
§112
39.1%
-0.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1839 resolved cases

Office Action

§102
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 . Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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 person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claim(s) 12 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Nithammer et al (US4591207). Note a reclining device for a vehicle seat (see the abstract), the reclining device comprising: a rotary bracket (16) having a center portion (see Figure 1, where the slot 18 is located along the longitudinal center line, i.e. a center portion) thereof rotatably connected to a first frame (11) and having a first locking section (an engaging position along 25) and a second locking section (another engaging position along 25) connected to the first locking section (see lines 60-62 in column 3); and a cam (19) configured to rotate about a center portion (at 21) thereof which is connected to the first frame and having a locking portion (23) disposed at one end thereof and disposed in the first locking section or the second locking section to be locked (depending on displacement of 16 on either side of its center position, as discussed in lines 60-62 in column 3), wherein a second pressure angle at which the locking portion is locked in the second locking section is smaller than a first pressure angle at which the locking portion is locked in the first locking section (see Figure 1), and wherein the center portion of the rotary bracket is rotatably connected to the first frame by a first hinge shaft (17), and the center portion of the cam and a center portion of a lever are rotatably connected to the first frame by a second hinge shaft (21). Allowable Subject Matter Claims 1-6 and 8-11 are allowed. Response to Amendment/Arguments Applicant’s response filed March 3, 2026 has been fully considered. Remaining issues are described above. Applicant has provided a new claim 12 and indicates that the claim includes the allowable subject matter of claim 8 as originally filed. Applicant is advised that substantial limitations of original claim 8, i.e. those provided by intervening claims 2, 4, 5, and 6, have not been included. As such, new claim 12 does not correspond to claim 8 as originally filed. Prior art has been applied to claim 12 as described above. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. A locking recliner assembly for a vehicle seat is shown by Boltze et al (US6598938). 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 MILTON NELSON JR whose telephone number is (571)272-6861. The examiner can normally be reached M-F 5:30am-1:30pm. 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. 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. mn /MILTON NELSON JR/March 13, 2026 Primary Examiner, Art Unit 3636
Read full office action

Prosecution Timeline

Nov 28, 2023
Application Filed
Nov 25, 2025
Non-Final Rejection — §102
Mar 03, 2026
Response Filed
Mar 13, 2026
Final Rejection — §102 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12600271
CHILD RESTRAINT
2y 5m to grant Granted Apr 14, 2026
Patent 12600267
INDICATING MECHANISM, SUPPORTING LEG HAVING INDICATING MECHANISM, AND CARRIER HAVING SUPPORTING LEG
2y 5m to grant Granted Apr 14, 2026
Patent 12600274
CONNECTING ASSEMBLY AND BABY SEAT
2y 5m to grant Granted Apr 14, 2026
Patent 12582234
SEATING ARRANGEMENT
2y 5m to grant Granted Mar 24, 2026
Patent 12570188
CHILD RESTRAINT
2y 5m to grant Granted Mar 10, 2026
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
85%
Grant Probability
90%
With Interview (+5.7%)
2y 2m
Median Time to Grant
Moderate
PTA Risk
Based on 1839 resolved cases by this examiner. Grant probability derived from career allow rate.

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