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 § 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.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claims 15-21, 26, and 28 are rejected under 35 U.S.C. 103 as being unpatentable over Ginestet et al. (US 20120306231 A1) in view of Ni (CN 106218370 A) and Ohba et al. (US 20130001982 A1).
Regarding claim 15, Ginestet discloses a reinforcement (Ginestet, 18 in Fig. 2) attachment arrangement (Ginestet, paragraph 23 and 47 described reinforcement attachment solutions) for a thermoplastic (Ginestet, paragraph 5) liftgate (Ginestet, Fig. 1-2, hinge attachment 30 is on the upper portion therefore making it a liftgate) comprising: a liftgate inner panel (Ginestet, 42 in Fig. 3) having an outer surface area (Ginestet, opposite side of Fig. 3, partially shown in Fig. 4) with a plurality of reinforcement areas (Ginestet, Fig. 4-9, areas in connection with reinforcement 18) each having at least one receiving portion defined by a bridge of material (Ginestet, paragraph 23 and 47, snap-riveting, screwing, or clipping, all have a bridge of material); a reinforcement (Ginestet, 18 in Fig. 2) connected to each respective one of the plurality of reinforcement areas (Ginestet, Fig. 4) of the liftgate inner panel, wherein each reinforcement includes at least one engagement tab (Ginestet, Fig. 5-9, reinforcement 18 has tabs/flanges that engages with inner panel 42) and each reinforcement further includes at least one aperture (Ginestet, paragraph 23 and 47, apertures for screw/riveting; also Fig. 4 shows triangular apertures form by 24 and 20), and a liftgate exterior panel (Ginestet, 6 in Fig. 1) connected to the liftgate inner panel (Ginestet, Fig. 5-9, at least through the reinforcement 18) and covering the reinforcement areas and each reinforcement (Ginestet, Fig. 1 and 5-9).
Ginestet fails to disclose at least one connection member extending from the outer surface area of the liftgate inner panel; at least one engagement tab received beneath the bridge of material of a respective one of the plurality of reinforcement areas; and at least one aperture that aligns with at least one connection member formed on an outer surface area of the liftgate inner panel to hold the reinforcement onto the outer surface area of the liftgate inner panel when the at least one engagement tab is positioned in engagement with the at least one receiving portion.
Ni teaches at least one connection member (Ni, Fig. 11, sleeve member around fastener 9, also shown in Fig. 13) extending from the outer surface area of the liftgate inner panel; at least one engagement tab (Ni, Fig. 11, engagement tab of reinforcement 4 where attachment means 9 is located) for engaging the at least one receiving portion (Ni, Fig. 11, engages an aperture receiving portion) of a respective one of the plurality of reinforcement areas; and at least one aperture (Ni, Fig. 11, aperture to hold the fastener 9) that aligns with at least one connection member formed on an outer surface area of the liftgate inner panel to hold the reinforcement onto the outer surface area of the liftgate inner panel when the at least one engagement tab is positioned in engagement with the at least one receiving portion (after combination, Ginestet already teaches using screws in paragraph 23, therefore the screws can be used at the tabs as taught by Ni such that the tabs engage with the receiving portion locations).
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Figure 1 Annotated Fig. 11 from Ni
Ni is considered to be analogous art because it is in the same field of vehicle door reinforcement attachment arrangement as Ginestet.
It would have been obvious to one of ordinary skill in the art before the earliest effective filing date of the claimed invention to have modified the arrangement as taught by Ginestet to incorporate the teachings of Ni with a reasonable expectation of success and use the attachment arrangement of Ni such that there is a connection member and the engagement tab engages with the receiving portions. Doing so provides strengthened connection between the reinforcement and the inner panel without the need to make additional contact interface structures since existing tabs can be utilized. Also allows the use of screw/bolt which is commonly available when other securing solutions are not available.
Ohba teaches a bridge of material (Ohba, 5a in Fig. 3) and the tab received beneath the bridge of material (Ohba, Fig. 3, tab of 10d beneath bridge of material 5a).
Ohba is considered to be analogous art because it is in the same field of vehicle door with bracket/plate member clipping attachments as Ginestet in view of Ni.
It would have been obvious to one of ordinary skill in the art before the earliest effective filing date of the claimed invention to have modified the arrangement as taught by Ginestet in view of Ni to incorporate the teachings of Ohba with a reasonable expectation of success and add the clip attachment of Ohba such that there’s a bridge of material. Doing so allows attachment without using tools and therefore provides more convenience in assembly; provides easy positioning means for adding additional securing means (screw, rivet, adhesives, etc.) after fastening the parts with the clips; and having additional connection makes the reinforcement more secured.
Regarding claim 16, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15 further comprising: wherein the at least one connection member is at least one fastener boss (Ni, see annotated Fig. 11, connection member can also be the fastener boss) formed on the outer surface area; a fastener (Ni, 9 in Fig. 11) extending through the at least one aperture of the reinforcement and connecting to the at least one fastener boss.
Regarding claim 17, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15, wherein the plurality of reinforcement areas include at least one hinge reinforcement area (Ginestet, Fig. 2, 30 is the hinge area).
Regarding claim 18, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15, wherein the plurality of reinforcement areas include at least one ball stud reinforcement area (Ginestet, Fig. 2, area 38 can be ball stud reinforcement area).
Regarding claim 19, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15, wherein the plurality of reinforcement areas include at least one latch reinforcement area (Ginestet, Fig. 2, 32 is the latch area).
Regarding claim 20, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15, wherein the at least one connection member is a snap tab (Ohba, 5b in Fig. 3) configured to slide through the at least one aperture of the reinforcement (Ohba, Fig. 3) and hold the reinforcement onto the outer surface area of the liftgate inner panel (Ohba, Fig. 3).
Ohba is considered to be analogous art because it is in the same field of vehicle door with bracket/plate member clipping attachments as Ginestet in view of Ni.
It would have been obvious to one of ordinary skill in the art before the earliest effective filing date of the claimed invention to have modified the arrangement as taught by Ginestet in view of Ni to incorporate the teachings of Ohba with a reasonable expectation of success and replace the connection member of Ni with the clip attachment of Ohba. Doing so allows attachment without using tools and therefore provides more convenience in assembly; also provides easy positioning means for adding additional securing means (screw, rivet, adhesives, etc.) after fastening the parts with the clips.
Regarding claim 21, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15, wherein at least one of the receiving portions has a key post (Ohba, 5 in Fig. 3) with a round head (Ohba, paragraph 36, circular head 5a) and stem (Ohba, Fig. 3, narrower body of 5), and at least one of the engagement tabs has a key hole (Ohba, 11b in Fig. 4) wherein the round head and stem align with and slide into (Ohba, paragraph 36, insert/slide from the side opening) the key hole to connect the reinforcement to the liftgate inner panel.
Ohba is considered to be analogous art because it is in the same field of vehicle door with bracket/plate member clipping attachments as Ginestet in view of Ni.
It would have been obvious to one of ordinary skill in the art before the earliest effective filing date of the claimed invention to have modified the arrangement as taught by Ginestet in view of Ni to incorporate the teachings of Ohba with a reasonable expectation of success and use the clip attachment of Ohba. Doing so allows attachment without using tools and therefore provides more convenience in assembly; also provides easy positioning means for adding additional securing means (screw, rivet, adhesives, etc.) after fastening the parts with the clips.
Regarding claim 26, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15 further comprising: wherein at least one of the receiving portions includes an aperture (Ginestet, paragraph 23 teaches screw/riveting, which would have apertures; Ni also teaches an aperture in Fig. 11) formed in the liftgate inner panel, wherein at least one of the engagement tabs (Ohba, 5b in Fig. 3 of a clipping device, Ginestet in paragraph 23 also teaches one can use clipping) frictionally slides (Ohba, paragraph 36, 5b is resilient therefore would frictionally slides into the aperture and secure there) into the aperture.
Ohba is considered to be analogous art because it is in the same field of vehicle door with bracket/plate member clipping attachments as Ginestet in view of Ni.
It would have been obvious to one of ordinary skill in the art before the earliest effective filing date of the claimed invention to have modified the arrangement as taught by Ginestet in view of Ni to incorporate the teachings of Ohba with a reasonable expectation of success and use the clip attachment of Ohba. Doing so allows attachment without using tools and therefore provides more convenience in assembly; also provides easy positioning means for adding additional securing means (screw, rivet, adhesives, etc.) after fastening the parts with the clips.
Regarding claim 28, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 15, wherein a pair of opposing tabs (Ohba, 5a and 5b in Fig. 3) and the at least one receiving portion includes a flange (Ohba, flange of 6 in Fig. 3) formed on the liftgate inner panel (after combination) that defines a bridge of material, wherein the tab lock the reinforcement in place against the liftgate inner panel by positioning the flange between the tabs (Ohba, Fig. 3), which prevents the reinforcement from sliding past the flange.
Claim 27 is rejected under 35 U.S.C. 103 as being unpatentable over the combination of Ginestet in view of Ni and Ohba as applied to claim 26 above, and further in view of Gold (US 4811519 A).
Regarding claim 27, the combination of Ginestet in view of Ni and Ohba teaches the reinforcement attachment arrangement of claim 26, wherein the tab has slanted edges (Ohba, Fig. 3, 5b has slanted edges).
The combination of Ginestet in view of Ni and Ohba fails to teach the aperture has slanted edges, where the slanted edges of the aperture and the slanted edges of the tab facilitate the alignment of the tab into the aperture.
Gold teaches the aperture has slanted edges (Gold, Fig. 5, aperture at 58/56 has slanted edges), where the slanted edges of the aperture and the slanted edges of the tab facilitate the alignment (Gold, Fig. 5, slanted edges match to align the tabs into the aperture) of the tab into the aperture.
Gold is considered to be analogous art because it is in the same field of vehicle door with clipping attachments as Ginestet in view of Ni and Ohba.
It would have been obvious to one of ordinary skill in the art before the earliest effective filing date of the claimed invention to have modified the arrangement as taught by Ginestet in view of Ni and Ohba to incorporate the teachings of Gold with a reasonable expectation of success and have slanted edges. Doing so provides a greater tolerance when securing the clip so that it is easier to assemble; also provides greater resistance against unintentional separation.
Response to Amendment
Due to the most recent amendment (5/4/2026) to claim 15, the limitation “receiving portion” in claim 15 is no longer interpreted under 35 U.S.C. § 112(f). The limitation “a bridge of material” constitutes sufficient structure.
Response to Arguments
Applicant’s arguments, see second to third paragraphs on page 8 of Applicant’s Reply, filed 5/4/2026, with respect to claims 1-6 and 8-14 have been fully considered and are persuasive. The rejection of 2/4/2026 has been withdrawn.
Applicant’s arguments, see second paragraph on page 9 of Applicant’s Reply, filed 5/4/2026, with respect to the rejection(s) of claim(s) 15 under 35 U.S.C. have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of Ohba, which teaches a bridge of material (Ohba, 5a in Fig. 3) and the tab received beneath the bridge of material (Ohba, Fig. 3, tab of 10d beneath bridge of material 5a). See rejection above for details.
Allowable Subject Matter
Claims 1-6 and 8-14 are allowed.
Claims 22-25 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.
The following is a statement of reasons for the indication of allowable subject matter: The primary reason for the allowance of the claims is the inclusion in the claims of the limitations directed to a neck that terminates at an engagement end and the at least one receiving portion is an aperture formed in the liftgate inner panel, wherein the engagement end slides into the aperture to connect the reinforcement to the liftgate inner panel as claimed in claims 1 and 22; and the at least one receiving portion has an aperture with a flexible tab, and wherein the at least one engagement tab has a neck that forms a bend in the reinforcement that bends away from a main surface of the reinforcement, the neck terminates at an engagement end, wherein the neck and the engagement end slide through the aperture and frictionally engage the flexible tab to hold the reinforcement onto the liftgate inner panel as claimed in claims 9 and 24. Such limitations, in combination with the rest of the limitations of the claims, are not disclosed or suggested by the prior art of record.
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 Wenwei Zhuo whose telephone number is (571)272-5564. The examiner can normally be reached Monday through Friday 8 a.m. - 4 p.m. EST.
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/WENWEI ZHUO/Examiner, Art Unit 3612
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