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 .
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 12/18/25 is being considered by the examiner.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 8-10 and 20 rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention.
Claims 8-10 and 20 each require that one or more “hydraulic valve(s)” be “hydraulically connected to the hydraulic motor.” However, the specification describes a hydraulic system in which hydraulic pump 160 supplies pressurized hydraulic fluid to hydraulic circuit 190 and hydraulic valves 162 (with reservoir 164), and separately describes motor 166 (e.g., a DC motor) driving the hydraulic pump 160 via belt 168 (see, e.g., paragraphs [0043]-[0045], [0053]-[0057]). As described, the motor 166 is not part of the hydraulic fluid path and is not described as being “hydraulically connected” to the valves. The disclosure therefore does not reasonably convey possession of the claimed arrangement in which hydraulic valves are hydraulically connected to a hydraulic motor.
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 2-11 and 14-20 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.
INDEFINITENESS ISSUE 1: “HYDRAULIC MOTOR” AND RELATED “HYDRAULIC” CONNECTIVITY/OPERATION LANGUAGE
Claims 2-4 and 14-16 recite a “hydraulic motor” that is “operable to drive” one or more hydraulic actuators/lift functions. Claims 8-11 and 20 further recite hydraulic valves that are “hydraulically connected to the hydraulic motor.” The claim language renders the metes and bounds unclear because it is uncertain whether “hydraulic motor” is intended to mean (i) a motor powered by hydraulic fluid (a term-of-art meaning), or (ii) an electric motor used in a hydraulic system to drive a hydraulic pump. This ambiguity is reinforced by the recitation that valves are “hydraulically connected to the hydraulic motor,” which is unclear under either interpretation (e.g., an electric motor is not hydraulically connected; a hydraulic motor is typically not the component supplying pressurized fluid to downstream control valves absent additional structure such as a pump/reservoir arrangement). Accordingly, it is unclear what structure is encompassed by “hydraulic motor” and how the claimed hydraulic circuit is arranged.
INDEFINITENESS ISSUE 2: LEG SUPPORT ACTUATOR CONNECTION LANGUAGE (CLAIMS 4 AND 16; AND DEPENDENTS)
Claim 4 recites “a pair of leg support hydraulic actuators connected to the seat and the backrest” and then states that the actuators are operable to “move the leg supports relative to the seat.” Claim 16 recites the same relationship. As written, the recited actuator connection points (seat and backrest) do not clearly establish how the actuators mechanically cooperate with the “leg supports” to move the leg supports, i.e., the structural relationship between the leg supports and the “leg support hydraulic actuators” is unclear. This prevents a clear understanding of the claimed linkage/actuation arrangement and therefore renders the scope indefinite.
INDEFINITENESS ISSUE 3: CLAIM 14 GRAMMATICAL/STRUCTURAL INCOMPLETENESS
Claim 14 recites “a controller configured to operate the hydraulic motor to drive the hydraulic lift the upper frame with respect to the lower frame between a raised position and a lowered position.” The phrase “drive the hydraulic lift the upper frame” is grammatically incomplete/structurally unclear, and it is uncertain whether the controller drives the lift to lift the upper frame, or drives the upper frame, or performs some other operation. This ambiguity prevents ascertaining the scope of the controller limitation.
INDEFINITENESS ISSUE 4: “CENTRIFUGAL SAFETY,” “THRESHOLD VELOCITY,” AND IDENTIFICATION OF THE MEASURED/LIMITED PARAMETER
Claim 13 recites “a centrifugal safety … configured to limit movement of the upper frame from the raised position to the lowered position when a velocity of the upper frame or the scissor lift exceeds a threshold velocity.” The terminology “centrifugal safety” does not, by itself, clearly convey a definite structure, and the claim does not clarify whether the “threshold velocity” refers to a linear velocity of the upper frame, an angular velocity of some component, or another velocity parameter, nor does it clarify which component of the multi-link scissor lift is measured for “velocity.” The scope of what constitutes the “centrifugal safety” and the triggering condition is therefore unclear.
PRIOR ART REFERENCES USED
Reference 1 (PRIMARY): Bayomy et al., US20080133089A1, published June 5, 2008 (“Height-Adjusting Wheelchair”).
Reference 2: Smith, US6154690A, issued November 28, 2000 (“Multi-feature Automated Wheelchair”).
Reference 3: Crepl et al., US3188136A, issued June 22, 1965 (“Electro-hydraulic System for Operating Elevatable Chairs”).
Reference 4: Kraft et al., US6047979A, issued April 11, 2000 (“Wheelchair Anti-tipping Device”).
Reference 5: Pedersen, US7461897B2, issued December 16, 2008 (“Seat Positioning and Control System”).
Reference 6: Johnson, US5105915A, issued April 14, 1992 (“Wheelchair Lifting Device”).
Reference 7: US9242128B2, issued January 26, 2016 (“Fall Arrester with Optimized Locking Mechanism”).
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.
Claims 1-2 and 14 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Bayomy (Reference 1).
───────── CLAIM 1
A lifting and reclining wheelchair comprising: a lower frame; a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment; one or more stabilizer wheels connected to the lower frame; a upper frame connected to the lower frame and movable with respect to the lower frame; a seat connected to the upper frame and movable with the upper frame relative to the lower frame; a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat; and a hydraulic lift connected to the lower frame and the upper frame and operable to lift the upper frame with respect to the lower frame between a raised position and a lowered position.
CLAIM 1 – LIMITATION-BY-LIMITATION ANALYSIS (REFERENCE 1)
a lifting and reclining wheelchair Bayomy discloses a height-adjusting wheelchair (wheelchair 100) having a wheeled chassis (chassis 302) and a seat assembly (seat assembly 300) that is height adjustable and includes a reclining seatback (reclining seatback 524).
a lower frame Bayomy discloses a wheeled chassis/base structure (chassis 302; base frame 500) supporting rear axle 502 and the wheels/casters. The chassis/base frame corresponds to the claimed “lower frame.”
a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment Bayomy discloses rear wheels (rear wheels 510) supported by the rear axle 502 of the base frame 500/chassis 302. Bayomy further discloses the rear wheels include a hand rim (hand rim 512) and are configured to be manually driven by a user. This meets the claimed drive wheels “operable by a user to move the wheelchair.”
one or more stabilizer wheels connected to the lower frame Bayomy discloses front wheels/casters (front wheels/casters 514) connected to the base frame 500/chassis 302 to support and stabilize the wheelchair during movement. These correspond to the claimed “one or more stabilizer wheels.”
a upper frame connected to the lower frame and movable with respect to the lower frame Bayomy discloses a seat assembly (seat assembly 300) including a seat bottom frame (seat bottom frame 520) that is coupled to the chassis (chassis 302) by a lifting mechanism (lifting mechanism 304). The seat assembly (including its frame) is movable relative to the chassis between lowered and raised positions by actuation of the lifting mechanism. Under the broadest reasonable interpretation, the seat assembly/frame (e.g., seat bottom frame 520) corresponds to an “upper frame” connected to, and movable with respect to, the “lower frame” (chassis 302).
a seat connected to the upper frame and movable with the upper frame relative to the lower frame Bayomy discloses the seat portion of the seat assembly (seat bottom frame 520) mounted on the seat assembly 300, which moves relative to the chassis 302 as the lifting mechanism 304 raises/lowers the seat assembly.
a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat Bayomy discloses a reclining seatback (reclining seatback 524) as part of the seat assembly 300. The reclining seatback is connected to the seat assembly and is described as “reclining,” i.e., configured to recline with respect to the seat. Because the seat assembly 300 (upper frame/seat structure) moves with respect to the chassis 302, the seatback 524 likewise moves with the seat assembly relative to the chassis.
a hydraulic lift connected to the lower frame and the upper frame and operable to lift the upper frame with respect to the lower frame between a raised position and a lowered position Bayomy discloses a lifting mechanism (lifting mechanism 304) including lifting cylinders (lifting cylinders 532) coupling the seat assembly 300 (upper frame/seat structure) to the chassis 302 (lower frame), whereby the cylinders raise and lower the seat assembly relative to the chassis to adjust seat height between lowered and raised positions. Bayomy further discloses the lifting cylinders are hydraulically driven via a pump box (pump box 536) including a hydraulic pump and motor. Accordingly, Bayomy discloses a hydraulic lift connected between the lower frame and upper frame and operable to lift between raised and lowered positions.
Accordingly, claim 1 is anticipated by Bayomy (Reference 1).
───────── CLAIM 2
The lifting and reclining wheelchair of claim 1, further comprising: a hydraulic motor connected to the lower frame and operable to drive the hydraulic lift to move the upper frame with respect to the lower frame.
CLAIM 2 – LIMITATION-BY-LIMITATION ANALYSIS (REFERENCE 1)
Claim 2 includes all limitations of claim 1, which are disclosed by Bayomy as set forth above.
a hydraulic motor connected to the lower frame and operable to drive the hydraulic lift to move the upper frame with respect to the lower frame Bayomy discloses a pump box (pump box 536) mounted to the chassis (chassis 302) and including a hydraulic pump and an electric motor for driving the hydraulic pump. The motor in the pump box drives the hydraulic pump to actuate the lifting cylinders 532, thereby driving the hydraulic lift (lifting mechanism 304) to move the seat assembly 300 relative to the chassis 302. Under a broadest reasonable interpretation consistent with the application’s usage (motor driving the hydraulic lift system), Bayomy’s pump-driving motor meets the claimed “hydraulic motor.”
Accordingly, claim 2 is anticipated by Bayomy (Reference 1).
───────── CLAIM 14
A lifting and reclining wheelchair comprising: a lower frame; a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment; one or more passive wheels connected to the lower frame; a linkage connected to the lower frame and configured to move with respect thereto; a upper frame connected to the lower frame by the linkage; a seat connected to the upper frame and movable with the upper frame relative to the lower frame; a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat; a hydraulic lift connected to the lower frame and the upper frame; a hydraulic motor connected to the lower frame; and a controller configured to operate the hydraulic motor to drive the hydraulic lift the upper frame with respect to the lower frame between a raised position and a lowered position.
CLAIM 14 – LIMITATION-BY-LIMITATION ANALYSIS (REFERENCE 1)
a lifting and reclining wheelchair Bayomy discloses a height-adjusting wheelchair (wheelchair 100) including a reclining seatback 524.
a lower frame Bayomy discloses chassis 302/base frame 500.
a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment Bayomy discloses rear wheels 510 on rear axle 502, with hand rim 512 for manual propulsion.
one or more passive wheels connected to the lower frame Bayomy discloses front wheels/casters 514 connected to the base frame 500/chassis 302. These are passive wheels.
a linkage connected to the lower frame and configured to move with respect thereto Bayomy discloses lifting cylinders 532 of the lifting mechanism 304 connected between the chassis 302 and seat assembly 300. The cylinders function as movable linkage members (extending/retracting) with respect to the lower frame (chassis 302).
a upper frame connected to the lower frame by the linkage Bayomy discloses seat assembly 300 (including seat bottom frame 520) connected to chassis 302 by lifting cylinders 532. The seat assembly/frame corresponds to the claimed “upper frame.”
a seat connected to the upper frame and movable with the upper frame relative to the lower frame Bayomy discloses seat bottom frame 520 as part of seat assembly 300 that moves relative to chassis 302 when raised/lowered by lifting mechanism 304.
a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat Bayomy discloses reclining seatback 524 as part of seat assembly 300, moving with the seat assembly relative to chassis 302.
a hydraulic lift connected to the lower frame and the upper frame Bayomy discloses lifting mechanism 304 including lifting cylinders 532 coupling seat assembly 300 and chassis 302.
a hydraulic motor connected to the lower frame Bayomy discloses pump box 536 on the chassis 302 including an electric motor driving a hydraulic pump for the hydraulic lift.
a controller configured to operate the hydraulic motor to drive the hydraulic lift the upper frame with respect to the lower frame between a raised position and a lowered position Bayomy discloses controls (controls 530) for operating the lifting mechanism 304 to adjust seat height (raising/lowering), which necessarily includes controlling the pump-driving motor within pump box 536 to actuate lifting cylinders 532.
Accordingly, claim 14 is anticipated by Bayomy (Reference 1).
Claim Rejections - 35 USC § 103
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 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.
PRIOR ART REFERENCES USED
Reference 1 (PRIMARY): Bayomy et al., US20080133089A1, published June 5, 2008 (“Height-Adjusting Wheelchair”).
Reference 2: Smith, US6154690A, issued November 28, 2000 (“Multi-feature Automated Wheelchair”).
Reference 3: Crepl et al., US3188136A, issued June 22, 1965 (“Electro-hydraulic System for Operating Elevatable Chairs”).
Reference 4: Kraft et al., US6047979A, issued April 11, 2000 (“Wheelchair Anti-tipping Device”).
Reference 5: Pedersen, US7461897B2, issued December 16, 2008 (“Seat Positioning and Control System”).
Reference 6: Johnson, US5105915A, issued April 14, 1992 (“Wheelchair Lifting Device”).
Reference 7: US9242128B2, issued January 26, 2016 (“Fall Arrester with Optimized Locking Mechanism”).
CLAIM REJECTIONS – 35 U.S.C. 102
Claims 1-2 and 14 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Bayomy (Reference 1). Anticipation requires that the reference disclose, expressly or inherently, each and every limitation of the claim arranged as in the claim.
───────── CLAIM 1
A lifting and reclining wheelchair comprising: a lower frame; a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment; one or more stabilizer wheels connected to the lower frame; a upper frame connected to the lower frame and movable with respect to the lower frame; a seat connected to the upper frame and movable with the upper frame relative to the lower frame; a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat; and a hydraulic lift connected to the lower frame and the upper frame and operable to lift the upper frame with respect to the lower frame between a raised position and a lowered position.
CLAIM 1 – LIMITATION-BY-LIMITATION ANALYSIS (REFERENCE 1)
a lifting and reclining wheelchair Bayomy discloses a height-adjusting wheelchair (wheelchair 100) having a wheeled chassis (chassis 302) and a seat assembly (seat assembly 300) that is height adjustable and includes a reclining seatback (reclining seatback 524).
a lower frame Bayomy discloses a wheeled chassis/base structure (chassis 302; base frame 500) supporting rear axle 502 and the wheels/casters. The chassis/base frame corresponds to the claimed “lower frame.”
a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment Bayomy discloses rear wheels (rear wheels 510) supported by the rear axle 502 of the base frame 500/chassis 302. Bayomy further discloses the rear wheels include a hand rim (hand rim 512) and are configured to be manually driven by a user. This meets the claimed drive wheels “operable by a user to move the wheelchair.”
one or more stabilizer wheels connected to the lower frame Bayomy discloses front wheels/casters (front wheels/casters 514) connected to the base frame 500/chassis 302 to support and stabilize the wheelchair during movement. These correspond to the claimed “one or more stabilizer wheels.”
a upper frame connected to the lower frame and movable with respect to the lower frame Bayomy discloses a seat assembly (seat assembly 300) including a seat bottom frame (seat bottom frame 520) that is coupled to the chassis (chassis 302) by a lifting mechanism (lifting mechanism 304). The seat assembly (including its frame) is movable relative to the chassis between lowered and raised positions by actuation of the lifting mechanism. Under the broadest reasonable interpretation, the seat assembly/frame (e.g., seat bottom frame 520) corresponds to an “upper frame” connected to, and movable with respect to, the “lower frame” (chassis 302).
a seat connected to the upper frame and movable with the upper frame relative to the lower frame Bayomy discloses the seat portion of the seat assembly (seat bottom frame 520) mounted on the seat assembly 300, which moves relative to the chassis 302 as the lifting mechanism 304 raises/lowers the seat assembly.
a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat Bayomy discloses a reclining seatback (reclining seatback 524) as part of the seat assembly 300. The reclining seatback is connected to the seat assembly and is described as “reclining,” i.e., configured to recline with respect to the seat. Because the seat assembly 300 (upper frame/seat structure) moves with respect to the chassis 302, the seatback 524 likewise moves with the seat assembly relative to the chassis.
a hydraulic lift connected to the lower frame and the upper frame and operable to lift the upper frame with respect to the lower frame between a raised position and a lowered position Bayomy discloses a lifting mechanism (lifting mechanism 304) including lifting cylinders (lifting cylinders 532) coupling the seat assembly 300 (upper frame/seat structure) to the chassis 302 (lower frame), whereby the cylinders raise and lower the seat assembly relative to the chassis to adjust seat height between lowered and raised positions. Bayomy further discloses the lifting cylinders are hydraulically driven via a pump box (pump box 536) including a hydraulic pump and motor. Accordingly, Bayomy discloses a hydraulic lift connected between the lower frame and upper frame and operable to lift between raised and lowered positions.
Accordingly, claim 1 is anticipated by Bayomy (Reference 1).
───────── CLAIM 2
The lifting and reclining wheelchair of claim 1, further comprising: a hydraulic motor connected to the lower frame and operable to drive the hydraulic lift to move the upper frame with respect to the lower frame.
CLAIM 2 – LIMITATION-BY-LIMITATION ANALYSIS (REFERENCE 1)
Claim 2 includes all limitations of claim 1, which are disclosed by Bayomy as set forth above.
a hydraulic motor connected to the lower frame and operable to drive the hydraulic lift to move the upper frame with respect to the lower frame Bayomy discloses a pump box (pump box 536) mounted to the chassis (chassis 302) and including a hydraulic pump and an electric motor for driving the hydraulic pump. The motor in the pump box drives the hydraulic pump to actuate the lifting cylinders 532, thereby driving the hydraulic lift (lifting mechanism 304) to move the seat assembly 300 relative to the chassis 302. Under a broadest reasonable interpretation consistent with the application’s usage (motor driving the hydraulic lift system), Bayomy’s pump-driving motor meets the claimed “hydraulic motor.”
Accordingly, claim 2 is anticipated by Bayomy (Reference 1).
───────── CLAIM 14
A lifting and reclining wheelchair comprising: a lower frame; a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment; one or more passive wheels connected to the lower frame; a linkage connected to the lower frame and configured to move with respect thereto; a upper frame connected to the lower frame by the linkage; a seat connected to the upper frame and movable with the upper frame relative to the lower frame; a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat; a hydraulic lift connected to the lower frame and the upper frame; a hydraulic motor connected to the lower frame; and a controller configured to operate the hydraulic motor to drive the hydraulic lift the upper frame with respect to the lower frame between a raised position and a lowered position.
CLAIM 14 – LIMITATION-BY-LIMITATION ANALYSIS (REFERENCE 1)
a lifting and reclining wheelchair Bayomy discloses a height-adjusting wheelchair (wheelchair 100) including a reclining seatback 524.
a lower frame Bayomy discloses chassis 302/base frame 500.
a pair of drive wheels rotatably connected to the lower frame and operable by a user to move the wheelchair about an environment Bayomy discloses rear wheels 510 on rear axle 502, with hand rim 512 for manual propulsion.
one or more passive wheels connected to the lower frame Bayomy discloses front wheels/casters 514 connected to the base frame 500/chassis 302. These are passive wheels.
a linkage connected to the lower frame and configured to move with respect thereto Bayomy discloses lifting cylinders 532 of the lifting mechanism 304 connected between the chassis 302 and seat assembly 300. The cylinders function as movable linkage members (extending/retracting) with respect to the lower frame (chassis 302).
a upper frame connected to the lower frame by the linkage Bayomy discloses seat assembly 300 (including seat bottom frame 520) connected to chassis 302 by lifting cylinders 532. The seat assembly/frame corresponds to the claimed “upper frame.”
a seat connected to the upper frame and movable with the upper frame relative to the lower frame Bayomy discloses seat bottom frame 520 as part of seat assembly 300 that moves relative to chassis 302 when raised/lowered by lifting mechanism 304.
a backrest connected to the upper frame and movable with the upper frame relative to the lower frame, the backrest configured to recline with respect to the seat Bayomy discloses reclining seatback 524 as part of seat assembly 300, moving with the seat assembly relative to chassis 302.
a hydraulic lift connected to the lower frame and the upper frame Bayomy discloses lifting mechanism 304 including lifting cylinders 532 coupling seat assembly 300 and chassis 302.
a hydraulic motor connected to the lower frame Bayomy discloses pump box 536 on the chassis 302 including an electric motor driving a hydraulic pump for the hydraulic lift.
a controller configured to operate the hydraulic motor to drive the hydraulic lift the upper frame with respect to the lower frame between a raised position and a lowered position Bayomy discloses controls (controls 530) for operating the lifting mechanism 304 to adjust seat height (raising/lowering), which necessarily includes controlling the pump-driving motor within pump box 536 to actuate lifting cylinders 532.
Accordingly, claim 14 is anticipated by Bayomy (Reference 1).
Claim Rejections - 35 USC § 103
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 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 3-13 and 15-20 are rejected under 35 U.S.C. 103 as being unpatentable over the combinations set forth below.
──────────────────────────────────────── CLAIMS 1-13 (INDEPENDENT CLAIM 1; DEPENDENTS 2-13)
───────── CLAIM 3
The lifting and reclining wheelchair of claim 2, further comprising: a pair of backrest hydraulic actuators connected to the seat and the backrest, the hydraulic motor operable to drive the pair of backrest hydraulic actuators to move the backrest relative to the seat between an upright position and a reclined position.
CLAIM 3 – REJECTION UNDER 35 U.S.C. 103 Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3).
CLAIM 3 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 3 includes all limitations of claim 2, which are disclosed by Bayomy as set forth above.
a pair of backrest hydraulic actuators connected to the seat and the backrest Crepl discloses an electro-hydraulic chair system including a seat (seat 20) and a backrest that is actuated by a hydraulic actuating cylinder (actuating cylinder 171) arranged between the seat 20 structure and the backrest structure to change backrest position relative to the seat.
Although Crepl illustrates an actuating cylinder 171, it would have been an obvious matter of design choice to provide a pair of such hydraulic actuators (e.g., left and right cylinders) in a wheelchair environment to balance loads on the backrest, reduce torsional loading, and improve stability during recline, particularly for wider backrests typical of wheelchairs.
the hydraulic motor operable to drive the pair of backrest hydraulic actuators to move the backrest relative to the seat between an upright position and a reclined position Bayomy discloses a hydraulic lift system with lifting cylinders 532 driven by a pump box 536 including a hydraulic pump and motor on chassis 302, and Bayomy discloses a reclining seatback 524. Crepl discloses an electric motor-driven hydraulic system (motor 151) and solenoid valve (solenoid valve 178) used to supply hydraulic fluid to the actuating cylinder 171 to move the backrest between positions.
Thus, modifying Bayomy to include (i) backrest hydraulic actuators configured like Crepl’s actuating cylinder 171 between Bayomy’s seat portion (seat bottom frame 520/seat assembly 300) and Bayomy’s reclining seatback 524, and (ii) using Bayomy’s existing pump box 536 motor/pump as the driving source for those backrest hydraulic actuators, yields the claimed configuration.
RATIONALE TO COMBINE / MODIFY (CLAIM 3) It would have been obvious to modify Bayomy’s reclining seatback 524 to be powered by hydraulic backrest actuators as taught by Crepl to provide powered, controlled recline for users with limited strength or dexterity, and to integrate multiple seat functions (height adjust and recline) into a single hydraulic power unit. This is a predictable use of prior art elements (hydraulic cylinders, solenoid valves, and a motor-driven pump) to obtain predictable results (powered recline).
───────── CLAIM 4
The lifting and reclining wheelchair of claim 3, further comprising: a pair of leg supports connected to the upper frame and the seat; and a pair of leg support hydraulic actuators connected to the seat and the backrest, the hydraulic motor operable to drive the pair of leg support hydraulic actuators to move the leg supports relative to the seat between a straight position and a seated position.
CLAIM 4 – REJECTION UNDER 35 U.S.C. 103 Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3) and further in view of Smith (Reference 2).
CLAIM 4 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 4 includes all limitations of claim 3, which are met by Bayomy in view of Crepl as set forth above.
a pair of leg supports connected to the upper frame and the seat Bayomy discloses footrests (footrests 526) as part of the seat assembly 300. Such footrests/leg supports are connected to the seat assembly (upper frame/seat structure) for supporting a user’s legs/feet.
a pair of leg support hydraulic actuators connected to the seat and the backrest Smith discloses a wheelchair having independently positionable components including a seat (seat 110), a back (back 112), and a leg rest (leg rest 114), with the system configured for powered positional adjustments of these components.
Crepl discloses using a hydraulically powered actuating cylinder 171 controlled by a solenoid valve 178 to reposition seating components.
Accordingly, it would have been obvious to provide, for Bayomy’s leg support structures (e.g., footrests 526), a pair of hydraulic actuators (by analogy to Crepl’s actuating cylinder 171 and Smith’s powered leg rest 114 functionality), arranged such that extension/retraction changes the angular position of the leg supports relative to the seat between a seated position (knees bent) and a straight position (legs extended).
the hydraulic motor operable to drive the pair of leg support hydraulic actuators to move the leg supports relative to the seat between a straight position and a seated position Bayomy provides a hydraulic pump/motor unit (pump box 536 including hydraulic pump and motor) for driving hydraulic cylinders. Thus, Bayomy’s hydraulic motor/pump system would be used to drive the additional leg support hydraulic actuators (with appropriate valve control as further discussed below), achieving the claimed movement.
RATIONALE TO COMBINE / MODIFY (CLAIM 4) It would have been obvious to modify Bayomy to include powered leg support positioning as taught by Smith (leg rest 114 adjusted under powered control) to enhance user comfort, circulation, and transfer capability, particularly in combination with height adjustment. Further, implementing the powered leg support positioning using hydraulic actuators, as taught by Crepl, is a predictable substitution leveraging Bayomy’s existing hydraulic power unit (pump box 536) to drive additional cylinders.
───────── CLAIM 5
The lifting and reclining wheelchair of claim 4, further comprising: a stabilization wheel connected to the lower frame and movable with respect to the lower frame between a stored position and a deployed position; an interlock configured to generate a signal based on whether the stabilization wheel is in the stored position or the deployed position; and a controller configured to prevent the pair of backrest hydraulic actuators from moving to the reclined position when the stabilization wheel is not in the deployed position.
CLAIM 5 – REJECTION UNDER 35 U.S.C. 103 Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3) and Smith (Reference 2) and further in view of Kraft (Reference 4) and further in view of Pedersen (Reference 5) and Johnson (Reference 6).
CLAIM 5 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 5 includes all limitations of claim 4, which are met by Bayomy in view of Crepl and Smith as set forth above.
a stabilization wheel connected to the lower frame and movable with respect to the lower frame between a stored position and a deployed position Kraft discloses a wheelchair (wheelchair 10) having a frame (frame 14) and anti-tipping devices (anti-tipping device 20) including a ground engagement member in the form of a wheel (wheel 22). Kraft discloses the wheel 22 is movable between a forwardly retracted inoperative position (stored) beneath the frame/seat and a rearwardly extended operative/deployed position, by operation of an extensible/retractable displacement device (displacement device 28) comprising multiple links (e.g., links 26, 30, 32, 34, etc.).
Thus, Kraft’s wheel 22 corresponds to the claimed stabilization wheel that is movable between stored and deployed positions.
an interlock configured to generate a signal based on whether the stabilization wheel is in the stored position or the deployed position Pedersen discloses a microprocessor-based positioning/control system (microprocessor 59) having sensor input channels that interface to sensors such as tip-switches and limit switches to limit travel of recline/tilt functions and to generate lock-out signals based on sensed conditions.
Johnson discloses a limit switch (limit switch 14) as an example of a position-sensing interlock used to generate an electrical control signal based on component position within a lifting system.
Accordingly, it would have been obvious to provide Kraft’s anti-tipping device 20 with a position sensor/interlock (e.g., a limit switch as taught by Johnson, integrated as a sensor input to a controller as taught by Pedersen) to generate a signal indicating whether the stabilization wheel (wheel 22) is in the stored (retracted) or deployed (extended) condition.
a controller configured to prevent the pair of backrest hydraulic actuators from moving to the reclined position when the stabilization wheel is not in the deployed position Bayomy discloses controls (controls 530) for operating the lifting mechanism 304, i.e., a controller for seat positioning functions. Pedersen discloses controller logic (microprocessor 59) using sensor inputs (e.g., tip-switches/limit switches) to limit recline and to generate lock-out signals that inhibit operation when a safety condition is not met.
Thus, the combined teachings support a controller configured to prevent actuation of recline (here, the backrest hydraulic actuators of claim 3) unless the stabilization wheel is deployed (per the interlock signal).
RATIONALE TO COMBINE / MODIFY (CLAIM 5) It would have been obvious to incorporate Kraft’s deployable anti-tipping wheel 22 into Bayomy’s height-adjusting wheelchair to mitigate rearward tipping risk when recline and/or height adjustment shifts the center of gravity. Further, it would have been obvious to add an interlock/position sensor (as taught by Johnson’s limit switch 14 and Pedersen’s sensor-based lock-out control) to inhibit recline unless the stabilization wheel is deployed, to improve user safety and reduce likelihood of tip-over. Such safety interlocks are a predictable application of known sensing and control techniques to known wheelchair positioning functions.
───────── CLAIM 6
The lifting and reclining wheelchair of claim 5, further comprising: a stabilization handle manually user-operable to move the stabilization wheel between the stored position and the deployed position.
CLAIM 6 – REJECTION UNDER 35 U.S.C. 103 Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3), Smith (Reference 2), Kraft (Reference 4), Pedersen (Reference 5), and Johnson (Reference 6), as applied to claim 5 above.
CLAIM 6 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 6 includes all limitations of claim 5, which are met by the combination applied to claim 5 above.
a stabilization handle manually user-operable to move the stabilization wheel between the stored position and the deployed position Kraft discloses an actuating member/hand grip for operating the anti-tipping device 20: Kraft describes a double-armed lever (double-armed lever 62) having an arm (arm 64) that “serves as an actuating member or hand grip” by which the wheelchair occupant can operate the anti-tipping device 20 to deploy/retract wheel 22.
Thus, Kraft teaches the claimed manually user-operable stabilization handle.
RATIONALE TO COMBINE / MODIFY (CLAIM 6) It would have been obvious to employ Kraft’s user-accessible hand grip (arm 64 of lever 62) on a deployable stabilization/anti-tip wheel to allow a seated user to rapidly deploy the stabilization wheel when needed and retract it to improve maneuverability when not needed, yielding predictable usability improvements.
───────── CLAIM 7
The lifting and reclining wheelchair of claim 5, further comprising: a wireless remote control user operable to communicate with the controller to move the wheelchair between the raised position and the lowered position, to move the pair of leg supports between the straight position and the seated position, and to move the backrest between the upright position and the reclined position.
CLAIM 7 – REJECTION UNDER 35 U.S.C. 103 Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3), Smith (Reference 2), Kraft (Reference 4), Pedersen (Reference 5), and Johnson (Reference 6).
CLAIM 7 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 7 includes all limitations of claim 5, which are met by the combination applied to claim 5 above, and further requires a wireless remote control.
a wireless remote control user operable to communicate with the controller Smith discloses a remote control (remote 217) communicating via infrared (infrared sensor at 219) and further indicates an RF remote could be employed.
to move the wheelchair between the raised position and the lowered position, to move the pair of leg supports between the straight position and the seated position, and to move the backrest between the upright position and the reclined position Bayomy discloses powered height adjustment (lifting mechanism 304) for moving the seat assembly between lowered and raised positions. Smith discloses powered positioning of chair components including back (back 112) and leg rest (leg rest 114), under control logic that can be commanded via the remote interface.
Thus, it would have been obvious to employ Smith’s wireless remote 217 (e.g., RF or IR) to communicate with the controller (Bayomy controls 530 / Pedersen microprocessor 59) to command the lift (raise/lower), backrest recline, and leg support positioning functions.
RATIONALE TO COMBINE / MODIFY (CLAIM 7) It would have been obvious to provide wireless remote control of the lift/recline/leg positioning functions to enhance accessibility for users with limited mobility and to allow an attendant to operate the functions without reaching under the seat or near moving mechanisms. Smith teaches wireless remote operation (remote 217; sensor 219; RF remote option), and applying that known interface to Bayomy’s controller-driven hydraulic actuation functions is a predictable integration.
───────── CLAIM 8
The lifting and reclining wheelchair of claim 5, comprising: a pair of leg hydraulic valves associated with respective ones of the pair of leg support hydraulic actuators, the pair of leg hydraulic valves hydraulically connected to the hydraulic motor, and the controller operable to control the pair of leg hydraulic valves and the hydraulic motor to move the pair of leg supports between the straight position and the seated position, individually.
CLAIM 8 – REJECTION UNDER 35 U.S.C. 103 Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3), Smith (Reference 2), Kraft (Reference 4), Pedersen (Reference 5), and Johnson (Reference 6).
CLAIM 8 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 8 includes all limitations of claim 5, which are met by the combination applied to claim 5 above, and further recites hydraulic valves associated with respective leg actuators and individual control.
a pair of leg hydraulic valves associated with respective ones of the pair of leg support hydraulic actuators, the pair of leg hydraulic valves hydraulically connected to the hydraulic motor Crepl discloses a solenoid valve (solenoid valve 178) for controlling hydraulic fluid flow to an actuating cylinder (actuating cylinder 171) in an electro-hydraulic system. Johnson discloses a hydraulic system driven by motor M and pump P with valves including return valve 88 and regulator valve 89 controlling hydraulic rams 76.
These teachings collectively show the use of hydraulic valves in a motor/pump-driven hydraulic system to control one or more hydraulic actuators. Applying this to the leg support hydraulic actuators of claim 4 would have predictably involved providing a respective valve (e.g., solenoid valve) for each leg actuator so each actuator can be controlled independently.
the controller operable to control the pair of leg hydraulic valves and the hydraulic motor to move the pair of leg supports between the straight position and the seated position, individually Pedersen discloses a controller (microprocessor 59) that controls multiple drive output channels independently or in groups, including left and right leg rest positioning mechanisms, in response to inputs and configuration mapping. Thus, it would have been obvious to implement the same independent control concept for left and right leg supports in a hydraulic architecture by controlling respective hydraulic valves (one per leg actuator) and energizing the hydraulic motor/pump when commanded.
RATIONALE TO COMBINE / MODIFY (CLAIM 8) It would have been obvious to provide individual control of left/right leg supports to accommodate user asymmetries, therapy needs, and comfort. Pedersen teaches independent control channels for left/right leg rest mechanisms, and Crepl/Johnson teach that hydraulic actuators are controlled via corresponding valves in a motor/pump-driven hydraulic circuit. Implementing Pedersen’s independent control concept in Bayomy’s hydraulic system via separate hydraulic valves is a predictable engineering choice using known hydraulic control components.
───────── CLAIM 9
The lifting and reclining wheelchair of claim 8, comprising: a main hydraulic valve associated with the hydraulic lift, the main hydraulic valve hydraulically connected to the hydraulic motor, and the controller operable to control the main hydraulic valve and the hydraulic motor to move the upper frame between the raised position and the lowered position.
CLAIM 9 – REJECTION UNDER 35 U.S.C. 103 Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3), Smith (Reference 2), Kraft (Reference 4), Pedersen (Reference 5), and Johnson (Reference 6).
CLAIM 9 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 9 includes all limitations of claim 8, which are met by the combination applied to claim 8 above, and further recites a main hydraulic valve for the hydraulic lift.
a main hydraulic valve associated with the hydraulic lift, the main hydraulic valve hydraulically connected to the hydraulic motor Bayomy discloses a hydraulic lift system (lifting mechanism 304; lifting cylinders 532) driven by a motor/pump unit (pump box 536). Crepl and Johnson teach hydraulic valves (e.g., solenoid valve 178; return valve 88; regulator valve 89) connected within the hydraulic circuit and controlled to actuate hydraulic cylinders/rams powered by a motor-driven pump.
Thus, it would have been obvious to provide a main hydraulic valve in Bayomy’s lift circuit associated with lifting cylinders 532 to control lifting/lowering flow, hydraulically connected to the pump box 536.
the controller operable to control the main hydraulic valve and the hydraulic motor to move the upper frame between the raised position and the lowered position Bayomy discloses controls 530 to operate lifting mechanism 304 (raise/lower). Pedersen teaches controller logic controlling outputs and inhibiting motion based on configuration/sensors, and thus supports controller-driven valve actuation.
Accordingly, the combined teachings meet claim 9.
RATIONALE TO COMBINE / MODIFY (CLAIM 9) It would have been obvious to include an explicit main hydraulic control valve for Bayomy’s lift cylinders to provide controlled extension/retraction, enable safe stopping/holding, and integrate with multi-function hydraulic circuits. Crepl and Johnson show motor/pump-driven hydraulic systems using valves to control actuators; implementing the same control architecture for Bayomy’s hydraulic lift is a predictable and standard hydraulic design approach.
───────── CLAIM 10
The lifting and reclining wheelchair of claim 9, comprising: a backrest hydraulic valve associated with the pair of backrest hydraulic actuators, the backrest hydraulic valve hydraulically connected to the hydraulic motor, and the controller operable to control the backrest hydraulic valve and the hydraulic motor to move the backrest between the upright position and the reclined position.
CLAIM 10 – REJECTION UNDER 35 U.S.C. 103 Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3), Smith (Reference 2), Kraft (Reference 4), Pedersen (Reference 5), and Johnson (Reference 6).
CLAIM 10 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 10 includes all limitations of claim 9, which are met by the combination applied to claim 9 above, and further recites a backrest hydraulic valve.
a backrest hydraulic valve associated with the pair of backrest hydraulic actuators, the backrest hydraulic valve hydraulically connected to the hydraulic motor Crepl discloses a solenoid valve (solenoid valve 178) controlling hydraulic flow to an actuating cylinder (actuating cylinder 171) that positions a backrest relative to the seat. Bayomy provides the hydraulic motor/pump unit (pump box 536) as the hydraulic power source.
Thus, providing a dedicated backrest hydraulic valve for the backrest cylinders (claim 3) hydraulically connected to the hydraulic motor/pump is taught by Crepl’s valve-controlled backrest cylinder architecture as applied to Bayomy’s hydraulic power unit.
the controller operable to control the backrest hydraulic valve and the hydraulic motor to move the backrest between the upright position and the reclined position Pedersen teaches controller (microprocessor 59) control over multiple positioning mechanisms, including recline, with sensor-based limits and control mapping. Accordingly, the controller would control the solenoid valve(s) corresponding to backrest actuation and operate/enable the pump motor as needed.
RATIONALE TO COMBINE / MODIFY (CLAIM 10) It would have been obvious to implement backrest recline control using a dedicated hydraulic valve to permit independent and safe control of recline motion, as taught by Crepl’s solenoid-valve-controlled backrest actuation, and to integrate this within the multi-function controller architecture taught by Pedersen. This yields predictable results: independent backrest recline control with hydraulic actuation.
───────── CLAIM 11
The lifting and reclining wheelchair of claim 10, comprising: an 18 volt direct current battery releasably securable to the lower frame and configured to deliver power to the hydraulic motor and the hydraulic valves.
CLAIM 11 – REJECTION UNDER 35 U.S.C. 103 Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3), Smith (Reference 2), Kraft (Reference 4), Pedersen (Reference 5), and Johnson (Reference 6).
CLAIM 11 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 11 includes all limitations of claim 10, which are met by the combination applied to claim 10 above.
an 18 volt direct current battery releasably securable to the lower frame and configured to deliver power to the hydraulic motor and the hydraulic valves Bayomy discloses a pump box 536 including an electric motor driving a hydraulic pump to actuate the lifting mechanism 304; such a motor necessarily requires an electrical power source. Crepl similarly discloses a motor-driven hydraulic system (motor 151) operating solenoid valves (solenoid valve 178), which likewise requires a power source to energize the motor and solenoid(s).
Selecting an 18 V direct current battery and providing it as a releasably securable battery pack on the wheelchair lower frame would have been an obvious matter of design choice for a portable, rechargeable power supply to energize the hydraulic motor/pump and hydraulic valve solenoids, yielding the predictable benefit of removable/replaceable power and simplified charging.
RATIONALE TO COMBINE / MODIFY (CLAIM 11) It would have been obvious to power the hydraulic motor and solenoid-operated hydraulic valves with a removable DC battery pack mounted on the wheelchair frame because Bayomy and Crepl both require electrical power for their motor-driven hydraulic systems, and it is well within ordinary skill to select an appropriate DC voltage (including 18 V) and a releasable mounting to facilitate battery replacement and charging. The choice of voltage and releasable mounting is a predictable design optimization absent unexpected results.
───────── CLAIM 12
The lifting and reclining wheelchair of claim 1, comprising: a scissor lift connected to the upper frame, the lower frame, and the hydraulic lift, the scissor lift configured to guide relative movement of the upper frame with respect to the lower frame between the raised position and the lowered position.
CLAIM 12 – REJECTION UNDER 35 U.S.C. 103 Claim 12 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Johnson (Reference 6).
CLAIM 12 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 12 includes all limitations of claim 1, which are disclosed by Bayomy as set forth above.
a scissor lift connected to the upper frame, the lower frame, and the hydraulic lift, the scissor lift configured to guide relative movement of the upper frame with respect to the lower frame between the raised position and the lowered position Johnson discloses a lifting device for a wheelchair that includes scissor-type lifting structure (two scissor-lever assemblies) driven by hydraulic rams (hydraulic rams 76) powered by a motor M and pump P. The scissor lever assemblies guide vertical movement of the lifted structure between lowered and raised positions.
Thus, Johnson teaches a scissor lift mechanism guiding relative movement between a lower supporting structure and an upper lifted structure, actuated by a hydraulic lift (rams 76).
Accordingly, it would have been obvious to modify Bayomy’s lifting mechanism 304 to include a scissor lift guide structure as taught by Johnson, connected between Bayomy’s chassis 302 (lower frame) and seat assembly 300 (upper frame), and actuated by Bayomy’s hydraulic lift cylinders 532 (or an equivalent hydraulic actuator), to guide and stabilize the vertical movement between raised and lowered positions.
RATIONALE TO COMBINE / MODIFY (CLAIM 12) It would have been obvious to add a scissor lift guide mechanism to Bayomy’s height-adjusting wheelchair to improve stability and constrain motion to a predictable, guided vertical path during lifting/lowering. Johnson teaches scissor-lever lifting driven by hydraulic rams 76 in the wheelchair-lift context, demonstrating the known benefits of scissor lift guidance. Integrating such a guidance mechanism into Bayomy’s lift is a predictable modification yielding improved guidance and load distribution without changing the fundamental lifting function.
───────── CLAIM 13
The lifting and reclining wheelchair of claim 12, further comprising: a centrifugal safety connected to the scissor lift and the lower frame, the centrifugal safety configured to limit movement of the upper frame from the raised position to the lowered position when a velocity of the upper frame or the scissor lift exceeds a threshold velocity.
CLAIM 13 – REJECTION UNDER 35 U.S.C. 103 Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Johnson (Reference 6) and further in view of US9242128B2 (Reference 7).
CLAIM 13 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 13 includes all limitations of claim 12, which are met by Bayomy in view of Johnson as set forth above.
a centrifugal safety connected to the scissor lift and the lower frame, the centrifugal safety configured to limit movement of the upper frame from the raised position to the lowered position when a velocity of the upper frame or the scissor lift exceeds a threshold velocity Johnson teaches safety-oriented hydraulic control components (e.g., return valve 88, regulator valve 89, and limit switch 14) in a wheelchair lifting system driven by motor M/pump P and hydraulic rams 76, which demonstrates the recognition of controlling lowering behavior for safety in lift systems.
Reference 7 teaches a fall arrester having a velocity/acceleration-responsive locking mechanism that engages (via pawl/teeth type locking) to prevent further motion when an overspeed/rapid movement condition occurs.
Accordingly, it would have been obvious to further modify the Bayomy+Johnson scissor lift structure to include a velocity-responsive safety device (i.e., a centrifugal/inertial safety lock as taught by Reference 7) mechanically coupled between the scissor lift and the lower frame so that, if the upper frame begins to descend at an excessive speed, the safety device locks and thereby limits further descent (limits movement from raised to lowered).
RATIONALE TO COMBINE / MODIFY (CLAIM 13) It would have been obvious to add an overspeed/velocity-responsive safety device to a scissor-lift wheelchair height adjustment mechanism to protect the user from sudden drops due to hydraulic failure or unintended rapid lowering. Johnson already teaches safety and controlled lowering concepts in a wheelchair lift (including valves and limit switch). Reference 7 teaches a known velocity-responsive locking mechanism to stop motion upon overspeed. Combining these teachings is a predictable safety enhancement yielding the expected result of limiting downward motion when velocity exceeds a threshold.
──────────────────────────────────────── CLAIMS 14-20 (INDEPENDENT CLAIM 14; DEPENDENTS 15-20)
───────── CLAIM 15
The lifting and reclining wheelchair of claim 14, further comprising: a pair of backrest hydraulic actuators connected to the seat and the backrest, the controller configured to operate the hydraulic motor to drive the pair of backrest hydraulic actuators to move the backrest relative to the seat between an upright position and a reclined position.
CLAIM 15 – REJECTION UNDER 35 U.S.C. 103 Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3).
CLAIM 15 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 15 depends from claim 14. Claim 14 is anticipated by Bayomy as set forth above.
a pair of backrest hydraulic actuators connected to the seat and the backrest Crepl teaches a hydraulic actuating cylinder 171 between the seat 20 and the backrest structure to reposition the backrest relative to the seat. As with claim 3, providing a pair of such actuators would have been an obvious load-balancing design choice in a wheelchair.
the controller configured to operate the hydraulic motor to drive the pair of backrest hydraulic actuators to move the backrest relative to the seat between an upright position and a reclined position Bayomy teaches controls 530 operating the lifting mechanism 304 and thus controlling the hydraulic motor/pump (pump box 536). Crepl teaches solenoid-valve-controlled hydraulic backrest actuation driven by a motor-driven pump.
Thus, the controller of Bayomy would be configured to operate the hydraulic motor and associated valve(s) to drive the backrest actuators to reposition the backrest between upright and reclined positions.
RATIONALE TO COMBINE / MODIFY (CLAIM 15) It would have been obvious to provide hydraulically powered backrest recline under controller command to improve user independence and comfort, using the known electro-hydraulic backrest actuation taught by Crepl and integrating it with Bayomy’s controller-operated hydraulic power unit. The modification is predictable and uses known components performing their known functions.
───────── CLAIM 16
The lifting and reclining wheelchair of claim 15, further comprising: a pair of leg supports connected to the upper frame and the seat; and a pair of leg support hydraulic actuators connected to the seat and the backrest, the controller configured to operate the hydraulic motor to drive the pair of leg support hydraulic actuators to move the leg supports relative to the seat between a straight position and a seated position.
CLAIM 16 – REJECTION UNDER 35 U.S.C. 103 Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3) and further in view of Smith (Reference 2).
CLAIM 16 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 16 includes all limitations of claim 15, which are met by Bayomy in view of Crepl as set forth above.
a pair of leg supports connected to the upper frame and the seat Bayomy discloses footrests 526 on the seat assembly/upper frame structure.
a pair of leg support hydraulic actuators connected to the seat and the backrest … to move the leg supports relative to the seat between a straight position and a seated position Smith discloses powered positioning of a leg rest (leg rest 114) relative to the seating system (seat 110; back 112). Crepl teaches hydraulic actuation of seating components using hydraulic cylinder(s) and valve(s).
Thus, providing hydraulic leg support actuators controlled by the controller to adjust leg supports between bent and straight positions is taught/ suggested by the combined teachings.
the controller configured to operate the hydraulic motor to drive the pair of leg support hydraulic actuators Bayomy discloses controller/controls for operating the hydraulic motor/pump unit. Therefore, the controller would operate the hydraulic motor and valves to drive the leg support actuators.
RATIONALE TO COMBINE / MODIFY (CLAIM 16) It would have been obvious to add powered leg support positioning to provide comfort and medical benefits (pressure relief, circulation), as taught by Smith’s adjustable leg rest, and to implement that positioning using hydraulic actuators powered and controlled by Bayomy’s hydraulic motor/pump system, as taught by Crepl’s electro-hydraulic actuation. The modification is a predictable application of known actuation technology.
───────── CLAIM 17
The lifting and reclining wheelchair of claim 16, further comprising: a stabilization wheel connected to the lower frame and movable with respect to the lower frame between a stored position and a deployed position; and an interlock configured to generate a signal based on whether the stabilization wheel is in the stored position or the deployed position, the controller configured to prevent the pair of backrest hydraulic actuators from moving to the reclined position when the stabilization wheel is not in the deployed position.
CLAIM 17 – REJECTION UNDER 35 U.S.C. 103 Claim 17 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3) and Smith (Reference 2) and further in view of Kraft (Reference 4) and Pedersen (Reference 5) and Johnson (Reference 6).
CLAIM 17 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 17 includes all limitations of claim 16, which are met by Bayomy in view of Crepl and Smith as set forth above.
a stabilization wheel … movable … between a stored position and a deployed position Kraft discloses anti-tipping device 20 with wheel 22 movable between a retracted inoperative (stored) position and an extended operative (deployed) position via linkage 28.
an interlock configured to generate a signal based on whether the stabilization wheel is in the stored position or the deployed position Pedersen teaches sensor input channels (microprocessor 59) interfacing tip-switches/limit switches to generate lock-out behavior based on sensed conditions. Johnson teaches a limit switch 14 as a position-based interlock generating a signal within a lift control system.
the controller configured to prevent the pair of backrest hydraulic actuators from moving to the reclined position when the stabilization wheel is not in the deployed position Pedersen teaches inhibiting/restricting recline/tilt based on sensor input data, i.e., using sensor conditions to prevent unsafe recline. Thus, the controller of claim 14 would be configured to inhibit recline when the stabilization wheel is not deployed, based on the interlock signal.
RATIONALE TO COMBINE / MODIFY (CLAIM 17) It would have been obvious to incorporate Kraft’s deployable anti-tip wheel and to add a position interlock as taught by Pedersen and Johnson to inhibit recline when the stabilization wheel is not deployed, in order to reduce tip-over risk and improve safety during recline. This is a predictable application of known anti-tip and interlock techniques to wheelchair recline functions.
───────── CLAIM 18
The lifting and reclining wheelchair of claim 17, further comprising: a stabilization handle manually user-operable to move the stabilization wheel between the stored position and the deployed position.
CLAIM 18 – REJECTION UNDER 35 U.S.C. 103 Claim 18 is rejected under 35 U.S.C. 103 as being unpatentable over the combination applied to claim 17 above.
CLAIM 18 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 18 includes all limitations of claim 17, and further requires a stabilization handle.
a stabilization handle manually user-operable to move the stabilization wheel between the stored position and the deployed position Kraft teaches a manually operable hand grip/actuating member (arm 64 of double-armed lever 62) used by the seated occupant to operate the anti-tipping device 20 (deploy/retract wheel 22).
RATIONALE TO COMBINE / MODIFY (CLAIM 18) It would have been obvious to provide an occupant-accessible handle to deploy/retract the stabilization wheel to allow rapid, convenient stabilization without requiring an attendant, as taught by Kraft’s lever/hand grip mechanism.
───────── CLAIM 19
The lifting and reclining wheelchair of claim 17, further comprising: a wireless remote control user operable to communicate with the controller to move the wheelchair between the raised position and the lowered position, to move the pair of leg supports between the straight position and the seated position, and to move the backrest between the upright position and the reclined position.
CLAIM 19 – REJECTION UNDER 35 U.S.C. 103 Claim 19 is rejected under 35 U.S.C. 103 as being unpatentable over the combination applied to claim 17 above and further in view of Smith (Reference 2).
CLAIM 19 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 19 includes all limitations of claim 17, which are met as set forth above.
a wireless remote control user operable to communicate with the controller Smith teaches a remote (remote 217) and IR sensor 219, and further indicates RF remote may be employed.
to move the wheelchair between the raised position and the lowered position, to move the pair of leg supports … and to move the backrest … Bayomy provides the lift function (raise/lower) via hydraulic lift; claim 17 combination provides backrest/leg support actuation and controller interlocks; Smith provides wireless remote interface.
RATIONALE TO COMBINE / MODIFY (CLAIM 19) It would have been obvious to add wireless remote control for the lift/recline/leg positioning functions to improve accessibility and allow operation without requiring the user to reach fixed controls, as taught by Smith’s wireless remote control architecture. Integration with the controller is straightforward and yields predictable results.
───────── CLAIM 20
The lifting and reclining wheelchair of claim 17, comprising: a pair of leg hydraulic valves associated with respective ones of the pair of leg support hydraulic actuators, the pair of leg hydraulic valves hydraulically connected to the hydraulic motor, and the controller operable to control the pair of leg hydraulic valves and the hydraulic motor to move the pair of leg supports between the straight position and the seated position, individually; a main hydraulic valve associated with the hydraulic lift, the main hydraulic valve hydraulically connected to the hydraulic motor, and the controller operable to control the main hydraulic valve and the hydraulic motor to move the upper frame between the raised position and the lowered position; and a backrest hydraulic valve associated with the pair of backrest hydraulic actuators, the backrest hydraulic valve hydraulically connected to the hydraulic motor, and the controller operable to control the backrest hydraulic valve and the hydraulic motor to move the backrest between the upright position and the reclined position.
CLAIM 20 – REJECTION UNDER 35 U.S.C. 103 Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Bayomy (Reference 1) in view of Crepl (Reference 3) and further in view of Johnson (Reference 6) and Pedersen (Reference 5) and as applied through claim 17.
CLAIM 20 – LIMITATION-BY-LIMITATION ANALYSIS
Claim 20 includes all limitations of claim 17, which are met by the combination applied to claim 17 above, and further recites specific valve groupings for leg supports, lift, and backrest.
a pair of leg hydraulic valves … controller operable to control the pair of leg hydraulic valves and the hydraulic motor … individually Crepl teaches solenoid valve 178 controlling a hydraulic cylinder 171. Johnson teaches hydraulic valve architecture in a motor/pump-driven system (return valve 88; regulator valve 89) controlling hydraulic rams 76. Pedersen teaches independent control channels for left/right leg rest positioning under microprocessor 59 control.
Thus, providing two separate hydraulic valves (one per leg actuator) under controller command is suggested by combining the valve-controlled hydraulic actuation teachings with Pedersen’s independent left/right control.
a main hydraulic valve associated with the hydraulic lift … controller operable to control the main hydraulic valve and the hydraulic motor to move the upper frame between the raised position and the lowered position Bayomy discloses the hydraulic lift function (lifting cylinders 532 driven by pump box 536), and Crepl/Johnson teach using valves to control hydraulic actuator motion. Thus, providing a main valve dedicated to the lift function is an obvious implementation detail of the hydraulic control circuit.
a backrest hydraulic valve associated with the pair of backrest hydraulic actuators … controller operable to control the backrest hydraulic valve and the hydraulic motor Crepl teaches valve-controlled backrest actuation (solenoid valve 178 controlling cylinder 171) and thus supports a dedicated backrest valve. Pedersen teaches microprocessor-controlled mapping of outputs to positioning mechanisms and supports controller operation of the valve(s) and pump motor.
RATIONALE TO COMBINE / MODIFY (CLAIM 20) It would have been obvious to implement a multi-function hydraulic circuit with dedicated valves for each controlled function (left/right leg supports, lift, and backrest) because Crepl and Johnson show that hydraulic actuators are controlled via valves in motor/pump-driven circuits, and Pedersen teaches that a controller can independently control multiple outputs (including left/right leg rest mechanisms and recline) with safety/sensor integration. Providing separate valves per function yields predictable benefits of independent control, safety, and maintainability.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JASON C SMITH whose telephone number is (703)756-4641. The examiner can normally be reached Monday - Friday 8:30 AM - 5:00 PM.
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, Allen Shriver can be reached at (303) 297-4337. 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.
/Jason C Smith/ Primary Examiner, Art Unit 3613