Prosecution Insights
Last updated: July 17, 2026
Application No. 18/680,671

ACTUATING WHEELS OF TOWED VEHICLE TO MITIGATE FOR INSTABILITY

Final Rejection §103
Filed
May 31, 2024
Examiner
IVEY, DANA DESHAWN
Art Unit
3662
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Toyota Motor Corporation
OA Round
2 (Final)
89%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 89% — above average
89%
Career Allowance Rate
691 granted / 778 resolved
+36.8% vs TC avg
Moderate +7% lift
Without
With
+7.0%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 11m
Avg Prosecution
17 currently pending
Career history
812
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
40.1%
+0.1% vs TC avg
§102
40.6%
+0.6% vs TC avg
§112
14.2%
-25.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 778 resolved cases

Office Action

§103
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 . This final action is in response to Applicant’s filing dated February 13, 2026. Claims 1-20 are currently pending and have been considered, as provided in more detail below. Claims 1-4, 6-17 and 19-20 have all been amended. *Examiner Note: Claim language is bolded. Cited References and Applicant’s arguments are italicized. Examiner interpretations are preceded with an asterisk *. Response to Arguments Applicant's arguments filed 2/13/26 have been fully considered but they are not persuasive and they are moot. Applicant asserts that the cited references fail to disclose or suggest the generation of the stability signature or actuation of the wheel of the towed vehicle as recited in the amended independent claims on pages 9-10 of Applicant’s Remarks. However, Examiner respectfully does not agree. The rejection relies on the combined teachings of Craig et al. (US 2010/0211277 A1), Crawford (US 2020/0238976 A1) and Czeschner (EP3176042 B1). Regarding the stability signature, as broadly recited, Craig (see at least para. [0061] of Craig which describes “stability control” and “operating conditions … a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”)., *Examiner interprets the collection and use of trailer operating condition signals and state estimation associated with stability control as corresponding to generating a stability signature because the sensed operating condition information is processed to characterize trailer stability conditions). Applicant additionally argues that the cited references fail to disclose that the stability signature indicates an unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle. However, paragraph [0018] of Crawford expressly discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer … Thus, such occurrences from … natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”. Examiner interprets the disclosed unopposed lateral force caused by the crosswinds and/or other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle, under the broadest reasonable interpretation. Applicant further argues that the cited references fail to disclose actuation of the wheel of the towed vehicle as recited in the amended independent claims. This argument is also not persuasive. Craig teaches generating a control signal (see at least para. [0050] of Craig which discloses “the controller 106 or the arbitration function of the controller 106 can provide control signals to various ones of the vehicle's 100 subsystems to provide stability control” and see at least para. [0056] of Craig which discloses “Control modules 406, in turn, may supply command or control signals to associated components 410 of the subsystem to which they are associated. In various embodiments, control modules 406 may send command or control signals”). Czeschner further teaches a stabilization system for a vehicle trailer (see at least the 1st paragraph on pg. 4 of the translation of Czeschner which discloses “It is the object of the present invention to provide an improved stabilization technique for vehicle trailers”, *Examiner interprets the improved stabilization technique will mitigate instability. Also see the 3rd paragraph on pg. 4 which discloses “An unstable driving state of a vehicle trailer is understood to mean a movement behavior of the vehicle trailer that deviates significantly from the movement of the train or does not follow this movement or follows this movement to a lesser extent, with unstable driving states particularly including: a rotation or oscillation of the vehicle trailer around the vertical axis, the transverse axis or the longitudinal axis (yaw, pitch or roll), the lifting of at least one trailer wheel from the roadway and / or translational vibrations in the longitudinal or transverse direction of the vehicle trailer”, *Examiner interprets these unstable conditions and notes the purpose of the actuator is for stabilization, i.e., mitigating instability). Examiner interprets the disclosed trailer brake actuation for stabilization as corresponding to generating a control signal that actuates a wheel of the towed vehicle to mitigate instability because actuation of the trailer brake necessarily actuates the associated trailer wheel in response to the detected trailer instability conditions. Therefore , Applicant’s arguments and amendments are not persuasive and the rejection under 35 USC 103 is maintained as outlined below. Response to Amendment Regarding the rejection under 35 USC 103, the amendments made to the claims fail to overcome the prior art. The rejection under 35 USC 103 is maintained as outlined below. Claim Objections Claims 8, 16 20 are objected to because of the following informalities: The phrase “wherein decision to minimize” of claims 8 and 16 and the phrase “and decision to minimize” of claim 20 appear to contain a typographical error. Perhaps Applicant intended to use the phrases – wherein a decision to minimize – and – and decision to minimize – instead. The phrase “steady state steady state” of claim 9 also appears to contain a typographical error. Perhaps Applicant intended to use – steady state – instead. Appropriate correction is required. 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. 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 1, 3-5, 9-11, 13 and 17-18 are rejected under 35 U.S.C. 103 as being unpatentable over Craig et al. (US 2010/0211277 A1) in view of Crawford (US 2020/0238976 A1) and further in view of Czeschner (EP3176042 B1). Regarding amended claim 1, Craig discloses A method comprising: analyzing sensor data (see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor may be used to decide how much torque to apply”, *Examiner interprets the use of feedback from steering, wheel speed, lateral and yaw sensors to determine corrective torque application as teaching analysis of sensor data because the sensed operating-condition information is processed to determine a vehicle stability-control response) from at least one sensor (see at least para. [0029] of Craig which discloses “sensors associated with one or more vehicle subsystems or sensors. Moreover, controller 106 can be configured to receive or collect data or signals directly from one or more vehicle subsystems or sensors. For example, controller 106 may receive or collect data or signals directly from an electronic control unit (ECU) associated with one or more of the vehicle subsystems or sensors”) positioned within an environment (see at least para. [0030] of Craig which discloses “controller 106 can be configured to receive a plurality of data or signals representing current vehicle operating conditions … Current driving conditions also may be GPS data or weather data indicative of a vehicle's real-time location or position“, Examiner interprets the receipt and use of current driving-condition data, GPS data and weather data associated with the vehicle’s real-time location as teaching sensing conditions within the environment in which the vehicle is traveling) in which a towed vehicle (Fig. 5, 800 and see at least para. [0009] of Craig which discloses “a method for electronic stability control of a wheeled tactical vehicle and a trailer coupled to the wheeled tactical vehicle” and see at least para. [0061] of Craig which discloses “the vehicle 700 and trailer 800 are physically and electronically coupled together”, *Examiner interprets the disclosed trailer 800 coupled to the wheeled tactical vehicle as corresponding to a towed vehicle being towed by a towing vehicle 700 because one of ordinary skill in the art would understand a trailer physically coupled behind a vehicle for joint operation and stability control to be towed by the vehicle) is traveling (see at least para. [0061] of Craig which discloses “operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”, *Examiner interprets the disclosed trailer operating conditions as corresponding to conditions experienced while the trailer/towed vehicle is traveling) to generate a stability signature (see at least para. [0061] of Craig which describes “stability control” and “operating conditions … a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets the collection and use of trailer operating condition signals and state estimation associated with stability control as corresponding to generating a stability signature because the sensed operating condition information is processed to characterize trailer stability conditions) that characterizes external conditions (see at least para. [0033] of Craig which discloses “weather data or signals. In various embodiments, controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets this weather data and driving condition signals as corresponding to external conditions associated with the envionrment surrounding the vehicle/trailer system since para. [0018] of Applicant’s specification describes “External conditions, as used herein, may refer to conditions or characteristics of an environment surrounding the towed vehicle/towing vehicle pair and external thereto, for example, but not limited to, crosswinds”) experienced by the towed vehicle (see at least para. [0061] of Craig which discloses “stability control may be provided for the vehicle 700 and the trailer 800 simultaneously. In various embodiments, stability control can be provided based on the dominant stability control system defined, chosen, or selected. For example, controller 106 can received vehicle operating signals or data from subsystems 200. Controller 106 also can receive trailer operating signals or data from subsystems 200 of trailer 800 via the J1939 bus. The operating conditions of vehicle 700 can be substantially as those described previously. Similarly, operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”) while the towed vehicle is towed (see at least para. [0061] of Craig which discloses “stability control may be provided for the vehicle 700 and the trailer 800 simultaneously. In various embodiments, stability control can be provided based on the dominant stability control system defined, chosen, or selected. For example, controller 106 can received vehicle operating signals or data from subsystems 200. Controller 106 also can receive trailer operating signals or data from subsystems 200 of trailer 800 via the J1939 bus. The operating conditions of vehicle 700 can be substantially as those described previously. Similarly, operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”, *Examiner interprets the disclosed trailer operating conditions and simultaneous vehicle/trailer stability control as corresponding to conditions experienced by the towed vehicle while being towed) by a towing vehicle (Fig. 5, 700 and see at least para. [0061] of Craig which discloses “a vehicle 700 and a trailer 800. As can be seen, the vehicle 700 and trailer 800 are physically and electronically coupled together. In various embodiments, the electronic coupling may be via a J1939 bus 900 and the physical coupling can be via physical links 750 and 850”, *Examiner interprets vehicle 700 as corresponding to the claimed towing vehicle because one of ordinary skill in the art would understand vehicle 700 to be physically coupled to and controlling trailer 800 to tow trailer 800 during operation), and having a response to the unopposed lateral force applied to the towed vehicle indicated by the stability signature; exceeding a stability threshold (see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor may be used to decide how much torque to apply” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets the use of sensed operating conditions and state estimation to determine when corrective stability control should be applied as corresponding to determining whether the stability condition exceeds a stability threshold, as broadly as recited), which indicates(see at least para. [0058] of Craig which discloses “Based on the values of the inputs, some or all of which may be compared to predetermined values, the system and method can determine that stability control needs to take place. The system and method can define, choose, or select a dominant control subsystem for control (torque-based stability control in this case), and can provide as outputs for stability control, a signal to disable brake-based stability control, a signal to increase torque to inside wheels of the vehicle (assuming the vehicle is turning), and a signal to increase damping on outside shocks. The foregoing may be actions taken for an “off-road oversteer” condition”, *Examiner interprets the comparison to predetermined values to be equivalent to satisfying a stability threshold), generating a control signal (see at least para. [0050] of Craig which discloses “the controller 106 or the arbitration function of the controller 106 can provide control signals to various ones of the vehicle’s 100 subsystems to provide stability control” and see at least para. [0056] of Craig which discloses “Control modules 406, in turn, may supply command or control signals to associated components 410 of the subsystem to which they are associated. In various embodiments, control modules 406 may send command or control signals”). Craig discloses a vehicle/trailer stability control system that analyzes sensor data to determine a stability-related condition and apply corrective control. Craig may not explicitly disclose that the stability signature is indicative of an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle. However, in the same field of endeavor, Crawford discloses the stability signature indicative of an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the stability control method of Craig to account for an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle, as taught in Crawford with a reasonable expectation off success in order to improve detection and mitigation of trailer instability caused by crosswinds and other lateral external disturbances and thereby improve vehicle/trailer stability and towing safety. Craig, as modified by Crawford, may not explicitly disclose that the control signal is based on the stability signature that actuates a wheel of the towed vehicle to mitigate the instability of the towed vehicle. However, in the same field of endeavor, Czeschner discloses the control signal based on the stability signature that actuates a wheel (Fig. 1, 114 and see at least the 5th full paragraph on pg. 8 of the translation of Czeschner which describes “the wheel (114) together with a wheel bearing”) of the towed vehicle to mitigate the instability (see at least the 1st paragraph on pg. 4 of the translation of Czeschner which discloses “It is the object of the present invention to provide an improved stabilization technique for vehicle trailers”, *Examiner interprets the improved stabilization technique will mitigate instability. Also see the 3rd paragraph on pg. 4 which discloses “An unstable driving state of a vehicle trailer is understood to mean a movement behavior of the vehicle trailer that deviates significantly from the movement of the train or does not follow this movement or follows this movement to a lesser extent, with unstable driving states particularly including: a rotation or oscillation of the vehicle trailer around the vertical axis, the transverse axis or the longitudinal axis (yaw, pitch or roll), the lifting of at least one trailer wheel from the roadway and / or translational vibrations in the longitudinal or transverse direction of the vehicle trailer”, *Examiner interprets these unstable conditions and notes the purpose of the actuator is for stabilization, i.e., mitigating instability) of the towed vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes, which is carried out by an overrun device. In this way, the fail-safe basic braking function, which is free of power supply, is retained”, *Examiner interprets this to be evidence of wheel actuation via the brake actuator with the superimposed actuation translating to an electronically commanded adjustment that is precisely a control signal actuation). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method and control signal of Craig, as modified by Crawford, to include generating a control signal based on the stability signature that actuates a wheel of the towed vehicle to mitigate the instability of the towed vehicle, as taught in Czeschner with a reasonable expectation of success in order to provide automated wheel actuation via brake or torque control in response to instability detection to improve mitigation of trailer sway and other instability events. See pg. 4, paragraphs. 3-5 of Czeschner for motivation. Regarding claim 3, the combination of Craig in view of Crawford and Czeschner, discloses wherein the towed vehicle is an actuated vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes”). Czeschner further discloses an over-actuated vehicle (see at least paragraph 2 on pg. 13 of Czeschner which discloses “two or more brake actuators (23) can be provided, each of which actuates a wheel brake (14) separately” , *Examiner interprets this to be evidence of an over-actuated vehicle because there may be more than two actuators and para. [0049] of Applicant’s specification discloses “an over-actuated vehicle may have more than two actuators”) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Czeschner to include an over-actuated vehicle, as further taught by Czeschner with a reasonable expectation of success in order to increase the flexibility in movement and to improve steering capabilities. Regarding claim 4, Craig, as modified by Crawford and Czeschner discloses wherein the sensor data comprises one or more of: environmental data (see at least para. [0030] of Craig which discloses “controller 106 can be configured to receive a plurality of data or signals representing current vehicle operating conditions … Current driving conditions also may be GPS data or weather data indicative of a vehicle's real-time location or position, for example. As will be described later, the GPS data and thus the GPS signal output can be correlated to a terrain map corresponding to the vehicle's real-time location. Furthermore, weather data and thus the weather signal output can be correlated to the GPS data corresponding to the vehicle's real-time position or location”, *Examiner interprets that since the sensors such as GPS and weather sensors measure environmental conditions external to the vehicle, they will produce environmental data) and vehicle dynamics of the towed vehicle see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor”, *Examiner interprets this as evidence of vehicle dynamics of the first vehicle). Regarding claim 5, the combination of Craig in view of Crawford and Czeschner discloses the sensor data (see at least para. [0033] of Craig which discloses “weather data or signals. In various embodiments, controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets this weather data may include wind data). Crawford further discloses wherein the sensor data comprises a wind speed (see at least para. [0051] of Crawford which discloses “depending on particular conditions (e.g., amount of sway/lateral forces, trailer size, weather conditions, traffic, etc.), the stability module 230 can vary the response to the sway in combinations of controls and the degree (e.g., amount of braking/acceleration) that is employed to counteract the sway“ see at least para. [0062] of Crawford which describes “weather conditions, and so on”, *Examiner interprets weather conditions to include wind speed) and a wind direction (see at least para. [0018] of Crawford which discloses “natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets these crosswinds to be an example of wind direction) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the sensor data of Craig, as modified by Czeschner, to include a wind speed and a wind direction, as taught in Crawford with a reasonable expectation of success in order to improve the effectiveness of the stabilization system to account for environmental factors. See para. [0051] of Crawford for motivation. Regarding claim 9, Craig, as modified by Crawford and Czeschner discloses wherein the stability threshold (see at least para. [0046] of Crawford which discloses “the stability module 230 determines the onset of instability according to a pressure differential by using the criteria 260 that define thresholds/conditions associated with the onset. As with other aspects of the trailer stability system 170, the criteria 260 can be implemented with varying degrees of specificity and characteristics depending on a particular implementation. For example, in one approach, the trailer stability system 170 defines the criteria 260 as a pressure threshold associated with the pressure differentials and indicating a magnitude of the pressure differential to trigger a response by the stability module 230. It should be appreciated that while the pressure threshold is discussed as a binary trigger, a response of the system 170 can include varying tiers (i.e., degrees/combinations) of controls according to the pressure differentials once the initial pressure threshold is satisfied“) is a steady state steady state threshold force that represents a maximum lateral force at which a pair of the towed vehicle and the towing vehicle remains in steady state (see at least para. [0036] of Crawford which discloses “The signature module 220 may sample the pressure measurements at regular intervals and, for example, normalize the pressure measurements according to identified steady states for the respective sensors”, *Examiner interprets the disclosed normalization according to identified steady states, when considered in view of Crawford’s lateral-force-induced trailer instability conditions and Craig’s predetermined stability control thresholds, as corresponding to a steady state threshold force representing a maximum lateral force at which the towing vehicle/trailer pair remains in a steady-state operating condition. Regarding amended claim 10, Craig discloses A vehicle stabilization system (see at least para. [0007] of Craig which discloses “a plurality of stability control subsystems for the wheeled vehicle, the plurality including at least a brake-based stability control subsystem and a torque management-based stability control subsystem; responsive to said received data associated with current vehicle operating conditions and said received data associated with current trailer operating conditions, automatically selecting one of the plurality as dominant; and providing stability control of the wheeled vehicle and the trailer using the automatically chosen dominant stability control system”), comprising: a towed vehicle (Fig. 5, 800 and see at least para. [0009] of Craig which discloses “a method for electronic stability control of a wheeled tactical vehicle and a trailer coupled to the wheeled tactical vehicle” and see at least para. [0061] of Craig which discloses “the vehicle 700 and trailer 800 are physically and electronically coupled together”, *Examiner interprets the disclosed trailer 800 coupled to the wheeled tactical vehicle as corresponding to a towed vehicle being towed by a towing vehicle 700 because one of ordinary skill in the art would understand a trailer physically coupled behind a vehicle for joint operation and stability control to be towed by the vehicle) having a wheel (Fig. 1, 104 and Fig. 5 of Craig illustrates wheels of the first vehicle 800 and see at least para. [0015] of Craig which discloses “wheels 104 being implemented, for example, but it will be appreciated that any suitable number of wheels can be implemented, such as four wheels or six wheels, without limitation” and see at least para. [0014] of Craig which discloses “Mobile vehicle 102 can be any suitable vehicle, such as a car, a truck, a trailer, a tactical vehicle, a flatbed truck adapted to receive different shelters or modules on its bed, a wheeled Human Mobility Vehicle (HMV), a Joint Light Tactical or Technology Vehicle (JLTV), etc.”) and a vehicle system configured to control the wheel (see at least para. [0059] of Craig which discloses “a dominant control subsystem for control (torque-based stability control in this case), and can provide as outputs for stability control, a signal to disable brake-based stability control, a signal to increase torque to outside wheels of the vehicle”); a memory storing instructions; and one or more processors communicably coupled to the memory and configured to execute the instructions to: analyze sensor data from at least one sensor positioned within an environment in which the towed vehicle is traveling (see at least para. [0061] of Craig which discloses “operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”, *Examiner interprets the disclosed trailer operating conditions as corresponding to conditions experienced while the trailer/towed vehicle is traveling) to generate a stability signature (see at least para. [0061] of Craig which describes “stability control” and “operating conditions … a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets the collection and use of trailer operating condition signals and state estimation associated with stability control as corresponding to generating a stability signature because the sensed operating condition information is processed to characterize trailer stability conditions) that characterizes external conditions (see at least para. [0033] of Craig which discloses “weather data or signals. In various embodiments, controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets this weather data and driving condition signals as corresponding to external conditions associated with the envionrment surrounding the vehicle/trailer system since para. [0018] of Applicant’s specification describes “External conditions, as used herein, may refer to conditions or characteristics of an environment surrounding the towed vehicle/towing vehicle pair and external thereto, for example, but not limited to, crosswinds”) experienced by the (see at least para. [0061] of Craig which discloses “stability control may be provided for the vehicle 700 and the trailer 800 simultaneously. In various embodiments, stability control can be provided based on the dominant stability control system defined, chosen, or selected. For example, controller 106 can received vehicle operating signals or data from subsystems 200. Controller 106 also can receive trailer operating signals or data from subsystems 200 of trailer 800 via the J1939 bus. The operating conditions of vehicle 700 can be substantially as those described previously. Similarly, operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”) while the towed vehicle is towed (see at least para. [0061] of Craig which discloses “stability control may be provided for the vehicle 700 and the trailer 800 simultaneously. In various embodiments, stability control can be provided based on the dominant stability control system defined, chosen, or selected. For example, controller 106 can received vehicle operating signals or data from subsystems 200. Controller 106 also can receive trailer operating signals or data from subsystems 200 of trailer 800 via the J1939 bus. The operating conditions of vehicle 700 can be substantially as those described previously. Similarly, operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”, *Examiner interprets the disclosed trailer operating conditions and simultaneous vehicle/trailer stability control as corresponding to conditions experienced by the towed vehicle while being towed) by a(Fig. 5, 700 and see at least para. [0061] of Craig which discloses “a vehicle 700 and a trailer 800. As can be seen, the vehicle 700 and trailer 800 are physically and electronically coupled together. In various embodiments, the electronic coupling may be via a J1939 bus 900 and the physical coupling can be via physical links 750 and 850”, *Examiner interprets vehicle 700 as corresponding to the claimed towing vehicle because one of ordinary skill in the art would understand vehicle 700 to be physically coupled to and controlling trailer 800 to tow trailer 800 during operation),, and having a response to(see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor may be used to decide how much torque to apply” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets the use of sensed operating conditions and state estimation to determine when corrective stability control should be applied as corresponding to determining whether the stability condition exceeds a stability threshold, as broadly as recited) which indicates an onset of an instability of the towed vehicle (see at least para. [0058] of Craig which discloses “Based on the values of the inputs, some or all of which may be compared to predetermined values, the system and method can determine that stability control needs to take place. The system and method can define, choose, or select a dominant control subsystem for control (torque-based stability control in this case), and can provide as outputs for stability control, a signal to disable brake-based stability control, a signal to increase torque to inside wheels of the vehicle (assuming the vehicle is turning), and a signal to increase damping on outside shocks. The foregoing may be actions taken for an “off-road oversteer” condition”, *Examiner interprets the comparison to predetermined values to be equivalent to satisfying a stability threshold): generate a control signal (see at least para. [0050] of Craig which discloses “the controller 106 or the arbitration function of the controller 106 can provide control signals to various ones of the vehicle’s 100 subsystems to provide stability control” and see at least para. [0056] of Craig which discloses “Control modules 406, in turn, may supply command or control signals to associated components 410 of the subsystem to which they are associated. In various embodiments, control modules 406 may send command or control signals”). Craig discloses a vehicle/trailer stability control system that analyzes sensor data to determine a stability-related condition and apply corrective control. Craig may not explicitly disclose that the stability signature is indicative of an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle. However, in the same field of endeavor, Crawford discloses the stability signature indicative of an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the stability control system of Craig to account for an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle, as taught in Crawford with a reasonable expectation off success in order to improve detection and mitigation of trailer instability caused by crosswinds and other lateral external disturbances and thereby improve vehicle/trailer stability and towing safety. Craig, as modified by Crawford, may not explicitly disclose that the control signal is based on the stability signature; and provide the control signal to the vehicle system to actuate the wheel of the towed vehicle to mitigate the instability of the towed vehicle. However, in the same field of endeavor, Czeschner discloses the control signal based on the stability signature that actuates a wheel (Fig. 1, 114 and see at least the 5th full paragraph on pg. 8 of the translation of Czeschner which describes “the wheel (114) together with a wheel bearing”) of the towed vehicle to mitigate the instability (see at least the 1st paragraph on pg. 4 of the translation of Czeschner which discloses “It is the object of the present invention to provide an improved stabilization technique for vehicle trailers”, *Examiner interprets the improved stabilization technique will mitigate instability. Also see the 3rd paragraph on pg. 4 which discloses “An unstable driving state of a vehicle trailer is understood to mean a movement behavior of the vehicle trailer that deviates significantly from the movement of the train or does not follow this movement or follows this movement to a lesser extent, with unstable driving states particularly including: a rotation or oscillation of the vehicle trailer around the vertical axis, the transverse axis or the longitudinal axis (yaw, pitch or roll), the lifting of at least one trailer wheel from the roadway and / or translational vibrations in the longitudinal or transverse direction of the vehicle trailer”, *Examiner interprets these unstable conditions and notes the purpose of the actuator is for stabilization, i.e., mitigating instability) of the towed vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes, which is carried out by an overrun device. In this way, the fail-safe basic braking function, which is free of power supply, is retained”, *Examiner interprets this to be evidence of wheel actuation vias the brake actuator with the superimposed actuation translating to an electronically commanded adjustment that is precisely a control signal actuation). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method and control signal of Craig, as modified by Crawford, to include generating a control signal based on the stability signature; and provide the control signal to the vehicle system to actuate the wheel of the towed vehicle to mitigate the instability of the towed vehicle, as taught in Czeschner with a reasonable expectation of success in order to provide automated wheel actuation via brake or torque control in response to instability detection to improve mitigation of trailer sway and other instability events. See pg. 4, paragraphs. 3-5 of Czeschner for motivation. Regarding claim 11, the combination of Craig in view of Crawford and Czeschner, discloses wherein the towed vehicle is an actuated vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes”). Czeschner further discloses an over-actuated vehicle (see at least paragraph 2 on pg. 13 of Czeschner which discloses “two or more brake actuators (23) can be provided, each of which actuates a wheel brake (14) separately” , *Examiner interprets this to be evidence of an over-actuated vehicle because there may be more than two actuators and para. [0049] of Applicant’s specification discloses “an over-actuated vehicle may have more than two actuators”) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Czeschner to include an over-actuated vehicle, as further taught by Czeschner with a reasonable expectation of success in order to increase the flexibility in movement and to improve steering capabilities. Regarding claim 13, Craig, as modified by Crawford and Czeschner discloses wherein the sensor data comprises one or more of: environmental data (see at least para. [0030] of Craig which discloses “controller 106 can be configured to receive a plurality of data or signals representing current vehicle operating conditions … Current driving conditions also may be GPS data or weather data indicative of a vehicle's real-time location or position, for example. As will be described later, the GPS data and thus the GPS signal output can be correlated to a terrain map corresponding to the vehicle's real-time location. Furthermore, weather data and thus the weather signal output can be correlated to the GPS data corresponding to the vehicle's real-time position or location”, *Examiner interprets that since the sensors such as GPS and weather sensors measure environmental conditions external to the vehicle, they will produce environmental data) and vehicle dynamics of the towed vehicle see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor”, *Examiner interprets this as evidence of vehicle dynamics of the first vehicle). Regarding amended claim 17, Craig discloses A vehicle (Fig. 5, 800 and see at least para. [0061] of Craig which discloses “a trailer 800” and see at least para. [0014] of Craig which discloses “Mobile vehicle 102 can be any suitable vehicle, such as a car, a truck, a trailer, a tactical vehicle, a flatbed truck adapted to receive different shelters or modules on its bed, a wheeled Human Mobility Vehicle (HMV), a Joint Light Tactical or Technology Vehicle (JLTV), etc.” *Examiner interprets the trailer to be a vehicle because a trailer is considered to be a vehicle since it is designed for transportation) comprising: a wheel (Fig. 1, 104 and Fig. 5 of Craig illustrates wheels of the first vehicle 800 and see at least para. [0015] of Craig which discloses “wheels 104 being implemented, for example, but it will be appreciated that any suitable number of wheels can be implemented, such as four wheels or six wheels, without limitation” and see at least para. [0014] of Craig which discloses “Mobile vehicle 102 can be any suitable vehicle, such as a car, a truck, a trailer, a tactical vehicle, a flatbed truck adapted to receive different shelters or modules on its bed, a wheeled Human Mobility Vehicle (HMV), a Joint Light Tactical or Technology Vehicle (JLTV), etc.”); a vehicle system configured to control the wheel (see at least para. [0059] of Craig which discloses “a dominant control subsystem for control (torque-based stability control in this case), and can provide as outputs for stability control, a signal to disable brake-based stability control, a signal to increase torque to outside wheels of the vehicle”); and a stabilization system (see at least para. [0007] of Craig which discloses “a plurality of stability control subsystems for the wheeled vehicle, the plurality including at least a brake-based stability control subsystem and a torque management-based stability control subsystem; responsive to said received data associated with current vehicle operating conditions and said received data associated with current trailer operating conditions, automatically selecting one of the plurality as dominant; and providing stability control of the wheeled vehicle and the trailer using the automatically chosen dominant stability control system”) configured to: receive a control signal (see at least para. [0050] of Craig which discloses “the controller 106 or the arbitration function of the controller 106 can provide control signals to various ones of the vehicle’s 100 subsystems to provide stability control” and see at least para. [0056] of Craig which discloses “Control modules 406, in turn, may supply command or control signals to associated components 410 of the subsystem to which they are associated. In various embodiments, control modules 406 may send command or control signals”) in response to a determination (see at least para. [0022] of Craig which discloses “output data or one or more signals representative of vehicle conditions associated with one or more of the above-noted roll, pitch, or yaw determination. Optionally, the data or one or more signals can be transmitted or outputted to controller 106, either directly or via another means, such as a converting means and/or an amplification means”) indicated by a stability signature (see at least para. [0061] of Craig which describes “stability control” and “operating conditions … a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets the collection and use of trailer operating condition signals and state estimation associated with stability control as corresponding to generating a stability signature because the sensed operating condition information is processed to characterize trailer stability conditions) exceeds a stability threshold (see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor may be used to decide how much torque to apply” and see at least para. [0033] of Craig which discloses “controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets the use of sensed operating conditions and state estimation to determine when corrective stability control should be applied as corresponding to determining whether the stability condition exceeds a stability threshold, as broadly as recited), which indicates an onset of an instability of the vehicle (see at least para. [0058] of Craig which discloses “Based on the values of the inputs, some or all of which may be compared to predetermined values, the system and method can determine that stability control needs to take place. The system and method can define, choose, or select a dominant control subsystem for control (torque-based stability control in this case), and can provide as outputs for stability control, a signal to disable brake-based stability control, a signal to increase torque to inside wheels of the vehicle (assuming the vehicle is turning), and a signal to increase damping on outside shocks. The foregoing may be actions taken for an “off-road oversteer” condition”, *Examiner interprets the comparison to predetermined values to be equivalent to satisfying a stability threshold), wherein the stability signature (see at least para. [0061] of Craig which describes “stability control” and “operating conditions”, *Examiner interprets this to be evidence of the stability signature because these operating conditions include “a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” as disclosed in para. [0061] and para. [0018] of Applicant’s specification discloses “a stability signature that characterizes external conditions experienced by the vehicle”) is based on sensor data (see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor may be used to decide how much torque to apply”, *Examiner interprets the determination of how much torque to apply to be evidence of analyzing sensor data since the feedback from sensors is used) from at least one sensor (see at least para. [0029] of Craig which discloses “sensors associated with one or more vehicle subsystems or sensors. Moreover, controller 106 can be configured to receive or collect data or signals directly from one or more vehicle subsystems or sensors. For example, controller 106 may receive or collect data or signals directly from an electronic control unit (ECU) associated with one or more of the vehicle subsystems or sensors”) positioned within an environment (see at least para. [0030] of Craig which discloses “controller 106 can be configured to receive a plurality of data or signals representing current vehicle operating conditions … Current driving conditions also may be GPS data or weather data indicative of a vehicle's real-time location or position, for example. As will be described later, the GPS data and thus the GPS signal output can be correlated to a terrain map corresponding to the vehicle's real-time location. Furthermore, weather data and thus the weather signal output can be correlated to the GPS data corresponding to the vehicle's real-time position or location”, *Examiner interprets that since the sensors such as GPS and weather sensors measure environmental conditions external to the vehicle, those sensors must be exposed to the envionrment and therefore they are positioned within an envionrment in which the vehicle is traveling) in which the vehicle is traveling (see at least para. [0061] of Craig which discloses “operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”, *Examiner interprets the disclosed trailer operating conditions as corresponding to conditions experienced while the trailer/towed vehicle is traveling) and characterizes the external conditions (see at least para. [0033] of Craig which discloses “weather data or signals. In various embodiments, controller 106 can include a state estimator, and the state estimator can be configured to perform the defining, choosing, or selecting of the dominant stability control system”, *Examiner interprets this weather data to be external conditions since para. [0018] of Applicant’s specification describes “External conditions, as used herein, may refer to conditions or characteristics of an environment surrounding the towed vehicle/towing vehicle pair and external thereto, for example, but not limited to, crosswinds”) experienced by the vehicle while the vehicle is towed (see at least para. [0061] of Craig which discloses “stability control may be provided for the vehicle 700 and the trailer 800 simultaneously. In various embodiments, stability control can be provided based on the dominant stability control system defined, chosen, or selected. For example, controller 106 can received vehicle operating signals or data from subsystems 200. Controller 106 also can receive trailer operating signals or data from subsystems 200 of trailer 800 via the J1939 bus. The operating conditions of vehicle 700 can be substantially as those described previously. Similarly, operating conditions of trailer 800 can include a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals”). Craig discloses a vehicle/trailer stability control system that analyzes sensor data to determine a stability-related condition and apply corrective control. Craig may not explicitly disclose that the stability signature is indicative of the unopposed lateral force applied to the vehicle from external conditions experienced by the vehicle. However, in the same field of endeavor, Crawford discloses the stability signature indicative of an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the stability control system of Craig to account for an unopposed lateral force applied to the towed vehicle from the external conditions experienced by the towed vehicle, as taught in Crawford with a reasonable expectation off success in order to improve detection and mitigation of trailer instability caused by crosswinds and other lateral external disturbances and thereby improve vehicle/trailer stability and towing safety. Craig may not explicitly disclose a wheel that is lifted off a road surface while the vehicle is towed and operate the vehicle system to autonomously control the wheel according to the control signal to mitigate the instability of the vehicle. However, in the same field of endeavor, Czeschner discloses a wheel that is lifted off a road surface while the vehicle is towed (see the 3rd paragraph on pg. 4 of Czeschner which discloses “the lifting of at least one trailer wheel from the roadway and/or translational vibrations in the longitudinal or transverse direction of the vehicle trailer” and see paragraph 4 on pg. 6 of Czeschner which discloses “lifting of a vehicle wheel from the ground, which can also be evaluated for the detection of an unstable driving situation”); and operate the vehicle system to control the wheel (Fig. 1, 114 and see at least the 5th full paragraph on pg. 8 of the translation of Czeschner which describes “the wheel (114) together with a wheel bearing”) according to the control signal to mitigate the instability (see at least the 1st paragraph on pg. 4 of the translation of Czeschner which discloses “It is the object of the present invention to provide an improved stabilization technique for vehicle trailers”, *Examiner interprets the improved stabilization technique will mitigate instability. Also see the 3rd paragraph which discloses “An unstable driving state of a vehicle trailer is understood to mean a movement behavior of the vehicle trailer that deviates significantly from the movement of the train or does not follow this movement or follows this movement to a lesser extent, with unstable driving states particularly including: a rotation or oscillation of the vehicle trailer around the vertical axis, the transverse axis or the longitudinal axis (yaw, pitch or roll), the lifting of at least one trailer wheel from the roadway and / or translational vibrations in the longitudinal or transverse direction of the vehicle trailer”, *Examiner interprets these unstable conditions and notes the purpose of the actuator is for stabilization, i.e., mitigating instability) of the vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes, which is carried out by an overrun device. In this way, the fail-safe basic braking function, which is free of power supply, is retained”, *Examiner interprets this to be evidence of wheel actuation vias the brake actuator with the superimposed actuation translating to an electronically commanded adjustment that is precisely a control signal actuation). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the method and control signal of Craig a wheel that is lifted off a road surface while the vehicle is towed and operate the vehicle system to control the wheel according to the control signal to mitigate the instability, as taught in Czeschner with a reasonable expectation of success in order to provide automated wheel actuation via brake or torque control in response to instability detection to improve mitigation of trailer sway and other instability events. See pg. 4, paras. 3-5 of Czeschner for motivation. Craig, as modified by Czeschner may not explicitly disclose autonomously controlling the wheel. However, in the same field of endeavor, Crawford discloses autonomously controlling the vehicle wheel (see at least para. [0074] of Crawford which discloses “the vehicle 100 is configured to switch selectively between an autonomous mode, one or more semi-autonomous operational modes“ and see at least para. [0093] of Crawford which discloses “the autonomous driving module(s) 160 can cause the vehicle 100 to accelerate (e.g., by increasing the supply of fuel provided to the engine), decelerate (e.g., by decreasing the supply of fuel to the engine and/or by applying brakes) and/or change direction (e.g., by turning the front two wheels“). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the driving system of Craig, as modified by Czeschner to include autonomously controlling the wheel, as taught in Crawford with a reasonable expectation of success in order to facilitate increased control of the power distribution among the vehicle wheels. See at least para. [0074] of Crawford for motivation. Regarding claim 18, the combination of Craig in view of Crawford and Czeschner, discloses wherein the towed vehicle is an actuated vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes”). Czeschner further discloses an over-actuated vehicle (see at least paragraph 2 on pg. 13 of Czeschner which discloses “two or more brake actuators (23) can be provided, each of which actuates a wheel brake (14) separately” , *Examiner interprets this to be evidence of an over-actuated vehicle because there may be more than two actuators and para. [0049] of Applicant’s specification discloses “an over-actuated vehicle may have more than two actuators”) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Czeschner to include an over-actuated vehicle, as further taught by Czeschner with a reasonable expectation of success in order to increase the flexibility in movement and to improve steering capabilities. Claims 2 and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Craig et al. (US 2010/0211277 A1) in view of Crawford (US 2020/0238976 A1) in view of Czeschner (EP3176042 B1) and further and further in view of DeMichele (US 5,013,209A). Regarding claim 2, the combination of Craig in view of Crawford and Czeschner discloses wherein the towed vehicle (Fig. 5, 800 and see at least para. [0061] of Craig which discloses “a vehicle 700 and a trailer 800. As can be seen, the vehicle 700 and trailer 800 are physically and electronically coupled together. In various embodiments, the electronic coupling may be via a J1939 bus 900 and the physical coupling can be via physical links 750 and 850. Note that vehicle 700 may be substantially the same as the vehicle 102 in Figs. 1 and 2”, *Examiner interprets vehicle 800 to be the first vehicle) is hitched (see at least para. [0061] of Craig which discloses “the physical coupling can be via physical links 750 and 850”, *Examiner interprets the physical links 750/850 to be evidence of vehicle 800 being hitched to vehicle 700) to the towing vehicle (Fig. 5, 700 and see at least para. [0061] of Craig which discloses “a vehicle 700 and a trailer 800. As can be seen, the vehicle 700 and trailer 800 are physically and electronically coupled together. In various embodiments, the electronic coupling may be via a J1939 bus 900 and the physical coupling can be via physical links 750 and 850. Note that vehicle 700 may be substantially the same as the vehicle 102 in FIGS. 1 and 2”, *Examiner interprets vehicle 700 to be the second vehicle because it is towing vehicle 800) on an underside of the towed vehicle that causes the wheel to be lifted above a road surface (see the 3rd paragraph on pg. 4 of Czeschner which discloses “the lifting of at least one trailer wheel from the roadway and/or translational vibrations in the longitudinal or transverse direction of the vehicle trailer” and see paragraph 4 on pg. 6 of Czeschner which discloses “lifting of a vehicle wheel from the ground, which can also be evaluated for the detection of an unstable driving situation”). The combination of Craig in view of Czeschner may not explicitly disclose the first and second vehicles are hitched on an underside of the towed vehicle. However, in the same field of endeavor, DeMichele discloses a first vehicles hitched on an underside of the towed vehicle (see at least col. 4 ln. 46-49 of DeMichele which discloses “The wheel lifting member 34 may be joined with the side panels 46 of the carriage 36 to provide the means for reaching under the towed vehicle to engage the vehicle's wheels for lifting one end thereof”, *Examiner interprets this as evidence that the first vehicle is hitched on its underside since the wheel is considered to be included in the underside of a vehicle. Fig. 4 of DeMichle illustrates the first vehicle lifted above the road surface and hitching occurs on the first vehicle underside. Also, see at least claim 18 of DeMichele which discloses “lifting force to the underside of the vehicle to be towed”, *Examiner interprets this as hitched on the underside of the first vehicle which is the vehicle being towed). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Czeschner, to include the first and second vehicles are hitched on an underside of the towed vehicle, as taught in DeMichele with a reasonable expectation of success in order to connect first and second vehicles for towing while simultaneously accounting for possible stability concerns. See col. 4 ln. 46-49 for motivation. Regarding claim 12, the combination of Craig in view of Crawford and Czeschner discloses wherein the towed vehicle (Fig. 5, 800 and see at least para. [0061] of Craig which discloses “a vehicle 700 and a trailer 800. As can be seen, the vehicle 700 and trailer 800 are physically and electronically coupled together. In various embodiments, the electronic coupling may be via a J1939 bus 900 and the physical coupling can be via physical links 750 and 850. Note that vehicle 700 may be substantially the same as the vehicle 102 in Figs. 1 and 2”, *Examiner interprets vehicle 800 to be the first vehicle) is hitched (see at least para. [0061] of Craig which discloses “the physical coupling can be via physical links 750 and 850”, *Examiner interprets the physical links 750/850 to be evidence of vehicle 800 being hitched to vehicle 700) to the towing vehicle (Fig. 5, 700 and see at least para. [0061] of Craig which discloses “a vehicle 700 and a trailer 800. As can be seen, the vehicle 700 and trailer 800 are physically and electronically coupled together. In various embodiments, the electronic coupling may be via a J1939 bus 900 and the physical coupling can be via physical links 750 and 850. Note that vehicle 700 may be substantially the same as the vehicle 102 in FIGS. 1 and 2”, *Examiner interprets vehicle 700 to be the second vehicle because it is towing vehicle 800) on an underside of the towed vehicle that causes the wheel to be lifted above a road surface (see the 3rd paragraph on pg. 4 of Czeschner which discloses “the lifting of at least one trailer wheel from the roadway and/or translational vibrations in the longitudinal or transverse direction of the vehicle trailer” and see paragraph 4 on pg. 6 of Czeschner which discloses “lifting of a vehicle wheel from the ground, which can also be evaluated for the detection of an unstable driving situation”). The combination of Craig in view of Czeschner may not explicitly disclose the first and second vehicles are hitched on an underside of the towed vehicle. However, in the same field of endeavor, DeMichele discloses a first vehicles hitched on an underside of the towed vehicle (see at least col. 4 ln. 46-49 of DeMichele which discloses “The wheel lifting member 34 may be joined with the side panels 46 of the carriage 36 to provide the means for reaching under the towed vehicle to engage the vehicle's wheels for lifting one end thereof”, *Examiner interprets this as evidence that the first vehicle is hitched on its underside since the wheel is considered to be included in the underside of a vehicle. Fig. 4 of DeMichele illustrates the first vehicle lifted above the road surface and hitching occurs on the first vehicle underside. Also, see at least claim 18 of DeMichele which discloses “lifting force to the underside of the vehicle to be towed”, *Examiner interprets this as hitched on the underside of the first vehicle which is the vehicle being towed). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Czeschner, to include the first and second vehicles are hitched on an underside of the towed vehicle, as taught in DeMichele with a reasonable expectation of success in order to connect first and second vehicles for towing while simultaneously accounting for possible stability concerns. See col. 4 ln. 46-49 for motivation. Claims 6, 14 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Craig et al. (US 2010/0211277 A1) in view of Crawford (US 2020/0238976 A1) and further in view of Czeschner (EP3176042 B1) and further in view of Lee (US 2009/0005932 A1). Regarding claim 6, Craig, as modified by Crawford and Czeschner discloses wherein analyzing the sensor data from the at least one sensor to generate the stability signature (see at least para. [0061] of Craig which describes “stability control” and “operating conditions”, *Examiner interprets the collection and processing of the disclosed operating-condition signals as corresponding to generating a stability signature because these operating conditions include “a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” as disclosed in para. [0061] and Applicant’s specification at para. [0018] of discloses “a stability signature that characterizes external conditions experienced by the vehicle”) indicative of the unopposed lateral force applied to the towed vehicle (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle). Craig, as modified by Crawford and Czeschner may not explicitly disclose the sensor data comprises at least one of: analyzing the sensor data to determine a current orientation of the wheel of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween; translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle. However, in the same field of endeavor, Lee discloses at least one of: analyzing the sensor data to determine a current orientation of the wheel (see at least para. [0017] of Lee which discloses “sensing the trailer articulation angle, using a set of sensors mounted on the rear and side of a vehicle to detect the position of objects being towed behind the vehicle”, * Lee teaches sensing the trailer articulation angle using sensors mounted on the vehicle and processing sensor data to compute and continuously monitor the articulation angle between the towing vehicle and the trailer. Examiner interprets the disclosed trailer articulation angle as corresponding to the claimed current orientation of the wheel/towed vehicle relative to the direction of travel because the articulation angle represents angular deviation between the trailer orientation and the vehicle travel geometry. Examiner also notes that Craig’s steering-angle sensor disclosures correspond to determining wheel orientation associated with vehicle/trailer directional behavior) of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween (see at least para. [0008] of Lee which discloses “a process for calculating the trailer hitch articulation angle in a combination comprising a motorized vehicle having a trailer comprising a wheeled axle that is pivotally-connected thereto. The motorized vehicle includes sensing means comprising one or more of: ultrasonic transducers, short-range radar transducers, and cameras. A process according to the invention comprises the steps of: a) acquiring position and range information concerning the trailer by means of the sensing means employed; b) conveying the position and range information to a microprocessor; c) calculating the trailer tongue length of the trailer; d) calculating the track width of the trailer; and e) calculating the trailer hitch articulation angle of the trailer”, *Examiner interprets Lee’s articulation angle as naturally corresponding to a detected orientation offset, as broadly as recited. Examiner interprets the disclosed trailer articulation angle/hitch angle as corresponding to the claimed offset because the articulation angle represents angular deviation between the orientation of the trailer/towed vehicle and the direction of travel of the vehicle/trailer system); translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle (see at least para. [0027] of Lee which discloses “The process is repeated periodically to provide continuous monitoring of the trailer hitch articulation angle θ”, *Lee discloses sensing and continuously monitoring a trailer articulation angle from sensor data, which Examiner interprets as the claimed offset between the orientation of the towed vehicle and the direction of travel. In view of Craig’s trailer stability-control system, it would have been obvious to translate that offset into a stability-related force condition, because the articulation angle and related trailer operating conditions are used to determine when corrective stability control is needed. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the method of Craig, as modified by Crawford and Czeschner to include at least one of: analyzing the sensor data to determine a current orientation of the wheel of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween; translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle, as taught in Lee with a reasonable expectation of success in order to improve detection and characterization of trailer instability conditions caused by articulation-angle deviation, crosswinds, and other lateral external disturbances so that corrective trailer stability-control actions may be initiated more accurately and responsively to improve vehicle/trailer stability and towing safety. Regarding claim 14, Craig, as modified by Crawford and Czeschner discloses wherein analyzing the sensor data from the at least one sensor to generate the stability signature (see at least para. [0061] of Craig which describes “stability control” and “operating conditions”, *Examiner interprets the collection and processing of the disclosed operating-condition signals as corresponding to generating a stability signature because these operating conditions include “a speed or velocity signal, a height signal, a roll/pitch/yaw signal, and one or more current trailer driving condition signals” as disclosed in para. [0061] and Applicant’s specification at para. [0018] of discloses “a stability signature that characterizes external conditions experienced by the vehicle”) indicative of the unopposed lateral force applied to the towed vehicle (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle). Craig, as modified by Crawford and Czeschner may not explicitly disclose the sensor data comprises at least one of: analyzing the sensor data to determine a current orientation of the wheel of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween; translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle. However, in the same field of endeavor, Lee discloses at least one of: analyzing the sensor data to determine a current orientation of the wheel (see at least para. [0017] of Lee which discloses “sensing the trailer articulation angle, using a set of sensors mounted on the rear and side of a vehicle to detect the position of objects being towed behind the vehicle”, * Lee teaches sensing the trailer articulation angle using sensors mounted on the vehicle and processing sensor data to compute and continuously monitor the articulation angle between the towing vehicle and the trailer. Examiner interprets the disclosed trailer articulation angle as corresponding to the claimed current orientation of the wheel/towed vehicle relative to the direction of travel because the articulation angle represents angular deviation between the trailer orientation and the vehicle travel geometry. Examiner also notes that Craig’s steering-angle sensor disclosures correspond to determining wheel orientation associated with vehicle/trailer directional behavior) of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween (see at least para. [0008] of Lee which discloses “a process for calculating the trailer hitch articulation angle in a combination comprising a motorized vehicle having a trailer comprising a wheeled axle that is pivotally-connected thereto. The motorized vehicle includes sensing means comprising one or more of: ultrasonic transducers, short-range radar transducers, and cameras. A process according to the invention comprises the steps of: a) acquiring position and range information concerning the trailer by means of the sensing means employed; b) conveying the position and range information to a microprocessor; c) calculating the trailer tongue length of the trailer; d) calculating the track width of the trailer; and e) calculating the trailer hitch articulation angle of the trailer”, *Examiner interprets Lee’s articulation angle as naturally corresponding to a detected orientation offset, as broadly as recited. Examiner interprets the disclosed trailer articulation angle/hitch angle as corresponding to the claimed offset because the articulation angle represents angular deviation between the orientation of the trailer/towed vehicle and the direction of travel of the vehicle/trailer system); translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle (see at least para. [0027] of Lee which discloses “The process is repeated periodically to provide continuous monitoring of the trailer hitch articulation angle θ”, *Lee discloses sensing and continuously monitoring a trailer articulation angle from sensor data, which Examiner interprets as the claimed offset between the orientation of the towed vehicle and the direction of travel. In view of Craig’s trailer stability-control system, it would have been obvious to translate that offset into a stability-related force condition, because the articulation angle and related trailer operating conditions are used to determine when corrective stability control is needed. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the method of Craig, as modified by Crawford and Czeschner to include at least one of: analyzing the sensor data to determine a current orientation of the wheel of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween; translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle, as taught in Lee with a reasonable expectation of success in order to improve detection and characterization of trailer instability conditions caused by articulation-angle deviation, crosswinds, and other lateral external disturbances so that corrective trailer stability-control actions may be initiated more accurately and responsively to improve vehicle/trailer stability and towing safety. Regarding claim 19 the combination of Craig in view of Crawford and Czeschner and discloses wherein the stabilization system is further configured to: obtain the sensor data from the at least one sensor (see at least para. [0029] of Craig which discloses “sensors associated with one or more vehicle subsystems or sensors. Moreover, controller 106 can be configured to receive or collect data or signals directly from one or more vehicle subsystems or sensors. For example, controller 106 may receive or collect data or signals directly from an electronic control unit (ECU) associated with one or more of the vehicle subsystems or sensors”), wherein the at least one sensor comprises one or more of: a sensor (Fig. 5, 200 of 800 and see at least para. [0036] of Craig which discloses “a system 200 according to various embodiments of the present invention. System 200 and vehicle 102 are substantially the same as the system 100 and vehicle 102 shown in FIG. 1. However, the system 200 shown in FIG. 2 additionally includes global positioning system (GPS) subsystem 202”) disposed on the vehicle; a sensor (Fig. 5, 200 of 700 and see at least para. [0036] of Craig which discloses “a system 200 according to various embodiments of the present invention. System 200 and vehicle 102 are substantially the same as the system 100 and vehicle 102 shown in FIG. 1. However, the system 200 shown in FIG. 2 additionally includes global positioning system (GPS) subsystem 202”) disposed on a second vehicle (see at least para. [0012] of Craig which discloses “feedback from system sensors, such as a steering angle sensor, a wheel speed sensor, and a lateral and yaw sensor may be used to decide how much torque to apply”, *Examiner interprets this as adjusting the steering angle to determine the direction and mitigate instability); and a sensor of an external infrastructure (see at least para. [0031] of Crawford which discloses “sensors of the surrounding vehicles leveraged via vehicle-to-vehicle communications (v2v), integrated sensors within the vehicle (e.g., IMU), and so on”, *Examiner interprets the v2v communications to be a sensor of an external infrastructure since para. [0022] of Applicant’s specification discloses “the stabilization system may communicate using vehicle-to-infrastructure (V2I) communications to obtain current weather conditions”). Craig, as modified by Crawford and Czeschner may not explicitly disclose analyzing the sensor data to determine a current orientation of the wheel of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween; translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle. However, in the same field of endeavor, Lee discloses at least one of: analyzing the sensor data to determine a current orientation of the wheel (see at least para. [0017] of Lee which discloses “sensing the trailer articulation angle, using a set of sensors mounted on the rear and side of a vehicle to detect the position of objects being towed behind the vehicle”, * Lee teaches sensing the trailer articulation angle using sensors mounted on the vehicle and processing sensor data to compute and continuously monitor the articulation angle between the towing vehicle and the trailer. Examiner interprets the disclosed trailer articulation angle as corresponding to the claimed current orientation of the wheel/towed vehicle relative to the direction of travel because the articulation angle represents angular deviation between the trailer orientation and the vehicle travel geometry. Examiner also notes that Craig’s steering-angle sensor disclosures correspond to determining wheel orientation associated with vehicle/trailer directional behavior) of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween (see at least para. [0008] of Lee which discloses “a process for calculating the trailer hitch articulation angle in a combination comprising a motorized vehicle having a trailer comprising a wheeled axle that is pivotally-connected thereto. The motorized vehicle includes sensing means comprising one or more of: ultrasonic transducers, short-range radar transducers, and cameras. A process according to the invention comprises the steps of: a) acquiring position and range information concerning the trailer by means of the sensing means employed; b) conveying the position and range information to a microprocessor; c) calculating the trailer tongue length of the trailer; d) calculating the track width of the trailer; and e) calculating the trailer hitch articulation angle of the trailer”, *Examiner interprets Lee’s articulation angle as naturally corresponding to a detected orientation offset, as broadly as recited. Examiner interprets the disclosed trailer articulation angle/hitch angle as corresponding to the claimed offset because the articulation angle represents angular deviation between the orientation of the trailer/towed vehicle and the direction of travel of the vehicle/trailer system); translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle (see at least para. [0027] of Lee which discloses “The process is repeated periodically to provide continuous monitoring of the trailer hitch articulation angle θ”, *Lee discloses sensing and continuously monitoring a trailer articulation angle from sensor data, which Examiner interprets as the claimed offset between the orientation of the towed vehicle and the direction of travel. In view of Craig’s trailer stability-control system, it would have been obvious to translate that offset into a stability-related force condition, because the articulation angle and related trailer operating conditions are used to determine when corrective stability control is needed. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the method of Craig, as modified by Crawford and Czeschner to include at least one of: analyzing the sensor data to determine a current orientation of the wheel of the towed vehicle and comparing the current orientation of the wheel of the towed vehicle to a direction of travel of the towed vehicle to detect an offset therebetween; translating the offset into the unopposed lateral force applied to the towed vehicle; and generating the stability signature indicative of the unopposed lateral force applied to the towed vehicle, as taught in Lee with a reasonable expectation of success in order to improve detection and characterization of trailer instability conditions caused by articulation-angle deviation, crosswinds, and other lateral external disturbances so that corrective trailer stability-control actions may be initiated more accurately and responsively to improve vehicle/trailer stability and towing safety. Claims 7 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Craig et al. (US 2010/0211277 A1) in view of Crawford (US 2020/0238976 A1) in view of Czeschner (EP3176042 B1) and further in view of Timmons (US 2010/0181743 A1). Regarding claim 7, Craig, as modified by Crawford and Czeschner discloses actuating the wheel of the towed vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes, which is carried out by an overrun device. In this way, the fail-safe basic braking function, which is free of power supply, is retained”, *Examiner interprets this to be evidence of wheel actuation via the brake actuator with the superimposed actuation translating to an electronically commanded adjustment that is precisely a control signal actuation. Craig, as modified by Crawford and Czeschner as set forth above, discloses detecting an unopposed lateral force applied to the towed vehicle from external conditions and generating a control signal to actuate a wheel of the towed vehicle to mitigate instability). Craig, as modified by Crawford and Czeschner may not explicitly disclose wherein actuating the wheel of the towed vehicle comprises adjusting a steering angle of the wheel towards the unopposed lateral force to minimize impact of the unopposed lateral force or adjusting the steering angle of the wheel away from the unopposed lateral force to maximize impact of the unopposed lateral force. However, Timmons discloses wherein actuating the wheel of the towed vehicle comprises adjusting a steering angle of the wheel towards the unopposed lateral force to minimize impact of the unopposed lateral force or adjusting the steering angle of the wheel away from the unopposed lateral force to maximize impact of the unopposed lateral force (see at least para. [0014] of Timmons which discloses “to relieve extreme pressures and forces in the system in the event of extreme steering angles by the tow vehicle during backing maneuvers. One or more steering frame and axle centering springs and adjustable steering stops may be provided to assist in centering the trailer steering and limit the steering angle of the trailer wheels”, *Timmons discloses steering mechanism for trailers having steerable wheels wherein a pivotally mounted steering frame acts upon the time rods of the trailer wheels and receives input from hydraulic cylinders coupled to the hitch bar, so that articulation between the towing vehicle and trailer steers the trailer wheels and the system selectively locks or steers the trailer wheels according to maneuvering conditions). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the wheel actuation of Craig, as modified by Crawford and Czeschner, to include adjustment of the steering angles of the trailer wheels, as taught by Timmons with a reasonable expectation of success in order to influence trailer directional behavior and stability during towing in response to detected lateral disturbances and articulation conditions because steering and the trailer wheels based on articulation and directional conditions improves control of trailer motion, maneuverability and stability during towing and backing maneuvers. Examiner further notes that steering angle adjustment responsive to the detected later force related instability conditions would predictably reduce or increase the effect of the lateral disturbance on the trailer behavior depending on the steering direction. See para. [0014] of Timmons for motivation. Regarding claim 15, Craig, as modified by Crawford and Czeschner discloses actuating the wheel of the towed vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes, which is carried out by an overrun device. In this way, the fail-safe basic braking function, which is free of power supply, is retained”, *Examiner interprets this to be evidence of wheel actuation via the brake actuator with the superimposed actuation translating to an electronically commanded adjustment that is precisely a control signal actuation. Craig, as modified by Crawford and Czeschner as set forth above, discloses detecting an unopposed lateral force applied to the towed vehicle from external conditions and generating a control signal to actuate a wheel of the towed vehicle to mitigate instability). Craig, as modified by Crawford and Czeschner may not explicitly disclose wherein actuating the wheel of the towed vehicle comprises adjusting a steering angle of the wheel towards the unopposed lateral force to minimize impact of the unopposed lateral force or adjusting the steering angle of the wheel away from the unopposed lateral force to maximize impact of the unopposed lateral force. However, Timmons discloses wherein actuating the wheel of the towed vehicle comprises adjusting a steering angle of the wheel towards the unopposed lateral force to minimize impact of the unopposed lateral force or adjusting the steering angle of the wheel away from the unopposed lateral force to maximize impact of the unopposed lateral force (see at least para. [0014] of Timmons which discloses “to relieve extreme pressures and forces in the system in the event of extreme steering angles by the tow vehicle during backing maneuvers. One or more steering frame and axle centering springs and adjustable steering stops may be provided to assist in centering the trailer steering and limit the steering angle of the trailer wheels”, *Timmons discloses steering mechanism for trailers having steerable wheels wherein a pivotally mounted steering frame acts upon the time rods of the trailer wheels and receives input from hydraulic cylinders coupled to the hitch bar, so that articulation between the towing vehicle and trailer steers the trailer wheels and the system selectively locks or steers the trailer wheels according to maneuvering conditions). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the wheel actuation of Craig, as modified by Crawford and Czeschner, to include adjustment of the steering angles of the trailer wheels, as taught by Timmons with a reasonable expectation of success in order to influence trailer directional behavior and stability during towing in response to detected lateral disturbances and articulation conditions because steering and the trailer wheels based on articulation and directional conditions improves control of trailer motion, maneuverability and stability during towing and backing maneuvers. Examiner further notes that steering angle adjustment responsive to the detected later force related instability conditions would predictably reduce or increase the effect of the lateral disturbance on the trailer behavior depending on the steering direction. See para. [0014] of Timmons for motivation. Claims 8 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Craig et al. (US 2010/0211277 A1) in view of Crawford (US 2020/0238976 A1) in view of Czeschner (EP3176042 B1) and further in view of Timmons (US 2010/0181743 A1) and further in view of Lee (US 2009/0005932 A1). Regarding claim 8, Craig, as modified by Crawford, Czeschner and Timmons discloses the unopposed lateral force (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle) and a hitch point (see at least the translation of Czeschner which discloses “by measuring the instantaneous tensile or compressive forces on the trailer in the area of the trailer hitch longitudinally and / or transversely to the direction of travel and / or in the vertical direction and possibly in the area of the axle bearings and by comparing these forces with the current movement behavior of the vehicle trailer. In particular, the courses of the determined forces can be compared with the courses of the instantaneous longitudinal and lateral acceleration as well as the pitch, roll and yaw rate. From a comparison of the measured at the contact points of the trailer chassis forces with the (resulting) movement behavior of the trailer, in particular with one or more accelerations in the longitudinal or transverse direction and about the longitudinal, transverse or vertical axis, the mass and / or loading be determined by calculation of the vehicle trailer. In particular, the center of gravity and / or the total mass and / or a momentary effective mass (at loose cargo or blasting loads) at different times” and see at least the translation of Czeschner which discloses “a trailer hitch (11) is arranged, which is designed for example as a ball-and-socket coupling. Further, on the chassis (4) an extendable support wheel or nose wheel (12) and a holder with chocks (not shown) and other trailer components may be arranged. When the trailer is attached to a towing vehicle (not shown) via the hitch (11) and accelerates the towing vehicle, a pulling force is generated on the hitch (11) in the longitudinal direction of the vehicle trailer (1). This pulling force accelerates the vehicle trailer (1), with the instantaneous value of the acceleration being substantially proportional to the tractive force and indirectly proportional to the total mass of the trailer in accordance with the laws of dynamics”) between the towed vehicle and the towing vehicle (and see at lest the translation of Czeschner which discloses “A particularly simple form of determining the mass of the vehicle trailer is to detect a horizontal traction in the longitudinal direction of the vehicle trailer via a sensor on the drawbar or towing hitch and to detect in parallel the longitudinal acceleration on the vehicle trailer, in particular by an ESP sensor”, *Czeschner discloses measuring tensile or compressive forces at the trailer hitch in longitudinal and transverse directions and comparing those forces with the vehicle trailer’s movement behavior, including longitudinal/lateral acceleration and pitch, roll and y aw rate. Examiner interprets these disclosures as teaching determining and comparing directional bending/articulation behavior at the hitch point). Craig, as modified by Crawford, Czeschner and Timmons may not explicitly disclose wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle. However, Lee discloses wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle (see at least para. [0018] which discloses the estimation of a “hitch articulation angle and trailer tongue length. These parameters are the essential information necessary for trailer stability and parking control”, Lee discloses estimating a trailer hitch articulation angle and trailer tongue length, which Examiner interprets as the bending or articulation behavior at the hitch connection between the towing vehicle and the trailer). Examiner interprets the disclosed high articulation angle as corresponding to directional bending/articulation behavior at the hitch connection between the towing vehicle and the towed vehicle because the articulation angle represents angular deviation between the towing vehicle and towed vehicle during movement. When considered in view of Crawford’s disclosure of directional unopposed lateral forces acting on the trailer/vehicle system and Czeschner’ s disclosure of comparing hitch forces with trailer movement behavior, the combined teachings would have suggested comparing the direction of the lateral disturbance with the direction of hitch articulation /bending in order to determine an appropriate trailer stability-control response. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Crawford, Czeschner and Timmons to include wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle, as taught in Lee with a reasonable expectation of success in order to improve determination of trailer instability conditions and selection of corrective trailer stability-control responses by utilizing hitch articulation/bending behavior relative to lateral-force disturbances so that the trailer steering and stability control actions may be more accurately adapted to the direction and magnitude of the detected instability condition, thereby improving towing stability and crosswind disturbance mitigation. Regarding claim 16, Craig, as modified by Crawford, Czeschner and Timmons discloses the unopposed lateral force (see at least para. [0018] of Crawford which discloses “Because this is an unopposed force (i.e., there is no balancing force on the opposite side of the vehicle/trailer) a net resulting lateral force pushes against the vehicle and the trailer in a generally perpendicular direction to that of the direction of travel of the semi-truck. Thus, such occurrences from semi-trucks, buses, passenger vehicles, and/or natural events (e.g., crosswinds) can impart such forces on the trailer and the vehicle”, *Examiner interprets the disclosed unopposed lateral force caused by crosswinds and other environmental conditions as corresponding to the claimed unopposed lateral force applied to the towed vehicle from external conditions experienced by the towed vehicle) and a hitch point (see at least the translation of Czeschner which discloses “by measuring the instantaneous tensile or compressive forces on the trailer in the area of the trailer hitch longitudinally and / or transversely to the direction of travel and / or in the vertical direction and possibly in the area of the axle bearings and by comparing these forces with the current movement behavior of the vehicle trailer. In particular, the courses of the determined forces can be compared with the courses of the instantaneous longitudinal and lateral acceleration as well as the pitch, roll and yaw rate. From a comparison of the measured at the contact points of the trailer chassis forces with the (resulting) movement behavior of the trailer, in particular with one or more accelerations in the longitudinal or transverse direction and about the longitudinal, transverse or vertical axis, the mass and / or loading be determined by calculation of the vehicle trailer. In particular, the center of gravity and / or the total mass and / or a momentary effective mass (at loose cargo or blasting loads) at different times” and see at least the translation of Czeschner which discloses “a trailer hitch (11) is arranged, which is designed for example as a ball-and-socket coupling. Further, on the chassis (4) an extendable support wheel or nose wheel (12) and a holder with chocks (not shown) and other trailer components may be arranged. When the trailer is attached to a towing vehicle (not shown) via the hitch (11) and accelerates the towing vehicle, a pulling force is generated on the hitch (11) in the longitudinal direction of the vehicle trailer (1). This pulling force accelerates the vehicle trailer (1), with the instantaneous value of the acceleration being substantially proportional to the tractive force and indirectly proportional to the total mass of the trailer in accordance with the laws of dynamics”) between the towed vehicle and the towing vehicle (and see at lest the translation of Czeschner which discloses “A particularly simple form of determining the mass of the vehicle trailer is to detect a horizontal traction in the longitudinal direction of the vehicle trailer via a sensor on the drawbar or towing hitch and to detect in parallel the longitudinal acceleration on the vehicle trailer, in particular by an ESP sensor”, *Czeschner discloses measuring tensile or compressive forces at the trailer hitch in longitudinal and transverse directions and comparing those forces with the vehicle trailer’s movement behavior, including longitudinal/lateral acceleration and pitch, roll and y aw rate. Examiner interprets these disclosures as teaching determining and comparing directional bending/articulation behavior at the hitch point). Craig, as modified by Crawford, Czeschner and Timmons may not explicitly disclose wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle. However, Lee discloses wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle (see at least para. [0018] which discloses the estimation of a “hitch articulation angle and trailer tongue length. These parameters are the essential information necessary for trailer stability and parking control”, Lee discloses estimating a trailer hitch articulation angle and trailer tongue length, which Examiner interprets as the bending or articulation behavior at the hitch connection between the towing vehicle and the trailer). Examiner interprets the disclosed high articulation angle as corresponding to directional bending/articulation behavior at the hitch connection between the towing vehicle and the towed vehicle because the articulation angle represents angular deviation between the towing vehicle and towed vehicle during movement. When considered in view of Crawford’s disclosure of directional unopposed lateral forces acting on the trailer/vehicle system and Czeschner’ s disclosure of comparing hitch forces with trailer movement behavior, the combined teachings would have suggested comparing the direction of the lateral disturbance with the direction of hitch articulation /bending in order to determine an appropriate trailer stability-control response. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Crawford, Czeschner and Timmons to include wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle, as taught in Lee with a reasonable expectation of success in order to improve determination of trailer instability conditions and selection of corrective trailer stability-control responses by utilizing hitch articulation/bending behavior relative to lateral-force disturbances so that the trailer steering and stability control actions may be more accurately adapted to the direction and magnitude of the detected instability condition, thereby improving towing stability and crosswind disturbance mitigation. Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Craig et al. (US 2010/0211277 A1) in view of Crawford (US 2020/0238976 A1) and further in view of Czeschner (EP3176042 B1) and further in view of Lee (US 2009/0005932 A1) and further in view of Timmons (US 2010/0181743 A1) Regarding claim 20, Craig, as modified by Crawford, Czeschner and Lee discloses wherein actuating the wheel of the vehicle (see at least the 4th paragraph on pg. 4 of the translation of Czeschner which describes “a stabilization system with a brake actuator for the superimposed mechanical actuation of at least one trailer brake, in particular with superimposition of a basic actuation for two or more wheel brakes, which is carried out by an overrun device. In this way, the fail-safe basic braking function, which is free of power supply, is retained”, *Examiner interprets this to be evidence of wheel actuation via the brake actuator with the superimposed actuation translating to an electronically commanded adjustment that is precisely a control signal actuation. Craig, as modified by Crawford and Czeschner as set forth above, discloses detecting an unopposed lateral force applied to the towed vehicle from external conditions and generating a control signal to actuate a wheel of the towed vehicle to mitigate instability); a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle (see at least para. [0018] which discloses the estimation of a “hitch articulation angle and trailer tongue length. These parameters are the essential information necessary for trailer stability and parking control”, Lee discloses estimating a trailer hitch articulation angle and trailer tongue length, which Examiner interprets as the bending or articulation behavior at the hitch connection between the towing vehicle and the trailer). Examiner interprets the disclosed high articulation angle as corresponding to directional bending/articulation behavior at the hitch connection between the towing vehicle and the towed vehicle because the articulation angle represents angular deviation between the towing vehicle and towed vehicle during movement. When considered in view of Crawford’s disclosure of directional unopposed lateral forces acting on the trailer/vehicle system and Czeschner’ s disclosure of comparing hitch forces with trailer movement behavior, the combined teachings would have suggested comparing the direction of the lateral disturbance with the direction of hitch articulation /bending in order to determine an appropriate trailer stability-control response. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify the method of Craig, as modified by Crawford, Czeschner and Timmons to include wherein a decision to minimize or maximize impact of the unopposed lateral force is made by comparing a direction of the unopposed lateral force with a direction of bending in a hitch point between the towed vehicle and the towing vehicle, as taught in Lee with a reasonable expectation of success in order to improve determination of trailer instability conditions and selection of corrective trailer stability-control responses by utilizing hitch articulation/bending behavior relative to lateral-force disturbances so that the trailer steering and stability control actions may be more accurately adapted to the direction and magnitude of the detected instability condition, thereby improving towing stability and crosswind disturbance mitigation. Craig, as modified by Crawford, Czeschner and Lee may not explicitly disclose wherein actuating the wheel of the towed vehicle comprises adjusting a steering angle of the wheel towards the unopposed lateral force to minimize impact of the unopposed lateral force or adjusting the steering angle of the wheel away from the unopposed lateral force to maximize impact of the unopposed lateral force. However, Timmons discloses wherein actuating the wheel of the towed vehicle comprises adjusting a steering angle of the wheel towards the unopposed lateral force to minimize impact of the unopposed lateral force or adjusting the steering angle of the wheel away from the unopposed lateral force to maximize impact of the unopposed lateral force (see at least para. [0014] of Timmons which discloses “to relieve extreme pressures and forces in the system in the event of extreme steering angles by the tow vehicle during backing maneuvers. One or more steering frame and axle centering springs and adjustable steering stops may be provided to assist in centering the trailer steering and limit the steering angle of the trailer wheels”, *Timmons discloses steering mechanism for trailers having steerable wheels wherein a pivotally mounted steering frame acts upon the time rods of the trailer wheels and receives input from hydraulic cylinders coupled to the hitch bar, so that articulation between the towing vehicle and trailer steers the trailer wheels and the system selectively locks or steers the trailer wheels according to maneuvering conditions). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the wheel actuation of Craig, as modified by Crawford, Czeschner, and Lee to include adjustment of the steering angles of the trailer wheels, as taught by Timmons with a reasonable expectation of success in order to influence trailer directional behavior and stability during towing in response to detected lateral disturbances and articulation conditions because steering and the trailer wheels based on articulation and directional conditions improves control of trailer motion, maneuverability and stability during towing and backing maneuvers. Examiner further notes that steering angle adjustment responsive to the detected later force related instability conditions would predictably reduce or increase the effect of the lateral disturbance on the trailer behavior depending on the steering direction. See para. [0014] of Timmons for motivation. Additional Prior Art The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Matoy (US 2013/0085649A1) discloses the method for controlling the brake pressure delivered from a towing vehicle to a towed vehicle includes sensing a load signal of the towing and towed vehicle combination; sensing a stability signal of the towing vehicle, which is indicative of at least one of the yaw rate, a steering angle, and the lateral acceleration of the towing vehicle; and determining a comparison value based on the load signal and the stability signal received. After determining the comparison value, the method further includes receiving a deceleration signal generated by an automated deceleration request; determining an empirical deceleration value based on the deceleration signal; and determining a brake control transmission signal based on the comparison value and the empirical deceleration value. In another embodiment the method further includes transmitting the brake control transmission signal to a towed vehicle control device. Gavit (US 11,845,497 B2) a flat towed vehicle includes a battery and wheels and a supplemental fuse. A transfer case generates a transfer case status signal an electric power steering system coupled to the wheels and the battery through the supplemental fuse. The electrical power steering system has a tow mode and a driven mode. The electric power steering system enters the tow mode when the supplemental fuse communicates battery power to the electrical power steering system and the transfer case status signal corresponding to a neutral position and method includes communicating power to an electrical power steering system though a supplemental fuse, communicating a neutral position signal to an electrical power steering system, and enabling a tow mode in the electrical power steering controller in response to the neutral position signal and communicating power through the supplemental fuse. 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 DANA IVEY whose telephone number is (313)446-4896. The examiner can normally be reached 9-5:30 EST Monday-Friday. 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, Jelani Smith can be reached at 571-270-3969. 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. /DANA D IVEY/Examiner, Art Unit 3662 /D.D.I/May 18, 2026 /JELANI A SMITH/Supervisory Patent Examiner, Art Unit 3662
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Prosecution Timeline

Show 2 earlier events
Jan 02, 2026
Interview Requested
Jan 16, 2026
Examiner Interview Summary
Jan 16, 2026
Applicant Interview (Telephonic)
Feb 13, 2026
Response Filed
May 29, 2026
Final Rejection mailed — §103
Jul 09, 2026
Interview Requested
Jul 14, 2026
Examiner Interview Summary
Jul 14, 2026
Applicant Interview (Telephonic)

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

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Prosecution Projections

3-4
Expected OA Rounds
89%
Grant Probability
96%
With Interview (+7.0%)
1y 11m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 778 resolved cases by this examiner. Grant probability derived from career allowance rate.

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