Prosecution Insights
Last updated: April 19, 2026
Application No. 18/708,218

A TOWING DEVICE

Final Rejection §103§112
Filed
May 08, 2024
Examiner
HARTMANN, ERIN MARIE
Art Unit
3664
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Bs Engineering Aps
OA Round
2 (Final)
62%
Grant Probability
Moderate
3-4
OA Rounds
3y 0m
To Grant
99%
With Interview

Examiner Intelligence

Grants 62% of resolved cases
62%
Career Allow Rate
5 granted / 8 resolved
+10.5% vs TC avg
Strong +50% interview lift
Without
With
+50.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
28 currently pending
Career history
36
Total Applications
across all art units

Statute-Specific Performance

§101
11.9%
-28.1% vs TC avg
§103
40.7%
+0.7% vs TC avg
§102
8.1%
-31.9% vs TC avg
§112
32.2%
-7.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 8 resolved cases

Office Action

§103 §112
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 . Status of Claims This office action is in response to application number 18/708,218 filed on 12/30/2025, in which Claims 1-40 are presented for examination. Applicant amends Claims 1, 4, 6-7, 10, 13, 16, 22, 24-27, 29, 31, 33-34, and 39 and cancels Claims 2, 5, 8-9, 11-12, 14-15, 18-21, 23, 28, 30, 32, 35-36, 38, and 40. Priority Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55 for Application No. DKPA 2021 01114. Response to Arguments Applicant's arguments, see pgs. 9-11, filed 12/30/2025 with respect to the objections to the drawings have been fully considered but they are not fully persuasive. Applicant argues that FIG. 3 is only intended as an outline illustrating the working parts and the reference numerals used are listed on specification pg. 10. Examiner respectfully disagrees and would like to note guidelines presented in MPEP 608.02 regarding the drawings and drawing standards, which note using conventional symbols or, where necessary, rectangular boxes appropriately labeled to properly provide a complete illustration of the invention (MPEP 608.02.V.(n).: DRAWING STANDARDS 37 C.F.R. 1.84 Standards for drawings. (n) Symbols; MPEP 608.02. IX.(n): DRAWING SYMBOLS 37 CFR 1.84; and 608.02(d) 37 C.F.R. 1.83 Content of drawing (a)-(c)). In the present application, FIG. 3 on its own does not provide a clear representation of the invention or application claims and therefore, does not on its own provide a clear illustration of the invention. The application would benefit from a more clear representation in FIG. 3. Therefore, Examiner maintains the objections to FIG. 3 regarding the missing labels or descriptions. Applicant further argues that the provision does not state that more than one reference numeral may not refer to the same item in the drawing and recites 37 CFR 18.84(p)(4): "The same part of an invention appearing in more than one view of the drawing must always be designated by the same reference character, and the same reference character must never be used to designate different parts." Examiner respectfully disagrees. Based on the rule, different reference numbers cannot be used to designate the same part. The drawings indicate multiple sets of reference characters as the same part where they point to the same thing and are indicated as such on specification, pgs. 24-27, "List of reference numerals." Examiner recommends to minimize using multiple reference characters for the same part, if the different reference characters are assemblies and sub-components or oriented on a specific side of the invention, that the names should clearly identify the differentiation and only one reference character should be used or, in the case of an assembly and subcomponent, an arrow and a connecting line should be used correctly (see below). Therefore, the related objections to the drawings are maintained. Further details are provided below. And therefore, the remaining objections to the drawings set forth in the office action of 9/30/2025 not identified, above and below, are withdrawn. Applicant's arguments, see pgs. 8-9, filed 12/30/2025 with respect to the objections to the abstract have been fully considered but they are not fully persuasive. Examiner provides an update to the objection to the abstract set forth in the office action of 9/30/2025. Further details are provided below. Applicant's arguments, see pg. 9, filed 12/30/2025 with respect to the objections to the specification have been fully considered and are persuasive. Examiner withdraws the objections to the specification set forth in the office action of 9/30/2025. Applicant's arguments, see pgs. 2-8, filed 12/30/2025 with respect to the objections to the claims have been fully considered but they are not fully persuasive. Examiner maintains the objection to Claim 34 (line 8) set forth in the office action of 9/30/2025. Examiner withdraws the remaining objections set forth in the office action of 9/30/2025. In light of the amendments, Examiner provides a new objection to Claim 31. Further details are provided below. Applicants arguments, see pg. 11, filed 12/30/2025, with respect to the interpretation and rejections of Claim 4 under 35 U.S.C. 112(f), 112(a), and 112(b) have been fully considered and are persuasive. Therefore, Examiner withdraws the interpretation of Claim 4 under 35. U.S.C. 112(f) and rejections of Claim 4 under 35 U.S.C. 112(a) and 112(b) set forth in the office action of 9/30/2025. In light of the amendments to Claim 1, see pg. 2, filed 12/30/2025, Examiner provides a new rejection to Claims 1, 3-4, 6-7, 10, 13, 16-17, 22, 24-27, 29, 31, 33-34, 37, and 39 under 35 U.S.C. 112(a) and 35 U.S.C. 112(b). Further details are provided below. Applicant’s arguments and amendments to the claims, see pgs. 2-8 and 11, with respect to the rejection of Claims 4, 6-7, 13, 22, 24-27, 29, 31, 33-34, and 39 under 35 U.S.C. 112(b) have been fully considered but are not fully persuasive. Examiner maintains the rejections of Claim 22 (lines 9-10) and Claim 25 (line 3) under 35 U.S.C. 112(b) set forth in the office action of 9/30/2025 and provides an updated rejection for clarity below. Examiner updates the rejections of Claim 22, 24, 26-27, and 29 under 35 U.S.C. 112(b) set forth in the office action of 9/30/2025 and provides an updated rejection for clarity and in light of the amendments. Examiner withdraws the remaining rejections to the claims under 35 U.S.C. 112(b) set forth in the office action of 9/30/2025. Applicant’s arguments, see pgs. 2-8 and 11-12, with respect to the rejection of Claims 1, 4, 6-7, 13, 22, 24-27, 29, 31, 33-34, and 39 under 35 U.S.C. 103 have been fully considered but are moot because they are directed to the amendments of Claim 1. Further, the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument because the claim amendments narrow the scope of the claims. Therefore, in light of the amendments, Examiner provides an updated rejection to Claims 1, 3-4, 6-7, 10, 13, 16-17, 22, 24-27, 29, 31, 33-34, 37, and 39 under 35 U.S.C. 103. Further details are provided below. Drawings The drawings are objected to as failing to comply with 37 CFR 1.84(p)(4) because multiple reference characters have both been used to designate one part. FIGs. 1-2; 16 and 48: In FIGs. 1-2, reference characters 16 and 48 both point to the propulsion cart because the "propulsion cart" is the variant of the "propulsion means." Examiner recommends using character 16 or character 48 and calling it a "propulsion means, such as a propulsion cart.” FIGs. 1-2 and 4; 20, 54, and 56: In FIGs. 1-2 and 4, reference characters 20 and 54 both point to the first set of lifting means and 20 and 56 both point to the second set of lifting means because "lifting means of the towing device" is a broader term. Examiner recommends using only first and second set of lifting means, for example, "lifting means of the towing device, such as a first set of lifting means 54 and a second set of lifting means 56.” FIGs. 1-4, 9-10, 12-14; 21, 21b and 21, 21a: Similar to above, Examiner recommends using only "left actuator 21a" and "right actuator 21b," without using 21. FIGs. 1-2, 3, and 9-11; 4, 66 and 4, 46, 46a: Examiner recommends using only "roller wheel 66," "46a right drive means," and "46b left drive means," without using 4 or 46. FIG. 3; 30, 36 and 24, 37: Examiner recommends using “receiver for receiving electromagnetic radiation 30, such as of the control system or a remote control” and “transmitter for transmitting electromagnetic radiation 24, such as of the control system or a remote control,” without using 36 and 37. FIGs. 5-8; 300, 300a and 300, 300b: Examiner recommends using only "detachable wheel support 300a" and "detachable L-shaped wheel support 300b" without using 300. FIGs. 5-8; 302, 302b and 308, 308a: Examiner recommends using only “first attachment means 302” and “second attachment means 308,” without using 302b and 308a (see below, 302a and 308b are not used in the drawings, and therefore only one reference character is required). FIGs. 6 and 13; 328, 330: Examiner recommends using “right longitudinally arranged beam of frame 330” and “left longitudinally arranged beam of frame 328.” Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. The drawings are objected to because of the following: FIG. 3: missing labels or more descriptive images that allow the figured to be more easily read on its own. FIG. 7, 300a and 316: Examiner recommends using 300a with an arrow and 316 with a connecting line, any other instances of indicating a part and sub-part should also be addressed. FIG. 8, 308 and 308a point to the same thing. Examiner recommends using only 308, see above and below. Any other instances of lines or arrows pointing to the same part should be similarly addressed. FIG. 9, 2 and 330 point to the same thing. Examiner recommends using only one of 2 or 330. Any other instances of lines or arrows pointing to the same thing, because they are unable to clearly distinguish two overlapping parts, should be similarly addressed (for example, FIG. 6 310, 330 and 310, 328 should use only 310 or 330 and 328). Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. The drawings are objected to as failing to comply with 37 CFR 1.84(p)(5) because they do not include the following reference signs mentioned in the description: multiple pages, FIGs. 5-8: 302a and 308b, and pg. 26, line 10: 314. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Specification Applicant is reminded of the proper language and format for an abstract of the disclosure. The abstract should be in narrative form and generally limited to a single paragraph on a separate sheet within the range of 50 to 150 words in length. The abstract should describe the disclosure sufficiently to assist readers in deciding whether there is a need for consulting the full patent text for details. The language should be clear and concise and should not repeat information given in the title. It should avoid using phrases which can be implied, such as, “The disclosure concerns,” “The disclosure defined by this invention,” “The disclosure describes,” etc. In addition, the form and legal phraseology often used in patent claims, such as “means” and “said,” should be avoided. The abstract of the disclosure is objected to because of the following: Contains more than 150 words, Contains legalese, "comprising" (line 1), and Requires grammatical correction in line 7 "lowing" should be "lowering" and line 11 "are being" should be "are". A corrected abstract of the disclosure is required and must be presented on a separate sheet, apart from any other text. See MPEP § 608.01(b). Claim Objections Claims 31 and 34 are objected to because of the following informalities: Claim 31 (line 14): "pivotall[[y]] element" should be "pivotal[[ly]] element" and Claim 34 (line 8): "so as to be able to" should be "is able to." Appropriate correction is required. Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that use the word “means” or “step” but are nonetheless not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph because the claim limitation(s) recite(s) sufficient structure, materials, or acts to entirely perform the recited function. Such claim limitation(s) is/are: "propulsion means" in Claim 1 and Propulsion means implies a structure required to drive the towing device. Further, the specification supports this structure and describes the propulsion means as a cart with drive wheels or caterpillars, spec pg. 13, lines 16-19, “The towing device 100 also comprises propulsion means 16 for propelling the device. The propulsion means 16 is in form of a separatable propulsion cart 48 which via a first coupling means 50 is detachable being coupled to a second coupling means 52 which in turn is mechanically connected to the frame 2,” and pg. 3, lines 34-36, “wherein said towing device comprises drive means in the form of a first set of drive wheels or 35 drive caterpillars arranged at a right side of the towing device and a second set of drive wheels or drive caterpillars arranged at a left side of the towing device.” "[first set of or second set of] lifting means [...] configured to" in Claim 1. Lifting means implies a structure capable of lifting the support surface. Further, specification supports this structure and describes actuators for lifting the support surface, for example see specification pg. 7, lines 32-36, “In one embodiment of the towing device according to the present invention, said lifting means comprises one or more actuators, such as electric, mechanical or hydraulic actuators, which via said control system are configured to be able to change configuration between an expanded configuration and a collapsed configuration, and thereby effect raising or lowering of said support surface in relation to said ground surface,” and, specification pgs. 13-14, lines 31-40 and lines 1-5, “It is seen in Fig. 1 that the first set of lifting means 54 comprises a wheel suspension 64 which is being pivotally mounted to the frame 2 and that an actuator 21,21a is being mounted between the wheel suspension 64 and said frame 2 in such a way that actuation of the actuator 21,21a will effect a pivoting of said wheel suspension 64 around a pivot axis 65, which is 35 being perpendicular to the longitudinal direction of said support surface 8. It is also seen in Fig. 1 that the second lifting means 56 comprises a parallelogrammical suspension 58, wherein a first end 60 of that parallelogrammical suspension 58 is being mounted at the longitudinally rear end 14 of the support surface 8, and that a second opposite end 62 of the parallelogrammical suspension 58 is being mounted to the separatable 40 propulsion cart 48. It is also seen that an actuator 21,21b is being mounted to the parallelogrammical suspension 58 in such a way that actuation of the actuator 21,21b will effect a raising or lowering of said longitudinally rear end 14 of the support surface 8, in relation to ground level.” Because these claim limitations are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, they are not being interpreted to cover only the corresponding structure, material, or acts described in the specification as performing the claimed function, and equivalents thereof. If applicant intends to have these limitations interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitations to remove the structure, materials, or acts that performs the claimed function; or (2) present a sufficient showing that the claim limitations do not recite sufficient structure, materials, or acts to perform the claimed function. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1 rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The amendments to Claim 1 recite “characterized in that said lifting means comprises a first set of lifting means which is configured for lifting/lowering the longitudinal front end of said support surface; and wherein said lifting means comprises a second set of lifting means which is configured for lifting/lowering the longitudinal rear end of said support surface and which are arranged below said support surface.” There is no support in the application specification and drawings that the second set of lifting means is arranged below the support surface. However, there is support in the application specification and drawings to support that the first set of lifting means is arranged below the support surface, see, for example, FIG. 1. Claims 3-4, 6-7, 10, 13, 16-17, 22, 24-27, 29, 31, 33-34, 37, and 39 are rejected by dependency on Claim 1. The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1, 3-4, 6-7, 10, 13, 16-17, 22, 24-27, 29, 31, 33-34, 37, and 39 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. As stated above, amended Claim 1 (lines 19-23) “which are arranged below said support surface.” There is no support in the application specification and drawings that the second set of lifting means is arranged below the support surface. However, there is support in the application specification and drawings to support that the first set of lifting means is arranged below the support surface, see, for example, FIG. 1. For examination purposes, amended Claim 1 will be read as considering “which are arranged below said support surface” as referring to the first set of lifting means. Claims 3-4, 6-7, 10, 13, 16-17, 22, 24-27, 29, 31, 33-34, 37, and 39 are rejected by dependency on Claim 1. Claim 22 (lines 9-10) and Claim 25 (line 3) recite “upwardly extending rail.” There is insufficient explanation of what “upwardly extending” refers to and instead should be explicitly stated or clarified. For examination purposes, “upwardly extending rail” will be read as a rail extending longitudinally along the frame. Claim 24 is rejected by dependency on Claim 22. Claim 2recites the limitation "said rail.” There is insufficient antecedent basis for this limitation in the claim. For examination purposes, “said rail” will be read as “upwardly extending rail” of Claim 22. Claim 22 recites: “[…] wherein said frame of said towing device, at opposite longitudinal sides thereof, comprises a second attachment means, wherein said first attachment means of said wheel support is configured to be detachably mounted to said second attachment means of said frame of said towing device; optionally wherein said second attachment means comprises an upwardly extending rail Claim 26 recites: “(Currently Amended) A towing device according to claim 24, wherein said rail comprises an array of longitudinally arranged holes, and wherein said block of said first attachment means comprises a hole, thereby via said holes in said rail and via said hole in said block, allowing locking of said first attachment means of said wheel support to said second attachment means of said frame, element. ” Claim 27 recites: “(Currently Amended) A towing device according to claim 22, wherein said frame of said towing device comprises longitudinally arranged beams arranged at opposite sides thereof, and wherein said second attachment means comprises a hollow interior in each said beam at a first longitudinal end thereof; optionally wherein said wheel support comprises an L-shaped element having a first end and an opposite, second end, wherein said first end of said L-shaped element is forming said first said longitudinally arranged beam of said frame at said first longitudinal end thereof. Claim 29 recites: (Currently Amended) A towing device according to claim 27, wherein said wheel support comprises a locking element for locking said first end of said L-shaped element into said hollow interior of said beam of said frame, Regarding Claims 27 and 29, it is unclear which part, the longitudinal beam or the second attachment means, contains the “hollow portion” for receiving the L-shaped element or if the longitudinal beam and the second attachment means are the same component. For example, Claim 27 (line) recites “second attachment means comprises a hollow interior in each said beam” is not clear and the relationship between the longitudinal beam and second attachment means should be clarified. For examination purposes, Claim 27 will be read as, the longitudinal beam contains the hollow interior for receiving the L-shaped element. Further, Claim 27 and Claim 29 uses both “said longitudinally arranged beam” and “said beam,” as bolded above, and should instead use only either. 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, 6, 10, 13, 16, 37 and 39 are rejected under 35 U.S.C. 103 as being unpatentable over Bryant et al., PG Pub US-2015/0217671-A1, (herein "Bryant") in view of Schutz et al., DE-102018221169-A1 (herein "Schutz"), Jacobsen, EP-3283308-B1 (herein "Jacobsen"), and Johnstone Patent No. US-3,924,701-A (herein "Johnstone"). Regarding Claim 1, Bryant discloses: (Currently Amended)[…]; wherein said towing device, in the orientation intended during use, comprises a frame, wherein said frame comprises one or more sets of wheels to be supported on a ground surface. See [Bryant, FIGs. 1 and 8 and pg. 3, para 0042], which describes the trailer frame, “Referring to FIG. 1, there is shown the boat lift trailer 10 of the present invention. The boat lift 10 of the present invention includes a trailer body 12. The trailer body 12 is preferably of a steel frame structure,” and [Bryant, pg. 3, paras 0043 and 0046], which describe the wheels of the trailer, “[0043] The trailer body 12 has a back stationary axle 16 with wheels and tires 14 affixed thereto. […] The wheels and components of the stationary axle can rotate as necessary so as to allow for movement of the trailer service on the trailer body on the ground surface there below. […]. [0046] Also shown in FIG. 1 is the front lift pivoting axle assembly 28 having wheels thereon. In FIG. 1, the front lift pivoting axle assembly 28 is shown above the ground surface, such that when the trailer boat lift trailer 10 is towed, it only rides on the wheels and tires 14 of the back stationary axle 16.” Bryant further discloses: […] wherein said frame comprises a support surface at an upper portion thereof, wherein said support surface has an extension in a longitudinal direction and in a transversal direction, which is perpendicular to said longitudinal direction; wherein said support surface has a longitudinal front end and a longitudinal rear end […]. See again [Bryant, FIG. 2] and see also [Bryant, pg. 2, para 0033], which describes the lifting surface, “The top surface of the first lifting arm the second lifting may define a lifting surface,” and further [Bryant, FIG. 8 and pg. 4 ,para 0056], which explains that the frame is rectangular with a lifting surface, “Finally, FIG. 8 shows a top view of the frame structure of the boat lift trailer 10. As can be seen in FIG. 8, the trailer body 12 is of a generally rectangular frame structure. Further, the lifting surface 20 also comprises a frame structure having a number of cross members 54, 56 and 58.” Bryant does not explicitly disclose: (Currently Amended) A towing device for moving a vehicle from a first location to a second location […and…] wherein said support surface is configured to be arranged below a vehicle and support said vehicle to be moved, when said support surface is in its raised position. However, [Bryant, FIGs. 1-2], do show a trailer for placement under a boat with a surface that can be raised for moving the boat. However, Schutz teaches: (Currently Amended) A towing device for moving a vehicle from a first location to a second location […and…] wherein said support surface is configured to be arranged below a vehicle and support said vehicle to be moved, when said support surface is in its raised position. See [Schutz, pg. 1, para 0002], which describes typical parking robot inventions and the capability to navigate under a vehicle to be moved when the area is raised, “For example, the parking robot drives at least a portion of its area under the vehicle, lifts it up, and then drives with the lifted vehicle to the specified parking position, where it sets the vehicle down again.” See also [Schutz, FIGs. 1-2 and pg. 3, para 0009], which explains that the parking robot moves under the vehicle, “The parking robot is now designed to drive under the vehicle with the respective wheel support arms folded in. The parking robot as a whole, i.e. with the connected main robot part and the secondary robot part, is designed to drive into the space between a vehicle floor of the motor vehicle and a driving floor, i.e. a surface on which the motor vehicle is currently standing, for example.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Schutz to move the towing device under a vehicle for moving it from one place to another. Doing so is the typical design for a parking robot [Schutz, pg. 1, para 0002], which allows the vehicle to be lifted off of all four wheels and maneuvered [Schutz, pg. 2, para 0007] without driver intervention [Schutz, pg. 1, para 0002]. Bryant does not disclose: […] wherein said towing device comprises propulsion means for propelling said towing device […]. However, Schutz teaches: […] wherein said towing device comprises propulsion means for propelling said towing device […]. See [Schutz, FIG. 1 and pg. 5, para 0014], which explains that the robot has a drive portion, including a motor and at least one drive wheel, “In a further development of the parking robot according to the invention, it is provided that the main robot part has a raised partial area which comprises an electric main drive machine, a battery for supplying the electric main drive machine with electrical energy and at least one drive wheel for moving the main robot part and the secondary robot part connected to the main robot part. The raised section is preferably arranged directly next to the flat section with the respective wheel support arms. The raised section includes all the components that are necessary for the drive and thus the movement, i.e. for driving, of the main robot part. The main drive motor, the battery and at least one drive wheel of the main robot part are designed to either drive the main robot part alone or to drive the entire parking robot, i.e. the main robot part with the connected secondary robot part.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Schutz to move the towing device use its own propulsion. Doing so is the typical design for a parking robot, which allows the vehicle to be maneuvered autonomously without driver intervention [Schutz, pg. 1, para 0002]. Bryant further disclose: […] wherein said towing device comprises a control system for controlling the operation of said towing device […]. See [Bryant, pg. 2, para 0030], which explains that the trailer has a control panel for operating the lift and pivoting assembly of the trailer, “In one embodiment of the present invention, the apparatus further includes a control panel mounted adjacent the second end of the trailer body. The control panel is suitable for selectively operating the lifting means and the pivoting axle assembly. A remote control maybe provided which is in communication with the control panel.” Bryant does not disclose: characterized in that said towing device comprises drive means in the form of a first set of drive wheels or drive caterpillars arranged at a right side of the towing device and a second set of drive wheels or drive caterpillars arranged at a left side of the towing device. However, Jacobsen teaches: characterized in that said towing device comprises drive means in the form of a first set of drive wheels […] arranged at a right side of the towing device and a second set of drive wheels […] arranged at a left side of the towing device. See [Jacobsen, FIGs. 1-2, and pgs. 2-3, para 0011], which describes that the automatically guided vehicle includes drive wheels mounted on the vehicle, “Specifically, the present invention provides an automatically guided vehicle for towing (or pushing) a wheeled cart having at least four wheels and provided with a cart frame, the vehicle comprising: drive wheels; a robot body mounted on said drive wheels […].” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Jacobsen to provide a set of drive whiles. Doing so allows the mobile robot to move autonomously between locations [Jacobsen, pg. 2, para 0002]. However, Johnstone teaches: characterized in that said towing device comprises drive means in the form of […] drive caterpillars arranged at a right side of the towing device and […] drive caterpillars arranged at a left side of the towing device. See [Johnstone, FIG. 1 and col 4, lines 49-53] , which shows the driven belt tracks on either side of the dolly, “Each belt track is driven by a separate drive system. Because the drive systems for both belt tracks are identical, only the drive system for the left side belt track 20 will be described, and it will be understood that the drive for the right side belt track is identical.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Johnstone to use driven tracks on each side of the device. Doing so is a method known to the art [Johnstone, col 1, lines 21-23], such as when moving heavy loads like a mobile home [Johnstone, col 6, lines 47-52]. Bryant further discloses: wherein said towing device comprises lifting means for raising and lowering said support surface in relation to said ground surface; […]; characterized in that said lifting means comprises a first set of lifting means which is configured for lifting/lowering the longitudinal front end of said support surface; and wherein said lifting means comprises a second set of lifting means which is configured for lifting/lowering the longitudinal rear end of said support surface and which are arranged below said support surface; and in that said first set of lifting means comprises a wheel suspension which is being pivotally mounted to said frame and wherein one or more actuators are being mounted between said wheel suspension and said frame in such a way that actuation of said one or more actuators affect a pivoting of said wheel suspension around a pivot axis. See [Bryant, FIG. 2 and pg. 3, para 0044], which explains that the trailer comprises a lifting surface and lifting means for raising and lowering the lifting surface, “The boat lift trailer 10 also has a lifting surface 20 positioned above the trailer body 12. The lifting surface 20 is also preferably of a frame structure and has curved ends 22 at an end thereof opposite the trailer jack 18. […]. The lifting surface 20 is positioned above the trailer body 12 by a lifting means 26. Preferably, the lifting means is a scissor lift 26. However, the lifting means can be any number of mechanisms including a jack such as a hydraulic jack, a motor power mechanism, a ratchet type system, or similar mechanisms.” See also [Bryant, pg. , paras 0046-0047], which explains that the trailer also has a front lift pivoting axle assembly which includes a hydraulic mechanism or actuator for pivoting the wheel assembly, “[0046] Also shown in FIG. 1 is the front lift pivoting axle assembly 28 having wheels thereon. In FIG. 1, the front lift pivoting axle assembly 28 is shown above the ground surface, such that when the trailer boat lift trailer 10 is towed, it only rides on the wheels and tires 14 of the back stationary axle 16. [0047] Preferably, both the front lift pivoting axle 28 and scissor lift 26 are hydraulically powered. A control panel 32 is positioned at the front of the boat lift trailer 10 adjacent to trailer jack 18. Hydraulic pumps 34 are also positioned adjacent the control panel 32. The hydraulic pumps 34 serve to power the scissor lift 26 and the front lift pivoting axle 28. […]. While hydraulic mechanisms are preferred, any number of actuators could be utilized with the front lift pivoting axle 28 so as to accomplish the same end result. The actuator could also be in the form of a pneumatic cylinder.” Finally see [Bryant, FIGS. 4-5, and pg. 4, paras 0051 and 0053], which explain that the front lift pivoting axle assembly pivots the wheels to move the surface, or trailer, up and down for load or unloading a boat, “[0051] As the boat lift trailer 10 approaches the boat lift or hoist 44, the hydraulics controlling the front lift pivoting axle and wheels 28 are actuated. FIG. 5 shows how the front lift pivoting axle and wheels 28 have been deployed downwardly by the axle hydraulic cylinder 38, causing the body of the boat lift trailer 10 opposite the tow vehicle 42 to be angled upwardly. […]. [0053] FIG. 6 shows the boat lift trailer 10 […]. As can be seen, the front lift pivoting axle 28, and the wheels thereof, are in a stowed position above the ground. The wheels of the front lift pivoting axle 28 were raised prior to coming into contact with the lower horizontal members 48 of the boat lift 44. It is also worth noting that the trailer jack 18 has been in a stowed position during the process of the present invention.” Regarding Claim 6, Bryant as modified discloses the limitations of Claim 1. Bryant further discloses: (Currently Amended) […] wherein said lifting means comprises one or more actuators. See again [Bryant, pg. , paras 0046-0047], which explains that the trailer also has a front lift pivoting axle assembly which includes a hydraulic mechanism or actuator for pivoting the wheel assembly and [Bryant, pg. 2, para 0030], which explains that the trailer has a control panel for operating the lift and pivoting assembly of the trailer Regarding Claim 10, Bryant as modified discloses the limitations of Claim 1. Bryant further discloses: (Currently Amended) […] wherein said frame comprises a second coupling means […]. See [Bryant, FIG. 4 and pg. 4, para 0050], which shows a standard trailer hitch, where the trailer has a female coupling for mating with a male coupling of a vehicle, “In FIG. 4, it can be seen that the boat lift trailer 10 is affixed to a truck or other tow vehicle 42. […]. The boat lift trailer 10 of the present invention can be used with a variety of boat lifts 44, including the most common four-post setup.” Bryant does not disclose: […] wherein said propulsion means is first coupling means and said second coupling means However, Schutz teaches: […] wherein said propulsion means is See again [Schutz, FIG. 1 and pg. 5, para 0014], which explains that the robot has a drive portion, including a motor and at least one drive wheel. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Schutz to include a propulsion means within the main device. Doing so a typical design for a parking robot, which allows the vehicle to be maneuvered autonomously without driver intervention [Schutz, pg. 1, para 0002]. However, Jacobsen teaches: […] wherein said propulsion means is in the form of a propulsion cart which is See [Jacobsen, pgs. 2-3, para 0011], which describes the robot for towing, “Accordingly, the present invention provides an improved wheeled robot for automatic docketing and towing/hauling carts and similar wagons from one position to another. […]. The cart mobile robot system of the present invention enables automatic docking and undocking of the cart, which is a major improvement over existing solutions. Specifically, the present invention provides an automatically guided vehicle for towing (or pushing) a wheeled cart having at least four wheels and provided with a cart frame, the vehicle comprising: drive wheels; a robot body mounted on said drive wheels; a control system utilizing a navigational system; a cart attaching mechanism mounted on said robot body for coupling the cart to said vehicle; […].” See also [Jacobsen, FIG. 7, Views A-C and pg. 4, para 0022],which shows the various vehicle and cart releasable linking means, “Figure 7 shows the procedure for linking the cart (3) and the cart attaching mechanism (1), wherein: View A illustrates the situation where the vehicle (2) has determined the position of the cart (3), whereby the flexible suspension of the cart attaching mechanism is lowered by means of the linear actuator (31 ); View B illustrates the situation where the vehicle (2) moves rearwards until there is contact between the supporting bracket (22) and the cart frame (50); View C illustrates the situation where the flexible suspension coupling mechanism is raised by means of the linear actuator (31) until there is contact between the joint (12) and the frame (50); View D illustrates the situation where the linear actuator (21) extends and pushes the base frame (50) back toward the hook (20) (View A) and the coupling between the cart attaching mechanism (1) and the cart (3) is established. Decoupling is done by the reverse operation (not shown).” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Jacobsen to use a releasable coupling means between a propulsion cart and the cart, or trailer. Doing so is a method known to the art for transporting using autonomously guided vehicles [Jacobsen, pg. 2, para 0002-0005]. Regarding Claim 13, Bryant as modified discloses the limitations of Claim 10. Bryant further discloses: […] wherein said second coupling means comprising a female part of a standard coupling means or hitch for attaching a trailer to a passenger car. See again [Bryant, FIG. 4 and pg. 4, para 0050], which shows a standard trailer hitch, where the trailer has a female coupling for mating with a male coupling of a vehicle Bryant does not disclose: wherein said first coupling means comprising a male part of a standard coupling means or hitch for attaching a trailer to a passenger car. However, Jacobsen teaches: wherein said first coupling means comprising a male part of a standard coupling means or hitch for attaching a trailer to a passenger car. See again [Jacobsen, FIG. 7, Views A-C and pg. 4, para 0022], which shows the various vehicle and cart releasable linking means. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Jacobsen to use a male coupling part, or hitch, on the propulsion cart. Doing so is a method known to the art for towing using autonomously guided vehicles [Jacobsen, pg. 2, para 0004]. Regarding Claim 16, Bryant as modified discloses the limitations of Claim 10. Bryant does not disclose: wherein said set of second set of lifting means comprises a parallelogrammical suspension, wherein a first end of said parallelogrammical suspension is being mounted at the longitudinally rear end of said support surface, and wherein a second opposite end of said parallelogrammical suspension is being mounted to said separatable propulsion cart; wherein one or more actuators are being mounted on said parallelogrammical suspension, in such a way that actuation of said one or more actuators will effect a raising or lowering of said longitudinally rear end of said support surface. However, Jacobsen teaches: wherein said set of second set of lifting means comprises a parallelogrammical suspension, wherein a first end of said parallelogrammical suspension is being mounted at the longitudinally rear end of said support surface, and wherein a second opposite end of said parallelogrammical suspension is being mounted to said separatable propulsion cart; wherein one or more actuators are being mounted on said parallelogrammical suspension, in such a way that actuation of said one or more actuators will effect a raising or lowering of said longitudinally rear end of said support surface. See again [Jacobsen, FIG. 7, View C and pg. 4, para 0022], which shows the parallelogram structure for linking the vehicle and the cart, including a linear actuator for raising and lowering the coupling mechanism. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Jacobsen to use a parallelogrammical suspension connected between the cart and the trailer. Doing so provides a flexible suspension coupling [Jacobsen, pg. 4, para 0022], which allows hauling over uneven surfaces [Jacobsen, pg. 2, para 0007]. Regarding Claim 37, Bryant as modified discloses the limitations of Claim 1. Bryant does not disclose: Use of a towing device according to claim 1 for moving a vehicle from one location to another location. However, Schutz teaches: Use of a towing device according to claim 1 for moving a vehicle from one location to another location. See again [Schutz, pg. 1, para 0002], which describes typical parking robot inventions and the capability to navigate under a vehicle to be moved. See [Schutz, pg. 7, para 0017], which explains that the robot has a control device for determining the trajectory and [Schutz, pg. 7, para 0018], which explains that the trajectory is used for autonomous control. Finally see again [Schutz, pg. 8, paras 0019-0020], which explain that the control device uses the trajectory to control the robot and wheel supports. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Schutz to use the towing device under a vehicle for moving it from one place to another. Doing so is the typical design for a parking robot [Schutz, pg. 1, para 0002], which allows the vehicle to be lifted off of all four wheels and maneuvered [Schutz, pg. 2, para 0007] without driver intervention [Schutz, pg. 1, para 0002]. Regarding Claim 39, Bryant as modified discloses: providing a towing device according to claim 1. Bryant does not explicitly disclose: A method for moving a vehicle from a first location to a second location; said method comprises the steps of: […]; arranging the towing device in line with the longitudinal direction of the vehicle to be moved, either in front of or behind that vehicle; ensuring that the support platform is the towing device in order to arrange said support surface, or at least part thereof, of the towing device, below said vehicle to be moved; once arranged below said vehicle to be moved, via said control system, raising said support surface a predetermined distance by means of said lifting means; using said control system of said towing device to propel and steer said towing device in order to move said vehicle from said first location to said second location. However, Schutz teaches: A method for moving a vehicle from a first location to a second location; said method comprises the steps of: […]; arranging the towing device in line with the longitudinal direction of the vehicle to be moved, either in front of or behind that vehicle; ensuring that the support platform is the towing device in order to arrange said support surface, or at least part thereof, of the towing device, below said vehicle to be moved; once arranged below said vehicle to be moved, via said control system, raising said support surface a predetermined distance by means of said lifting means; using said control system of said towing device to propel and steer said towing device in order to move said vehicle from said first location to said second location. See again [Schutz, pg. 1, para 0002], which describes typical parking robot inventions and the capability to navigate under a vehicle to be moved and [Schutz, FIGs. 1-2 and pg. 3, para 0009], which explains that the parking robot moves under the vehicle. See also [Schutz, pg. 3, para 0011], which explains that the parking robot lifts the vehicle by placing and raising the wheels, “The parking robot is now designed to lift the respective wheels of the respective wheel axle of the vehicle by folding out the respective pairs of wheel support arms. When the respective wheel support arms are unfolded, they are in a position of use of the respective wheel support arms. To lift the wheels of the motor vehicle, for example, the wheel support arms are folded out from their folded position until they touch the outer surface of the respective wheel on two opposite sides and, by folding out further, press against the respective wheel from both sides and finally lift the respective wheel of the motor vehicle. When the respective wheel support arms are unfolded, the respective wheels are ultimately pushed upwards in a vertical direction of the vehicle, so that when the respective wheel support arms are at an angle of typically 90 degrees to the outer wall of the main robot part or the secondary robot part, they have completely lifted the vehicle from the driving floor.” Also see again [Schutz, FIG. 1 and pg. 5, para 0014], which explains that the robot has a drive portion, including a motor and at least one drive wheel. Also see again [Schutz, pg. 7, para 0017], which explains that the robot has a control device for determining the trajectory, [Schutz, pg. 7, para 0018], which explains that the trajectory is used for autonomous control, and [Schutz, pg. 8, paras 0019-0020], which explain that the control device uses the trajectory to control the robot. And finally see [Schutz, pg. 11, para 0027], which further explains that the control device is used for control of the parking robot, “The invention also includes the control device of the main robot part. This control device has a processor device which is designed to control the parking robot. For this purpose, the processor device can comprise at least one microprocessor or at least one microcontroller. Furthermore, the processor device can have a program code which is designed to carry out the acceptance, transport and parking of the motor vehicle by means of the corresponding control of the parking robot. The program code can be stored in a data memory of the processor device of the control device.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Schutz to use a method of moving the device under a vehicle, raising the vehicle, and moving the vehicle from one location to another. Doing so is the typical design for a parking robot [Schutz, pg. 1, para 0002], which allows the vehicle to be lifted off of all four wheels and maneuvered [Schutz, pg. 2, para 0007] without driver intervention [Schutz, pg. 1, para 0002]. Claims 3 and 4 are rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, and Johnstone, further in view of Tang et al., PG Pub US-2020/0307667-A1 (herein "Tang"). Regarding Claim 3, Bryant as modified discloses the limitations of Claim 1. Bryant does not explicitly disclose: […] wherein said towing device comprises a remote control comprising a transmitter for transmitting electromagnetic radiation representing control instructions, and wherein said control system comprises a receiver for receiving electromagnetic radiation representing said control instructions. However, [Bryant, pg. 2, para 0030], does explain that the trailer has a control panel for operating the lift and pivoting assembly of the trailer, including a remote control. However, Tang teaches: […] wherein said towing device comprises a remote control comprising a transmitter for transmitting electromagnetic radiation representing control instructions, and wherein said control system comprises a receiver for receiving electromagnetic radiation representing said control instructions. See [Tang, pg. 3, para 0026], which explains that the AGV can be controlled wirelessly by a management system or operator, “It is contemplated that the command or instruction may be any information associated with various tasks that may be performed within the facility. For example, the information may identify an inventory holder to be moved by the AGV 100, inventory storage, a destination of the inventory holder and/or the AGV 100, a current location of the AGV 100, and/or adjust the height of the upper surface 106 of the mobile base 102 of the AGV 100, etc. The command or instruction may be sent wirelessly over an internet, through a wired connection, or using any suitable manner to communicate with an operator or a management system. Examples of wireless communication may include, but are not limited to, ultra-wideband, radio frequency identification (active and/or passive), Bluetooth, WiFi, and/ or any other form of communication of the communication.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Tang to include remote control capabilities. Doing so provides a safer and more controlled environment [Tang, pg. 1, para 0002], but allowing operator intervention as needed [Tang, pg. 2, para 0018]. Regarding Claim 4, Bryant as modified discloses the limitations of Claim 3. Bryant does not disclose: […] wherein said towing device comprises one or more image capturing units which is or However, Tang teaches: […] wherein said towing device comprises one or more image capturing units which is or. See [Tang, pg. 3, para 0027], which explains the AGV comprises sensors and cameras for aiding in autonomous movement, “The AGV 100 includes one or more sensors or cameras to ensure proper docking or engagement with the inventory holder 103 or any other objects such as inventory items. The sensors or cameras to be discussed below with respect to FIGS. 1, 2, and 4-6 allow the AGV 100 to determine whether the inventory holder 103/object is properly docked/placed and ready to be lifted up. In addition, the combination of the information recorded, detected, and/or measured by the sensors or cameras can be used to help autonomously move the AGV 100 in a given direction while avoiding nearby obstacles. In some cases, the combination of the information recorded, detected, and/or measured by the sensors or cameras can be used to help autonomously maintain the AGV 100 in a rear follow position and/or a side follow position next to an operator. For example, the AGV 100 may be programmed or controlled to maintain in the side follow position as the operator moves in a given direction. […].” See also [Tang, pg. 5, paras 0045 and 0047-0049], which explain that the AGV includes a console with a display connected with the sensors and cameras and for an operator to communicate, wired or wirelessly, “[0045] FIG. 1 further shows that the AGV 100 includes a button 158 disposed at the rear side of the mobile base 102. The button 158 can be pushed by an operator to notify the AGV 100 that the inventory holder is properly docked and ready to be lifted up. While the button 158 is shown located on the rear side of the mobile base 102, the button 158 may be located at different positions on the mobile base 102. The button 158 may also be located at the console 104. […]. [0047] The processor 702 is also in communication with proximity sensors 706, contact type sensors 708, and image acquiring device 710. The proximity sensors 706 may include any non-contact type […]. The contact type sensors may include any sensors described above such as pressure sensors. The image acquiring device 710 may include any image taking or recording cameras described above. The information detected or collected by the proximity sensors 706, contact type sensors 708 and the image acquiring device 710 are provided to the processor 702 so that it can determine whether the inventory holder is properly docked and ready to be lifted up. In addition, the combination of the information recorded, detected, or gathered by the sensors and/or cameras can be used to help autonomously move the AGV 100 in a given direction while avoiding nearby obstacles. [0048] The processor 702 is also in communication with a user input, device 712. The user input device 712 may include the display as discussed above to display needed information. The user input device 712 also allows the operator to provide commands/instructions to the AGV system manually, or wirelessly via a remote control.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to further modify Nguyen with Tang to include cameras and a display for remote control. Doing so ensure proper use and loading [Tang, pg. 2, para 0021] and allows the operator to avoid obstacles [Tang, pg. 3, para 0027]. Claim 7 and 31 is rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, and Johnstone, further in view of Newhard, Patent No. US-4,456,420-A (herein "Newhard"). Regarding Claim 7, Bryant as modified discloses the limitations of Claim 1. Bryant does not disclose: […] wherein the towing device comprises a winch, However, Newhard teaches: ([…] wherein the towing device comprises a winch, See [Newhard, FIG. 3 and col 6, lines 45-56], which describes the winch with a cable, “A winch 32 is provided at the front of the platform 25 to assist in loading and securing the carried car 35.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Newhard to include a winch. Doing so assists the loading and securing of the vehicle on to the platform [Newhard, col 6, lines 45-56]. Regarding Claim 31, Bryant as modified discloses the limitations of Claim 1. Bryant does not disclose: […] wherein said frame at a longitudinally arranged beam at its right side and/or at its left side thereof comprises an auxiliary actuator having a first end and a second end, and/or at its left side thereof comprises a pivoting element; wherein said pivoting element is is able to pivot around a pivoting axis; wherein said pivoting element comprises a push portion; wherein said first end of said auxiliary actuator is However, Newhard teaches: […] wherein said frame at a longitudinally arranged beam at its right side and/or at its left side thereof comprises an auxiliary actuator having a first end and a second end, . See [Newhard, FIGs. 4-6 and col 8, lines 36-62], which describes the hydraulic lock cylinders at each wheel assembly, which contract and expand movement of the main lift cylinder, to support pushing the foot assemblies to the ground and lifting the bed, “assembly 25 in the transport position. In order to displace the platform assembly 25, the double action hydraulic drive cylinder 51 is activated by hydraulic means well known in the art thereby causing the ram end 53 to begin exerting a pulling force on the rotatable cross bar 57. This pulling action on cross bar 57 causes the platform 25 simultaneously to tilt and slide by the pivoting action of the couplers 63 and 65 on upper shaft 67 about lower shaft 69. As the platform 25 tilts and slides rearward towards the load position, the support foot return roller 123 follows the bottom extrusion surface 93 of the platform 25 thereby allowing the support foot assemblies 29 to pivot about support foot shaft 131, this action being caused by the gravitational pull of the heavier pad end 139 of the support foot assembly 29. As the support foot assemblies 29 lower to meet their respective ground levels, each lock cylinder 117 draws in hydraulic fluid from a common hydraulic fluid reservoir noting however that each lock cylinder 117 and support foot assembly 29 is independent of the other in operation. At an intermediate position where the platform 25 would be located is the support feet 29 were to engage the ground their maximum allowable distance below that level of ground being experienced by the rear wheels 19, a lock cylinder fluid feed control valve (not shown) would be tripped closed.” Newhard further teaches: […] wherein said frame at said longitudinally arranged beam at its right side and/or at its left side thereof comprises a pivoting element; wherein said pivoting element is is able to pivot around a pivoting axis; wherein said pivoting element comprises a push portion […]. See [Newhard, FIGs. 4-6 and col 8, lines 7-22],which describes the slide assembly of the support foot, which slides and rotates about the bottom of the platform as the hydraulic lock actuator pushed down on the opposite end, “As illustrated in FIG. 5, the support foot assembly 29 comprises a slide assembly 121 consisting of various section of standard rectangular tubing. Connected to this slide assembly 121 is a support foot return roller 123 and a coupler contact guide pad 125. The support foot return roller 123 contacts the bottom surface of the extrusions 93 attached to the mam support beams 91 of the platform 25 thus retaining the support feet 29 as shown when the platform 25 is in the transport position illustrated in FIGS. 1 ana 5. As the platform 25 is upwardly displaced, the support foot roller 123 follows the bottom surface of the extrus10ns 93 of the platform 25 until such contact is ceased which thus indicates the support foot 29 has gravitated to and contacted to support surface.” Newhard further teaches: wherein said first end of said auxiliary actuator is See again [Newhard, FIGs. 4-6 and col 8, lines 36-62], which describes the hydraulic lock cylinders at each wheel assembly, which contract and expand movement of the main lift cylinder, to support pushing the foot assemblies to the ground and lifting the bed. Also see again [Newhard, FIGs. 4-6 and col 8, lines 7-22],which describes the slide assembly of the support foot, which slides and rotates about the bottom of the platform as the hydraulic lock actuator pushed down on the opposite end. Finally see [Newhard, FIGs. 4-6, and col 7, lines 62-67], which explain that one end of the lock cylinder is connected to the support foot and the other end is connected to the secondary roller and roller shaft of the frame, “A pair of secondary rollers 109 are attached to a secondary roller shaft 111 that connects to the rearmost portion of the service vehicle frame 17 by means of brackets 113. Attached to 65 shaft 111 are the ends of two support feet lock cylinders 117 which are coupled at opposite ends to the support foot assemblies 29,” and [Newhard, col 9, lines 3-8], which explain that the cylinder can be controlled via a low- or high-pressure fluid, “It should be noted that the hydraulic lock cylinders 117 could be fed by low-pressure fluid or assisted by spring means to aid the gravitational pull of the support foot assemblies 29. Also, the lock cylinders 117 could be fed by high-pressure fluid such as that used by cylinder 51.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Newhard to include an auxiliary actuator for pushing up the support platform. Doing so allows the load to be transferred through the lock cylinders [Newhard, col 8, lines 64-68] and assist the main hydraulic lift mechanism [Newhard, col 9, lines 11-15]. Claim 17 is rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, and Johnstone, further in view of Shindo, JP-H05193497-A (herein "Shindo"). Regarding Claim 17, Bryant as modified discloses the limitations of Claim 16. Bryant does not explicitly disclose: […] wherein said wheel suspension comprises one or more wheels in the form of rollers, supporting said support frame at a longitudinal front end thereof. However [Bryant, FIGs. 1 and 8 and pg. 3, para 0042], does describes the trailer frame and [Bryant, pg. 3, paras 0043 and 0046], the wheels of the trailer, which are unpowered and roll. However, Shindo teaches: […] wherein said wheel suspension comprises one or more wheels in the form of rollers, supporting said support frame at a longitudinal front end thereof. See [Shindo, FIG. 3 and pg. 1, para 0008], which explains that, “The bracket 20 includes a pair of rollers 22, are mounted these rollers 22 on the rear cross member 23 (see FIG. 1).” See also [Shindo, pg. 2, para 0009], which explains that as the surface moves up and down the brackets pivot to meet the ground, “Then, in conjunction with the movement of the link rod 18, so that the lift -up bracket 20 is gradually erected gradually while rolling the roller 22 forward.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Shindo to include rollers on the wheel suspension. Doing so allows for a design that minimizes the drive wheels, to as low as one drive wheel [Shindo, pg. 1, para 0002] and the pivoting mechanism holding the roller further supports the frame as the roller passively rolls [Shindo, pg. 2, para 0009]. Claim 22 and 24-26 are rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, and Johnstone, further in view of Rossi, EP-3040235-A1 (herein "Rossi") and Pijanowski, Patent No. US-5,271,705-A (herein "Pijanowski"). Regarding Claim 22, Bryant as modified discloses the limitations of Claim 1. Bryant does not disclose: […] further comprising an array of detachable wheel supports, detachably mounted to said second attachment means of said frame of said towing device; optionally wherein said second attachment means comprises an upwardly extending rail However, Schutz teaches: […] further comprising an array of […] wheel supports, . See [Schutz, FIG. 2 and pg. 2, para 0008], which shows the parking robot with four sets of wheel supports, “The parking robot according to the invention for a motor vehicle with at least two wheel axles comprises a main robot part and a secondary robot part. The parking robot for a motor vehicle according to the invention is therefore in two parts. The main robot part and the secondary robot part each have a pair of wheel support arms on two opposite sides. These wheel support arms are provided as foldable, i.e. extendable and retractable components, of which both the main robot part and the secondary robot part each have a total of four, i.e. two respective pairs of wheel support arms.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Schutz to include four wheel supports. Doing so is the typical design for a parking robot [Schutz, pg. 1, para 0002], which allows the vehicle to be lifted off of all four wheels and maneuvered [Schutz, pg. 2, para 0007]. However, Rossi teaches: […] an array of detachable supports, […], wherein each […] support comprises a first attachment means and wherein said frame of said towing device, at opposite longitudinal sides thereof, comprises a second attachment means, wherein said first attachment means of said wheel support is configured to be detachably mounted to said second attachment means of said frame of said towing device; […]. See [Rossi, FIG. 13 and Abstract], which explains that the trailer has, “at least one couple of forks (50,51) parallel to each other and mounted to the frame (30) substantially orthogonal to the towing direction.” Also see [Rossi, FIGs. 7-9 and pg. 8, para 0056], which show the engagement element of the fork and the longitudinal element, which slidingly engage, “For instance, counterframe 41 can be a metal structure, for example it can comprise horizontally arranged longitudinal elements 42',42" that are connected to one another by vertically arranged transversal elements 43',43". Transversal elements 43',43" may have 15 a portion which slidingly engages with guide 38. Forks 50,51 can be connected to a lower longitudinal element 42" of counterframe 41, preferably by means of engagement elements 59 slidingly arranged along lower longitudinal element 42", in order to adjust the distance be- 20 tween forks 50 and 51 responsive to the size and to the position of the engagement socket or of the engagement sockets of the palletized material to be lifted.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to further modify Nguyen with Rossi to make the supports detachable along one end of the support and the longitudinal side of the frame. Doing so allows the supports to be modular [Rossi, pg. 2, para 0001] and adapt to the size of the object to be carried [Rossi, pg. 13, para 0056]. However, Pijanowski teaches: […] optionally wherein said second attachment means comprises an upwardly extending rail See [Pijanowski, FIG. 8 and col 12, lines 37-52], which shows a wheel support with multiple holes at one end and the frame with multiple longitudinal holes. Further, it shows a locking pin which can be placed through the holes to lock the support in place, “The ability of the components of the assembly to assume various configurations is due to the various mating components being fabricated of channel iron with mating square cross-sectional configurations in combination with additional locking holes for being secured by various locking pins. More specifically, locking pins 146 and 172 couple with holes 148, 150 and 170 in the primary mode of FIG. 8, as well as holes 184 of FIG. 12. Additional alternate holes 148A, 150A, 170A and 184A are provided on adjacent faces of the opposite ends of the extender bars and the end of the elongated section of the J bracket. This allows the extender bar to be coupled to the centra support 123 and corner bracket 140 and J-bracket 154 to be coupled to the L-shaped bracket in any rotational orientation to extend the utility of the wheel life assembly 120.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to further modify Nguyen with Pijanowski to provide a hole and locking pin mechanism for the wheel support. Doing so allows the assembly to provide multiple configurations which can be securely attached [Pijanowski, col 12, lines 37-52]. Regarding Claim 24, Bryant as modified discloses the limitations of Claim 22. Bryant does not disclose: […] wherein said wheel support comprises a rod having a first end and an opposite second end, wherein said first end comprises said first engagement attachment means. However, Rossi teaches: […] wherein said wheel support comprises a rod having a first end and an opposite second end, wherein said first end comprises said first engagement attachment means. See again [Rossi, FIG. 13 and Abstract], which explains that the trailer has, “at least one couple of forks (50,51) parallel to each other and mounted to the frame (30) substantially orthogonal to the towing direction” and [Rossi, FIGs. 8-9], which show the fork with the engagement means at one end. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Rossi to provide a support with an engagement means at one end. Doing so allows the supports to be modular [Rossi, pg. 2, para 0001], where it can slidingly engage with the frame to adapt to the size of the object to be carried [Rossi, pg. 13, para 0056]. Regarding Claim 25, Bryant as modified discloses the limitations of Claim 24. Bryant does not disclose: […] wherein said first attachment means comprises a block comprising a recess, wherein a geometry and dimensions of said upwardly extending rail of said frame, upwardly extended rail may be accommodated in said recess of said block. However, Rossi teaches: […] wherein said first attachment means comprises a block comprising a recess, wherein a geometry and dimensions of said upwardly extending rail of said frame, upwardly extended rail may be accommodated in said recess of said block. See again [Rossi, FIGs. 7-9 and pg. 8, para 0056], which show the engagement element of the fork and the longitudinal element, which slidingly engage, where the fork engagement element comprises a support with a recess and a hook for attaching to the geometry of the longitudinal element. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Rossi to provide a support with a recessed geometry at one end for attaching to the geometry of the longitudinal element. Doing so allows the supports to be modular [Rossi, pg. 2, para 0001], where it can slidingly engage with the frame to adapt to the size of the object to be carried [Rossi, pg. 13, para 0056]. Regarding Claim 26, Bryant as modified discloses the limitations of Claim 24. Bryant does not disclose: […] wherein said rail comprises an array of longitudinally arranged holes, and wherein said block of said first attachment means comprises a hole, thereby via said holes in said rail and via said hole in said block, allowing locking of said first attachment means of said wheel support to said second attachment means of said frame,element. However, Rossi teaches: […] wherein said block of said first attachment means […], allowing […] of said first attachment means of said wheel support to said second attachment means of said frame, […]. See again [Rossi, FIGs. 7-9 and pg. 8, para 0056], which show the engagement element of the fork and the longitudinal element, which slidingly engage, where the fork engagement element comprises a support with a recess and a hook for attaching to the geometry of the longitudinal element. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Rossi to provide a support with a recessed geometry at one end for attaching to the geometry of the longitudinal element. Doing so allows the supports to be modular [Rossi, pg. 2, para 0001], where it can slidingly engage with the frame to adapt to the size of the object to be carried [Rossi, pg. 13, para 0056]. However, Pijanowski teaches: […] wherein said rail comprises an array of longitudinally arranged holes, and wherein said block […] comprises a hole, thereby via said holes in said rail and via said hole in said block, allowing locking […] of said wheel support to […] said frame,element. See again [Pijanowski, FIG. 8 and col 12, lines 37-52], which shows a wheel support with multiple holes at one end and the frame with multiple longitudinal holes. Further, it shows a locking pin which can be placed through the holes to lock the support in place. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to further modify Nguyen with Pijanowski to provide a hole and locking pin mechanism for the wheel support. Doing so allows the assembly to provide multiple configurations which can be securely attached [Pijanowski, col 12, lines 37-52]. Claim 27 and 29 are rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, Johnstone, Rossi, and Pijanowski, further in view of Roberts et al., Patent No. US-5,352,083-A (herein "Roberts"). Regarding Claim 27 Bryant as modified discloses the limitations of Claim 22. Bryant does not disclose: […] wherein said frame of said towing device comprises longitudinally arranged beams arranged at opposite sides thereof, and wherein said second attachment means comprises a hollow interior in each said beam at a first longitudinal end thereof; optionally wherein said wheel support comprises an L-shaped element having a first end and an opposite, second end, wherein said first end of said L-shaped element is forming said first attachment means by having geometries and dimensions allowing said first end of said L-shaped element to be accommodated in the hollow interior of said longitudinally arranged beam of said frame at said first longitudinal end thereof. However, Roberts teaches: […] wherein said frame of said towing device comprises longitudinally arranged beams arranged at opposite sides thereof, and wherein said second attachment means comprises a hollow interior in each said beam at a first longitudinal end thereof; optionally wherein said wheel support comprises an L-shaped element having a first end and an opposite, second end, wherein said first end of said L-shaped element is forming said first attachment means by having geometries and dimensions allowing said first end of said L-shaped element to be accommodated in the hollow interior of said longitudinally arranged beam of said frame at said first longitudinal end thereof. See [Roberts, FIG. 9 and col 4, lines 14-21], which shows the support, with tire supports that slide into the hollow member at opposite sides, where the tire support is an L-shape, “Each end of sliding member 78 is pivotally connected to tire support 82 that engages tire 84 and prevents it from turning. ARROW 86 indicates how tire support 82 can pivot with respect to sliding members 78 with tire support 82 also being able to be locked in place as needed. Extending out the end of tire support 82 is adjustable tire brace 88 which, for storage purposes, can be removed from car support.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Roberts to include hollow beams with an L-shaped support that slides into the beam. Doing so allows the support to be removable for storage and adjustable [Roberts, col 4, lines 19-21], so that it can fit behind the tire [Roberts, col 4, lines 21-25]. Regarding Claim 29, Bryant as modified discloses the limitations of Claim 27. Bryant does not disclose: […] wherein said wheel support comprises a locking element for locking said first end of said L-shaped element into said hollow interior of said beam of said frame, However, Roberts teaches: […] wherein said wheel support comprises a locking element for locking said first end of said L-shaped element into said hollow interior of said beam of said frame, See again [Roberts, FIG. 9 and col 4, lines 14-21], which shows the support, with tire supports that slide into the hollow member at opposite sides, where the tire support is an L-shape and can be locked in place. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to further modify Nguyen with Roberts to allow the support to be locked in place. Doing so allows the support to be secured and prevent movement during use [Roberts, col 4, lies 28-30]. Claim 33 is rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, Johnstone, and Newhard, further in view of Tang. Regarding Claim 33, Bryant as modified discloses the limitations of Claim 31. Bryant does not explicitly disclose: […] wherein said control system is However, Tang teaches: […] wherein said control system is See again [Tang, pg. 3, para 0026], which explains that the AGV can be controlled wirelessly by a management system or operator. See also [Tang, pg. 5, paras 0046 and 0049], which explains the AGV includes processor which communicates and controls the lifting system actuator, “[0046] FIG. 7 is a block diagram of an AGV system 700 according to one embodiment of the present disclosure. The AGV system 700 includes a processor 702 that can be configured to perform various tasks or instructions described in this disclosure. […]. [0049] The processor 702 is further in communication with a lifting system 714, an inventory checking system 716, and an autonomous driving system 718. The lifting system 714 may include an actuator as discussed above for raising or lowering the inventory holder.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to further modify Nguyen with Tang to include controlling the actuator. Doing so automates the system and provides a safer and more controlled environment [Tang, pg. 1, para 0002]. Claim 34 is rejected under 35 U.S.C. 103 as being unpatentable over Bryant in view of Schutz, Jacobsen, and Johnstone, further in view of Warachka, CA-2595196-C (herein "Warachka"). Regarding Claim 34, Bryant as modified discloses the limitations of Claim 1. Bryant does not disclose: […] further comprising one or more auxiliary wheel assemblies, a lower side of said wheel suspension or or detachable wheel assembly using an attachment mechanism. However, Warachka teaches: […] further comprising one or more auxiliary wheel assemblies, a lower side of said wheel suspensionassembly or or detachable wheel assembly using an attachment mechanism. See [Warachka, pg. 20 , lines 7-15], which describes the auxiliary portions of the transporter, which include wheels that can be mounted to the frame at the base of the transporter, “Auxiliary frame members 62 are provided for telescoping insertion into the open ends of the tubes 14 of the base to support any of the wheel mounts 20 farther from the base in the 1 0 longitudinal direction if desired. […].” See also [Warachka, pg. 20, lines 16-25], which further explains the modular mounting configuration of the frame and wheels, “The arrangement of the wheels permits the caster wheels 56 to be readily interchanged with the fixed orientation wheels 58 having a fixed rolling direction once mounted, due to the stem 60 and the auxiliary frame members 62 being interchangeable with one another within the tubes 14 in telescoping mounting configuration.” See also [Warachka, pg. 21, lines 5-14], which explains that the wheels can be placed below the lift mechanism and can be made fully removable, “In some embodiments the frame may be fully supported on the wheels so that the implement supported on either the lift carriage or the uprights of the frame is fully supported by the wheels for rolling movement on the ground. […]. The wheel mounts 20 further permit the wheels to be completely removed from the base of the frame by simply removing locking pins or bolts through cooperating apertures in the telescoping members of the stem 60, auxiliary member 62 and the tubes 14.” Finaly see [Warachka, pg. 5, lines 3-7], which explains various wheel attachment options, “Some of the kits component units such as the wheel options both powered/unpowered main wheels and casters, booster beam, battery pack, electric 5 motors, reduction gearcases and controls, towbars, etc. in addition to use on the "Tultruk", can be easily detached at their often unique "Quikclamp" "Quiklatch" or "Quikpin" and used separately elsewhere on other alien machinery with compatible attachment interfaces,” and [Warachka, pg. 57, lines 6-8], which explains a universal wheel mount, “At least two removable caster wheels. Their insert tube universal mount allows them to be inserted at many sleeve tube locations on the implement carrier frame or on the wheel adapters.” It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to modify Nguyen with Warachka to include detachable auxiliary wheels. Doing so allows the system to be properly supported dependent on the configuration [Warachka, pg. 20, lines 16-25]. Further, it allows to the wheels to be configurable for the correct spacing and orientation [Warachka, pg. 21, lines 1-14] or type, such as casters [Warachka, pg. 57, lines 6-8]. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Nguyen, PG Pub US-2011/0038699-A1, discusses and adjustable height trailer with two lifting means for lifting the front or rear end of the trailer support surface, where one lifting means is a pivoting wheel for lowering the end of the trailer. 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 ERIN MARIE HARTMANN whose telephone number is (571)272-5309. The examiner can normally be reached M-F 7-5. 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, Kito Robinson can be reached at (571) 270-3921. 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. /E.M.H./Examiner, Art Unit 3664 /KITO R ROBINSON/Supervisory Patent Examiner, Art Unit 3664
Read full office action

Prosecution Timeline

May 08, 2024
Application Filed
Sep 25, 2025
Non-Final Rejection — §103, §112
Dec 30, 2025
Response Filed
Mar 05, 2026
Final Rejection — §103, §112 (current)

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

3-4
Expected OA Rounds
62%
Grant Probability
99%
With Interview (+50.0%)
3y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 8 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month