Prosecution Insights
Last updated: April 18, 2026
Application No. 18/755,989

Vehicle Seat Recliner Mechanism With Encapsulating Ring

Non-Final OA §102§103
Filed
Jun 27, 2024
Examiner
NELSON JR, MILTON
Art Unit
3636
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Fisher & Company Incorporated
OA Round
1 (Non-Final)
85%
Grant Probability
Favorable
1-2
OA Rounds
2y 2m
To Grant
90%
With Interview

Examiner Intelligence

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

Statute-Specific Performance

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

Office Action

§102 §103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Election/Restrictions Applicant’s election without traverse of Invention I, Claims 1-16, drawn to a recliner heart, in the response filed March 12, 2026 is acknowledged. Non-elected claims 17-20 have been withdrawn from further consideration. Information Disclosure Statement Applicant has filed 10 separate Information Disclosure Statement with at least 676 citations, including nearly 300 foreign language and non-patent literature documents. The volume of citations appears excessive and is overwhelming to the examination process. While the Office wants Applicants to file relevant documents that they become aware of, the filing of an IDS which blindly lists documents without apparent thought to what relevance may or may not exist to the claims of the instant application does not assist in examination and raises the question if there is intent to bury a relevant reference. Cloaking of a clearly relevant reference by inclusion in a long list of citations may not comply with the Applicant’s duty to disclose. Examples of cited documents that appear to lack relevancy to the current application are as follows: FR73767, directed to decking and net scaffolding. JP2000084684, directed to energy beam welding. DE102017100374 directed to an oil bypass valve. DE907608 directed to the heat value of a spark plug. DE1098292 directed to a method of exposing the center electrode of a spark plug. Also, numerous duplicate copies of foreign language documents have been filed. Examples are CN102442228, KR100817000, DE112014000343, and KR101420164. The information referred to in the IDS filed December 19, 2025 has been considered. The information referred to in the IDS filed October 7, 2025 has been considered except as noted. Non-Patent Literature Documents Cite Nos. 2, 11, 12 and 14 have not been considered as these foreign language documents lack a translation or statement as relevancy. Non-Patent Literature Documents Cite No. 9 has not been considered as a copy of this documents has not been included. The information referred to in the IDS filed September 30, 2025 has been considered. The information referred to in the IDS filed September 16, 2025 has been considered. The information referred to in the IDS filed June 2, 2025 has been considered. The information referred to in the IDS filed April 23, 2025 has been considered. The information referred to in the IDS filed March 14, 2025 has been considered. The information referred to in the IDS filed August 22, 2024 has been considered. The information referred to in the 8 page IDS filed July 2, 2024 has been considered except where noted. Foreign Patent Document Cite No. 17 has not been considered, as no copy is provided. Non-Patent Literature Document Cite No. 2 has not been considered, as no copy is provided. The information referred to in the 38 page IDS filed July 2, 2024 has been considered except where noted. Foreign Patent Document Cite Nos. 1 and 3 have not been considered, as copies have not been provided. Foreign Patent Document Cite No. 37 has not been considered as no translation or statement of relevancy has been provided. Non-Patent Literature Document Cite No. 17 has not been considered, as the listed date is inconsistent with the cited document. Non-Patent Literature Document Cite Nos. 22 and 49 have not been considered, as copies are not provided. Non-Patent Literature Document Cite Nos. 31 and 50 have not been considered, as no translation is provided although the documents are foreign language documents. Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claim(s) 1-5, 9 and 10 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Enokijima et al (US20150091354). Note a recliner heart comprising: a first locking plate (20) including an outer diametrical surface having first teeth formed thereon; a second locking plate (10) rotatable relative to the first locking plate and including an inner diametrical surface having second teeth formed thereon, wherein some of the second teeth are meshingly engaged with some of the first teeth; a hub (5R) extending through the first and second locking plates; an encapsulating ring (70) extending annularly about the first and second locking plates and not pressed (welded, wherein pressing is an option; see ¶ 0061) into the first locking plate; and a spacer ring (50) disposed axially between the second locking plate and the encapsulating ring and radially between the hub and the encapsulating ring. Regarding claim 2, note the spacer ring has a central aperture extending through the spacer ring and a body extending annularly about the central aperture. Note the opening withing the periphery as shown in Figure 5. Regarding claim 3, note the body (see Figure 5) has a thickness measured between a first surface and a second surface of the spacer ring, wherein the thickness is uniform along the body. Note the diameter of the rod forming the body. Regarding claim 4, note the first surface of the spacer ring is positioned adjacent to a lip of the encapsulating ring and the second surface of the spacer ring is positioned adjacent to a rim of the second locking plate. See Figure 7. Regarding claim 5, note the second surface of the spacer ring is spaced from the rim of the second locking plate. Note the outer surface adjacent the leader line for “50”, as shown in Figure 7. Regarding claim 9, note the first locking plate has a rim that is positioned radially outwardly from the first teeth and extends annularly about the first teeth. In Figure 5, note between the teeth and the perimeter edge. Regarding claim 10, note the rim of the first locking plate has an outer radial surface that is spaced from an inner radial surface of the encapsulating ring. In Figure 7, note the surface adjacent to the leader line for “72”. Claim(s) 11-16 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Enokijima et al (US20150091354). Note a recliner heart comprising: a first locking plate (20); a second locking plate (10) rotatable relative to the first locking plate; a hub (5R) extending through the first locking plate and configured to rotate to position the recliner heart in a locked state and in an unlocked state; an encapsulating ring (70) extending annularly about the first and second locking plates and not pressed (welded, wherein pressing is an option; see ¶ 0061) into the first locking plate; and a spacer ring (50) disposed axially between the second locking plate and the encapsulating ring and radially between the hub and the encapsulating ring. Regarding claim 12, note the spacer ring is positioned adjacent to the encapsulating ring and spaced from a rim of the second locking plate. See Figure 7. Regarding claim 13, note the encapsulating ring includes a body and a lip (72) that extends radially inwardly from one end of the body. Regarding claim 14, note the body of the encapsulating ring has an inner radial surface (note adjacent to the leader line “73” in Figure 7) that is spaced from an outer radial surface of the first locking plate. Regarding claim 15, note the first locking plate has a rim that is positioned radially outwardly from the second locking plate. See Figure 7. Regarding claim 16, note the rim of the first locking plate has an outer radial surface that is spaced from an inner radial surface of the encapsulating ring. See Figure 7. 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. Claim(s) 1-10 is/are rejected under 35 U.S.C. 103 as being unpatentable over DE102006044490B4 in view of over Enokijima et al (US20150091354). The primary reference shows all claimed features of the instant invention with the exception of the encapsulating ring not pressed into the first locking plate. In the primary reference, note a recliner heart comprising: a first locking plate (12) including an outer diametrical surface having first teeth formed thereon; a second locking plate (11) rotatable relative to the first locking plate and including an inner diametrical surface having second teeth formed thereon, wherein some of the second teeth are meshingly engaged with some of the first teeth; a hub (7) extending through the first and second locking plates; an encapsulating ring (51) extending annularly about the first and second locking plates and pressed and welded into the first locking plate; and a spacer ring (53) disposed axially between the second locking plate and the encapsulating ring and radially between the hub and the encapsulating ring. Regarding claim 2, note the spacer ring has a central aperture extending through the spacer ring and a body extending annularly about the central aperture. Note the opening withing the periphery as shown in Figure 5. Regarding claim 3, note the body has a thickness measured between a first surface (outer surface) and a second surface (opposite outer surface) of the spacer ring, wherein the thickness is uniform along the body. See Figure 1. Regarding claim 4, note the first surface of the spacer ring is positioned adjacent to a lip of the encapsulating ring and the second surface of the spacer ring is positioned adjacent to a rim of the second locking plate. See Figure 1. Regarding claim 5, note the second surface of the spacer ring is spaced from the rim of the second locking plate. See Figure 1. Regarding claim 6, note the encapsulating ring includes a body that includes a first end and a second end, a lip (note the portion adjacent to the leader lines for “53”, as shown in Figure 1) that extends radially inwardly form the first end of the body, and a flange (in Figure 5, note the unlabeled extension in the gap of 51) that extends radially outwardly from the second end of the body. Regarding claim 7, note the lip of the encapsulating ring abuts the spacer ring. See Figure 1. Regarding claim 8, note the body of the encapsulating ring has an inner radial surface that is spaced from an outer radial surface of the first locking plate. In Figure 1, note the inner surface of 53 that extends away from 21. Regarding claim 9, note the first locking plate has a rim that is positioned radially outwardly from the first teeth and extends annularly about the first teeth. In Figure 5, note between the teeth and the perimeter edge. Regarding claim 10, note the rim of the first locking plate has an outer radial surface that is spaced from an inner radial surface of the encapsulating ring. In Figure 7, note the surface adjacent to the leader line for “72”. The secondary reference teaches configuring a recliner heart with an encapsulating ring extending annularly about first and second locking plates and not pressed into the first locking plate. Note as described in the rejection above, based on Enokijima et al. It would have been obvious to one having ordinary skill in the pertinent art before the effective filing date of the instant invention to modify the primary reference in view of the teachings of the secondary reference by replacing press fitting and welding with just welding between the encapsulating ring and the first locking plate. This modification provides an alternate, equivalent engagement type between the encapsulating ring and the first locking plate. This modification is representative of simple substitution of one known element for another to obtain predictable results. Claim(s) 6 and 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Enokijima et al (US20150091354) in view of Poptani et al (US11052797). The primary reference shows all claimed features of the instant invention with the exception of encapsulating ring body having a flange that extends radially outwardly from the second end of the body. In the primary reference, note the encapsulating ring has a body that includes a first end (a peripheral end) and a second end (an opposite side peripheral end), a lip (72) that extends radially inwardly from the first end of the body. Regarding claim 8, note the body of the encapsulating ring has an inner radial surface (note adjacent to the leader line for “73” as shown in Figure 7) that is spaced from an outer radial surface of the first locking plate. The secondary reference teaches configuring an encapsulating ring (27) as having a flange that extends radially outwardly from a second end of the body of encapsulating ring. See Figure 3. It would have been obvious to one having ordinary skill in the pertinent art before the effective filing date of the instant invention to modify the primary reference in view of the teachings of the secondary reference by adding a flange as extending radially outwardly from the second end of the encapsulating ring body. This modification provides structure to help reduce debris entry into the recliner heart, thereby improving assembly durability and reliability. Claim(s) 11-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over DE102006044490B4 in view of over Enokijima et al (US20150091354). The primary reference shows all claimed features of the instant invention with the exception of the encapsulating ring not pressed into the first locking plate. Note a recliner heart comprising: a first locking plate (12); a second locking plate (11) rotatable relative to the first locking plate; a hub (7) extending through the first locking plate and configured to rotate to position the recliner heart in a locked state and in an unlocked state; an encapsulating ring (51) extending annularly about the first and second locking plates and pressed and welded into the first locking plate; and a spacer ring (53) disposed axially between the second locking plate and the encapsulating ring and radially between the hub and the encapsulating ring. Regarding claim 12, note the spacer ring is positioned adjacent to the encapsulating ring and spaced from a rim of the second locking plate. See Figure 1. Regarding claim 13, note the encapsulating ring includes a body and a lip (note the portion adjacent to the leader line for “53” in Figure 1) that extends radially inwardly from one end of the body. Regarding claim 14, note the body of the encapsulating ring has an inner radial surface that is spaced from an outer radial surface of the first locking plate. See Figure 1. Regarding claim 15, note the first locking plate has a rim that is positioned radially outwardly from the second locking plate. See Figure 1. Regarding claim 16, note the rim of the first locking plate has an outer radial surface that is spaced from an inner radial surface of the encapsulating ring. See Figure 1. The secondary reference teaches configuring a recliner heart with an encapsulating ring extending annularly about first and second locking plates and not pressed into the first locking plate. Note as described in the rejection above, based on Enokijima et al. It would have been obvious to one having ordinary skill in the pertinent art before the effective filing date of the instant invention to modify the primary reference in view of the teachings of the secondary reference by replacing press fitting and welding with just welding between the encapsulating ring and the first locking plate. This modification provides an alternate, equivalent engagement type between the encapsulating ring and the first locking plate. This modification is representative of simple substitution of one known element for another to obtain predictable results. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MILTON NELSON JR whose telephone number is (571)272-6861. The examiner can normally be reached M-F 5:30am-1:30pm. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. mn /MILTON NELSON JR/March 27, 2026 Primary Examiner, Art Unit 3636
Read full office action

Prosecution Timeline

Jun 27, 2024
Application Filed
Apr 02, 2026
Non-Final Rejection — §102, §103 (current)

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

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Prosecution Projections

1-2
Expected OA Rounds
85%
Grant Probability
90%
With Interview (+5.7%)
2y 2m
Median Time to Grant
Low
PTA Risk
Based on 1839 resolved cases by this examiner. Grant probability derived from career allow rate.

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