Prosecution Insights
Last updated: April 19, 2026
Application No. 18/758,798

PORTABLE AREA LIGHT

Final Rejection §102§103
Filed
Jun 28, 2024
Examiner
ENDO, JAMES M
Art Unit
2875
Tech Center
2800 — Semiconductors & Electrical Systems
Assignee
Milwaukee Electric Tool Corporation
OA Round
2 (Final)
65%
Grant Probability
Moderate
3-4
OA Rounds
2y 5m
To Grant
86%
With Interview

Examiner Intelligence

Grants 65% of resolved cases
65%
Career Allow Rate
250 granted / 385 resolved
-3.1% vs TC avg
Strong +21% interview lift
Without
With
+21.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
25 currently pending
Career history
410
Total Applications
across all art units

Statute-Specific Performance

§103
57.2%
+17.2% vs TC avg
§102
16.9%
-23.1% vs TC avg
§112
20.8%
-19.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 385 resolved cases

Office Action

§102 §103
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Response to Amendment Applicant’s amendment filed on 12/19/2025 has been entered. Claims 1-17 and 19-20 are pending in this application. Claim Rejections - 35 USC § 102 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 8-10 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by HARVEY (US 2016/0312967). Regarding claim 8, HARVEY discloses an area light configured to provide light to an active working area comprising a base (134, Fig.2) extending between a first end and a second end; a pair of legs (142, Fig.2) coupled to the first end (146, Fig.2) of the base for movement between an open configuration (Fig.2) and a stowed configuration (Fig.1); a mast (14, 42, 38, Fig.3) coupled to the first end of the base, the mast including a plurality of telescoping members (14, 42, 38, Fig.3) configured to extend and retract the mast along a mast axis (as seen in Fig.1, the telescoping members 14, 42, 38 were considered to retract the mast); and a light head (60, Figs.4-5) extending along a plane between a first head end coupled to the mast, and a second head end, wherein the light head includes a light source (para[0031]) configured to emit light in a light distribution pattern, wherein in the light distribution pattern all the light is distributed below the plane and more than 50% of the light is distributed within the active working area (as seen in Figs.4-5, since the light head 60 is rotatable, the light distribution pattern of the light head 60 was considered to be at least more than 50% within the desired active working area depending on the direction each light source of the light head 60 is rotated). Regarding claim 9, HARVEY further discloses wherein in the light distribution pattern more light is distributed past the second head end of the light head than past the first head end (as seen in Figs.4-5, since the light head 60 is rotatable, the light distribution pattern of the light head 60 would have more light distributed past the second head end of the light head than past the first head end). Regarding claim 10, HARVEY further discloses wherein in the light distribution pattern, more than 50% of the light is distributed in front of the light head, away from the mast (as seen in Figs.4-5, since the light head 60 is rotatable, the light distribution pattern of the light head 60 was considered to be at least more than 50% in front of the light head away from the mast depending on the direction each light source of the light head 60 is rotated). Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1-5 are rejected under 35 U.S.C. 103 as being unpatentable over CORNELL (US 2018/0149344), and in view of PROEBER (US 2019/0346122). Regarding claim 1, CORNELL discloses an area light, comprising a base (55, Fig.1) having a first end, a second end, and a top end and a bottom end extending between the first end and the second end; a pair of legs (60, Fig,1) rotatably coupled to the first end (180, Fig.2) of the base adjacent the bottom end (as seen in Figs.1-2, the legs 60 are generally rotatably coupled to the first end 180 of the base 55 adjacent the bottom end), wherein the pair of legs are coupled to sides of the base (as seen in Fig.1, the legs 60 are coupled to the sides 100 of the base 55), wherein the pair of legs are rotated towards the base when the area light is in a stowed configuration (as seen in Fig.2, the legs 60 are rotated towards the base 55 in a stowed configuration) and are rotated away from the base when the area light is in an open configuration (as seen in Fig.1, the legs 60 are rotated away from the base 55 in an open configuration); and a light body (65, Fig.1) having a mast (70, Fig.1) and a light head (75, Fig.1) coupled to the mast, the light body being rotatably coupled to the top end adjacent the first end of the base (as seen in Figs.1-2 and 15, the light body 65 is generally rotatably 270 coupled to the top end adjacent the first end of the base 55), wherein the light body is rotated towards the base when the area light is in the stowed configuration (as seen in Fig.2, the light body 65 is rotated towards the base 55 in the stowed configuration) and is rotated away from the base when the area light is in the open configuration (as seen in Fig.1, the light body 65 is rotated away from the base 55 in the open configuration); wherein in the stowed configuration the pair of legs extend toward the top end (as seen in Fig.2, as the legs 60 are rotated towards the stowed configuration, the legs 60 were considered to generally extend toward the top end of the base 55). CORNELL fails to disclose wherein the pair of legs are positioned closer to the bottom end than the top end. However, PROEBER discloses legs (182, Fig.3) are positioned closer to a bottom end than a top end of a base (as seen in Fig.3, when the legs 182 are deployed, the legs 182 are positioned closer to a bottom end than a top end of the base 10, 14, 46). Therefore, in view of PROEBER, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate legs positioned closer to the bottom end than the top end as taught by PROEBER to the legs of CORNELL in order to provide an alternative configuration for the legs to be in the stored configuration and the open configuration. Regarding claim 2, CORNELL further discloses wherein the mast (70, Fig.1) includes a plurality of telescoping members (285a, 285b, Fig.1) configured to extend and retract the mast along a mast axis, wherein each telescoping member of the plurality of telescoping members has an adjustment assembly (330, 335, Fig.1) configured to selectively lock (345, Fig.15) the telescoping member to an adjacent telescoping member, and wherein each telescoping member has a rectangular profile when viewed along the mast axis (as seen in Figs.1 and 15, the telescoping member 285a, 285b was considered to generally have rectangular profile). Regarding claim 3, CORNELL further discloses wherein the adjustment assembly includes a cuff (240, Fig.15) and a friction lever (as seen in Fig.15 and para[0048], a “friction lever” was considered to be the latch 345) rotatably coupled to the cuff between a locked position and an unlocked position, wherein in the locked position the adjustment assembly prevents the adjacent telescoping member from moving with respect to the adjustment assembly. Regarding claim 4, CORNELL further discloses wherein the mast extends along a mast axis between a first end and a second end, and wherein the light body further includes a handle (“handle” was interpreted to be a structure held by a hand; as seen in Fig.15, the “handle” was considered to be the sleeve 260 because a user grasps or holds the sleeve 260 by a hand and then rotating the light body 65) positioned adjacent the first end and extending generally parallel to the mast axis. Regarding claim 5, CORNELL further discloses wherein the base includes a pair of leg cradles (“cradle” was interpreted to be the space on the base receiving the legs; as seen in Figs.1-2, the “cradle” was considered to be the space 100 on the base 55 receiving the legs 60 in the stowed configuration), wherein each leg is rotatably coupled to the base adjacent an associated leg cradle (100, Figs.1-2), and wherein in the stowed configuration each of the pair of legs are received by the associated leg cradle and fit within a footprint of the base (Fig.2). Claims 6-7 are rejected under 35 U.S.C. 103 as being unpatentable over CORNELL (US 2018/90149344) modified by PROEBER (US 2019/0346122), and in view of ZHOU (US 2020/0191343). Regarding claim 6, CORNELL further discloses wherein each leg (60, Fig.1) includes a proximal end coupled to the associated leg cradle. CORNELL modified by PROEBER fails to disclose wherein each leg includes a distal end having a foot configured to engage a surface in the open configuration. However, ZHOU discloses a leg (434, Fig.15) includes a distal end having a foot (435, Fig.15) configured to engage a surface in an open configuration. Therefore, in view of ZHOU, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate a foot as taught by ZHOU to the legs of CORNELL modified by PROEBER in order to secure the leg to the surface. Regarding claim 7, CORNELL further discloses wherein in the stowed configuration the pair of legs are approximately parallel to each other (Fig.2), and wherein in the open configuration the pair of legs are angled with respect to each other such that a distance between each of the distal ends is greater than the distance between each of the proximal ends and the pair of legs create a wide base (Figs.1 and 9). Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over HARVEY (US 2016/0312967), and in view of PROEBER (US 2019/0346122). Regarding claim 11, HARVEY fails to explicitly discloses wherein the light head is positioned with the second head end directly above the base and more of the light of the light distribution pattern is distributed toward the second end of the base than toward the first end of the base. However, PROEBER discloses more of the light of the light distribution pattern is distributed toward the second end of a base than toward the first end of the base (the rightmost image of Fig.51). Therefore, in view of PROEBER, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate more of the light of the light distribution pattern is distributed toward the second end of a base than toward the first end of the base as taught by PROEBER to the light distribution pattern of HARVEY in order to direct the light towards the desired work area. Claims 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over HARVEY (US 2016/0312967), and in view of BIHONG (US 2020/0370716). Regarding claim 12, HARVEY fails to explicitly disclose a light driver module configured to control the light source, wherein the light driver module controls a brightness of the light source using analog current control. However, BIHONG discloses a light driver module (143, Fig.1) configured to control a light source (141 Fig.1), and the light driver module controls a brightness of the light source using analog current control (e.g. RC circuit; para[0035]). Therefore, in view of BIHONG, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate a light driver module as taught by BIHONG to the light source of HARVEY in order to control the light source. Regarding claim 13, HARVEY further discloses a user interface (354, Fig.18) configured to receive an input (370, 374, Fig.18) indicating a desired brightness and generate a brightness output associated with received input. Claims 14-16 are rejected under 35 U.S.C. 103 as being unpatentable over HARVEY (US 2016/0312967) modified by BIHONG (US 2020/0370716), and in view of LU (US 2015/0257227). Regarding claim 14, HARVEY modified by BIHONG as discussed above for claim 13 further disclose an analog control circuit (RC circuit; para[0035] of BIHONG). HARVEY modified by BIHONG fails to explicitly disclose to receive the brightness output; generate a brightness control signal based on the received brightness output; and provide the generated brightness control signal to the light driver module. However, LU discloses a circuit (112b, Fig.3) receives a brightness output, generates a brightness control signal based on the received brightness output; and provides the generated brightness control signal to a light driver module (112c, Fig.3). Therefore, in view of LU, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate a control signal as taught by LU to the user interface of HARVEY modified by BIHONG in order to control the light source. Regarding claim 15, HARVEY modified by BIHONG and LU as discussed above for claim 14 further discloses wherein the analog control circuit is an RC circuit (para[0035] of BIHONG). Regarding claim 16, HARVEY modified by BIHONG and LU as discussed above for claim 14 further discloses wherein the analog current control uses a DC current to control the brightness of the light source (para[0035] of BIHONG shows the analog current control and para[0029] of LU shows using DC current to control the brightness of the light source). Claims 17 and 19-20 are rejected under 35 U.S.C. 103 as being unpatentable over CORNELL (US 2018/0149344), and in view of SHARRAH (US 2015/0192243). Regarding claim 17, CORNELL discloses an area light comprising a base (55, Fig.1); a pair of legs (60, Fig.1) coupled to the base, wherein the legs are each positioned adjacent the base when the area light is in a stowed configuration (Fig.2) and the legs each extend away from the base when the area light is in an open configuration (Fig.1); a light body (65, Fig.1) having a mast (250, 70, Fig.1) and a light head (75, Fig.1) coupled to the mast, the light body being rotatably coupled to a top surface of the base (as seen in Figs.1-2 and 15, the light body 65 is generally rotatably 270 coupled to the top end adjacent the first end of the base 55), wherein the light body is rotated towards the base when the area light is in the stowed configuration (Fig.2) and is rotated away from the base when the area light is in the open configuration Fig.1); a latch assembly (265, Fig.15) configured to retain the light body in the open configuration. CORNELL fails to disclose a stop member that biases the mast toward the stowed configuration; wherein the stop member is a resilient pad positioned on the top surface of the base and engages a lower surface of the mast to bias the mast toward the stowed configuration; wherein in the open configuration the mast is secured between the stop member and the latch assembly to improve stability of the mast. However, SHARRAH discloses a stop member (80, 83, Fig.5D) biases a mast (40, Fig.5D) toward a stowed configuration (as seen in Fig.5D, the stop member 80, 83 was considered to exert a vertical force such that the stop member 80, 83 provides a degree of bias to the mast 40 toward the stowed configuration). Therefore, in view of SHARRAH, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate a stop member as taught by SHARRAH to the area light of CORNELL in order to aid in locking and biasing the mast. As a result, in the open configuration the mast would have been secured between the stop member and the latch assembly. Regarding “wherein the stop member is a resilient pad”, since SHARRAH shows the stop member as a resilient structure (e.g. spring), one of ordinary skill in the art would have recognize to substitute the type of resilient structure such as a resilient pad. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate a resilient pad to the stop member of CORNELL modified by SHARRAH in order to provide a type of resilient structure. Regarding “positioned on the top surface of the base and engages a lower surface of the mast to bias the mast toward the stowed configuration”, since CORNELL shows the mast is located on the top surface of the base, the resulting structure of CORNELL modified by SHARRAH was considered to suggest the stop member would have been positioned on the top surface of the base and would have engaged a lower surface of the mast. Regarding claim 19, CORNELL further discloses wherein the light body (65, Fig.15) rotates about a rotation axis and the latch assembly (260, 365, Fig.15) is spaced from the rotation axis, the latch assembly including a plunger (365, Fig.15) that selectively engages an opening (270a, Fig.15) in the mast (250, 70, Fig.15) to prevent rotation of the light body relative to the base (55, Fig.1), wherein the plunger is narrower than the opening and movable perpendicular to the rotation axis. Regarding claim 20, CORNELL modified by SHARRAH as discussed above for claim 19 further discloses wherein the stop member is coupled to the base and is spaced from the rotation axis (as seen in Fig.5D of SHARRAH, the stop member 80, 83 is coupled to a base (20, Fig.5D and is spaced from a rotation axis), wherein the stop member is configured to engage the mast to bias the mast toward the stowed configuration (as seen in Fig.5D of SHARRAH, the stop member 80, 83 was considered to exert a vertical force such that the stop member 80, 83 provides a degree of bias to the mast 40 toward the stowed configuration), and wherein the stop member biases the mast such that the plunger is held against a side of the opening (as a result of CORNELL modified by SHARRAH, the forced exerted by the stop member would have biased the mast such that the plunger is held against a side of the opening). Response to Arguments Applicant's arguments filed 12/19/2025 have been fully considered but they are not persuasive. Applicant has argued “Claim 8 recites "a light head extending along a plane between a first head end coupled to the mast, and a second head end, wherein the light head includes a light source configured to emit light in a light distribution pattern, wherein in the light distribution pattern all the light is distributed below the plane and more than 50% of the light is distributed within the active working area." The Examiner has alleged that Harvey discloses the claimed light distribution pattern because "since the light head 60 is rotatable, the light distribution pattern of the light head 60 was considered to be at least more than 50% within the desired active working area depending on the direction each light source of the light head 60 is rotated." Applicant respectfully disagrees. Claim 8 requires a light source that is "configured to emit light in a light distribution pattern" having specific characteristics-namely, that "all the light is distributed below the plane and more than 50% of the light is distributed within the active working area." This claim language requires the light source itself to be configured to produce this specific asymmetric distribution pattern, not merely that the light head can be rotated to various positions”. In response to applicant’s argument, first, the term “active working area” is not specifically defined in the claims. As a result, the term “active working area” was generally interpreted as an area to receive the light distribution pattern of the light head. In this case, the “active working area” was considered to be the surface the lighting device is on (i.e. below the light head). Second, the claim currently recites the functional limitation of the light head that allows for HARVEY to meet the claim language as opposed to further defining the structure of the claimed light head. For example: The claim fails to specifically recite the light head structured or oriented in a particular manner such that the light head preforms the claimed light distribution pattern. The claim currently merely recites the light head, and the light distribution pattern of the light head is distributed below the plane and more than 50% of the light is distributed within the active working area. As seen in Fig.5 of HARVEY, the light head has a light distribution pattern, and the light distribution pattern of the light head illuminates downward to the active working area or below the light head. The claim is suggested to incorporate additional structural limitations to further define the light head. However, it is noted that a downward directed light distribution pattern is a typical configuration for light heads of similar lighting devices and applications. In this case, the claim is suggested to incorporate a combination of additional structural limitations to differentiate the applicant’s invention from the prior art of record. Therefore, the references disclose the limitations as currently claimed. Applicant has argued “Claim 17, as amended, recites, inter alia, "a stop member that biases the mast toward the stowed configuration, wherein the stop member is a resilient pad positioned on the top surface of the base and engages a lower surface of the mast to bias the mast toward the stowed configuration." The Examiner has alleged that Sharrah discloses a stop member (80, 83) that biases a mast toward a stowed configuration. See Office Action, page 10. However, Applicant respectfully submits that Sharrah's stop member is fundamentally different from the claimed resilient pad. Sharrah describes elements 80 and 83 as components of a latch assembly. Specifically, Sharrah discloses that "latch plate 82 moves upward under the urging of spring 83 to engage ridge 52r." Sharrah, paragraph [0057]. Thus, Sharrah's stop member (80, 83) is a spring that is an integral component of the latch assembly, functioning to bias a latch plate into engagement with a pole base. This is structurally and functionally different from the claimed "resilient pad positioned on the top surface of the base" that "engages a lower surface of the mast to bias the mast toward the stowed configuration." Applicant submits that the combination of Cornell and Sharrah fails to teach the specific structural arrangement recited in amended claim 17. The claimed stop member is a resilient pad-not a spring-that is positioned on the top surface of the base and engages a lower surface of the mast. Sharrah's spring 83 does not engage a lower surface of the mast; rather, it biases a latch plate. Furthermore, Cornell teaches legs positioned closer to the top end than the bottom end, which is the opposite of the configuration in the present application where the stop member and resilient pad arrangement work in conjunction with legs positioned closer to the bottom end”. In response to applicant’s argument, regarding “the stop member is a resilient pad”, it is noted that the applicant has not explicitly argued against why one of ordinary in the skill in art would not have substituted the spring of SHARRAH with a resilient pad as an alternative resilient structure as indicated in the Office Action. The term “resilient” was interpreted to be a structure able to recoil or spring back into shape after deformation. SHARRAH was considered to disclose the stop member as a spring for biasing the mast, where the spring is a resilient structure. As of now, it is still considered well within one of ordinary skill in the art to substitute one type of resilient structure with another type of resilient structure such as a resilient pad. Regarding “positioned on the top surface of the base”, as seen in Fig.5B of CORNELL, the base was considered to have different sections where the upper section 22u has a top surface, and the latch section 80 was considered to have a top surface 82. As a result, based on the discussion above, the resilient structure or resilient pad was considered to be generally positioned on the top surface of the base (or the top surface of this section of the base) and engages with the mast. Since the concept of biasing the mast with a resilient pad was considered to be generally shown in the prior art, the claim is suggested to incorporate a combination of additional structural limitations to differentiate the applicant’s invention from the prior art of record. Therefore, the references disclose the limitations as currently claimed. Conclusion Regarding claims 1-7, Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. The legs have been further defined and amended in the claims. Regarding claims 8-17 and 19-20, the applicant’s arguments regarding the references have been addressed. 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAMES ENDO whose telephone number is (571)272-2782. The examiner can normally be reached Monday and Thursday 9AM-5PM. 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, JONG-SUK LEE can be reached at 571-272-7044. 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. /J.M.E/Examiner, Art Unit 2875 /JONG-SUK (JAMES) LEE/Supervisory Patent Examiner, Art Unit 2875
Read full office action

Prosecution Timeline

Jun 28, 2024
Application Filed
Sep 16, 2025
Non-Final Rejection — §102, §103
Dec 19, 2025
Response Filed
Mar 21, 2026
Final Rejection — §102, §103 (current)

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Prosecution Projections

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Expected OA Rounds
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Grant Probability
86%
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2y 5m
Median Time to Grant
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