Prosecution Insights
Last updated: April 19, 2026
Application No. 18/771,034

SYSTEMS FOR SUPPLYING ELECTRICITY AT A TRAY ASSEMBLY FOR A PASSENGER SEAT OF A TRANSPORTATION VEHICLE

Non-Final OA §102§103
Filed
Jul 12, 2024
Examiner
MILLER, WILLIAM L
Art Unit
3677
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Panasonic Avionics Corporation
OA Round
1 (Non-Final)
79%
Grant Probability
Favorable
1-2
OA Rounds
2y 2m
To Grant
93%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allow Rate
1362 granted / 1724 resolved
+27.0% vs TC avg
Moderate +14% lift
Without
With
+14.3%
Interview Lift
resolved cases with interview
Typical timeline
2y 2m
Avg Prosecution
36 currently pending
Career history
1760
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
27.4%
-12.6% vs TC avg
§102
29.3%
-10.7% vs TC avg
§112
35.6%
-4.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1724 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 . 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. Claims 1-3, 7-9, and 20 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Pajic (US#2016/0039525). Regarding claim 1, Pajic discloses a tray assembly for a passenger seat 128 for a transportation vehicle, comprising: a center bar 124 including at least one electrical outlet 208 (Fig. 2B); and a tray table 104 pivotably coupled to a first support arm 116 at a first corner of the tray table and pivotably coupled to a second support arm 116 at a second corner of the tray table, the tray table being pivotably coupled to the first support arm and the second support arm that are coupled to the passenger seat to pivotably move between a stow position (Fig. 1A) where the tray table is substantially parallel and anchored to a seatback of the passenger seat and an open position (Fig. 1B, service position) where the tray table is substantially parallel to a floor of the transportation vehicle and released away from the seatback, wherein the center bar is pivotably coupled to the tray table ([0060]) to be movable to a first position (Fig. 2B) where the at least one electrical outlet faces “substantially” upward with respect to the floor, when the tray table is in the open position, and to be movable to a second position (Fig. 1A) where the at least one electrical outlet face substantially downward with respect to the floor, when the tray table is in the stow position. Regarding claim 2, wherein the tray assembly further comprises a position detector component configured to detect whether the tray table is in the stow position or in the open position ([0091], switch and/or sensor(s)). Regarding claim 3, wherein the position detector component is configured to turn off electricity (disconnect battery 304) to the at least one electrical outlet in response to sensing that the tray table is in the stow position, and turn on electricity to the at least one electrical outlet in response to sensing that the tray table is in the open position ([0091]). Regarding claim 7, wherein the tray table includes at least one wireless charging module embedded within the tray table, the at least one wireless charging module configured to charge an electronic device 108 wirelessly when the electronic device is within a threshold distance from the at least one wireless charging module ([0062], lines 13-18). Regarding claim 8, wherein the at least one wireless charging module includes a first wireless charging module configured to wirelessly charge the electronic device when the electronic device is within the threshold distance from the first wireless charging module by contacting a first charging area on a top surface of the tray table, the top surface being a surface on a top side of the tray table with respect to the floor when the tray table is in the open position, and wherein a location of the first charging area corresponds to a location of the first wireless charging module embedded within the tray table ([0062], lines 13-18, “charged or powered by placing it on or near the tray table 104”). Regarding claim 9, as discussed previously with respect to claims 7 and 8, Pajic discloses wherein the tray table includes at least one wireless charging module embedded within the tray table, the at least one wireless charging module configured to charge an electronic device 108 wirelessly when the electronic device is within a threshold distance from the at least one wireless charging module ([0062], lines 13-18). Therefore, due to the minimal thickness of the tray table and the at least one wireless charging module embedded therein, the at least one wireless charging module is configured to, i.e. capable of, wirelessly charge the electronic device when the electronic device is within the threshold distance from the wireless charging module by contacting a charging area on either the top (“first charging area”, claim 8) or the bottom surface (“second charging area”, claim 9) of the tray table, the bottom surface being a surface on a bottom side of the tray table facing the floor when the tray table is in the open position, and wherein the tray assembly further comprises a device holding structure ([0075]) configured to hold the electronic device close to the second charging area to wirelessly charge the electronic device. Regarding claim 20, Pajic discloses a tray assembly for a passenger seat 128 for a transportation vehicle, comprising: a tray table 104 pivotably coupled to a first support arm 116 at a first corner of the tray table and pivotably coupled to a second support arm 116 at a second corner of the tray table, the tray table being pivotably coupled to the first support arm and the second support arm that are coupled to the passenger seat to pivotably move between a stow position (Fig. 1A) where the tray table is substantially parallel and anchored to a seatback of the passenger seat and an open position (Fig. 1B, service position) where the tray table is substantially parallel to a floor of the transportation vehicle and released away from the seatback, wherein the tray table includes at least one wireless charging module embedded within the tray table, the at least one wireless charging module configured to charge an electronic device wirelessly when the electronic device is within a threshold distance from the at least one wireless charging module ([0062], lines 13-18). 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. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Pajic (US#2016/0039525) in view of Mackin (US#2016/0250362). Regarding claim 4, Pajic fails to disclose a lighting device configured to illuminate a surrounding area of the tray assembly when activated, wherein the position detector component is configured to activate the lighting device in response to sensing that the tray table is in the stow position, and deactivate the lighting device in response to sensing that the tray table is in the open position. However, as evidenced by Mackin, such a configuration is known in the analogous art, see tray assembly 100 including UV lighting device 112 configured to illuminate and sanitize a surrounding area (e.g. top surface of the tray table 102) of the tray assembly when activated, wherein a position detector component 116 is configured to activate the lighting device in response to sensing that the tray table is in the stow position, and deactivate the lighting device in response to sensing that the tray table is in the open position ([0035]). Therefore, as evidenced by Mackin, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Pajic to include a UV lighting device configured to illuminate a surrounding area of the tray assembly (e.g. top surface of the tray table) when activated, wherein the position detector component is configured to activate the lighting device in response to sensing that the tray table is in the stow position, and deactivate the lighting device in response to sensing that the tray table is in the open position. The rational for supporting this conclusion of obviousness is the proposed combination is based upon combining prior art elements according to known methods to yield predictable results. Moreover, all the claimed elements are known in the prior art and one skilled in the art could combine the elements as claimed by known methods with no change in their respective functions, and the combination yield nothing more than predictable results to one of ordinary skill in the art (MPEP 2143 and KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007)). The inclusion of the UV lighting device configured to illuminate a surrounding area of the tray assembly (e.g. top surface of the tray table) when activated would provide sanitization of the tray table. Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Pajic (US#2016/0039525) in view of Stephens et al. (US#2018/0281967). Regarding claim 10, Pajic discloses the first support arm 116 coupled to a first side of the passenger seat 128; and the second support arm 116 spaced apart from the first support arm and coupled to a second side of the passenger seat 128. Although Pajic discloses a battery power supply 304 for the tray table, Pajic also admits to an alternative power supply option of wiring to the aircraft power system ([0084]). In any event, Stephens teaches a tray assembly wherein support arm 150 includes at least one power line (cabling) carrying electricity to supply electricity to the tray table 105 and its wireless charging module 110 ([0031]). Therefore, as taught by Stephens, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Pajic by replacing its power supply configuration such that the support arm(s) include(s) at least one power line (cabling) carrying electricity to supply electricity to the tray table and its wireless charging module. The rationale to support a conclusion that the claim would have been obvious is that the substitution of one known element for another yields predictable results to one of ordinary skill in the art (See MPEP 2143 and KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007)). The substitution of the support arm(s) including at least one power line (cabling) carrying electricity to supply electricity to the tray table and its wireless charging module would ensure availability of continuous and sufficient power thereto. Allowable Subject Matter Claims 5 and 6 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Claims 11-19 are allowed. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. See PTO-892. Any inquiry concerning this communication or earlier communications from the examiner should be directed to WILLIAM L MILLER whose telephone number is (571)272-7068. The examiner can normally be reached 9:30 - 6:00 PM. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Jason San can be reached at (571) 272-6531. 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. WILLIAM L. MILLER Primary Examiner Art Unit 3677 /WILLIAM L MILLER/Primary Examiner, Art Unit 3677
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Prosecution Timeline

Jul 12, 2024
Application Filed
Feb 10, 2026
Non-Final Rejection — §102, §103
Mar 25, 2026
Applicant Interview (Telephonic)
Mar 25, 2026
Examiner Interview Summary

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Prosecution Projections

1-2
Expected OA Rounds
79%
Grant Probability
93%
With Interview (+14.3%)
2y 2m
Median Time to Grant
Low
PTA Risk
Based on 1724 resolved cases by this examiner. Grant probability derived from career allow rate.

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