Prosecution Insights
Last updated: July 17, 2026
Application No. 18/771,034

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

Final Rejection §102§103
Filed
Jul 12, 2024
Examiner
MILLER, WILLIAM L
Art Unit
3677
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Panasonic Holdings Corporation
OA Round
2 (Final)
79%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
94%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allowance Rate
1381 granted / 1749 resolved
+27.0% vs TC avg
Moderate +15% lift
Without
With
+14.7%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 0m
Avg Prosecution
30 currently pending
Career history
1771
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
36.5%
-3.5% vs TC avg
§102
14.0%
-26.0% vs TC avg
§112
46.6%
+6.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1749 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. Claim 20 is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Pajic (US#2016/0039525). 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 further includes: at least one wireless charging module 124 configured to wirelessly charge an electronic device 108 when the electronic device is within a threshold distance from the at least one wireless charging module ([0062], lines 13-18, “It is noted that the tray table 104 may be configured to inductively or otherwise wirelessly charge the electronic device 108 in some embodiments. Therefore, the electronic device 108 may be charged or powered by placing it on or near the tray table 104, or in the inner tray 124.”). The inner tray 124 rotates in an opening 112 which extends through both a top surface and bottom surface of the tray table 104, such that the inner tray extends to both the top and bottom surfaces of the tray table and thus creates the following: a first charging area on the top surface of the tray table (see Fig. 1B orientation), 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, a location of the first charging area corresponding to a location of the at least one wireless charging module, and a second charging area on the bottom surface 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 (see Fig. 1A orientation), a location of the second charging area corresponding to a location of the at least one wireless charging module; and a device holding structure configured to hold the electronic device to face the bottom surface of the tray table (see Fig. 1A orientation) and close to the second charging area on the bottom surface within the threshold distance to wirelessly charge the electronic device ([0075], “It is noted that the electronic device 108 may be removably secured to the inner tray 124 in various ways. For example, the electronic device 108 and inner tray 124 may comprise coupling or mating fasteners, which releasably hold the electronic device to the inner tray. Alternatively or in addition, the electronic device 108 may be removably secured to the inner tray 124 by a friction fit or magnets.”). 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 21 is rejected under 35 U.S.C. 103 as being unpatentable over Pajic (US#2016/0039525). Regarding claim 21, Pajic discloses one inner tray 124 and thus one wireless charging module capable of charging the electronic device 108 at the top or bottom surface of the tray table 104 as discussed above in detail with respect to claim 20. Pajic fails to disclose a second wireless charging module different from the first wireless charging module and configured to wirelessly charge the electronic device when the electronic device is within the threshold distance from the second wireless charging module by contacting the second charging area on the bottom surface of the tray table. However, it would have been an obvious design consideration to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Pajic by including a second opening 112 in the tray table 104 receiving a second inner tray 24 (i.e. second charging module) as duplicating the components of a prior art device is a design consideration within the skill of the art. In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960). The inclusion of the second opening in the tray table and the second inner tray (second charging module) would allow for charging multiple devices simultaneously. The addition of the second inner tray (second charging module) would provide the claimed two distinct wireless charging modules, each capable of being at the top or bottom surface of the tray table. Allowable Subject Matter Claims 1 and 3-19 are allowed. The following is a statement of reasons for the indication of allowable subject matter: Regarding claim 1, the applicant’s arguments are accurate and persuasive. Claim 1 was amended to include the previously indicated allowable subject matter of objected claim 6. Pajic (US#2016/0039525) fails to disclose or suggest wherein the at least one electrical outlet 208 (Fig. 2B) is accessible with the tray table in the stow position (Fig. 1A). Regarding claim 11, the inner tray element 124 of Pajic (US#2016/0039525) can be viewed as a power supply bar attached to and movable with the tray table 104 and including an electrical outlet 208 (Fig. 2B). However, Pajic and the remaining prior art of record fails to disclose or suggest the collective following: a power supply bar including at least one first-surface electrical outlet at a first surface of the power supply bar and at least one second-surface electrical outlet at a second surface of the power supply bar different from the first surface; wherein the power supply bar is attached to the tray table to move with the tray table and is positioned to have the at least one first-surface electrical outlet face substantially upward with respect to the floor and away from the passenger seat when the tray table is in the open position, and wherein the power supply bar is positioned to have the at least one second-surface electrical outlet face substantially upward with respect to the floor and away from the passenger seat when the tray table is in the stow position. Response to Arguments Regarding claim 1 and Pajic (US#2016/0039525), and as previously stated above, the applicant's arguments are accurate and persuasive. Regarding claim 20, the applicant’s arguments with respect to Pajic (US#2016/0039525) are not persuasive. Fig. 1A of Pajic clearly shows the electronic device 108 secured to the inner tray 124, and thus charging, when the tray table 104 is in the stow position. As discussed above, the inner tray 124 rotates in an opening 112 which extends through both a top surface and bottom surface of the tray table 104, such that the inner tray extends to both the top and bottom surfaces of the tray table and thus creates the following: a first charging area on the top surface of the tray table (see Fig. 1B orientation), 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, a location of the first charging area corresponding to a location of the at least one wireless charging module, and a second charging area on the bottom surface 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 (see Fig. 1A orientation), a location of the second charging area corresponding to a location of the at least one wireless charging module; and a device holding structure configured to hold the electronic device to face the bottom surface of the tray table (see Fig. 1A orientation) and close to the second charging area on the bottom surface within the threshold distance to wirelessly charge the electronic device ([0075], “It is noted that the electronic device 108 may be removably secured to the inner tray 124 in various ways. For example, the electronic device 108 and inner tray 124 may comprise coupling or mating fasteners, which releasably hold the electronic device to the inner tray. Alternatively or in addition, the electronic device 108 may be removably secured to the inner tray 124 by a friction fit or magnets.”). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. See PTO-892. It is noted Schultheis (US# 2014/0167457) discloses multiple wired charging modules 12 on a top surface 16 of the tray table 10 (Fig. 1). 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 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
Read full office action

Prosecution Timeline

Jul 12, 2024
Application Filed
Feb 12, 2026
Non-Final Rejection mailed — §102, §103
Mar 25, 2026
Applicant Interview (Telephonic)
Mar 25, 2026
Examiner Interview Summary
Apr 22, 2026
Response Filed
May 29, 2026
Final Rejection mailed — §102, §103
Jul 14, 2026
Response after Non-Final Action

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

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Prosecution Projections

3-4
Expected OA Rounds
79%
Grant Probability
94%
With Interview (+14.7%)
2y 0m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 1749 resolved cases by this examiner. Grant probability derived from career allowance rate.

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