Prosecution Insights
Last updated: April 19, 2026
Application No. 18/782,857

AIRCRAFT SEATBACK TRAY TABLE MODULE

Non-Final OA §102§103
Filed
Jul 24, 2024
Examiner
ALEKSIC, NEVENA
Art Unit
3647
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
B/E Aerospace, Inc.
OA Round
1 (Non-Final)
74%
Grant Probability
Favorable
1-2
OA Rounds
2y 5m
To Grant
83%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allow Rate
78 granted / 105 resolved
+22.3% vs TC avg
Moderate +9% lift
Without
With
+9.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
24 currently pending
Career history
129
Total Applications
across all art units

Statute-Specific Performance

§101
1.3%
-38.7% vs TC avg
§103
49.4%
+9.4% vs TC avg
§102
23.2%
-16.8% vs TC avg
§112
24.9%
-15.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 105 resolved cases

Office Action

§102 §103
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 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. (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. Claim(s) 1, and 4-6 is/are rejected under 35 U.S.C. 102(a)(1)/102(a)(2) as being anticipated by Buchanan et al. (US 2019/0308538 A1), hereinafter Buchanan. Regarding claim 1, Buchanan discloses a modular seatback tray table module comprising: a modular body including a plurality of internal walls, wherein the plurality of internal walls at least partially defines an interior cavity (as shown in annotated fig. 1 below); a deployable tray table (main table 102, fig. 4) configured to actuate between at least one of a tray table stowed position (Para. [0036], “the tray table 100 is shown fully stowed in a near vertical orientation against the seat back within a recess defined in the seat back shroud.”; as shown in fig. 1) and a tray table deployed position (Para. [0039], “the table extension 108 is shown fully deployed, thus substantially doubling the surface area of the main table 102. The table extension 108 deploys from a stowed position below the main table 102 to a fully deployed position laterally-adjacent the main table 102”; as shown in fig. 4), wherein at least a portion of the interior cavity of the modular body is configured to receive at least a portion of the deployable tray table when the deployable tray table is in the tray table stowed position (as shown in fig. 1); and one or more tray table actuation members (as shown in annotated fig. 1 below) configured to couple to one or more mount points on the modular body (as shown in annotated fig. 1 below), wherein the one or more tray table actuation members are configured to actuate the deployable tray table between at least one of the tray table stowed position and the tray table deployed position (as shown in figs. 1 & 4). PNG media_image1.png 521 639 media_image1.png Greyscale Annotated fig. 1: annotated image of Buchanan’s fig. 4 Regarding claim 4, modified Buchanan discloses the invention in claim 1, and further discloses wherein the one or more tray table actuation members include one or more hinges (as shown in annotated fig. 2 below), wherein the deployable tray table is configured to actuate about a hinge axis between at least one of the tray table stowed position and the tray table deployed position (as shown in figs. 1-4). PNG media_image2.png 492 562 media_image2.png Greyscale Annotated fig. 2: annotated image of Buchanan’s fig. 5 Regarding claim 5, Buchanan discloses the invention in claim 1, and further discloses wherein the deployable tray table comprises: a primary surface (top of main table 102, fig. 4) and one or more auxiliary surfaces (top of table extension 108, fig. 4). Regarding claim 6, Buchanan discloses the invention in claim 5, and further discloses wherein the one or more auxiliary surfaces include one or more deployable extension members (table extension 108, fig. 4), wherein the one or more deployable extension members include one or more table actuators configured to couple the one or more deployable extension members to the primary surface (as shown in figs. 6-9, the table extension 108 [i.e., the deployable extension members] include a first and second elongate parallel guides 116 coupled to the table extension 108 to the main table 102). 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. Claim(s) 2, 3, and 20 is/are rejected under 35 U.S.C. 102(a)(1)/102(a)(2) as anticipated by or, in the alternative, under 35 U.S.C. 103 as obvious over Buchanan (US 2019/0308538 A1). Regarding claim 2, Buchanan discloses the invention in claim 1, and it is considered that Buchanan further discloses wherein the modular body of the modular seatback tray table module is configured to be mounted to a portion of a seatback of an aircraft seat (as shown in figs. 1-4, it appears to show a modular tray table module mounted to a portion of the seatback). However, in the interest of compact prosecution, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have a modular body configured to be mounted to a portion of a seatback, in order to securely attach it to the seatback, and provide easier maintenance, and rapid reconfiguration. Regarding claim 3, modified Buchanan discloses the invention in claim 2, and further discloses wherein the seatback of the aircraft seat includes a fixed seatback (see seatback in figs. 1-4). Regarding claim 20, Buchanan discloses an aircraft seat comprising: a seating section, the seating section including a seat pan and a seatback, wherein the seatback includes a fixed seatback (as shown in fig. 4, the tray table deploy from against a seatback of a passenger seat); and a modular seatback tray table module comprising: a modular body including a plurality of internal walls, wherein the plurality of internal walls at least partially defines an interior cavity (as shown in annotated fig. 1 above); a deployable tray table (main table 102, fig. 4) configured to actuate between at least one of a tray table stowed position (Para. [0036], “the tray table 100 is shown fully stowed in a near vertical orientation against the seat back within a recess defined in the seat back shroud.”; as shown in fig. 1) and a tray table deployed position (Para. [0039], “the table extension 108 is shown fully deployed, thus substantially doubling the surface area of the main table 102. The table extension 108 deploys from a stowed position below the main table 102 to a fully deployed position laterally-adjacent the main table 102”; as shown in fig. 4), wherein at least a portion of the interior cavity of the modular body is configured to receive at least a portion of the deployable tray table when the deployable tray table is in the tray table stowed position (as shown in fig. 1); and one or more tray table actuation members (as shown in annotated fig. 1 above) configured to couple to one or more mount points on the modular body (as shown in annotated fig. 1 above), wherein the one or more tray table actuation members are configured to actuate the deployable tray table between at least one of the tray table stowed position and the tray table deployed position (as shown in figs. 1 & 4). It is considered that the modular seatback tray table module disclosed by Buchanan is coupled to a rear surface of the fixed seatback (as shown in figs. 1-4, it appears to show a modular tray table module mounted to a portion of the seatback). However, in the interest of compact prosecution, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have a modular seatback tray table configured to be mounted to a portion of a seatback, in order to securely attach it to the seatback, and provide easier maintenance, and rapid reconfiguration. Claim(s) 7-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Buchanan as applied to claim 6 above, and further in view of Decker et al. (US 2018/0116391 A1). Regarding claim 7, Buchanan discloses the invention in claim 6, and further discloses a wide tray table surface (see table extension 108 and main table 102 in figs. 1-4), but does not appear to specifically disclose wherein the one or more deployable extension members are configured to actuate between at least one of a first position and a second position about a second axis of the one or more table actuators. However, Decker is in the field of a table for aircraft interiors (Abstract) and teaches one or more deployable extension members configured to actuate between at least one of a first position and a second position about a second axis (Para. [0019], “[t]he extension member 120 can be transformed into a fully-deployed mode (see FIG. 7) where opposing extension member flaps 126 and 128 are extended out in forward and aft directions, respectively. Top-mounted hinge sets 130 and 132 are arranged such that rotation occurs at the top of the edges at the interfaces between each flap (of extension flaps 126 and 128) and the extension member 120”; as shown in fig. 7). Examiner notes, as set forth above in claim 6, Buchanan discloses wherein the one or more deployable extension members include one or more table actuators. However, the table actuators of Buchanan are not configured to actuate between a second axis. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the table actuators of the extension member of modified Buchanan to be hinge sets 130 and 132 as taught by Decker, since hinge mechanisms ensure stability, to provide a more compact flush-mounted profile when folded, and as a known alternative manner of stowing or retracting a table surface. Regarding claim 8, Buchanan in view of Decker discloses the invention in claim 7, and further provides wherein the one or more deployable extension members includes at least a first extension member (table extension 108, fig. 4), but does not appear to specifically disclose wherein the one or more deployable extension members comprise a plurality of deployable extension members, wherein the plurality of deployable extension members includes at least a second extension member. However, Decker is in the field of a table for aircraft interiors (Abstract) and teaches wherein the one or more deployable extension members comprise a plurality of deployable extension members, wherein the plurality of deployable extension members includes at least a first extension member and a second extension member (extension member flaps 126 and 128, figs. 3-7). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of modified Buchanan such that in addition to the first extension member, there was a second extension member as taught by Decker, since it is a well-known alternative method of deploying tables for aircraft interiors. Furthermore, including a second extension member provides a user with adjustable usage since the table could be partially opened or fully opened as needed. Regarding claim 9, Buchanan in view of Decker discloses the invention in claim 8, and further discloses a first extension member and a second extension member (as modified above in claim 8), but is silent regarding a length of the first extension member and a length of the second extension member configured to cause a length of the wide tray table surface of the deployable tray table to be substantially proportional to a length of a seatback of an aircraft seat. However, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of modified Buchanan such that a length of the first extension member and a length of the second extension member were configured to cause a length of the wide tray table surface of the deployable tray table to be substantially proportional to a length of a seatback of an aircraft seat, in order to avoid obstructing the adjacent passenger seat, and also ensure that the extension member does not extend into the aisle. Claim(s) 10-13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Buchanan as applied to claim 1 above, and further in view of Pozzi et al. (US 2016/0355263 A1), hereinafter Pozzi. Regarding claim 10, Buchanan discloses the invention in claim 1, but does not appear to specifically disclose a personal electronic device support configured to actuate between at least one of a support stowed position and a support deployed position via one or more support actuators. However, Pozzi is in the field of an electronic device holder (Abstract) and teaches a personal electronic device support (shelf 28, fig. 3) configured to actuate between at least one of a support stowed position (fig. 2) and a support deployed position (fig. 3) via one or more support actuators (Para. [0047], “[t]he shelf 28 as shown is hinged along a bottom edge thereof to the frame 36 such that the top edge of the shelf 28 when released from the latch 30 is free to rotate outward and downward, i.e., away from the frame 36”; as shown in figs. 2 & 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of Buchanan such there was an electronic device support provided on the seatback as taught by Pozzi, in order to provide for a convenient, hands-free way of using electronic devices for ease of viewing. Regarding claim 11, Buchanan in view of Pozzi discloses the invention in claim 10, and Buchanan further discloses a modular body of the modular seatback tray table (as set forth above in claim 1), but does not appear to specifically disclose wherein the modular body of the modular seatback tray table module further comprises an indentation set within the modular body, wherein at least a portion of the indentation is configured to receive at least a portion of the personal electronic device support when the personal electronic device support is in the support stowed position, wherein the personal electronic device support sits substantially flush with a surface of the modular body of the modular seatback tray table module when in the support stowed position. However, Pozzi is in the field of an electronic device holder (Abstract) and teaches wherein the modular body of the modular seatback tray table module further comprises an indentation (as shown in figs. 2 & 3, the space occupied by the shelf 28 is the indentation) set within the modular body (as shown in fig. 9, the space that occupied by the shelf 28 [i.e., the indentation] is set within the upper seatback shroud 26), wherein at least a portion of the indentation is configured to receive at least a portion of the personal electronic device support when the personal electronic device support is in the support stowed position (as shown in fig. 2), wherein the personal electronic device support sits substantially flush with a surface of the modular body of the modular seatback tray table module when in the support stowed position (as shown in fig. 1, the portable electronic device holder sits substantially flush with a surface of the upper seatback shroud 26 when in the stowed position). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the modular body of Buchanan such that it has an electronic device holder which stows flush with the back of the seat as taught by Pozzi, in order to enhance passenger comfort without requiring them to hold devices. Furthermore, having the electronic device lie flush with the back of the seat would provide for a more aesthetic design since it would eliminate protruding hardware. Regarding claim 12, Buchanan in view of Pozzi discloses the invention in claim 10, and further provides wherein the personal electronic device support is configured to hold a personal electronic device when the personal electronic device support is in the support deployed position (Pozzi: see the electronic device 100 in fig. 3). Regarding claim 13, Buchanan in view of Pozzi discloses the invention in claim 12, and further provides wherein the personal electronic device includes at least one of a mobile phone or a tablet (Para. [0006], “[i]t is another object of the invention to provide a seatback holder for hands-free use of personal electronic devices such as smartphones and tablets”; as shown in fig. 3). Claim(s) 14 and 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Buchanan as applied to claim 1 above, and further in view of Bhat et al. (US 2018/0194477 A1), hereinafter Bhat. Regarding claim 14, Buchanan discloses the invention in claim 1, but does not appear to specifically disclose one or more tray table locks configured to stow the deployable tray table in the tray table stowed position. However, Bhat is in the filed of a table latch assembly (Abstract) and teaches one or more tray table locks configured to stow the deployable tray table in the tray table stowed position (latch assembly 110, figs. 1 & 2). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of Buchanan such that there was a tray table lock as taught by Bhat, since “[a] latch assembly can prevent a tray table from moving from a stowed position” (Bhat: Para. [0004]). Regarding claim 15, Buchanan in view of Bhat discloses the invention in claim 14, and Bhat further discloses wherein the one or more tray table locks comprise one or more slidable latches (Para. [0050], “[t]o deploy the tray table 104, the user can slide the one-motion latch 110 to an unlocked position, using the force in a single vertical direction, allowing the tray table 104 to rotate along the path from its stowed position to the deployed position”; as shown in fig. 3A). Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Buchanan as applied to claim 1 above, and further in view of Setele et al. (US 2026/0015085 A1), hereinafter Setele. Regarding claim 16, Buchanan discloses the invention in claim 1, but does not appear to specifically disclose wherein at least one of the modular body of the modular seatback tray table module or the deployable tray table includes one or more universal serial bus ports. However, Setele is in the field of a system for supplying electricity at a tray assembly for a passenger seat (Abstract) and teaches wherein the deployable tray table includes one or more universal serial bus ports (as shown in fig. 2A, tray table 240 includes a center bar 230 with a plurality of electrical outlets 232A, 232B, and 232C). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the tray table of Buchanan such that it includes a bus port as taught by Setele, since “implementing one or more power outlets and/or at least one wireless charging module with the tray assembly, a passenger may conveniently power an electronic device while sitting on a passenger seat” (Setele: Para. [0031]). Claim(s) 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Buchanan as applied to claim 1 above, and further in view of Quatmann et al. (US 2020/0094985 A1), hereinafter Quatmann. Regarding claim 17, Buchanan discloses the invention in claim 1, but does not appear to specifically disclose wherein at least one of the modular body of the modular seatback tray table module or the deployable tray table includes an information panel. However, Quatmann is in the field of an aircraft passenger seat having a textile display (Abstract) and teaches wherein at least one of the modular body of the modular seatback tray table module or the deployable tray table includes an information panel (second textile display 10b, fig. 2. Para. [0049], “[a]second textile display 10b may be used to provide more generic information, such as flight information, the obligation to fasten seatbelts, the occupation of a lavatory or the like”). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the modular body of the modular seatback tray table module of Buchanan such that it included an information panel as taught by Quatmann, “so that passengers sitting in such passenger seats are able to derive information displayed on the display devices.” (Quatmann: Para. [0002]). Claim(s) 18-19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Buchanan in view of Quatmann as applied to claim 17 above, and further in view of Ruiz et al. (US 2020/0002023 A1), hereinafter Ruiz. Regarding claim 18, Buchanan in view of Quatmann discloses the invention in claim 17, but does not appear to specifically disclose wherein the information panel includes a display screen configured to display one or more graphical icons. However, Ruiz is in the field of a passenger communication system (Abstract) and teaches a display screen configured to display one or more graphical icons (as shown in fig. 3B, display screen 10 is configured to display icons 203-206). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the display screen of modified Buchanan such that the information displayed on the display screen was presented as a graphical icon as taught by Ruiz, since icons are processed faster by the user than text, and further provide an enhanced aesthetic. Regarding claim 19, Buchanan in view of Quatmann and Ruiz discloses the invention in claim 18, but is silent regarding the one or more graphical icons include at least one of a fasten seatbelt icon, a no smoking icon, wireless fidelity, flight status, or seat location. Examiner notes, Quatmann discloses that the display screen can provide information such as the obligation to fasten seatbelts (Para. [0049]), and Ruiz discloses the use of graphical icons. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the invention of modified Buchanan such that the graphical icons include at least one of a fasten seatbelt icon, since there is a universal understanding of the fasten seatbelts icon. 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 NEVENA ALEKSIC whose telephone number is (571)272-1659. The examiner can normally be reached Monday-Thursday 8:30am-5:30pm ET. 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, Kimberly Berona can be reached at (571)272-6909. 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. /N.A./Examiner, Art Unit 3647 /Richard Green/Primary Examiner, Art Unit 3647
Read full office action

Prosecution Timeline

Jul 24, 2024
Application Filed
Feb 07, 2026
Non-Final Rejection — §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
74%
Grant Probability
83%
With Interview (+9.0%)
2y 5m
Median Time to Grant
Low
PTA Risk
Based on 105 resolved cases by this examiner. Grant probability derived from career allow rate.

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