Prosecution Insights
Last updated: October 02, 2026
Application No. 18/790,202

Pressure washer

Final Rejection §102§103
Filed
Jul 31, 2024
Priority
Aug 02, 2023 — EU 23189259.7
Examiner
LEE, KEVIN G
Art Unit
1711
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Andreas Stihl AG & Co. KG
OA Round
2 (Final)
64%
Grant Probability
Moderate
3-4
OA Rounds
1y 0m
Est. Remaining
91%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allowance Rate
380 granted / 593 resolved
-0.9% vs TC avg
Strong +27% interview lift
Without
With
+27.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
25 currently pending
Career history
640
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
55.3%
+15.3% vs TC avg
§102
18.7%
-21.3% vs TC avg
§112
22.0%
-18.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 593 resolved cases

Office Action

§102 §103
DETAILED CORRESPONDENCE Acknowledgements This office action is in response to the application filed 5/14/2026. Claims 1-20 and 22-23 are pending and have been examined. 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 § 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 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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. Claims 1-20 and 22-23 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by, and/or in the alternate, rejected under 35 U.S.C 103 as being obvious over Tracey et al. (US 2005/0011968 A1) Tracey discloses a pressure washer (title, abstract) comprising: high-pressure pump (see fig. 3A ref. 330 ¶ [0070] fluid control device 330 is a pressure generator or pump) by which cleaning fluid can be pressurized in the pressure washer ; a hose reel (ref. 200), which is mounted so that it can rotate about an axis of rotation (see fig. 3A); a reel hose (ref. 50), which can be wound onto and unwound from the hose reel (¶ [0062]); and a housing (ref. 338), wherein the high-pressure pump is arranged in the housing (¶ [0069]), wherein the high-pressure pump comprises at least one piston (¶ [0070] fluid control device 330…reciprocating pump (e.g. single piston pump or a radial piston pump), which can be moved back and forth in a direction of movement to generate pressure on the cleaning fluid, wherein the high-pressure pump has a middle axis running in the direction of movement of the at least one piston (see fig. 3A and/or fig. 4A showing at least two orientations of the pump within fluid control device 330, with respect to the hose reel. Here, a radial piston pump is expected to have plural pistons extending in multiple angles with respect to flow including parallel to fluid flow, such to make it prima facie obvious to arrange at least one piston vertical in Fig. 3A, thus transverse to the hose reel. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Here, a single/axial pump would similarly be obvious to orient in the longitudinal length of the fluid control device 330 in order to provide compact construction, i.e. piston travel length over longest dimension of the container. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Alternatively, even if assuming the piston in Fig. 3A is not transverse, Figs. 3A and 4A show 90 degree rotational difference of the fluid control device 330, such that at least one of the two orientations is expected to include at least one piston transverse to the hoes reel. See MPEP 2144.04(VI)(C) Rearrangement of Parts. PNG media_image1.png 820 692 media_image1.png Greyscale ), wherein the cleaning fluid can be conveyed to the reel hose by the high-pressure pump during operation of the pressure washer (¶ [0069]-[0070]), wherein the axis of rotation (see fig. 3A horizontally through hose reel 220) runs transversely to the direction of movement of the at least one piston (vertically), and wherein the axis of rotation intersects the high-pressure pump (see fig. 3A). Re claim 2, wherein the axis of rotation of the hose reel intersects the middle axis of the high-pressure pump (see fig. 3A horizontal axis of hose reel expected to intersect with the vertical axis of the pump 330; Examiner noting that as shown in Fig. 2A the components can be in the same housing 212 such to be prima facie obvious to arrange the hose reel and the high-pressure pump in a line. Moreover, it being simply an obvious rearrangement of parts for purposes of maximizing space utilization. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Re claim 3, wherein the axis of rotation of the hose reel and the middle axis of the high-pressure pump are oriented perpendicularly relative to one another (see fig. 3A horizontal and vertical). Re claims 4-6, regarding “wherein the hose reel (20) has a reel spacing (a) from the middle axis (48) measured in the direction of the axis of rotation (50) of the hose reel (20), wherein the pressure washer (1) has a maximum width (b) measured in the direction of the axis of rotation (50), and wherein the reel spacing (a) is at most 50% of the maximum width (b)”, “wherein the hose reel (20) has a reel width (c) measured in the direction of the axis of rotation (50), and wherein the reel spacing (a) is at most 70% of the reel width (c).” and “wherein a reel width (c) is at most 60% of the maximum width (b) of the pressure washer (1).”. The mere change in size/dimensions of the reel width and/or overall pressure washer width is simply an obvious engineering design choice based on the size/length of hose and size of pump, balanced with decreasing cost of construction of the overall housing. Here, there being no patentable feature in adjusting the overall size of the pressure washer to achieve the % widths, as claimed. See MPEP 2144.04(IV)(A) Changes in Size/Proportion. Re claims 7-9 and 11-13, Regarding “wherein the hose reel (20) is rotatably mounted on a fluid distributor piece (3), wherein the fluid distributor piece (3) is held in a rigid connecting element (30), wherein the rigid connecting element (30) is directly connected to a rigid base body (13) of the high-pressure pump (10), and wherein, during the operation of the pressure washer (1), the cleaning fluid flows from the rigid base body (13) through the rigid connecting element (30) to the fluid distributor piece (3)”, Tracey further appears to disclose the first hose section 50a, 343 (see figs. 2A and 3A) entering the hose reel from along the axis and Tracey incorporates the rotatable hose reel apparatus of US 6422500 with a hose aperture and drum (¶ [0057]). Regarding “rigid”, the use of commonly known hose connectors and piping for a movable component is prima facie obvious to one of ordinary skill in the art, for the purposes of durability and function under use. See MPEP 2144.07 Art Recognized Suitability for its Intended Purpose. Regarding “wherein no flexible line piece is arranged between the fluid distributor piece (3) and the high-pressure pump (10)” and “wherein no flexible line piece is arranged between the fluid distributor piece (3) and the rigid base body (13) of the high-pressure pump (10).”, the simple substitution and selection of commonly available rigid/non-flexible fluid lines is prima facie obvious to one of ordinary skill in the art, for the purposes of durability and function under use. See MPEP 2144.07 Art Recognized Suitability for its Intended Purpose. Regarding claims 11-12 are drawn to projecting and overlapping of components. Here, the overlapping and projecting appear to be satisfied (see fig. 3A) and it further being simply an obvious rearrangement of parts to maximize projected overlaps, in order to minimized overall footprint. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Regarding claim 13, “wherein the hose reel has, on its inner outer side turned towards the high-pressure pump, a receiving chamber located radially inwards with respect to the axis of rotation.”, Tracey further discloses hose having passage 402 for additives (¶ [0096]), it thus being obvious that the hose entering hose reel 200 laterally in fig. 3A satisfies “a receiving chamber”. Re claim 10, Regarding “wherein the high-pressure pump (10) projects into the hose reel (20) in the direction of the axis of rotation (50).” Tracey appears to show where if the high-pressure pump 330 is projected laterally (see fig. 3A), it would project into the hose reel 200 in the direction of the axis of rotation. Re claims 14-15, Regarding “wherein the receiving chamber (23) is designed to receive a cleaning supply line (32) for adding cleaning agent to the cleaning fluid”, Tracey further discloses adding cleaning agent (¶ [0096]) along passage 402, as such, as seen in fig. 3A, the hose entering the hose reel 200 laterally thus satisfies “designed to receive a cleaning supply line”, i.e. passage 402 of the hose. Regarding “wherein the receiving chamber (23) has a maximum diameter (d1) measured in a direction perpendicular to the axis of rotation (50), and wherein the maximum diameter (d1) is greater than a diameter (d2) of the fluid distributor piece (3) measured in the direction perpendicular to the axis of rotation (50)”, the mere change in size/proportion of component is prima facie obvious engineering design choices to one of ordinary skill in the art in order to maximize space for fluid flow of cleaning additives. See MPEP 2144.04(IV)(A) Changes in Size/Proportion. Re claim 16-17, Regarding “wherein the rigid connecting element (30) comprises a cleaning supply opening (31) for adding cleaning agent to the cleaning fluid”, Tracey further discloses adding cleaning agent (¶ [0096]). Regarding the specific location at which the cleaning agent is added, would have been an obvious rearrangement of parts on the rigid connecting element between the pump 330 and the hose reel 200, for purposes of compact construction and ease of adding liquids post pressurization. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Regarding “wherein the cleaning supply opening (31) is arranged in a region of the hose reel (20) with respect to the direction of the axis of rotation (50)”, it being obvious in view of the pump 330 being along the axis of rotation, any cleaning additive would be added therebetween and thus “in a region”, as claimed. See MPEP 2144.04(VI)(C). Re claims 18-20, Tracey further discloses wherein the pressure washer comprises a battery pack (¶ [0073]) for supplying power to a drive of the high-pressure pump, wherein the pressure washer has a battery compartment for receiving the battery pack (¶ [0073]), and wherein the battery compartment and the hose reel at least partially overlap one another with respect to the direction of the axis of rotation (¶ [0073] battery in the housing of the fluid control device 330 or in the housing of the hose reel apparatus, both in the direction of the axis of rotation). Regarding “wherein the battery compartment (6) and the high-pressure pump (10) at least partially overlap one another with respect to the direction of the axis of rotation (50). “ and “wherein the high-pressure pump (10), a drive (5) for the high-pressure pump (10), and the battery compartment (6) are arranged one behind another with respect to the direction of the middle axis (48)”, the arrangement of known components in a compact linear manner is prima facie obvious to one of ordinary skill in the art for reducing footprint, moreso where the components of the pump 330 and the hose reel 200 are in a line (see fig. 3A). See MPEP 2144.04(VI)(C) Rearrangement of Parts. Re claim 22, Regarding “wherein the hose reel (20) protrudes in the direction of the axis of rotation (50) by less than 35% of its reel width (c) beyond an outer contour of the housing (2)”, the mere change in size/dimensions of the housing is an obvious engineering design choice to one of ordinary skill in the art, depending on the size/length of the hose and the desired footprint of the machine. See MPEP 2144.04(IV)(A) Changes in Size/Proportion. Re claim 23, Claim 23 defines over Claim 1 only in the recitation “wherein the hose reel (20) forms a part of an outer contour of the pressure washer (1)”. The mere change in aesthetic shape of the pressure washer housing is prima facie obvious and simply an engineering design choice with no effect on functionality. See MPEP 2144.04(I) Aesthetic Design Changes. It further being an obvious rearrangement of parts to enable easy access to the hose for unwinding, winding and/or maintenance. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Response to Arguments Applicant's arguments filed 5/14/2026 have been fully considered and are persuasive in part with respect to a 102 rejection, but they are not persuasive with respect to the 103 rejection over Tracey. The 102 rejection is hereby withdrawn, but the 103 rejection is maintained over Tracey, as applied above. In response to Applicant’s arguments as to Tracey, Examiner respectfully disagrees. As a first issue of interpretation, Examiner assumes “the axis of rotation (50)” derives its antecedent basis from a axis of rotation of the reel hose. At issue is the language, “the axis of rotation (50) runs transversely to the direction of movement (49) of the at least one piston”. Applicant agrees that Tracey teaches a piston pump (¶ [0070] e.g. single piston pump or a radial piston pump), but disagrees with Examiner’s interpretation of the orientation of such a piston pump based on the schematic of Fig. 3A depicting a rectangular box for the more broadly disclosed fluid control device 330, said rectangular box having a longitudinal length and a fluid flow transverse to the hose reel axis. PNG media_image2.png 409 692 media_image2.png Greyscale Here, Examiner maintains that one of ordinary skill in the art of pressure washer design would be familiar with a broad-range of piston pumps, including at least the disclosed A) a radial piston pump or B) a single piston pump with inline flow arrangements (see e.g. common pumps known in the conclusion). With respect to a radial piston pump, having plural pistons arranged in 360 degrees radially around a rotational shaft, at least one of the pistons would thus be expected to run parallel to the flow and thus transverse to the hose reel axis. Alternatively, the mere rotation of the radial piston to achieve such is prima facie obvious. See MPEP 2144.04(VI)(C) Rearrangement of Parts. PNG media_image3.png 416 767 media_image3.png Greyscale With respect to a single or axial piston pump, the orientation of the pump vertically (as seen in Fig. 3A) is prima facie obvious in view of the generally vertically-rectangular orientation of fluid control device 330, such that the piston would thus be transverse to the hose reel. It being simply an obvious rearrangement of parts for purposes of space-utilization and/or compact design, in order to utilize the longer dimensional length for the dimensionally longer linear piston movement. See MPEP 2144.04(VI)(C) Rearrangement of Parts. PNG media_image4.png 416 763 media_image4.png Greyscale Moreover, Examiner points to Figs. 3A and 4A, that shows the same fluid control device 330 with a 90 degree rotational difference, with respect to the hose reel, such that it would be prima facie obvious to one of ordinary skill in the art to change the angle of rotation of the piston pump relative to the hose reel. See MPEP 2144.04(VI)(C) Rearrangement of Parts. Here, it is clear that at least one of the two orientations between either fig. 3A and 4A should thus be parallel to the hose reel (and the other orientation is perpendicular). PNG media_image1.png 820 692 media_image1.png Greyscale The test for obviousness under 35 USC 103 is not “directly and unambiguously disclosed [in Tracey]” nor is it that the claimed invention must be expressly suggested in any one or all of the references. Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981). Here, the mere orientation of the piston of the piston pump of Tracey, to include at least one piston transverse the axis of the hose reel is prima facie obvious in view of compact construction and/or the multiple disclosed orientations within Tracey. See MPEP 2144.04(VI)(C) Rearrangement of Parts. There being no patentable significance or unexpected results in changing the orientation of the piston. With respect to Claim 23 (previously claim 20), Examiner maintains that the language “wherein the hose reel (20) forms a part of an outer contour of the pressure washer (1)” is simply an aesthetic design choice or obvious rearrangement of parts. See MPEP 2144.04(I) and (VI)(C). The mere exposure of any portion of the hose reel to an outside of the apparatus satisfies this limitation, and the mere mounting of the hose reel such to be easily accessible such to form the outer contour is prima facie obvious. Examiner highlights that prior art cited in the conclusions of the prior action and the current action all depict pressure washers with at least a portion of the hose reel exposed such to “form a part of an outer contour of the pressure washer”. There is no patentable subject matter in the exposure of the hose reel. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. DE 4237356 A1 note fig. 2 pistons 58,59 transverse to hose reel 5. US 5816499 A note orientation of hose reel in either vertical or horizontal direction, with respect to same pump orientation. Types of Piston Pumps, haudeonline.com, accessed 9/15/2026 (available at https://huadeonline.com/news/what-is-the-difference-between-piston-pump-and-axial-piston-pump.html). 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 KEVIN LEE whose telephone number is (571)270-7299. The examiner can normally be reached M-F 8:30am to 6:30pm. 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. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Michael Barr can be reached on 571-272-1414. 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. KEVIN G. LEE Examiner Art Unit 1711 /KEVIN G LEE/Examiner, Art Unit 1711 /MICHAEL E BARR/Supervisory Patent Examiner, Art Unit 1711
Read full office action

Prosecution Timeline

Jul 31, 2024
Application Filed
Jan 15, 2026
Non-Final Rejection mailed — §102, §103
May 14, 2026
Response Filed
Sep 17, 2026
Final Rejection mailed — §102, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
64%
Grant Probability
91%
With Interview (+27.2%)
3y 3m (~1y 0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 593 resolved cases by this examiner. Grant probability derived from career allowance rate.

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