Prosecution Insights
Last updated: April 19, 2026
Application No. 18/823,172

LIFTGATE WITH BULKHEAD REINFORCEMENTS

Final Rejection §102§103
Filed
Sep 03, 2024
Examiner
HESCHEL, SUSAN MARIE
Art Unit
3637
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Magna Exteriors Inc.
OA Round
2 (Final)
78%
Grant Probability
Favorable
3-4
OA Rounds
2y 2m
To Grant
97%
With Interview

Examiner Intelligence

Grants 78% — above average
78%
Career Allow Rate
104 granted / 134 resolved
+25.6% vs TC avg
Strong +19% interview lift
Without
With
+19.3%
Interview Lift
resolved cases with interview
Fast prosecutor
2y 2m
Avg Prosecution
26 currently pending
Career history
160
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
49.8%
+9.8% vs TC avg
§102
20.9%
-19.1% vs TC avg
§112
27.7%
-12.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 134 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 . Amendments to claims 1, 11, and 19, filed 27 October 2025 have been entered into the above-identified application. Claims 13, and 17 have been canceled. Claim 3 remains canceled. Claims 1-2, 4-12, 14-16, and 18-20 are currently pending. 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(s) 1-2, 4-5, 7-11, 14-16. and 18-20 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Ukra (U.S. 10,926,812). Regarding claim 1, Ukra teaches a liftgate adapted for a vehicle, comprising: at least one first panel (202 or 204); and a plurality of reinforcements (218) on said first panel (202 or 204) at predetermined locations (see steps 920 and 930 in fig 10) in at least a bulkhead of said first panel (see fig 2, 218 are bulkheads) for predetermined structural strength and without adding parts for strength to meet predetermined performance requirements; said plurality of reinforcements (218) including a curvilinear surface (300) providing a bonding surface extending uninterrupted along said curvilinear surface (300). Regarding claim 2, Ukra the apparatus of claim 1, Ukra further teaches wherein the reinforcements (218) are a plurality of ribs (as seen in fig 2). Regarding claim 4, Ukra the apparatus of claim 1, Ukra further teaches comprising a second panel (204) operably connected to the first panel (202, column 5, lines 42-45). Regarding claim 5, Ukra the apparatus of claim 1, Ukra further teaches comprising a second panel (204) operably connected to the first panel (202) by adhesive (column 7, lines 29-31). Regarding claim 7, Ukra the apparatus of claim 1, Ukra further teaches comprising adhesive (column 7, line 29-31) on the reinforcements (218) to bond a second panel (204) to the plurality of reinforcements (218). Regarding claim 8, Ukra the apparatus of claim 1, Ukra further teaches wherein the first panel (202) is an inner panel (column 5, line 36-37). Regarding claim 9, Ukra the apparatus of claim 1, Ukra further teaches wherein the first panel (204) is an outer panel (as seen in fig 2). Regarding claim 10, Ukra the apparatus of claim 1, Ukra further teaches wherein the plurality of reinforcements are ribs (218) and adhered to at least one second panel (204) of the liftgate (described in column 7, lines 29-31). Regarding claim 11, Ukra teaches a liftgate adapted for a vehicle, comprising: at least one first panel (202); a plurality of reinforcements (218) centrally located in a bulkhead area of at least said at least one first panel (202, see fig 2, 218 are bulkheads) for structural strength to meet predetermined performance requirements; said plurality of reinforcements (218) including a curvilinear surface (300) providing a bonding surface extending uninterrupted along said curvilinear surface (300). Regarding claim 14, Ukra the apparatus of claim 11, Ukra further teaches comprising at least one second panel (204) operably connected to the first panel (202, column 5, lines 42-45). Regarding claim 15, Ukra the apparatus of claim 11, Ukra further teaches wherein the plurality of rib reinforcements (218) are adhered (described in column 7, lines 29-31) to at least one outer panel of the liftgate (204). Regarding claim 16, Ukra the apparatus of claim 14, Ukra further teaches wherein said at least one second panel (204) additionally includes a plurality of rib reinforcements (ribs 218 are attached to both first panel 202 and second panel 204, and therefore both panels include a plurality of rib reinforcements). Regarding claim 18, Ukra the apparatus of claim 11, Ukra further teaches wherein said plurality of rib reinforcements (218) extend in a rearward direction from a backside of a bulkhead reinforcement area of the at least one first panel (as seen in fig 2, the plurality of reinforcement ribs 218 extend in the rearward direction from the inner panel 202). Regarding claim 19, Ukra teaches a liftgate adapted for a motor vehicle, comprising: at least one inner panel (202) including a header area portion (central upper area of panel 202); a plurality of raised reinforcements (218) centrally located at the header area portion of said at least one inner panel (as seen in fig 2, the bulkhead reinforcements 218 are centrally spread throughout the panel, including the central upper area, or header area); said plurality of raised reinforcements (218) including a curvilinear surface (300) providing a bonding surface extending uninterrupted along said curvilinear surface (300); and at least one outer panel (204) operably coupled (described in column 7, lines 29-31) to said plurality of raised reinforcements (218). Regarding claim 20, Ukra the apparatus of claim 19, Ukra further teaches wherein the plurality of raised reinforcements (218) are connected to said at least one outer panel (204) with adhesive (described in column 7, lines 29-31). 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. 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) 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Ukra (U.S. 10,926,812) in view of Chaaya (US 10,549,611). Regarding claim 6, Ukra teaches the apparatus of claim 1. Ukra further teaches a second panel (204) but is silent as to the second panel (204) being connected to the first panel (202) by plastic welding. Chaaya teaches a similar body panel assembly where the reinforcement panel is infrared welded to the adjacent inner and/or outer panel. Chaaya teaches the infrared welding can be done on a ribs-to-flat configuration (column 6, lines 2-4) which matches the configuration taught by Ukra. Ukra and Chaaya are considered to be analogous to the claimed invention because they are both in the same field of vehicle rear panel assemblies. Therefore, it would have been obvious to someone of ordinary skill in the art before the effective filing date of the claimed invention to have modified Ukra to incorporate the teachings of Chaaya and utilize infrared welding to connect the first panel and the second panel via reinforcement rib. Doing so would utilize a bonding process that is clean and creates a seal between the two components, not just a simple bond, as taught by Chaaya in column 2, lines 59-62. Claim(s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over Ukra (U.S. 10,926,812). Regarding claim 12, Ukra teaches the apparatus of claim 11. Ukra further teaches wherein said plurality of rib reinforcements (218) are connected to said at least one first panel (202). The claim limitation “integrally molded” is considered a product-by-process claim limitation. The determination of the patentability is based on the product of claim 12 itself and does not depend on its method of production. See MPEP 2113. Response to Arguments Applicant's arguments filed 27 October 2025 have been fully considered but they are not persuasive. Applicant has amended independent claims 1, 11, and 19 to include the limitation "said plurality of raised reinforcements including a curvilinear surface providing a bonding surface extending uninterrupted along said curvilinear surface." The addition of the curvilinear surface in the claim amendment prompted a further prior art search which discovered the prior art of Ukra, previously cited in the non-final office action. Ukra teaches a curvilinear surface on rib reinforcements that created an uninterrupted bonding surface, and therefore teaches the claims as amended. As applicant's arguments are directed to the prior art rejection before the amendments, the arguments are moot in view of this latest final rejection. Applicant’s claim amendments have resolved the drawing objections from the non-final office action and the drawing objections have been withdrawn. Conclusion 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 Susan M Heschel whose telephone number is (571)272-6621. The examiner can normally be reached Monday-Friday 8:00 am-4:00 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, Daniel Troy can be reached at (571)270-3742. 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. /SUSAN M. HESCHEL/Examiner, Art Unit 3637 /Muhammad Ijaz/Primary Examiner, Art Unit 3631
Read full office action

Prosecution Timeline

Sep 03, 2024
Application Filed
Jul 22, 2025
Non-Final Rejection — §102, §103
Oct 27, 2025
Response Filed
Jan 23, 2026
Final Rejection — §102, §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
78%
Grant Probability
97%
With Interview (+19.3%)
2y 2m
Median Time to Grant
Moderate
PTA Risk
Based on 134 resolved cases by this examiner. Grant probability derived from career allow rate.

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