Prosecution Insights
Last updated: April 17, 2026
Application No. 18/870,208

SHIFT DEVICE

Final Rejection §102§103
Filed
Nov 27, 2024
Examiner
MACARTHUR, VICTOR L
Art Unit
3618
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Kabushiki Kaisha Tokai-Rika-Denki-Seisakusho
OA Round
2 (Final)
66%
Grant Probability
Favorable
3-4
OA Rounds
3y 1m
To Grant
79%
With Interview

Examiner Intelligence

Grants 66% — above average
66%
Career Allow Rate
697 granted / 1059 resolved
+13.8% vs TC avg
Moderate +13% lift
Without
With
+13.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 1m
Avg Prosecution
34 currently pending
Career history
1093
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
29.0%
-11.0% vs TC avg
§102
32.7%
-7.3% vs TC avg
§112
32.5%
-7.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1059 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. (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. Claims 1-5 are rejected under 35 U.S.C. 102(a)(1) and/or (a)(2) as being anticipated by Ono US20190145513. Claim 1. A shift device, comprising: an assembly body (24) configured to be installed to a vehicle as a side unit (see vehicle side 23 of “vehicle” [para.0038] and note that 24 meets all assembly body structural limitations that are claimed and thus is presumed to be inherently capable of meeting the installation property/function, thereby shifting burden to applicant to obtain/test the prior art to prove otherwise in accordance with MPEP 2112.01 and 2114, see also response to arguments section elsewhere below); a shift body (3) movably mounted to the assembly body; a moving portion (7) assembled to the assembly body, the moving portion moving when the shift body is moved; and a detection mechanism (5, 6 and 8) assembled to the assembly body, the detection mechanism detecting a shift position of the shift body by detecting a relative position between the detection mechanism and the moving portion (via 5a, 5b, 5c). Claim 2. The shift device of claim 1, wherein the shift body and the moving portion are separate bodies (3 is separate from 6/7). Claim 3. The shift device of claim 1, further comprising a support shaft (a first one of the shafts of 7 protruding from 24) protruding from the assembly body, an assembly shaft (a second one of the shafts of 7 protruding from 24) protruding from the assembly body in the same direction as the support shaft, and restriction pillars (3rd and 4th ones of the shafts of 7 protruding from 24) protruding from the assembly body in the same direction as the support shaft, wherein the shift body is fitted onto the support shaft (see before assembly fig.2 and after assembly fig.3), , the moving portion is fitted onto the support shaft (see fig.3 showing 6 fitted onto the first one of the shafts of 7), and the detection mechanism is fitted onto the restriction pillars (see fig.3 showing 6 fitted onto the 3rd and 4th ones of the shafts of 7). Claim 4. The shift device of claim 1, further comprising a restraint block (28 and/or 33) assembled to the assembly body, the restraint block guiding the shift body to a home position (Neutral position, Reverse position, or Drive position). Claim 5. The shift device of claim 1, wherein the assembly body is one piece (24 is one piece as seen in fig.2). Response to Arguments Applicant's arguments the drawing objections and 35 USC 112 rejections have been overcome by amendment are persuasive. Those objections/rejections are withdrawn. Applicant’s arguments that the 35 USC 102 rejections have been overcome by amendment are not persuasive. The art continues to read on the newly amended claims, albeit under slightly different interpretation, as is detailed in the reworded rejections above, e.g., while assembly (2) previously relied upon was multi-part, the newly reworded rejections rely on element (24) to be the one-piece assembly body. Regarding applicant’s argument toward the order of assembly, note that the argued phraseology “before… after” are not present in the claims. Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). Furthermore, even if the order of assembly steps were expressly amended into the claims later, note that the MPEP § 2113 states that the specific method of forming is not germane to the issue of patentability of the device itself and that it is well established by case law that it is the patentability of the product that is to be determined even though such claims are limited and defined by process steps. See also In re Thorpe et al, 227 USPQ 964 (CAFC 1985). Regarding inherency of property and/or functional limitations (such as applicant’s newly amended claim 1 preamble) in product claims note the following case law and MPEP sections: MPEP §2112.01 (I) states “When the structure recited in the reference is substantially identical to that of the claims, claimed properties or functions are presumed to be inherent… [and] a prima facie case of either anticipation or obviousness has been established… the applicant has the burden of showing that they are not…” (emphasis added). MPEP §2112 (V) states “[T]he PTO can require an applicant to prove that the prior art products do not necessarily or inherently possess the characteristics of his [or her] claimed product. Whether the rejection is based on ‘inherency’ under 35 U.S.C. 102, on ‘prima facie obviousness’ under 35 U.S.C. 103, jointly or alternatively, the burden of proof is the same...[footnote omitted].’ The burden of proof is similar to that required with respect to product-by-process claims. In re Fitzgerald, 619 F.2d 67, 70, 205 USPQ 594, 596 (CCPA 1980) (quoting In re Best, 562 F.2d 1252, 1255, 195 USPQ 430, 433-34 (CCPA 1977)). PNG media_image1.png 18 19 media_image1.png Greyscale ” MPEP §2112 (IV) further states “In In re Schreiber, 128 F.3d 1473, 44 USPQ2d 1429 (Fed. Cir. 1997), the court affirmed a finding that a prior patent to a conical spout used primarily to dispense oil from an oil can inherently performed the functions recited in applicant’s claim to a conical container top for dispensing popped popcorn. The examiner had asserted inherency based on the structural similarity between the patented spout and applicant’s disclosed top, i.e., both structures had the same general shape. The court stated: [N]othing in Schreiber’s [applicant’s] claim suggests that Schreiber’s container is of a ‘different shape’ than Harz’s [patent]. In fact, [ ] an embodiment according to Harz (Fig. 5) and the embodiment depicted in Fig. 1 of Schreiber’s application have the same general shape. For that reason, the examiner was justified in concluding that the opening of a conically shaped top as disclosed by Harz is inherently of a size sufficient to ‘allow [ ] several kernels of popped popcorn to pass through at the same time’ and that the taper of Harz’s conically shaped top is inherently of such a shape ‘as to by itself jam up the popped popcorn before the end of the cone and permit the dispensing of only a few kernels at a shake of a package when the top is mounted to the container.’ The examiner therefore correctly found that Harz established a prima facie case of anticipation. In re Schreiber, 128 F.3d at 1478, 44 USPQ2d at 1432.” MPEP §2114(I) states “Apparatus claims must be structurally distinguishable from the prior art… While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. In re Schreiber, 128 F.3d 1473, 1477-78, 44 USPQ2d 1429, 1431-32 (Fed. Cir. 1997) (The absence of a disclosure in a prior art reference relating to function did not defeat the Board’s finding of anticipation of claimed apparatus because the limitations at issue were found to be inherent in the prior art reference); see also In re Swinehart, 439 F.2d 210, 212-13, 169 USPQ 226, 228-29 (CCPA 1971);In re Danly, 263 F.2d 844, 847, 120 USPQ 528, 531 (CCPA 1959). “[A]pparatus claims cover what a device is, not what a device does.” Hewlett-Packard Co. v. Bausch & Lomb Inc., 909 F.2d 1464, 1469, 15 USPQ2d 1525, 1528 (Fed. Cir. 1990) (emphasis in original).” MPEP §2114(II) states “[the] Manner of operating the device does not differentiate apparatus claim from the prior art… A claim containing a “recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus” if the prior art apparatus teaches all the structural limitations of the claim. Ex parte Masham, 2 USPQ2d 1647 (Bd. Pat. App. & Inter. 1987) (The preamble of claim 1 recited that the apparatus was “for mixing flowing developer material” and the body of the claim recited “means for mixing ..., said mixing means being stationary and completely submerged in the developer material”. The claim was rejected over a reference which taught all the structural limitations of the claim for the intended use of mixing flowing developer. However, the mixer was only partially submerged in the developer material. The Board held that the amount of submersion is immaterial to the structure of the mixer and thus the claim was properly rejected.)” (emphasis in original). In In re Best the court relied upon In re Ludke and In re Brown to explain that “Where, as here, the claimed and prior art products are identical or substantially identical, or are produced by identical or substantially identical processes, the PTO can require an applicant to prove that the prior art products do not necessarily or inherently possess the characteristics of his claimed product. See In re Ludke, supra. Whether the rejection is based on 'Inherency' under 35 USC 102, on 'prima facie obviousness’ under 35 USC 103, jointly or alternatively, the burden of proof is the same, and its fairness is evidenced by the PTO’s inability to manufacture products or to obtain and compare prior art products. See In re Brown, 59 CCPA 1036, 459 F.2d 531, 173 USPQ 685 (1972)" (emphasis added) In re Best, 562 F.2d 1252, 1255, 195 USPQ 430, 433-34 (CCPA 1977); In re Schreiber found that "choosing to define an element functionally, i.e., by what it does, carries with it a risk... [W]here the Patent Office has reason to believe that a functional limitation asserted to be critical for establishing novelty in the claimed subject matter may, in fact, be an inherent characteristic of the prior art, it possesses the authority to require the applicant to prove that the subject matter shown to be in the prior art does not possess the characteristic relied on.” (emphasis added) See In Re Schreiber, 128 F.3d 1473 (Fed. Cir. 1997). In re Schreiber held that “Apparatus must be distinguished from the prior art in terms of structure rather than function.” In re Schreiber, 128 F.3d 1473, 1477-78 44 USPQ2d 1429, 1431-32 (Fed.Cir.1997). In re Swinehart and In re Ludtke held that “[I]t is elementary that the mere recitation of a newly discovered function or property, inherently possessed by things in the prior art, does not cause a claim drawn to those things to distinguish over the prior art. Additionally, where the Patent Office has reason to believe that a functional limitation asserted to be critical for establishing novelty in the claimed subject matter may, in fact, be an inherent characteristic of the prior art, it possesses the authority to require the applicant to prove that the subject matter shown to be in the prior art does not possess the characteristic relied on.” (emphasis added) In re Swinehart, 58 CCPA --, --F.2d --, 169 USPQ 226 (1971), and In re Ludtke, 441 F.2d 660, 664, 169 USPQ 563, 566 (CCPA 1971). In re Brown held that “[I]t is the patentability of the product claimed and not of the recited process steps which must be established. We are therefore of the opinion that when the prior art discloses a product which reasonably appears to be either identical with or only slightly different than a product claimed in a product-by-process claim, a rejection based alternatively on either section 102 or section 103 of the statute is eminently fair and acceptable. As a practical matter, the Patent Office is not equipped to manufacture products by the myriad of processes put before it and then obtain prior art products and make physical comparisons therewith.” (emphasis added) In re Brown, 459 F.2d 531, 535, 173 USPQ 685, 688 (CCPA 1972). In re King held that "Contrary to appellant's reasoning, after the PTO establishes a prima facie case of anticipation based on inherency, the burden shifts to appellant to prove that the subject matter shown to be in the prior art does not posses the characteristic relied on… Here, appellant’s burden before the board was to prove that Donley’s structure does not perform the so-called method defined in the claims when placed in ambient light. Appellant did not satisfy that burden, it did not suffice merely to assert that Donley does not inherently achieve enhanced color through interference effects, challenging the PTO to prove the contrary by experiment or otherwise. The PTO is not equipped to perform such tasks.” In re King, 801 F.2d 1324, 1327, 231 USPQ 136, 138 (Fed. Cir. 1986). In re Spada held that “Spada was reasonably required to show that his polymer compositions are different from those described by Smith. This burden was not met by simply including the assertedly different properties in the claims. When the claimed compositions are not novel they are not rendered patentable by recitation of properties, whether or not these properties are shown or suggested in the prior art." In re Spada, 911 F.2d 705, 709, 15 USPQ2d 1655, 1658 (Fed. Cir. 1990). Conclusion Applicant's amendment necessitated the new grounds 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to VICTOR L MACARTHUR whose telephone number is (571)272-7085. Information regarding the status of an application may be obtained from Patent Center. Status information for published applications may be obtained from Patent Center. Status information for unpublished applications is available through Patent Center for authorized users only. Should you have questions about access to Patent Center, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). /VICTOR L MACARTHUR/Primary Examiner, Art Unit 3618
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Prosecution Timeline

Nov 27, 2024
Application Filed
Aug 20, 2025
Non-Final Rejection — §102, §103
Nov 10, 2025
Response Filed
Jan 12, 2026
Final Rejection — §102, §103
Mar 26, 2026
Request for Continued Examination
Apr 01, 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
66%
Grant Probability
79%
With Interview (+13.4%)
3y 1m
Median Time to Grant
Moderate
PTA Risk
Based on 1059 resolved cases by this examiner. Grant probability derived from career allow rate.

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