Prosecution Insights
Last updated: October 02, 2026
Application No. 18/890,220

RECLINING AIRCRAFT SEAT STRUCTURE, AND ASSOCIATED AIRCRAFT CABIN

Final Rejection §102§112
Filed
Sep 19, 2024
Priority
Sep 26, 2023 — FR FR 2310197
Examiner
WHITE, RODNEY BARNETT
Art Unit
3636
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Dassault Aviation
OA Round
2 (Final)
82%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 82% — above average
82%
Career Allowance Rate
1819 granted / 2204 resolved
+30.5% vs TC avg
Strong +18% interview lift
Without
With
+17.8%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 8m
Avg Prosecution
45 currently pending
Career history
2224
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
37.0%
-3.0% vs TC avg
§102
30.5%
-9.5% vs TC avg
§112
27.1%
-12.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 2204 resolved cases

Office Action

§102 §112
August 20, 2026 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 . Response to Amendment Applicants’ arguments filed 08/10/2026 have been fully considered but they are not persuasive. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1-18 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Applicant has amended Claim 1 to define that “the vertical median plane intersecting the front edge and the rear edge and dividing the seat structure into two parts”. It appears that Applicant is attempting to define that the “vertical median plane” is an imaginary flat surface that extends up and down (vertically) through the middle of the seat. It splits the seat into left and right halves. If a person was sitting in the seat, the plane would run from the front edge to the back edge, directly between his or her legs, dividing the seat into two equal parts (left side and right side). However, the original disclosure does not define the orientation of the “vertical median plane”, so it is possible that the vertical plane could have been side to side (dividing the seat into front and back halves). The drawings do not show the plane. So, the amendment to Claim 1 now specifies that the plane is front to back, which is new matter. The language also appears in new Claims 17 and 18. The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 3-5 and 10 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. In claim 3, line 2, the word “of” after the word “and” needs to be removed. Applicant only deleted the second instance of the word “of”. In claim 10, line 2, the word “of” after the word “and” needs to be removed. Just as in Claim 3, Applicant only deleted the second instance of the word “of” after the word “and”. The aforementioned problems render the claims vague and indefinite. Clarification and/or correction is required. 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. Claims 1-5, 7, 11, 13, and 16, so far as understood, is rejected under 35 U.S.C. 102(a)(1) as being anticipated by Vigeant (U.S. Patent Application Publication No. 2023/0111420 A1, now U.S. Patent No. 12,054,079 B2). PNG media_image1.png 274 174 media_image1.png Greyscale PNG media_image2.png 282 310 media_image2.png Greyscale As for Claim 1, Vigeant teaches an aircraft seat structure comprising: a base 12 to be mounted on a floor 7 of an aircraft cabin; a main displacement carriage 8, supported by the base, the main displacement carriage comprising, in projection onto a vertical median plane of the seat structure, a front edge and a rear edge, the vertical median plane intersecting the front edge and the rear edge and dividing the seat structure into two parts; a seat pan support 14, articulated on the main displacement carriage about a transverse front articulation axis 22, located between the front edge and the rear edge of the main displacement carriage, in a projection onto the vertical median plane; a backrest support 16, articulated with respect to the seat pan support 14, about a transverse rear articulation axis 18, the transverse rear articulation axis being located rearward of the front articulation axis 22, the backrest support comprising at least one lower arm 16b protruding under the seat support; and an actuator 32 comprising a body and a deployable rod, deployable with respect to the body between a retracted position in the body and a deployed position with respect to the body, one of the body and of the deployable rod being articulated on the lower arm 16b at a rear articulation point 30, another one of the body and of the deployable rod being articulated on the main displacement carriage in a front articulation point 36, the rear articulation point 30 being situated rearward of the front articulation axis 22 over at least part of a travel of the deployable rod between the retracted position and the deployed position, wherein the rear articulation point is at the lower end of the lower arm; or the rear articulation point is below the front articulation point in at least one of the retracted position and the deployed position. As for Claim 2, Vigeant teaches that the rear articulation point 30 is located rearward of the front articulation axis 22 throughout the whole travel of the deployable rod between the retracted position and the deployed position. As for Claims 3-5, Vigeant teaches that wherein one of the lower arm and of the main displacement carriage defines a slide , another one of the lower arm and of the main displacement carriage supports a slider 44 received in the slide; wherein the slider is located, in projection onto the vertical median plane, at a same point as the rear articulation point; wherein the slide extends entirely rearward of the front articulation axis (annotated Fig. 7a above). As for Claim 7, Vigeant teaches that the front articulation axis 22 is located at a highest point of the main displacement carriage, in projection onto the vertical median plane. As for Claim 11, Vigeant teaches that the backrest support includes two lateral uprights, each lateral upright having a lower region 16b located below the rear articulation axis and an upper portion 16a located above the rear articulation axis, the lower arm being formed by the lower region of the lateral upright. As for Claim 13, Vigeant teaches that in the retracted position, a value of an angle formed between the seat pan support and the backrest support in projection onto the vertical median plane at the rear articulation axis is greater than the value of the angle formed between the seat pan support and the backrest support in the deployed position, in a projection onto the vertical median plane. As for Claim 16, Vigeant teaches an aircraft cabin having a floor, and at least one aircraft seat, the at least one aircraft seat comprising the seat structure according to claim 1. Claims 1-2, 7, and 11-16, so far as understood, is rejected under 35 U.S.C. 102(a)(1) as being anticipated by BOMBARDIER INC. (U.S. Patent Nos. 11,186,374 B2, 11,358,722 B2, and 11,447,254 B2). PNG media_image3.png 426 268 media_image3.png Greyscale PNG media_image4.png 226 348 media_image4.png Greyscale PNG media_image5.png 236 334 media_image5.png Greyscale As for Claim 1, BOMBARDIER INC. teaches an aircraft seat structure comprising: a base 12 to be mounted on a floor 7 of an aircraft cabin; a main displacement carriage 8, supported by the base, the main displacement carriage comprising, in projection onto a vertical median plane of the seat structure, a front edge and a rear edge; a seat pan support 14, articulated on the main displacement carriage about a transverse front articulation axis 22, located between the front edge and the rear edge of the main displacement carriage, in a projection onto the vertical median plane; a backrest support 16, articulated with respect to the seat pan support 14, about a transverse rear articulation axis 18, the transverse rear articulation axis being located rearward of the front articulation axis 22, the backrest support comprising at least one lower arm 16b protruding under the seat support; and an actuator 32 comprising a body and a deployable rod, deployable with respect to the body between a retracted position in the body and a deployed position with respect to the body, one of the body and of the deployable rod being articulated on the lower arm 16b at a rear articulation point 30, another one of the body and of the deployable rod being articulated on the main displacement carriage in a front articulation point 36, the rear articulation point 30 being situated rearward of the front articulation axis 22 over at least part of a travel of the deployable rod between the retracted position and the deployed position. As for Claim 2, BOMBARDIER INC. teaches that the rear articulation point 30 is located rearward of the front articulation axis 22 throughout the whole travel of the deployable rod between the retracted position and the deployed position. As for Claim 7, BOMBARDIER INC. teaches that the front articulation axis 22 is located at a highest point of the main displacement carriage, in projection onto the vertical median plane. As for Claim 11, BOMBARDIER INC. teaches that the backrest support includes two lateral uprights, each lateral upright having a lower region 16b located below the rear articulation axis and an upper portion 16a located above the rear articulation axis, the lower arm being formed by the lower region of the lateral upright. As for Claim 12, BOMBARDIER INC. teaches that the seat pan support 14 includes two longitudinal beams and a rear cross-piece 34, the lateral uprights of the backrest support being rotatably mounted on the rear cross-piece (see Fig. 3 above of U.S. Patent Nos. 11,358,722 B2 and 11,447,254 B2). As for Claim 13, BOMBARDIER INC. teaches that in the retracted position, a value of an angle formed between the seat pan support and the backrest support in projection onto the vertical median plane at the rear articulation axis is greater than the value of the angle formed between the seat pan support and the backrest support in the deployed position, in a projection onto the vertical median plane. As for Claim 14, BOMBARDIER INC. teaches that the base includes a frame configured to be fastened to the floor of the cabin, and a turret 8b, mounted rotatably with respect to the frame about a vertical axis, the main displacement carriage being mounted at least partly above the turret. As for Claim 15, BOMBARDIER INC. teaches that the main displacement carriage is mounted movable in translation in the turret (see column 4, lines 33-47 of U.S. Patent No. 11,186,374 B2, where it reads “Referring particularly to FIG. 2, the seat 10 includes a base or carrier 12 which is configured to be connected to a floor structure 7, for example to floor beams interconnected to the fuselage 2. In the embodiment shown, the base 12 is connected to a pivot 8 which is slidingly received on rails 9 attached to the floor structure 7, allowing the base 12 to be displaced along a limited path defined by the rails 9 and pivoted about the pivot 8; the pivot 8 is located toward the rear of the base 12, such that a greater part of the base 12 is located in front if the pivot 8. It is however understood that the attachment between the base 12 and floor structure 7 shown here is exemplary only and that any other suitable type of attachment may alternately be used, including, but not limited to, pivoting attachments, sliding attachments, and fixed attachments.”) and column 4, lines 10-39 in U.S. Patent No. 11,358,722 B2 where it reads “Referring particularly to FIG. 2, the seat 10 generally includes a bottom support 12 configured to be connected to a floor 7 of the aircraft, for example to floor beams interconnected to the fuselage 2, a seat pan frame 14 supporting a seat pan (not shown), and a backrest frame 16 supporting a backrest (not shown). The bottom support 12 defines a footprint F of the seat 10 along a surface of the floor 7, and includes a fixed portion 9 configured to be connected to the floor 7 and a movable connection assembly 11 engaged to the fixed portion 9 and movable with respect thereto. In the embodiment shown, the fixed portion 9 includes rails attached to the floor structure 7, and the movable connection assembly 11 is slidingly engaged to the rails and includes a swivel assembly 8. The swivel assembly 8 includes a first portion 8a slidable with respect to the fixed portion 9 and configured to have a fixed orientation with respect to the floor and a second portion 8b rotatable relative to the first portion 8a. The second portion 8b extends forwardly from the first portion 8a so as to be supported in a cantilevered manner from the first portion 8a. The seat pan frame 14 and backrest frame 16 are connected to the bottom support 12, and more particularly in the embodiment shown to the second portion 8b of the swivel assembly 8, by a support structure 15 which is described in greater detail below. Accordingly, the seat pan frame 14 is pivotable via the swivel assembly 8 from a neutral position (as shown), and is slidable via the movable connection assembly 11 between a forwardmost position and a rearward most position (as shown). In a particular embodiment, the neutral, rearward most position corresponds to the TTOL position.”, and column 3, lines 53-67 and column 4, lines 1-15 of U.S. Patent No. 11,447,254 B2 where the same description the same disclosure as in U.S. Patent No. 11,358,722 B2 occurs.) As for Claim 16, BOMBARDIER INC. teaches an aircraft cabin having a floor, and at least one aircraft seat, the at least one aircraft seat comprising the seat structure according to claim 1 Allowable Subject Matter Claims 6 and 8-10 would be allowable if rewritten to overcome the rejection(s) under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, set forth in this Office action and to include all of the limitations of the base claim and any intervening claims. Claims 17-18 would be allowable if rewritten or amended to overcome the rejection(s) under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, set forth in this Office action. Response to Arguments Applicant has amended Claim 1 to include the language “wherein at least one of: the rear articulation point is at the lower end of the lower arm; or the rear articulation point is below the front articulation point in at least one of the retracted position and the deployed position.” PNG media_image6.png 418 346 media_image6.png Greyscale Since the limitation has been amended to be in alternative form and only one of the limitations needs to be met, the “the pivot connection 30” in both Vigeant (U.S. Patent Application Publication No. 2023/0111420 A1, now U.S. Patent No. 12,054,079 B2) and BOMBARDIER INC. (U.S. Patent Nos. 11,186,374 B2, 11,358,722 B2, and 11,447,254 B2), which the examiner considers the “rear articulation point” of the two references, is below “pivot connection 22”, which the Examiner considers to be the “front articulation point” of the two references (see Figures 2-3 and 6a of Vigeant and Figures 2-3 and 7a of BOMBARDIER INC.) Conclusion THIS ACTION IS MADE FINAL. Applicants are 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 Rodney B. White whose telephone number is (571)272-6863. The examiner can normally be reached 8:30 AM-5:00 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, David R. Dunn can be reached at (571) 272-6670. 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. /Rodney B White/Primary Examiner, Art Unit 3636
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Prosecution Timeline

Sep 19, 2024
Application Filed
Apr 09, 2026
Non-Final Rejection mailed — §102, §112
Jun 18, 2026
Applicant Interview (Telephonic)
Jun 18, 2026
Examiner Interview Summary
Aug 10, 2026
Response Filed
Aug 25, 2026
Final Rejection mailed — §102, §112 (current)

Precedent Cases

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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
82%
Grant Probability
99%
With Interview (+17.8%)
1y 8m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 2204 resolved cases by this examiner. Grant probability derived from career allowance rate.

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