Prosecution Insights
Last updated: April 19, 2026
Application No. 18/892,138

TRAY TABLE WITH ELECTRONIC DEVICE POSITIONING APPARATUS

Non-Final OA §103
Filed
Sep 20, 2024
Examiner
KIM, SHIN H
Art Unit
3636
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
B/E Aerospace, Inc.
OA Round
1 (Non-Final)
64%
Grant Probability
Moderate
1-2
OA Rounds
2y 2m
To Grant
76%
With Interview

Examiner Intelligence

Grants 64% of resolved cases
64%
Career Allow Rate
735 granted / 1149 resolved
+12.0% vs TC avg
Moderate +12% lift
Without
With
+11.6%
Interview Lift
resolved cases with interview
Typical timeline
2y 2m
Avg Prosecution
35 currently pending
Career history
1184
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
54.2%
+14.2% vs TC avg
§102
28.4%
-11.6% vs TC avg
§112
9.7%
-30.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1149 resolved cases

Office Action

§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 § 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. Claim(s) 1-13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jackson et al. U.S. Patent 11,305,876 B2 (Wanner) in view of Ronald Joseph Valme et al. U.S. Patent 10,285,495 B1 (Valme). Regarding claim 1, Wanner discloses a tray table for a passenger seat (Figure 8 Element 100), the tray table having a main body defining a table surface (Element 104), and the tray table comprising: a second member (Element 110) configured to move relative to the main body between a first, stowed position and a second, extended position, wherein in the second position the second member protrudes upwardly from the table surface of the main body to define a second rest for supporting a second portion of an electronic device (Figure 1-5), wherein the second member, when in their respective second, extended positions, thus cooperate to support and position an electronic device (Figure 7). Wanner does not directly disclose a first member. Valme discloses a table comprising a first member configured to slide relative to the main body between a first position and a second, extended position, wherein at least when in the second, extended position the first member is configured to define a first rest for supporting a first portion of an electronic device (Element 96 extended from main support surface). Therefore it would have been an obvious modification well known in the art before the effective filing date of the claimed invention to modify Wanner as taught by Valme to include Valme’s first member extension on a main tray surface. Such a modification would provide a means to expand the support surface of the support tray apparatus. Regarding claim 2, Wanner in view of Valme discloses the tray table wherein the main body comprises a pocket configured to receive the second member in the first position such that the second member is substantially flush with the table surface when the second member is in the first position (Figure 5A and 5B Element 110, Wanner). Regarding claim 3, Wanner in view of Valme discloses the tray table wherein the second member is angled relative to the table surface when the second member is in the second position (Figure 5A and 5B Element 110, Wanner). Regarding claim 4, Wanner in view of Valme discloses the tray table wherein the first member comprises an end portion comprising a flange for supporting a bottom of an electronic device (Element 98, Valme). Regarding claim 5, Wanner in view of Valme discloses the tray table wherein the first position of the first member is a stowed position in which an end portion of the first member is substantially flush with an end portion of the tray table, the stowed position being the position in which the first member is stored in a respective cavity of the main body (Figure 5A and 5B Element 110, Wanner). Regarding claim 6, Wanner in view of Valme discloses the tray table wherein the first member comprises a stop configured to abut against a stop in the cavity of the main body when the first member reaches a or the fully extended position (Element 102, Column 2 Line 65-Column 3 Line 13, Valme). Regarding claim 7, Wanner in view of Valme discloses the tray table wherein the first member is operable to extend to multiple different positions in order to support and position the electronic device at different angles (Element 96 range position from closed to extension, Valme). Regarding claim 8, Wanner in view of Valme discloses the tray table wherein the first member is configured to slide into or out of a or the cavity which is formed in an end of the tray table closest to the passenger in use (tray with cavity as disclosed in Wanner in view of Figure 3, Valme). Regarding claim 9, Wanner in view of Valme discloses the tray table wherein the main body comprises a bushing disposed in a or the cavity, the first member being in sliding contact with the bushing (Element 102, Valme). Regarding claim 10, Wanner in view of Valme discloses the tray table wherein the second member is hinged to the table surface of the main body (Figure 5 Element 116, Wanner). Regarding claim 11, Wanner in view of Valme discloses the tray table further comprising a charging port for charging an electronic device, the charging port being provided in the main body of the tray table (Element 120, 122, 124, Valme). Regarding claim 12, Wanner in view of Valme discloses an apparatus comprising: an aircraft passenger seat; and the tray table (Column 5 Line 41-56, Wanner), wherein the tray table is attached to the aircraft seat and is moveable between a stowed and deployed position relative to the aircraft seat, wherein the tray table is configured to operate as described above when the tray table is in the deployed position. Regarding claim 13, Wanner in view of Valme discloses a method of installing the tray table onto a passenger aircraft seat, the method comprising providing at least two arms of the tray table, and pivotally attaching the tray table to the aircraft via the at least two arms (Figure 1-10 Element 810, Wanner). Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Any inquiry concerning this communication or earlier communications from the examiner should be directed to SHIN H KIM whose telephone number is (571)272-7788. The examiner can normally be reached Monday-Friday 9AM-6PM. 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 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. /SHIN H KIM/Primary Examiner, Art Unit 3636
Read full office action

Prosecution Timeline

Sep 20, 2024
Application Filed
Mar 07, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
64%
Grant Probability
76%
With Interview (+11.6%)
2y 2m
Median Time to Grant
Low
PTA Risk
Based on 1149 resolved cases by this examiner. Grant probability derived from career allow rate.

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