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
The Amendment filed July 28th, 2026 has been entered. Claims 1 – 3 & 6 – 22 remain pending in the application. Applicant’s amendments to the Specification and Claims have overcome each and every objection and 112(b) rejections previously set forth in the Non-Final Office Action mailed April 30th, 2026.
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.
Claims 1 – 3, 6 – 12, & 14 are rejected under 35 U.S.C. 103 as being unpatentable over Nasu US 20170066352 A1 (hereinafter Nasu) in view of Ronzi et al. US 9187017 B2 (hereinafter Ronzi) and Yokota et al. US 20090200843 A1 (hereinafter Yokota).
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Annotated Section of Ronzi Fig. 9
Re. Cl. 1, Nasu discloses a sleeve apparatus for a headrest (Fig. 3, Ref. 30), comprising a sleeve body (Fig. 3, Ref. 31) for insertion into a frame of a vehicle seat, wherein, during use, the sleeve body is inserted into the frame of the vehicle seat (Para. 0023) and is generally located therein, wherein the sleeve body comprises a tubular wall (See Fig. 3) defining an inner axial passageway (Fig. 3, Ref. 34) having an inner surface (Fig. 3, Ref. 313) configured to receive a rod of a headrest, wherein the tubular wall comprises an outer surface (Fig. 3, Ref. 312) opposite the inner surface of the tubular wall, and wherein the tubular wall comprises at least two recesses (Fig. 3, Ref. 314) extending in a longitudinal direction of the tubular wall between the outer surface and the inner surface, wherein the recesses define a deformable part (Fig. 3, Ref. 315) of the tubular wall of the sleeve apparatus.
Re. Cl. 1, Nasu discloses recesses, but the recesses are a generally inverted U-shape and thus fails to disclose a groove extending between the at least two recesses. Ronzi teaches a tubular wall (Fig. 3, Ref. 44) that comprises at least one groove (See Fig. 9) extending between two recesses, wherein the groove connects the recesses to one another (See Fig. 9). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Ronzi’s teaching of a tubular wall that comprises at least one groove extending substantially perpendicular to the parallel recesses, wherein the groove connects the recesses to one another. Doing so allows for a firmer fit between headrest parts, minimizing tolerance and reducing buzz, squeak, and rattle (BSR).
Re. Cl. 1, Nasu as modified by Ronzi fails to disclose the groove having a reduced wall thickness. Yokota teaches a groove with a reduced thickness (Fig. 6, Ref. 18) in the context of localizing deformation in a vehicle seat headrest. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to further modify Nasu’s invention with Yokota’s teaching of a groove with a reduced thickness. Doing so would make the deformable portion more prone to deformation under a load, thus ensuring deformation occurs in a particular section (Para. 0062). This allows for ease of use when inserting the sleeve apparatus to the seat frame and a lower tolerance and tighter fit between the headrest rods, the sleeve apparatus, and the seat frame.
Re. Cl. 2, Nasu discloses recesses, but the recesses are a generally inverted U-shape and thus fails to disclose two parallel recesses. Ronzi teaches a sleeve apparatus where the two recesses are configured to be substantially parallel to one another (See Fig. 9). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Ronzi’s teaching of a sleeve apparatus where the two recesses are configured to be substantially parallel to one another. Doing so would reduce manufacturing time and costs as they are simpler than the inverted U-shape of Nasu while maintaining the same functionality by defining a deformable part that fixes the sleeve apparatus to the seat frame.
Re. Cl. 3, Nasu fails to disclose L-shaped recesses. Ronzi teaches a sleeve apparatus where the two recesses are configured to be L-shaped (See Fig. 9). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Ronzi’s teaching of two recesses are configured to be L-shaped. Doing so would create a fixed end deformable part, as opposed to the cantilevered part of Nasu, where the distribution of force across two restrained points when in use makes the deformable part formed in Ronzi less prone to a weakened fit due to long-term wear and tear.
Re. Cl. 6, Nasu discloses that the generally inverted U-shaped recess form a deformable part, but fails to disclose L-shaped recesses. Ronzi teaches two recesses configured to be L-shaped and the L-shaped peaks of the two recesses are conjugate with one another (See Fig. 9). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Ronzi’s teaching of two recesses configured to be L-shaped and the L-shaped peaks of the two recesses are preferably conjugate with one another by positioning the recesses of Ronzi to align with the orientation of the recess in Nasu. Doing so would result in a deformable part with the same functionality as the deformable part of Nasu, with the improved tolerance, longevity, and stiffness of the deformable part of Ronzi.
Re. Cl. 7, Nasu discloses the sleeve apparatus according to claim 1, wherein the sleeve apparatus is a one-piece injection-molded part (Para. 0024), and wherein the sleeve apparatus does not comprise over-molded parts (Para. 0024).
Re. Cl. 8, Nasu discloses the sleeve apparatus according to claim 1, wherein the deformable part comprises a thickened portion configured to contact the frame of the vehicle seat (Fig. 3, Ref. 315).
Re. Cl. 9, Nasu discloses the sleeve apparatus according to claim 1, wherein the thickened portion of the deformable part has dimensions such that the deformable part is pushed towards the inner axial passageway when the sleeve apparatus is inserted into the frame of the vehicle seat (Fig. 3, Ref. 315, Para. 0026).
Re. Cl. 10, Nasu discloses the sleeve apparatus according to claim 1, wherein the deformable part (Fig. 3, Ref. 315) comprises a projection extending across the outer surface of the tubular wall (Fig. 3, Ref. 316), wherein the projection defines a latch (Fig. 3, Ref. 316) that is suitable for securing the sleeve apparatus within the frame of the vehicle seat, in particular in a longitudinal direction of the sleeve apparatus (See Fig. 3).
Re. Cl. 11, Nasu discloses the sleeve apparatus according to claim 10, wherein the projection is substantially ramp-like in form (Fig. 3, Ref. 316), and its thickness increases gradually from a distal end of the deformable part towards a proximal end of the deformable part, wherein the projection defines a shoulder portion for engagement into a recess of the frame of the vehicle seat when it is in use (Para. 0026).
Re. Cl. 12, Nasu discloses the sleeve apparatus according to claim 1, wherein the deformable part comprises a protruding portion (Fig. 3, Ref. 316) at a lower region of the deformable part (Fig. 3, Ref. 315), which is configured to extend beyond the outer surface when a rod of a headrest is arranged in the sleeve apparatus and cooperates with a frame of a vehicle seat (Para. 0026).
Re. Cl. 14, Nasu discloses the sleeve apparatus according to claim 12, wherein the protruding portion is formed integrally in or on the deformable part (Para. 0024), and the sleeve apparatus having the deformable part with the protruding portion is a one-piece injection-molded part (Para. 0024).
Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Nasu in view of Ronzi and Yokota as applied to claims 1 – 3, 6 – 12, & 14 above, and further in view of Aquillue et al. US 20150329021 A1 (hereinafter Aquillue).
Re. Cl. 13, Nasu fails to disclose an inwardly offset protruding portion. Aquillue teaches a protruding portion configured to not extend beyond the outer surface when no rod of a headrest is arranged in the sleeve apparatus (Fig. 1, Ref. 5; Para. 0012). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Aquillue’s teaching of a protruding portion configured to not extend beyond the outer surface when no rod of a headrest is arranged in the sleeve apparatus. Doing so would simplify the assembly process as the insertion of the sleeve apparatus into the seat frame would have no resistance from the deformable
part. The protruding portion would not engage with the frame until the headrest rod was inserted, fixing the rod and sleeve in the frame as desired.
Claim 15 - 17 are rejected under 35 U.S.C. 103 as being unpatentable over Nasu in view of Ronzi and Yokota as applied to claims 1 – 3, 6 – 12, & 14 above, and in further view of Bivens US 20230071448 A1 (hereinafter Bivens).
Re. Cl. 15, Nasu fails to disclose a stand-away annulus. Bivens teaches a protruding portion configured as a stand-away annulus (Fig. 2, Ref. 214d) having an opening being configured as a semicircular annular segment or three-quarter annular segment, wherein the opening is configured as a slot in the stand-away annulus or missing annular segment (See Fig. 2). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Bivens teaching of a stand-away annulus having an opening being configured as a semicircular annular segment or three-quarter annular segment, wherein the opening is configured as a slot in the stand-away annulus or missing annular segment. Doing so would result in the annular protruding portion would undergoing radial deformation, rather than the axial deformation in Nasu, which requires less force and would result in easier assembly.
Re. Cl. 16, Nasu fails to disclose the form or material of an annulus. Bivens teaches that the opening is formed outwardly, and the stand-away annulus is preferably configured to be shape-retaining and elastic, specifically that it is made of an elastomeric material (Fig. 2, Ref. 214d, Para. 0029). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Biven’s teaching of the opening formed outwardly and the stand-away annulus is preferably configured to be shape-retaining and elastic. Doing so would reduce tolerances for a tighter fit between the headrest components to minimize BSR and mitigate any user annoyance and discomfort (Para. 0020).
Re. Cl. 17, Nasu fails to disclose the configuration or direction of an annulus. Bivens teaches that in the transverse direction of the deformable part, the stand-away annulus is configured as an annular cylinder at or in the deformable part, and preferably wherein the annular cylinder is configured in the transverse direction over a portion or over the entire width of the deformable part (Fig. 2, Ref. 214d). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Biven’s teaching of that in the transverse direction of the deformable part, the stand-away annulus is configured as an annular cylinder at or in the deformable part, and preferably wherein the annular cylinder is configured in the transverse direction over a portion or over the entire width of the deformable part. Doing so would optimize fit between the headrest components with reduced tolerances to optimize user experience by mitigating BSR.
Claims 18 – 20 are rejected under 35 U.S.C. 103 as being unpatentable over Nasu in view of Ronzi and Yokota as applied to claims 1 – 3, 6 – 12, & 14 above, and in further view of Hagan et al. US 9446692 B2 (hereinafter Hagan).
Re. Cl. 18, Nasu fails to disclose any ribbing structures. Hagan teaches a protruding portion configured as one or more ribs (Fig. 37, Ref. 614), wherein the one or more ribs are each cuboidal in shape (See Fig. 37). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Hagan’s teaching of a protruding portion configured as one or more ribs, wherein the one or more ribs are each cuboidal in shape. Doing so would reduce radial stiffness in the protruding portion, allowing for easer insertion into a frame (Col. 17, Ln. 47-50). When the ribbing structure is compressed, the apertures between the ribs can at least partially close, thereby enhancing the structural stiffness in an inserted state (Col. 17, Ln. 53-55).
Re. Cl. 19, Nasu fails to disclose any configuration of ribs. Hagan teaches that the one or more ribs are configured in the transverse direction over a portion or over the entire width of the deformable part (Fig. 37, Ref. 614), and extend outwardly orthogonally to the axis of the axial passageway, or wherein the one or more ribs are configured in the longitudinal direction over a portion or over the entire length of the deformable part and extend parallel to the axis of the axial passageway (See Fig. 37B). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Hagan’s teaching of one or more ribs are configured in the transverse direction over a portion or over the entire width of the deformable part, and extend outwardly orthogonally to the axis of the axial passageway, or wherein the one or more ribs are configured in the longitudinal direction over a portion or over the entire length of the deformable part and extend parallel to the axis of the axial passageway. Doing so would create various configurations of ribs have different apertures between them, allowing for tailored levels of structural stiffness in each configuration.
Re. Cl. 20, Nasu fails to disclose any configuration of ribs. Hagan teaches the plurality of ribs are configured to be offset from one another on the deformable part in the longitudinal direction of the deformable part, and wherein the length of the ribs is configured to differ in their transverse direction, and preferably the length of the offset ribs decreases in the lower, or distal, direction of the deformable part (Col. 18, Ln. 27-33). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Hagan’s teaching of the plurality of ribs are configured to be offset from one another on the deformable part in the longitudinal direction of the deformable part, and/or wherein the length of the ribs is configured to differ in their transverse direction, and preferably the length of the offset ribs decreases in the lower, or distal, direction of the deformable part. Doing so would allow for a non-uniform structural stiffness across the ribs, further ensuring an optimal fit and BSR minimization.
Claims 21 & 22 are rejected under 35 U.S.C. 103 as being unpatentable over Nasu in view of Ronzi and Yokota as applied to claims 1 – 3, 6 – 12, & 14 above, and in further view of Ford US 20030205925 A1 (hereinafter Ford).
Re. Cl. 21, Nasu discloses a sleeve apparatus for a headrest (Fig. 3, Ref. 30), comprising a sleeve body (Fig. 3, Ref. 31) for insertion into a frame of a vehicle seat, wherein, during use, the sleeve body is inserted into the frame of the vehicle seat (Para. 0023) and is generally located therein, wherein the sleeve body comprises a tubular wall (See Fig. 3) defining an inner axial passageway (Fig. 3, Ref. 34) having an inner surface (Fig. 3, Ref. 313) configured to receive a rod of a headrest, wherein the tubular wall comprises an outer surface (Fig. 3, Ref. 312) opposite the inner surface of the tubular wall, and wherein the tubular wall comprises at least two recesses (Fig. 3, Ref. 314) extending in a longitudinal direction of the tubular wall between the outer surface and the inner surface, wherein the recesses define a deformable part (Fig. 3, Ref. 315) of the tubular wall of the sleeve apparatus and wherein the deformable part comprises a protruding portion (Fig. 3, Ref. 316), which is configured to extend beyond the outer surface when a rod of a headrest is arranged in the sleeve apparatus and cooperates with a frame of a vehicle seat (Para. 0026).
Re. Cl. 21, Nasu as modified by Ronzi and Yokota fails to disclose ribs. Ford teaches a plurality of ribs (Fig. 2, Ref. 34) extending outwardly from the surface of the guide sleeve (See Fig. 2). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the protruding portion of Nasu’s invention with Ford's teaching of a plurality of protruding ribs. Doing so creates a deformable surface on the deformable part that interfaces with the seat frame for an optimal pressure fit.
Re. Cl. 22, Nasu fails to disclose ribbing. Ford teaches that the plurality of ribs cooperate with a shoulder portion of the vehicle seat frame to form a friction fit between the vehicle seat frame, sleeve body, and headrest (Fig. 2, Ref. 34; Para. 0016). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify Nasu with Ford's teaching of a plurality of ribs that cooperate with a shoulder portion of the vehicle seat frame. Doing so minimizes buzzing or rattling noises due to intermittent contact between the components (Para. 0016).
Response to Arguments
Applicant's arguments filed July 28th, 2026 have been fully considered but they are not persuasive. The additional subject matter pertaining to claim 1 has been fully considered but it is not persuasive.
In response to applicant’s arguments that Ronzi is silent to a groove, drawings can anticipate claims if they clearly show the structure which is claimed, and an enabling picture may be used to reject claims to the article (See MPEP § 2121.04 and 2125). Figure 9 of Ronzi shows two substantially parallel L-shaped grooves that form the resilient feature and a groove between them. Additionally, the tubular wall must include some uncut or unrecessed portion between the recesses, forming a groove, or they would be a singular U-shaped groove. The device of Ronzi therefore appears to disclose a groove between two recesses. Thus, the applicant’s arguments are not persuasive and the rejection of claim 1 as obvious over Nasu in view of Ronzi and Yokota is maintained.
In response to applicant’s arguments that a person of ordinary skill in the art would have no motivation to modify Nasu with Yokota because the arts are not analogous, a reference is analogous art to the claimed invention if: (1) the reference is from the same field of endeavor as the claimed invention (even if it addresses a different problem); or (2) the reference is reasonably pertinent to the problem faced by the inventor (even if it is not in the same field of endeavor as the claimed invention) (See MPEP § 2141.01(a)). The purpose of Yokota’s recessed portion is to ensure deformation in a particular section the bar portion (Para. 0062). Additionally, plastic and elastic deformations occur in adjacent regions of the same stress-strain curve and restricting the location of deformation to an intended region would be the same field of endeavor. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to use the recessed portion of Yokota to localize the region of deformation in a vehicle seat headrest. Thus, the applicant’s arguments are not persuasive and the rejection of claim 1 as obvious over Nasu in view of Ronzi and Yokota is maintained.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Ronzi et al. US 20140028072 A1, Muto et al. US 8967721 B2, Hans et al. US 20170088024 A1.
THIS ACTION IS MADE FINAL. 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.
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/GELILA KEBEDE/Examiner, Art Unit 3632
/TERRELL L MCKINNON/Supervisory Patent Examiner, Art Unit 3632
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