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 .
Status of Claims
This Office Action is in response to Applicant’s Response dated May 12, 2026. Claims 1-20 are presently pending and are presented for examination.
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on September 4, 2026 has been entered.
Response to Amendments
In response to Applicant’s amendments dated September 4, 2026, Examiner withdraws the previous abstract objections; withdraws the previous abstract objections; and withdraws the previous prior art rejections
Response to Arguments
Applicant’s arguments with respect to all pending claims filed September 4, 2026, the claims have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
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.
Claims 21-24 and 26 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. Specifically, Examiner has found no mention of “yaw” anywhere in the original disclosure and has failed to find any disclosure pertaining to the estimating of yaw or any other disclosure pertaining to yaw. For at least these reasons, claims 21-24 and 26 are considered new matter and are rejected as such.
Claim Rejections - 35 USC § 102
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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, 10, and 12-26 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by U.S. Pub. No. 2020/0391840 (hereinafter, “Inoue”; newly of record).
Regarding claim 1, Inoue discloses A method of controlling movement, relative to a watercraft, of at least one steering device on the watercraft (see at least [0006] and the publication generally), the method comprising:
causing the at least one steering device to move relative to the watercraft in response to (see at least [0006] and [0052]; a controller may cause the steering device to move relative to the watercraft responsive to the following), at least:
a steering-input position of a steering input relative to the watercraft (see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; steering angle data comprising the steering angle of the steering handle (i.e., steering input)); and
an estimated heading effect caused by a non-steering influence on movement of the watercraft (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence)).
Regarding claim 2, Inoue discloses An apparatus for controlling movement, relative to a watercraft, of at least one steering device on the watercraft (see at least [0006] and the publication generally), the apparatus comprising:
at least one controller configured to, at least, cause the at least one steering device to move relative to the watercraft in response to(see at least [0006] and [0052]; a controller may cause the steering device to move relative to the watercraft responsive to the following), at least:
a steering-input position of a steering input relative to the watercraft (see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; steering angle data comprising the steering angle of the steering handle (i.e., steering input)); and
an estimated heading effect caused by a non-steering influence on movement of the watercraft (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence)).
Regarding claim 3, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses wherein the estimated heading effect caused by the non-steering influence on movement of the watercraft comprises an estimated non-steering influence on a direction of movement of the watercraft (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence) which impacts a steering angle of the watercraft).
Regarding claim 4, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses wherein the estimated heading effect caused by the non-steering influence on movement of the watercraft comprises an estimated non-steering influence on a rate of change over time of a direction of movement of the watercraft (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence) which impacts the angular velocity of the watercraft (i.e., rate of change over time of a direction of movement of the watercraft)).
Regarding claim 5, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses wherein the at least one controller is further configured to, at least, estimate the estimated heading effect caused by the non-steering influence on movement of the watercraft (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence)).
Regarding claim 10, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses wherein the at least one controller is configured to estimate the estimated heading effect caused by the non-steering influence on movement of the watercraft in response to at least estimated positions of trim tabs of the watercraft (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence)).
Regarding claim 12, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses wherein the at least one controller is further configured to, at least, cause the at least one steering device to move in response to, at least:
the steering-input position of the steering input relative to the watercraft (see at least [0037]; the steering handle input); and
an association between steering-input positions of the steering input relative to the watercraft and respective target quantities related to direction of the watercraft (see at least [0037]-[0038]; target propulsion quantities related to the input direction are associated).
Regarding claim 13, Inoue discloses all of the limitations of claim 12. Additionally, Inoue discloses wherein causing the at least one steering device to move comprises causing the at least one steering device to move in response to, at least, a direction difference between:
a measured direction quantity related to the direction of travel of the watercraft (see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; steering angle data used to find the second steering angle includes measured direction information corresponding to the direction of travel of the watercraft); and
a desired direction quantity related to the direction of travel of the watercraft (see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; the second steering angle may be considered the desired direction quantity and it corresponds to the direction of travel of the watercraft).
Regarding claim 14, Inoue discloses all of the limitations of claim 13. Additionally, Inoue discloses wherein the at least one controller is further configured to, at least, identify the desired direction quantity according to ((see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; the second steering angle may be considered the desired direction quantity and it corresponds to the direction of travel of the watercraft)), at least:
the steering-input position of the steering input (see at least [0037]; input into the steering handle); and
the association between steering-input positions of the steering input relative to the watercraft and respective target quantities (see at least [0037]-[0038]; target propulsion quantities related to the input direction are associated).
Regarding claim 15, Inoue discloses all of the limitations of claim 14. Additionally, Inoue discloses wherein the target, measured, and desired quantities are respective directions of travel of the watercraft ((see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; all variables correspond to the steering angle (i.e., direction of travel) of the watercraft).
Regarding claim 16, Inoue discloses all of the limitations of claim 14. Additionally, Inoue discloses wherein the target, measured, and desired quantities are respective rates of change over time of the direction of travel of the watercraft ((see at least [0006], [0037], [0065], [0076], and [0085]-[0086]; all variables correspond to the steering angle (i.e., direction of travel) of the watercraft over time).
Regarding claim 17, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses wherein the at least one controller is further configured to, at least, cause the at least one steering device to move in response to, at least, a heading difference between:
a measured heading quantity related to a heading of the watercraft (see at least [0130]-[0139]; a measured heading is determined); and
a measured direction quantity related to a direction of travel of the watercraft (see at least [0130]-[0139]; a measured direction of travel is determined and used to determine the yaw difference).
Regarding claim 18, Inoue discloses all of the limitations of claim 17. Additionally, Inoue discloses wherein the measured heading quantity is a measured heading of the watercraft (see at least [0130]-[0139]; a measured heading is determined), and
the measured direction quantity is a measured direction of travel of the watercraft (see at least [0130]-[0139]; a measured direction of travel is determined and used to determine the yaw difference).
Regarding claim 19, Inoue discloses all of the limitations of claim 17. Additionally, Inoue discloses wherein the measured heading quantity is a measured rate of change over time of heading of the watercraft (see at least [0130]-[0139]; a measured heading change over time is determined), and
the measured direction quantity is a measured rate of change over time of direction of travel of the watercraft (see at least [0130]-[0139]; a measured direction of travel over time is determined and used to determine the yaw rate difference).
Regarding claim 20, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses A system comprising:
the apparatus of claim 2 (see at least the claim 2 citations);
the watercraft, wherein the apparatus is on the watercraft (see at least [0006]-[0009]; the apparatus is disposed on the watercraft);
the at least one steering device, wherein the at least one steering device comprises at least one steering actuator operable to steer the watercraft (see at least [0033]-[0037]; the steering actuator), and the at least one steering actuator is coupled to at least one engine or to at least one rudder on the watercraft and operable to change a steering angle of the at least one engine or of the at least one rudder relative to the watercraft to steer the watercraft in response to movement of the at least one steering actuator relative to the watercraft (see at least [0033]-[0037]); and
the steering input, wherein the steering input comprises an electronic helm on the watercraft (see at least [0037]; the steering handle (i.e., steering helm)).
Regarding claim 21, Inoue discloses all of the limitations of claim 2. Additionally, Inoue discloses wherein the estimated heading effect caused by the non-steering influence on movement of the watercraft comprises an estimate of yaw of the watercraft other than yaw induced by the steering device (see at least [0048]-[0049]; the yaw associated with the trim tabs).
Regarding claim 22, Inoue discloses all of the limitations of claim 21. Additionally, Inoue discloses wherein the yaw of the watercraft other than the yaw induced by the steering device is caused by a non-steering vessel control (see at least [0048]-[0049]; the yaw associated with the trim tabs (i.e., non-steering vessel control)).
Regarding claim 23, Inoue discloses all of the limitations of claim 21. Additionally, Inoue discloses wherein the yaw of the watercraft other than yaw induced by the steering device is induced at least in part by trim tabs of the watercraft (see at least [0048]-[0049]; the yaw associated with the trim tabs).
Regarding claim 24, Inoue discloses all of the limitations of claim 21. Additionally, Inoue discloses wherein the yaw of the watercraft other than yaw induced by the steering device is induced by at least one external force that is applied to the watercraft (see at least [0048]-[0049]; the yaw associated with the trim tabs which is caused by fluid resistance (i.e., external force) against the trim tabs).
Regarding claim 25, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses wherein the at least one controller is configured to implement a feed-forward controller to estimate the estimated heading effect caused by the non-steering influence on movement of the watercraft (see at least [0006]-[0007], [0037], [0065], [0076], and [0085]-[0086]; the controller estimating the needed update via the look-up table may be considered a feed-forward controller which estimates the movement influence on the watercraft).
Regarding claim 26, Inoue discloses A method of steering a watercraft (see at least Fig. 1, [0006] and the publication generally), the method comprising:
determining a computed position of a steering device relative to a hull of the watercraft based on at least an operator input defining a desired heading of the watercraft and an estimated variance from the desired heading of the watercraft caused by one or more influences on the watercraft other than yaw induced by the steering device (see at least [0006], [0076], and [0085]-[0086]; the second steering angle is based on the first steering angle and the impact of the trim tab adjustment (i.e., non-steering influence)); and
positioning the steering device in the determined computed position relative to the hull (see at least Fig. 1, Fig. 6A-6B, and [0032]-[0037]; the steering device is positioned relative to the hull).
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 is incorrect, any correction of the statutory basis for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claims 6-9 and 11 are rejected under 35 U.S.C. 103 as being unpatentable over Inoue, as applied to claim 5 above, in view of NPL document “Obtaining the Practical Formula for the Trim-tab Dimensions to reach the minimum Drag for Planing Boat” (hereinafter, “Mohebbi”; newly of record).
Regarding claim 6, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses that the effect of the trim tabs is determined via look-up tables corresponding to the trim tab controls. However, Inoue fails to disclose the equation used. Mohebbi, in the same field of endeavor, teaches a potential equation for filling in the look up table which includes the mass of the watercraft; see at least Mohebbi at least at Section 2; the trim tab formula for optimal trim includes a mass estimation of a watercraft.
One of ordinary skill in the art, before the effective filing date of the instant application and with a reasonable likelihood of success, would have recognized the equation of Mohebbi as an optional means of populating the look up table of Inoue as Mohebbi provides the necessary table via the corresponding equation. For at least these reasons, claim 6 is obvious over Inoue in view of Mohebbi.
Regarding claim 7, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses that the effect of the trim tabs is determined via look-up tables corresponding to the trim tab controls. However, Inoue fails to disclose the equation used. Mohebbi, in the same field of endeavor teaches a potential equation for filling in the look up table which includes the mass of the watercraft; see at least Mohebbi at least at Section 2; the trim tab formula for optimal trim takes into account frictional drag (i.e., fluid resistance)).
One of ordinary skill in the art, before the effective filing date of the instant application and with a reasonable likelihood of success, would have recognized the equation of Mohebbi as an optional means of populating the look up table of Inoue as Mohebbi provides the necessary table via the corresponding equation. For at least these reasons, claim 6 is obvious over Inoue in view of Mohebbi.
Regarding claim 8, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses that the effect of the trim tabs is determined via look-up tables corresponding to the trim tab controls. However, Inoue fails to disclose the equation used. Mohebbi, in the same field of endeavor teaches a potential equation for filling in the look up table which includes the mass of the watercraft; see at least Mohebbi at least at Section 2; the trim tab formula for optimal trim takes into account vessel speed).
One of ordinary skill in the art, before the effective filing date of the instant application and with a reasonable likelihood of success, would have recognized the equation of Mohebbi as an optional means of populating the look up table of Inoue as Mohebbi provides the necessary table via the corresponding equation. For at least these reasons, claim 6 is obvious over Inoue in view of Mohebbi.
Regarding claim 9, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses that the effect of the trim tabs is determined via look-up tables corresponding to the trim tab controls. However, Inoue fails to disclose the equation used. Mohebbi, in the same field of endeavor teaches a potential equation for filling in the look up table which includes the mass of the watercraft; see at least Mohebbi at least at Section 2; the trim tab formula for optimal trim takes into account dynamic force (i.e., engine thrust)).
One of ordinary skill in the art, before the effective filing date of the instant application and with a reasonable likelihood of success, would have recognized the equation of Mohebbi as an optional means of populating the look up table of Inoue as Mohebbi provides the necessary table via the corresponding equation. For at least these reasons, claim 6 is obvious over Inoue in view of Mohebbi.
Regarding claim 11, Inoue discloses all of the limitations of claim 5. Additionally, Inoue discloses that the effect of the trim tabs is determined via look-up tables corresponding to the trim tab controls. However, Inoue fails to disclose the equation used. Mohebbi, in the same field of endeavor teaches a potential equation for filling in the look up table which includes the mass of the watercraft; see at least Mohebbi at least at Section 2; the trim tab formula for optimal trim takes into mass distribution (i.e., ballast configuration)).
One of ordinary skill in the art, before the effective filing date of the instant application and with a reasonable likelihood of success, would have recognized the equation of Mohebbi as an optional means of populating the look up table of Inoue as Mohebbi provides the necessary table via the corresponding equation. For at least these reasons, claim 6 is obvious over Inoue in view of Mohebbi.
Additional Relevant Art (Previously of Record)
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure and may be found on the accompanying PTO-892 Notice of References Cited:
U.S. Pub. No. 2017/0038771 which pertains to navigation control of a marine vessel having a ballast, trim tabs, and a defined weight.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to TIFFANY P YOUNG whose telephone number is (313)446-6575. The examiner can normally be reached M-R 6:30 AM- 4:30 PM.
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TIFFANY YOUNG
Primary Examiner
Art Unit 3666
/TIFFANY P YOUNG/Primary Examiner, Art Unit 3666
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