DETAILED ACTION
This is the second Office Action regarding application number 19/009,273, filed on 01/03/2025, which claims priority to PRO 63/567,464, filed on 03/20/2024, PRO 63/554,254, filed on 02/16/2024, PRO 63/550,122, filed on 02/06/2024, and PRO 63/621,144, filed on 01/16/2024.
This action is in response to the Applicant’s Response received 07/06/2026.
Status of Claims
Claims 1-20 are currently pending.
Claims 1, 5, 8-11, 14, and 16-19 are amended.
Claims 1-20 are examined below.
The rejections under sections 102 and 112 are withdrawn in light of the applicant’s amendments.
Upon further examination, the Office has set forth a new ground of rejection.
No claim is allowed.
Response to Arguments
The Applicant’s arguments received 07/06/2026 have been carefully considered but they are moot in light of the Office’s new grounds of rejection.
Claim Rejections - 35 USC § 112
Written Description - New Matter
Claims 1-20 are rejected under 35 U.S.C. 112(a) as failing to comply with the written description requirement. The claims contain 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 had possession of the claimed invention. Each of the independent claims now recite that both the first and second rail self-centering members are located at the respective frame support arms further from the central longitudinal axis than their respective rail clamps. Page 9 of the applicant’s remarks identify paragraphs 100-122 and Figs. 10A-10O to support the amendments. However, no portion of the specification or drawings support or illustrate such an arrangement as claimed.
In each of the drawings, only the second rail self-centering member 1011 is illustrated to possess such a relative arrangement with respect to the rail clamps, and self-centering member 1010 is in fact closer than its respective rail clamps.
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The examiner requests that the applicant explain its position on the written support matter, and further identify in its illustrations its own understanding of its disclosure and drawings if it is different than the examiner’s.
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 of this title, 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.
Claims 1-20 are rejected under 35 U.S.C. 103 as being unpatentable over YADLAPALLI (US 2023/0402963 A1).
Regarding claim 1, YADLAPALLI teaches a self-centering rail system comprising:
a first solar module frame comprising a first flange and a first frame self-centering member (146) included at least at the first flange (support flanges 142, Fig. 16);
a second solar module frame comprising a second flange and a second frame self- centering member included at least at the second flange (figures clearly illustrate that the rail system is used to couple to at least two module frames, so a second frame is present); and
a self-centering rail (support rail 212) comprising:
a bottom portion that is configured to interface with a torque tube so as to orient a central longitudinal axis of the self-centering rail in an east-west direction (the examiner interprets this limitation as intended use, since it is ultimately up to the installer to decide the physical orientation for arranging the torque tube of the solar array, and east-west direction are one common option that is well-known; the bottom portion is simply the bottom surface that contacts the torque tube),
a first side portion comprising a first frame support arm, a first rail clamp, a second rail clamp, and a first rail self-centering member, wherein each of the first rail clamp, the second rail clamp, and the first rail self-centering member is at the first frame support arm (see annotated Fig. 28 below with callouts to each recite feature; the examiner also asserts that the various first and second portions are equally anticipating when split along the A axis in Fig. 28 and also when split along the torque tube direction);
a second side portion comprising a second frame support arm, a third rail clamp, a fourth rail clamp, and a second rail self-centering member, wherein each of the third rail clamp, the fourth rail clamp, and the second rail self-centering member is at the second frame support arm (see annotated Fig. 28 below with callouts to each recite feature),
wherein the first side portion is configured to couple to the first solar module frame when the first flange is received at the first rail clamp and the second rail clamp and when the first frame self-centering member is received at the first rail self-centering member (Fig. 36 illustrates how the frame engages to couple with the rail exactly as recited), and
wherein the second side portion is configured to couple to the second solar module frame when the second flange is received at the third rail clamp and the fourth rail clamp and when the second frame self-centering member is received at the second rail self-centering member (Fig. 36 illustrates how the frame engages to couple with the rail exactly as recited).
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YADLAPALLI does not disclose expressly that the first and second rail self-centering members are located at their respective frame support arms further from the central longitudinal axis of the self-centering rail than the respective rail clamps of each side portion. However, the examiner identifies two rationales that render the necessary modification of the prior art prima facie obvious. First, a modification to swap the positions of the rail self-centering members with the rail clamps with respect to the central longitudinal axis is only a simple reversal of parts. Second, said modification is also only a simple rearrangement of parts. Both types of modifications would not be expected by skilled artisans to materially modify the operation of the claimed invention, and would also be seen by said skilled artisans to be routine and obvious matters of design choice. MPEP 2144.04(VI)(A) and (C). Further, YADLAPALLI also indicates to skilled artisans that the relative positions of these features are to be disposed according to the design needs of the clamp assembly (para. 102). Skilled artisans would sense and possess sufficient motivation and guidance from the prior art reference to make the necessary modifications that would yield the arrangement of the claimed invention and the relative positions of the recited features, without any expectation of unexpected or surprising results or outcomes.
Regarding claim 2, YADLAPALLI teaches the system of claim 1, wherein the first solar module frame comprises a first set of retention slots (146a/b, Fig. 16) spaced from a first side of the first frame self-centering member at the first flange, and wherein the first solar module frame comprises a second set of retention slots spaced from a second, opposite side of the first frame self-centering member at the first flange.
Regarding claim 3, YADLAPALLI teaches the system of claim 2, wherein the first rail clamp is spaced from a first side of the first rail self-centering member at the first frame support arm, and wherein the second rail clamp is spaced from a second, opposite side of the first rail self-centering member at the first frame support arm (see Fig. 28 illustrating recited arrangement).
Regarding claim 4, YADLAPALLI teaches the system of claim 3, wherein the first rail clamp, the second rail clamp, and the first rail self-centering member extend out from a top side of the first frame support arm (see Fig. 28 illustrating recited arrangement).
Regarding claim 5, YADLAPALLI teaches the system of claim 4, wherein the self-centering rail comprises a bottom side that is opposite the top side of the first frame support arm, and wherein the bottom side of the self-centering rail comprises a generally semi-circular cross-sectional geometry configured to receive a torque tube (Fig. 5 illustrates a “generally” semi-circular cross-sectional geometry configured to receive a torque tube; the examiner interprets “generally” to allow for shapes that are not perfectly semi-circular, but also those that are partially semi-circular).
Regarding claim 6, YADLAPALLI teaches the system of claim 4, wherein each of the first rail clamp and the second rail clamp comprise teeth members, and wherein each of the first set of retention slots and the second set of retention slots comprises slots extending through the first flange (see that Fig. 32 illustrates claims comprising teeth members; Fig. 16 illustrates the slots extending through the flange).
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Regarding claim 7, YADLAPALLI teaches the system of claim 6, wherein the teeth members of the first rail clamp engage the slots of the first set of retention slots extending through the first flange when the first flange is received at the first rail clamp and the second rail clamp and when the first frame self-centering member is received at the first rail self-centering member (Fig. 36 illustrates the recited arrangement).
Regarding claim 8, YADLAPALLI teaches the system of claim 7, wherein the first frame self-centering member comprises a slot extending into the first flange (Fig. 16), and wherein, as the first rail self-centering member is received at the slot extending into the first flange, the first rail self-centering member is configured to adjust a position of the first solar module frame relative to a torque tube in an east-west direction (Fig. 36 illustrates some space to adjust east-west direction position).
Regarding claim 9, YADLAPALLI teaches the system of claim 7, wherein the first rail clamp is radially spaced apart from the first rail self-centering member to define a landing surface radially between the first rail clamp and the first rail-self centering member (Figs. illustrate radial spacing similar to applicant).
Regarding claim 10, YADLAPALLI teaches the system of claim 9, wherein the first frame support arm terminates at a first floating end that defines an outside bound of the first side portion, and wherein the first rail-self centering member is closer to the first floating end than is the first rail clamp (annotated Fig. 28 illustrates the first rail-self centering member is closer to the first floating end than is the first rail clamp.
Regarding claim 11, YADLAPALLI teaches a self-centering rail comprising:
a bottom portion that is configured to interface with a torque tube so as to orient a central longitudinal axis of the self-centering rail in an east-west direction (the examiner interprets this limitation as intended use, since it is ultimately up to the installer to decide the physical orientation for arranging the torque tube of the solar array, and east-west direction are one common option that is well-known; the bottom portion is simply the bottom surface that contacts the torque tube),
a first side portion comprising a first frame support arm, a first rail clamp, a second rail clamp, and a first rail self-centering member, wherein each of the first rail clamp, the second rail clamp, and the first rail self-centering member is at the first frame support arm (see annotated Fig. 28 below with callouts to each recite feature);
and a second side portion comprising a second frame support arm, a third rail clamp, a fourth rail clamp, and a second rail self-centering member, wherein each of the third rail clamp, the fourth rail clamp, and the second rail self-centering member is at the second frame support arm (see annotated Fig. 28 below with callouts to each recite feature),
wherein the first side portion is configured to couple to a first solar module frame when a first flange of the first solar module frame is received at the first rail clamp and the second rail clamp and when a frame self-centering member of the first solar module frame is received at the first rail self-centering member (the examiner determines that this claim does not require the first or second modules frames be present, because the claim literally recites in its preamble only a rail; and further, that the prior art rail would in fact be capable of coupling to a solar module frame also so configured), and
wherein the second side portion is configured to couple to a second solar module frame when a second flange of the second solar module frame is received at the third rail clamp and the fourth rail clamp and when a frame self-centering member of the second solar module frame is received at the second rail self-centering member (the examiner determines that this claim does not require the first or second modules frames be present, because the claim literally recites in its preamble only a rail; and further, that the prior art rail would in fact be capable of coupling to a solar module frame also so configured).
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YADLAPALLI does not disclose expressly that the first and second rail self-centering members are located at their respective frame support arms further from the central longitudinal axis of the self-centering rail than the respective rail clamps of each side portion. However, the examiner identifies two rationales that render the necessary modification of the prior art prima facie obvious. First, a modification to swap the positions of the rail self-centering members with the rail clamps with respect to the central longitudinal axis is only a simple reversal of parts. Second, said modification is also only a simple rearrangement of parts. Both types of modifications would not be expected by skilled artisans to materially modify the operation of the claimed invention, and would also be seen by said skilled artisans to be routine and obvious matters of design choice. MPEP 2144.04(VI)(A) and (C). Further, YADLAPALLI also indicates to skilled artisans that the relative positions of these features are to be disposed according to the design needs of the clamp assembly (para. 102). Skilled artisans would sense and possess sufficient motivation and guidance from the prior art reference to make the necessary modifications that would yield the arrangement of the claimed invention and the relative positions of the recited features, without any expectation of unexpected or surprising results or outcomes.
Regarding claim 13, YADLAPALLI teaches the rail of claim 12, wherein the first rail clamp, the second rail clamp, and the first rail self-centering member extend out from a top side of the first frame support arm, and
wherein the third rail clamp, the fourth rail clamp, and the second rail self-centering member extend out from a top side of the second frame support arm (all of the clamps and self-centering members extend out and upward from a top side of the support arms, see annotated Fig. 28).
Regarding claim 14, YADLAPALLI teaches the rail of claim 13, wherein the self-centering rail comprises a bottom side that is opposite the top side of the first frame support arm and opposite the top side of the second frame support arm, and wherein the bottom side of the self-centering rail comprises a generally semi-circular cross-sectional geometry configured to receive a torque tube (Fig. 5 illustrates a “generally” semi-circular cross-sectional geometry configured to receive a torque tube; the examiner interprets “generally” to allow for shapes that are not perfectly semi-circular, but also those that are partially semi-circular).
Regarding claim 15, YADLAPALLI teaches the rail of claim 12, wherein each of the first rail clamp and the second rail clamp comprise teeth members, and wherein each of the third rail clamp and the fourth rail clamp comprise teeth members (see that Fig. 32 illustrates claims comprising teeth members).
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Regarding claim 16, YADLAPALLI teaches the rail of claim 12, wherein the first rail clamp is radially spaced apart from the first rail self-centering member to define a first landing surface, at the first side portion, radially between the first rail clamp and the first rail-self centering member, and wherein the third rail clamp is radially spaced apart from the second rail self- centering member to define a second landing surface, at the second side portion, radially between the third rail clamp and the second rail self-centering member (Figs. Illustrate radial spacing similar to applicant).
Regarding claim 17, YADLAPALLI teaches the rail of claim 16, wherein the first frame support arm terminates at a first floating end that defines an outside bound of the first side portion, and wherein the first rail-self centering member is closer to the first floating end than is the first rail clamp, and wherein the second frame support arm terminates at a second floating end that defines an outside bound of the second side portion, and wherein the second rail self-centering member is closer to the second floating end than is the third rail clamp (illustrated in additional annotated Fig. 28 below).
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Regarding claim 18, YADLAPALLI teaches a method for coupling a first solar module frame and a second solar module frame to a self-centering rail, a bottom portion that is configured to interface with a torque tube so as to orient a central longitudinal axis of the self-centering rail in an east-west direction (the examiner interprets this limitation as intended use, since it is ultimately up to the installer to decide the physical orientation for arranging the torque tube of the solar array, and east-west direction are one common option that is well-known; the bottom portion is simply the bottom surface that contacts the torque tube), the method comprising the steps of: placing the first solar module frame at a first side portion of the self-centering rail with first self-centering member alignment;
moving the first solar module frame relative to the self-centering rail to engage one or more rail clamps at the first side portion of the self-centering rail to the first solar module frame;
placing a second solar module frame at a second, opposite side portion of the self-centering rail with second self-centering member alignment; and
moving the second solar module frame relative to the self-centering rail to engage one or more rail clamps at the second side portion of the self-centering rail to the second solar module frame (see Figs. 28 and 36 illustrating the claimed components and method steps of assembling module frames to a torque tube rail; see also rejection rationale of substantially limitations above).
YADLAPALLI does not disclose expressly that the first and second rail self-centering members are located at their respective frame support arms further from the central longitudinal axis of the self-centering rail than the respective rail clamps of each side portion. However, the examiner identifies two rationales that render the necessary modification of the prior art prima facie obvious. First, a modification to swap the positions of the rail self-centering members with the rail clamps with respect to the central longitudinal axis is only a simple reversal of parts. Second, said modification is also only a simple rearrangement of parts. Both types of modifications would not be expected by skilled artisans to materially modify the operation of the claimed invention, and would also be seen by said skilled artisans to be routine and obvious matters of design choice. MPEP 2144.04(VI)(A) and (C). Further, YADLAPALLI also indicates to skilled artisans that the relative positions of these features are to be disposed according to the design needs of the clamp assembly (para. 102). Skilled artisans would sense and possess sufficient motivation and guidance from the prior art reference to make the necessary modifications that would yield the arrangement of the claimed invention and the relative positions of the recited features, without any expectation of unexpected or surprising results or outcomes.
Regarding claim 19, YADLAPALLI teaches the method of claim 18, wherein placing the first solar module frame at the first side portion of the self-centering rail with first self-centering member alignment comprises placing the first solar module frame at the first side portion of the self-centering rail with a first frame self- centering member at the first solar module frame aligned with a first rail self-centering member at the first side portion of the self-centering rail, and
wherein placing the second solar module frame at the second side portion of the self- centering rail with second frame self-centering member alignment comprises placing the second solar module frame at the second side portion of the self-centering rail with a second rail self-centering member at the second side portion of the self-centering rail (see Figs. 28 and 36 illustrating the claimed components and method steps of assembling module frames to a torque tube rail; see also rejection rationale of substantially limitations above).
Regarding claim 20, YADLAPALLI teaches the method of claim 19, wherein placing the first solar module frame at the first side portion of the self- centering rail with first self-centering member alignment further comprises placing the first solar module frame at a first landing surface that is at the first side portion and spaced radially between the one or more rail clamps and the first rail self-centering member at the first side portion, and wherein placing the second solar module frame at the second side portion of the self-centering rail with second self-centering member alignment further comprises placing the second solar module frame at a second landing surface that is at the second side portion and spaced radially between the one or more rail clamps and the second rail self-centering member at the second side portion (see Figs. 28 and 36 illustrating the claimed components and method steps of assembling module frames to a torque tube rail; see also rejection rationale of substantially limitations above).
Conclusion
No claim is allowed.
The Applicant’s amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). The Applicant is reminded of the extension of time policy as set forth in 37 C.F.R. § 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 mailing date of this final action.
Contact Information
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANGELO TRIVISONNO whose telephone number is (571) 272-5201 or by email at <angelo.trivisonno@uspto.gov>. The examiner can normally be reached on MONDAY-FRIDAY, 9:00a-5:00pm EST. The examiner's supervisor, NIKI BAKHTIARI, can be reached at (571) 272-3433.
/ANGELO TRIVISONNO/
Primary Examiner
Prosecution Insights