Prosecution Insights
Last updated: May 29, 2026
Application No. 19/041,175

Method and Control Device for Operating a Steering Mechanism of a Vehicle

Non-Final OA §101§102
Filed
Jan 30, 2025
Priority
Feb 15, 2024 — DE 10 2024 201 391.9
Examiner
MORALES, OMAR
Art Unit
3747
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Robert Bosch GmbH
OA Round
1 (Non-Final)
58%
Grant Probability
Moderate
1-2
OA Rounds
2y 0m
Est. Remaining
77%
With Interview

Examiner Intelligence

Grants 58% of resolved cases
58%
Career Allowance Rate
289 granted / 494 resolved
-11.5% vs TC avg
Strong +18% interview lift
Without
With
+18.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
21 currently pending
Career history
529
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
81.8%
+41.8% vs TC avg
§102
15.5%
-24.5% vs TC avg
§112
1.3%
-38.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 494 resolved cases

Office Action

§101 §102
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This Office Action is sent in response to Applicants’ Communication received on January 30, 2025 for application number 19/041,175. This Office hereby acknowledges receipt of the following and placed of record in file: Specification, Drawings, Abstract, Oath/Declaration, and Claims. Priority Acknowledgment is made of applicants’ claim for foreign priority under 35 U.S.C. 119(a)-(d). The certified copy has been filed in parent Application No. DE 10 2024 201 391.9 filed on February 15, 2024. Claim Rejections - 35 USC § 101 35 U.S.C. 101 reads as follows: Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title. Claims 1-4 and 6-12 are rejected under 35 U.S.C. 101, because the claimed invention is directed to an abstract idea without significantly more. Independent claim 1 is directed toward a method. Therefore, independent claim 1 along with the corresponding dependent claims 2-4 and 6-12 are directed to a statutory category of invention under Step 1. Under Step 2A, Prong 1, the claims are analyzed to determine whether one or more of the claims recites subject matter that falls within one of the following groups of abstract ideas: (1) mental processes, (2) certain methods of organizing human activity, and/or (3) mathematical concepts. In this case, the independent claim 1 is directed to an abstract idea without significantly more. Specifically, the claims, under their broadest reasonable interpretation cover certain mental processes and certain methods of organizing human activity. The language of independent claim 1 is used for illustration: Independent Claim 1: A method for operating a steering mechanism of a vehicle, comprising: in response to detecting a squealing situation {{{A human can hear the sound of tire slip and/or other noises of vehicle wheels even when the vehicle is in a resting position. The steering wheel can be operated when the vehicle is at zero speed in a safe environment, while hearing a squealing noise}}}, articulating at least two steerable wheels of the vehicle according to Ackermann. {{{A human can at least perform the Ackerman arrangement when the vehicle is at zero speed in a safe environment}}} Examiner Notes: The Ackermann steering mechanism is a geometric arrangement for motor vehicle linkage that ensures the inside front wheel turns at a tighter angle than the outside front wheel, allowing all wheels to circle a common center. As explained above, independent claim 1 recites at least one abstract idea under Step 2A, Prong 1. Under Step 2A, Prong 2, the claims are analyzed to determine whether the claim, as a whole, integrates the abstract idea into a practical application. As noted in the 2019 PEG, it must be determined whether any additional elements in the claim beyond the abstract idea integrate the exception into a practical application in a manner that imposes a meaningful limit on the judicial exception. The courts have indicated that additional elements such as merely using a computer to implement an abstract idea, adding insignificant extra solution activity, or generally linking use of a judicial exception to a particular technological environment or field of use do not integrate a judicial exception into a “practical application”; see at least MPEP 2106.04(d). In this case, the mental processes and certain methods of organizing human activity judicial exception are not integrated into a practical application. For example, independent claim 1 recite the additional elements of “steering mechanism of a vehicle”. These limitations amount to implementing the abstract idea on a computer, add insignificant extra solution activity, and/or generally link use of the judicial exception to a particular technological environment or field of use (i.e., a well-known vehicle steering mechanism); see at least MPEP 2106.04(d). More specifically: a. “steering mechanism of a vehicle” … found in independent claim 1 limitations adds insignificant extra solution activity. Therefore, taken alone, the additional elements do not integrate the abstract idea into a practical application. Furthermore, looking at the additional limitation(s) as an ordered combination or as a whole, the limitations add nothing significant that is not already present when looking at the elements taken individually. Because the additional elements, do not integrate the abstract idea into a practical application by imposing meaningful limits on practicing the abstract idea, independent claim 1 is directed to an abstract idea. Under Step 2B, the claims do not include any additional elements that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application in Step 2A, Prong Two, the additional element of limiting the use of the idea to one particular environment employs generic computer functions to execute an abstract idea and, therefore, does not add significantly more. Limiting the use of the abstract idea to a particular environment or field of use cannot provide an inventive concept. Additionally, as discussed above, the limitation of “steering mechanism of a vehicle” … as recited above, is considered insignificant extra solution activity. A conclusion that an additional element is insignificant extra solution activity in Step 2A must be re-evaluated in Step 2B to determine if the element is more than what is well-understood, routine, and conventional in the field. In this case, the additional limitations of “steering mechanism of a vehicle” … is well-understood, routine, and conventional activity, because it has been deemed insignificant extra solution activity by one or more Courts; see at least MPEP 2106.05(d) and MPEP 2106.05(g): Because the claims fail to recite anything sufficient to amount to significantly more than the judicial exception, independent claims 1 is patent ineligible under 35 U.S.C. 101. Dependent claims 2-4 and 6-12 have been given the full two-part analysis, including analyzing the additional limitations, both individually and in combination. Dependent claims 2-4 and 6-12, when analyzed both individually and in combination, are also patent ineligible under 35 U.S.C. § 101 based on same analysis as above. The additional limitations recited in the dependent claims fail to establish that the dependent claims are not directed to an abstract idea. The additional limitations of the dependent claims, when considered individually and as an ordered combination, do not amount to significantly more than the abstract idea. Accordingly, dependent claims 2-4 and 6-12 are patent ineligible. Therefore, claims 1-4 and 6-12 are patent ineligible under 35 U.S.C. 101. 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claims 1-12 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Nariyambut et al. (US PG Pub No. 2019/0250631 A1), hereinafter “Nariyambut”. Regarding claim 1, Nariyambut discloses a method for operating a steering mechanism of a vehicle (Figs. 1A and 1B), comprising: in response to detecting a squealing situation, articulating at least two steerable wheels of the vehicle according to Ackermann (paragraphs 30, 50, 138: (“FIG. 1A illustrates an example target tracker 100 monitoring a first vehicle 102 approaching a second vehicle 104 while performing an autonomous vehicle maneuver on a ground surface 106. As depicted in FIG. 1A, the first and the second example vehicles 102, 104 are moving in a forward direction with the first vehicle 102 following the second vehicle 104. The first vehicle 102 of FIG. 1A includes four wheels 108. In the illustrated example, the two front wheels 108 are operatively coupled to each other using Ackermann steering geometry. Similarly, the two rear wheels 108 are operatively coupled to each other using Ackermann steering geometry. For example, the front wheels 108 are operatively coupled to each other via a geometric arrangement of linkages in the vehicle steering that allow the front wheels 108 to turn at different respective radii.” and “In the illustrated example of FIG. 2, the target tracker 100 includes the displacement determiner 215 to determine a change in position of the second vehicle 104 with respect to the first vehicle 102 using Ackermann odometry. For example, the displacement determiner 215 may calculate a displacement of the second vehicle 104 with respect to the first vehicle 102 based on at least one of vehicle speed or steering wheel angle data. For example, the displacement determiner 215 may obtain vehicle speed data and steering wheel angle data from the engine control module 270. In some examples, the displacement determiner 215 integrates vehicle speed data over time and uses Ackermann geometry to calculate lateral displacement, longitudinal displacement, etc., and/or a combination thereof of the second vehicle 104 with respect to the first vehicle 102” and “At block 806, the example target tracker 100 obtains noise model(s) for the determined method(s). For example, the odometry calculator 235 may obtain an Ackermann noise model, a GFT noise model, a GMV noise model, etc., and/or a combination thereof. For example, the odometry calculator 235 may obtain an Ackermann noise model and a GFT noise model in response to determining to use the Ackermann odometry model and the GFT odometry model to calculate odometry parameters”)). Regarding claim 2, Nariyambut discloses the method according to claim 1, wherein at least one of the at least two steerable wheels is articulated at a maximum steering lock in a manner that deviates from Ackermann (paragraphs 102, 104, 112-114, 116, 149). Regarding claim 3, Nariyambut discloses the method according to claim 1, further comprising: correcting a steering kinematics of an axle of the vehicle that is articulated in a manner that deviates from Ackermann using a further steered axle of the vehicle according to Ackermann (paragraphs 102, 104, 112-114, 116, 149). Regarding claim 4, Nariyambut discloses the method according to claim 1, wherein the at least two steerable wheels are steered according to Ackermann when the vehicle is traveling slower than a predefined speed value (paragraph 24: (“For example, the target tracker apparatus may correct odometry parameters calculated by the Ackermann odometry method with odometry parameters calculated by the GFT method and/or the GMV method. In another example, the target tracker apparatus may use only odometry parameters determined by the GFT method and/or the GMV method when the vehicle speed is below a speed threshold such as 1 kilometer per hour (kph). For example, vehicle speed data obtained via the CAN bus may be floored to 0 kph for all vehicle speeds less than the speed threshold. In such an example, zeroing the vehicle speed may pose a significant complication to calculating odometry parameters using the odometry method when the vehicle is performing a low-speed vehicle maneuver (e.g., a maneuver including low creep speeds and/or occasional braking) such as driving in a congested area or parking”)). Regarding claim 5, Nariyambut discloses the method according to claim 1, further comprising: adjusting a steering differential angle of individual wheel steering actuators of at least one axle of the vehicle according to Ackermann (paragraphs 30, 50, 138). Regarding claim 6, Nariyambut discloses the method according to claim 1, further comprising: detecting the squealing situation using at least one microphone of the vehicle (paragraph 144: (“In the illustrated example, one or more input devices 922 are connected to the interface circuit 920. The input device(s) 922 permit(s) a user to enter data and/or commands into the processor 912. The input device(s) can be implemented by, for example, an audio sensor, a microphone, a camera (still or video), a keyboard, a button, a mouse, a touchscreen, a track-pad, a trackball, an isopoint device, and/or a voice recognition system”)). Regarding claim 7, Nariyambut discloses the method according to claim 1, further comprising: detecting the squealing situation when entering an interior space (paragraph 26: (“For example, the target tracker apparatus may characterize a light reflective property of a ground surface. For example, the target tracker apparatus may determine a light reflective property of the ground surface by characterizing the ground surface as exhibiting or possessing a dry quality (e.g., the ground surface is dry), a wet quality (e.g., the ground surface is wet, covered in water or similar liquid, etc.), a snow accumulation quality (e.g., the ground surface is covered in snow), etc. For example, the target tracker apparatus may determine that the ground surface has a low or a reduced light reflective property when the ground surface is dry. A ground surface having a reduced light reflective property may produce improved visual odometry results by using a GFT method compared to a GMV method. In another example, the target tracker apparatus may determine that the ground surface has a high or an increased light reflective property when the ground surface is wet or covered in snow compared to when the ground surface is dry. A ground surface having an increased light reflective property may produce improved visual odometry results by using a GMV method compared to a GFT method”)). Regarding claim 8, Nariyambut discloses the method according to claim 7, further comprising: detecting entry into the interior space using a time and an ambient brightness (paragraph 26: (“For example, the target tracker apparatus may characterize a light reflective property of a ground surface. For example, the target tracker apparatus may determine a light reflective property of the ground surface by characterizing the ground surface as exhibiting or possessing a dry quality (e.g., the ground surface is dry), a wet quality (e.g., the ground surface is wet, covered in water or similar liquid, etc.), a snow accumulation quality (e.g., the ground surface is covered in snow), etc. For example, the target tracker apparatus may determine that the ground surface has a low or a reduced light reflective property when the ground surface is dry. A ground surface having a reduced light reflective property may produce improved visual odometry results by using a GFT method compared to a GMV method. In another example, the target tracker apparatus may determine that the ground surface has a high or an increased light reflective property when the ground surface is wet or covered in snow compared to when the ground surface is dry. A ground surface having an increased light reflective property may produce improved visual odometry results by using a GMV method compared to a GFT method”)). Regarding claim 9, Nariyambut discloses the method according to claim 7, further comprising: detecting entry into the interior space using a navigation system of the vehicle (paragraph 47: (“the surface evaluator 210 may characterize the surface quality of the ground surface 106 as wet by obtaining a rain weather report from the Internet weather service for an area in which the first vehicle 102 is located. In another example, the surface evaluator 210 may characterize the surface type of the ground surface as covered in sand or similar material by determining that the first vehicle 102 is located on a beach, in a desert, etc., by querying a GPS system for a location of the first vehicle 102”)). Regarding claim 10, Nariyambut discloses the method according to claim 1, wherein a computer program product is configured to direct a processor to execute, implement, and/or control the method when the computer program product is executed (paragraph 141: (“The processor platform 900 of the illustrated example includes a processor 912. The processor 912 of the illustrated example is hardware. For example, the processor 912 can be implemented by one or more integrated circuits, logic circuits, microprocessors, GPUs, DSPs, or controllers from any desired family or manufacturer. The hardware processor may be a semiconductor based (e.g., silicon based) device. In this example, the processor 912 implements the example surface evaluator 210, the example displacement determiner 215, the example ground feature tracker 220, the example global motion vector determiner 225, the example method fusioner 230, the example odometry calculator 235, the example weight factor optimizer 240, and the example vehicle command generator 245”)). Regarding claim 11, Nariyambut discloses a non-transitory machine-readable storage medium on which the computer program product according to claim 10 is stored (paragraph 141). Regarding claim 12, Nariyambut discloses a control device, wherein the control device is configured to execute, implement and/or control the method according to claim 1 (paragraph 141). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to OMAR MORALES whose telephone number is (571)272-5923. The examiner can normally be reached on Monday thru Friday. 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, Lindsay Low can be reached on (571)272-1196. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see https://ppair-my.uspto.gov/pair/PrivatePair. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /O.M/Examiner, Art Unit 3747 /LINDSAY M LOW/Supervisory Patent Examiner, Art Unit 3747
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Prosecution Timeline

Jan 30, 2025
Application Filed
Apr 06, 2026
Non-Final Rejection mailed — §101, §102 (current)

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Prosecution Projections

1-2
Expected OA Rounds
58%
Grant Probability
77%
With Interview (+18.5%)
3y 4m (~2y 0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 494 resolved cases by this examiner. Grant probability derived from career allowance rate.

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