Prosecution Insights
Last updated: October 04, 2026
Application No. 19/072,752

METHOD AND APPARATUS FOR A ROTATABLE CHILD SAFETY SEAT

Non-Final OA §102§103§112
Filed
Mar 06, 2025
Priority
Jan 23, 2017 — provisional 62/449,319 +4 more
Examiner
NELSON JR, MILTON
Art Unit
Tech Center
Assignee
Graco Children's Products Inc.
OA Round
1 (Non-Final)
85%
Grant Probability
Favorable
1-2
OA Rounds
5m
Est. Remaining
90%
With Interview

Examiner Intelligence

Grants 85% — above average
85%
Career Allowance Rate
1585 granted / 1874 resolved
+24.6% vs TC avg
Moderate +6% lift
Without
With
+5.7%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 12m
Avg Prosecution
39 currently pending
Career history
1898
Total Applications
across all art units

Statute-Specific Performance

§101
1.8%
-38.2% vs TC avg
§103
27.2%
-12.8% vs TC avg
§102
23.7%
-16.3% vs TC avg
§112
45.8%
+5.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1874 resolved cases

Office Action

§102 §103 §112
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 . Information Disclosure Statement The information referred to in the IDS filed March 6, 2025 has been considered. Specification The status of any related application should be updated, where appropriate, on page 1 of the specification. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the “the seat is configured to rotate” … “along a non-vertical axis with respect to the base” (claims 1, 17 and 19); and “a child restraint system” (claim 1) must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-12, and 17-19 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 1 recites the limitation “the seat is configured to rotate at least 180 degrees along a non-vertical axis with respect to the base” in lines 6 to 7. Figures 1E, 4, 5A, and 5B appear to show rotation as along or about a substantially vertical axis (Y) with respect to the base (104). Note the vertical axis (Y) appears perpendicular to plane of the base (104). Similarly note claims 17 and 19. Claim 4 recites the limitation “causes the seat to be released from a locked rotational position and to rotate with respect to the seat”. It appears the claim is stating that the seat rotates relative to itself. This renders the claim as vague. Claim 8 recites the limitation "the predetermined rotational positions" in line 2. There is insufficient antecedent basis for this limitation in the claim. Claim 9 recites the limitation "the angle of recline" in line 1. There is insufficient antecedent basis for this limitation in the claim. Claim 18 recites the limitation "the angle of recline of the seat" in line 1. There is insufficient antecedent basis for this limitation in the claim. The remaining claims are indefinite as each depends from an indefinite claim. 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 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) 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. Claim(s) 1, 2, 4, 8 and 12, as best understood with the above cited indefiniteness, is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by DaSilva (US6199949). Note a car seat comprising: a base; and a seat (12) removably coupled to the base (13), wherein the seat is configured to rotate about the base from a front-facing position to a rear-facing position, the seat comprising: a child restraint system (12E, 12F, 12G); wherein the seat is configured to rotate at least 180 degrees along a non-vertical axis (note the axis through 17 is non-vertical (i.e. offset ), as shown in Figure 4, with respect to the base from the front-facing position to the rear-facing position; and a release tab (30A) configured to facilitate rotation of the seat, wherein the release tab is disposed at a front of the seat. Regarding claim 2, note the seat is configured to rotate at least 90 degrees along the non-vertical axis from the front-facing position to a side-facing position, wherein the seat is configured to lock in the side-facing position. See Figure 3. Regarding claim 4, note the seat further comprises: a handle (17A or 18A) disposed at a rear side of the seat, wherein pulling the handle allows the seat to be released from a locked rotational position and to rotate with respect to the seat. Regarding claim 8, note the seat is configured to be secured to the base in a plurality of predetermined positions, wherein the predetermined rotational positions comprise the front-facing position (Figure 1), a side-facing position (Figure 3), and the rear-facing position (further rotation from the Figure 3 position). Regarding claim 12, note the seat is removable from the base only at a first predetermined position (non-rotated, both 17A and 18A removed) and a second predetermined position (rotated, remove a 2nd of 17A or 18A).. Claim(s) 1-3, 5, 6, 8-10, and 12, as best understood with the above cited indefiniteness, is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Young (US4971392). Note a car seat comprising: a base (16, 42); and a seat (12, 32, 54, 72, 73, 110) removably (by releasing threaded fasteners 88, 89, and 89a, 91a, and 89b, 91b) coupled to the base, wherein the seat is configured to rotate about the base from a front-facing position to a rear-facing position, the seat comprising: a child restraint system (24); wherein the seat is configured to rotate at least 180 degrees along a non- vertical axis (note that the bottom surface of 16 is inclined, thereby offsetting the rotation axis that extends through 50, as seen in Figure 2) with respect to the base from the front-facing position to the rear-facing position; and a release tab (34) configured to facilitate rotation of the seat, wherein the release tab is disposed at a front of the seat. Regarding claim 2, note the seat is configured to rotate at least 90 degrees along the non-vertical axis from the front-facing position to a side-facing position, wherein the seat is configured to lock in the side-facing position. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 3, note the seat is configured to rotate 360 degrees with respect to the base. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 5, note the base comprises: a lower surface (lowermost surface of 16); a first sidewall portion (rear wall) extending from the lower surface; and a rim (upper surface of 16 having channel 30) extending radially inward from the first sidewall portion; wherein the lower surface and the rim define a cavity (28) that receives the seat. See Figure 2. Regarding claim 6, note the first sidewall portion extends upward from a rear end of the lower surface at a first height, the base further comprising: a second sidewall portion (front wall) extending upward from a front end of the lower surface at a second height that is less than the first height. See Figures 1 and 2. Regarding claim 8, note the seat is configured to be secured to the base in a plurality of predetermined positions, wherein the predetermined rotational positions comprise the front-facing position, a side-facing position, and the rear-facing position. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 9, note the angle of recline of the seat changes as it rotates from the front-facing position to the rear-facing position. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 10, note the seat is in an upright position with respect to the base when the seat is in the front-facing position and the seat is in an angled position with respect to the base when the seat is in the rear-facing position. See Figure 8. Regarding claim 12, note the seat is removable from the base only at a first predetermined position (upright, forward facing) and a second predetermined position (non-upright, non-forward facing). Claim(s) 13, 14 and 16-20, as best understood with the above cited indefiniteness, is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Young (US4971392). Note a car seat comprising: a base (16, 42) comprising: a bottom surface (lowermost surface of 16; see Figure 2); one or more sidewall portions (front wall and rear wall) extending from the bottom surface; a rim (upper surface of 16 having channel 30) extending radially inward from the one or more sidewall portions, wherein the bottom surface and the rim define a cavity (28) configured to receive the seat; and a channel (30); a seat (12, 32, 54, 72, 73, 110) removably (by releasing threaded fasteners 88, 89, and 89a, 91a, and 89b, 91b) coupled to the base, wherein the seat rotates at least 180 degrees with respect to the base, the seat comprising a tab (34) configured to engage the channel, the seat comprising: a seatbelt attachment pathway (see Figure 1) extending from a first side of the base to a second side of the seat, wherein the seatbelt attachment pathway is disposed at a rear end of the seat, and wherein the seatbelt attachment pathway is capable of receiving a portion of an automobile seatbelt to secure the seat to an automobile seat; and a child restraint system coupled to the seat. Regarding claim 14, note the one or more sidewall portions comprise: a first sidewall portion (rear wall) extending vertically upward from a rear end of the bottom surface at a first height; and a second sidewall portion (front wall) extending vertically upward from a front end of the bottom surface at a second height, wherein the second height is shorter than the first height. Regarding claim 16, note the seat is configured to secure to the base in a plurality of predetermined positions, wherein the predetermined positions comprise a front-facing position and a rear-facing position. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 17, note the seat is configured to rotate at least 180 degrees along a non-vertical axis with respect to the base from a front-facing position to a rear-facing position. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 18, note the angle of recline of the seat changes as the seat rotates from the front-facing position to the rear-facing position, such that the seat is in an upright position with respect to the base when the seat is in the front-facing position and the seat is in an angled position with respect to the base when the seat is in the rear-facing position. See Figure 8. Regarding claim 19, note the seat is configured to rotate at least 90 degrees along the non-vertical axis from the front-facing position to a side-facing position, wherein the seat is configured to lock in the side-facing position. Note the circular configuration of Figure 3, and the locking mechanism of Figure 4. Regarding claim 20, note the seat further comprises: a release tab (34) configured to facilitate rotation of the seat, wherein the release tab is disposed at a front of the seat. See Figure 2. 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 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) 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. Claim(s) 1-3 and 8-10, as best understood with the above cited indefiniteness, is/are rejected under 35 U.S.C. 103 as being unpatentable over CN202911586 in view of Horsfall (US20150336481) and Young (US4971392). The primary reference shows all claimed features of the instant invention with the exception of the seat being removably coupled to the base, and a child restraint system. In the primary reference, note a car seat comprising: a base (2); and a seat (1) coupled to the base, wherein the seat is configured to rotate about the base from a front-facing position (Figure 7) to a rear-facing position (Figure 12), the seat being configured to rotate at least 180 degrees along a non- vertical axis (about pivot pin 10, which is offset to the horizontal plane of the bottom surface of the base; see Figure 4) with respect to the base from the front-facing position to the rear-facing position; and a release tab (6) configured to facilitate rotation of the seat, wherein the release tab is disposed at a front of the seat. Regarding claim 2, note the seat is configured to rotate at least 90 degrees along the non-vertical axis from the front-facing position to a side-facing position, wherein the seat is configured to lock in the side-facing position. See Figures 7 and 12, and locking mechanism (6). Regarding claim 3, note the seat is configured to rotate 360 degrees with respect to the base. Note Figure 7 to Figure 12, and back to Figure 7. Regarding claim 8, note the seat is configured to be secured to the base in a plurality of predetermined positions, wherein the predetermined rotational positions comprise the front-facing position, a side-facing position, and the rear-facing position. Note by way of locking mechanism (6). Regarding claim 9, note the angle of recline of the seat changes as it rotates from the front-facing position to the rear-facing position. See Figures 7 and 12. Regarding claim 10, note the seat is in an upright position with respect to the base when the seat is in the front-facing position and the seat is in an angled position with respect to the base when the seat is in the rear-facing position. See Figures 7 and 12. Horsfall conventionally teaches configuring a car seat as having a seat that is removably coupled to a base. Note as discussed in the abstract. Young conventionally teaches configuring a child seat with a child restraint system (24). It would have been obvious to one having ordinary skill in the pertinent art before the effective filing date of the instant invention to modify the primary reference in view of the teachings of the Young by adding a child restraint system to the seat. This modification conventionally enhances user safety. It would have been obvious to one having ordinary skill in the pertinent art before the effective filing date of the instant invention to modify the primary reference in view of the teachings of the Horsfall by configuring the base and seat with structure that provides the capacity to removably couple the seat to the base. This modification conventionally enhances selectively decoupling of the seat from the base for cleaning, repairing, carrying, etc. Claim(s) 11, as best understood with the above cited indefiniteness, is/are rejected under 35 U.S.C. 103 as being unpatentable over CN202911586 in view of Horsfall (US20150336481) and Young (US4971392), as applied to claim 1 above, and further in view of Zahar (US20090026819). The primary reference, as modified above, shows all claimed features of the instant invention with the exception of a seatbelt attachment pathway extending from a first side of the seat to a second side of the seat, wherein the seatbelt attachment pathway is disposed at a rear end of the seat, and wherein the seatbelt attachment pathway is configured to receive a portion of an automobile seatbelt to secure the base to an automobile seat. Zahar teaches configuring a child safety seat as having a seatbelt attachment pathway (155) extending from a first side of the seat to a second side of the seat, wherein the seatbelt attachment pathway is disposed at a rear end of the seat, and wherein the seatbelt attachment pathway is configured to receive a portion of an automobile seatbelt to secure the base to an automobile seat. It would have been obvious to one having ordinary skill in the pertinent art before the effective filing date of the instant invention to further modify the primary reference in view of the teachings of Zahar by adding seatbelt attachment pathway as extending from a first side of the seat to a second side of the seat, wherein the seatbelt attachment pathway is disposed at a rear end of the seat, and wherein the seatbelt attachment pathway is configured to receive a portion of an automobile seatbelt to secure the base to an automobile seat. This modification enhances securement of the seat for improved user safety. Allowable Subject Matter Claim 7 would be allowable if rewritten to overcome the rejection(s) under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), 2nd paragraph, set forth in this Office action and to include all of the limitations of the base claim and any intervening claims. Claim 15 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MILTON NELSON JR whose telephone number is (571)272-6861. The examiner can normally be reached M-F 5:30am-1:30pm. 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. 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. mn /MILTON NELSON JR/July 31, 2026 Primary Examiner, Art Unit 3636
Read full office action

Prosecution Timeline

Mar 06, 2025
Application Filed
Aug 04, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

Precedent Cases

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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
85%
Grant Probability
90%
With Interview (+5.7%)
1y 12m (~5m remaining)
Median Time to Grant
Low
PTA Risk
Based on 1874 resolved cases by this examiner. Grant probability derived from career allowance rate.

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