Prosecution Insights
Last updated: April 19, 2026
Application No. 17/254,171

REFILLABLE PET BOTTLE CODIFICATION FOR CONTAINER LIFECYCLE TRACEABILITY

Non-Final OA §103
Filed
Dec 18, 2020
Examiner
SULLIVAN, JESSICA E
Art Unit
3627
Tech Center
3600 — Transportation & Electronic Commerce
Assignee
Amcor Rigid Packaging Usa LLC
OA Round
5 (Non-Final)
15%
Grant Probability
At Risk
5-6
OA Rounds
3y 7m
To Grant
36%
With Interview

Examiner Intelligence

Grants only 15% of cases
15%
Career Allow Rate
16 granted / 108 resolved
-37.2% vs TC avg
Strong +21% interview lift
Without
With
+21.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
29 currently pending
Career history
137
Total Applications
across all art units

Statute-Specific Performance

§101
30.7%
-9.3% vs TC avg
§103
40.3%
+0.3% vs TC avg
§102
21.9%
-18.1% vs TC avg
§112
4.6%
-35.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 108 resolved cases

Office Action

§103
DETAILED ACTION This is a Non-Final Office Action in response to the Appeal Brief Filed on 10/03/2025. Claims 1, 5, 7, 9-13, 18 and 20 are pending. The effective filing date is 06/20/18. Prosecution Reopened After Appeal Brief In view of the appeal brief filed on 10/03/2025, PROSECUTION IS HEREBY REOPENED. A new ground of rejection is set forth below. To avoid abandonment of the application, appellant must exercise one of the following two options: (1) file a reply under 37 CFR 1.111 (if this Office action is non-final) or a reply under 37 CFR 1.113 (if this Office action is final); or, (2) initiate a new appeal by filing a notice of appeal under 37 CFR 41.31 followed by an appeal brief under 37 CFR 41.37. The previously paid notice of appeal fee and appeal brief fee can be applied to the new appeal. If, however, the appeal fees set forth in 37 CFR 41.20 have been increased since they were previously paid, then appellant must pay the difference between the increased fees and the amount previously paid. A Supervisory Patent Examiner (SPE) has approved of reopening prosecution by signing below: /FAHD A OBEID/Supervisory Patent Examiner, Art Unit 3627 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 disclosure statement (IDS) submitted on 04/11/2024 was filed. The submission is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. 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. Claims 1, 5, 7, 9-3, 18 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over US 2014/0284380 A1 Toedtli (hereinafter Toedtli) in view of US 2010/0147418 A1 Piana (hereinafter Piana). Regarding claim 1, Toedtli teaches a polymeric container (Toedtli [0022] receptacle may be plastic bottle) comprising: a finish defining an opening (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a top portion, with opening/lid); a neck adjacent to the finish (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a curved portion, neck, to attach lid); a shoulder extending from the neck, the shoulder including a curved surface that gradually tapers outward from the neck and away from a longitudinal axis of the container (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a location between the top opening and body portion is tapered); a body, the shoulder is between the neck and the body (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a body below the shoulder and neck); a base configured to support the container upright (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a bottom to keep container upright); and the code is unique to the container, identifies the container, and is accessible over a plurality of refilling cycles (Toedtli [0020] the machine readable marking contains identification and other information; [0021] a machine readable marking located on the outer surface of the receptacle; when a marking is laser etched onto a bottle it is not removed, and therefore is available throughout its lifecycle); wherein: the code identifies the container in a database including manufacturing information for the container, filling information for the container, and field information for the container (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]); and the filling information includes an original fill date, a number of refilling cycles subsequent to the original fill date, refill dates of each one of the refill cycles, and refilling locations of each one of the refill cycles (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]; Under MPEP 2111.05 examiner must consider all claim limitations, however if the limitation is considered printed matter, there must be a determination whether this information is functional. Under MPEP 2111.05 the matter is to be considered printed matter if the claim it to the content of information, here the limitation is directly related to information contained within a code, and therefore is printed matter. Next, there needs to be a determination about whether that information has a functional relationship. When the information is used to merely convey a message, this is considered nonfunctional. There is no new feature of physical structure and no new relation when introducing the messaging, and therefore, the functional relationship exists.). Toedtli fails to explicitly disclose the container is a refillable container and a code laser etched on the curved surface such that the code is curved both horizontally and vertically. Under MPEP 2111.04 the claim scope is not limited by claim language that suggests or makes optional, this non limiting language includes “wherein” statements. When the wherein clause gives meaning and purpose it is given patentable weight, however, when it simply expresses the intended result, it is not given weight. Here, the bottle is the claim, and its intended purpose to refill, but the refill ability of the bottle does not change its shape, or where codes are etched, and therefore its refill ability is a suggestion. Piana is in the field of plastic containers (Piana Abstract, plastic containers) and teaches a code laser etched on the curved surface such that the code is curved both horizontally and vertically (Piana [0010] laser inscription etched marking onto wall of containers; Fig. 1, marking 7 on neck of the bottle, which is curved both horizontally and vertically; [0025] laser etched on neck of bottle). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the marking of Toedtli with the laser etching and location of the marking as taught by Piana. The motivation for doing so would be apply necessary marking to bottles that are cheap and easy to apply, while maintaining visibility (Piana [0001] various reason to imprint bottles; [0004-0005] easy and inexpensive to mark and review). Regarding claim 5, modified Toedtli teaches the polymeric container of Claim 1, wherein the code includes at least one of the following: a QR code; a data matrix code; an Aztec code; a PDF417 code; a UPC/EAN code; a code 128; and a code 39 (Toedtli [0053] the code may be QR, code 39, data matrix, Aztec). Regarding claim 7, modified Toedtli teaches the polymeric container of Claim 1, wherein the manufacturing information includes at least one of the following: manufacturing date, manufacturing lot, manufacturing location, and production parameters (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]). Regarding claim 9, modified Toedtli teaches the polymeric container of Claim 1, wherein the field information includes at least one of the following: date, location, orbit, appearance, and promotional campaigns (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]). Regarding claim 10, Toedtli teaches a system for tracking containers (Toedtli [0022] receptacle may be plastic bottle), the system comprising: a container (Toedtli [0022] receptacle may be plastic bottle), the container including: a finish defining an opening (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a top portion, with opening/lid); a neck adjacent to the finish (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a curved portion, neck, to attach lid); a shoulder extending from the neck, the shoulder including a curved surface that gradually tapers outward from the neck and away from a longitudinal axis of the container (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a location between the top opening and body portion is tapered); a body, the shoulder is between the neck and the body (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a body below the shoulder and neck); a base configured to support the container upright (Toedtli [0126] receptacle has identifier; Fig. 4A, the receptacle has a bottom to keep container upright); and a code etched on the curved surface (Toedtli [0021] marking the machine readable codes include printing or laser inscription; Fig. 4A, code is etched on a bottle, which is curved), the code is unique to the container, identifies the container, and is accessible over a plurality of refilling cycles (Toedtli [0020] the machine readable marking contains identification and other information; [0021] a machine readable marking located on the outer surface of the receptacle; when a marking is laser etched onto a bottle it is not removed, and therefore is available throughout its lifecycle); wherein the code identifies the container in a database including manufacturing information for the container, filling information for the container, and field information for the container, the filling information includes: an original fill date, a number of refilling cycles subsequent to the original fill date, refill dates of each one or the refill cycles, and refilling locations of each one of the refill cycles (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]; Under MPEP 2111.05 examiner must consider all claim limitations, however if the limitation is considered printed matter, there must be a determination whether this information is functional. Under MPEP 2111.05 the matter is to be considered printed matter if the claim it to the content of information, here the limitation is directly related to information contained within a code, and therefore is printed matter. Next, there needs to be a determination about whether that information has a functional relationship. When the information is used to merely convey a message, this is considered nonfunctional. There is no new feature of physical structure and no new relation when introducing the messaging, and therefore, the functional relationship exists.); a first belt (Toedtli [0126] readout device transport the receptacle between two belts; Fig. 4A); a second belt spaced apart from the first belt a distance sufficient for both the first belt and the second belt to contact the container when the container is arranged between the first belt and the second belt (Toedtli [0126] readout device transport the receptacle between two belts; Fig. 4A); and a camera arranged along a first side of the first belt and the second belt, the camera is positioned above the container and angled downward towards the shoulder to read the code off of the container as the first belt and the second belt convey the container along a distance (Toedtli [0127-0128] readout device with optical detector, using a camera, to read the barcode; Fig. 4A; [0127] illumination may be provided at an incline from above OR the front; the image may show a horizontal camera, but [0127] describes an angular view of the bottles); and at least one reflector arranged along a second side of the first belt and the second belt, the second side is opposite to the first side where the camera is arranged, the at least one reflector configured to direct a light beam generated by the camera to the code to read the code off the container to allow the code to be read regardless of whether the code is facing the first side or the second side (Toedtli [0058] the device includes an illumination device that may be reflective, and shine a light at the container to read the marking no matter the angle of the marking to the camera); wherein the first belt and the second belt are configured to be operated by a controller to move at different speeds to rotate the container such that as the container passes the camera the code faces the camera and is visible to the camera (Toedtli [0047] actuators may be used to align and rotate the receptacle; [0072] rotation in front of optical detector; [0035] actuator is used with coordinate system to move the receptacle, and can have different speeds for different arms to rotate). Toedtli fails to explicitly disclose the container is a refillable container and t a code laser etched on the curved surface such that the code is curved both horizontally and vertically. Under MPEP 2111.04 the claim scope is not limited by claim language that suggests or makes optional, this non limiting language includes “wherein” statements. When the wherein clause gives meaning and purpose it is given patentable weight, however, when it simply expresses the intended result, it is not given weight. Here, the bottle is the claim, and its intended purpose to refill, but the refill ability of the bottle does not change its shape, or where codes are etched, and therefore its refill ability is a suggestion. Piana teaches a code laser etched on the curved surface such that the code is curved both horizontally and vertically (Piana [0010] laser inscription etched marking onto wall of containers; Fig. 1, marking 7 on neck of the bottle, which is curved both horizontally and vertically; [0025] laser etched on neck of bottle). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the marking of Toedtli with the laser etching and location of the marking as taught by Piana. The motivation for doing so would be apply necessary marking to bottles that are cheap and easy to apply, while maintaining visibility (Piana [0001] various reason to imprint bottles; [0004-0005] easy and inexpensive to mark and review). Regarding claim 11, modified Toedtli teaches the system of Claim 10, wherein the first belt and the second belt are operated by the controller to move at different speeds or in different directions to rotate the container such that as the container passes the camera the code faces the camera and is visible to the camera (Toedtli [0047] actuators may be used to align and rotate the receptacle; [0072] rotation in front of optical detector; [0035] actuator is used with coordinate system to move the receptacle, and can have different speeds for different arms to rotate). Regarding claim 12, modified Toedtli teaches the system of Claim 10, wherein the camera is a first camera with the option for more cameras (Toedtli [0025] the optical detection contains at least one camera). Toedtli fails to explicitly disclose the system further comprises a second camera; and wherein the system includes no more than two cameras. It would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify the teaching of one or more cameras of Toedtli, which suggests that more than one camera may be used, with only one additional camera of the instant invention. Under MPEP 2144.04(VI)(b) that mere duplication of parts has no patentable significant unless a new and unexpected result is produced. The limitation of only 2 cameras, compared to multiple camera, would not be patentably distinguishable. Regarding claim 13, modified Toedtli teaches the system of Claim 10, wherein the code includes at least one of the following: a QR code; a data matrix code; an Aztec code; a PDF417 code; a UPC/EAN code; a code 128; and a code 39 (Toedtli [0053] the code may be QR, code 39, data matrix, Aztec). Regarding claim 18, modified Toedtli teaches the system of Claim 10, wherein the manufacturing information includes at least one of the following: manufacturing date, manufacturing lot, manufacturing location, and production parameters (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]). Regarding claim 20, modified Toedtli teaches the system of Claim 10, wherein the filling information includes at least one of the following: date, location, orbit, appearance, and promotional campaigns (Toedtli [0009-0010] information in the marking can include specification of the content, filling time, use of the content, content, manufacture and filler information; [0004] filling process, production date, dosage; [0018]). Response to Arguments Applicant’s arguments, see Pg. 7, Para. 2, filed 10/03/2025, with respect to the rejections of claims 1 and 10 under 103 have been fully considered and are persuasive. Prior rejection recitation of the curve horizontally and vertically is not found in prior art. Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground of rejection is made in view of Toedtli in view of Piana. Regarding 35 U.S.C. 103 Rejection of Independent Claim 1: Features emphasized by the Applicant include “the code is curved both horizontal and vertically…and is accessible over a plurality of refilling cycles”, “the container is a refillable container”, and “the filling information includes an original fill date, a number of refilling cycles subsequent to the original fill date, refill dates of each one of the refill cycles, and refilling locations of each one of the refill cycles”. Toedtli is able to teach marking a bottle with a machine readable code, the claim specifies that the code is etched on a curved surface, but fails to teach the curve horizontally and vertically. Therefore, a new prior art is introduced to teach this limitation. See Piana above in the 103 rejection. Toedtli is also able to teach that filling information is included in the code marked on the bottle. The claim has specified what information is being stored within the code, and that include fill dates, refilling cycles, refill dates and refill locations. As described in the claimed citation, Toedtli is able to teach that the information stored in the code includes time, date, and location of the filling, and therefore, if it is the first filling or any subsequent refilling, the claim element is storing information in a code to identifier time date and location is taught, and the fact is it a refill compared to the original fill is extra-solution activity, since the type of data stored in the code does not change the product of the code itself string information. See MPEP 2111.05 about the functionality of printed matter, and the information does not provide any functional limitations. Toedtli is not used to teach the refilling of bottles. Under MPEP 2111.04 the wherein statement about the sue of the bottle merely provides a suggestion on what to do with the bottle, and therefore does not carry significant weight to limit the claim. Toedtli therefore is able to teach printing a code on a bottle, and that code includes filling information, and the secondary reference Piana is able to teach a bottle with a code on the neck. Therefore, the combination of the two references showcases how the original code and original filling information may also include refilling information. There is no indication that the recycling of bottles in Toedtli would prevent the code on the bottle from containing information about refilling. The code itself contains information, and that information can be easily changed based on the desired outcome of the bottle. Regarding 35 U.S.C. 103 Rejection of Independent Claim 10: Features emphasized by the Applicant include “the code is curved both horizontal and vertically…and is accessible over a plurality of refilling cycles”, “a number of refilling cycles…refill dates…refilling locations”; “a second belt spaced apart from the first belt”; “the camera is positioned above the container and angled downward towards the shoulder to read the code off the container as the fist belt and the second belt convey the container”; “the at least one reflector configured to direct a light beam generated by the camera to the code to read the code of the container to allow the code to be read regardless of whether the code is facing the first side or the second side”; “to move at different speeds to rotate the container such that as the container passes the camera the code faces the camera and is visible to the camera”. As discussed, in regards to claim 1, the combination of references is used to teach the information details and curved surface the code is etched onto. Toedtli is used to teach a bottle having a code, that contain information about the filling, Piana teaches that codes can be etched on curved surfaces, and therefore the combination would have been obvious to combine and teach the claimed invention elements. In Toedtli Fig.4A, there is an obvious showcase of a conveyor system with two belts, and as described in [0035] it is described that the conveyor system has an actuator, and that actuator is used with the coordinate system to move the receptables, and that they may have different speeds in order to rotate, specifically one arm may stand still, while the other moves and they are independent of each other. Therefore, each belt is controlled and moves at different speeds to rotate the container, the limitation of claim 10. The next elements of the claim limitation relate to the angle of the camera, and the reflector arranged to direct light. Toedtli [0127-0128] describes an optical detector, a camera, and providing illumination to properly read the barcode on the bottle. Applicant specifically points to the camera being angled downward being different from Toedtli, but in [0127] the camera is described as an angular view of the bottles. The system of Toedtli has a camera, and that camera is able to read the barcode, and additionally contains a light in order to illuminate the barcode in order to properly read that barcode. The system includes the camera, and the position described in Toedtli completes the function described in the instant application, and therefore, the system of Toedtli is able to perform as described in the instant application. Prior Art The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. US 10,585,107 B2 Sinnema et al. teaches moving vessels (Abstract); US 10,775,396 B2 Gemperle et al. teaches handling samples (Abstract); US 9,600,982 B2 MacIntosh teaches identification of items using downward facing cameras (Abstract); US 11,741,733 B2 Filler et al. teaches identifying images using cameras (Abstract); US 10,776,729 B2 Smith et al. teaches tracking containers (Abstract); US 11,741,733 B2 Filler et al. teaches tracking items through their lifecycle (Abstract). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JESSICA E SULLIVAN whose telephone number is (571)272-9501. The examiner can normally be reached M-Th; 9:00 AM-5PM EST. 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, FAHD OBEID can be reached at (571) 270-3324. 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. /J.E.S./Examiner, Art Unit 3627
Read full office action

Prosecution Timeline

Dec 18, 2020
Application Filed
Sep 01, 2023
Non-Final Rejection — §103
Nov 20, 2023
Applicant Interview (Telephonic)
Nov 28, 2023
Examiner Interview Summary
Jan 02, 2024
Response Filed
Mar 01, 2024
Final Rejection — §103
Jun 05, 2024
Request for Continued Examination
Jun 07, 2024
Response after Non-Final Action
Aug 10, 2024
Non-Final Rejection — §103
Oct 10, 2024
Examiner Interview Summary
Oct 10, 2024
Applicant Interview (Telephonic)
Dec 20, 2024
Response Filed
Mar 01, 2025
Final Rejection — §103
Jun 05, 2025
Notice of Allowance
Oct 03, 2025
Response after Non-Final Action
Oct 19, 2025
Response after Non-Final Action
Feb 19, 2026
Non-Final Rejection — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
15%
Grant Probability
36%
With Interview (+21.4%)
3y 7m
Median Time to Grant
High
PTA Risk
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