Office Action Predictor
Application No. 17/332,695

COMPOSITIONS AND METHODS FOR TREATING KERATIN FIBERS

Non-Final OA §103
Filed
May 27, 2021
Examiner
NGUYEN, JOHN P
Art Unit
1619
Tech Center
1600 — Biotechnology & Organic Chemistry
Assignee
L'Oreal
OA Round
5 (Non-Final)
44%
Grant Probability
Moderate
5-6
OA Rounds
3y 2m
To Grant
86%
With Interview

Examiner Intelligence

44%
Career Allow Rate
177 granted / 398 resolved
Without
With
+41.0%
Interview Lift
avg trend
3y 2m
Avg Prosecution
42 pending
440
Total Applications
career history

Statute-Specific Performance

§101
1.9%
-38.1% vs TC avg
§103
54.2%
+14.2% vs TC avg
§102
6.1%
-33.9% vs TC avg
§112
18.9%
-21.1% vs TC avg
Black line = Tech Center average estimate • Based on career data

Office Action

§103
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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 28 August 2025 has been entered. Status of Claims Receipt is acknowledged of claim amendments filed on 28 August 2025. Claims 1, 11-12 and 16 have been amended. Claims 9-10 have been canceled. Claims 19-20 remains withdrawn from consideration. Claims 1-8 and 11-18 are presented for examination herein to the extent that the film former is carrageenan, e.g., applicant elected species. Information Disclosure Statement The information disclosure statement (IDS) filed 08/27/2025 has been considered by the Examiner. A signed and initialed copy of the IDS is included with the instant Office Action. Objections and/or Rejections Withdrawn The objection of claims 1 and 16 is withdrawn in view of the amendment of claims 1 and 16. The rejection of claims 11-12 under U.S.C. 112(d), as being of improper dependent form for failing to further limit the subject matter of the claim upon which it depends, is withdrawn in view of the amendment of claims 11-12. Rejections Modified as Necessitated by the Claim Amendments 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, 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 for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. The rejection of claims 1-7, 11-12 and 16-18 under 35 U.S.C. 103 as being unpatentable over the combination of US 2015/0190333 (publication date: 9 July 2015, hereafter ‘333) and US 2008/0031841 (publication date: 7 February 2008, hereafter ‘841) is maintained. In claim 16, component d) is optionally, which means it can be present or absent. Art is applied for claims 16-18 where component d) is absent. US‘333 teaches hair cosmetic (claimed composition for treating keratin fibers) and at [0015] teaches: PNG media_image1.png 84 472 media_image1.png Greyscale US ‘333 at [0025] teaches cyclodextrins and this includes alpha cyclodextrin, beta cyclodextrin and gamma cyclodextrins and also derivatives (claims 1-3 and 16-17) and at [0026] teaches the amount of cyclodextrins, which is from 0.1 to 30% by mass and the claimed amount of 0.1-1 and 0.5-1% is within this amount (claims 1 and 4, respectively) and the claimed amount of claim 16, which is from about 0.1 to about 1% is within the amount taught by US ‘333. US ’333 at [0028] teaches water (drawn to claimed solvent (claims 1 and 5)) and at [0037] teaches: PNG media_image2.png 319 441 media_image2.png Greyscale The above paragraph reads on claims 5-6 and claims 16 and 18. Propylene glycol, 1,3 butane diol, diethylene glycol and dipropylene glycol reads on linear unsubstituted C2-C8 polyols of claim 18. For claim 16, note that the amount 0.1 to about 1% is within the preferred amount which is 0-15% and overlaps with more preferably amount which is 0-6%. US ’333 at [0045] teaches that the hair cosmetic composition is suitable as a hair styling agent. See also paragraphs [0085-0092] for set retentivity, washability and sprayability. See also examples. Examples 2-7 and 9-10 has weight percent of cyclodextrin as 5% (alpha or gamma cyclodextrin) and the content of solvent other than water is more preferably as 0-6% and when the solvent other than water is 3 % then the ratio is 5/3 and this is 1.66 and this is within the ratio of about 5:1 to about 1:5 of cyclodextrin: additional solvent (claim 7). When the amount of cyclodextrin is 5% and when the solvent other than water is 3 % then the ratio is 5/5 and this is 1.00 and this is within the ratio of about 5:1 to about 1:5 of cyclodextrin: additional solvent (claim 7). When the amount of cyclodextrin is 5% and when the solvent other than water is 1 % then the ratio is 5/1 and this is 5.00 and this is within the ratio of about 5:1 to about 1:5 of cyclodextrin: additional solvent (claim 7). The difference between US ‘333 and instant application is US ’333 does not teach the claimed film former species. US ‘841 teaches cosmetic compositions comprising at least one lambda carrageenan ( claims 1 and 16) for fixing and caring of keratin fibers (claimed keratin fibers) and teaches claimed carrageenan at paragraphs [0021-0024] and at [0025] teaches the amount which is 0.1 to 30% by mass and the claimed amount “ about 0.01 to about 1%” and “0.25% to about 0.75%” overlaps with the amount taught by US ‘841 (claims 1 and 11, respectively) and at [ 0348] teaches the cosmetically acceptable medium, which can be water or C1-C4 alcohols and example 2 exemplifies carrageenan and the amount is 1.4% and the ratio of cyclodextrin from the example to the carrageenan from the example is 5/1.4 and this is 3.571 and this is within the “weight ratio of the at least one cyclodextrin or derivative thereof to the at least one film former ranges from about 2:1 to about 10:1” of claim 1 and also within the “weight ratio of the at least one cyclodextrin or derivative thereof to the at least one film former ranges from about 2:1 to about 5:1” of claim 12 and also within “weight ratio of the at least one cyclodextrin or derivative thereof to the at least one film former ranges from about 3:1 to about 10:1”. Accordingly, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to prepare compositions for treating hair using cyclodextrins taught and exemplified by US’333 and solvent taught by US ‘333 and add the carrageenan taught by US ‘841 to the compositions with the reasonable expectation of success that the modified compositions not only provide preventing keratin fiber (hair) from detangling after application, retain hair setting property after long time even in humidity but also can be used for fixing the hair. This is a prima facie case of obviousness. The rejection of claims 8 and 13-15 under 35 U.S.C. 103 as being unpatentable over the combination of US 2015/0190333 (‘333) and US 2008/0031841 (‘841) as applied to claims 1-7 and 9-12 and 16-18 above, and further in view of US 2019/0125650 (‘650) is maintained. US ’333 teaches as solvents propylene glycol but not hexylene glycol or pentylene glycol, which are polyols. The references above do not teach the limitation of claims 13-15 drawn to acids and the amount. US ‘650 teaches hair care compositions and at [107] teaches cosmetically acceptable solvents and describes propylene glycol and hexylene glycol and at b[0108] teaches pentylene glycol and also propylene glycol. Propylene glycol taught by US ’333 is functionally equivalent to hexylene glycol and also pentylene glycol and all these are solvents. US ‘650 at [0122] pH adjusters and this includes claimed citric acid and ascorbic acid (claims 13 and15) and teaches the amount at [0125] and this is 0.01 to 0.75% by weight and there is overlap with the claimed amount which is from about 0.1 to about 5% (claim 14). Accordingly, it would be obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to prepare compositions for treating hair using cyclodextrins taught and exemplified by US’333 and solvent taught by US ‘333 and change the solvent from propylene glycol to any solvents including hexylene glycol or pentylene glycol taught by US ‘650 and also add the pH adjusters taught by US ‘650 and add the carrageenan taught by US ‘841 to the compositions and with the reasonable expectation of success that the modified compositions not only provide preventing keratin fiber (hair) from detangling after application, retain hair setting property after long time even in humidity but also can be used for fixing the hair. This is a prima facie case of obviousness. Response to Arguments Applicant argues that Tanimura does not teach or suggest the claimed film former species and that Laurent also does not teach or suggest either the claimed “(i) nonionic film forming polymers chosen from vinylpyrrolidone homopolymers” or the claimed “(ii) anionic film forming polymers chosen from the group consisting of carrageenan and xanthan gum” (e.g., applicant elected species is carrageenan). Applicant's arguments filed on 28 August 2025 have been fully considered but they are not persuasive. In response, US‘333 (e.g., Tanimura) discloses a hair cosmetic composition for styling hair comprising cyclodextrin, a solvent including water and other solvents other than water (paragraphs [0015], [0026], [0028] and [0037]). US’333 (e.g., Tanimura) discloses that the amount of cyclodextrin is from 0.1 to 30% (paragraph [0026]). US ‘841 (e.g., Laurent) teaches a composition for treating hair including fixing hair (e.g., styling) that comprises lambda-carrageenan (e.g., anionic film forming polymer) (paragraph [0026]). US ‘841 teaches that in the composition the lambda-carrageenan provide better texture, which are less brittle and less hard and is easier to apply (paragraph [0012]). Therefore, one of ordinary skill in the art would have been motivated to include the lambda-carrageenan of US ‘841 (e.g., Laurent) into the composition of US’333 (e.g., Tanimura) in order to obtain a hair cosmetic composition that has additional benefits including provide better texture including less brittle and less hard and which is easier to apply. Thus, for the reasons of record and for the reasons presented above claims 1-8 and 11-18 are rejected under 35 U.S.C. 103(a). Conclusion and Correspondence No claims are allowed. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JOHN P NGUYEN whose telephone number is (571)270-5877. The examiner can normally be reached Monday-Friday 10am-6pm 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, David Blanchard can be reached on (571) 272-0827. 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. /JOHN P NGUYEN/ Examiner, Art Unit 1619 /ANNA R FALKOWITZ/Primary Examiner, Art Unit 1600
Read full office action

Prosecution Timeline

May 27, 2021
Application Filed
Dec 03, 2022
Non-Final Rejection — §103
Apr 10, 2023
Response Filed
Nov 04, 2023
Final Rejection — §103
May 16, 2024
Request for Continued Examination
May 16, 2024
Interview Requested
May 17, 2024
Response after Non-Final Action
Jun 11, 2024
Applicant Interview (Telephonic)
Jun 14, 2024
Non-Final Rejection — §103
Jun 18, 2024
Examiner Interview Summary
Sep 30, 2024
Interview Requested
Oct 08, 2024
Examiner Interview Summary
Dec 19, 2024
Response Filed
Dec 19, 2024
Response after Non-Final Action
Apr 04, 2025
Final Rejection — §103
Aug 28, 2025
Request for Continued Examination
Sep 03, 2025
Response after Non-Final Action
Sep 29, 2025
Non-Final Rejection — §103
Apr 01, 2026
Notice of Allowance

Precedent Cases

Applications granted by this same examiner with similar technology. Study what changed to get past this examiner.

Patent 12403109
SOTALOL HYDROCHLORIDE DOSING
2y 5m to grant Granted Sep 02, 2025
Patent 12329855
DRUG DELIVERY SYSTEM WITH ENHANCED IMMUNE ACTIVE FUNCTION
2y 5m to grant Granted Jun 17, 2025
Patent 12303518
SYSTEM FOR PROVIDING BIRTH CONTROL
2y 5m to grant Granted May 20, 2025
Patent 12285015
NEW AGROCHEMICAL FORMULATIONS
2y 5m to grant Granted Apr 29, 2025
Patent 12186337
SODIUM NITRITE-CONTAINING PHARMACEUTICAL COMPOSITIONS
2y 5m to grant Granted Jan 07, 2025

AI Strategy Recommendation

Click below to generate an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

5-6
Expected OA Rounds
44%
Grant Probability
86%
With Interview (+41.0%)
3y 2m
Median Time to Grant
High
PTA Risk
Based on 398 resolved cases by this examiner