Prosecution Insights
Last updated: April 18, 2026
Application No. 17/757,694

Laundry Composition

Non-Final OA §103
Filed
Jun 17, 2022
Examiner
EASHOO, MARK
Art Unit
1767
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Firmenich SA
OA Round
4 (Non-Final)
39%
Grant Probability
At Risk
4-5
OA Rounds
3y 6m
To Grant
71%
With Interview

Examiner Intelligence

Grants only 39% of cases
39%
Career Allow Rate
54 granted / 139 resolved
-26.2% vs TC avg
Strong +32% interview lift
Without
With
+31.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 6m
Avg Prosecution
10 currently pending
Career history
149
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
48.7%
+8.7% vs TC avg
§102
19.1%
-20.9% vs TC avg
§112
19.6%
-20.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 139 resolved cases

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 . Claim Rejections - 35 USC§ 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1-3 and 9-13 are rejected under 35 U.S.C. 103 as being unpatentable over Michael (US Pat. 4,946,624) in view of Rassat et al. (WO 2018/115250 Al) when taken with Bacon et al. (US Pat. 5,500,138). Regarding Claims 1-2 and 11-13: Michael teaches microcapsules for an aqueous fabric softener (ie. a laundry composition) (2:35-50); wherein the microcapsules (ie. core-shell) have an encapsulating material / biodegradable carrier made from gelatin and gum Arabic (reads upon claim 2 and 13) (5:10-25 and 2:45-51); a perfume formulation having a portion that is encapsulated/entrapped and a portion without encapsulation (ie. free perfume oil) (4:5-20 and Table 2); laundry additives such as dialkyl quaternary ammonium salts (11:34-52, eg. when RS and R8 are alkyl groups) and silicones (15:9-26); and a perfume composition comprising about 30% orange terpenes (90% d-limonene), 20% para tertiary butyl cyclohexyl acetate, 10% linalyl acetate, 30% alpha ionone, and 10% para tertiary butyl alpha methyl hydrocinnamic aldehyde (16:44-55). It is submitted that para tertiary butyl cyclohexyl acetate contains a cyclohexane ring and that alpha ionone contains a cyclohexene ring. Bacon et al. provides evidence that para tertiary butyl alpha methyl hydrocinnamic aldehyde has a log P of 3.86, d-limonene has a log P of 4.23, and linalyl acetate has a log P of 3.50 (Table 1 and Table 4). Michael does not specifically teach a single embodiment of a perfume composition containing at least 15% of a perfume material having log T less than -4. However, Michael does teach a perfume composition containing beta ionone and methyl beta-napthyl ketone at about 11% (16:55-68). Rassat et al. teaches a perfume oil comprising at least 15% of a perfume material having log T less than -4 (pg. 6, Ii. 10-12) and that beta ionone and methyl napthyl ketone having a log T less than -4 (Table 1). Michael and Rassat et al. are analogous art because they are from the same field of endeavor, namely, microcapsules encapsulating perfume materials. At the time of filing a person of ordinary skill in the art would have found it obvious to have substituted a least 15% of a perfume material having log T less than -4, such as beta ionone and/or methyl napthyl ketone, as taught by Rassat et al. for a portion of the perfume materials in Michael, and would have been motivated to do so since Rassat et al. suggests that adding such high impact perfume materials help deliver a high olfactive performance at very low dosages. Regarding Claim 3: The above perfume composition of Michael (16:44-55) constitutes a mixture of ingredients that reads upon a "perfume oil" of about 100% of a perfume formulation. Regarding Claims 9-10: Michael further teaches fabric softener compositions comprising 0.25-0.90% perfume capsules/delivery system and 0.25-0.30% of unencapsulated perfume/free perfume (Table 2). The examples in Table 2 also show a perfume capsule to unencapsulated perfume ratio of about 3:1 to about 1:1. Regarding Claims 2, 13, and 15: The Office realizes that all of the claimed effects or physical properties are not positively stated by the reference(s). However, the reference(s) teaches all of the claimed ingredients in the claimed amounts made by a substantially similar process. The original specification does not identify a feature that resuIts in the claimed effect or physical property outside of the presence of the claimed components in the claimed amount. Specifically, the original specification states that “In case the delivery system is a core-shell microcapsule having a biodegradable shell, it is herein understood that the perfume formulation is comprised in the core which is surrounded by a biodegradable shell wall of the microcapsule. The nature of the biodegradable shell of the microcapsules of the invention can vary.” (page 4, lines 13-16) and merely suggests that the effects and properties arise by the composition of biodegradable shell. Furthermore, the original specification specifically teaches that the biodegradable shell can comprise “gelatin / gum Arabic shell wall”. (page 4, line 22) which is taught by the applied prior art (see above). Therefore, the claimed effects and physical properties, ie. the chemical stability and percentage of perfume leaks out of the microcapsules and the biodegradability of the carrier, would naturally arise and be achieved by a composition with all the claimed ingredients. "Products of identical chemical composition cannot have mutually exclusive properties." In re Spada, 911 F.2d 705, 709, 15 USPQ2d 1655, 1658 (Fed. Cir. 1990). A chemical composition and its properties are inseparable. Therefore, if the prior art teaches the identical chemical structure, the properties applicant discloses and/or claims are necessarily present. See MPEP § 2112.01. If it is the applicant's position that this would not be the case: (1) evidence would need to be provided to support the applicant's position; and (2) it would be the Office's position that the application contains inadequate disclosure that there is no teaching as to how to obtain the claimed properties with only the claimed ingredients. Claims 6-7 are rejected under 35 U.S.C. 103 as being unpatentable over Michael (US Pat. 4,946,624) in view of Rassat et al. (WO 2018/115250 Al) when taken with Bacon et al. (US Pat. 5,500,138) as set forth above regarding claims 1-3 and 9-13, and further in view of Taylor et al. (US Pat. 4,741,856). Regarding claims 6-7: Michael teaches the basic claimed laundry composition (ie. aqueous fabric softener) as set forth above. Michael does not specifically teach a perfume composition containing the claimed Hansen solubility parameters (eg. an atomic dispersion force from 12 to 20, a dipole moment from 1 to 8, and a hydrogen bonding from 2.5 to 11). However, Taylor et al. teaches a perfume oil comprising hexyl salicylate, hexyl cinnamic aldehyde, hexyl cinnamic aldehyde, or mixtures thereof (5:1-30). Michael and Taylor et al. are analogous art because they are from the same field of endeavor, namely, perfume materials for laundry products. At the time of filing a person of ordinary skill in the art would have found it obvious to have substituted the at least one of the perfume materials, as taught by Taylor et al. for a portion of the perfume materials in Michael, and would have been motivated to do so since Michael suggests the perfume materials of Taylor et al. are especially desirable (3:30-42). Response to Arguments Applicant's arguments filed 16-MAR-2026 have been fully considered but they are not persuasive in view of the following: Applicant argues that the instant claims have “improved olfactive performance and reduced perfume leakage”. This is not persuasive as Applicant’s arguments do not dispute that the applied references of the rejection teach all of the claimed ingredients in the claimed amounts. As such, as set forth in the rejection above, the instant effects and properties of the composition would be necessarily present in a composition formed by the combination of references. Furthermore, Applicant’s arguments allege that various improvements are observed, however, it is noted that there is no evidence presented that such effects are unexpected. In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). Correspondence Any inquiry concerning this communication or earlier communications from the examiner should be directed to MARK EASHOO whose telephone number is (571)272-1197. The examiner can normally be reached M-F, 7am - 4pm. 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, Patricia Mallari, can be reached at 571-272-4729. 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. MARK EASHOO, Ph.D. Supervisory Patent Examiner Art Unit 1767 /MARK EASHOO/ Supervisory Patent Examiner, Art Unit 1767
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Prosecution Timeline

Jun 17, 2022
Application Filed
Jan 23, 2025
Non-Final Rejection — §103
Apr 15, 2025
Response Filed
Jun 28, 2025
Non-Final Rejection — §103
Aug 13, 2025
Response Filed
Dec 04, 2025
Final Rejection — §103
Feb 09, 2026
Response after Non-Final Action
Mar 16, 2026
Request for Continued Examination
Mar 18, 2026
Response after Non-Final Action
Apr 03, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12559700
METHOD OF MAKING LIQUID LAUNDRY DETERGENT FORMULATION
2y 5m to grant Granted Feb 24, 2026
Patent 11401382
THERMOPLASTIC POLYAMIDE PARTICLES
2y 5m to grant Granted Aug 02, 2022
Patent 11370913
THERMOPLASTIC ELASTOMER COMPOSITION, METHOD FOR PRODUCING THE SAME, AND ELASTOMER MOLDED BODY
2y 5m to grant Granted Jun 28, 2022
Patent 10907107
AMPHIPHILIC ASPHALTENE IONIC LIQUIDS AS DEMULSIFIERS FOR HEAVY PETROLEUM CRUDE OIL-WATER EMULSIONS
2y 5m to grant Granted Feb 02, 2021
Patent 10882947
RAPID CURING EPOXY ADHESIVE COMPOSITIONS
2y 5m to grant Granted Jan 05, 2021
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

4-5
Expected OA Rounds
39%
Grant Probability
71%
With Interview (+31.8%)
3y 6m
Median Time to Grant
High
PTA Risk
Based on 139 resolved cases by this examiner. Grant probability derived from career allow rate.

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