Prosecution Insights
Last updated: April 19, 2026
Application No. 17/793,817

NOVEL FORMULATIONS COMPRISING CANNABIS

Final Rejection §102§103
Filed
Jul 19, 2022
Examiner
SCHMIDT, IZABELA MARIA
Art Unit
1621
Tech Center
1600 — Biotechnology & Organic Chemistry
Assignee
Nutramax Laboratories, Inc.
OA Round
2 (Final)
62%
Grant Probability
Moderate
3-4
OA Rounds
3y 0m
To Grant
99%
With Interview

Examiner Intelligence

Grants 62% of resolved cases
62%
Career Allow Rate
49 granted / 79 resolved
+2.0% vs TC avg
Strong +53% interview lift
Without
With
+53.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
39 currently pending
Career history
118
Total Applications
across all art units

Statute-Specific Performance

§101
1.0%
-39.0% vs TC avg
§103
31.5%
-8.5% vs TC avg
§102
19.7%
-20.3% vs TC avg
§112
18.1%
-21.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 79 resolved cases

Office Action

§102 §103
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 . Final Action Priority Instant application 17/793,817 filed on 07/19/2022 claims benefit as follow: CONTINUING DATA: PNG media_image1.png 63 338 media_image1.png Greyscale Status of the Application Claims 1, 3-5, 7-15, 17-19 and 21-32 are pending. Response to Arguments/Amendments The amendment filled on 10/21/2025 has been entered. Applicant amended claim 1 and added new claims 29-32. Applicant’s amendment overcome the rejections of record; therefore, all rejections of record are withdrawn. However, it should be noted that none of the amended claims is directed to the elected composition comprising only cannabidiol and analgesics. The amended claims require at least one of a yeast wall source and hydrolyzed brewer’s yeast. Applicant’s amendment necessitated new grounds of rejections presented in this office action. The withdrawn rejections are reapplied with an additional reference. In addition, new rejections over US-20190078168-A1 are made. Regarding Applicant’s arguments, Applicant submitted: PNG media_image2.png 234 715 media_image2.png Greyscale Applicant's arguments have been fully considered but they are not persuasive. It should be noted that the instant specification describes comparative data of instant gel compositions and oil compositions. However, no comparative data of the instant composition and gel compositions disclosed in prior art has been presented. In addition, even if the disclosed compositions show improvements over the gel compositions described in prior art, the improved results are not commensurate in scope with the instant claims because it is not clear what amount of yeast (and/or other ingredients) lead to improved bioavailability. As evidenced by Pletcher (https://www.healthline.com/health/food-nutrition/is-yeast-extract-bad-for-me, updated on October 12, 2017) yeast are often used as food flavoring and/or as nutritional supplements: PNG media_image3.png 429 1030 media_image3.png Greyscale Regarding nutritional supplements, for example Macrogard Pet is sold as food supplement supporting immune system of dogs (https://www.biolabfarma.com.br/en/product-9/macrogard-pet-2/, printed 12/3/2025): PNG media_image4.png 127 601 media_image4.png Greyscale Further, Immune Health Basis contains ingredients derived from “the call wall of a proprietary strain of yeast” (https://www.nhc.com/immune-health-basics-500-mg-by-immune-health-basics ): PNG media_image5.png 95 563 media_image5.png Greyscale Therefore, a person of ordinary skill would have been motivated to add yeast cell wall source or/and hydrolyzed brewer’s yeast to the compositions disclosed in prior art. It is known that unflavored cannabidiol (CBD) has a strong taste that many people consider unpleasant (as evidenced by https://sorsetech.com/why-do-most-cannabis-products-taste-so-bad/).The skilled artisan would have been motivated to add yeast as nutritional supplement or/and to improve the taste of the composition. Election/Restrictions Claims 15, 17-19 and 21-28 are withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected invention, there being no allowable generic or linking claim. Applicant timely traversed the restriction (election) requirement in the reply filed on 06/16/2025. In response to species election requirement, PNG media_image6.png 313 605 media_image6.png Greyscale Applicant elected composition of cannabidiol and analgesics for oral administration to mammalian. Applicant also elected inflammation for the species of disease or disorder. The instant claim 1 recite “a source of the at least one cannabinoid is a hemp oil extract”. Since the elected composition comprises only cannabidiol and analgesics (additional ingredients have not been named/elected), it implies that the cannabidiol is derived from hemp oil extract (is not synthetic as required in instant claim 7). Regarding instant claims 30-32, the elected composition comprises only cannabidiol and analgesics, thus, the newly added claims 30-32 do not read on the elected composition. Claims 7, 8, 9, 13 and 30-32 are withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected species, there being no allowable generic or linking claim. Applicant timely traversed the restriction (election) requirement in the reply filed on 06/16/2025. Examination will begin with the elected species. In accordance with the MPEP 803.02, if upon examination of the elected species, no prior art is found that would anticipate or render obvious the instant invention based on the elected species, the search of the Markush-type claim will be extended. If prior art is then found that anticipates or renders obvious the non-elected species, the Markush-type claim will be rejected. It should be noted that the prior art search will not be extended unnecessarily to cover all non-elected species. Should Applicant overcome the rejection by amending the claim, the amended claim will be reexamined. Id. The prior art search will be extended to the extent necessary to determine patentability of the Markush-type claim. Id. In the event prior art is found during reexamination that renders obvious or anticipates the amended Markush-type claim, the claim will be rejected and the action made final. Id. 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. (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, 3-5, 10-12 and 14 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Sayre (US2019/0078168 A1). Sayre teaches and claims compositions comprising water soluble cannabinoids and yeast cells (see claim 1): PNG media_image7.png 248 436 media_image7.png Greyscale Sayre teaches cannabidiol (CBD) from Cannabis (aka hemp): PNG media_image8.png 82 426 media_image8.png Greyscale Sayre teaches a composition comprising CBD and yeast: PNG media_image9.png 129 431 media_image9.png Greyscale Sayre teaches gel formulations for oral administration: PNG media_image10.png 130 340 media_image10.png Greyscale Sayre teaches pharmaceutical formulations in unit dosage forms: PNG media_image11.png 78 434 media_image11.png Greyscale Regarding claims 10-11, Sayre teaches the compositions are intended for mammals: PNG media_image12.png 154 420 media_image12.png Greyscale Regarding claim 12, Sayre does not explicitly teach that the mammalian subject is a cat. However, MPEP states that a reference disclosure can anticipate a claim when the reference describes the limitations but "'d[oes] not expressly spell out' the limitations as arranged or combined as in the claim, if a person of skill in the art, reading the reference, would ‘at once envisage’ the claimed arrangement or combination." (See also MPEP 2131.02 III). Sayre teaches administrations to mammals (e.g., humans), thus, one of ordinary skill would ‘at once envisage’ common mammals, for example, cats. Regarding claim 14, Sayre teaches the compositions further comprising nutritional supplements: PNG media_image13.png 137 431 media_image13.png Greyscale Since the teachings of Sayre meet all the limitations of instant claims 1, 3-5, 10-12 and 14, those claims are anticipated. 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. 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. Claims 1, 3-5, 10-12, 14 and 29 are rejected under 35 U.S.C. 103 as being unpatentable over Ghalili (US-20200085739 -A1, Filed Aug, 29, 2019) in view of Auinger (Annegret Auinger et al., Eur J Nutr (2013) 52:1913–1918) evidenced by Regulations.gov (Yeast Extract Hydrolysate from Saccharomyces cerevisiae ; PC Code: 100053., September 24, 2018). Ghalili teaches hydrogel compositions useful as analgesics comprising cannabinoids, menthol and anesthetic in a composition formulated to be administrable to a non-human animal rectally (abstract). Ghalili teaches compositions used to relive pain and/or inflammation for oral administration: PNG media_image14.png 462 364 media_image14.png Greyscale Ghalili teaches cannabidiol (CBD) and full spectrum hemp oil: PNG media_image15.png 119 528 media_image15.png Greyscale Regarding instant claims 4 and 5, please note that the instant specification states that cannabis oil extract comprising CBD is extracted from hemp and any cannabis plants (see page 92): PNG media_image16.png 301 595 media_image16.png Greyscale Ghalili teaches unit dose formulations (see para [0045]): PNG media_image17.png 416 509 media_image17.png Greyscale Ghalili teaches the composition comprising analgetic, menthol (see para [0051]): PNG media_image18.png 119 509 media_image18.png Greyscale Ghalili teaches the composition comprising analgetic, benzocaine: PNG media_image19.png 169 347 media_image19.png Greyscale Ghalili teaches: PNG media_image20.png 75 530 media_image20.png Greyscale Regarding claims 10-12, Ghalili teaches mammalian subjects, including cats: PNG media_image21.png 128 513 media_image21.png Greyscale Ghalili is silent about yeast cell wall source and hydrolyzed brewer’s yeast. Auinger teaches that yeast (1,3)-(1,6)-beta-glucan helps to maintain the body’s defense against pathogens (see title and Introduction): PNG media_image22.png 193 468 media_image22.png Greyscale Applying KSR prong (A) - it would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine cannabinoids and yest beta-glucans. A person of ordinary skill would have been motivated to add yeast cell wall source or/and hydrolyzed brewer’s yeast to the compositions disclosed by Ghalili as nutritional supplement. In addition, since it is known that unflavored cannabidiol (CBD) has a strong taste that many people consider unpleasant, the skilled artisan would have been motivated to add hydrolyzed brewer’s yeast to improve the taste of the composition. As evidenced by Regulations.gov, hydrolized brewer’s yeast is a safe flavor enhancer (see page 4, II Use and Usage): PNG media_image23.png 150 746 media_image23.png Greyscale Claims 1, 3, 4, 5, 10-12, 14 and 29 are rejected under 35 U.S.C. 103 as being unpatentable over Hoag (US-20180344676-A1) in view of Auinger (Annegret Auinger et al., Eur J Nutr (2013) 52:1913–1918) evidenced by Regulations.gov (Yeast Extract Hydrolysate from Saccharomyces cerevisiae; PC Code: 100053., September 24, 2018). Hoag teaches compositions comprising cannabidiol and one or more NSAIDs: PNG media_image24.png 186 524 media_image24.png Greyscale PNG media_image25.png 140 519 media_image25.png Greyscale Hoag teaches analgesics compositions that can be administered orally: PNG media_image26.png 146 517 media_image26.png Greyscale Hoag teaches extract from Cannabis sativa (aka hemp): PNG media_image27.png 165 516 media_image27.png Greyscale Hoag teaches gel formulations (para [00310]): PNG media_image28.png 110 521 media_image28.png Greyscale Hoag teaches composition comprising CBD and THC: PNG media_image29.png 167 525 media_image29.png Greyscale Regarding claims 10-12, Hoag teaches mammals: PNG media_image30.png 162 505 media_image30.png Greyscale Regarding instant claim 12, a person of ordinary skill would at once envisioned mammals including domestic animals (cats and dogs). MPEP 2131.02 states that “A reference disclosure can anticipate a claim when the reference describes the limitations but "'d[oes] not expressly spell out' the limitations as arranged or combined as in the claim, if a person of skill in the art, reading the reference, would ‘at once envisage’ the claimed arrangement or combination." Further the person of ordinary skill would at once envisioned the formulations formulated in unit dosage because unit dosage packaging enhances safety and convenience. However, Hoag is silent about yeast cell wall source and hydrolyzed brewer’s yeast. Auinger teaches that yeast (1,3)-(1,6)-beta-glucan helps to maintain the body’s defense against pathogens (see title and Introduction): PNG media_image22.png 193 468 media_image22.png Greyscale Applying KSR prong (A) - it would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine cannabinoids and yest beta-glucans. A person of ordinary skill would have been motivated to add yeast cell wall source or/and hydrolyzed brewer’s yeast to the compositions disclosed by Hoag as nutritional supplement. In addition, since it is known that unflavored cannabidiol (CBD) has a strong taste that many people consider unpleasant, the skilled artisan would have been motivated to add hydrolyzed brewer’s yeast to improve the taste of the composition. As evidenced by Regulations.gov, hydrolized brewer’s yeast is a safe flavor enhancer (see page 4, II Use and Usage): PNG media_image23.png 150 746 media_image23.png Greyscale Claims 1, 3-5, 10-12, 14 and 29 are rejected under 35 U.S.C. 103 as being unpatentable over Stinchcomb (US-20100273895-A1) in view of Nielsen (Nielsen et al., Neuropsychopharmacology (2017) 42, 1752–1765) evidenced by Atlas of Florida Plants (https://florida.plantatlas.usf.edu/plant/species/1838; printed 04/10/2025 and in view of Auinger (Annegret Auinger et al., Eur J Nutr (2013) 52:1913–1918) and evidenced by Regulations.gov (Yeast Extract Hydrolysate from Saccharomyces cerevisiae ; PC Code: 100053., September 24, 2018). This rejection applies to the elected composition comprising analgesics. Stinchcomb teaches compositions comprising pharmaceutically active cannabinoids (paragraph [0002]). Further, Stinchcomb teaches that “cannabinoids have been shown to regulate various steps in the immune response and could show some therapeutic benefit in the treatment of certain inflammatory diseases such as psoriatic arthritis” (paragraph [0008]). Furthermore, Stinchcomb teaches the cannabinoid, or mixture of cannabinoids, is obtained from the extract from of a natural source e.g., Cannabis sativa (aka hemp) or from synthetic chemical reactions: PNG media_image31.png 174 425 media_image31.png Greyscale As evidenced by Atlas of Florida Plants (https://florida.plantatlas.usf.edu/plant/species/1838; printed 04/10/2025 –provided with the previous office action) “Hemp” refers to a plant, scientifically known as Cannabis sativa. Further, Stinchcomb teaches CBD gels formulations: PNG media_image32.png 101 434 media_image32.png Greyscale Stinchcomb teaches pharmaceutical dosage forms (see paragraphs [0100] – [0109]) including “a single dosage unit of any formulation comprises a therapeutically effective amount or a therapeutically and/or prophylactically effective amount of cannabidiol” (paragraph [0110]). Moreover, Stinchcomb teaches pharmaceutical compositions suitable for different methods of administration e.g., for oral administration: PNG media_image33.png 88 447 media_image33.png Greyscale Stinchcomb teaches the pharmaceutical compositions comprise one or more pharmaceutically acceptable excipients, including oils (paragraph [0073]). Regarding instant claims 10-12, Stinchcomb teaches mammalian subjects, including domestic animals (see para [0092]): PNG media_image34.png 144 520 media_image34.png Greyscale However, Stinchcomb is silent about yeast cell wall source and hydrolyzed brewer’s yeast. Further, regarding the elected composition, Stinchcomb does not teach the composition comprising additional analgesics. Auinger teaches that yeast (1,3)-(1,6)-beta-glucan helps to maintain the body’s defense against pathogens (see title and Introduction): PNG media_image22.png 193 468 media_image22.png Greyscale Regarding additional analgesics, Stinchcomb teaches cannabinoids, including cannabidiol, are effective in alleviating pain: PNG media_image35.png 302 513 media_image35.png Greyscale In addition, Nielsen teaches combinations of medications can maximize analgetic response (see abstract and page 1752, right column): PNG media_image36.png 275 494 media_image36.png Greyscale Applying KSR prong (A) - it would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine cannabinoids, analgesics and yeast cell wall source and/or hydrolyzed brewer’s yeast with a reasonable expectation of success. One of ordinary skill would have been motivated by the teachings of Nielson to maximize analgetic response of the composition. Further, one of ordinary skill in the art would have been motivated to formulate the compositions comprising CBD and analgetic in unit dosage because unit dosage packaging enhances safety and convenience. In addition, a person of ordinary skill would have been motivated to add yeast cell wall source or/and hydrolized brewer’s yeast to the compositions disclosed by Stinchcomb as nutritional supplement because Auinger teaches immunostimulatory effect of a yeast (1,3)-(1,6)-beta-glucan preparation (see page 1917, left column, second paragraph and right column, first paragraph): PNG media_image37.png 76 466 media_image37.png Greyscale […] PNG media_image38.png 270 477 media_image38.png Greyscale Since it is known that unflavored cannabidiol (CBD) has a strong taste that many people consider unpleasant, the skilled artisan would have been motivated to add hydrolyzed brewer’s yeast to improve the taste of the composition. As evidenced by Regulations.gov, hydrolized brewer’s yeast is a safe flavor enhancer (see page 4, II Use and Usage): PNG media_image23.png 150 746 media_image23.png Greyscale Claims 1, 3-5, 10-12 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Sayre (US2019/0078168 A1) in view of Nielsen (Nielsen et al., Neuropsychopharmacology (2017) 42, 1752–1765). This rejection applies to the elected composition comprising analgesics. The teachings of Sayre have been discussed above (see the 102 rejection above) and those teachings are incorporated herein by reference Regarding analgesics Sayre teaches cannabinoids for treating pain (see paragraph [0254]): PNG media_image39.png 234 434 media_image39.png Greyscale However, Sayre does not explicitly teach composition comprising additional analgesics. Nielsen teaches combinations of medications can maximize analgetic response (see abstract and page 1752, right column): PNG media_image36.png 275 494 media_image36.png Greyscale Applying KSR prong (A) - it would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to combine cannabinoids, analgesics and yeast with a reasonable expectation of success. One of ordinary skill would have been motivated by the teachings of Nielson to maximize analgetic response of the composition. Claim 29 is rejected under 35 U.S.C. 103 as being unpatentable over Sayre (US2019/0078168 A1) in view of Regulations.gov (Yeast Extract Hydrolysate from Saccharomyces cerevisiae ; PC Code: 100053., September 24, 2018) evidenced by Joseph (2014, Encyclopedia of Food Microbiology). The teachings of Sayre have been discussed above (see the 102 rejections) and those teachings are incorporated herein by reference. Sayre teaches compositions comprising autolyzed yest extract: PNG media_image40.png 307 437 media_image40.png Greyscale However, regarding claim 29, Sayre does not teach hydrolyzed brewer’s yeast. As evidenced by Joseph, the difference between autolyzed yeast and hydrolyzed yeast is the method of cell breakdown. In preparation of autolyzed yeast, the enzymes found in the yeast are used to break down the proteins. In hydrolyzed yeast, enzymes or other agents are added to the yeast: PNG media_image41.png 274 632 media_image41.png Greyscale Regulations.gov, teaches hydrolyzed brewer’s yeast is a safe flavor enhancer (see page 4, II Use and Usage): PNG media_image23.png 150 746 media_image23.png Greyscale Applying KSR prong (B) - Simple substitution of one known element for another to obtain predictable results - it would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to substitute autolyzed yeast disclosed by Sayre for hydrolyzed brewer’s yeast for the same purpose. For example, since it is known that unflavored cannabidiol (CBD) has a strong taste that many people consider unpleasant, the skilled artisan would have been motivated to add hydrolyzed brewer’s yeast to improve the taste of the composition. In addition, yeast extracts are often used as dietary supplements because yeast extracts are rich in B vitamins. Conclusion No claim is allowed. Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to IZABELA SCHMIDT whose telephone number is (703)756-4787. The examiner can normally be reached Monday - Friday from 9 am to 5 pm. 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, Clinton A Brooks can be reached at (571)270-7682. 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. /I.S./Examiner, Art Unit 1621 /CLINTON A BROOKS/Supervisory Patent Examiner, Art Unit 1621
Read full office action

Prosecution Timeline

Jul 19, 2022
Application Filed
Jul 17, 2025
Non-Final Rejection — §102, §103
Oct 21, 2025
Response Filed
Dec 10, 2025
Final Rejection — §102, §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

3-4
Expected OA Rounds
62%
Grant Probability
99%
With Interview (+53.3%)
3y 0m
Median Time to Grant
Moderate
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