Prosecution Insights
Last updated: April 18, 2026
Application No. 18/086,538

CATALYST FOR FUEL CELLS, ELECTRODE CATALYST LAYER, MEMBRANE ELECTRODE JOINED BODY, SOLID POLYMER TYPE FUEL CELL, METHOD FOR PRODUCING TITANIUM OXIDE FOR CATALYST CARRIERS, AND METHOD FOR PRODUCING CATALYST FOR FUEL CELLS

Final Rejection §102§112
Filed
Dec 21, 2022
Examiner
CONLEY, OI K
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Toppan Inc.
OA Round
2 (Final)
70%
Grant Probability
Favorable
3-4
OA Rounds
3y 7m
To Grant
77%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
597 granted / 858 resolved
+4.6% vs TC avg
Moderate +8% lift
Without
With
+7.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
38 currently pending
Career history
896
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
37.2%
-2.8% vs TC avg
§102
34.5%
-5.5% vs TC avg
§112
21.5%
-18.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 858 resolved cases

Office Action

§102 §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 . The Applicant’s amendments were received on 11/3/2025. Claim 1 and 2 are amended. Claims 5-8 are new. The text of those sections of Title 35, U.S.C. code not included in this action can be found in the prior Office Action. Information Disclosure Statement The information disclosure statement (IDS) submitted on 8/4/25 is considered by the examiner. Specification The disclosure objection is maintained. The disclosure is objected to because of the following informalities: “j” and “i” are not further define. In addition, the disclosure is objected to because of the following informalities: “y is less than 2,” “j is less than 2,” “y+j is less than 2,“ “z is less than 1,” “i is less than 1, and “z+i is less than 1,” “x is 1 or 2,” “y is 0, 1, or 2,” “w is 0 or 1” and “z is 0 or 1” are not supported in Applicant’s specification. Appropriate correction is required without adding new matter. Claim Rejections - 35 USC § 112 The rejection under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, on claims 1-4 are maintained. The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 1-4 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the enablement requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to enable one skilled in the art to which it pertains, or with which it is most nearly connected, to make and/or use the invention. The limitation “j” is not defined since it is unknown what “j” is. The Applicant’s discloses a formula but how one of ordinary skill in the art find “j” is unknown. Appropriate corrections and further clarification is required. Claims depending from claims rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph are also rejected for the same. Claims 1-4 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the enablement requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to enable one skilled in the art to which it pertains, or with which it is most nearly connected, to make and/or use the invention. The upper limit of j is not defined in j≥0 The subject matter of a claim must still have definite boundaries, no matter how broad or narrow. The problem arising from the lack of limits on subscripts would not be undue breadth, but that the actual extent of this breadth cannot be determined. While a skilled artisan may be able to select some values for the subscript, the artisan would not know what the limits or boundaries of the possible values are. Appropriate corrections and further clarification is required. Claims depending from claims rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph are also rejected for the same. Claim 2 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the enablement requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to enable one skilled in the art to which it pertains, or with which it is most nearly connected, to make and/or use the invention. The limitation “i” is not defined since it is unknown what “i” is. The Applicant’s discloses a formula but how one of ordinary skill in the art find “i” is unknown. Appropriate corrections and further clarification is required. Claim 2 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the enablement requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to enable one skilled in the art to which it pertains, or with which it is most nearly connected, to make and/or use the invention. The upper limit of i is not defined in i≥0 The subject matter of a claim must still have definite boundaries, no matter how broad or narrow. The problem arising from the lack of limits on subscripts would not be undue breadth, but that the actual extent of this breadth cannot be determined. While a skilled artisan may be able to select some values for the subscript, the artisan would not know what the limits or boundaries of the possible values are. Appropriate corrections and further clarification is required. Claim 5 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “x is less than 2” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 5 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “y is less than 2” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 5 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “j is less than 2” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 5 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “y+j is less than 2” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 6 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “w is less than 1” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 6 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “z is less than 1” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 6 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “i is less than 1” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 6 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “z+i is less than 1” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 7 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “x is 1 or 2” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 7 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “y is 0, 1, or 2” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 8 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “w is 0 or 1” is not supported in Applicant’s specification. Appropriate corrections are required. Claim 8 is rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. The limitation “z is 0 or 1” is not supported in Applicant’s specification. Appropriate corrections are required. Claim Rejections - 35 USC § 112 The rejection under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, on claims 1-4 are withdrawn because the Applicant amended the claims. Claim Rejections - 35 USC § 102 As best understood, the rejections under 35 U.S.C. 102(a)(1) as being anticipated by Morikawa et al., on claim 1 has been maintained. The rejection is modified in view of the Applicant’s amendments. 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. Claim(s) 1 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Morikawa et al. (EP1205244). Regarding claim 1, the Morikawa et al. reference discloses a known component comprising fibrous, rutile, an oxide including an oxygen atom, a nitrogen atom, and a transition metal atom, wherein the transition metal atom is at least one selected from the group consisting of a titanium atom, a tantalum atom, a niobium atom, and a zirconium atom, the fibrous rutile-type oxide is represented by a chemical formula MOXNy, where the transition metal atom is represented by M, and x in the chemical formula satisfies the following: x=2-(y+j) (j≥0) (P10). It is noted that the claim limitation “of the catalyst for the fuel cell” are “intended” use limitations and it has been held that a recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647 (1987). Response to Arguments Applicant's arguments filed 11/3/2025 have been fully considered but they are not persuasive. The Applicants argue, “For clarity, "wherein" has been added to claims 1 and 2 to make it clear that the definition of j in claim 1 is (j > 0) and the definition of i in claim 2 is (i > 0). Therefore, variables j and i are defined.” The variable of “i” and “j” aren’t define in how one of ordinary skill would find “j” and “i” to even understand what the maximum limit would be. Thus, the rejection are maintained. The Applicant’s argue, “As described in paragraphs [0024] and [0025], the fibrous catalyst 21 is a rutile- type metal oxide in which a part of the oxygen atoms are replaced with nitrogen atoms. For example, when the transition metal atom of the catalyst is titanium, in the chemical formula TiOXNy, the valence of Ti is +4, that of O is -2, and that of N is -3. In TiOXNy, only a part of the oxygen atoms are replaced with nitrogen atoms, and not all of them.” However, that is assuming that Ti has a valence of -4 for x to be -2 and potentially for N is -3. It can be possible that Ti can be valence of -3 or even 2p-3/2 or even TiO6-xNx for rutile oxides, for example. The Applicants have to provide, specifically where to find the valence of Ti, O and N from Applicant’s specification for the Examiner to consider these arguments. Otherwise, since it is unknown if Ti even comprises a valence of -4 from Applicant’s specification, these arguments are moot. The Applicants argue, “Paragraph [0025] further states that "a part of the oxygen atoms is removed to eliminate the charge imbalance caused by the replacement of oxygen atoms with nitrogen atoms." Since the valence of O is -2 and that of N is -3, in TiOXNy, charge balance can be achieved only when x is greater than y (i.e., x > y) and x is less than 2. However, that is only assuming that Ti comprises a valence of -4 which isn’t supported. Again, it can be possible that Ti can be valence of -3 or even 2p-3/2 or even TiO6-xNx for rutile oxides, for example. In these examples, x>y but one cannot assume that O can be less than 2 for TiO6- xNx since it appears to state that O can equal to 2 or more. The Applicants argue, “Accordingly, it is apparent that x corresponds to the number obtained by subtracting the sum of y and j (which compensates for the charge imbalance) from 2, i.e., x 2 -(y +7). It is also evident that x, y, and j are each less than 2, and that (y +j) is less than 2.” However, there is no evidence that Applicant’s specification discloses x, y, or j is less than 2. Therefore, these arguments are moot. The Applicants argue, “As described in paragraphs [0028] and [0029], another example of the fibrous catalyst 21 is a rutile-type metal oxide in which a part of the oxygen atoms are replaced with nitrogen atoms, and a part of the transition metal atoms are replaced with phosphorus atoms. For example, when the transition metal atom is titanium, in the chemical formula TiwOxNyPz, the valence of Ti is +4, and that of P is +5. In TiWOXNyPz, only a part of the titanium atoms are replaced with phosphorus atoms, and not all of them. Paragraph [0025] also states that "a part of the oxygen atoms is removed to eliminate the charge imbalance caused by the replacement of oxygen atoms with nitrogen atoms." Since the valence of Ti is +4 and that of P is +5, charge balance in TiwOXNyPz can be maintained only when w is greater than z (i.e., w > z) and w is less than 1.” Actually, in Paragraph 31, it states that 0.1≤z≤2 and w is 1, then z can be higher than w. Again, there are no sufficient evidence to support the Applicant’s arguments. Therefore, these arguments are moot. Applicant argues, “Accordingly, it is apparent that w corresponds to the number obtained by subtracting the sum of z and i (which compensates for the charge imbalance) from 1, i.e., w 1-(z+i). It is also evident that w, z, and i are each less than 1, and that (z +i) is less than 1. Therefore, a person of skill in the art would understand the upper limit of j and i in the specification and Applicant requests reconsideration of the rejection under 35 U.S.C.112(a). “ Again, there are no sufficient evidence to support the Applicant’s arguments. Therefore, these arguments are moot. Conclusion 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 HELEN OI CONLEY whose telephone number is (571)272-5162. The examiner can normally be reached 8:30 am - 5:00 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, Nicholas Smith can be reached at 5712728760. 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. /Helen Oi K CONLEY/ Primary Examiner, Art Unit 1752
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Prosecution Timeline

Dec 21, 2022
Application Filed
Jun 27, 2025
Non-Final Rejection — §102, §112
Oct 02, 2025
Interview Requested
Oct 23, 2025
Examiner Interview Summary
Oct 23, 2025
Applicant Interview (Telephonic)
Nov 03, 2025
Response Filed
Nov 28, 2025
Final Rejection — §102, §112
Apr 01, 2026
Response after Non-Final Action
Apr 01, 2026
Request for Continued Examination
Apr 05, 2026
Response after Non-Final Action

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Prosecution Projections

3-4
Expected OA Rounds
70%
Grant Probability
77%
With Interview (+7.8%)
3y 7m
Median Time to Grant
Moderate
PTA Risk
Based on 858 resolved cases by this examiner. Grant probability derived from career allow rate.

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