Prosecution Insights
Last updated: April 19, 2026
Application No. 18/161,349

MULTIFUNCTIONAL TOOL FOR APPLYING MAKEUP

Final Rejection §103
Filed
Jan 30, 2023
Examiner
CHEYNEY, CHARLES
Art Unit
3754
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
L'Oréal
OA Round
4 (Final)
56%
Grant Probability
Moderate
5-6
OA Rounds
2y 8m
To Grant
99%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allow Rate
436 granted / 777 resolved
-13.9% vs TC avg
Strong +43% interview lift
Without
With
+43.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
60 currently pending
Career history
837
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
53.9%
+13.9% vs TC avg
§102
26.4%
-13.6% vs TC avg
§112
14.6%
-25.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 777 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 . Response to Arguments Applicant's arguments filed 02/24/2026 have been fully considered but they are not persuasive. Applicant argues that Giron doses not teach a tool between lid and dispenser to be removed. However, in Para. 114, 332, cosmetic applicator configured to receive a tool therein, and it’s implied if the applicator is kept in the recess, then the lid would cover it, thus positioning the tool between dispenser and lid. In response to applicant's argument that Zhang isn’t intended to be removed and used, a recitation of the intended use of the claimed invention must result in a structural difference between the claimed invention and the prior art in order to patentably distinguish the claimed invention from the prior art. If the prior art structure is capable of performing the intended use, then it meets the claim. However, Zhang clearly teaches the removable nature of the tool placed between the lid and dispenser as recited in para. 15. Further delineation is needed to adequately define the claimed invention from the prior art of record. In response to applicant's argument against the combination of Giron in view of Zhang, the test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference; nor is it that the claimed invention must be expressly suggested in any one or all of the references. Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981). In response to applicant’s argument that there is no teaching, suggestion, or motivation to combine the references, the examiner recognizes that obviousness may be established by combining or modifying the teachings of the prior art to produce the claimed invention where there is some teaching, suggestion, or motivation to do so found either in the references themselves or in the knowledge generally available to one of ordinary skill in the art. See In re Fine, 837 F.2d 1071, 5 USPQ2d 1596 (Fed. Cir. 1988), In re Jones, 958 F.2d 347, 21 USPQ2d 1941 (Fed. Cir. 1992), and KSR International Co. v. Teleflex, Inc., 550 U.S. 398, 82 USPQ2d 1385 (2007). In this case, keeping the outlets from drying out with fluid would lead to improper dosing and further malfunction, thus incorporating the sealing nature of lid with the tool against the dispenser ensures that when the lid is removed, the dispenser is in ready condition for use. 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. Claim(s) 1-3, 10, and 12-14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Giron et al. (US 2018/0042361 A1), and further in view of Zhang (US 2012/0074178 A1). Re: Claim 1, Giron discloses the claimed invention including a cosmetic system for dispensing customized cosmetic compositions, comprising: a dispenser (11) configured to dispense customized amounts of at least two cosmetic components from different cartridges (30) through apertures (115a) in a plate (115b), wherein a recess (115) is formed in the plate and receives the at least two cosmetic components from the apertures (Fig. 6, Para. 331, two cosmetics dispensed into recess); a lid (118) detachably mountable to the plate (Para. 333, lid mounting to plate); and a flexible tool stored between the dispenser and the lid, the tool being removable to collect, mix and apply the at least two cosmetic components (Para. 114, 332, cosmetic applicator configured to receive a tool within the recess), the tool having a convex surface sized and configured to be received within the recess, the tool being, the tool being configured to be disposed between the lid and the plate when the lid is mounted to the plate (Para. 114, 332, cosmetic applicator configured to receive a tool therein) and the tool being configured to be slidably supported by the plate when the lid is removed from the plate as the tool being unsecured to the plate and to the lid when the lid is removed from the plate, (Para. 332, applicator is a separate tool from the device), except for the particulars of the interaction of the tool with the plate and lid. However, Zhang teaches a lid (40) compressing a tool (10) against a plate to sealingly engage an aperture (22), the tool being unsecured to the plate and to the lid when the lid is removed from the plate (Para. 14, lid compressing the tool to sealing engage aperture). It would have been obvious to one having ordinary skill in the art at the time of effective filing date to include a removable tool as taught by Zhang, since Zhang states in Para. 14 that such modification effectively seals the aperture to prevent leaks and inadvertent dispensing of materials. Re: Claim 2, Giron discloses the claimed invention including the plate is detachably coupled to the dispenser (Fig. 17, Para. 114, plate decoupled from the dispenser). Re: Claim 3, Giron discloses the claimed invention including cartridge includes a nozzle (30a, 37) from which the corresponding cosmetic component is discharged, each nozzle being in sealing engagement with one of the apertures (Fig. 5, 16A, Para. 292, nozzles tightly engaged with the aperture). Re: Claim 10, Giron disclose a device capable performing the claimed method of cosmetic composition from a dispenser having at least two cartridges, each cartridge containing a cosmetic component (Para. 342, dispenser for cartridges and allowing the user to customize the amounts) and being configured to dispense the corresponding cosmetic component through an aperture in a plate (115b) into a recess (115) formed in the plate (Fig. 16a, Para. 331, dispenses into recess), the plate forming part of the dispenser, the method comprising the steps of: removing a tool stored between the plate (Para. 114, 332, cosmetic applicator configured to receive a tool within the recess) and a lid (118) detachably coupled to the dispenser and a tool being unsecured to the plate and to the lid when the lid is removed from the plate (Para. 332, removing lid and separate tool placed in recess), except for the engagement of the lid and plate with the tool. However, Zhang discloses a lid compresses a tool against the plate to maintain sealing engagement with the apertures in the plate (Fig. 3, Para. 14, lid compressing the tool to sealing engage aperture) and unsealing the apertures in the plate by removing the tool after removing the lid (Fig. 2); It would have been obvious to one having ordinary skill in the art at the time of effective filing date to include a removable tool as taught by Zhang, since Zhang states in Para. 14 that such modification effectively seals the aperture to prevent leaks and inadvertent dispensing of materials. Giron further teaching dispensing an amount of one or more of the cosmetic components into the recess (Para. 331, dispensing an amount of material); mixing the one or more cosmetic components in the recess with the tool to form the cosmetic composition (Para. 332, mixing with the recess); and applying the cosmetic composition using the tool (Para. 332, applying with tool). Re: Claim 12, the device of Giron as modified by Zhang in the rejection of claim 10 above is capable of performing the claimed method of cleaning the tool; cleaning the plate; placing the tool in the recess of the plate; and coupling the lid to the dispenser (Zhang: Para. 15, plate and tool may be removed from each other for cleaning). Re: Claim 13, the device of Giron as modified by Zhang in the rejection of claim 10 above is capable of performing the claimed method of coupling the lid to the dispenser compresses the tool to seal the apertures (Zhang: Col. 19, lines 13-16, tightly grips tool against the apertures for sealing). Re: Claim 14, the device of Giron discloses a device capable of performing the claimed method including a plurality of apertures to be cover by a flexible tool (Para. 332) and as modified by Zhang teaching a tool including a protrusions (11) extending from one side, wherein one of the protrusion extends into and is compressed by each of the apertures (22) (Zhang: Depicted in Fig. 3). It would have been obvious to one having ordinary skill in the art at the time of the effective filing date to include a tool with protrusions as taught by Zhang, since Zhang states in para. 14 that such a modification provides for a sealing engagement between the protrusion and aperture, and as a result, liquid contained in the cartridges is prevented from flowing out of the aperture Claim(s) 4-9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Giron et al. (US 2018/0042361 A1) and Zhang (US 2012/0074178 A1) as applied to claim 2 above, and further in view of Gueret (US 2005/0042018 A1). Re: Claim 4, Giron discloses the claimed invention including the tool may take many forms (Para. 332, any suitable tool) except for the claimed particulars. However, Gueret teaches a tool has a disk-shaped profile with a central portion surrounded by an annular tapered portion (Para. 62, disc shape and annularly tapered). It would have been obvious to one having ordinary skill in the art at the time of the effective filing date to include the tool as taught by Gueret, since Gueret states in paragraph 62 that such a modification provides a tool of increased flexibility, and further it has been held that the configuration of the claimed feature was a matter of choice which a person of ordinary skill in the art would have found obvious absent persuasive evidence that the particular configuration of the claimed feature was significant. In re Dailey, 357 F.2d 669, 149 USPQ 47 (CCPA 1966). Re: Claim 5, Giron as modified by Gueret in the rejection of claim 4 above discloses the claimed invention including the tool includes a first portion made from a first material and a second portion made from a second material, wherein the first material has a difference hardness that the second material (Gueret: Para. 62, different portions of different material hardness). Re: Claim 6, Giron discloses the claimed invention except for tool protrusions on a side to be received in the apertures. However, Zhang teaches tool (10) includes at least one protrusion (11) extending from one side, each protrusion being sized and positioned to be received by one of the apertures (22) of the plate when the tool is disposed between the lid and the plate, and the lid is mounted to the plate (Fig. 3, Para. 14, projection received in aperture between lid and plate)). It would have been obvious to one having ordinary skill in the art at the time of the effective filing date to include a tool with protrusions as taught by Zhang, since Zhang states in para. 14 that such a modification provides for a sealing engagement between the protrusion and aperture, and as a result, liquid contained in the cartridges is prevented from flowing out of the aperture. Re: Claim 7, Giron as modified by Zhang in the rejection of claim 6 above discloses the claimed invention including each protrusion is compressed by and sealingly engages the corresponding aperture of the plate (Zhang: Depicted in Fig. 3). Re: Claim 8, Giron as modified by Zhang in the rejection of claim 6 above discloses the claimed invention including the tool includes a number of protrusions (11) extending from one side, each protrusion being sized and positioned to be received by one of the apertures (22) of the plate when the tool is disposed between the lid and the plate, and the lid is mounted to the plate (Zhang: Fig. 3, Para. 14, projection received in aperture between lid and plate). Re: Claim 9, Giron as modified by Zhang in the rejection of claim 6 above discloses the claimed invention including each protrusion is compressed by and sealingly engages the corresponding aperture of the plate (Zhang: Depicted in Fig. 3, Para. 14, protrusion engage with protrusion). Conclusion THIS ACTION IS MADE FINAL. 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 CHARLES P. CHEYNEY whose telephone number is (571)272-9971. The examiner can normally be reached Monday - Friday, 8:00 am - 4:30 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, Paul Durand can be reached at 571-272-4459. 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. /CHARLES P. CHEYNEY/Primary Examiner, Art Unit 3754
Read full office action

Prosecution Timeline

Jan 30, 2023
Application Filed
Apr 23, 2025
Non-Final Rejection — §103
Jul 30, 2025
Response Filed
Aug 07, 2025
Final Rejection — §103
Oct 09, 2025
Response after Non-Final Action
Nov 10, 2025
Request for Continued Examination
Nov 15, 2025
Response after Non-Final Action
Nov 19, 2025
Non-Final Rejection — §103
Feb 24, 2026
Response Filed
Mar 06, 2026
Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12599687
Fluid Dispenser With UV Sanitation
2y 5m to grant Granted Apr 14, 2026
Patent 12595104
CONTAINER
2y 5m to grant Granted Apr 07, 2026
Patent 12594576
REMOVABLE CLOSURE CAP FOR CONTAINERS CONTAINING AIR-CURABLE MATERIAL
2y 5m to grant Granted Apr 07, 2026
Patent 12583011
DRIVE MECHANISM AND VISCOUS MATERIAL DISPENSING GUN
2y 5m to grant Granted Mar 24, 2026
Patent 12569914
SYSTEM AND METHOD FOR CONTROLLING FLOW THROUGH A 3D PRINTER
2y 5m to grant Granted Mar 10, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get 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
56%
Grant Probability
99%
With Interview (+43.4%)
2y 8m
Median Time to Grant
High
PTA Risk
Based on 777 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month