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 .
Applicant’s amendment, filed on 2/09/2026, is acknowledged.
Claims 1-10 and 17-22 are cancelled.
Claims 11-16 and 23-36 are currently pending.
Claims 11 and 28 are independent claims
Election/Restrictions
Applicants’ election without traverse of Group I, claims 11-16 and 28-33, directed to an anti-TSPAN3 antibody, and the Species of: i) an anti-TSPAN3 antibody comprising the CDRs set forth in SEQ ID NO: 13-15 and 33-35 and the VH and VL of SEQ ID NO: 12 and 32; and ii) myeloid neoplasm, filed on 2/09/2026, is acknowledged.
As stated in the Restriction Requirement mailed on 11/13/2025, the inventions of Groups I and III have unity of invention, and therefore Group III will be examined as well.
Claims 11-16 and 23-36 are under examination as reading on an anti-TSPAN3 antibody and methods of treatment comprising administration of anti-TSPAN3 antibodies.
Priority
Applicant’s claim for the benefit of a prior-filed U.S. Provisional Patent Application No. 63/092,384, filed on October 15, 2020, is acknowledged.
Information Disclosure Statement
The information disclosure statement (IDS) submitted on 7/10/2023 and 2/09/2026 are in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statements are being considered by the examiner in their entireties.
Specification
The title of the invention is not descriptive. A new title is required that is clearly indicative of the invention to which the claims are directed.
Claim Rejections - 35 USC § 112
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 11-16 and 23-36 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, because the specification, while being enabling for the anti-TSPAN3 TSPAN-3 M1-M6 antibody clone structures, and methods of treating a cancer expressing TSPAN3 in a subject comprising administration of these antibody clone structures, does not reasonably provide enablement for the currently claimed genera of anti-TSPAN3 antibodies with the function “anti-TSPAN3” and methods of treating and/or preventing a TSPAN3 expressing cancer comprising administration of these genera of antibodies. The specification does not enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the invention commensurate in scope with these claims.
Factors to be considered in determining whether undue experimentation is required to practice the claimed invention are summarized In re Wands (858 F2d 731, 737, 8 USPQ2d 1400, 1404 (Fed. Cir. 1988)). The factors most relevant to this rejection are the scope of the claim, the amount of direction or guidance provided, the lack of sufficient working examples, the unpredictability in the art and the amount of experimentation required to enable one of skill in the art to practice the claimed invention.
Breadth of claims and nature of invention:
Claims 11-16 and 28-33 encompass a broad genus of anti-TSPAN3 antibodies with either no recited structure (claim 28 and 31-33) or a genus of antibodies encompassing the CDR combinations recited in claim 11 (claims 11-16, 29, and 30), with the recited function of “anti-TSPAN3”. For example, the genus of antibodies recited in claim 11(c), which includes the elected species of antibody, includes 36 different CDR combinations, and therefore the total number of antibodies in the genus recited in claim 11 is 108 antibodies.
Claims 23-27 and 34-36 encompass methods of treating and/or preventing a cancer that expressed TSPAN3 comprising administration a therapeutically effective amount of a broad genus of anti-TSPAN3 antibodies with either no recited structure (claims 34-36) or a genus of antibodies encompassing the CDR combinations recited in claim 11 (claims 23-27), with the recited function of “anti-TSPAN3”
The specification discloses the identification of antibodies that specifically bind to TSPAN3 from immunization of mice followed by hybridoma clone isolation (Example 1, Tables 1 and 3).
Amount of direction and existence of working examples:
Six anti-TSPAN3 clones were identified and characterized, TSPAN3-C M1-M6 (Tables 1-3). Each of these antibodies has a specific set of CDR sequences that are critical for antigen binding that give rise to the function of “anti-TSPAN3”, which are disclosed in Table 1. For example, the M5/M6 clones have the HCDR1-3 of SEQ ID NO: 13-15, respectively, and the LCDR1-3 of SEQ ID NO: 33-35, respectively. Other than listing these different clone structure, no other structure-function relationship between an antibody’s amino acid sequence and the function of “anti-TSPAN3”.
The instant specification additionally discloses examples of methods of inhibiting AML and bcCML cancer growth in vitro (Example 1, Fig. 3-4) and in vivo (Example 1, Fig 6), comprising administration of the anti-TSPAN3 M5 and M6 clones.
Level of predictability, state of prior art, and quantity of experimentation needed:
Regarding the claimed genera of antibodies and the function of “anti-TSPAN3”:
The claims are directed to a genus of antibodies or a method of treatment/prevention of cancer comprising administration of a genus of antibodies with either no recited structure (claims 28 and 31-36), or a genus of 108 different antibody CDR combinations (claims 11-16, 23-27, 29, and 30), all with the function of “anti-TSPAN3”.
However, the specification did not give the skilled in the art enough information to choose candidate antigen binding structures from the vast number of options of millions of candidates, and therefore required scientists to engage in a great deal of experimentation and failure. “That is not enablement”—it is a “hunting license.”
The specification discloses 6 different antibody structures with the function of “anti-TSPAN3”. These antibody clones, defined by their specific amino acid sequences, have a great deal of variation between their CDR regions. The instant specification does not disclose any guidance on which amino acid sequence structures would predictably give rise to antibodies with the function of “anti-TSPAN3”.
In Amgen Inc. et al. v. Sanofi et al., 598 U.S. 594, 2023 USPQ2d 602 (2023), the Supreme Court held that claims drawn to a genus of monoclonal antibodies, which were functionally claimed by their ability to bind to a specific protein, PCSK9, were invalid due to lack of enablement. The claims at issue were functional, in that they defined the genus by its function (the ability to bind to specific residues of PCSK9) as opposed to reciting a specific structure (the amino acid sequence of the antibodies in the genus). The Supreme Court concluded that the patents at issue failed to adequately enable the full scope of the genus of antibodies that performed the function of binding to specific amino acid residues on PCSK9 and blocking the binding of PCSK9 to a particular cholesterol receptor, LDLR. This decision reaffirmed the prior decision made by the Federal District Court in Amgen Inc. v. Sanofi, Aventisub LLC., 987 F.3d 1080 (Fed. Cir. 2021).
The Court clarified that the specification does not always need to "describe with particularity how to make and use every single embodiment within a claimed class." Id. at 610-11. However, "[i]f a patent claims an entire class of processes, machines, manufactures, or compositions of matter, the patent’s specification must enable a person skilled in the art to make and use the entire class….The more one claims, the more one must enable." Id.
The specification may require a reasonable amount of experimentation to make and use the invention and what is reasonable will depend on the nature of the invention and the underlying art. For example, "it may suffice to give an example (or a few examples) if the specification also discloses some general quality … running through the class that gives it a peculiar fitness for the particular purpose" and "disclosing that general quality may reliably enable a person skilled in the art to make and use all of what is claimed, not merely a subset." Id. at 611 (internal quotations omitted). However, the Supreme Court found that Amgen failed to enable all that it claimed, even if allowing for a reasonable degree of experimentation. Id. at 613; see also Baxalta Inc. v Genentech, Inc., 81 F.4th 1362, 1367, 2023 USPQ2d 1103 (Fed. Cir. 2023) ("[t]he facts of this case are more analogous to—and are, in fact, indistinguishable from—those in Amgen. We do not interpret Amgen to have disturbed our prior enablement case law, including Wands and its factors."). Moreover, "[w]e see no meaningful difference between Wands' ‘undue experimentation’ and Amgen's ‘[un]reasonable experimentation’ standards. Id. at footnote 4. See also Guidelines for Assessing Enablement in Utility Applications and Patents in View of the Supreme Court Decision in Amgen Inc. et al. v. Sanofi et al., 89 FR 1563 (January 10, 2024), which explains that regardless of the technology the Wands factors should be used when assessing enablement.
However, while the specification in Amgen identified 26 exemplary antibodies that performed the claimed function by their amino acid sequences, the claims at issue were directed to a class which included "a ‘vast’ number of additional antibodies" that Amgen had not described by their amino acid sequences. Id. at 613. The Court found that Amgen sought to monopolize an entire class by their function, even though that class was much broader than the 26 exemplary antibodies disclosed by their amino acid structure. Id. at 613.
In Amgen Inc. v. Sanofi, Aventisub LLC, 987 F.3d 1080 (Fed. Cir. 2021), which the Supreme Court affirmed, the Federal Circuit explicitly applied the Wands factors to assess whether the specification of Amgen’s patent provided sufficient enablement, for purposes of 35 U.S.C. 112(a), to make and use the full scope of the claimed invention. The court relied on evidence showing that the scope of the claims encompassed millions of antibodies and that it was necessary to screen each candidate antibody in order to determine whether it met the functional limitations of the claim. Id. at 1088. Consequently, the Federal Circuit concluded that there was a lack of enablement. See also the following cases across various technology areas: McRO, Inc. v. Bandai Namco Games Am. Inc., 959 F.3d 1091, 2020 USPQ2d 10550 (Fed. Cir. 2020); Wyeth & Cordis Corp. v. Abbott Laboratories, 720 F.3d 1380, 107 USPQ2d 1273 (Fed. Cir. 2013); Enzo Life Sciences, Inc. v. Roche Molecular Systems, Inc., 928 F.3d 1340 (Fed. Cir. 2019); and Idenix Pharmaceuticals LLC v. Gilead Sciences Inc., 941 F.3d 1149, 2019 USPQ2d 415844 (Fed. Cir. 2019).
Amgen attempted to claim an entire class of compounds by their function, namely antibodies that bind to the “sweet spot” of PCSK9 thereby inhibiting it from binding to LDL, while only describing 26 amino acid sequences in its specification. The two processes, the “roadmap” and “conservative substitution” did not save Amgen. According to the Court, these amounted to “little more than two research assignments” which forced scientists to conduct “painstaking experimentation” to see what worked. (citing Incandescent Lamp). The Court therefore held that Amgen’s specification did not enable the claims.
This case is akin to the issue in Amgen Inc. v. Sanofi, Aventisub LLC, in which the court relied on evidence showing that the scope of the claims encompassed millions of antibodies and that it was necessary to screen each candidate antibody in order to determine whether it met the functional limitations of the claim. Sanofi-Aventisub at 1088. Consequently, the Federal Circuit concluded that there was a lack of enablement. While the specification in Amgen identified 26 exemplary antibodies that performed the claimed function by their amino acid sequences, the claims at issue were directed to a class that included “a ‘vast' number of additional antibodies” that Amgen had not described by their amino acid sequences. Id. at 1256. The Supreme Court found that Amgen sought to monopolize an entire class of antibodies by their function, which was much broader than the 26 exemplary antibodies disclosed by their amino acid structure.
In the instant case, the claims are directed to a broad class of antibodies or a method of treatment/prevention of cancer comprising administration of a broad class of antibodies with either no recited structure (claims 28 and 31-36), or a genus of 108 different antibody CDR combinations (claims 11-16, 23-27, 29, and 30), all with the function of “anti-TSPAN3”.
The instant claims are directed to a class of antibodies that include “a ‘vast’ number” of additional structures in which the instant specification fails to describe. It would be necessary to first generate and then screen each candidate antibody to determine whether it met the functional limitations of “anti-TSPAN3”. The Federal Circuit concluded that there was a lack of enablement, which was affirmed by the Supreme Court in Amgen.
The instant specification does not disclose any common structural feature delineating which antibody variants would have the function of “anti-TSPAN3”. For example, regarding the CDR combinations recited in claim 11, the instant specification does not disclose if mixing the order of the CDR sequences in the M5 antibody clone would yield antibody variants that would still functionally bind to TSPAN3. The only structure-function relationship guidance the specification provides is to disclose individual monospecific antibodies with these functions.
The instant claims simply direct skilled artisans to engage in the same iterative, trial-and-error process the inventors followed to discover the antibody structures they elected to disclose and that “[u]nder Amgen, such random trial-and-error discovery, without more, constitutes unreasonable experimentation that falls outside the bounds required by § 112(a).” Id. at *8, *10.
Applicant is relying upon certain biological activities such as inhibitory antibody that targets TSPAN3 and a limited number of species of antibodies with defined structures (e.g. amino acid sequences) to support an entire genus of diverse and structurally unrelated inhibitory antibodies. Yet the instant specification does not provide sufficient guidance and directions as to the structural features of the inhibitory antibody and the correlation between the structure and the desired antigen binding and inhibitory function.
The Supreme Court’s 2023 decision in Amgen v. Sanofi, which mainly involves the enablement requirement, states that “where a patentee purports to invent an entire genus, it must enable the entire genus”; “disclosing how to produce some antibodies that perform a specified function is not equivalent to disclosing how to produce all such antibodies – and it is the latter that petitioners claim as their invention”; S. Ct.
Additionally, in its recent decision in Baxalta Inc. v. Genentech, Inc., No. 2022-1461, 2023 WL 6135930 (Fed. Cir. Sept. 20, 2023) the Federal Circuit found the facts of this case to be "materially indistinguishable from those in Amgen." Baxalta, 2023 WL 6135930, at *4. According to the Federal Circuit, claim 1 covers "millions of potential candidate antibodies" (id.) that bind to Factor IX/IXa and increase the procoagulant activity of Factor IXa. The court, however, noted that the specification discloses the amino acid sequence of just 11 of those antibodies. And like the roadmap in the patents at issue in Amgen, "the '590 patent's roadmap simply directs skilled artisans to engage in the same iterative, trial-and-error process the inventors followed to discover the [11] antibodies they elected to disclose." (Id.) Missing from the specification, according to the Federal Circuit, was "'a quality common to every functional embodiment' ... that would allow a skilled artisan to predict which antibodies will perform the claimed functions" (id.; quoting Amgen Inc. v. Sanofi., 598 U.S. 594, 614 (2023)), such as a common structural or other feature that would allow the antibodies to perform the claimed functions, or an explanation as to why the 11 antibodies do so and others do not. (Baxalta, 2023 WL 6135930, at *4). And the Federal Circuit was not persuaded by Baxalta's argument that its disclosed hybridoma-and screening process "predictably and reliably generates new claimed antibodies every time it is performed" (id.), because "it is undisputed that to practice the full scope of the claimed invention, skilled artisans must make candidate antibodies and screen them to determine which ones perform the claimed functions." (Id.).
Regarding the claimed methods of treating and/or preventing a cancer that expressed TSPAN 3 in a subject in need thereof comprising administration of a genus of antibodies with the function of “anti-TSPAN3” (claims 23-27 and 34-36):
The burden of enabling the prevention of a disease (i.e., the need for additional testing) would be greater than that of enabling a treatment due to the need to screen those mammals susceptible to such diseases and the difficulty of proof that the administration of the drug was the agent that acted to prevent the condition. Further, the specification does not provide guidance as to how one skilled in the art would go about screening those patients susceptible to diabetic retinopathy within the scope of the presently claimed invention. Nor is sufficient guidance provided as to a specific protocol to be utilized in order to prove the efficacy of the presently claimed genera of anti-TSPAN3 antibodies in preventing a cancer that expressed TSPAN3. For example, the specification discloses that experimental mice were first transplanted with primary patient AML cells, followed by administration of the anti-TSPAN3 antibody clones M5 or M6 (¶[0110], Example 1, and Fig. 6). The specification does not show an anti-TSPAN3 antibody being administered prior to AML transplantation. Therefore, the specification at most discloses a method of treating a cancer that expresses TSPAN3 comprising administration of the disclosed anti-TSPAN3 antibody clone structures, but not preventing cancer.
The specification does not reasonably provide enablement to use the invention of claims 11-16 and 23-36 as they are currently written. The specification does reasonably provide enablement to make and use the invention discussed supra.
Reasonable correlation must exist between the scope of the claims and scope of the enablement set forth. In view on the quantity of experimentation necessary the limited working examples, the nature of the invention, the state of the prior art, the unpredictability of the art and the breadth of the claims, it would take undue trials and errors to practice the claimed invention.
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.
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.
Claims 28 and 33-36 are rejected under 35 U.S.C. 103 as being unpatentable over Cacho et al. (Vaccine. 2013 Sep 23;31(41):4668-74. doi: 10.1016/j.vaccine.2013.06.109. Epub 2013 Jul 20) in view of Kwon et al. (Cell Stem Cell. 2015 Aug 6;17(2):152-164. doi: 10.1016/j.stem.2015.06.006. Epub 2015 Jul 23).
Cacho et al. teaches a rabbit polyclonal anti-TSPAN3 blocking antibody (Abstract): “…a tetraspanin-3 (Tspan-3) blocking antibody…”. Cacho et al. further teaches that this blocking antibody can successfully treat/protect against E. tenella infection (Table 1).
Cacho et al. does not teach anti-TSPAN3 antibodies that are capable of treating cancer in methods of treating TSPAN3 expressing cancer such as AML (i.e., the limitations of instant claims 28 and 34-36).
Kwon et al., in the same field of endeavor, teaches that TSPAN-3 is critical for AML progression (pg. 155): “[t]hese data indicate Tspan3 is crucial for MLL-driven leukemia, and that its inhibition can impair propagation of established AML…”.
Kwon et al. further teaches TSPAN-3 inhibition in AML patient samples blocked disease progression (Abstract). TSPAN-3 inhibition via shRNA knockdown impaired AML tumor cell growth in patient AML samples (pg. 155, last full ¶, Fig. 6). Kwon et al. teaches (pg. 159 and 161): “…inhibition of Tspan3 signaling may be an effective strategy for blocking leukemia growth. This is a particularly attractive possibility because the cell-surface expression of Tspan3 makes it well suited for antibody-mediated therapy…”
It would have been obvious to one with ordinary skill in the art, before the effective filing date of the instant application, to have tried to use the anti-TSPAN3 blocking antibody taught by Cacho et al. in a method of treating TSPAN3 expressing AML in a subject (i.e., the limitations of instant claims 28 and 34-36) with a reasonable expectation of success, as Cacho et al. teaches a TSPAN-3 antibody that blocks TSPAN3-mediated functions in subject such as E. tenella infection. One would be motivated to try this because Kwon et al. teaches that anti-TSPAN3 antibody immunotherapy is an attractive strategy to block AML tumor growth.
Regarding the function limitations recited in instant claim 28, one with ordinary skill in the art would expect an anti-TSPAN3 blocking antibody to also block TSPAN-3 mediated functions in other cells such as AML cells, and thus would expect the antibody taught by Cacho et al. to be “capable of inhibiting growth of cancer cells”, meeting the claim limitations.
Regarding claim 33, Cacho et al. teaches 100µL pharmaceutical compositions comprising the blocking antibody injected intramuscularly into subjects (Section 2.7), meeting the claim limitations.
Therefore, the invention as a whole was prima facie obvious to one of ordinary skill in the art at the time the invention was made, as evidenced by the references, especially in the absence of evidence to the contrary.
Claim 31 is rejected under 35 U.S.C. 103 as being unpatentable over Cacho et al. (supra) in view of Kwon et al. (supra) as applied to claims 28 and 33-36 above, and further in view of Mueller et al. (U.S. PGPub 20050074400).
The combined teachings of Cacho et al. and Kwon et al. have been discussed supra. The combined teachings do not teach a monoclonal antibody (the limitations of instant claim 31).
Mueller et al., in the same field of endeavor, teaches compounds comprising a binding moiety that specifically binds to TSPAN3 (¶[0165]), including monoclonal antibodies (¶[0170]). Mueller et al. further teaches that these antibodies can be used to treat cancer (¶[0063]).
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the instant application, to have modified the combined teachings of Cacho et al. and Kwon et al. further in view of Mueller et al. to use the monoclonal anti-TSPAN3 antibody taught by Mueller et al. in the method of treating cancer taught by Cacho et al. in view of Kwon et al. The antibodies taught by Cacho et al. and Mueller et al. are considered art-recognized equivalents of antibody structures with the function of “anti-TSPAN3” and “capable of inhibiting growth of cancer cells”. See Smith v. Hayashi, 209 USPQ 754 (Bd. of Pat. Inter. 1980) (The mere fact that phthalocyanine and selenium function as equivalent photoconductors in the claimed environment was not sufficient to establish that one would have been obvious over the other. However, there was evidence that both phthalocyanine and selenium were known photoconductors in the art of electrophotography. "This, in our view, presents strong evidence of obviousness in substituting one for the other in an electrophotographic environment as a photoconductor." 209 USPQ at 759.)
Therefore, the invention as a whole was prima facie obvious to one of ordinary skill in the art at the time the invention was made, as evidenced by the references, especially in the absence of evidence to the contrary.
Claim 32 is rejected under 35 U.S.C. 103 as being unpatentable over Cacho et al. (supra) in view of Kwon et al. (supra) as applied to claims 28 and 33-36 above, and further in view of Safdari et al. (Biotechnol Genet Eng Rev. 2013;29:175-86 doi: 10.1080/02648725.2013.801235).
The combined teachings of Cacho et al. and Kwon et al. have been discussed supra. The combined teachings do not teach a humanized antibody (the limitations of instant claim 32).
Safdari et al. in the same field of endeavor, teaches than the human immune response neutralizes administered non-human antibodies in patients, which limits the application of such antibodies in the treatment of human diseases (Introduction). Safdari et al. teaches that there are multiple known techniques to “humanize” antibodies to overcome this limitation, such as CDR grafting onto human frameworks and germline humanization (pages 175-177).
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the invention, to have modified the combined teachings of Cacho et al. and Kwon et al. further in view of Safdari et al. to humanize the anti-TSPAN3 blocking antibody to reduce the antibody’s immunogenicity in humans with a reasonable expectation of success, as Safdari et al. teaches multiple methods of antibody humanization. One would have been motivated to make this change for the purposes of reducing the immunogenicity of the anti-TSPAN3 blocking antibody taught by Cacho et al. when it is administered into humans.
Therefore, the invention as a whole was prima facie obvious to one of ordinary skill in the art at the time the invention was made, as evidenced by the references, especially in the absence of evidence to the contrary.
Conclusion
No claim is allowed.
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/ALEC JON PETERS/Examiner, Art Unit 1641
/MISOOK YU/Supervisory Patent Examiner, Art Unit 1641