Prosecution Insights
Last updated: April 19, 2026
Application No. 18/253,436

AEROSOL-GENERATING ARTICLE SYSTEM WITH OLFACTORY MALODOR INHIBITION

Final Rejection §103
Filed
May 18, 2023
Examiner
GRAY, LINDA LAMEY
Art Unit
1745
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Philip Morris Products, S.A.
OA Round
2 (Final)
83%
Grant Probability
Favorable
3-4
OA Rounds
2y 9m
To Grant
99%
With Interview

Examiner Intelligence

Grants 83% — above average
83%
Career Allow Rate
651 granted / 787 resolved
+17.7% vs TC avg
Strong +17% interview lift
Without
With
+16.9%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
23 currently pending
Career history
810
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
37.3%
-2.7% vs TC avg
§102
22.9%
-17.1% vs TC avg
§112
33.9%
-6.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 787 resolved cases

Office Action

§103
DETAILED ACTION Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 15, 21-23, and 27-29 are rejected under 35 U.S.C. 103 as being unpatentable over Herron (EP 0 294 972 A2) in view of “List of Additives to Cigarettes”. Claim 15: Herron teaches an aerosol-generating article, comprising: an aerosol-forming substrate (tobacco: c1 para1-5); an odor inhibition substrate (flavorant: c1 para6; c3 para2) comprising at least 10 different odor components (aromatic agent: c3 para2-7; [Column 3, paragraph 7, lists 13 different odor components, recites that the aromatic agent comprises any number of these components, and suggests having more than the number listed]); and a wrapper circumscribing at least a portion of the aerosol-forming substrate (c1 para6), wherein the odor inhibition substrate is provided on the wrapper (c3 para10). Other locations within reference may be included in the above recited locations (paragraphs, drawing, abstract, claims) to demonstrate further the features in the reference as claimed in the instant claims. Herron teaches, for example, that the odor components are coumarin, menthol, and methyl salicylate (c3 para7). Claim 15: Herron teaches 3 odor components from the claimed list but lacks a recitation of 7 more at least. However, “List of Additives to Cigarettes” (i.e. LAC) teaches a list of additives added to cigarettes. For example: hexanoic acid, octanal, acetoin, acetic acid, vanillin, isoamyl acetate, and acetophenone are recited. It would have been obvious to a person of ordinary skill in the art, before the effective filing date of the invention, to have provided in Herron the additives of hexanoic acid, octanal, acetoin, acetic acid, vanillin, isoamyl acetate, and acetophenone in that LAC teaches, in the same art as Herron, that these additives are conventional and well-known such that one would use these additives for the inherent properties provided therein. Claim 21: the odor inhibition substrate is provided as a band, which circumscribes a portion of the wrapper, in that such is impregnated into the wrapper forming a band (see previously recited locations of reference). Claims 22-23: the odor inhibition substrate further comprises a solid support material impregnated with odor components in that the wrapper comprises paper wherein components making up the paper, all over the paper, will necessarily support the odor inhibition substrate wherein the wrapper is a strip/band (see previously recited locations of reference). Claim 27: the odor inhibition substrate further comprises a portion of the wrapper with odor components adsorbed or absorbed thereon (see previously recited locations of reference). Claim 28: the aerosol-generating article comprises the aerosol-forming substrate where any portion of the tobacco substrate is considered to necessarily be a downstream segment relative the an opposite end area of the tobacco substrate having the odor inhibition substrate thereover by way of the wrapper. Claim 29: Herron teaches an aerosol-generating system, comprising, an aerosol-generating device (full cigarette) comprising a heater (when lit); and an aerosol-generating article according to claim 15. Claims 19-20 and 24-26 are rejected under 35 U.S.C. 103 as being unpatentable over Herron (EP 0 294 972 A2) in view of “List of Additives to Cigarettes”. Claims 19 and 20: with respect the having at least 20 (at least 30) different odor components, Herron does not specifically recite this limitation. However, the number of odor components to which one skilled in the art would consider is a function of, among other variables, the degree of masking desired, available materials on the market at proper expense, odor component interactions, and temperature and/or operational pressure. Accordingly, it would have been obvious to a person having ordinary skill in the art, before the effective filing date of the invention, to have optimized the number of odor components to which one skilled in the art would consider based on known variables, as those listed; and thus, the claimed value ranges cannot be considered critical. “[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum and workable ranges by routine experimentation,” In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 195). “It is a well settled principle of law that a mere carrying forward of an original patented conception involving only change of form, proportions, or degree, or the substitution of equivalents doing the same this as the original invention, by substantially the same means, is not such an invention as will sustain a patent, even though the changes of the kind may produce better results that prior inventions.” In re Williams, 36 F.2d 436, 438 (CCPA 1929). See MPEP 2144.05 II.A. Claims 24-25 and 26: with respect to the claimed value ranges for the distance between the support and either end of the article (claims 24-25) and for the support width (claim 26), these value to which one skilled in the art would consider is a function of, among other variables, aesthetic appeal of the wrapper, overall size of the item smoked, and desired amount of space available for the impregnation. Accordingly, it would have been obvious to a person having ordinary skill in the art, before the effective filing date of the invention, to have optimized these values based on known variables, as those listed; and thus, the claimed value ranges cannot be considered critical. “[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum and workable ranges by routine experimentation,” In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 195). “It is a well settled principle of law that a mere carrying forward of an original patented conception involving only change of form, proportions, or degree, or the substitution of equivalents doing the same this as the original invention, by substantially the same means, is not such an invention as will sustain a patent, even though the changes of the kind may produce better results that prior inventions.” In re Williams, 36 F.2d 436, 438 (CCPA 1929). See MPEP 2144.05 II.A. Conclusion The amendments and comments filed 11-12-25 have been entered and fully considered – the results of which are provided herein. 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 LINDA GRAY whose telephone number is (571) 272-5778. The examiner can normally be reached Monday - Friday, 9 AM to 5:30 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, Phil Tucker can be reached at (571) 272-1095. 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. /LINDA L GRAY/Primary Examiner, Art Unit 1745
Read full office action

Prosecution Timeline

May 18, 2023
Application Filed
Aug 09, 2025
Non-Final Rejection — §103
Nov 12, 2025
Response Filed
Jan 25, 2026
Final Rejection — §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
83%
Grant Probability
99%
With Interview (+16.9%)
2y 9m
Median Time to Grant
Moderate
PTA Risk
Based on 787 resolved cases by this examiner. Grant probability derived from career allow rate.

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