Prosecution Insights
Last updated: April 19, 2026
Application No. 18/327,531

FLAVOR INHALER

Non-Final OA §102
Filed
Jun 01, 2023
Examiner
KUMAR, SRILAKSHMI K
Art Unit
1700
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Japan Tobacco Inc.
OA Round
2 (Non-Final)
55%
Grant Probability
Moderate
2-3
OA Rounds
4y 1m
To Grant
71%
With Interview

Examiner Intelligence

Grants 55% of resolved cases
55%
Career Allow Rate
305 granted / 551 resolved
-9.6% vs TC avg
Strong +15% interview lift
Without
With
+15.2%
Interview Lift
resolved cases with interview
Typical timeline
4y 1m
Avg Prosecution
415 currently pending
Career history
966
Total Applications
across all art units

Statute-Specific Performance

§101
1.7%
-38.3% vs TC avg
§103
47.7%
+7.7% vs TC avg
§102
21.1%
-18.9% vs TC avg
§112
21.0%
-19.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 551 resolved cases

Office Action

§102
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Examiner’s Note: The Office Action Summary included with the Non-Final Rejection mailed on 02/18/2026 incorrectly indicated that Applicant had a shortened statutory period of reply of two months (instead of three months). This additional Non-Final Rejection includes a correct Office Action Summary indicating that Applicant has a shortened statutory period of three months. The substance of the Non-Final Rejection mailed on 02/18/2026 is reproduced below for the reader’s convivence. Information Disclosure Statement The foreign references identified in the Information Disclosure Statements filed on 06/01/2023, 08/30/2024, 06/25/2025, 10/09/2025 were searched for corresponding US Patents, Publications, or other English equivalents. Please see below: WO 2020035454 = US 20210212366; WO 2020074604 = US 20210378307; WO 2019228037 = US 20210076741; WO 2020182743 = US 20220183372; JP 2018174784 = no US or other English equivalents located; CN 207653596 = no US or other English equivalents located; and JP 3065356 = no US or other English equivalents located. The above US references are being cited in the PTO-892 mailed on 02/18/2026 to ensure they are made of record. Claim Rejections - 35 USC § 102 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) 1–6, 13–15, and 20 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by THORSEN US 2020268053 (“THORSEN”). As to claim 1, THORSEN discloses the flavor inhaler comprising: PNG media_image1.png 615 538 media_image1.png Greyscale a housing (Fig. 1, 108; [0086]); PNG media_image2.png 282 560 media_image2.png Greyscale a containing unit (Fig. 13, 142; [0135]) contained in the housing and configured to contain a consumable (104; [0144]); a tubular unit (110; [0135]) surrounding the containing unit (142); and a holding unit (deformable attachments 152) holding the tubular unit movably in an axial direction of the tubular unit or a first direction perpendicular to the axial direction ([0135]). As to claim 2, THORSEN discloses the flavor inhaler according to claim 1, wherein the holding unit includes a first restriction unit (Fig. 13) configured to restrict a movement of the tubular unit in the first direction ([0135]). As to claim 3, THORSEN discloses the flavor inhaler according to claim 2, wherein the first restriction unit is configured to restrict a movement of the tubular unit in a second direction perpendicular to the axial direction of the tubular unit and the first direction (the first restriction units hold the tubular unit in place and restrict/limit movement of the tubular unit along x-axis, y-axis, and z-axis). As to claim 4, THORSEN discloses the flavor inhaler according to claim 2, wherein the first restriction unit includes an inner first restriction unit located inside the tubular unit (Fig. 10, 152 is within 110). As to claim 5, THORSEN discloses the flavor inhaler according to claim 4, wherein the flavor inhaler satisfies D1 > D2, assuming that D1 represents an inner diameter of the tubular unit and D2 represents a diameter of an imaginary circle circumscribed around the inner first restriction unit as viewed from the axial direction of the tubular unit (Fig. 13 evidences that, when viewed in the axial direction of the tubular unit 110, the inner diameter of the tubular unit 110 is greater than a diameter of an imaginary circle circumscribed around the inner first restriction unit 152). As to claim 6, THORSEN discloses the flavor inhaler according to claim 5, wherein the inner first restriction unit includes at least two protrusion portions protruding in the first direction (see 152s in Fig. 13), and wherein the imaginary circle is circumscribed around the at least two protrusion portions (Fig. 13). As to claim 13, THORSEN discloses the flavor inhaler according to claim 2, wherein the tubular unit includes a first end portion (left side of 110 in Fig. 13), and a second end portion (right side of 110) opposite from the first end portion (Fig. 13) and, wherein the first restriction unit is disposed inside or outside at least one of the first end portion or the second end portion of the tubular unit in the first direction (Fig. 13). As to claim 14, THORSEN discloses the flavor inhaler according to claim 13, wherein the first restriction unit is disposed inside or outside both the first end portion and the second end portion of the tubular unit in the first direction (Fig. 13). As to claim 15, THORSEN discloses the flavor inhaler according to claim 1, wherein the tubular unit includes a base portion (110) and a heat insulation layer (124/112) provided on an outer peripheral side of the base portion ([0086–87]). As to claim 20, THORSEN discloses the flavor inhaler according to claim 1, wherein the holding unit includes a second restriction unit (Fig. 13, the other 152)configured to restrict a movement of the tubular unit in the axial direction, and is configured to hold the tubular unit movably in the axial direction (Fig. 13). Claim(s) 1–6, 10–14, and 20 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by CHEN US 20210076741 (“CHEN”). As to claim 1, CHEN discloses the flavor inhaler comprising: PNG media_image3.png 652 282 media_image3.png Greyscale PNG media_image4.png 692 435 media_image4.png Greyscale a housing (Fig. 2, 110); PNG media_image5.png 333 517 media_image5.png Greyscale a containing unit (Fig. 12, 113) contained in the housing and configured to contain a consumable (200; [0068]); a tubular unit (140) surrounding the containing unit (Fig. 12); and PNG media_image6.png 690 390 media_image6.png Greyscale a holding unit (130) holding the tubular unit (140) movably in an axial direction of the tubular unit or a first direction perpendicular to the axial direction ([0072]). As to claim 2, CHEN discloses the flavor inhaler according to claim 1, wherein the holding unit includes a first restriction unit (130/133/134) configured to restrict a movement of the tubular unit in the first direction (Figs. 7–8). As to claim 3, CHEN discloses the flavor inhaler according to claim 2, wherein the first restriction unit (130/133/134) is configured to restrict a movement of the tubular unit in a second direction perpendicular to the axial direction of the tubular unit and the first direction (Figs. 7–8). As to claim 4, CHEN discloses the flavor inhaler according to claim 2, wherein the first restriction unit includes an inner first restriction unit (Fig. 8, 133) located inside the tubular unit (Fig. 8, 140). As to claim 5, CHEN discloses the flavor inhaler according to claim 4, wherein the flavor inhaler satisfies D1 > D2, assuming that D1 represents an inner diameter of the tubular unit and D2 represents a diameter of an imaginary circle circumscribed around the inner first restriction unit as viewed from the axial direction of the tubular unit (Figs. 7–8). As to claim 6, CHEN discloses the flavor inhaler according to claim 5, wherein the inner first restriction unit includes at least two protrusion portions protruding in the first direction (Fig. 8 illustrates threaded loops, which can be interpreted as at least two protrusion portions protruding in the first direction), and wherein the imaginary circle is circumscribed around the at least two protrusion portions (Fig. 8). As to claim 10, CHEN discloses the flavor inhaler according to claim 2, wherein the first restriction unit (130) includes an outer first restriction unit (130/134) located outside the tubular unit (Fig. 8). As to claim 11, CHEN discloses the flavor inhaler according to claim 10, wherein the first restriction unit includes an inner first restriction unit (133) located inside the tubular unit (Fig. 8, 140), and wherein the inner first restriction unit (133) and the outer first restriction unit (134) are disposed at positions overlapping each other in the axial direction (Fig. 8). As to claim 12, CHEN discloses the flavor inhaler according to claim 11, wherein a space in the first direction is formed between the inner first restriction unit and the outer first restriction unit, and wherein the tubular unit is contained in the space (Fig. 8). As to claim 13, CHEN discloses the flavor inhaler according to claim 2, wherein the tubular unit includes a first end portion (Fig. 8), and a second end portion opposite from the first end portion and (Fig. 8), wherein the first restriction unit is disposed inside or outside at least one of the first end portion or the second end portion of the tubular unit in the first direction (Fig. 8). As to claim 14, CHEN discloses the flavor inhaler according to claim 13, wherein the first restriction unit is disposed inside or outside both the first end portion and the second end portion of the tubular unit in the first direction (Fig. 8). As to claim 20, CHEN discloses the flavor inhaler according to claim 1, wherein the holding unit includes a second restriction unit (133) configured to restrict a movement of the tubular unit in the axial direction, and is configured to hold the tubular unit movably in the axial direction (Fig. 8). Claim(s) 1–15 and 20 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by ABI AOUN US 20220183372 (“ABI AOUN”). As to claim 1, ABI AOUN discloses the flavor inhaler comprising: PNG media_image7.png 506 281 media_image7.png Greyscale a housing (Fig. 1, 102); PNG media_image8.png 531 347 media_image8.png Greyscale PNG media_image9.png 651 385 media_image9.png Greyscale a containing unit (132; [0119]) contained in the housing and configured to contain a consumable (Figs 5A-5B, 110; [0133]); PNG media_image10.png 593 497 media_image10.png Greyscale a tubular unit (128) surrounding the containing unit (132); and PNG media_image9.png 651 385 media_image9.png Greyscale PNG media_image11.png 668 443 media_image11.png Greyscale a holding unit (Figs. 6 and 12–13, illustrate a holding unit at either end of 128) holding the tubular unit (128 illustrated in Fig. 13) movably in an axial direction of the tubular unit or a first direction perpendicular to the axial direction (The broadest reasonable interpretation of “a holding unit holding the tubular unit movably in an axial direction of the tubular unit or a first direction perpendicular to the axial direction” captures at least one of elements 144, 520, 522, 506, 226, 224, 202, 136, 212, 214, 216 because these elements work together to hold tubular element 128 and containing unit 132 in a set position between each. The overall structures are “movable” in that o-rings 214/520, as discussed in [0178], “may be compressed when the insulating member 128 surrounds the susceptor 132.”). As to claim 2, ABI AOUN discloses the flavor inhaler according to claim 1, wherein the holding unit includes a first restriction unit configured to restrict a movement of the tubular unit in the first direction (Figs. 6 and 12–13, elements 144, 520, 522, 506, 226, 224, 202, 136, 212, 214, 216; [0178–0180]). As to claim 3, ABI AOUN discloses the flavor inhaler according to claim 2, wherein the first restriction unit is configured to restrict a movement of the tubular unit in a second direction perpendicular to the axial direction of the tubular unit and the first direction (Figs. 6 and 12–13, elements 144, 520, 522, 506, 226, 224, 202, 136, 212, 214, 216; [0178–0180]). As to claim 4, ABI AOUN discloses the flavor inhaler according to claim 2, wherein the first restriction unit includes an inner first restriction unit located inside the tubular unit (Figs. 6 and 12–13, 214 or 512; [0178–0180]). As to claim 5, ABI AOUN discloses the flavor inhaler according to claim 4, wherein the flavor inhaler satisfies D1 > D2, assuming that D1 represents an inner diameter of the tubular unit and D2 represents a diameter of an imaginary circle circumscribed around the inner first restriction unit as viewed from the axial direction of the tubular unit (Figs. 6 and 12–13, 214 or 512; [0178–0180]). As to claim 6, ABI AOUN discloses the flavor inhaler according to claim 5, wherein the inner first restriction unit includes at least two protrusion portions (226) protruding in the first direction (Figs. 12–13), and wherein the imaginary circle is circumscribed around the at least two protrusion portions (Figs. 12–13). As to claim 7, ABI AOUN discloses the flavor inhaler according to claim 6, wherein the protrusion portions (226) include top portions shaped so as to conform with an inner surface of the tubular unit as viewed from the axial direction (226 are shaped to conform with an inner surface of the tubular unit 128 because they do not interfere with the inner surface of the tublare element. They also appear curved and have an outer surface shape which is substantially similar to the inner surface of the tubular unit. Accordingly, the protrusion portions 226 include top portions shaped so as to conform with an inner surface of the tubular unit as viewed from the axial direction), respectively, wherein the imaginary circle is circumscribed around the top portions, and wherein the flavor inhaler satisfies L1 > L2, assuming that L1 represents a circumferential length of the imaginary circle and L2 represents a sum of lengths of portions of the top portions that are circumscribed by the imaginary circle (Fig. 13). As to claim 8, ABI AOUN discloses the flavor inhaler according to claim 4, wherein the inner first restriction unit includes an annular portion (144, 520, 522, 506, 226, 224, 202, 136, 212, 214, 216) located between the containing unit (132) and the tubular unit (128). As to claim 9, ABI AOUN discloses the flavor inhaler according to claim 8, wherein the annular portion has an outer peripheral surface that faces an inner surface of the tubular unit (Figs. 6 and 12–13), and wherein the outer peripheral surface has such a tapering surface that an outer diameter is reducing as the outer peripheral surface extends toward a center of the tubular unit in the axial direction (at least the curved shape of the o-rings 520/214. Also, elements Figs. 12 and 13 illustrate elements 224, 226, 212 and 216 also have a tapering surface that an outer diameter is reducing as the outer peripheral surface extends toward a center of the tubular unit in the axial direction.) As to claim 10, ABI AOUN discloses the flavor inhaler according to claim 2, wherein the first restriction unit includes an outer first restriction unit (Fig. 13, 512 and 220) located outside the tubular unit (128). As to claim 11, ABI AOUN discloses the flavor inhaler according to claim 10, wherein the first restriction unit includes an inner first restriction unit (144, 520, 522, 506, 226, 224, 202, 136, 212, 214, 216) located inside the tubular unit (Fig. 13, 128), and wherein the inner first restriction unit and the outer first restriction unit (512/220) are disposed at positions overlapping each other in the axial direction (Fig. 13). As to claim 12, ABI AOUN discloses the flavor inhaler according to claim 11, wherein a space in the first direction is formed between the inner first restriction unit and the outer first restriction unit, and wherein the tubular unit is contained in the space (Fig. 12). As to claim 13, ABI AOUN discloses the flavor inhaler according to claim 2, wherein the tubular unit includes a first end portion (top of 128 in Fig. 13), and a second end portion (bottom of 128 in Fig. 13) opposite from the first end portion and, wherein the first restriction unit is disposed inside or outside at least one of the first end portion or the second end portion of the tubular unit in the first direction (Fig. 13). As to claim 14, ABI AOUN discloses the flavor inhaler according to claim 13, wherein the first restriction unit is disposed inside or outside both the first end portion and the second end portion of the tubular unit in the first direction (Fig. 13). As to claim 15, ABI AOUN discloses the flavor inhaler according to claim 1, wherein the tubular unit includes a base portion (Fig. 3, 128) and a heat insulation layer (124/126; [0119]. These structures, although described as inductor coils, will inherently limit the transfer of heat and accordingly meet the broadest reasonable interpretation of a heat insulation layer) provided on an outer peripheral side of the base portion (Fig. 3). As to claim 20, ABI AOUN discloses the flavor inhaler according to claim 1, wherein the holding unit includes a second restriction unit configured to restrict a movement of the tubular unit in the axial direction, and is configured to hold the tubular unit movably in the axial direction (Figs. 6 and 12–13, elements 144, 520, 522, 506, 226, 224, 202, 136, 212, 214, 216; [0178–0180]). Claim(s) 1–3, 10, and 13–20 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by REEVELL US 20210378307 (“REEVELL”). As to claim 1, REEVELL discloses the flavor inhaler comprising: PNG media_image12.png 532 237 media_image12.png Greyscale a housing (102; [0054]); PNG media_image13.png 583 296 media_image13.png Greyscale PNG media_image14.png 692 241 media_image14.png Greyscale a containing unit (108) contained in the housing and configured to contain a consumable (114; [0057]); PNG media_image15.png 636 584 media_image15.png Greyscale a tubular unit (152) surrounding the containing unit (180; [0058]; See partial reproduction from Fig. 2 above); and a holding unit (160; [0059]) holding the tubular unit (152) movably in an axial direction of the tubular unit or a first direction perpendicular to the axial direction (Fig. 2, [0059]). As to claim 2, REEVELL discloses the flavor inhaler according to claim 1, wherein the holding unit includes a first restriction unit configured to restrict a movement of the tubular unit in the first direction (Fig. 2). As to claim 3, REEVELL discloses the flavor inhaler according to claim 2, wherein the first restriction unit is configured to restrict a movement of the tubular unit in a second direction perpendicular to the axial direction of the tubular unit and the first direction (the interference fit provided by deformable member 160 restricts a movement of the tubular unit 152 in a second direction perpendicular to the axial direction of the tubular unit and the first direction). As to claim 10, REEVELL discloses the flavor inhaler according to claim 2, wherein the first restriction unit includes an outer first restriction unit located outside the tubular unit (Fig. 2, 106). As to claim 13, REEVELL discloses the flavor inhaler according to claim 2, wherein the tubular unit includes a first end portion, and a second end portion opposite from the first end portion and, wherein the first restriction unit is disposed inside or outside at least one of the first end portion or the second end portion of the tubular unit in the first direction (Fig. 2). As to claim 14, REEVELL discloses the flavor inhaler according to claim 13, wherein the first restriction unit (160) is disposed outside both the first end portion and the second end portion of the tubular unit (152) in the first direction (Fig. 2). As to claim 15, REEVELL discloses the flavor inhaler according to claim 1, wherein the tubular unit includes a base portion (inner wall of 152) and a heat insulation layer provided on an outer peripheral side of the base portion ([0058] discloses filling 152 with a thermally insulating material, for example fibres, foams, gels). As to claim 16, REEVELL discloses the flavor inhaler according to claim 15, wherein the holding unit includes a first restriction unit configured to restrict a movement of the tubular unit in the first direction (see discussion above), wherein the first restriction unit includes an inner first restriction unit located inside the tubular unit (156), wherein the first restriction unit includes an outer first restriction unit located outside the tubular unit (160/107b), wherein the inner first restriction unit and the outer first restriction unit are disposed at positions overlapping each other in the axial direction (Fig. 2), wherein a space in the first direction is formed between the inner first restriction unit and the outer first restriction unit, wherein the tubular unit is contained in the space (Fig. 2), wherein the base portion (inner wall of 152) includes a protrusion portion on one end of the tubular unit (148), the protrusion portion protruding from the heat insulation layer in the axial direction (Fig. 2), and wherein the protrusion portion is contained in the space (Fig. 2). As to claim 17, REEVELL discloses the flavor inhaler according to claim 15, wherein the holding unit includes a first restriction unit (one of 160) configured to restrict a movement of the tubular unit in the first direction (Fig. 2), wherein the first restriction unit includes an outer first restriction unit (the other of 160) located outside the tubular unit (152), and wherein the outer first restriction unit is out of contact with the heat insulation layer (because outer wall 154 separates the a thermally insulating material from the outer first restriction unit; see [0058]). As to claim 18, REEVELL discloses the flavor inhaler according to 1, wherein the containing unit includes a tubular sidewall portion (108; [0061–64]), wherein the sidewall portion includes a contact portion (Fig. 2(a), 140) in contact with the consumable when the consumable is contained in the containing unit ([0063]), and a separation portion (126) located circumferentially adjacent to the contact portion and spaced apart from the consumable ([0087]), and wherein an air flow path in communication with an end surface of the consumable in the containing unit and an opening of the containing unit is formed between the separation portion and the consumable when the consumable is contained in the containing unit ([0085]). As to claim 19, REEVELL discloses the flavor inhaler according to claim 1, further comprising a heating unit (Fig. 2, 124) disposed on an outer periphery of the containing unit (108) and configured to heat the consumable contained in the containing unit ([0096–97]). As to claim 20, REEVELL discloses the flavor inhaler according to claim 1, wherein the holding unit includes a second restriction unit (top or bottom 160) configured to restrict a movement of the tubular unit in the axial direction, and is configured to hold the tubular unit movably in the axial direction (Fig. 2). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to MANLEY L CUMMINS IV whose telephone number is (571)272-1060. The examiner can normally be reached Monday-Friday 9:30 a.m. - 6:00 p.m. (CST). 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, Michael H. Wilson can be reached at (571) 270-3882. 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. /MANLEY L CUMMINS IV/Primary Examiner, Art Unit 1747
Read full office action

Prosecution Timeline

Jun 01, 2023
Application Filed
Feb 04, 2026
Non-Final Rejection — §102
Feb 18, 2026
Non-Final Rejection — §102 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12420336
ANTI-FRETTING COATING COMPOSITION AND COATED COMPONENTS
2y 5m to grant Granted Sep 23, 2025
Patent 12417853
ENGINEERED SIC-SIC COMPOSITE AND MONOLITHIC SIC LAYERED STRUCTURES
2y 5m to grant Granted Sep 16, 2025
Patent 12418039
MEMBRANE ELECTRODE ASSEMBLY MANUFACTURING PROCESS
2y 5m to grant Granted Sep 16, 2025
Patent 12410882
VACUUM ADIABATIC BODY
2y 5m to grant Granted Sep 09, 2025
Patent 12397261
METHOD FOR ELECTROCHEMICAL HYDROGEN SEPARATION FROM NATURAL-GAS PIPELINES
2y 5m to grant Granted Aug 26, 2025
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

2-3
Expected OA Rounds
55%
Grant Probability
71%
With Interview (+15.2%)
4y 1m
Median Time to Grant
Moderate
PTA Risk
Based on 551 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