Prosecution Insights
Last updated: April 19, 2026
Application No. 18/358,859

DEFORMABLE SPINAL CORD STIMULATION DEVICE AND RELATED SYSTEMS AND METHODS

Non-Final OA §102§103§DP
Filed
Jul 25, 2023
Examiner
MARLEN, TAMMIE K
Art Unit
3796
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Neuroone Medical Technologies Corporation
OA Round
1 (Non-Final)
75%
Grant Probability
Favorable
1-2
OA Rounds
3y 11m
To Grant
96%
With Interview

Examiner Intelligence

Grants 75% — above average
75%
Career Allow Rate
601 granted / 801 resolved
+5.0% vs TC avg
Strong +21% interview lift
Without
With
+21.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 11m
Avg Prosecution
52 currently pending
Career history
853
Total Applications
across all art units

Statute-Specific Performance

§101
5.3%
-34.7% vs TC avg
§103
26.9%
-13.1% vs TC avg
§102
33.7%
-6.3% vs TC avg
§112
28.0%
-12.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 801 resolved cases

Office Action

§102 §103 §DP
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 . Election/Restrictions Applicant's election with traverse of Invention I, claims 1-17, in the reply filed on December 29, 2025 is acknowledged. The traversal is on the ground(s) that no search and/or examination burden exists and the method of claims 18-20 cannot be practiced by another and materially different apparatus than that described in claims 1-17. This is not found persuasive because as set forth in the restriction requirement, inventions I and II are classified in different areas and would require distinct searches in order to find each individual invention. Furthermore, as set forth in the restriction requirement, the process as claimed can be practiced by another and materially different apparatus, such as one including a pusher device. The requirement is still deemed proper and is therefore made FINAL. Claims 18-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected invention, there being no allowable generic or linking claim. Applicant timely traversed the restriction (election) requirement in the reply filed on December 29, 2025. Information Disclosure Statement The information disclosure statement(s) (IDS) submitted on 9/18/2023, 12/11/2023, 4/15/2024, 12/26/2024, 5/19/2025, and 1/29/2026 has/have been acknowledged and is/are being considered by the Examiner. Drawings The Applicant is reminded to carefully review the drawing figures and the accompanying specification to ensure that all reference numerals present in the drawing figures are defined within the specification. Claim Rejections - 35 USC § 102 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. Claims 1-6 and 8-16 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Feler (U.S. 2013/0238077). Regarding claim 1, Feler discloses a spinal cord stimulation device (Abstract) comprising:(a) an elongate thin film lead body 244 (see Figure 4); and(b) a thin film electrode body 230 disposed at one end of the elongate thin film lead body (see Figure 4), the thin film electrode body comprising:(i) at least one deformation section 410 disposed longitudinally through the electrode body such that the at least one deformation section is parallel with a longitudinal axis of the lead body (“ the front surface or face 231 of paddle structure 230 includes lengthwise or longitudinal score lines 410 that extend between ends 250 and 252 from edge to edge”, paragraph [0031]); and(ii) at least two contacts 222 disposed on the electrode body (see Figure 4). Regarding claim 2, Feler discloses that the at least two contacts comprises at least twelve contacts (see Figure 4, which shows 25 contacts). Regarding claim 3, Feler discloses that the at least one deformation section comprises at least two deformation sections (see Figure 4, which shows 4 longitudinal score lines). Regarding claim 4, Feler discloses that the at least one deformation section comprises three deformation sections (see Figure 4, which shows 4 longitudinal score lines). Regarding claim 5, Feler discloses that the thin film electrode body comprises a distal flap disposed at a distal end of the thin film electrode body (the broadest reasonable interpretation for a “flap” is a broad or flat structure, usually thin and flexible that hangs loose or projects freely, which is satisfied by the distalmost portion of the thin film electrode body shown in Figure 4 and reproduced below). PNG media_image1.png 272 532 media_image1.png Greyscale Regarding claim 6, Feler discloses at least one distal deformation section comprising a first end disposed at a distal end of the at least one deformation section and a second end disposed at a side of the electrode body (see annotated Figure 4 below, where it is respectfully submitted that the claimed “deformation section” is merely a section that can deform and, thus, the section of the score line 410 illustrated in bold below and showing the distal end). PNG media_image2.png 412 533 media_image2.png Greyscale Regarding claim 8, Feler discloses that the flap is moveable between a flat configuration and a pocket configuration (it is respectfully submitted that the flap is capable of being moved and manipulated into a pocket configuration based on the score lines and flexibility). Regarding claim 9, Feler discloses that the flap is moveable between a flat configuration and a collar configuration (it is respectfully submitted that the flap is capable of being moved and manipulated into a collar configuration based on the score lines and flexibility). Regarding claim 10, Feler discloses a spinal cord stimulation device (Abstract) comprising:(a) an elongate thin film lead body 244 (see Figure 4); and (b) a thin film electrode body 230 disposed at one end of the elongate thin film lead body (see Figure 4), the thin film electrode body comprising:(i) at least two deformation sections 410 disposed longitudinally through the electrode body (see Figure 4);(ii) at least one first contact 222 disposed between a first outer edge of the electrode body and a first of the at least two deformation sections (see Figure 4); (iii) at least one second contact 222 disposed between the first and a second of the at least two deformation sections (see Figure 4); and (iv) at least one third contact disposed between the second of the at least two deformation sections and a second outer edge of the electrode body, wherein the first and second outer edges are moveable in relation to each other via the at least two deformation sections such that the electrode body is laterally conformable to a shape of a target spinal cord (“the front surface or face 231 of paddle structure 230 includes lengthwise or longitudinal score lines 410 that extend between ends 250 and 252 from edge to edge”, paragraph [0031] and “The score lines increase the flexibility of the paddle in both the length and width directions which facilitate the implantation of the paddle within the epidural space of the spinal cord, and further permits the paddle to conform more uniformly to the target area of implantation to minimize the gap between the electrodes and targeted fibers.”, Abstract). PNG media_image3.png 412 533 media_image3.png Greyscale Regarding claim 11, Feler discloses at least one pair of notches defined in the first and second sides of the electrode body, whereby the electrode body has increased lateral and longitudinal flexibility (score lines 410 and 412 shown in Figure 4 are notches defined in the first and second sides of the electrode body and give increased lateral and longitudinal flexibility). Regarding claim 12, Feler discloses that the first and second outer edges are rotatable around a longitudinal axis of the electrode body (“The score lines of paddle portion facilitate the bending or shaping of paddle portion 230 to match the posterior shape of the epidural space.”, paragraph [0042], which is respectfully submitted to be a disclosure that the first and second outer edges are capable of rotation around a longitudinal axis of the electrode body). Regarding claim 13, Feler discloses that the thin film electrode body comprises a distal flap disposed at a distal end of the thin film electrode body (the broadest reasonable interpretation for a “flap” is a broad or flat structure, usually thin and flexible that hangs loose or projects freely, which is satisfied by the distalmost portion of the thin film electrode body shown in annotated Figure 4 above). Regarding claim 14, Feler discloses that the flap is moveable between a flat configuration and a pocket configuration or a collar configuration (it is respectfully submitted that the flap is capable of being moved and manipulated into a pocket or collar configuration based on the score lines and flexibility). Regarding claim 15, Feler discloses a spinal cord stimulation device (Abstract) comprising:(a) an elongate thin film lead body 244 (see Figure 4); (b) a thin film electrode body 230 disposed at one end of the elongate thin film lead body (see Figure 4), the thin film electrode body comprising:(i) at least three deformation sections 410 disposed longitudinally through the electrode body such that each of the at least three deformation sections is parallel with a longitudinal axis of the lead body (see annotated Figure 4 below); (ii) at least two contacts 222 disposed on the electrode body; and (iii) first and second outer edges moveable in relation to each other via the at least three deformation sections such that the electrode body is laterally conformable to a shape of a target spinal cord (“the front surface or face 231 of paddle structure 230 includes lengthwise or longitudinal score lines 410 that extend between ends 250 and 252 from edge to edge”, paragraph [0031] and “The score lines increase the flexibility of the paddle in both the length and width directions which facilitate the implantation of the paddle within the epidural space of the spinal cord, and further permits the paddle to conform more uniformly to the target area of implantation to minimize the gap between the electrodes and targeted fibers.”, Abstract); and(c) a distal flap disposed at a distal end of the thin film electrode body (the broadest reasonable interpretation for a “flap” is a broad or flat structure, usually thin and flexible that hangs loose or projects freely, which is satisfied by the distalmost portion of the thin film electrode body shown in annotated Figure 4 below), wherein the flap is movable between a flat configuration and a pocket configuration or a collar configuration body (it is respectfully submitted that the flap is capable of being moved and manipulated into a pocket or collar configuration based on the score lines and flexibility). PNG media_image4.png 412 533 media_image4.png Greyscale Regarding claim 16, Feler discloses at least one distal deformation section comprising a first end disposed at a distal end of one of the at least three deformation sections and a second end disposed at one of the first and second outer edges (see annotated Figure 4 below). PNG media_image5.png 412 533 media_image5.png Greyscale 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 7 and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Feler (U.S. 2013/0238077, cited above). Feler discloses the invention substantially as claimed, but fails to disclose that the second end of the at least one distal deformation section is disposed between the distal flap and the distal end of the thin film electrode body. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to dispose the second end of the at least one distal deformation section between the distal flap and the distal end of the thin film electrode body, since it has been held that rearranging parts of an invention involves only routine skill in the art. MPEP 2144.04 Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg, 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman, 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi, 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum, 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel, 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington, 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA . A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA /25, or PTO/AIA /26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer. Claims 1, 10, and 15 are provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of copending Application No. 18/455,258 in view of Feler (U.S. 2013/0238077, cited above). Claim 1 of the copending application provides the invention claimed in claims 1, 10, and 15 of the present application except for the claimed at least one (claim 1), at least two (claim 10), and at least three (claim 15) deformation sections. Feler teaches a spinal cord stimulation device including at least three deformation sections 410 (see Figure 4) that serve the purpose of allowing greater flexibility to the spinal cord stimulation device and “permits the paddle to conform more uniformly to the target area of implantation to minimize the gap between the electrodes and targeted fibers” (Abstract). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify claim 1 of the copending application to include at least one, at least two, and at least three deformation sections, as taught by Feler, in order to allow greater flexibility to the spinal cord stimulation device and permit the paddle to conform more uniformly to the target area of implantation to minimize the gap between the electrodes and targeted fibers. This is a provisional nonstatutory double patenting rejection. Claims 1, 10, and 15 are provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claim 1 of copending Application No. 18/796,426 in view of Feler (U.S. 2013/0238077, cited above). Claim 1 of the copending application provides the invention claimed in claims 1, 10, and 15 of the present application except for the claimed at least one (claim 1), at least two (claim 10), and at least three (claim 15) deformation sections. Feler teaches a spinal cord stimulation device including at least three deformation sections 410 (see Figure 4) that serve the purpose of allowing greater flexibility to the spinal cord stimulation device and “permits the paddle to conform more uniformly to the target area of implantation to minimize the gap between the electrodes and targeted fibers” (Abstract). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to modify claim 1 of the copending application to include at least one, at least two, and at least three deformation sections, as taught by Feler, in order to allow greater flexibility to the spinal cord stimulation device and permit the paddle to conform more uniformly to the target area of implantation to minimize the gap between the electrodes and targeted fibers. This is a provisional nonstatutory double patenting rejection. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to TAMMIE K MARLEN whose telephone number is (571)272-1986. The examiner can normally be reached Monday through Friday from 8 am until 4 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, Carl Layno can be reached at 571-272-4949. 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. /TAMMIE K MARLEN/Primary Examiner, Art Unit 3796
Read full office action

Prosecution Timeline

Jul 25, 2023
Application Filed
Oct 16, 2023
Response after Non-Final Action
Feb 06, 2026
Non-Final Rejection — §102, §103, §DP (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

1-2
Expected OA Rounds
75%
Grant Probability
96%
With Interview (+21.3%)
3y 11m
Median Time to Grant
Low
PTA Risk
Based on 801 resolved cases by this examiner. Grant probability derived from career allow rate.

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