Prosecution Insights
Last updated: April 19, 2026
Application No. 18/645,688

EYEBROW PRIMER

Non-Final OA §103§112
Filed
Apr 25, 2024
Examiner
YU, HONG
Art Unit
1614
Tech Center
1600 — Biotechnology & Organic Chemistry
Assignee
L’Oréal
OA Round
1 (Non-Final)
31%
Grant Probability
At Risk
1-2
OA Rounds
4y 0m
To Grant
37%
With Interview

Examiner Intelligence

Grants only 31% of cases
31%
Career Allow Rate
214 granted / 681 resolved
-28.6% vs TC avg
Moderate +5% lift
Without
With
+5.3%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
73 currently pending
Career history
754
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
49.5%
+9.5% vs TC avg
§102
16.7%
-23.3% vs TC avg
§112
15.1%
-24.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 681 resolved cases

Office Action

§103 §112
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 . 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 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. DETAILED ACTION Claims 1-19 are pending in this application. This application is a division of 17/732,697, filled on 04/29/2022. Claim Objection Claim 1 is objected in the recitation the acronyms “HLB”. Use of the full terminology at the first occurrence would obviate this objection. Claim Rejections - 35 USC 112(b) The following is a quotation of the second paragraph of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. Claim 19 is rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which applicant regards as the invention. The recitation of "substantially free of oils" in claim 1 and the recitation of “optionally an oil" in claim 19 render claim 19 indefinite. It is confusing to one of ordinary skill whether the primer is substantially free of oils as recited in claim 1 or not as recited in claim 19. 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. This application currently names joint inventors. In considering patentability of the claims under 35 U.S.C. 103(a), the examiner presumes that the subject matter of the various claims was commonly owned at the time any inventions covered therein were made absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and invention dates of each claim that was not commonly owned at the time a later invention was made in order for the examiner to consider the applicability of 35 U.S.C. 103(c) and potential 35 U.S.C. 102(e), (f) or (g) prior art under 35 U.S.C. 103(a). The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103(a) 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. Claims 1-4, 6-8, 11, and 14-19 are rejected under 35 U.S.C. 103(a) as being unpatentable over Masuda et al. (US 2015/0056152 A1). Masuda et al. teach an eyebrow color or foundation (implies the claimed applying an eyebrow primer to an eyebrow and applying an eyebrow makeup composition over the eyebrow primer in the instant claim 1) (paragraph 24 and claim 9) comprising 0.1 to 30% by weight (calculated as solids and based on the composition) of an emulsion (paragraph 24), 8-80% by weight of inorganic powder including talc (the claimed transparent filler in the instant claims 1-4 and 19); wherein the emulsion comprises polymerization product of a triorganosiloxysilicic acid and an ethylenically unsaturated monomer including t-butyl acrylamide (the claimed polyacrylamide thickener in the instant claims 1 and 19), in the presence of 0.1-20% by weight of at least one emulsion stabilizer such as nonionic surfactant including polyoxyethylene hardened castor oil (HLB of about 8.6-16, the claimed high HLB surfactant, HLB ≥9, in the instant claims 1, 17, and 18 according to the instant specification paragraph 28) and sorbitol fatty acid esters (HLB of about 1.6-8.6, the claimed additional not high HLB surfactant in the instant claims 14 and 15 according to the instant specification paragraph 76), and polyvinyl alcohol (the claimed water-soluble polymer in the instant claims 8 and 10 and the claimed polyhydric alcohol in the instant claim 11) (abstract and paragraph 14, 20-23, and 32 and claim 8), and water (paragraph 40) (the claimed polyacrylamide thickener in the instant claims 1, 6, and 7 and also the claimed water-dispersed latex polymer in the instant claims 1 and 19). Masuda et al. do not teach oil as a must have component (the instant claim 1). Masuda et al. do not teach clay and pigment as must have components (the instant claim 16). The weight percentage of surfactant is calculated to be 0.0001-6% by weight (0.-1%x0.1%=0.0001%, 20%x30%=6%). Masuda et al. do not specify the same weight percentages of talc (5-80% vs the claimed 5-10% in the instant claim 4), surfactant 0.0001-6% vs the claimed ≥2%, ≥4%, and ≥6% in the instant claims 1, 17, and 18 and 1-3% in the instant claim 15), polyacrylamide thickener/latex polymer (0.1 to 30% vs the claimed ≥0.5% and ≥2% in the instant claims 6 and 7). This deficiency is cured by the rationale that a prima facie case of obviousness typically exists when the range of a claimed composition lies inside/overlaps with the range disclosed in the prior art, such as in the instant rejection. The claimed range of talc is 5-10% by weight and the range of talc taught in the prior art is 5-80% by weight and therefor, includes the claimed range. The claimed ranges of surfactant are ≥2%, ≥4%, ≥6%, and 1-3% by weight and the range of surfactant taught in the prior art is 0.0001-6% by weight and therefor, includes/overlaps with the claimed range. The claimed range of polyacrylamide thickener/latex polymer is ≥0.5% and ≥2% by weight and the range of polyacrylamide thickener/latex polymer taught in the prior art is 0.1 to 30% by weight and therefor, overlaps with the claimed range. Claims1-19 are rejected under 35 U.S.C. 103(a) as being unpatentable over Masuda et al. (US 2015/0056152 A1) in view of Den-Braven et al. (US 2010/0105638 A1). The teachings of Masuda et al. are discussed above and applied in the same manner. Masuda et al. also tech the non-ionic surfactants including polyoxyalkylene alkyl ethers (paragraph 34) and 0-10% by weight of polymers and common cosmetic ingredients (paragraph 52). Masuda et al. do not specify the polyoxyalkylene alkyl ethers non-ionic surfactants including ceteareth-25 in the instant claim 5, the polymers including polyvinylpyrrolidone (PVP) in the instant claim 9 and the same weight percentage of it in the instant claim 10, and the common cosmetic ingredients including glycerin and a plurality of glycols in the instant claims 12 and 13. This deficiency is cured by Den-Braven et al. who teach cosmetic compositions (abstract) comprising surface active ingredients including ceteareth-25 (a polyoxyalkylene alkyl ether) (paragraph 35), usual cosmetic additives such as propylene glycol, glycerin, and ethylene glycol (paragraph 50), and cosmetically and dermatologically acceptable polymers including PVP (paragraph 55, 57, and 58) and the rationale that a prima facie case of obviousness typically exists when the range of a claimed composition overlaps with the range disclosed in the prior art. It would have been prima facie obvious before the effective filing date of the claimed invention to a person of ordinary skill in the art to combine the teachings in Masuda et al. and Den-Braven et al. to specify the polyoxyalkylene alkyl ethers non-ionic surfactants, the 0-10% by weight of polymers, and the common cosmetic ingredients in the composition taught by Masuda et al. including ceteareth-25, including PVP, and including propylene glycol, glycerin, and ethylene glycol, respectively. Cosmetic compositions comprising ceteareth-25 as a surface-active ingredient, propylene glycol, glycerin, and ethylene glycol as usual cosmetic additives, and PVP as a cosmetically and dermatologically acceptable polymer was well known to a person of ordinary skill in the art before the effective filing date of the claimed invention. The motivation for specifying them flows from its having been used in the prior art, and from their being recognized in the prior art as useful for the same purpose. The claimed range of water-soluble polymer is 7-13% by weight and the range of polymer taught in the prior art is 0-10% by weight and therefor, overlaps with the claimed range. Correspondence Any inquiry concerning this communication or earlier communications from the examiner should be directed to HONG YU whose telephone number is (571)270-1328. The examiner can normally be reached on 9 am - 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, Ali Soroush can be reached on 571-272-9925. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /HONG YU/ Primary Examiner, Art Unit 1614
Read full office action

Prosecution Timeline

Apr 25, 2024
Application Filed
Jan 09, 2026
Non-Final Rejection — §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12599623
SKIN COMPOSITIONS AND METHODS OF USE THEREOF
2y 5m to grant Granted Apr 14, 2026
Patent 12589059
MINERAL SUNSCREEN COMPOSITIONS WITH HIGH SPF AND SHELF STABILITY
2y 5m to grant Granted Mar 31, 2026
Patent 12577725
ODOR CONTROL COMPOSITION AND METHOD OF USING
2y 5m to grant Granted Mar 17, 2026
Patent 12569428
OIL-IN-WATER CLEANSING COSMETIC COMPOSITION
2y 5m to grant Granted Mar 10, 2026
Patent 12558432
BIOCOMPATIBLE POLYMERIC DRUG CARRIERS FOR DELIVERING ACTIVE AGENTS
2y 5m to grant Granted Feb 24, 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

1-2
Expected OA Rounds
31%
Grant Probability
37%
With Interview (+5.3%)
4y 0m
Median Time to Grant
Low
PTA Risk
Based on 681 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