Prosecution Insights
Last updated: April 19, 2026
Application No. 18/681,308

USE OF AN ACID WHEY TO STIMULATE THE GERMINATION OF A PLANT POLLEN GRAIN

Non-Final OA §103§112
Filed
Feb 05, 2024
Examiner
ALLEY, GENEVIEVE S
Art Unit
1617
Tech Center
1600 — Biotechnology & Organic Chemistry
Assignee
UNIVERSITE DE ROUEN NORMANDIE
OA Round
1 (Non-Final)
60%
Grant Probability
Moderate
1-2
OA Rounds
2y 11m
To Grant
99%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allow Rate
426 granted / 711 resolved
At TC average
Strong +50% interview lift
Without
With
+49.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
46 currently pending
Career history
757
Total Applications
across all art units

Statute-Specific Performance

§101
0.9%
-39.1% vs TC avg
§103
47.1%
+7.1% vs TC avg
§102
14.0%
-26.0% vs TC avg
§112
18.8%
-21.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 711 resolved cases

Office Action

§103 §112
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 Applicants’ election of Group II (claims 10-13) drawn to a composition comprising whey acid and brown seaweed extract, is acknowledged. The election was made without traverse. As the requirement for restriction is deemed proper, it is maintained and hereby made FINAL. Claims 2-9 and 14 are hereby withdrawn from further consideration by the Examiner, pursuant to 37 CFR 1.142(b), as being drawn to non-elected inventions, there being no allowable generic or linking claim. The instant claims have been examined commensurate with the scope of the elected invention. Applicants timely responded to the restriction requirement in the reply filed 1/21/26. Accordingly, claims 10-13 are under current examination. Status of Claims No new claim set was filed in response to the restriction requirement filed on 12/17/25. Withdrawn claims 2-9 and 14 Claims under instant examination 10-13 Claim Rejections - 35 USC § 112(b) The following is a quotation of 35 U.S.C. 112(b): (b)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. Claims 12-13 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claims 12-13 are unclear. Claim 12 recites “…brown seaweed extract is chosen from an extract of Ascophyllum nodosum, an extract of Focus serratus…, preferably an extract of Ascophyllum nodosum”. Claim 13 recites “the content of acid whey is between 0.5% and 25%..., preferably between 1% and 10%, more preferably between 1% and 5%...the content of brown seaweed extract is between 0.5% and 25%..., preferably between 1% and 10%, more preferably between 0.5 and 5%...the content of sucrose is between 0.5% and 25%..., preferably between 1% and 10%, more preferably between 1 and 5%...”. A broad range or limitation together with a narrow range or limitation that falls within the broad range or limitation (in the same claim) may be considered indefinite if the resulting claim does not clearly set forth the metes and bounds of the patent protection desired. See MPEP § 2173.05(c). In the present instance, claim 12-13 recite the broad recitation species/range before the “preferably”, and the claim also recites species/ranges after the “preferably” and “more preferably” which is the narrower statement of the range(s)/limitation(s). The claim(s) are considered indefinite because there is a question or doubt as to whether the feature introduced by such narrower language is (a) merely exemplary of the remainder of the claim, and therefore not required, or (b) a required feature of the claims. Claim 13 is also unclear, in view of the phrase "for example". Such phrase renders the claim indefinite because it is unclear whether the limitation(s) following the phrase are part of the claimed invention. See MPEP § 2173.05(d). 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. 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 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 10-13 are rejected under 35 U.S.C. 103 as being unpatentable over Lee (US 2013/0164233; published: 6/27/13), in view of Rocha-Mendoza et al. (J. Dairy Sci., 104(2), Feb. 2021). Determination of the Scope and Content of the Prior Art (MPEP §2141.01) Lee teaches the Estee Lauder product, CyberWhite Brilliant Cells Full Spectrum Brightening Essence as Group F of their study [0042]. Lee teaches that the product comprises the following ingredients: Water/Aqua Solvent EAU, Dimethicone Providing smoothness in use Polysorbate 40 Hydrophilic emulsifier, surfactant, fragrance dispersing agent Pentylene glycol Small-molecule humectant, Emollient, bacteriostat Acorbyl glucoside Whitening agent, Anti-oxidant Yeast extract/Faex/Extrait de Containing enzymes, various levure vitamins, minerals and saccharides, being helpful to nurse and nourish skin Polyacrylamide High-molecular-weight polymer, thickener, Antistatic agent, highly absorbent Myristyl alcohol Skin emollient, emulsification stabilizer, thickener, viscosity controlling agent Acetyl glucosamine Moisturizing, replenishing Sucrose Small-molecule moisturizer PEG-10 Dimethicone Skin emollient Phenoxyethanol Preservative, perfume fixative C 13-14 Isoparaffin Thickener Titanium dioxide (CI77891) Titanium dioxide dispersing agent Sorbitol Small-molecule humectant, thickener Sodium hydroxide Adjusting ph value Butylene glycol Solvent, moisturizing MICA Emollient, coloring agent Propylene glycol dicaprate Skin emollient Caffeine Anti-irritation, promoting metabolism and blood circulation Tocopheryl acetate Moisturizing, nourishing, protecting skin from UV Algae extract Promoting metabolism, moisturizing, softening, reducing inflammation and calming skin, anti free radical Laureth-7 Emulsifier, surfactant Pantethine Vitamin B5 derivative, softener, moisturizing, softening Chlorphenesin Preservative, bactericide Glycyrrhetinic acid (K2) Anti-irritation, skin conditioning agent Bifidus ferment filtrate Moisturizing, replenish Sodium RNA Skin conditioning agent O-Cymen-5-ol Bacteriostat Glycine soja (soybean) seed Softener, humectant extract Fragrance (Parfum) Fragrance Gentianalutea (Gentian) root Calming, allaying extract Phytosphingosine Moisturizing and improving skin immunization Sodium hyaluronate Strong humectant Helianthus annuus (Sunflower) Strengthening skin defense seedcake Silica Viscosity reguator Citric acid Peeling, toner Whey protein/lactis protein/ Tightening and smoothening skin proteine du petit-lait Chamomilla recutita Calming, allaying, antiseptic, (matricaria) flower extract astringent Disodium EDTA-2Na Metal chelating agent Oryza sativa (Rice) bran Moisturizing, anti-irritation, extract enhanced whitening effect Hordeum vulgare (Barley) Skin emollient extract/extrait d'orge Laminaria saccharina extract Skin conditioning agent Hydrolyzed rice bran extract Calming and whitening skin Plankton extract Skin conditioning agent Lecithine Natural surfactant, moisturizer, anti-oxidant Cucumis sativus (Cucumber) Moisturizing, reducing fruitextract inflammation and calming skin, and whitening Pyrus malus (Apple) fruit Moisturizing, reducing extract free-radical incurred harm and anti-aging Pueraria lobata root extract Moisturizing, anti-irritation Scutellaria baicalensis root Reducing inflammation and exract calming skin, whitening (underlined ingredients are the instantly claimed ingredients) [Table 3]. Ascertainment of the Difference Between the Scope of the Prior Art and Claims (MPEP §2141.012) Although Lee teaches a composition comprising “whey protein/lactis protein/proteine du petit-lait”, Lee does not specify if this is or contains acid whey, as required by instant claim 10. However, this deficiency is cured by Rocha-Mendoza. It is noted, the instant specification defines “acid whey” as the product resulting from the coagulation of milk by acidification (also called “sour whey”) [0016]. Rocha-Mendoza teaches that acid whey holds significant potential as a valuable source of health-promoting milk phospholipids (MPL) [Acid Whey Lipids Section]. More specifically, Rocha-Mendoza teaches that continuous topical application of MPL improves skin health through measures such as skin hydration, water-holding capacity and recovery of damaged skin [Health Benefits of the Lipid Fraction]. Lee does not teach the concentration of the claimed ingredients (i.e., acid whey, Laminaria saccharina extract and sucrose), as required by instant claim 13. It is noted that claim 13 recites a wide range of 0.5-25% by dry weight of each of the abovementioned ingredients. Finding of Prima Facie Obviousness Rationale and Motivation (MPEP §2142-2143) Lee and Rocha-Mendoza are both directed to whey-containing compositions. Based on these teachings, it would have been prima facie obvious to one of ordinary skill in the art, before the invention was effectively filed, to modify the composition of Mintel either substituting “whey protein/lactis protein/proteine du petit-lait” with Greek yogurt acid whey or further incorporating the Greek yogurt acid whey taught by Rocha-Mendoza to achieve the predictable result of obtaining a composition suitable for topical application. One of ordinary skill in the art would have been motivated to do so because Rocha-Mendoza teach that it is advantageous for skin hydration, water-holding capacity and recovery of damaged skin [Health Benefits of the Lipid Fraction]. The concentration of acid whey, brown seaweed extract (e.g., Laminaria saccharina extract) and sucrose is clearly a result effective parameter that a person of ordinary skill in the art would routinely optimize. Optimization of parameters is a routine practice that would be obvious for a person of ordinary skill in the art to employ and would reasonably expect success. It would have been customary for an artisan of ordinary skill to determine the optimal concentration in order to best achieve the desired results as such would provide advantageous biological effect. It would have been prima facie obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to engage in routine experimentation to determine optimal or workable ranges that produce expected results. Where the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation. In re Aller, 220 F. 2d 454, 105 USPQ 233 (CCPA 1955). In the instant case, Rocha-Mendoza teaches that acid whey contains milk phospholipids (MPL) and that continuous topical application of MPL improves skin health through measures such as skin hydration, water-holding capacity and recovery of damaged skin [Health Benefits of the Lipid Fraction]. Lee teaches that Laminaria saccharina extract behaves as a skin conditioning agent and that sucrose behaves as a small-molecule moisturizer in the product of Estee Lauder CyberWhite Brilliant Cells Full Spectrum Brightening Essence [Table 3]. The Examiner considers it prima facie obvious to optimize the amounts of any biologically active agent to achieve their known biological effect, absent unexpectedly superior properties of the claimed invention. In the instant case, one of ordinary skill in the art would have recognized that the concentration of acid whey, brown seaweed extract (e.g., Laminaria saccharina extract) and sucrose would impact skin hydration, water-holding capacity, recovery of damaged skin, skin conditioning and moisturization and therefore be an optimizable variable. From the teachings of the references, it is apparent that one of ordinary skill in the art would have had a reasonable expectation of success in producing the claimed invention. Therefore, the invention as a whole would have been prima facie obvious to one of ordinary skill in the art before the invention was effectively filed, as evidenced by the references, especially in the absence of evidence to the contrary. Thus, the claimed invention was prima facie obvious before the effective filing date of the claimed invention. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to GENEVIEVE S ALLEY whose telephone number is (571)270-1111. The examiner can normally be reached Monday-Friday 8:00-5:00. 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, David Blanchard can be reached at 571-272-0827. 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. /GENEVIEVE S ALLEY/Primary Examiner, Art Unit 1617
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Prosecution Timeline

Feb 05, 2024
Application Filed
Feb 18, 2026
Non-Final Rejection — §103, §112 (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
60%
Grant Probability
99%
With Interview (+49.5%)
2y 11m
Median Time to Grant
Low
PTA Risk
Based on 711 resolved cases by this examiner. Grant probability derived from career allow rate.

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