Prosecution Insights
Last updated: April 19, 2026
Application No. 18/818,927

Holster Tensioner Device

Non-Final OA §102§DP
Filed
Aug 29, 2024
Examiner
SKURDAL, COREY NELSON
Art Unit
3734
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
Safariland LLC
OA Round
1 (Non-Final)
61%
Grant Probability
Moderate
1-2
OA Rounds
2y 5m
To Grant
73%
With Interview

Examiner Intelligence

Grants 61% of resolved cases
61%
Career Allow Rate
729 granted / 1189 resolved
-8.7% vs TC avg
Moderate +11% lift
Without
With
+11.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 5m
Avg Prosecution
31 currently pending
Career history
1220
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
38.7%
-1.3% vs TC avg
§102
35.9%
-4.1% vs TC avg
§112
17.8%
-22.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1189 resolved cases

Office Action

§102 §DP
DETAILED ACTION 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 11-24 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-10 of U.S. Patent No. 12,078,450 in view of Rogers et al. (US 5,944,239). The prior patented claims 1-10 of US 12,078,450 recite the same essential device as the presently claimed device, including: a holster, holster body, tensioner body and spring, but the prior claims do not disclose the tensioner being a plastic member as now claimed. However, Rogers discloses a similar tensioner body 12/14 that is controlled by a spring 15 and wherein the tensioner body is a plastic member (nylon or Teflon as in col. 4 lines 56-60). Therefore, it would have been obvious to one of ordinary skill in the art at the time of invention to make the tensioner body as a plastic member in order to provide a known material used in the art. Claims 25-29 are rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-10 of U.S. Patent No. 12,078,450. Although the claims at issue are not identical, they are not patentably distinct from each other because they claim the same essential device but in broader language, i.e. only the tensioner itself is claimed, including a tensioner body engaged and deformed by an item and a spring for resisting and controlling deformation of the tensioner body. The claimed structure of the tensioner is disclosed throughout claims 1-10 in similar language to claims 25-29 of the present application. 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. Claim(s) 11-12, 14, 17-22 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Rogers et al. (US 5,944,239). Regarding claim 11, Rogers discloses a holster (Figure 1) for a handgun assembly, the holster including: a holster body 10 having a chamber for receiving the handgun assembly; a tensioner body 12/14 on the holster body that is engaged and deformed by the handgun assembly; and a spring 15 connected with the tensioner body; wherein the tensioner body is a plastic member (col. 4 lines 56-58) that flexed and kept under tension when a handgun assembly is in the holster, and the spring inhibits relaxation of the tensioner under a continuous load. Regarding claims 12 and 14, Rogers discloses the spring is a metal compression spring 15. Regarding claim 17, Rogers discloses the tensioner 12 is operative to apply biasing force to the handgun assembly in a direction toward a top wall of the holster (see directional arrow 27 as in Figure 1). Regarding claim 18, Rogers discloses several different tensioner body shapes, including Figure 10 which has a central portion (see body portion to the left of lead line 106, below spring 108, and above pivot 105) in an arcuate configuration that is concave in a direction away from the holster chamber and an outer side surface 106 that is presented toward the holster chamber. Regarding claim 19, Rogers discloses a one-piece tensioner body 14. Regarding the body being formed by molding, the method of forming the device is not germane to the issue of patentability of the device itself. Therefore, this limitation has not been given patentable weight. Regarding claim 20, Rogers discloses wherein a central portion 14/16 of the tensioner body projects into the chamber of the holster through an opening in a wall of the holster body (e.g. opening defined by wall 13/21, such that an outer side surface of the tensioner body central portion is engageable by the handgun assembly when the handgun assembly is in the chamber (see Figure 1). Regarding claim 21, Rogers discloses a holster 10 comprising: a holster body 10 having a chamber for receiving a handgun assembly (Figure 1); a plastic element 12/14 (col. 4 lines 56-58) on the holster body, having a central portion 14/16 that is engageable by the handgun assembly in the chamber and that is operable to apply a resilient biasing force to the handgun assembly in the chamber; and a spring 15 connected in a force-transmitting relationship with the plastic element and operable to control deformation of the plastic element. Regarding claim 22, see Figure 1 wherein the tensioner engages the start of the trigger guard. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to COREY NELSON SKURDAL whose telephone number is (571)272-9588. The examiner can normally be reached Mon-Fri 9am-4pm EST. 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, Nathan Newhouse can be reached at 571-272-4544. 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. /COREY N SKURDAL/Primary Examiner, Art Unit 3734
Read full office action

Prosecution Timeline

Aug 29, 2024
Application Filed
Apr 24, 2025
Response after Non-Final Action
Dec 18, 2025
Non-Final Rejection — §102, §DP (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12600424
CONVERTIBLE CARGO HOLDER AND BICYCLE SEAT
2y 5m to grant Granted Apr 14, 2026
Patent 12584711
UNIVERSAL MOUNT SYSTEMS AND METHODS FOR TACTICAL ACCESSORIES
2y 5m to grant Granted Mar 24, 2026
Patent 12571609
QUICK RELEASE HOLSTER
2y 5m to grant Granted Mar 10, 2026
Patent 12570218
TRACK ASSEMBLY WITH STORAGE BIN
2y 5m to grant Granted Mar 10, 2026
Patent 12545344
Reconfigurable Arm for a Bicycle Rack
2y 5m to grant Granted Feb 10, 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
61%
Grant Probability
73%
With Interview (+11.4%)
2y 5m
Median Time to Grant
Low
PTA Risk
Based on 1189 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