Prosecution Insights
Last updated: August 17, 2026
Application No. 18/866,246

VAPORIZATION CHAMBER FOR A HAIRSTYLING APPLIANCE THAT DIFFUSES STEAM

Final Rejection §103
Filed
Nov 15, 2024
Priority
May 19, 2022 — FR FR2204781 +1 more
Examiner
WEBB LYTTLE, ADRIENA JONIQUE
Art Unit
3700
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
L'Oréal
OA Round
2 (Final)
17%
Grant Probability
At Risk
3-4
OA Rounds
1y 0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants only 17% of cases
17%
Career Allowance Rate
2 granted / 12 resolved
-53.3% vs TC avg
Strong +100% interview lift
Without
With
+100.0%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
37 currently pending
Career history
63
Total Applications
across all art units

Statute-Specific Performance

§101
14.4%
-25.6% vs TC avg
§103
46.6%
+6.6% vs TC avg
§102
21.0%
-19.0% vs TC avg
§112
16.1%
-23.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 12 resolved cases

Office Action

§103
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 . Information Disclosure Statement The information disclosure statement filed 02/24/2026 fails to comply with the provisions of 37 CFR 1.97, 1.98 and MPEP § 609 because the translation of the NPL reference, JP First Office Action, is not provided although a copy is readily available (37 CFR 1.98(a)(3)(ii)). It has been placed in the application file, but the information referred to therein has not been considered as to the merits. Applicant is advised that the date of any re-submission of any item of information contained in this information disclosure statement or the submission of any missing element(s) will be the date of submission for purposes of determining compliance with the requirements based on the time of filing the statement, including all certification requirements for statements under 37 CFR 1.97(e). See MPEP § 609.05(a). Specification The specification is objected to as failing to provide proper antecedent basis for the claimed subject matter. See 37 CFR 1.75(d)(1) and MPEP § 608.01(o). Correction of the following is required: Claim 1, paragraph 5, recites, “wherein each orifice included in the plurality of orifices defines an opening into the vaporization chamber having an area of between 0.1 mm2and 6 mm2”. The specification does not define what “an area” of the orifice is. For examination purposes, “area” is given its plain meaning. Claim Objections Claims 5 and 7 are objected to because of the following informalities: Claim 5, line 1, “the” needs to be capitalized. Claim 7, line 3, “the two longitudinal axes”, should be, “the at least two longitudinal axes”. Appropriate correction is required. 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. Claim(s) 1-5, and 8-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Ganem et al. (US 20220071364), hereinafter Ganem, in view of Legrain et al. (EP3025610; refer to translation), herein Legrain, Fereyre et al. (US 20160324290 A1), herein Fereyre, and Piatetsky (US 20150026904 A1). Regarding claim 1, Ganem discloses a household that diffuses steam (refer to Paragraph [0039]; FIG. 1 illustrates an exploded perspective view of a steam hair-styling appliance for shaping hair), comprising: a reservoira liquid product to be vaporized (refer to Paragraphs [0042], [0043]; the liquid reservoir is advantageously comprised in the jaw comprising the system for vaporizing 7 the liquid); a vaporization chamber (7+7’; refer to Fig. 3) that is separate from the reservoir (refer to Paragraphs [0043]-[0044]; the liquid reservoir communicates fluid via an injection tube 74 to a system for vaporizing 7 the liquid; the vaporization system 7 comprises at least one vaporization chamber 71; therefore the reservoir is separate from the vaporizing system and associated chamber) and is able to be fed with the liquid product contained in the reservoir (refer to Paragraph [0043]; the liquid reservoir communicates fluid via an injection tube 74 to a system for vaporizing 7 the liquid), wherein the reservoir at least one inlet (74) for feeding the liquid product to [[a]]the vaporization chamber (7+7’) (refer to Paragraph [0043]) wherein the household electrical appliance (1) is the vaporization chamber (7+7’) with the liquid product and output at least partially vaporized product at (refer to Paragraph [0043]) a steam diffusion flow rate greater than or equal to 0.5 g/minwherein the vaporization chamber (7+7’) includes: at least one outlet (76) for outputting the at least partially vaporized product (refer Paragraph [0047]; the steam dispensing system 7′ can comprise, for example, a dispensing chamber 76 that receives steam from the vaporization chamber 71, and in which the at least one steam dispensing port 75 is arranged), the at least one outlet (76) wsteam diffusion orifices (75) a treatment surface of the household electrical appliance (refer to Paragraph [0047], annotated Figs.1, 3 below) [[,]]; and a hollow body (7+7’) defining a free interior space (refer to annotated Fig. 3 below) that is able to allow fluid circulation between the at least one inlet (74)the at least one outlet (76) (refer to Paragraphs [0045], [0047]; a so-called free end of the injection tube 74 forms a point of injection into the main vaporization chamber 71; a dispensing chamber 76 receives steam from the vaporization chamber 71) wherein the at least one inlet (74) for feeding the liquid product has an orifice (free end of injection tube (74)) (refer to Paragraph [0045])wherein each orifice (free end of injection tube (74)) defines an opening into the vaporization chamber (free end of injection tube (74)) having an area of 7mm2(refer to Paragraphs [0062]-[0063]; the diameter of the circular injection tube is 3mm, yielding an area of 7mm2) and wherein the free interior space (refer to annotated Fig. 3 below) does not have[[ing]] a porous material around [[said]] the orifice (free end of injection tube (74))a distance of at least 2 mm from the orifice (free end of injection tube (74)) (refer to Paragraphs [0052]-[0053]; the vaporization system (7) is made from aluminum, a non-porous material; thus, the free interior space does not have a porous material and the free end of the injection tube (74) also does not have any porous material within 2mm of its structure) so as to allow the liquid product given orifice (free end of injection tube (74)) to arrive directly in contact with at least one evaporation surface of the vaporization chamber (refer to Paragraph [0044]; the surface of the lower wall of the vaporization chamber 71, is called the inner surface of the vaporization chamber 71, the fluid will be deposited by the injection tube 74 primarily on this inner surface in order to be turned into steam.). PNG media_image1.png 354 578 media_image1.png Greyscale PNG media_image2.png 370 821 media_image2.png Greyscale Ganem does not explicitly teach feeding the vaporization chamber (7+7’) with a pumping member. Although Ganem does not explicitly teach this limitation, Ganem explicitly discloses that the liquid reservoir can be incorporated into the steam hair-styling appliance in the same fashion as proposed by Legrain in EP3025610 (refer to Paragraph [0042]). Legrain further discloses using a pump (6) which will bring the fluid into the chamber of vaporization of the fluid (refer to Paragraph [0035], Fig. 1). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the interface between the vaporization chamber (7+7’) and reservoir of Ganem, with the pumping member (6) of Legrain, as Ganem discloses the liquid reservoir of Legrain as a suitable alternative. Ganem and Legrain do not disclose wherein the at least one inlet (74) for feeding the liquid product have, together, a plurality of orifices, wherein each orifice included in the plurality of orifices defines an opening into the vaporization chamber of an area between 0.1 mm2and 6 mm2 and ,wherein individual orifices included in the plurality of orifices are spaced apart from one another. Fereyre discloses a household electrical appliance (Fig. 1) in the same field of endeavor, for treating the hair (refer to Paragraph [0083]). The household electrical appliance (Fig. 1) includes a refill component (20) (refer to Paragraph [0098]), with a reservoir (23), and inlet (53) for feeding the liquid product from the reservoir (23) into the chamber (27) (refer to Paragraphs [0103], [0105], annotated Fig. 10 below; the refill 20 shown in FIGS. 5 to 7 has a reservoir 23 and a dispensing end piece 53; the first housing 27 may comprise the dispensing end piece 53 and the second housing 29 may comprise the reservoir 23), wherein the at least one inlet (53) for feeding the liquid product have, together, a plurality of orifices (68) (refer to Paragraph [0130]; the dispensing end piece 53 may comprise a number of dispensing orifices 68 so as to deliver the product), wherein each orifice included in the plurality of orifices (68) defines an opening (68) into the chamber (27) (refer to Paragraph [0131]; these dispensing orifice(s) 68 may be slots) and wherein individual orifices (68) included in the plurality of orifices (68) are spaced apart from one another (refer to Paragraph [0131]; the dispensing orifices 68 may be distributed evenly along the dispensing end piece 53). The plurality of orifices (68) dispense the product more evenly along the axis of the inlet (53) (refer to Paragraphs [0130]-[0131]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the inlet (74) of Ganem and Legrain with the inlet (53) and plurality of spaced apart orifices (68) as taught by Fereyre in order to evenly dispense the product from the reservoir (23) (refer to Paragraphs [0130]-[0131]). PNG media_image3.png 279 681 media_image3.png Greyscale Ganem, Legrain and Fereyre do not explicitly teach the opening of the orifices into the vaporization chamber being of an area between 0.1 mm2and 6 mm2. Piatetsky discloses a household electrical appliance (1) in the same field of endeavor, for dispensing liquid product (12) (refer to Paragraph [0016]; a liquid-reservoir hairbrush 1 of the present invention is designed to disperse water-based solutions and other thin and non-viscous liquids). The orifices (25) for dispensing the liquid product (12) from the reservoir (13) are of an area between 0.1 mm2and 6 mm2 (refer to Paragraphs [0016], [0017], Fig. 3; a diameter 32 of the capillary hole 25 of the roller-ball seat 21 is about 0.8 mm; the area of the circle formed by the capillary hole (25) is 0.5 mm2). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the area of the plurality of orifices of Ganem, Legrain and Fereyre with an area of 0.5 mm2 as taught by Piatetsky, as Piatetsky teaches orifices (25) of this size for dispensing liquid product (12) (refer to Paragraphs [0016]-[0017]). Regarding claims 2-4, Ganem, Legrain, Fereyre and Piatetsky disclose the household of; wherein the at least one inlet (74) for feeding the vaporization chamber (7+7’)the liquid product is in the form of a pipe (74) a terminal partextending insidethe vaporization chamber (7+7’) (refer to Paragraph [0059], annotated Fig. 3 below; the injection tube 74 is advantageously arranged substantially in the center of the vaporization chamber 71, with the end of the injection tube 74 arranged substantially in the first quarter of the length of the vaporization chamber 71) PNG media_image4.png 242 555 media_image4.png Greyscale Ganem and Legrain are silent to the plurality of orifices arranged along the pipe within the vaporization chamber wherein the plurality of orifices an to form the at least one inlet. Fereyre further discloses the plurality of orifices (68) arranged along the pipe within the chamber (27) in a regular, spaced-apart manner, substantially along an to form the at least one inlet (53) (refer to Paragraph [0131], Figs. 10-12; the dispensing orifices 68 may be distributed evenly along the dispensing end piece 53). The plurality of orifices (68) dispense the product more evenly along the axis of the inlet (53) (refer to Paragraphs [0130]-[0131]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have further modified the inlet (74) of Ganem, Legrain, Fereyre and Piatetsky with the plurality of spaced apart orifices (68) arranged along the pipe within the chamber (27) as taught by Fereyre in order to evenly dispense the product from the reservoir (23) (refer to Paragraphs [0130]-[0131]). Regarding claim 5, Ganem, Legrain, Fereyre and Piatetsky disclose the household of; Ganem and Legrain are silent to wherein the terminal para closed distal end Fereyre further discloses wherein the terminal part of the pipe (53) has a closed distal end (refer to Paragraph [0135], Fig. 9A; the dispensing end piece 53 has a tubular shape closed at one end). The closed end prolongs the dispensing of product, by only dispensing product through the orifices (68) (refer to Paragraph [0135]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have further modified the inlet (74) of Ganem, Legrain, Fereyre and Piatetsky with the closed end as taught by Fereyre in order to prolong the dispensing of product, by only dispensing product through the orifices (68) (refer to Paragraph [0135]). Regarding claims 8-10, Ganem, Legrain, Fereyre and Piatetsky disclose the household ofClaim 1,the at least one inlet (74) feeding the liquid product into the vaporization chamber (7+7’) to be vaporized (refer to Paragraph [0059]), defining at least one orifice/a single opening (free end of injection tube (74)) opening into the free space of the vaporization chamber (refer to annotated Fig. 3 above) to be vaporized, wherein each inlet (74) includes an open distal end (free end of injection tube (74)) extending into the free interior space of the vaporization chamber (refer to Paragraph [0045], annotated Fig. 3 above); however, Ganem, Legrain and Fereyre are silent to wherein the at least one inlet corresponds to a plurality of inlets. Piatetsky further discloses wherein the at least one inlet (9) corresponds to a plurality of inlets (9) with at least one orifice/a single opening (end of feeder (9)) for feeding the liquid product (12) (refer to Paragraph [0016]; each bristle 5 is comprised of a feeder 9). Multiple inlets enables dispersion of the liquid product over a greater area of the vaporization chamber. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the inlet of Ganem, Fereyre with the plurality of inlets (9) as taught by Piatetsky to enable dispersion of the liquid product over a greater area of the vaporization chamber Regarding claim 11, Ganem, Legrain, Fereyre and Piatetsky disclose the household of,wherein at least one orifice (free end of injection tube (74)) is positioned internal surfaces of thevaporization chamber (7+7’),wherein the internal surfaces include peripheral walls interior chicanes of the vaporization chamber (73) (refer to Paragraphs [0044], [0060], [0083], Fig. 4A; the surface of the lower wall of the vaporization chamber 71, is called the inner surface of the vaporization chamber 71; the injection tube 74 has an outer wall that is at least 1 mm from the inner wall of the vaporization chamber 71; The second vaporization chamber or secondary vaporization chamber 72 preferably comprises interruptions or obstacles in the form of baffles 73, analogous to chicanes). As disclosed in the rejection for claim 1 above, Fereyre discloses a household electrical appliance (Fig. 1) in the same field of endeavor, for treating the hair (refer to Paragraph [0083]), wherein the at least one inlet (53) for feeding the liquid product have, together, a plurality of orifices (68) (refer to Paragraph [0130]; the dispensing end piece 53 may comprise a number of dispensing orifices 68 so as to deliver the product) to dispense the product more evenly along the axis of the inlet (53) (refer to Paragraphs [0130]-[0131]). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the inlet (74) of Ganem with the inlet (53) and plurality of spaced apart orifices (68) as taught by Fereyre in order to evenly dispense the product from the reservoir (23) (refer to Paragraphs [0130]-[0131]). Regarding claim 12, Ganem, Legrain, Fereyre and Piatetsky disclose the household ofwherein the household electrical appliance (1) is a hairstyling appliance Regarding claim 13, Ganem, Legrain, Fereyre and Piatetsky disclose the household of; Ganem further discloses wherein the household electrical appliance (1) includes a portable treatment unit (2 or 3) including the vaporization chamber (7+7’) and the reservoir (refer to Paragraphs [0014]-[0015], [0042]; said first and/or second jaw additionally comprising a system for vaporizing the liquid to form steam, including a water reservoir) Regarding claim 14, Ganem, Legrain, Fereyre and Piatetsky disclose the household electrical appliance of claim 13; Ganem further discloses wherein the portable treatment unit includes a handle (refer to annotated Fig. 1 below). Ganem does not explicitly teach wherein the reservoir is disposed within the handle. PNG media_image5.png 240 559 media_image5.png Greyscale Legrain further discloses wherein the reservoir is disposed within the handle (refer to Paragraph [0039], Fig. 1; the main fluid reservoir (19) is shown in the handle of the device). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the placement of the reservoir of Ganem, Fereyre and Piatetsky with handle placement of the reservoir as taught by Legrain, as Ganem discloses the liquid reservoir configuration of Legrain as a suitable alternative. Regarding claim 15, Ganem, Legrain, Fereyre and Piatetsky disclose the household electrical appliance of claim 13; Ganem further discloses wherein the vaporization chamber (7+7’) is positioned in an immediate vicinity of the treatment surface of the household electrical appliance (refer to annotated Fig. 1 from claim 1) (refer to Paragraph [0046]; the steam dispensing system 7′, which is in communication with the vaporization system 7, comprises one or multiple ports 75 for dispensing steam to a lock of hair). Claim(s) 6-7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Ganem et al. (US 20220071364), hereinafter Ganem, in view of Legrain et al. (EP3025610; refer to translation), herein Legrain, Fereyre et al. (US 20160324290 A1), herein Fereyre, and Piatetsky (US 20150026904 A1), as applied to claim 2 above, and further in view of Duan (WO 2017174035; refer to translation). Regarding claims 6-7, Ganem, Legrain, Fereyre and Piatetsky disclose the household of; wherein the plurality of orificesat least two longitudinal axes of the pipe that form, between one another, a non-zero angular sector with a longitudinal central axis of the pipe, and wherein individual orifices included in the plurality of orificesare arranged along the two longitudinal axes Duan discloses a household electric appliance generating steam in the same field of endeavor (refer to Invention, lines 1-2). A pipe (1125) with a plurality of orifices (1140) provided along at least two longitudinal axes of the pipe that form, between one another, a non-zero angular sector with a longitudinal central axis of the pipe, and wherein individual orifices included in the plurality of orifices are arranged along the two longitudinal axes in an alternating manner (refer to Detailed Description, paragraph 5, annotated Figs. 4A,4B; the shunt tube 1125 is a hollow cylindrical tube, which includes a plurality of water dividing ports 1140 distributed on both sides of the shunt tube 1125). This arrangement allows for more even flow of the liquid from the reservoir (119) (refer to Detailed Description, paragraph 5). It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to have modified the orifices of Ganem, Legrain, Fereyre and Piatetsky with the orifice arrangement (Figs. 4A, 4B) as taught by Fereyre in order to allow for more even flow of the liquid from the reservoir (119) (refer to Detailed Description, paragraph 5). Response to Arguments The outstanding objections of claims 2-8, and 10-11 are withdrawn in view of the newly submitted claim amendment. The outstanding 35 U.S.C. 112(b) rejection of claims 1-13 is withdrawn in view of the newly submitted claim amendment. Applicant's arguments filed 03/02/2026 have been fully considered but they are not persuasive. In response to the argument that Ganem is silent to the hollow body of the vaporization chamber not having porous material (claim 1), Examiner points to the above rejection, in which Ganem discloses the chamber as an aluminum material (refer to Paragraphs [0052]-[0053]); thus, the entire chamber is free from porous material. In response to the argument of claim 7 that the water outlets of Duan are not alternating, Examiner points to Fig. 4B, in which the individual ports are shown as being on alternate sides of the pipe. Examiner recommends Applicant incorporate specific language from the specification into the claim language to detail the meaning of “alternate” for their invention. Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). Applicant’s arguments with respect to claim 1, in terms of the use of Duan (WO 2017174035) and Fereyre (US 20170079400), claim 5, in terms of the use of Ganem (US 20220071364), and claim 8, in terms of the use of Schmid (US 20120186599 A1), have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to Adriena J Webb Lyttle whose telephone number is (571)270-7639. The examiner can normally be reached Mon - Fri 10:00-7:00 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, Edelmira Bosques can be reached at (571) 270-5614. 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. /ADRIENA J WEBB LYTTLE/Examiner, Art Unit 3772 /EDELMIRA BOSQUES/Supervisory Patent Examiner, Art Unit 3772
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Prosecution Timeline

Nov 15, 2024
Application Filed
Jan 30, 2026
Non-Final Rejection mailed — §103
Mar 02, 2026
Response Filed
Jul 23, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

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Expected OA Rounds
17%
Grant Probability
99%
With Interview (+100.0%)
2y 9m (~1y 0m remaining)
Median Time to Grant
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