Prosecution Insights
Last updated: April 17, 2026
Application No. 29/936,109

Cosmetic Sponge

Non-Final OA §103
Filed
Apr 05, 2024
Examiner
ERSHOCK, EVIN FRANKLIN GEO
Art Unit
2963
Tech Center
2900
Assignee
unknown
OA Round
1 (Non-Final)
97%
Grant Probability
Favorable
1-2
OA Rounds
1y 11m
To Grant
99%
With Interview

Examiner Intelligence

Grants 97% — above average
97%
Career Allow Rate
125 granted / 129 resolved
+36.9% vs TC avg
Minimal +4% lift
Without
With
+3.5%
Interview Lift
resolved cases with interview
Fast prosecutor
1y 11m
Avg Prosecution
3 currently pending
Career history
132
Total Applications
across all art units

Statute-Specific Performance

§103
9.1%
-30.9% vs TC avg
§102
44.0%
+4.0% vs TC avg
§112
43.6%
+3.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 129 resolved cases

Office Action

§103
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 . DETAILED ACTION CONTINUATION IN PART Reference to this design application as a continuation-in-part under 35 U.S.C. 120 is acknowledged. Unless the filing date of the earlier application is actually needed, such as to avoid intervening prior art, the entitlement to priority in this CIP application will not be considered. See In re Corba, 212 USPQ 825 (Comm’r Pat. 1981). EXAMINER’S COMMENT ON INFORMATION DISCLOSURE STATEMENT (IDS) The Examiner has not considered the non-patent literature document in the IDS submitted on 04/05/2024 as the citation is incorrect. For publications obtained from the internet, the uniform resource locator (URL) of the webpage that is the source of the publication must be provided for the place of publication (e.g., www.uspto.gov). See MPEP 609.04(a) § I, 707.05(e). “TinyURL” is not considered to be the source of the publication, as it is a URL shortening service. 35 U.S.C. § 103 STATEMENT OF STATUTORY BASIS 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 REJECTION –35 U.S.C. § 103 The claim is rejected under 35 U.S.C. §103 as being unpatentable over the design of the “LAURA GELLER NEW YORK Cosmetic Brushes (01 Retractable Airbrush Kabuki Brush)” published by the Amazon website on 04/13/2022, hereinafter referred to as “Laura Geller” as evidenced by the “LIDENKORS Beauty Blender” published by the Amazon website on 04/11/2023 hereinafter referred to as “LIDENKORS” and the “Buf-Puf Reusable Facial Sponge” published by the Amazon website on 10/26/2024 hereinafter referred to as “Buf-Puf”. Although the invention is not identically disclosed or described as set forth in 35 U.S.C. 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 designer having ordinary skill in the art to which the claimed invention pertains, the invention is not patentable. In rejections of design claims based on 35 U.S.C. 103, the proper standard is whether a design would have been obvious to a designer of ordinary skill in the articles involved. In re Nalbandian, 661 F. 2d 1214, 211 USPQ 782 (CCPA 1981). A proper obviousness rejection based on a combination of references requires that the visual ornamental design features of the claimed design appear in the prior art in a manner which suggests the applications as used in the claimed design. In re Sung Nam Cho, 813 F. 2d 378, 382; 1 USPQ. 2d 1662, 1663 (Fed. Cir. 1987); In re Glavas, 230 F. 2d 447, 450; 109 USPQ 50, 52 (CCPA1956); and In re Carter, 673 F. 2d 1378, 213 USPQ 625 (CCPA 1982). It is distinctiveness in overall appearance of an object when compared with the prior art, rather than minute details or small variations in configuration, that constitutes the test of design patentability. In re Lapworth, 451 F. 2d 1094, 1096; 172 USPQ 129,131 (CCPA 1971). The LAURA GELLER reference shows design characteristics which are immensely visually similar to the claimed design, in that they consist of: The base of both the claimed design and LAURA GELLER show a beveled edge at the bottom and are similar in height The lower middle portion of both the claimed design and LAURA GELLER is rounded, raised and extends outwards beyond the overall cylindrical shape In both the claimed design and the LAURA GELLER reference, the upper middle cylindrical portion shows four evenly spaced shapes spanning the circumference and have an overall rectangular appearance. Both the claimed design and LAURA GELLER have an overall rounded appearance in the uppermost portion. The claimed design differs from LAURA GELLER in that the claimed design shows an uppermost portion with a smooth and more rounded appearance. The LIDENKORS reference shows a smooth appearance, and Buf-Puf shows a more rounded appearance. It would have been obvious to a designer of ordinary skill in the art not later than the effective filing date of the present claimed invention to have modified the LAURA GELLER reference to include a smooth and more rounded appearance, as demonstrated by the LIDENKORS reference and the Buf-Puf reference. It would have been obvious to a designer of ordinary skill in the art before the effective filing date of the claimed invention to modify LAURA GELLER with the LIDENKORS reference and the Buf-Puf reference by substituting the rough and angular appearance seen in the uppermost portion by substituting the smooth appearance of LIDENKORS with the rounded apperance seen in the Buf-Puf reference. Moreover, such substitutions of known design elements for other known design elements in the same field would have been within the skill of an ordinarily skilled designer. This combination of references would result in a design over which the claimed design would have to patentable distinction. No patentable differences are seen form an ornamental standpoint. Please refer to the annotated drawing comparison. PNG media_image1.png 778 1825 media_image1.png Greyscale This modification of the primary reference in light of the secondary reference is proper because the applied references are so related that the appearance of features shown in one would suggest the application of those features to the other. The basic factual inquiries guiding the evaluation of obviousness, as outlined by Graham v. John Deere, are applicable to the evaluation of design patentability. See MPEP 1504.03(I). The difference is not significant enough to warrant a patent for the overall appearance of the claimed design over the prior art. In re Lapworth, 172 USPQ 129 (C.C.P.A. 1971); In re Lamb, 48 CCPA 817, 286 F. 2d 610, 128 USPQ 539 (1961). Further, it is noted that case law has held that one skilled in the art is charged with knowledge of the related art; therefore, the combination of old elements, herein, would have been well within the level of ordinary skill. See In re Antle, 170 USPQ 285 (CCPA 1961) and In re Nalbandian, 211 USPQ 782 (CCPA 1982). CONCLUSION Accordingly, the claim stands rejected under 35 U.S.C. 103 over the LAURA GELLER design, as modified, as set forth above. The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Applicant may view and obtain copies of the cited references by visiting <https://ppubs.uspto.gov/pubwebapp/static/pages/ppubsbasic.html> and pressing the “Patent Number Search” button. CONTACT INFORMATION Any inquiry concerning this communication or earlier communications from the examiner should be directed to Evin F G Ershock whose telephone number is (571)272-1833. The examiner can normally be reached Monday - Friday, 9:00AM - 5:00PM. 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, Christian Mclean can be reached at (571) 270-1996. 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. /EVIN F ERSHOCK/Examiner, Art Unit 2923
Read full office action

Prosecution Timeline

Apr 05, 2024
Application Filed
Nov 25, 2025
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent D1118172
Brush
2y 5m to grant Granted Mar 17, 2026
Patent D1119161
Cosmetic brush
2y 5m to grant Granted Mar 17, 2026
Patent D1113168
Hair brush
2y 5m to grant Granted Feb 17, 2026
Patent D1104486
HAIR BRUSH
2y 5m to grant Granted Dec 09, 2025
Patent D1104485
Brush
2y 5m to grant Granted Dec 09, 2025
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
97%
Grant Probability
99%
With Interview (+3.5%)
1y 11m
Median Time to Grant
Low
PTA Risk
Based on 129 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in for Full Analysis

Enter your email to receive a magic link. No password needed.

Free tier: 3 strategy analyses per month