MPEP § 2260 — Office Actions (Annotated Rules)

§2260 Office Actions

USPTO MPEP version: BlueIron's Update: 2025-12-31

This page consolidates and annotates all enforceable requirements under MPEP § 2260, including statutory authority, regulatory rules, examiner guidance, and practice notes. It is provided as guidance, with links to the ground truth sources. This is information only, it is not legal advice.

Office Actions

This section addresses Office Actions. Primary authority: 35 U.S.C. 304, 37 CFR 1.104, and 37 CFR 1.530. Contains: 1 requirement, 2 guidance statements, 1 permission, and 2 other statements.

Key Rules

Topic

First Action on Merits

2 rules
StatutoryInformativeAlways
[mpep-2260-7cf7110d96809c9e5f7c8bb9]
Examiner’s First Ex Parte Action Establishes Issues in Reexamination
Note:
The examiner must issue a primary action on the merits to establish issues between the examiner and patent owner, following 37 CFR 1.104.

As is true in the examination of applications, 37 CFR 1.104 (Nature of examination) applies to the examination of reexamination proceedings. It is intended that the examiner’s first ex parte action on the merits be the primary action to establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. At the time the first action is issued in reexaminations ordered under 35 U.S.C. 304, the patent owner has already been permitted to file a statement and an amendment pursuant to 37 CFR 1.530; and the reexamination requester, if the requester is not the patent owner, has been permitted to reply thereto pursuant to 37 CFR 1.535. In any case, thus, at this point, the issues should be sufficiently focused to enable the examiner to make a definitive first ex parte action on the merits which should clearly establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. In view of the fact that the examiner’s first action will clearly establish the issues, the first action should include a statement cautioning the patent owner that a complete response should be made to the action since the next action is expected to be a final action. The first action should further caution the patent owner that the requirements of 37 CFR 1.116(b) will be strictly enforced after final action and that any amendment after a final action must include “a showing of good and sufficient reasons why the amendment is necessary and was not earlier presented” in order to be considered. The language of form paragraph 22.04 is appropriate for inclusion in the first Office action:

Jump to MPEP Source · 37 CFR 1.104First Action on MeritsFirst Office Action on MeritsExamination in Reexamination
StatutoryRecommendedAlways
[mpep-2260-a00e5158c68998ccbb045536]
Issues Must Be Clearly Defined In First Ex Parte Action
Note:
The examiner’s first ex parte action on the merits must clearly establish the issues between the examiner and the patent owner, ensuring a definitive response is required from the patent owner.

As is true in the examination of applications, 37 CFR 1.104 (Nature of examination) applies to the examination of reexamination proceedings. It is intended that the examiner’s first ex parte action on the merits be the primary action to establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. At the time the first action is issued in reexaminations ordered under 35 U.S.C. 304, the patent owner has already been permitted to file a statement and an amendment pursuant to 37 CFR 1.530; and the reexamination requester, if the requester is not the patent owner, has been permitted to reply thereto pursuant to 37 CFR 1.535. In any case, thus, at this point, the issues should be sufficiently focused to enable the examiner to make a definitive first ex parte action on the merits which should clearly establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. In view of the fact that the examiner’s first action will clearly establish the issues, the first action should include a statement cautioning the patent owner that a complete response should be made to the action since the next action is expected to be a final action. The first action should further caution the patent owner that the requirements of 37 CFR 1.116(b) will be strictly enforced after final action and that any amendment after a final action must include “a showing of good and sufficient reasons why the amendment is necessary and was not earlier presented” in order to be considered. The language of form paragraph 22.04 is appropriate for inclusion in the first Office action:

Jump to MPEP Source · 37 CFR 1.104First Action on MeritsFirst Office Action on MeritsFinal Office Action
Topic

First Action on Merits (FAOM)

2 rules
StatutoryPermittedAlways
[mpep-2260-0d31c2d9f6b6258c552e40bd]
Patent Owner Must File Statement and Amendment Before First Action
Note:
Before the examiner issues its first action on the merits, the patent owner must file a statement and amendment under 37 CFR 1.530, and if applicable, the requester must reply to these filings under 37 CFR 1.535.

As is true in the examination of applications, 37 CFR 1.104 (Nature of examination) applies to the examination of reexamination proceedings. It is intended that the examiner’s first ex parte action on the merits be the primary action to establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. At the time the first action is issued in reexaminations ordered under 35 U.S.C. 304, the patent owner has already been permitted to file a statement and an amendment pursuant to 37 CFR 1.530; and the reexamination requester, if the requester is not the patent owner, has been permitted to reply thereto pursuant to 37 CFR 1.535. In any case, thus, at this point, the issues should be sufficiently focused to enable the examiner to make a definitive first ex parte action on the merits which should clearly establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. In view of the fact that the examiner’s first action will clearly establish the issues, the first action should include a statement cautioning the patent owner that a complete response should be made to the action since the next action is expected to be a final action. The first action should further caution the patent owner that the requirements of 37 CFR 1.116(b) will be strictly enforced after final action and that any amendment after a final action must include “a showing of good and sufficient reasons why the amendment is necessary and was not earlier presented” in order to be considered. The language of form paragraph 22.04 is appropriate for inclusion in the first Office action:

Jump to MPEP Source · 37 CFR 1.104First Action on Merits (FAOM)First Action on MeritsAmendments Adding New Matter
StatutoryInformativeAlways
[mpep-2260-a08ad167c780b4dee9e97407]
Cautionary Statement for First Office Action
Note:
The first action should include a cautionary statement to the patent owner about responding completely and including good reasons for any amendments after final action.

As is true in the examination of applications, 37 CFR 1.104 (Nature of examination) applies to the examination of reexamination proceedings. It is intended that the examiner’s first ex parte action on the merits be the primary action to establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. At the time the first action is issued in reexaminations ordered under 35 U.S.C. 304, the patent owner has already been permitted to file a statement and an amendment pursuant to 37 CFR 1.530; and the reexamination requester, if the requester is not the patent owner, has been permitted to reply thereto pursuant to 37 CFR 1.535. In any case, thus, at this point, the issues should be sufficiently focused to enable the examiner to make a definitive first ex parte action on the merits which should clearly establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. In view of the fact that the examiner’s first action will clearly establish the issues, the first action should include a statement cautioning the patent owner that a complete response should be made to the action since the next action is expected to be a final action. The first action should further caution the patent owner that the requirements of 37 CFR 1.116(b) will be strictly enforced after final action and that any amendment after a final action must include “a showing of good and sufficient reasons why the amendment is necessary and was not earlier presented” in order to be considered. The language of form paragraph 22.04 is appropriate for inclusion in the first Office action:

Jump to MPEP Source · 37 CFR 1.104First Action on Merits (FAOM)Form Paragraph UsageColumn and Line References
Topic

Final Office Action

2 rules
StatutoryRecommendedAlways
[mpep-2260-584692111e4ce59a0fd42dbc]
Caution for Complete Response After First Action
Note:
The first action should warn the patent owner to provide a complete response since the next action is expected to be final.

As is true in the examination of applications, 37 CFR 1.104 (Nature of examination) applies to the examination of reexamination proceedings. It is intended that the examiner’s first ex parte action on the merits be the primary action to establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. At the time the first action is issued in reexaminations ordered under 35 U.S.C. 304, the patent owner has already been permitted to file a statement and an amendment pursuant to 37 CFR 1.530; and the reexamination requester, if the requester is not the patent owner, has been permitted to reply thereto pursuant to 37 CFR 1.535. In any case, thus, at this point, the issues should be sufficiently focused to enable the examiner to make a definitive first ex parte action on the merits which should clearly establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. In view of the fact that the examiner’s first action will clearly establish the issues, the first action should include a statement cautioning the patent owner that a complete response should be made to the action since the next action is expected to be a final action. The first action should further caution the patent owner that the requirements of 37 CFR 1.116(b) will be strictly enforced after final action and that any amendment after a final action must include “a showing of good and sufficient reasons why the amendment is necessary and was not earlier presented” in order to be considered. The language of form paragraph 22.04 is appropriate for inclusion in the first Office action:

Jump to MPEP Source · 37 CFR 1.104Final Office ActionFirst Action on Merits (FAOM)First Action on Merits
StatutoryRequiredAlways
[mpep-2260-1840cc6e2318e25a58d3d062]
Amendments Must Show Reasons for Delayed Presentation After Final Action
Note:
Patent owners must provide a showing of good and sufficient reasons why amendments are necessary and were not earlier presented after receiving a final action.

As is true in the examination of applications, 37 CFR 1.104 (Nature of examination) applies to the examination of reexamination proceedings. It is intended that the examiner’s first ex parte action on the merits be the primary action to establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. At the time the first action is issued in reexaminations ordered under 35 U.S.C. 304, the patent owner has already been permitted to file a statement and an amendment pursuant to 37 CFR 1.530; and the reexamination requester, if the requester is not the patent owner, has been permitted to reply thereto pursuant to 37 CFR 1.535. In any case, thus, at this point, the issues should be sufficiently focused to enable the examiner to make a definitive first ex parte action on the merits which should clearly establish the issues which exist between the examiner and the patent owner insofar as the patent is concerned. In view of the fact that the examiner’s first action will clearly establish the issues, the first action should include a statement cautioning the patent owner that a complete response should be made to the action since the next action is expected to be a final action. The first action should further caution the patent owner that the requirements of 37 CFR 1.116(b) will be strictly enforced after final action and that any amendment after a final action must include “a showing of good and sufficient reasons why the amendment is necessary and was not earlier presented” in order to be considered. The language of form paragraph 22.04 is appropriate for inclusion in the first Office action:

Jump to MPEP Source · 37 CFR 1.104Final Office ActionFirst Action on Merits (FAOM)After-Final Amendments

Examiner Form Paragraphs

Examiner form paragraphs are standard language that you might see in an Office Action or communication from the USPTO. Examiners have latitude to change the form paragraphs, but you will often see this exact language.

¶ 22.04 ¶ 22.04 Papers To Be Submitted in Response to Action – Ex Parte Reexamination

In order to ensure full consideration of any amendments, affidavits or declarations, or other documents as evidence of patentability, such documents must be submitted in response to this Office action. Submissions after the next Office action, which is intended to be a final action, will be governed by the requirements of 37 CFR 1.116 after final rejection and 37 CFR 41.33 after appeal, which will be strictly enforced.

Citations

Primary topicCitation
Final Office Action
First Action on Merits
First Action on Merits (FAOM)
35 U.S.C. § 304
Final Office Action
First Action on Merits
First Action on Merits (FAOM)
37 CFR § 1.104
Final Office Action
First Action on Merits
First Action on Merits (FAOM)
37 CFR § 1.116(b)
Final Office Action
First Action on Merits
First Action on Merits (FAOM)
37 CFR § 1.530
Final Office Action
First Action on Merits
First Action on Merits (FAOM)
37 CFR § 1.535
Final Office Action
First Action on Merits
First Action on Merits (FAOM)
Form Paragraph § 22.04

Source Text from USPTO’s MPEP

This is an exact copy of the MPEP from the USPTO. It is here for your reference to see the section in context.

BlueIron Last Updated: 2025-12-31