Is a 37 CFR 1.105 requirement considered an Office action?
Yes, a 37 CFR 1.105 requirement is considered an Office action, even if it is not accompanied by an action on the merits. The MPEP explicitly states: “Note that a 37 CFR 1.105 requirement, even absent an action on the merits, is an Office action.” This means that a requirement for information under 37 CFR…
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