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The Guidelines (C‑V, 15.2 – November 2018 version) state that reference can be made to more than one communication only in exceptional cases and that, especially if the various communications deal with different sets of claims and it is therefore unclear which of the reasons given in them by the examining division might be essential to its decision to refuse, a fully reasoned decision should be issued instead.

CLR III K 3.5.4.A Requirements

CLR III K 3.5.4 Reasons for a decision by way of EPO Form 2061

a) Requirements

b) Reference to more than one communication

CLR III K 3.5.3 No waiver of right to a reasoned decision

CLR III K 3.5.2 No absolute right to a decision issued by way of EPO Form 2061

CLR III K 3.5.1 Request for decision "according to the state of the file"

Applicants may request a decision "according to the state of the file" or based "on the file as it stands" during examination proceedings, e.g. when their arguments have already been sufficiently put forward and they are interested in a speedy appealable decision. In such a case, a decision can be issued by way of a standard form (EPO Form 2061), simply referring to a previous communication (see Guidelines C‑V, 15 – November 2018 version).