★ THE APRIL 24, 2026 REPLY · DECONSTRUCTED
"A paper provided with a lead bromide solution is not a painted surface."
That is the actual quoted argument from page 1 of the Lumetallix reply, signed by their European patent attorney. To support this novelty distinction over Yan 2019, two paint-definition documents were submitted as authorities. They are consumer painting blog posts.
These are the documents Lumetallix's European patent attorneys submitted to the European Patent Office as authorities for what paint is. They are reproduced here with their full first pages, as the EPO received them.
Citation A · submitted to the EPO on April 24, 2026
"Basic Paint Ingredients and Chemicals"
By Haseeb Jamal · February 21, 2017 · 4 pages · civil-engineering blog post. Defines paint as solvent + binder + pigment + additives.
Above: the actual first page of the document Lumetallix's representative submitted to the European Patent Office as evidence of what paint is. Author photo at top of post. Click image to view the full PDF.
Citation B · submitted to the EPO on April 24, 2026
"Painting 101: What Is Paint Made Of?"
By "admin" · September 21, 2018 · 4 pages · ultrafinishpainting.com. Subtitled "A primer on paint ingredients" with a consumer paint-can infographic.
Above: the title page and the consumer infographic from the second document submitted as authority for what paint is. Authored by "admin" on a residential painting company's blog. Click images to view the full PDF.
From the Lumetallix reply, with their definition of paint:
"A binder is necessary for forming the final paint layer; it ensures binding of the paint to the surface on which it is applied and forms the durable coating layer. A solvent dissolves or disperses the binder before application to form a liquid medium. Pigments, such as lead white, are applied to provide color and/or opacity. Additives may be present to improve the properties of the paint."De Vries & Metman reply to ED, April 24, 2026, page 1.
Then the conclusion they want to reach:
"the lead bromide solution of D8/D9 is not a paint within the broadest technical interpretation of the word as used in the application as filed. The lead bromide solution does not contain binder or pigment, and does not form a protective or decorative layer."Same reply, page 2.