Prosecution Insights
Last updated: April 19, 2026
Application No. 17/203,114

ELECTRICALLY CONDUCTIVE SUBSTANCE, POSITIVE ELECTRODE, AND SECONDARY BATTERY

Final Rejection §103
Filed
Mar 16, 2021
Examiner
CHUO, TONY SHENG HSIANG
Art Unit
1751
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Hydro-Québec
OA Round
6 (Final)
46%
Grant Probability
Moderate
7-8
OA Rounds
4y 0m
To Grant
54%
With Interview

Examiner Intelligence

Grants 46% of resolved cases
46%
Career Allow Rate
319 granted / 696 resolved
-19.2% vs TC avg
Moderate +8% lift
Without
With
+8.0%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
54 currently pending
Career history
750
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
58.3%
+18.3% vs TC avg
§102
18.9%
-21.1% vs TC avg
§112
17.7%
-22.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 696 resolved cases

Office Action

§103
DETAILED ACTION Response to Amendment Claims 1, 2, 5, 11-14, 22, 24, and 25 are current pending. Claims 3, 4, 6-10, 15-21, and 23 are cancelled. New claims 24 and 25 have been added. The amended claim 1 does overcome the previously stated 103 rejections. However, upon further consideration, claims 1, 2, 5, 11-14, 22, 24, and 25 are rejected under the following new 103 rejection. This action is made FINAL as necessitated by the amendment. Claim Rejections - 35 USC § 103 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. Claims 1, 2, 5, 11-14, 22, 24, and 25 are rejected under 35 U.S.C. 103 as being unpatentable over Miyayama et al (JP 2005123107 A, machine translation) in view of Yamashita et al (US 2018/0083284), and further in view of Sukino et al (JP 2011228293 A, machine translation). Regarding claims 1, 2, 5, 11-14, 22, 24, and 25, Miyayama et al discloses an electrochemical device (lithium ion secondary battery) comprising: a positive electrode; a negative electrode; and a nonaqueous electrolyte (electrolytic solution); wherein the positive electrode comprises: a positive electrode current collector and a positive electrode mixture (positive electrode active material layer) that is provided on the positive electrode current collector and includes a composite (electrically conductive substance) comprising: a carbon material (electrically conductive supports) each including a carbon material; a lithium phosphate (electrically conductive particles) supported by the carbon material, wherein the lithium phosphate includes primary particles each consisting of a lithium compound including a lithium phosphate compound represented by LiFePO4, wherein the carbon material includes artificial graphite (sheet-shaped carbon material), acetylene black, carbon black (spherical carbon material), carbon fiber (fibrous carbon material), carbon nanotube ([0013],[0016]-[0020],[0026]). However, Miyayama et al does not expressly teach a lithium phosphate compound represented by LiMn0.75Fe0.20Mg0.05PO4 (claim 1). Yamashita et al discloses a positive electrode active material (electrically conductive particles) that is LiMn0.75Fe0.20Mg0.05PO4 ([0145]). Therefore, the invention as a whole would have been obvious to one of ordinary skill in the art at the time the invention was made because the disclosure of Yamashita indicates that LiMn0.75Fe0.20Mg0.05PO4 is a suitable material for use as a positive electrode active material. The selection of a known material based on its suitability for its intended use has generally been held to be prima facie obvious (MPEP §2144.07). As such, it would be obvious to use LiMn0.75Fe0.20Mg0.05PO4. However, Miyayama et al as modified by Yamashita et al does not expressly teach a lithium phosphate compound having an average particle size ranging from 21 nm to 26 nm; and a covering layer including carbon in a carbon source that is water soluble and covering at least a part of the electrically conductive supports (claim 1); the secondary particles having an average particle size from 50 nanometers to 1000 nanometers (claim 2); wherein the positive electrode active material layer further includes a positive electrode active material (claim 12); wherein the average particle size of the electrically conductive particles is 26 nm (claim 22); wherein the carbon source of the covering layer includes sucrose (claim 25). Sukino et al teaches the concept of coating a surface of active material particles such as lithium phosphate (electrically conductive particles) with carbon (covering layer) that can be obtained by heat treating a carbon source that is water soluble such as sucrose; wherein the average particle size of the secondary particles is preferably 0.5 (500 nm) to 50 um (50,000 nm) and the particle size of the primary particles of LiFePO4 is more preferably 50 nm to 500 nm; wherein the positive electrode active material layer further includes a lithium transition metal composite oxide (positive electrode active material) ([0032]-[0034]). Therefore, it would have been obvious to one of ordinary skill in the art at the time the invention was made to modify the Miyayama/Yamashita composite to include primary particles of a lithium phosphate compound having an average particle size of 50 nm to 500 nm and secondary particles having an average particle size from 500 nm to 50,000 nm; a covering layer that includes carbon in a carbon source that is water soluble such as sucrose; wherein the positive electrode active material layer further includes a positive electrode active material such as lithium transition metal composite oxide in order to ensure sufficient electron conduction between particles to fully exhibit the effects of the invention ([0032]); thereby providing a battery having a high ratio of a low-SOC output with respect to a high-SOC output, and a high energy density (Abstract). In addition, it would have been obvious to one of ordinary skill in the art at the time the invention was made to modify the Miyayama/Yamashita/Sukino composite to include primary particles of the lithium phosphate compound having an average particle size ranging from 21 nm to 26 nm or 26 nanometers and secondary particles having an average particle size from 50 nanometers to 1000 nanometers because it has been held that the discovery of an optimum value of a result effective variable in a known process is ordinarily within the skill of the art. In re Boesch, 205 USPQ 215 (CCPA 1980). Sukino et al also discloses that by reducing the primary particle size of LiFePO4, the conduction path length of electrons in the solid phase and the diffusion path length of Li ions can be shortened, making it possible to maximize the performance of the LiFePO4 ([0034]). So, the average particle sizes of the primary particles and secondary particles are result effective variables of shortening the conduction path length of electrons in the solid phase and the diffusion path length of Li ions to maximize the performance of the lithium phosphate compound. Where the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation. In re Aller, 220 F.2d 454. 456, 105 USPQ 233, 235 (CCPA 1955)). There is no evidence of criticality of the claimed average particle size of primary particles and secondary particles the lithium phosphate compound. Lastly, the Office takes the position that the Miyayama/Yamashita/Sukino composite inherently comprises a covering layer covering at least a part of the carbon material (electrically conductive supports). Response to Arguments Applicant’s arguments with respect to claim(s) 1, 2, 5, 11-14, 22, 24, and 25 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to TONY S CHUO whose telephone number is (571)272-0717. The examiner can normally be reached Monday - Friday, 9:00am - 5:30pm. 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, Jonathan Leong can be reached on 571-270-1292. 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. /T.S.C/Examiner, Art Unit 1751 /JONATHAN G LEONG/Supervisory Patent Examiner, Art Unit 1751 12/16/2025
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Prosecution Timeline

Mar 16, 2021
Application Filed
Nov 21, 2023
Non-Final Rejection — §103
Feb 14, 2024
Response Filed
May 03, 2024
Final Rejection — §103
Jul 23, 2024
Response after Non-Final Action
Jul 29, 2024
Examiner Interview (Telephonic)
Jul 29, 2024
Response after Non-Final Action
Aug 07, 2024
Request for Continued Examination
Aug 08, 2024
Response after Non-Final Action
Oct 03, 2024
Non-Final Rejection — §103
Dec 31, 2024
Response Filed
Mar 25, 2025
Final Rejection — §103
Jun 30, 2025
Request for Continued Examination
Jul 01, 2025
Response after Non-Final Action
Jul 09, 2025
Non-Final Rejection — §103
Oct 08, 2025
Response Filed
Dec 15, 2025
Final Rejection — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

7-8
Expected OA Rounds
46%
Grant Probability
54%
With Interview (+8.0%)
4y 0m
Median Time to Grant
High
PTA Risk
Based on 696 resolved cases by this examiner. Grant probability derived from career allow rate.

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