Prosecution Insights
Last updated: July 17, 2026
Application No. 17/590,831

BATTERY MODULE HOUSING AND ARRANGEMENT OF BATTERY MODULES

Final Rejection §103
Filed
Feb 02, 2022
Priority
Feb 02, 2021 — DE 10 2021 102 360
Examiner
ALBAN, FELICITY BERNARD
Art Unit
1728
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Lisa Dräxlmaier GmbH
OA Round
4 (Final)
61%
Grant Probability
Moderate
5-6
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 61% of resolved cases
61%
Career Allowance Rate
17 granted / 28 resolved
-4.3% vs TC avg
Strong +46% interview lift
Without
With
+45.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
20 currently pending
Career history
77
Total Applications
across all art units

Statute-Specific Performance

§103
92.8%
+52.8% vs TC avg
§102
3.3%
-36.7% vs TC avg
§112
2.0%
-38.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 28 resolved cases

Office Action

§103
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 05/09/2025 has been entered. Claim Status Claims 1, 11, and 15 have been amended. Claims 1-17 have been examined on the merits. Response to Arguments Applicant's arguments filed 05/09/2025 have been fully considered but they are not persuasive. Applicant argues that the instant application has specific differences from the cited references as follows: Claims 1, 2 and 5-8 are not obvious over Esrom in view of Khalighi (pg. 7-12). Applicant argues that Wang 2 does not teach that a manifold area must be at least as large as the sum of the port areas (pg. 13 and 23) nor does Wang identify 2 as a critical threshold or design parameter (pg. 14, 21, 24). Applicant argues that the flow distributor elements taught by Kind are not equivalent to inner housing walls and further does not teach a second manifold region with outlet functionality (pg. 16). Applicant argues that none of Esrom, Khalighi, or Sun, either alone or in combination, teaches or suggests the modular structure of claims 11-12. Applicant argues that the rejection of claims 13-14 over a five-reference combination is unsupported and improper (pg. 20-22). Applicant argues that the motivation to combine Esrom and Wang is conclusory and claim 15 would not be considered obvious in view of the two references. Regarding argument a, applicant’s arguments with respect to claim(s) 1, 2 and 5-8 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. Regarding argument b, Wang 2 teaches the theory of flow distribution and pressure drop and their importance in controlling flow in manifolds. Wang 2 teaches that uniform flow distribution can be found only when the ratio (M) of the sum of all the ports areas to the area of the manifold is smaller (Section 6.3, page 1339). At the extreme condition (i.e., M= 0), there is no the effect of the flow branching (Section 6.3, Page 1339). The equation for M is given as 𝑀 = 𝐹𝑐 𝑛/𝐹 where F and Fc are the cross-sectional areas of the manifold and the port, respectively (Section 6.3, Page 1339). Utilizing a large manifold size in relation to the size of the holes in the inner wall would allow for even and consistent fluid flow that can then be controlled by the hole sizing. The uniformity of the flow distribution in a manifold system often determines efficiency, durability and cost of the units (Section 1, page 1331). While it is conceded that Wang 2 does not teach system specific constraints of battery cooling applications, it is the examiner’s position that one of ordinary skill in the art would be familiar with relevant theory of manifold design and would look to Wang 2 when designing a cooling fluid manifold system. Fluid flow through manifolds follows principles which are applicable in a variety of industries and fields. It is not necessary to look only at battery specific manifolds when designing a cooling manifold system for a battery, rather one of ordinary skill would look to manifold specific art to design an optimally performing fluid manifold. Wang discloses a theoretical model to provide design guidance to investigate the interactions among structures, operating conditions and manufacturing tolerances under a wide variety of combination of flow conditions and geometries (abstract). As Wang teaches a generalized theory providing understanding of flow in manifold systems and offers a tool for designs of manifold systems (pg. 1342), it would be reasonable for one of ordinary skill in the art to utilize the teachings of Wang in the design of a cooling fluid manifold system. Regarding argument c, there is no structural difference between the claimed inner housing wall and the flow distributor element taught by Kind which spatially separates a housing outer wall and housing inner space (see Fig. 2 below). The space between the housing outer wall and the housing inner wall is equivalent to a manifold. Further, the current rejection of claim 9 relies on newly cited Wang 1 to teach a further manifold. PNG media_image1.png 554 529 media_image1.png Greyscale Regarding argument d, applicant’s arguments with respect to claim(s) 11-12 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. In regards to argument e, Esrom, Khalighi, and Shimoike are no longer relied upon. A discussion of Wang 2 is provided above. Further, in response to applicant's argument that the examiner has combined an excessive number of references, reliance on a large number of references in a rejection does not, without more, weigh against the obviousness of the claimed invention. See In re Gorman, 933 F.2d 982, 18 USPQ2d 1885 (Fed. Cir. 1991). Regarding argument f, Esrom is no longer relied upon. Discussion of Wang is provided above. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 1-2, 5-8 are rejected under 35 U.S.C. 103 as being unpatentable over Wang et al. (US 20160315366 A1) hereinafter “Wang 1”. Regarding claim 1, Wang 1 teaches a battery module housing comprising: a housing interior configured to receive at least one battery module element ([0025]), a housing inner wall arranged to spatially separate housing inner space from a housing outer wall of the battery module housing, and a cooling fluid manifold bounded between the housing inner wall and the housing outer wall (abstract; [0025]; [0027]; Fig. 4; Fig. 5), wherein the housing inner wall comprises at least one opening configured to facilitate flow of a cooling fluid from the cooling fluid manifold into the housing inner space and around the at least one battery module element ([0027]-[0028]). Wang 1 teaches that flow uniformity is desired and non-uniform flow should be prevented ([0028]; [0032]-[0033]), and the use of a plate assists with achieving a more uniform flow ([0033]). Wang 1 teaches wherein a plate (inner wall) may be spaced apart from a battery array to create an air pocket between the first longitudinal side and the plate ([0027]; Fig. 5). Wang 1 does not explicitly teach wherein the flow is passively inhibited by the at least one battery module element so as to enable a uniform flow distribution of the cooling fluid around the housing interior. However, Wang 1 teaches wherein a plate (inner wall) may be spaced apart from a battery array to create an air pocket between a first longitudinal side and the plate ([0027]; Fig. 5) and teaches wherein air flow uniformity is desired ([0028]; [0032]-[0033]). Fig. 5 of Wang 1 illustrates a fluid flow path around battery cells (Fig. 5 annotated below). Once the air flows into the air pocket it is passively inhibited by the battery cells, because the battery cells are stationary and thus passively inhibit flow through the system. Therefore, the structure taught by Wang 1 meets the limitations of claim 1. PNG media_image2.png 313 597 media_image2.png Greyscale Regarding claim 2, Wang 1 teaches wherein the housing inner wall further comprises a plurality of openings distributed and disposed in the housing inner wall ([0028]-[0029]). Regarding claim 5, Wang 1 teaches wherein the at least one opening is arranged in the housing inner wall such that when the cooling fluid flows into the housing inner space, the cooling fluid flows around the battery module element (Fig. 5 annotated above; [0032]; abstract). Regarding claim 6, Wang 1 teaches wherein: a plurality of battery module elements is arranged in the housing interior (Fig. 2; [0022]-[0024]) and an opening is associated with at least one of the battery module elements (Fig. 5 annotated below; [0028]). PNG media_image3.png 353 631 media_image3.png Greyscale Regarding claim 7, Wang 1 teaches wherein the opening is arranged in front of a battery module element that is closest to the opening (Fig. 5 annotated above, each opening is in front of a battery module element; [0028]). Regarding claim 8, Wang 1 teaches wherein the cooling fluid manifold comprises a cooling fluid inlet configured to facilitate flow of the cooling fluid into the cooling fluid manifold ([0025]-[0026]). Claim(s) 3 is rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Wang (Chemical Engineering Journal, Volume 168, Issue 3, Pages 1331-1345 "Theory of flow distribution in manifolds") hereinafter “Wang 2”. Regarding claim 3, Wang 1 teaches the battery module housing according to claim 2. Wang 1 does not teach wherein a cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings. However, Wang 2 teaches the theory of flow distribution and pressure drop and their importance in controlling flow in manifolds. Wang 2 teaches that uniform flow distribution can be found only when the ratio (M) of the sum of all the ports areas to the area of the manifold is smaller (Section 6.3, page 1339). At the extreme condition (i.e., M= 0), there is no the effect of the flow branching (Section 6.3, Page 1339). The equation for M is given as 𝑀 = 𝐹𝑐 𝑛/𝐹 where F and Fc are the cross-sectional areas of the manifold and the port, respectively (Section 6.3, Page 1339). Utilizing a large manifold size in relation to the size of the holes in the inner wall would allow for even and consistent fluid flow that can then be controlled by the hole sizing. The claimed limitation of “cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings” would result in a M value equal to or less than 1, which limits the effects of flow branching and aids in maintaining a uniform fluid flow (Section 6.3, Page 1339). The uniformity of the flow distribution in a manifold system often determines efficiency, durability and cost of the units (Section 1, page 1331). It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified the battery module housing taught by Wang 1 such that a cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings as taught by Wang 2. One of ordinary skill in the art would have been motivated to modify the battery module housing taught by Wang 1 such that a cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings as taught by Wang 2 to increase the uniformity of fluid distribution (Section 6.3, page 1339; Section 1, page 1331). Claim(s) 4 is rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Wang 2 (Chemical Engineering Journal, Volume 168, Issue 3, Pages 1331-1345 "Theory of flow distribution in manifolds") in further view of Huazhao et al. (US 20110017438 A1) hereinafter “Huazhao” Regarding claim 4, modified Wang 1 teaches the battery module housing according to claim 3. Modified Wang 1 does not teach wherein the cross-sectional area of the cooling fluid manifold is greater by √2 than the sum of all cross- sectional areas of the plurality of openings. However, Wang 2 teaches the theory of flow distribution and pressure drop and their importance in controlling flow in manifolds. Wang 2 teaches that uniform flow distribution can be found only when the ratio (M) of the sum of all the ports areas to the area of the manifold is smaller (Section 6.3, page 1339). At the extreme condition (i.e., M= 0), there is no the effect of the flow branching (Section 6.3, Page 1339). The equation for M is given as 𝑀 = 𝐹𝑐 𝑛/𝐹 where F and Fc are the cross-sectional areas of the manifold and the port, respectively (Section 6.3, Page 1339). Utilizing a large manifold size in relation to the size of the holes in the inner wall would allow for even and consistent fluid flow that can then be controlled by the hole sizing. The claimed difference in cross-sectional area of √2 would result in a M value always less than 1, which limits the effects flow branching and aids in maintaining a uniform fluid flow (Section 6.3, Page 1339). Further, Huazhao teaches a multi-channel heat exchanger in which distribution of refrigerant can be improved by balancing the ratio of the total area of the openings in a distributor tube to the cross-sectional area of the distributor tube with a given distributor tube length ([0030]-[0032]). Specifically, controlling a ratio between total opening area and distributor tube cross-sectional area allows control over uniformity of fluid flow ([0032]). Huazhao discloses that there is an art recognized relationship between the cross-sectional area of the manifold and port which affects the overall uniformity of fluid flow. Therefore, the cross-sectional area of both the manifold and openings are considered result effective variables, wherein the selection of the particular values thereof would be considered a matter of routine optimization to one of ordinary skill in the art and as such the relative difference in area between the manifold and openings would likewise be a matter of routine optimization (see MPEP §2144.05 II). One of ordinary skill in the art would have been motivated to optimize the cross-sectional area of the manifold and the cross-sectional area of the fluid exits taught by modified Wang 1, in order to minimize the effects of cooling fluid flow branching while maintaining a compact design. Claims 9 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Kind (DE102011015337 A1). Reference is made to previously enclosed machine translation. Regarding claim 9, Wang 1 teaches the battery module housing according to claim 1. Wang 1 teaches that a plate with holes (inner wall) can be arranged within the outlet manifold or the inlet manifold ([0033]). Wang 1 teaches that a plate increases air flow consistency across a battery array ([0033]). Wang 1 teaches a further cooling fluid manifold ([0026]; Fig. 5). Wang 1 does not teach where the battery module housing further comprises: a further housing inner wall, arranged to spatially separate the housing inner space from the housing outer wall, and a further cooling fluid manifold arranged between the further housing inner wall and the outer wall, and wherein the further housing inner wall comprises at least one further opening configured and arranged to enable the cooling fluid to flow out of the housing inner region. However, Kind teaches where a battery module housing further comprises a still further housing inner wall, and between the further housing inner wall and a further housing outer wall, and wherein the further housing inner wall comprises at least one further opening configured and arranged to enable the cooling fluid to flow out of the housing inner region ([0015] “one flow distributor element is arranged in front of the battery module group and one flow distributor element is arranged behind the battery module group”, distributer element is considered an inner wall). Kind teaches that two inner walls with holes results in a reduction in turbulent flow ([0015]). It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to have modified the battery module housing of Wang 1 by adding a further plate (inner wall) as taught by Kind. One of ordinary skill in the art would have been motivated to modify the battery module housing of Wang 1 by adding a further plate (inner wall) as taught by Kind to further reduce turbulent cooling fluid flow ([0015]). Regarding claim 10, Wang 1 teaches where the further cooling fluid manifold further comprises a cooling fluid drain configured to enable the cooling fluid to flow out of the further cooling fluid manifold ([0026]). Claim(s) 11-12, 14 are rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Tanjo et al. (JPH11329517A) hereinafter “Tanjo”, reference is made to the enclosed machine translation, in further view of Sun (US Pat. No. 9093727 B2) hereinafter "Sun". Regarding claim 11, Wang 1 teaches a battery module, comprising: a first battery module housing comprising: a housing inner space configured to accommodate at least one battery module element therein ([0025]), a housing inner wall arranged to spatially separate the housing inner space from a housing outer wall of the battery module housing ([0027]), a first cooling fluid manifold arranged between the housing inner wall and the housing outer wall, a cooling fluid distributor arranged between the housing inner wall and the housing outer wall ([0027]; Fig. 4; Fig. 5), and wherein the housing inner wall comprises at least one opening configured and arranged to enable a cooling fluid to flow from the cooling fluid distributor into the housing inner space ([0028]-[0029]; Fig. 4). Wang 1 does not teach a second battery module housing spatially distinct form the first battery module housing, comprising a second fluid manifold; and wherein a cooling fluid manifold of the first battery module housing is fluidly connected via conduit to a second cooling fluid manifold. However, Tanjo teaches a battery pack configured by connecting a plurality of modules, for example two modules, each housed in a separate module case, with 24 cells each ([0023]; Fig. 1; [0009]). Tanjo teaches wherein a cooling duct provides air to both modules, thereby providing cooling for cells in each respective module ([0010]; Fig. 1). PNG media_image4.png 469 581 media_image4.png Greyscale Battery modules comprising a cooling fluid manifold arranged between the housing inner wall and the housing outer wall and wherein the housing inner wall comprises at least one opening configured and arranged to enable a cooling fluid to flow from the cooling fluid distributor into the housing inner space are known in the art (Wang 1 [0028]-[0029]; Fig. 4; Fig. 5). Cooling multiple battery module units via a cooling fluid manifold that is fluidly connected between battery modules is known in the art (Tanjo Fig. 1; [0009]-[0010]; [0023]). Therefore, it would have been obvious to one of ordinary skill in the art to have modified the battery module taught by Wang 1 by including a second battery module housing (for example duplicating the disclosed battery module housing of Wang 1) spatially distinct form the first battery module housing wherein a cooling fluid manifold of the first battery module housing is fluidly connected via conduit to a second cooling fluid manifold as taught by Tanjo. One of ordinary skill in the art could have modified the battery module taught by Wang 1 by including a second battery module housing (for example duplicating the disclosed battery module housing of Wang 1) spatially distinct form the first battery module housing wherein a cooling fluid manifold of the first battery module housing is fluidly connected via conduit to a second cooling fluid manifold as taught by Tanjo to achieve the predictable result of cooling multiple connected battery modules. Cooling of multiple connected battery modules via a fluidly connected manifold is known in the prior art. Further, one of ordinary skill in the art would recognize that increasing modules increases total battery pack capacity. Wang 1 in view of Tanjo does not teach wherein a cross-section of the cooling fluid manifold of the first battery module housing is larger than a cross-section of the cooling fluid manifold of the second battery module housing. However, Sun teaches a cooling system for a battery assembly containing a plurality of battery units where each battery unit contains a first and second battery cell (column 1, lines 53-54; column 3, line 5). Sun teaches a second battery module housing comprising fluid manifold (Fig. 1, annotated below; element 22); and wherein the cooling fluid manifold of the first battery module housing is connected to the cooling fluid manifold of the second battery module housing (column 3, lines 52-55; element 22 is considered to be a second battery module housing comprising a fluid manifold); and wherein a cross-section of the cooling fluid manifold of the first battery module housing is larger than a cross-section of the cooling fluid manifold of the second battery module housing (column 3, lines 37-42; column 3, lines 60-63; Fig. 1 annotated below; element 20 considered to be a manifold). Sun teaches that the use of a variable cross-sectional area of cooling fluid manifolds is advantageous to minimize the variations in pressure between cooling fluid channels formed between battery units, thereby maintain uniform cooling (column 5, lines 51-60). PNG media_image5.png 292 624 media_image5.png Greyscale It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to modify the battery module taught by Wang 1 in view of Tanjo by using variable cross-sectional areas for the cooling fluid manifolds as taught by Sun and described above. One of ordinary skill in the art would have been motivated to modify the battery module taught by Wang in view of Tanjo by using variable cross-sectional areas for the cooling fluid manifolds as taught by Sun to maintain appropriate fluid flow and minimize the variations in pressure between cooling fluid channels formed between battery units, thereby maintaining uniform cooling (column 1, lines 13-16; column 5, lines 51-60). Regarding claim 12, Wang 1 further teaches wherein the cooling fluid manifold of the first battery module housing further comprises a cooling fluid inlet configured and arranged to enable the cooling fluid to flow into the cooling fluid manifold of the first battery module housing ([0025]-[0026]). Regarding claim 14, Wang 1 further teaches wherein the flow is inhibited by the at least one battery module element so as to enable a uniform flow of the cooling fluid around the housing interior (Fig. 5, once the air flows into the air pocket it is subsequently inhibited by the battery cells). Claim(s) 13 is rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Tanjo (JPH11329517A) in further view of Sun (US Pat. No. 9093727 B2) in further view of Wang 2 (Chemical Engineering Journal, Volume 168, Issue 3, Pages 1331-1345 "Theory of flow distribution in manifolds") and Huazhao (US 20110017438 A1). Regarding claim 13, Wang 1 in view of Tanjo and Sun teaches the battery module of claim 11. Wang 1 in view of Tanjo and Sun does not teach wherein the cross-sectional area of the cooling fluid manifold is greater by √2 than the sum of all cross-sectional areas of the plurality of openings. However, Wang 2 teaches the theory of flow distribution and pressure drop and their importance in controlling flow in manifolds. Wang 2 teaches that uniform flow distribution can be found only when the ratio (M) of the sum of all the ports areas to the area of the manifold is smaller (Section 6.3, page 1339). At the extreme condition (i.e., M= 0), there is no the effect of the flow branching (Section 6.3, Page 1339). The equation for M is given as 𝑀 = 𝐹𝑐 𝑛/𝐹 where F and Fc are the cross-sectional areas of the manifold and the port, respectively (Section 6.3, Page 1339). Utilizing a large manifold size in relation to the size of the holes in the inner wall would allow for even and consistent fluid flow that can then be controlled by the hole sizing. The claimed difference in cross-sectional area of √2 would result in a M value always less than 1, which limits the effects flow branching and aids in maintaining a uniform fluid flow (Section 6.3, Page 1339). Further, Huazhao teaches a multi-channel heat exchanger in which distribution of refrigerant can be improved by balancing the ratio of the total area of the openings in a distributor tube to the cross-sectional area of the distributor tube with a given distributor tube length ([0030]-[0032]). Specifically, controlling a ratio between total opening area and distributor tube cross-sectional area allows control over uniformity of fluid flow ([0032]). Huazhao discloses that there is an art recognized relationship between the cross-sectional area of the manifold and port which affects the overall uniformity of fluid flow. Therefore, the cross-sectional area of both the manifold and openings are considered result effective variables, wherein the selection of the particular values thereof would be considered a matter of routine optimization to one of ordinary skill in the art and as such the relative difference in area between the manifold and openings would likewise be a matter of routine optimization (see MPEP §2144.05 II). One of ordinary skill in the art would have been motivated to optimize the cross-sectional area of the manifold and the cross-sectional area of the fluid exits taught by Wang 1 in view of Tanjo and Sun, in order to minimize the effects of cooling fluid flow branching while maintaining a compact design. Claim(s) 15, 17 are rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Wang 2 (Chemical Engineering Journal, Volume 168, Issue 3, Pages 1331-1345 "Theory of flow distribution in manifolds"). Regarding claim 15, Wang 1 teaches a battery module housing comprising: a housing interior configured to receive at least one battery module element ([0025]), a housing inner wall arranged to spatially separate housing inner space from a housing outer wall of the battery module housing ([0027]), and a cooling fluid manifold arranged between the housing inner wall and the housing outer wall ([0027]; Fig. 4; Fig. 5), wherein the housing inner wall comprises at least one opening configured to facilitate flow of a cooling fluid from the cooling fluid manifold into the housing inner space, wherein the housing inner wall further comprises a plurality of openings distributed and disposed in the housing inner wall ([0028]-[0029]; Fig. 4). Wang 1 does not teach wherein a cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings such that the cooling fluid is distributed uniformly into the housing interior through passive flow impedance caused by the battery module elements. However, Wang 2 teaches the theory of flow distribution and pressure drop and their importance in controlling flow in manifolds. Wang 2 teaches that uniform flow distribution can be found only when the ratio (M) of the sum of all the ports areas to the area of the manifold is smaller (Section 6.3, page 1339). At the extreme condition (i.e., M= 0), there is no the effect of the flow branching (Section 6.3, Page 1339). The equation for M is given as 𝑀 = 𝐹𝑐 𝑛/𝐹 where F and Fc are the cross-sectional areas of the manifold and the port, respectively (Section 6.3, Page 1339). Utilizing a large manifold size in relation to the size of the holes in the inner wall would allow for even and consistent fluid flow that can then be controlled by the hole sizing. The claimed limitation of “cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings” would result in a M value equal to or less than 1, which limits the effects of flow branching and aids in maintaining a uniform fluid flow (Section 6.3, Page 1339). The uniformity of the flow distribution in a manifold system often determines efficiency, durability and cost of the units (Section 1, page 1331). It would have been obvious to one of ordinary skill in the art, prior to the effective filing date of the claimed invention, to have modified the battery module housing taught by Wang 1 such that a cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings as taught by Wang 2. One of ordinary skill in the art would have been motivated to modify the battery module housing taught by Wang 1 such that a cross-section of the cooling fluid manifold is at least as large as a sum of all cross-sections of the plurality of openings as taught by Wang 2 to increase the uniformity of fluid distribution (Section 6.3, page 1339; Section 1, page 1331). Modified Wang 1 does not explicitly teach that the cooling fluid is distributed uniformly into the housing interior through passive flow impedance caused by the battery module elements. However, Wang 1 teaches wherein a plate (inner wall) may be spaced apart from a battery array to create an air pocket between a first longitudinal side and the plate ([0027]; Fig. 5) and teaches wherein air flow uniformity is desired ([0028]; [0032]-[0033]). Fig. 5 of Wang 1 illustrates a fluid flow path around battery cells (Fig. 5 annotated below). Once the air flows into the air pocket it is subsequently passively inhibited by the battery cells. Therefore, the structure taught by modified Wang 1 meets the limitations of claim 1. PNG media_image3.png 353 631 media_image3.png Greyscale Regarding claim 17, Wang 1 in view of Wang 2 does not explicitly teach wherein the flow is inhibited by the at least one battery module element so as to enable a uniform flow of the cooling fluid around the housing interior. However, Wang 1 teaches wherein a plate (inner wall) may be spaced apart from a battery array to create an air pocket between a first longitudinal side and the plate ([0027]; Fig. 5) and teaches wherein air flow uniformity is desired ([0028]; [0032]-[0033]). Fig. 5 of Wang 1 illustrates a fluid flow path around battery cells (Fig. 5 annotated below). Once the air flows into the air pocket it is subsequently inhibited by the battery cells. Therefore, the structure taught by Wang 1 in view of Wang 2 meets the limitations of claim 1. PNG media_image3.png 353 631 media_image3.png Greyscale Claim(s) 16 is rejected under 35 U.S.C. 103 as being unpatentable over Wang 1 (US 20160315366 A1) in view of Wang 2 (Chemical Engineering Journal, Volume 168, Issue 3, Pages 1331-1345 "Theory of flow distribution in manifolds") in further view of Huazhao (US 20110017438 A1). Regarding claim 16, Wang 1 in view of Wang 2 does not teach wherein the cross-sectional area of the cooling fluid manifold is greater by √2 than the sum of all cross-sectional areas of the plurality of openings. However, Wang 2 teaches the theory of flow distribution and pressure drop and their importance in controlling flow in manifolds. Wang 2 teaches that uniform flow distribution can be found only when the ratio (M) of the sum of all the ports areas to the area of the manifold is smaller (Section 6.3, page 1339). At the extreme condition (i.e., M= 0), there is no the effect of the flow branching (Section 6.3, Page 1339). The equation for M is given as 𝑀 = 𝐹𝑐 𝑛/𝐹 where F and Fc are the cross-sectional areas of the manifold and the port, respectively (Section 6.3, Page 1339). Utilizing a large manifold size in relation to the size of the holes in the inner wall would allow for even and consistent fluid flow that can then be controlled by the hole sizing. The claimed difference in cross-sectional area of √2 would result in a M value always less than 1, which limits the effects flow branching and aids in maintaining a uniform fluid flow (Section 6.3, Page 1339). Further, Huazhao teaches a multi-channel heat exchanger in which distribution of refrigerant can be improved by balancing the ratio of the total area of the openings in a distributor tube to the cross-sectional area of the distributor tube with a given distributor tube length ([0030]-[0032]). Specifically, controlling a ratio between total opening area and distributor tube cross-sectional area allows control over uniformity of fluid flow ([0032]). Huazhao discloses that there is an art recognized relationship between the cross-sectional area of the manifold and port which affects the overall uniformity of fluid flow. Therefore, the cross-sectional area of both the manifold and openings are considered result effective variables, wherein the selection of the particular values thereof would be considered a matter of routine optimization to one of ordinary skill in the art and as such the relative difference in area between the manifold and openings would likewise be a matter of routine optimization (see MPEP §2144.05 II). One of ordinary skill in the art would have been motivated to optimize the cross-sectional area of the manifold and the cross-sectional area of the fluid exits taught by modified Wang 1, in order to minimize the effects of cooling fluid flow branching while maintaining a compact design. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Oda et al. (US 20020051340 A1) teaches a battery module housing comprising: a housing interior configured to receive at least one battery module element, a housing inner wall arranged to spatially separate housing inner space from a housing outer wall of the battery module housing, and a cooling fluid manifold bounded between the housing inner wall and the housing outer wall (Fig. 3, [0013]; p0039]) wherein the housing inner wall comprises at least one opening configured to facilitate flow of a cooling fluid from the cooling fluid manifold into the housing inner space and around the at least one battery module element (Fig. 3; [0039]), and wherein the flow is passively inhibited by the at least one battery module element so as to enable a uniform flow distribution of the cooling fluid around the housing interior ([0051]). Any inquiry concerning this communication or earlier communications from the examiner should be directed to FELICITY B. ALBAN whose telephone number is (703)756-5398. The examiner can normally be reached Monday-Friday 7:30-5:00. 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, Matthew Martin can be reached at 571-270-7871. 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. /F.B.A./Examiner, Art Unit 1728 /MATTHEW T MARTIN/Supervisory Patent Examiner, Art Unit 1728
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Prosecution Timeline

Show 1 earlier event
Sep 06, 2024
Non-Final Rejection mailed — §103
Dec 05, 2024
Response Filed
Feb 10, 2025
Final Rejection mailed — §103
May 09, 2025
Request for Continued Examination
May 14, 2025
Response after Non-Final Action
Oct 17, 2025
Non-Final Rejection mailed — §103
Jan 29, 2026
Response Filed
Jul 14, 2026
Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12626911
CATHODE MIXTURE
3y 11m to grant Granted May 12, 2026
Patent 12603353
Battery Pack Case, and Battery Pack Including the Same
4y 3m to grant Granted Apr 14, 2026
Patent 12573632
Anode Mixture for Secondary Battery, Anode and Secondary Battery Including the Same
3y 10m to grant Granted Mar 10, 2026
Patent 12562385
POSITIVE ELECTRODE ACTIVE MATERIAL AND MAGNESIUM SECONDARY BATTERY
3y 10m to grant Granted Feb 24, 2026
Patent 12558975
Structural Battery Comprising Cooling Channels
3y 7m to grant Granted Feb 24, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
61%
Grant Probability
99%
With Interview (+45.6%)
3y 5m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 28 resolved cases by this examiner. Grant probability derived from career allowance rate.

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