Prosecution Insights
Last updated: October 01, 2026
Application No. 17/596,814

RECHARGEABLE BATTERY

Final Rejection §103§DOUBLEPATENT
Filed
Dec 17, 2021
Priority
Apr 21, 2020 — RE 10-2020-0048221 +1 more
Examiner
DISNEY, CHRISTINE CONLON
Art Unit
1723
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Samsung SDI Co., Ltd.
OA Round
4 (Final)
22%
Grant Probability
At Risk
5-6
OA Rounds
0m
Est. Remaining
48%
With Interview

Examiner Intelligence

Grants only 22% of cases
22%
Career Allowance Rate
6 granted / 27 resolved
-42.8% vs TC avg
Strong +26% interview lift
Without
With
+25.8%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
19 currently pending
Career history
66
Total Applications
across all art units

Statute-Specific Performance

§103
66.0%
+26.0% vs TC avg
§102
15.4%
-24.6% vs TC avg
§112
9.8%
-30.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 27 resolved cases

Office Action

§103 §DOUBLEPATENT
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 . Response to Amendment This is a final office action in response to Applicant’s remarks and amendments filed on 01/28/2026. Claim 1 is currently amended. Claims 10-11 and 16-20 remain withdrawn. Claims 1-4, 8-9, and 12-15 are presented for examination. Applicant’s amendments to claim 1 have overcome the rejections set forth in the previous Office Action. The 35 U.S.C. § 102 and 103 rejections in the previous office action are withdrawn. New grounds of rejection necessitated by Applicant's amendments are presented below. Response to Arguments Applicant’s arguments with respect to claim 1 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. The new ground of rejection does not rely on Katsumoto or Eguchi teach the height terminal portion relative to the height of the cap plate. Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1-4, 8, and 12-15 are rejected under 35 U.S.C. 103 as being unpatentable over of Eguchi (US 2022/0311108 A1; priority to Japanese patent application JP2019-219432, filed 12/04/2019; previously cited) in view of Guo (US 2021/0408650 A1; cited in the IDS filed 07/10/2025). Regarding claim 1, Eguchi discloses a rechargeable battery (secondary battery 100, FIG. 5B, [0116]) comprising: an electrode assembly (10, FIGS. 1 and 5B, [0039]) including: a first electrode (positive electrode 1, FIG. 1, [0039]) and a second electrode (negative electrode 2, FIG. 1, [0039]) spaced from the first electrode (1); a case (52, FIG. 5B, [0071]) connected to the first electrode (1) (the metal exterior body serves as a positive electrode and therefore is connected to the positive, or first, electrode, [0076]) to receive the electrode assembly (10), and including an opening (opening in annotated figure 1 below) for exposing the electrode assembly (10); a cap plate (54, FIG. 5B, [0071]) combined to the case (52) to cover a peripheral region of the opening (opening), and including a through-hole (opening portion 55, FIG. 5B, [0099]) for exposing a center region of the opening (opening); a terminal plate (60, FIG. 3A, [0059]) to cover the center region of the opening (opening), and connected to the second electrode (2) (terminal plate includes a metal plate 62 that is connected to the negative electrode via tab 70, FIGS. 3A and 5B, [0059]-[0060]); and a sealing portion (insulating member 64, FIG. 5B, [0089]) disposed between the cap plate (54) and the terminal plate (60), and bonding between the cap plate (54) and the terminal plate (60) ([0089]), and wherein the terminal plate (60) includes a flange portion (62, FIG. 5B, [0092]) overlapping the cap plate (54), and wherein the cap plate (54) is in contact with the case (52), and the cap plate (54) and the case (52) have the same polarity as first electrode (1) (the metal exterior body includes both the case and the cap plate [0093] and serves as a positive electrode so the cap plate and the case are in electrical contact with each other, [0076]). PNG media_image1.png 303 554 media_image1.png Greyscale Annotated figure 1 (Eguchi FIG. 5) Eguchi does not disclose wherein the terminal plate is disposed between the cap plate and the electrode assembly, wherein the terminal plate comprises a terminal portion integrally formed with and protruding from the flange portion corresponding to the through-hole, an end of the terminal portion opposite the flange portion forming an outermost surface of the terminal plate, a height of the end of the terminal portion from the electrode assembly being lower than a height of a surface of the cap plate from the electrode assembly. However, in the embodiment of FIG. 7, Eguchi teaches a rechargeable battery comprising a terminal plate (60, FIG. 7, [0082]) disposed between a top surface of the metal exterior body (analogous to the cap plate of the FIG. 5B embodiment because it includes a through-hole as depicted in annotated figure 2 below) and the electrode assembly (not depicted in the FIG. 7 embodiment), wherein the terminal plate (60) comprises a terminal portion (67) integrally formed with (welded to, [0123]) and protruding from the flange portion (62) corresponding to the through-hole (through-hole), an end of the terminal portion (67) opposite the flange portion (62) forming an outermost surface of the terminal plate (60). It would have been obvious to a person having ordinary skill in the art before the effective filing date of the invention before the effective filing date of the claimed invention to have modified button cell of Eguchi FIG. 5B to substitute the terminal plate 60 from the FIG. 7 embodiment of Eguchi, such that the terminal plate comprises a terminal portion integrally formed with and protruding from the flange portion corresponding to the through-hole, an end of the terminal portion opposite the flange portion forming an outermost surface of the terminal plate, because Eguchi teaches that doing so improves the energy density of the battery and can contribute to an increase of the degree of freedom in designing the secondary battery ([0081]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments of the disclosure ([0155]) and it has been held that combining two embodiments disclosed adjacent to each other in prior art does not require a leap of inventiveness and involves only routine skill in the art. PNG media_image2.png 162 404 media_image2.png Greyscale Annotated figure 2 (Eguchi FIG. 7) Guo teaches a battery (100, FIGS. 1-4, [0038]) comprising an electrode assembly (10, FIG. 3, [0038]), a cap plate (21, FIG. 3, [0050]), and a terminal (40, FIG. 3, [0038]), wherein a height of the outermost surface of the terminal (40) from the electrode assembly (10) is lower than a height of a surface of the cap plate (21) from the electrode assembly (10) (FIG. 3). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have modified the battery of Eguchi by reducing the height of the terminal portion, such that a height of the outermost surface of the terminal portion from the electrode assembly is lower than a height of a surface of the cap plate from the electrode assembly, because Guo teaches that doing so improves the energy density of the battery by reducing a thickness of the case ([0022]) and reduces the risk of short circuit ([0044]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments depicted in the disclosure ([0155]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results [MPEP § 2143A]). Regarding claim 2, Eguchi in view of Guo teaches (see Eguchi) wherein the flange portion (62) has a greater area than the terminal portion (67) (the width of the flange portion is greater than the width of the terminal portion in FIG. 7). Regarding claim 3, Eguchi in view of Guo teaches (see Eguchi) wherein the flange portion (62) contacts the sealing portion (64), and the terminal portion (67) does not contact the sealing portion (64) (FIG. 7). Regarding claim 4, Eguchi in view of Guo teaches (see Eguchi) wherein the flange portion (62) is parallel to the cap plate (54) (FIG. 5B). Regarding claim 8, Eguchi in view of Guo teaches (see Eguchi) wherein a thickness of the terminal portion (67) is greater than a thickness of the flange portion (62) (FIG. 7). Regarding claim 12, Eguchi in view of Guo teaches (see Eguchi) wherein a first end (toward bottom of page in FIG. 5B) of the electrode assembly (10) faces the case (52), and a second end (toward top of page in FIG. 5B) of the electrode assembly (10) faces the flange portion (62). Regarding claim 13, Eguchi in view of Guo teaches (see Eguchi) wherein the electrode assembly (10) further includes: a separator (3, FIG. 1, [0039]) disposed between the first electrode (1) and the second electrode (2); and a second electrode tab (70, FIGS. 3A and 5B, [0059]-[0060]) for connecting between the second electrode (2) and the terminal plate (60), and contacting the flange portion (62). Eguchi in view of Guo does not disclose a first electrode tab for connecting between the first electrode and the case, and contacting the case. However, Guo further teaches a case (22, FIG. 3, [0062]) connected to a first electrode (12, FIG. 3, [0065]) and a first electrode tab (102, FIG. 3, [0062]) for connecting between the first electrode (12) and the case (22), and contacting the case (22). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have further modified the battery of Eguchi in view of Guo by adding a first electrode tab for connecting between the first electrode and the case, and contacting the case, because Guo teaches such a tab may electrically connect between the case and the first electrode ([0062]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments depicted in the disclosure ([0155]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results ([MPEP § 2143A]). Regarding claim 14, Eguchi in view of Guo does not disclose wherein the flange portion is disposed between the second electrode tab and the sealing portion in the embodiment of Eguchi FIGS. 3A and 5B. However, in modifying the Eguchi FIG. 5B embodiment such that the terminal plate has the configuration of the Eguchi FIG. 7 embodiment as discussed in claim 1, a person having ordinary skill in the art before the effective filing date of the invention would find it obvious to adopt the configuration of Eguchi FIGS. 3B and FIG. 7 in which the flange portion (62) is disposed between the second electrode tab (70) and the sealing portion (64) because Eguchi teaches that doing so improves the energy density of the battery and can contribute to an increase of the degree of freedom in designing the secondary battery ([0081]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments of the disclosure ([0155]) and it has been held that combining two embodiments disclosed adjacent to each other in prior art does not require a leap of inventiveness and involves only routine skill in the art. Regarding claim 15, Eguchi in view of Guo teaches (see Eguchi) wherein the sealing portion (64) insulates between the cap plate (54) and the terminal plate (60) ([0069]). Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Guo (US 2021/0408650 A1), as applied to claim 8 above, and further in view of Aress High Duty Forgings (5 Reasons Why Aluminium Forging is Better Than Aluminum Casting, 2018; cited 11/13/2024). Regarding claim 9, Eguchi teaches wherein the terminal plate (60) includes aluminum ([0067]), but Eguchi in view of Guo does not disclose wherein the terminal plate includes forged aluminum. Aress High Duty Forgings teaches forged aluminum. A person having ordinary skill in the art before the effective filing date of the claimed invention would have found it obvious to have used forged aluminum for the terminal plate of Eguchi with a reasonable expectation of improving its strength and reducing production costs as taught by Aress High Duty Forgings (p. 1-2). Double Patenting The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1-4, 8-9, and 12-15 are provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-4, 7-9 and 12-15 of copending Application No. 17/870,755 (reference application) in view of Katsumoto (US 2022/0384919 A1; previously cited). Regarding claim 1, claim 1 of the ‘755 application discloses a battery (button cell) comprising: an electrode assembly including a first electrode and a second electrode spaced from the first electrode; a case connected to the first electrode to receive the electrode assembly, and including an opening for exposing the electrode assembly; a cap plate combined to the case to cover a peripheral region of the opening, and including a through-hole for exposing a center region of the opening; a terminal plate disposed between the cap plate and the electrode assembly to cover the center region of the opening, and connected to the second electrode; and a sealing portion disposed between the cap plate and the terminal plate, and bonding between the cap plate and the terminal plate, wherein the terminal plate includes a flange portion overlapping the cap plate, and a terminal portion protruding from the flange portion corresponding to the through-hole, an end of the terminal portion opposite the flange portion forming an outermost surface of the terminal plate, a height of an end of the terminal portion from the electrode assembly being lower than a height of a surface of the cap plate from the electrode assembly, and wherein the cap plate is in contact with the case, and the cap plate and the case have the same polarity as the first electrode (cap plate is electrically connected to the case, case is connected to the first electrode). Claim 7 of the ‘755 application depends on claim 1 and discloses wherein the flange portion is integrally formed with the terminal portion. The ‘755 application does not disclose wherein the battery (button cell) is a rechargeable battery. However, Katsumoto teaches a button cell that is rechargeable (button-type secondary battery, [0032]). Therefore, a person having ordinary skill in the art before the effective filing date of the invention would find it obvious to form the button cell of the ‘755 application as a rechargeable battery. Regarding claim 2, claims 1 and 7 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 2 of the ‘755 application depends on claim 1 and teaches wherein the flange portion has a greater area than the terminal portion. Regarding claim 3, claims 1, 2, and 7 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 2. Claim 3 of the ‘755 application depends on claim 2 and teaches wherein the flange portion contacts the sealing portion, and the terminal portion does not contact the sealing portion. Regarding claim 4, claims 1, 2 and 7 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 2. Claim 4 of the ‘755 application depends on claim 2 and teaches wherein the flange portion is parallel to the cap plate. Regarding claim 8, claims 1 and 7 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 8 of the ‘755 application depends on claim 7 and teaches wherein a thickness of the terminal portion is greater than a thickness of the flange portion. Regarding claim 9, claims 1, and 7-8 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 8. Claim 9 of the ‘755 application depends on claim 8 and teaches wherein the terminal plate includes forged aluminum. Regarding claim 12, claims 1 and 7 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 12 of the ‘755 application depends on claim 1 and teaches wherein a first end of the electrode assembly faces the case, and a second end of the electrode assembly faces the flange portion. Regarding claim 13, claims 1, 7, and 12 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 12. Claim 13 of the ‘755 application depends on claim 12 and teaches wherein the electrode assembly further comprises: a separator between the first electrode and the second electrode; a first electrode tab for connecting between the first electrode and the case, and contacting the case; and a second electrode tab for connecting between the second electrode and the terminal plate, and contacting the flange portion. Regarding claim 14, claims 1, 7, and 12-13 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 13. Claim 14 of the ‘755 application depends on claim 13 and further teaches wherein the flange portion is disposed between the second electrode tab and the sealing portion. Regarding claim 15, claims 1 and 7 of the ‘755 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 15 of the ‘755 application depends on claim 1 and teaches wherein the sealing portion insulates between the cap plate and the terminal plate. This is a provisional nonstatutory double patenting rejection because the patentably indistinct claims have not in fact been patented. Claims 1-4, 8-9, and 12-15 are provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-2, 4-5, 8-9, 12-14, and 18 of copending Application No. 17/870,763 (reference application) in view of Katsumoto (US 2022/0384919 A1). Regarding claim 1, claim 1 of the ‘763 application discloses a battery (button cell) comprising: an electrode assembly including a first electrode and a second electrode spaced from the first electrode; a case connected to the first electrode to receive the electrode assembly, and including an opening for exposing the electrode assembly; a cap plate combined to the case to cover a peripheral region of the opening, and including a through-hole for exposing a center region of the opening; a terminal plate disposed between the cap plate and the electrode assembly to cover the center region of the opening, and connected to the second electrode; and a sealing portion disposed between the cap plate and the terminal plate, and bonding between the cap plate and the terminal plate, wherein the terminal plate includes a flange portion overlapping the cap plate, and a terminal portion integrally formed with and protruding from the flange portion corresponding to the through-hole, and wherein the cap plate is in contact with the case, and the cap plate and the case have the same polarity as the first electrode Claim 5 of the ‘763 application depends on claim 1 and discloses wherein a height of an end of the terminal portion from the electrode assembly is lower than a height of a surface of the cap plate from the electrode assembly (the end may be arbitrarily selected and therefore can correspond to the end opposite the flange portion forming an outermost surface of the terminal plate). The ‘763 application does not disclose wherein the battery (button cell) is a rechargeable battery. However, Katsumoto teaches a button cell that is rechargeable (button-type secondary battery, [0032]). Therefore, a person having ordinary skill in the art before the effective filing date of the invention would find it obvious to form the button cell of the ‘763 application as a rechargeable battery. Regarding claim 2, claims 1 and 5 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 2 of the ‘763 application depends on claim 1 and teaches wherein the flange portion has a greater area than the terminal portion. Regarding claim 3, claims 1, 2, and 5 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 2. Claim 3 of the ‘763 application depends on claim 2 and teaches wherein the flange portion contacts the sealing portion, and the terminal portion does not contact the sealing portion. Regarding claim 4, claims 1, 2, and 5 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 2. Claim 4 of the ‘763 application depends on claim 2 and teaches wherein the flange portion is parallel to the cap plate. Regarding claim 8, claims 1 and 5 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 8 of the ‘763 application depends on claim 7 and teaches wherein a thickness of the terminal portion is greater than a thickness of the flange portion. Regarding claim 9, claims 1, 5, and 8 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 8. Claim 9 of the ‘763 application depends on claim 8 and teaches wherein the terminal plate includes forged aluminum. Regarding claim 12, claims 1 and 5 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 12 of the ‘763 application depends on claim 1 and teaches wherein a first end of the electrode assembly faces the case, and a second end of the electrode assembly faces the flange portion. Regarding claim 13, claims 1, 5, and 12 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 12. Claim 1 of the ‘763 application further teaches wherein the electrode assembly further includes: a first electrode tab for connecting between the first electrode and the case, and contacting the case; and a second electrode tab for connecting between the second electrode and the terminal plate. Claim 13 of the ‘763 application depends on claim 12 and teaches wherein the electrode assembly further includes: a separator disposed between the first electrode and the second electrode. Claims 1, 5, and 12 of the ‘763 application do not teach wherein the second electrode tab contacts the flange portion. However, since the terminal plate comprises integrally formed components, the second electrode tab must electrically contact the flange portion if it contacts any part of the terminal plate. Regarding claim 14, claims 1, 5, and 12-13 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 13. Claim 14 of the ‘763 application depends on claim 13 and further teaches wherein the flange portion is disposed between the second electrode tab and the sealing portion. Regarding claim 15, claims 1 and 5 of the ‘763 application in view of Katsumoto teaches the rechargeable battery of claim 1. Claim 18 of the ‘763 application depends on claim 1 and teaches wherein the sealing portion insulates between the cap plate and the terminal plate. This is a provisional nonstatutory double patenting rejection because the patentably indistinct claims have not in fact been patented. 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 CHRISTINE C. DISNEY whose telephone number is (703)756-1076. The examiner can normally be reached M-F 8:30-5:30 MT. 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, Tiffany Legette-Thompson can be reached at (571) 270-7078. 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. /C.C.D./Examiner, Art Unit 1723 /TIFFANY LEGETTE/Supervisory Patent Examiner, Art Unit 1723
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Prosecution Timeline

Show 5 earlier events
Jun 04, 2025
Applicant Interview (Telephonic)
Jun 05, 2025
Response after Non-Final Action
Jun 06, 2025
Examiner Interview Summary
Jul 08, 2025
Request for Continued Examination
Jul 10, 2025
Response after Non-Final Action
Nov 05, 2025
Non-Final Rejection mailed — §103, §DOUBLEPATENT
Jan 28, 2026
Response Filed
Sep 16, 2026
Final Rejection mailed — §103, §DOUBLEPATENT (current)

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Prosecution Projections

5-6
Expected OA Rounds
22%
Grant Probability
48%
With Interview (+25.8%)
4y 0m (~0m remaining)
Median Time to Grant
High
PTA Risk
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