Prosecution Insights
Last updated: April 19, 2026
Application No. 17/619,126

Pouch-Shaped Secondary Battery Including Pressure Sensing Device Configured to Measure Internal Pressure

Non-Final OA §103
Filed
Dec 14, 2021
Examiner
HARRIS, MARY GRACE
Art Unit
1729
Tech Center
1700 — Chemical & Materials Engineering
Assignee
LG Energy Solution, Ltd.
OA Round
5 (Non-Final)
70%
Grant Probability
Favorable
5-6
OA Rounds
3y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
130 granted / 187 resolved
+4.5% vs TC avg
Strong +33% interview lift
Without
With
+32.6%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
43 currently pending
Career history
230
Total Applications
across all art units

Statute-Specific Performance

§103
59.3%
+19.3% vs TC avg
§102
19.1%
-20.9% vs TC avg
§112
18.3%
-21.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 187 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 09/17/2025 has been entered. Response to Amendment Support for the amendments to claim 1 and newly added claim 16 can be found in P63 and previously presented claim 1. The amendments to the claims have been entered. Response to Arguments Applicant’s arguments with respect to the claims have been considered but are moot due to the amendment to the claims. Claim Rejections - 35 USC § 103 Claims 1, 3, 8, and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Watanabe et al (US 20120328934 A1) in view of Elian (US 20140342203 A1) in view of Yang et al (US 20100239895 A1). Regarding claim 1, Watanabe discloses a pouch-shaped secondary battery (laminate-packaged electric storage device 10 in Fig. 1; see entire disclosure and especially P51) comprising: a case having a receiving portion configured to receive an electrode assembly, the receiving portion defining a first volume (receiving section 23 in Figs. 1 and 8; see entire disclosure and especially P51); a gas pocket within the case configured to receive gas from the receiving portion, the gas pocket defining a second volume separate from the first volume (functional section 24a in Fig. 8; see entire disclosure and especially P83, 88, 94), the gas pocket being connected to the receiving portion by a neck portion defining a third volume, the third volume being less than the first and second volumes (link section 24b that links the functional section 24a and the receiving section 23 in Fig. 8; see entire disclosure and especially P90, 94), and the neck portion including an expanding conduit defining the third volume (“When gas has been generated inside the receiving section 23 of the outer package 20 that holds the electric storage device element 11, the gas enters the non-bonding section 24 formed in the outer edge area of the outer package 20, and the receiving section 23 and the non-bonding section 24 are sufficiently expanded corresponding to the amount of the gas”, P88). However, Watanabe does not disclose a pressure sensing device extending continuously through the case from an outside of the case to an inside of the case such that at least a portion of the pressure sensing device is in direct contact with the gas in the gas pocket, wherein the pressure sensing device is configured to directly measure gas pressure of the gas in the gas pocket within the case, wherein the pressure sensing device comprises: a measurement portion located in the case, the measurement portion being configured to measure pressure; a connection terminal located outside the case, the connection terminal being configured to connect the measurement portion to an external instrument; and a through-opening located between the measurement portion and the connection terminal, the through-opening being hermetically sealed together with the case, further including a one-way valve in the neck portion configured to allow gas to move from the receiving portion to the gas pocket, wherein at least a portion of the through-opening comprises a coupling portion without an insulation film, an outer surface of the coupling portion is made of copper. In a similar field of endeavor, Elian teaches a battery comprising a hermetically sealed enclosure (400 in Fig. 4, P7, 45). Elian teaches an apparatus for measuring pressure (100 in Fig. 1, 420 in Fig. 4, 45). Elian teaches the apparatus includes a semiconductor die (110 in Fig. 1) having a micro-mechanical element (112 in Fig. 1) and a circuit board (120 in Fig. 1, P20). Elian teaches the micro-mechanical element measures pressure through gas pressure accessing the micro-mechanical element (P25). Elian teaches the circuit board of the apparatus can extend through the enclosure so that a measurement signal can be provided to the outside (P51). Elian teaches by measuring an increase of the pressure inside the enclosure erroneous behavior can be detected very easily and counter measures can be started very early to avoid a destruction of the battery and improve safety (P46). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Elian and provided to Watanabe a pressure sensing device extending continuously through the case from an outside of the case to an inside of the case, such as the apparatus taught by Elian, and provided wherein at least a portion of the pressure sensing device is in direct contact with the gas in the gas pocket, wherein the pressure sensing device is configured to directly measure gas pressure of the gas in the gas pocket the case, given that Elian teaches this can detect an increase of pressure inside the case of Watanabe so that counter measures can be started very early to avoid a destruction of the battery and improve safety. Modified Watanabe meets the limitation wherein the pressure sensing device comprises: a measurement portion located in the case, the measurement portion being configured to measure pressure (micro-mechanical element of Elian); a connection terminal located outside the case, the connection terminal being configured to connect the measurement portion to an external instrument (circuit board of Elian); and a through-opening located between the measurement portion and the connection terminal, the through-opening being hermetically sealed together with the case (the through-opening being drawn to the circuit board of the apparatus of Elian that leads through the case and would be sealed alongside the bonding section 22 of the pouch of Watanabe such that the micro-mechanical element is on the inside and the circuit board is on the outside, P51 of Elian, P83 of Watanabe). Watanabe does not mention the use of an insulation film on the case, therefore modified Watanabe meets the limitation wherein at least a portion of the through-opening comprises a coupling portion without an insulation film. Modified Wantabe meets the limitation wherein an outer surface of the coupling portion is made of copper (given Elian teaches the circuit board is made of an insulating carrier layer and at least one metal layer or a layer comprising electrically-conductive material for implementing the at least one electrically-conductive line, copper, P27, therefore at least a portion of the outer surfaces of the coupling portion of the circuit board would be made of copper). However, modified Watanabe does not meet the limitation of the battery including a one-way valve in the neck portion configured to allow gas to move from the receiving portion to the gas pocket. In a similar field of endeavor, Yang teaches using a one-way exhaust valve with a pouch-shaped secondary battery in order to exhaust internal high-pressure gas while preventing external gas from being introduced into the battery cell (P48-50). Yang teaches when high-pressure gas is generated in the battery due to the abnormal operation of the battery, the gas is immediately exhausted through the exhaust valve, and therefore, the lowering in efficiency of the battery due to the internal high-pressure gas of the battery is minimized (P17). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Yang and provided to modified Watanabe a one-way valve in the neck portion configured to allow gas to move from the receiving portion to the gas pocket, given Yan teaches this would allow the discharging of internal gas while preventing entrance of external gas, and one of ordinary skill in the art would recognize it would allow gas to be discharged from the receiving portion while preventing the same gas from being reintroduced to the receiving portion. Applying a known technique to a known device (method or product) ready for improvement to yield predictable results is likely to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007) (see MPEP § 2143, D.). Regarding claim 3, Watanabe discloses the battery including the electrode assembly, the electrode assembly comprising: a stack having a positive electrode, a separator, and a negative electrode (an electrode stack 11a that is formed by alternately stacking a plurality of positive plates and a plurality of negative plates via separators S in Fig. 4; see entire disclosure and especially P68), one or more electrode tabs protruding from the stack, the one or more electrode tabs being configured to electrically connect the stack to an outside (connection members 16 and 17 in Fig. 4; see entire disclosure and especially P69-70; it is well known that the tabs of batteries are used to electrically connect an electrode assembly to leads that connect to an outside to supply power); and an electrode lead to which the one or more electrode tabs are electrically connected, the electrode lead protruding out of the case (positive electrode power supply tab 14 and negative electrode power supply tab 15 in Fig. 4; see entire disclosure and especially P69-70). Regarding claim 8, modified Watanabe meets the limitation wherein the coupling portion is provided at a portion of the pressure sensing device at which no board is located (given the measurement portion of the apparatus of Elian is not at the coupling portion and also a portion the coupling portion is provided on a surface of the apparatus opposite to the surface at which the measurement portion is upon). Regarding claim 16, Watanabe discloses a pouch-shaped secondary battery (laminate-packaged electric storage device 10 in Fig. 1; see entire disclosure and especially P51) comprising: a case having a receiving portion configured to receive an electrode assembly, the receiving portion defining a first volume (receiving section 23 in Figs. 1 and 8; see entire disclosure and especially P51); a gas pocket within the case configured to receive gas from the receiving portion, the gas pocket defining a second volume separate from the first volume (functional section 24a in Fig. 8; see entire disclosure and especially P83, 88, 94), the gas pocket being connected to the receiving portion by a neck portion defining a third volume, the third volume being less than the first and second volumes (link section 24b that links the functional section 24a and the receiving section 23 in Fig. 8; see entire disclosure and especially P90, 94). However, Watanabe does not disclose a pressure sensing device extending continuously through the case from an outside of the case to an inside of the case such that at least a portion of the pressure sensing device is in direct contact with the gas in the gas pocket, the pressure sending device being located away from the receiving portion, wherein the pressure sensing device is configured to directly measure gas pressure of the gas in the gas pocket within the case. In a similar field of endeavor, Elian teaches a battery comprising a hermetically sealed enclosure (400 in Fig. 4, P7, 45). Elian teaches an apparatus for measuring pressure (100 in Fig. 1, 420 in Fig. 4, 45). Elian teaches the apparatus includes a semiconductor die (110 in Fig. 1) having a micro-mechanical element (112 in Fig. 1) and a circuit board (120 in Fig. 1, P20). Elian teaches the micro-mechanical element measures pressure through gas pressure accessing the micro-mechanical element (P25). Elian teaches the circuit board of the apparatus can extend through the enclosure so that a measurement signal can be provided to the outside (P51). Elian teaches by measuring an increase of the pressure inside the enclosure erroneous behavior can be detected very easily and counter measures can be started very early to avoid a destruction of the battery and improve safety (P46). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Elian and provided to Watanabe a pressure sensing device extending continuously through the case from an outside of the case to an inside of the case, such as the apparatus taught by Elian, and provided wherein at least a portion of the pressure sensing device is in direct contact with the gas in the gas pocket, wherein the pressure sensing device is configured to directly measure gas pressure of the gas in the gas pocket the case, given that Elian teaches this can detect an increase of pressure inside the case of Watanabe so that counter measures can be started very early to avoid a destruction of the battery and improve safety. Regarding “the pressure sending device being located away from the receiving portion”, given the pressure sensing device is within the gas pocket, it can be considered located away from the receiving portion. Claims 9 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Watanabe et al (US 20120328934 A1) in view of Elian (US 20140342203 A1) in view of Yang et al (US 20100239895 A1) as applied to claim 1, further in view of Cho et al (Micropatterned Pyramidal Ionic Gels for Sensing Broad-Range Pressures with High Sensitivity). Regarding claims 9 and 13, modified Watanabe does not meet the limitations wherein the measurement portion has a fluid therein to sense pressure and wherein the fluid is a gel. Analogous art is a term used to connect multiple prior arts that are in the same field of endeavor. Modified Watanabe (Watanabe in view of Elian) and Sung are analogous art due to their contents being directed to pressure sensing devices. Cho teaches flexible capacitive pressure sensors that incorporate micropatterned pyramidal ionic gels to enable ultrasensitive pressure detection (Abstract). Cho teaches their devices show superior pressure-sensing performance, with a broad sensing range from a few pascals up to 50 kPa, with fast response times of <20 ms and a low operating voltage of 0.25 V (Abstract). Cho teaches the micropatterned pyramidal ionic gels exhibit significant capacitance variations as a function of pressure (Page 10129, right column). Cho teaches ionic gels, composed of a blend of polymer and nonvolatile ionic liquid, are useful for sensing pressures over the broad range up to 50 kPa (Conclusions, Page 10132). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Cho and substituted the micro-mechanical element of modified Watanabe (via Elian) with the micropatterned pyramidal ionic gels of Cho, given that Cho teaches devices incorporating micropatterned pyramidal ionic gels have superior and ultrasensitive pressure detection. Furthermore, the simple substitution of one known element for another is likely to be obvious when predictable results are achieved. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007) (see MPEP § 2143, B.). Claims 10 and 11 are rejected under 35 U.S.C. 103 as being unpatentable over Watanabe et al (US 20120328934 A1) in view of Elian (US 20140342203 A1) in view of Yang et al (US 20100239895 A1) as applied to claim 1, further in view of Park et al (US 20140356692 A1, hereinafter referred to ask Park ‘692) and Clark (US 20190086476 A1). Regarding claim 10, Watanabe discloses the case of the pouch-shaped cell includes two pieces sealed together on the outer peripheral surfaces to seal the internal space (upper outer package film 21A and upper outer package film 21A in Fig. 4; see entire disclosure and especially P75). Wantabe discloses the pieces are thermally bonded (see entire disclosure and especially P75). However, modified Watanabe does not meet the limitations a pressure measurement apparatus comprising: a jig configured to press an upper part and a lower part of the pouch-shaped secondary battery of claim 1; and a pressure transmission device connected to the pressure sensing device disposed in the pouch-shaped secondary battery so as to protrude outwards therefrom, the pressure transmission device being configured to transmit pressure information to an external device. In a similar field of endeavor, Park ‘692 teaches a pouch-type secondary battery including a pouch casing and a cell assembly (P34). Park ‘692 teaches the pouch casing (20 in Fig. 1) includes an upper and lower pouch film (20a and 20b in Fig. 2) that are sealed along their periphery by heat and pressure (P34). Park ‘692 teaches a sealing jig (60 in Fig. 2) is used in the sealing process to apply heat and pressure along the edges of the upper and lower pouch film (P55). Therefore it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Park ‘692 and provided a jig configured to press an upper part and a lower part of the pouch-shaped secondary battery to modified Watanabe, given that Park ‘692 teaches this can be used in a sealing method to seal two cases of a pouch-shaped battery together by heat and pressure. However, modified Watanabe still does not meet the limitation a pressure transmission device connected to the pressure sensing device disposed in the pouch-shaped secondary battery so as to protrude outwards therefrom, the pressure transmission device being configured to transmit pressure information to an external device. In a similar field of endeavor, Clark teaches a circuit board disposed within a housing and connected to batteries (P15). Clark teaches the circuit board contains various sensors to monitor the cell (P4, 14). Clark teaches an antenna can be provided to the circuit board to wirelessly link the circuit board to an outside processor to communicate the data from one or more sensors to a battery management system outside of the housing (P5-7, 16). While Clark teaches the antenna to be located on a circuit board, one of ordinary skill in the art would recognize the benefits of using the antenna to wirelessly communicate pressure data from the pressure sensing device of modified Watanabe to an external processor, and if a technique has been used to improve one device (such as wirelessly communicate data from sensors to an external processor), and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way (wirelessly communicate pressure data from a pressure sensing device to an external processor), using the technique is obvious unless its actual application is beyond his or her skill. SEE MPEP § 2141 (III) Rationale C, KSR v. Teleflex (Supreme Court 2007). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Clark within the pressure measurement apparatus of modified Watanabe to provide a pressure transmission device connected to the pressure sensing device disposed in the pouch-shaped secondary battery so as to protrude outwards therefrom, the pressure transmission device being configured to transmit pressure information to an external device, given Clark teaches this allows data from a sensor to be wirelessly communicated to an external processor. Regarding claim 11, modified Watanabe meets the limitation wherein the pressure transmission device transmits the pressure information to the external device wirelessly (see the rejection of claim 10 above). Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Jo et al (WO2020046018A1 using US 20200373535 A1 as an English equivalent) in view of in view of Elian (US 20140342203 A1). Regarding claim 16, Jo discloses a pouch-shaped secondary battery comprising: a case (pouch 120 in Figs. 1-3) having a receiving portion (accommodation part 121 in Figs. 1-3) configured to receive an electrode assembly (electrode assembly 110 in Figs. 1-3, P45, P69), the receiving portion defining a first volume (see Fig. 3); a gas pocket within the case configured to receive gas from the receiving portion (gas pocket part 124 in Figs. 1-3, P47), the gas pocket defining a second volume separate from the first volume (see Fig. 3), the gas pocket being connected to the receiving portion by a neck portion (inlet hole 122c-1 in Figs. 1-3, P47) defining a third volume (see Figs. 2-3), and the third volume being less than the first and second volumes (see Figs. 2-3). However, Jo does not disclose a pressure sensing device extending continuously through the case from an outside of the case to an inside of the case such that at least a portion of the pressure sensing device is in direct contact with the gas in the gas pocket, the pressure sensing device being located away from the receiving portion, wherein the pressure sensing device is configured to directly measure gas pressure of the gas in the gas pocket within the case. In a similar field of endeavor, Elian teaches a battery comprising a hermetically sealed enclosure (400 in Fig. 4, P7, 45). Elian teaches an apparatus for measuring pressure (100 in Fig. 1, 420 in Fig. 4, 45). Elian teaches the apparatus includes a semiconductor die (110 in Fig. 1) having a micro-mechanical element (112 in Fig. 1) and a circuit board (120 in Fig. 1, P20). Elian teaches the micro-mechanical element measures pressure through gas pressure accessing the micro-mechanical element (P25). Elian teaches the circuit board of the apparatus can extend through the enclosure so that a measurement signal can be provided to the outside (P51). Elian teaches by measuring an increase of the pressure inside the enclosure erroneous behavior can be detected very easily and counter measures can be started very early to avoid a destruction of the battery and improve safety (P46). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Elian and provided to Lee a pressure sensing device extending continuously through the case from an outside of the case to an inside of the case, such as the apparatus taught by Elian, and provided wherein at least a portion of the pressure sensing device is in direct contact with the gas in the gas pocket, wherein the pressure sensing device is configured to directly measure gas pressure of the gas in the gas pocket the case, given that Elian teaches this can detect an increase of pressure inside the case of Jo so that counter measures can be started very early to avoid a destruction of the battery and improve safety. Regarding “the pressure sending device being located away from the receiving portion”, given the pressure sensing device is within the gas pocket, it can be considered located away from the receiving portion. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Mary Byram whose telephone number is (571)272-0690. The examiner can normally be reached M-F 8 am-5 pm EST. 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, Ula Ruddock can be reached at (571)272-1481. 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. /MARY GRACE BYRAM/Examiner, Art Unit 1729
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Prosecution Timeline

Dec 14, 2021
Application Filed
Jul 02, 2024
Non-Final Rejection — §103
Sep 26, 2024
Interview Requested
Oct 07, 2024
Examiner Interview Summary
Oct 07, 2024
Applicant Interview (Telephonic)
Oct 11, 2024
Response Filed
Oct 23, 2024
Final Rejection — §103
Nov 29, 2024
Interview Requested
Dec 12, 2024
Applicant Interview (Telephonic)
Dec 12, 2024
Examiner Interview Summary
Jan 27, 2025
Request for Continued Examination
Jan 28, 2025
Response after Non-Final Action
Feb 27, 2025
Non-Final Rejection — §103
May 12, 2025
Interview Requested
May 19, 2025
Examiner Interview Summary
May 19, 2025
Applicant Interview (Telephonic)
Jun 04, 2025
Response Filed
Jun 17, 2025
Final Rejection — §103
Jul 29, 2025
Interview Requested
Aug 06, 2025
Examiner Interview Summary
Aug 06, 2025
Applicant Interview (Telephonic)
Aug 27, 2025
Response after Non-Final Action
Sep 17, 2025
Request for Continued Examination
Oct 01, 2025
Response after Non-Final Action
Nov 06, 2025
Non-Final Rejection — §103 (current)

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Prosecution Projections

5-6
Expected OA Rounds
70%
Grant Probability
99%
With Interview (+32.6%)
3y 3m
Median Time to Grant
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