Prosecution Insights
Last updated: July 17, 2026
Application No. 17/741,236

BATTERY AND USE OF SUCH

Final Rejection §103
Filed
May 10, 2022
Priority
May 11, 2021 — DE 102021204787.4
Examiner
CHOI, EVERETT TIMOTHY
Art Unit
1751
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Robert Bosch GmbH
OA Round
4 (Final)
12%
Grant Probability
At Risk
5-6
OA Rounds
0m
Est. Remaining
-2%
With Interview

Examiner Intelligence

Grants only 12% of cases
12%
Career Allowance Rate
2 granted / 17 resolved
-53.2% vs TC avg
Minimal -14% lift
Without
With
+-14.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
36 currently pending
Career history
71
Total Applications
across all art units

Statute-Specific Performance

§103
84.6%
+44.6% vs TC avg
§102
11.8%
-28.2% vs TC avg
§112
1.8%
-38.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 17 resolved cases

Office Action

§103
CTFR 17/741,236 CTFR 99814 Notice of Pre-AIA or AIA Status 07-03-aia AIA 15-10-aia The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA. 12-151 AIA 26-51 12-51 Status of Claims Applicant’s amendment and arguments filed 04/06/2026 have been fully considered. Claims 1, 6, and 14 have been amended. Claim 2 has been cancelled. Claim 12 remains withdrawn. Examiner affirms that the original disclosure provides adequate support for the amendment. Claim Rejections - 35 USC § 103 07-103 AIA The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. 07-21-aia AIA Claim s 1, 3-6, 8-11, 13-16, and 21 are rejected under 35 U.S.C. 103 as being unpatentable over Roh et al. US20160087319A1, in view of Ciaccio et al. WO2017151788A1 (Copy provided in previous office action filed 02/11/2025), Lee et al. US20150236314A1, and Kurosawa US20110020676A1 . Regarding claims 1, 14 Roh discloses a battery comprising a first housing element 112 (“second case member”) and a second housing element 110 (“first case member”) which jointly form an inner chamber 130 (“inner space”) for receiving a battery module 102 ([0030], [0049], FIG. 1). While Roh discloses that the second housing element 110 includes a top wall and side walls that extend downwardly from the top wall toward the first housing element 112 (Roh FIG. 1), Roh fails to explicitly disclose a first housing element 112 including a bottom wall and size walls that extend upwardly from the bottom wall. Lee, directed to an analogous structure of battery, teaches a first housing element 20 and a second housing element 10 which jointly form an inner chamber for accommodating (i.e., receiving) a battery module (Lee [0023], FIGs. 1, 2), wherein the first housing element 20 comprises a bottom wall and side walls that extend upwardly from the bottom wall (FIG. 1, 2). As the respective first and second housings of both Roh and Lee perform an identical function of forming an inner chamber for receiving a battery module, absent persuasive evidence that the particular configuration of the first housing element including the bottom wall extending upward has a significant function, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to change the shape of Roh’s first housing element to comprise a side wall that extends upwardly from the bottom wall as taught by Lee (see MPEP 2144.04 IV A). Modified Roh further discloses a battery wherein a plurality of battery cells 102 of the battery module is arranged in the inner chamber 130 , said battery cells being connected in an electrically conductive manner in series and/or in parallel to one another (Roh [0004]), wherein a first element of a battery control system (“thermistors, controller”, [0033]) is arranged in the inner chamber 130 . A side of the first housing element 112 exchanges heat (i.e., controls temperature) with a refrigerant on a first face that is isolated from the inner chamber 130 ([0051], [0017], see Annotated Roh FIG. 3 below) and is broadly and reasonably interpreted as a first temperature control structure on a first face that is remote (“isolated”) from the inner chamber 130 . PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 While Roh discloses a second embodiment of the battery (see Roh FIGs. 7, 8) comprising a third housing element 610 (“first case member”) which provides a second temperature control chamber 613 ’ to improve uniformity and efficiency of heat exchange (FIG. 8, [0065], [0068]), Roh fails to disclose a singular embodiment of the battery comprising a second housing element jointly forming an inner chamber with the first housing element (i.e., Roh FIG. 1) where the second housing element is further connected to a separate third housing element (Roh FIG. 7) as claimed in claim 1. Kurosawa, directed to a similar battery comprising a first 42 (“lid plate”) and a second 40 (“container body”) housing element forming an inner chamber for battery module 21 (“battery pack”), teaches connecting the second housing element 40 to a separate third housing element 230 (“heat exchanger”) on a second face (“outside of the surface”) that is remote from the inner chamber (Kurosawa FIG. 11, [0128]). Advantageously, while still allowing for cooling of the battery cells ([0129]), this configuration allows the battery to be hermetically sealed, preventing intrusion of grit, dust, or condensation into the inner chamber ([0129, 0131]). Such considerations are pertinent to Roh’s battery, where Roh’s first housing element 112 and second housing element 110 also serve to hermetically isolate the battery (Roh [0050]). As such, in seeking to maintain the hermetic sealing of Roh’s inner chamber while improving the uniformity and efficiency of heat exchange to the battery modules, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to modify Roh’s second housing element 110 (Roh FIG. 1) to further connect to a separate, third housing element 610 (Roh FIG. 7) on a second face that is remote from the inner chamber 130 as according to Roh and Kurosawa’s disclosure. Such a modification would be made with a reasonable expectation of success, as Roh recognizes the use of a third housing element 610 to provide heat exchange capabilities (Roh [0065]), and Kurosawa teaches a suitability of connecting the second and third housing element on a face remote from the inner chamber for the same purpose of performing heat exchange with the battery cells (Kurosawa FIG. 11); see MPEP 2144.07. Additionally, while modified Roh envisions a general use of the housing elements to protect and support electrical components (Roh [0017]), Roh does not expressly specify use of the third housing element 610 to receive a second element of the battery control system. Ciaccio, directed to a battery comprising a cooling plate assembly 202 analogous to modified Roh’s third housing element, teaches use of the cooling plate assembly 202 to receive a second element 162, 164 (“DC/DC boost converter”, “DC/DC buck converter”) of a battery control system (Ciaccio FIG. 1C), which advantageously allows heat exchange to be performed with the second element 172 ([0093]). As such, in seeking to perform heat exchange on a second element the battery control system in modified Roh’s battery control system, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to use modified Roh’s third housing element to receive a second element of the battery control system as taught by Ciaccio. Such a modification would be made with a reasonable expectation of success, as Roh envisions a suitability of using housing elements to protect and support electrical components, e.g., supporting the second element of the battery control system on the third housing element. Modified Roh further discloses the third housing element 610 includes a temperature control fluid inlet 630 and a temperature control fluid outlet 632 (Roh [0064], FIG. 7), wherein the surface of the third housing element 610 facing the second housing element 110 through which heat exchange (i.e., temperature control) is performed (Roh [0017], [0065]; Kurosawa [0128]) is recognized as the second temperature control structure. Furthermore, the sides and bottom faces of Roh’s third housing element 610 are connected to the third housing element at edges of an inner face of the third housing element (see Annotated Roh FIG. 7 below) and define (i.e., limit) a second temperature control chamber 613 ’ (“hollow space”) ([0068], Roh FIG. 8). Thus, the sides and bottom faces are broadly and reasonably interpreted as the second covering element connected to the third housing element 610 which limits a second temperature control chamber 613’ as claimed in claim 1. Additionally, temperature control fluid (“liquid refrigerant”) may flow through the second temperature control chamber ([0068]); and as the temperature control fluid is hermetically isolated from the interior of the battery ([0014]), the temperature control fluid flows in a fluid-tight manner as claimed, relative to the interior of the battery. PNG media_image2.png 708 2029 media_image2.png Greyscale Annotated Roh FIG. 7 The second covering element , which extends in a plane along the length and width of the battery, is thus recognized as a planar component (Annotated Roh FIG. 7). While Roh does not explicitly indicate a material of the planar component, Roh discloses a finite selection of thermally conductive and mechanically rigid materials to use for the housing (“pack case”) including metal ([0017]); a skilled artisan would necessarily select at least some material in order to produce the housing elements and to provide the required thermal conductivity and rigidity, with Roh’s finite list of materials recognized as predictable solutions such that it would be obvious for one having ordinary skill in the art to routinely explore selecting a metallic material for the planar component (MPEP 2143 I. E). The areas of the planar component through which the temperature control fluid inlet/outlet 630/632 of the third housing element 610 passes are recognized as the passages for the temperature control fluid inlet and outlet of the third housing element as claimed ([0064], Annotated Roh FIG. 7). Roh further discloses the first element of the battery control system comprises an electrical component (“connectors for electrical connection”, [0018]) and an electronic component of the battery module (“thermistors”, “controller”, [0033]). Roh fails to expressly disclose that the second element of the battery control system is an electrical voltage converter. However, Roh envisions the use of the battery in an electric vehicle ([0035-0036]); it is known in the art that an electrical voltage converter such as a DC converter is used in an electric vehicle to control output of a desired voltage to vehicle components such as a generator or motor during vehicle operation (Ciaccio [0070-0072], [0077]), such that one of ordinary skill in the art recognizing the use of Roh’s battery in an electrical vehicle would reasonably expect Roh’s second element of the battery control system to include at least an electrical voltage converter as claimed in claim 1, where the electrical voltage converter is a DC converter as claimed in claim 14. Assuming arguendo that Applicant convincingly proves that Roh’s battery, envisioned for use in an electric vehicle, does not necessarily or inherently comprise some form of electrical voltage converter or DC convertor, it would be obvious for one having ordinary skill in the art to provide an electrical voltage converter as a second element in Roh’s battery, where the electrical voltage converter is a DC converter as taught by Ciaccio for the intended purpose of controlling the voltage output for use of the battery in an electric vehicle (Ciaccio [0070-0073], [0077]; Roh [0035-0036]); see MPEP 2144.07. Regarding claim 6, modified Roh discloses the battery according to claim 1 wherein the electrical component of the battery control system is a cell connector (“connectors for electrical connection”, Roh [0018]) and/or a cable (“wires”, [0009]), and the electronic component of the battery module is a battery control system (“controller”), or a resistor (“thermistors”) ([0033]) as claimed in claim 6. PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 Regarding claim 8 , modified Roh discloses the battery according to claim 1, wherein the bottom surface of the pack case 101 recognized as a first covering element (Annotated Roh FIG. 3) is connected to the first housing element 112 and limits a first temperature control chamber 103 (“hollow space”) through which temperature control fluid may flow ([0056]). The inner chamber 130 is hermetically isolated from the temperature control chambers (“hollow space”) ([0050-0052]); thus, relative to the inner chamber, the temperature control fluid flows in a fluid-tight manner. While Roh disclose the use of sealing elements 107 (FIG. 2, [0050]) elsewhere in the battery, Roh fails to explicitly disclose a second sealing element between the first housing element and the first covering element specifically. Lee, relied upon in claim 1 to teach features of an analogous first housing element 112 , further teaches a first covering element 30 connected to the first housing element 20 to limit a first temperature control chamber 31 (“flow path”) (Lee [0033]). A second sealing element (“adhesive”) is arranged between the first housing element 20 and the first covering element 30 ([0036]), advantageously sealing a first temperature control chamber 31 to prevent leakage of a temperature control fluid ([0033], FIG. 2) and allowing the surfaces to be more closely adhered to each other to improve the stability of the battery pack ([0036]). As such, in seeking to further prevent damage from leakage in modified Roh’s battery, and to improve the stability of the battery, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to arrange a second sealing element between the first housing element and first covering element as taught by Lee. Regarding claim 9, modified Roh discloses the battery according to claim 8, wherein the battery has a first connection 114 (“inlet port”) that is configured to convey temperature control fluid to the battery and a second connection 116 (“outlet port”) that is configured to discharge temperature control fluid from the battery (Roh [0051], FIG. 1), wherein the battery has temperature control fluid ducts that are configured such that temperature control fluid flows through separate inlets and outlets for each housing element and temperature control chamber ([0064-0065], Annotated Roh FIG. 7), and is thus configured to flow through the first and second temperature control chambers in parallel. Regarding claim 10 , modified Roh discloses the battery according to claim 1. Roh teaches providing interior surfaces of the housing members (“pack case”, understood to include the first and second temperature control structures comprising interior surfaces of the first 112 and third 610 housing elements) with a heat dissipation plate 418 comprising a radiator structure for accelerating heat exchange with a temperature control fluid (Roh [0062], [0028-0030], Roh FIG. 6). While Roh does not explicitly describe the radiator structure as being a flow guiding element or as flow disturbing element, it would be recognized by a person having ordinary skill in the art that a fluid (i.e., temperature control fluid) necessarily comprises either a laminar or turbulent flow regime, and thus the radiator structure may only guide laminar flow as a flow guiding element or induce turbulent flow as a flow disturbing element. Furthermore, the first and second temperature control structures necessarily limit the flow to within the temperature control chambers in order to carry temperature control fluid, and thus function as flow limiting elements ([0015], Roh FIGs. 3, 8). Regarding claims 11 and 21, modified Roh discloses the battery according to claim 1, wherein the plurality of battery cells 102 is connected in a thermally conductive manner to a first inner face of the inner chamber 130 , said first inner face being arranged directly adjacent to the first temperature control structure (Roh [0017], [0055], Roh FIG. 3) as claimed in claim 11. Roh in view of Ciaccio further discloses that the second element 162, 164 of the battery control system is arranged in a thermally conductive manner to an inner face 258 (“outer top surface”) of the third housing element 202 (“cooling plate assembly”) (Ciaccio [0093], FIG. 1C), said inner face of the third housing element being arranged directly adjacent to the second housing element (see Annotated Roh FIG. 7 below) as claimed in claim 11. PNG media_image2.png 708 2029 media_image2.png Greyscale Annotated Roh FIG. 7 The portion of the third housing element 202 in thermal contact with the second element 162, 164 of the battery control system, being configured for thermally conductive connection of the second element 162, 164 (Ciaccio [0093], FIG. 1C), is broadly and reasonably understood as the thermal contact area as claimed in claim 21. Furthermore, modified Roh’s housing elements (“pack case”) including the third housing element 610 are collectively made of a thermally conductive material to enable heat dissipation (Roh [0017]). The selection of a thermally conductive material for the third housing element increases the thermal conductivity when compared to a third housing element constructed of a thermally insulative material; thus, the third housing element 610 itself and its components are recognized as the thermal conductor elements configured to increase thermal conductivity. PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 Regarding claim 13 , modified Roh discloses the battery according to claim 1. Roh’s first face , being a surface of first housing element 112 partly defining a first temperature control chamber 103 (“hollow space”) isolated (i.e., remote) from the inner space 130 jointly formed with second housing element 110 (Roh [0050-0052], FIG. 2, Annotated Roh FIG. 3) is thus remote from the second housing element 110 (Annotated Roh FIG. 3). The second face (formed on the top face of the exterior of second housing element 110 ) is similarly remote from the first housing element 112 (Roh FIGs. 1, 7). Regarding claims 3 and 15 , modified Roh discloses the battery according to claims 1 and 14 comprising the first housing element 101 , the second housing element 130 and the third housing element 610 (Roh FIGs. 1, 7). While Roh discloses metal as a preferable housing element material due to its thermal conductivity and mechanical rigidity (Roh [0017]) and notes empty space or gaps between solids as undesirable for purposes of thermal conduction rate ([0024]), Roh fails to explicitly disclose the use of die casting to manufacture the housing elements. Lee, teaching an analogous first and second housing element 10, 20 (Lee FIG. 2), further teaches embodying the housing elements as die-cast housings, which advantageously improves the assembly tolerance of the housing elements and allows them to be more closely adhered to each other ([0035-0036]). Ciaccio, teaching a cooling plate assembly 202 analogous to the third housing element, also teaches a suitability of manufacturing the third housing element through die casting (Ciaccio [0084]). As such, in seeking to improve the assembly tolerance and more closely adhere modified Roh’s first, second, and third housing elements to each other, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to embody each housing as a die-cast housing, with a reasonable expectation of success due to the analogous structure and function between modified Roh’s housing elements and the housing elements disclosed by Lee and Ciaccio, and because Roh envisions the use of metal for the housing elements. Regarding claims 4-5 and 16 , modified Roh discloses the battery according to claims 1 and 15, wherein the first housing element 112 and the second housing element 110 are connected in a fluid-tight manner to one another (Roh [0017]) as claimed in claims 4 and 16. Roh further discloses a first sealing element 107 (“sealing member”) arranged between the first housing element 112 and the second housing element 110 (FIG. 2) (claim 16), and discloses a plurality of battery cells 102 comprising rectangular (i.e., prismatic) module cases (Roh FIGs. 1, [0055]) which are broadly and reasonably interpreted as prismatic battery cells as claimed in claims 5 and 16 . 07-22-aia AIA Claim s 7 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Roh in view of Lee, Ciaccio, and Kurosawa as applied to claim s 1 and 14 above, and further in view of Ling et al. US20180159098A1 . Regarding claims 7 and 18 , modified Roh discloses the battery according to claims 1 and 14, comprising the first element of the battery control system (Roh [0033]) (claim 7), and wherein the electrical component of the battery module is a cell connector (“connectors for electrical connection”, [0018]) and/or a cable (“wires”, [0009]), and that the electronic component of the battery module is a battery control system (“controller”), and/or a resistor (“thermistors”, [0033]) as claimed in claim 18, but does not explicitly specify that the first element of the battery control system is integrated into a circuit board. Ling, similarly directed to a battery module, teaches integrating a first element (“control circuit”) of the battery control system into a circuit board (Ling FIG 2A, 2B, Abstract, [0038]), which advantageously minimizes and simplifies the control circuit components to better meet space limitations ([0002-0004], [0038]), and also allows for the heat-generating electrical components of the first element to contact a heat sink during battery operation ([0043]). As such, in seeking to reduce the size and simplify the manufacturing process of Roh’s battery, and in seeking to cool the electrical components, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to integrate the first element of Roh’s battery control system into a circuit board as taught by Ling, thus reading on claims 7 and 18. PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 Modified Roh further discloses the battery wherein the bottom surface of the pack case 101 recognized as a first covering element (Annotated Roh FIG. 3) is connected to the first housing element 110 and limits a first temperature control chamber 103 (“hollow space”) through which temperature control fluid may flow ([0056]). The inner chamber 130 is hermetically isolated from the temperature control chambers (“hollow space”) ([0050-0052]); thus, relative to the inner chamber, the temperature control fluid flows in a fluid-tight manner. While Roh envisions the use of sealing elements 107 (FIG. 2, [0050]) elsewhere in the battery, Roh fails to expressly disclose a second sealing element between the first housing element and the first covering element specifically, or specify that the first covering element is connected to the first housing element in a material-bonded manner. Lee, relied upon to teach features of an analogous first housing element 112 , further teaches a first covering element 30 connected to the first housing element 20 (Lee [0033]) and furthermore a second sealing element (“adhesive”) is arranged between the first housing element 20 and the first covering element 30 ([0036]), advantageously materially bonding and sealing a first temperature control chamber 31 to prevent leakage of a temperature control fluid ([0033], FIG. 2) and allowing the surfaces to be more closely adhered to each other to improve the stability of the battery pack ([0036]). As such, in seeking to further prevent damage from leakage in modified Roh’s battery, and to improve the stability of the battery, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to arrange a second sealing element between the first housing element and first covering element as taught by Lee, such that the first covering element and first housing element are connected in a material-bonded manner as claimed in claim 18 . 07-22-aia AIA Claim 22 is rejected under 35 U.S.C. 103 as being unpatentable over Roh in view of Lee, Ciaccio, and Kurosawa as applied to claim 1 above, and further in view of Landerer et al. US20170346142A1 PNG media_image2.png 708 2029 media_image2.png Greyscale Annotated Roh FIG. 7 Regarding claim 22, modified Roh discloses the battery according to claim 1, wherein the second covering element includes the planar component formed from the metallic material having passages (Annotated Roh FIG. 7), but fails to further indicate use of the passages for connection to the second housing element 110 in a fluid-conducting manner. Landerer, similarly directed to fluid connections of a battery (Landerer [0010]) comprising a second housing element 3 (“frame component”) and a second covering element 4 (“heat exchanger”) ([0044-0046], FIGs. 1-2, 5) including a planar component (“heat sink side”) having passages 8, 9 (“second connection unit”) for the temperature fluid control inlet and outlet ([0044], FIG. 2), further teaches use of the passages 8, 9 for connection to the second housing element 3 in a fluid-conducting manner ([0043-0044], FIGs. 1-2). Advantageously, the use of the second housing element 3 to conduct fluid provides additional space to insulate the fluid connection ([0027]) or allows for a reduction in size and complexity of the battery ([0028]). Thus, in seeking to provide these advantages to modified Roh’s battery, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to form Roh’s planar component with passages for connection to the second housing element in the fluid conducting manner as taught by Landerer. Such a modification would be made with a reasonable expectation of success, as Roh desires to protect the battery from coolant leakage (Roh [0011]) and generally envisions providing coolant channels in hollow spaces of the housing elements ([0016]), e.g., the second housing element . 07-21-aia AIA Claim s 1, 14, and 23 are rejected under 35 U.S.C. 103 as being unpatentable over Roh in view of Lee, Ciaccio, Kurosawa, and Landerer . Regarding claims 1, 14 Roh discloses a battery comprising a first housing element 112 (“second case member”) and a second housing element 110 (“first case member”) which jointly form an inner chamber 130 (“inner space”) for receiving a battery module 102 ([0030], [0049], FIG. 1). While Roh discloses that the second housing element 110 includes a top wall and side walls that extend downwardly from the top wall toward the first housing element 112 (Roh FIG. 1), Roh fails to explicitly disclose a first housing element 112 including a bottom wall and size walls that extend upwardly from the bottom wall. Lee, directed to an analogous structure of battery, teaches a first housing element 20 and a second housing element 10 which jointly form an inner chamber for accommodating (i.e., receiving) a battery module (Lee [0023], FIGs. 1, 2), wherein the first housing element 20 comprises a bottom wall and side walls that extend upwardly from the bottom wall (FIG. 1, 2). As the respective first and second housings of both Roh and Lee perform an identical function of forming an inner chamber for receiving a battery module, absent persuasive evidence that the particular configuration of the first housing element including the bottom wall extending upward has a significant function, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to change the shape of Roh’s first housing element to comprise a side wall that extends upwardly from the bottom wall as taught by Lee (see MPEP 2144.04 IV A). Modified Roh further discloses a battery wherein a plurality of battery cells 102 of the battery module is arranged in the inner chamber 130 , said battery cells being connected in an electrically conductive manner in series and/or in parallel to one another (Roh [0004]), wherein a first element of a battery control system (“thermistors, controller”, [0033]) is arranged in the inner chamber 130 . A side of the first housing element 112 exchanges heat (i.e., controls temperature) with a refrigerant on a first face that is isolated from the inner chamber 130 ([0051], [0017], see Annotated Roh FIG. 3 below) and is broadly and reasonably interpreted as a first temperature control structure on a first face that is remote (“isolated”) from the inner chamber 130 . PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 While Roh discloses a second embodiment of the battery (see Roh FIGs. 7, 8) comprising a third housing element 610 (“first case member”) which provides a second temperature control chamber 613 ’ to improve uniformity and efficiency of heat exchange (FIG. 8, [0065], [0068]), Roh fails to disclose a singular embodiment of the battery comprising a second housing element jointly forming an inner chamber with the first housing element (i.e., Roh FIG. 1) where the second housing element is further connected to a separate third housing element (Roh FIG. 7) as claimed in claim 1. Kurosawa, directed to a similar battery comprising a first 42 (“lid plate”) and a second 40 (“container body”) housing element forming an inner chamber for battery module 21 (“battery pack”), teaches connecting the second housing element 40 to a separate third housing element 230 (“heat exchanger”) on a second face (“outside of the surface”) that is remote from the inner chamber (Kurosawa FIG. 11, [0128]). Advantageously, while still allowing for cooling of the battery cells ([0129]), this configuration allows the battery to be hermetically sealed, preventing intrusion of grit, dust, or condensation into the inner chamber ([0129, 0131]). Such considerations are pertinent to Roh’s battery, where Roh’s first housing element 112 and second housing element 110 also serve to hermetically isolate the battery (Roh [0050]). As such, in seeking to maintain the hermetic sealing of Roh’s inner chamber while improving the uniformity and efficiency of heat exchange to the battery modules, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to modify Roh’s second housing element 110 (Roh FIG. 1) to further connect to a separate, third housing element 610 (Roh FIG. 7) on a second face that is remote from the inner chamber 130 as according to Roh and Kurosawa’s disclosure. Such a modification would be made with a reasonable expectation of success, as Roh recognizes the use of a third housing element 610 to provide heat exchange capabilities (Roh [0065]), and Kurosawa teaches a suitability of connecting the second and third housing element on a face remote from the inner chamber for the same purpose of performing heat exchange with the battery cells (Kurosawa FIG. 11); see MPEP 2144.07. Additionally, while modified Roh envisions a general use of the housing elements to protect and support electrical components (Roh [0017]), Roh does not expressly specify use of the third housing element 610 to receive a second element of the battery control system. Ciaccio, directed to a battery comprising a cooling plate assembly 202 analogous to modified Roh’s third housing element, teaches use of the cooling plate assembly 202 to receive a second element 162, 164 (“DC/DC boost converter”, “DC/DC buck converter”) of a battery control system (Ciaccio FIG. 1C), which advantageously allows heat exchange to be performed with the second element 172 ([0093]). As such, in seeking to perform heat exchange on a second element the battery control system in modified Roh’s battery control system, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to use modified Roh’s third housing element to receive a second element of the battery control system as taught by Ciaccio. Such a modification would be made with a reasonable expectation of success, as Roh envisions a suitability of using housing elements to protect and support electrical components, e.g., supporting the second element of the battery control system on the third housing element. Modified Roh further discloses the third housing element 610 includes a temperature control fluid inlet 630 and a temperature control fluid outlet 632 (Roh [0064], FIG. 7), wherein the surface of the third housing element 610 facing the second housing element 110 through which heat exchange (i.e., temperature control) is performed (Roh [0017], [0065]; Kurosawa [0128]) is recognized as the second temperature control structure. Furthermore, the sides and bottom faces of Roh’s third housing element 610 are connected to the third housing element at edges of an inner face of the third housing element (see Annotated Roh FIG. 7 below) and define (i.e., limit) a second temperature control chamber 613 ’ (“hollow space”) ([0068], Roh FIG. 8). Thus, the sides and bottom faces are broadly and reasonably interpreted as the second covering element connected to the third housing element 610 which limits a second temperature control chamber 613’ as claimed in claim 1. Additionally, temperature control fluid (“liquid refrigerant”) may flow through the second temperature control chamber ([0068]); and as the temperature control fluid is hermetically isolated from the interior of the battery ([0014]), the temperature control fluid flows in a fluid-tight manner as claimed, relative to the interior of the battery. PNG media_image3.png 708 2029 media_image3.png Greyscale Annotated Roh FIG. 7 Roh’s second covering element comprises connections 630, 632 (“ports”) through which temperature control fluid is introduced and discharged ([0064], Annotated Roh FIG. 7) and can thus be connected in a fluid-conducting manner, but Roh fails to further indicate the connections may be connected to the second housing element 110 in a fluid conducting manner. Additionally, Roh fails to expressly provide passages for screw-connection points to connect the second covering element to the third housing element 610 . Landerer, similarly directed to fluid connections of a battery (Landerer [0010]) comprising a second housing element 3 (“frame component”) and a second covering element 4 (“heat exchanger”) ([0044-0046], FIGs. 1-2, 5) including connections 8, 9 (“second connection unit”) for the temperature fluid control inlet and outlet ([0044], FIG. 2), further teaches use of the connections 8, 9 for connection to the second housing element 3 in a fluid-conducting manner ([0043-0044], FIGs. 1-2). Advantageously, use of the second housing element 3 to conduct fluid provides additional space to insulate the temperature control fluid or allows for a reduction in battery size and complexity ([0027-0028]). Thus, in seeking to provide these advantages to modified Roh’s battery, it would be obvious before the effective filing date of the instant application for one having ordinary skill in the art to provide Roh’s second covering element with connections that can be connected to the second housing element in the fluid conducting manner as taught by Landerer, thus reading on the scope of claim 1. Such a modification would be made with a reasonable expectation of success, as Roh desires to protect the battery from coolant leakage (Roh [0011]) and discloses a general suitability of providing coolant channels in hollow spaces of the housing elements ([0016]), e.g., the second housing element. Landerer further teaches the second covering element 4 includes passages for screw connection points 36 “bore”) to connect the second covering element 4 to a third housing element 35 (“housing”) and to the second housing element 3 (Landerer [0050], FIGs. 5-7), allowing use of a single set of screws to connect the elements, simplifying assembly ([0030]), and facilitating tolerance compensation between components ([0018]). Such an advantage would be recognized by Roh, which addresses considerations of preventing gaps between components (Roh [0024]). Thus, in seeking to provide these advantages to modified Roh’s battery it would further be obvious to provide Roh’s second covering element with passages for screw-connection points to connect the second covering element to the third housing element as claimed in claims 1 and 23 in addition to connection to the second housing element as according to Landerer’s teaching. Such a modification would be made with a reasonable expectation of success, as Roh desires to prevent gaps between components such as the housing elements (Roh [0024]). Roh further discloses the first element of the battery control system comprises an electrical component (“connectors for electrical connection”, [0018]) and an electronic component of the battery module (“thermistors”, “controller”, [0033]) as claimed in claim 1. Roh fails to expressly disclose that the second element of the battery control system is an electrical voltage converter. However, Roh envisions the use of the battery in an electric vehicle ([0035-0036]); Ciaccio teaches that electrical voltage converters such as DC converters are used in electric vehicle batteries in order to control output of a desired voltage to vehicle components such as a generator or motor during vehicle operation (Ciaccio [0070-0072], [0077]), such that one of ordinary skill in the art recognizing the use of Roh’s battery in an electrical vehicle would reasonably expect Roh’s second element of the battery control system to include at least an electrical voltage converter as claimed in claim 1, where the electrical voltage converter is a DC converter as claimed in claim 14. Assuming arguendo that Applicant convincingly proves that Roh’s battery, envisioned for use in an electric vehicle, does not necessarily or inherently comprise some form of electrical voltage converter or DC convertor, it would be obvious for one having ordinary skill in the art to provide an electrical voltage converter as a second element in Roh’s battery, where the electrical voltage converter is a DC converter as taught by Ciaccio for the intended purpose of controlling the voltage output for use of the battery in an electric vehicle (Ciaccio [0070-0073], [0077]; Roh [0035-0036]); see MPEP 2144.07 . Response to Arguments 07-37 AIA Applicant's arguments filed 04/06/2026 have been fully considered but they are not persuasive. Applicant asserts that Ciaccio does not disclose or suggest the particular arrangement of component and cooling that is now claimed in claim 1 which provides advantages not found in the prior art, where an electrical voltage converter now recited in claim 1 produces significant amounts of energy which may be cooled efficiently by the specific arrangement of components in claim 1 (Remarks pp. 11). While this argument has been considered, it has not been found persuasive; Ciaccio [0093] teaches providing a voltage converter (“DC/DC boost converter 162 and the DC/DC buck converter 164”) on an inner face (258, “outer top surface”) of a third housing element (202, “cooling plate assembly”) in order to provide a heat exchange relationship with the voltage converter ([0093]). The advantage of efficiently cooling the significant amounts of energy produced by the electrical voltage converter is found in Ciaccio’s teaching, which provides heat exchange with a cooling plate (e.g., cooling) to the electrical voltage converter. Additionally, the inventive problem of the significant amounts of energy produced by the electrical voltage converter appears to be recognized, at least implicitly, within Ciaccio’s teaching; Ciaccio would otherwise not seek to establish thermal contact or a heat exchange relationship between the voltage converter and a third housing element in the form of a cooling plate if excessive energy produced by the voltage converter did not require cooling. Applicant asserts that the Office relies on an excessive number of references to reject each of the pending claims of the application, amounting to impermissible hindsight reconstruction of the claims (Remarks pp. 12). Similarly, Applicant asserts that the references cited are directed to different problems, using different structures/arrangements of problems such that a skilled artisan would not look to the references cited for modification. As an example, Applicant cites Kurosawa, directed to a hermetically sealed battery case filled with inert gas or dried air, and internal circulation of cooled air from a heat exchanger, compared to Roh, which is directed to externalized liquid cooling with emphasis on isolating the liquid refrigerant from an inner space (Remarks pp. 12). 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). It must also be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin , 443 F.2d 1392, 170 USPQ 209 (CCPA 1971). The cited references (Roh et al. US20160087319A1, Ciaccio et al. WO2017151788A1, Lee et al. US20150236314A1, and Kurosawa US20110020676A1), and additionally Ling et al. US20180159098A1 in the rejection of claims 7 and 18, and Landerer et al. US20170346142A1, in the rejection of claim 22 and alternative rejection of claims 1, 14, and 23 (see pp. 15-21 of this Office action) are combinable according to means within the knowledge of an ordinary skilled artisan before the effective filing date of the claimed invention. Additionally, motivation to modify Roh according to the respective prior art is present within each cited reference or otherwise demonstrated to be generally known in the art, and is pertinent to the structure or intended purpose and function of Roh’s battery for the reasons below. Roh is directed to a battery where the battery pack which serves functions of sealing, protecting, and supporting a plurality of battery cells and electric components (Roh [0017]), where housing elements of the battery pack provide heat exchange while being isolated from the inner space of the battery pack ([0015-0017]), the battery pack being intended for use in an electric vehicle ([0036]). Lee and Kurosawa teach alternate structures of battery known in the art for the same purpose of isolating an inner space of a battery and performing heat exchange through cooling with the battery (Lee [0023]; Kurosawa [0128-0129], [0131]), the respective structures and functionalities thereof being within the knowledge of one of ordinary skill in the art before the effective filing date of the claimed invention. Based on the similar intended function of the respective batteries and housing elements, it would be obvious for a skilled artisan to select of known structures taught by Lee and Kurosawa for an identical intended purpose in Roh’s battery; see MPEP 2144.07. Furthermore, Lee’s battery structure and construction provides improvements to mechanical rigidity and heat transfer characteristics (Roh [0017], [0024]) and Kurosawa’s structure of second and third housing elements sufficiently provides or improves sealing capabilities of the inner chamber (Kurosawa [0129, 0131]), this providing motivation to combine with Roh provided not solely from Applicant’s disclosure. Ciaccio teaches further structural details of the battery control system such as the electrical voltage converter (Ciaccio [0070-0073], [0077]) and means of effectively mounting and cooling this component (Ciaccio [0093]), the electrical voltage converter being a necessary component for operability of Roh’s battery in an electrical vehicle as intended (Roh [0036]). Based on the similar intended usage of both Roh and Ciaccio’s battery in a vehicle, it would be obvious for a skilled artisan to select of known structures and components taught by Ciaccio for an identical intended purpose in Roh’s battery. Ling et al. US20180159098A1, cited in the rejection of claims 7 and 18, demonstrates knowledge of one of ordinary skill in the art to provide elements of a battery control system integrated into a circuit board (Ling [0002-0004], [0038], [0043]), where considerations of mounting and establishing heat exchange with electronic components are pertinent to Roh’s intended function of sealing, protecting, and supporting a plurality of battery cells and electric components and providing heat exchange with the battery (Roh [0015-0017]). Based on the similar considerations of mounting and cooling electrical components, it would be obvious for a skilled artisan to select of known structures of battery components taught by Ling for an identical intended purpose in Roh’s battery. Landerer et al. US20170346142A1, cited in the rejection of claim 22 and alternative rejection of claims 1, 14, and 23 (see pp. 15-21 of this Office action) provides further structural details of structures for the flow of temperature control fluid through a structure of housing elements comparable to that of modified Roh (Landerer [0010]; [0043-0044]), Landerer’s considerations being pertinent to Roh’s battery pack where housing elements of the battery pack must also provide heat exchange while being isolated from the inner space of the battery pack (Roh [0015-0017]) and being known to one of ordinary skill in the art before the effective filing date of the instant application. Based on the similar structures of housing elements and functionality of performing fluid connections throughout or between housing elements, it would also be obvious for a skilled artisan to select of known structures of battery components taught by Landerer for an identical intended purpose in Roh’s battery. Thus, the cited references (Roh et al. US20160087319A1, Ciaccio et al. WO2017151788A1, Lee et al. US20150236314A1, and Kurosawa US20110020676A1, Ling et al. US20180159098A1, and/or Landerer et al. US20170346142A1) present knowledge available to one of ordinary skill in the art before the effective filing date of the claimed invention and are directed to comparable structures of battery or are otherwise pertinent as providing equivalent function to Roh’s battery, and are combinable without modifying the intrinsic functionality or intended use of Roh’s battery. Furthermore, reasoning to combine or provide each of the structures taught by the above prior art is present in each cited piece of prior art and is not gleaned solely from the Applicant’s disclosure . Conclusion 07-96 AIA The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Kim et al. (US20200365955A1) shows a similar battery comprising first housing element (300, “cover”) and second housing element (400, “second cover”) which receive battery modules (100, 200), the first housing element forming a first temperature control structure (800, “battery module cooling unit”) on a first face, and the second housing element (400) is further connected to a separate third housing element (600, “third cover”) on a second face that is remote from the inner chamber (Kim [0038-0042], FIG. 6), wherein the third housing element (600) forms a second temperature control structure (500, “cooling flow channel”) on a face that is turned towards the second housing element (400) [0043-0044], FIGs. 5, 6). 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 EVERETT T CHOI whose telephone number is (703)756-1331. The examiner can normally be reached Monday-Friday 11:00-8:00. 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, Jonathan G Leong can be reached on (571) 270 1292. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /E.C./Examiner, Art Unit 1751 /JONATHAN G LEONG/Supervisory Patent Examiner, Art Unit 1751 5/27/2026 Application/Control Number: 17/741,236 Page 2 Art Unit: 1751 Application/Control Number: 17/741,236 Page 3 Art Unit: 1751 Application/Control Number: 17/741,236 Page 4 Art Unit: 1751 Application/Control Number: 17/741,236 Page 5 Art Unit: 1751 Application/Control Number: 17/741,236 Page 6 Art Unit: 1751 Application/Control Number: 17/741,236 Page 7 Art Unit: 1751 Application/Control Number: 17/741,236 Page 8 Art Unit: 1751 Application/Control Number: 17/741,236 Page 9 Art Unit: 1751 Application/Control Number: 17/741,236 Page 10 Art Unit: 1751 Application/Control Number: 17/741,236 Page 11 Art Unit: 1751 Application/Control Number: 17/741,236 Page 12 Art Unit: 1751 Application/Control Number: 17/741,236 Page 13 Art Unit: 1751 Application/Control Number: 17/741,236 Page 14 Art Unit: 1751 Application/Control Number: 17/741,236 Page 15 Art Unit: 1751 Application/Control Number: 17/741,236 Page 16 Art Unit: 1751 Application/Control Number: 17/741,236 Page 17 Art Unit: 1751 Application/Control Number: 17/741,236 Page 18 Art Unit: 1751 Application/Control Number: 17/741,236 Page 19 Art Unit: 1751 Application/Control Number: 17/741,236 Page 20 Art Unit: 1751 Application/Control Number: 17/741,236 Page 21 Art Unit: 1751 Application/Control Number: 17/741,236 Page 22 Art Unit: 1751 Application/Control Number: 17/741,236 Page 23 Art Unit: 1751 Application/Control Number: 17/741,236 Page 24 Art Unit: 1751
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Prosecution Timeline

Show 3 earlier events
Apr 29, 2025
Examiner Interview Summary
Apr 30, 2025
Response Filed
Jul 03, 2025
Final Rejection mailed — §103
Aug 18, 2025
Request for Continued Examination
Aug 27, 2025
Response after Non-Final Action
Jan 12, 2026
Non-Final Rejection mailed — §103
Apr 06, 2026
Response Filed
Jun 01, 2026
Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12494537
BATTERY MODULE
3y 8m to grant Granted Dec 09, 2025
Patent 12381237
FUEL CELL STACK
3y 5m to grant Granted Aug 05, 2025
Study what changed to get past this examiner. Based on 2 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
12%
Grant Probability
-2%
With Interview (-14.3%)
3y 7m (~0m remaining)
Median Time to Grant
High
PTA Risk
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