Prosecution Insights
Last updated: April 19, 2026
Application No. 17/741,236

BATTERY AND USE OF SUCH

Non-Final OA §103§DP
Filed
May 10, 2022
Examiner
CHOI, EVERETT TIMOTHY
Art Unit
1751
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Robert Bosch GmbH
OA Round
3 (Non-Final)
17%
Grant Probability
At Risk
3-4
OA Rounds
3y 7m
To Grant
-2%
With Interview

Examiner Intelligence

Grants only 17% of cases
17%
Career Allow Rate
2 granted / 12 resolved
-48.3% vs TC avg
Minimal -18% lift
Without
With
+-18.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
55 currently pending
Career history
67
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
59.4%
+19.4% vs TC avg
§102
25.5%
-14.5% vs TC avg
§112
10.8%
-29.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 12 resolved cases

Office Action

§103 §DP
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 08/18/2025 has been entered. Status of Claims Applicant’s amendment and arguments filed 08/18/2025 have been fully considered. Claims 1, 2, 13, 14, 16, and 18 have been amended, and new claims 21-23 have been added. Claim 12 remains withdrawn; as noted above. Examiner affirms that the original disclosure provides adequate support for the amendment. 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 1-6, 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 claim 1, 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]). 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 battery, teaches a first housing element 20 and a second housing element 10 which jointly form an inner chamber for 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 both the first and second housings of 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, and the first housing element 112 forms a first temperature control structure on a first face that is remote from the inner chamber 130 (see Annotated Roh FIG. 3 below [0051], [0015]). PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 While Roh discloses a suitability of providing temperature control chambers (“refrigerant channels”) on outer faces of the housing elements ([0030]) and discloses a second embodiment (Roh FIGs. 7, 8) comprising a third housing element 610 (“first case member”) with a second temperature control chamber 613’ (FIG. 8) to improve uniformity and efficiency of heat exchange ([0065]), Roh fails to further disclose the first embodiment discussed above comprising a second housing element 110 jointly forming inner chamber 130 with the first housing element 112 (Roh FIG. 1) as having a second housing element 110 further connected to a separate third housing element as claimed. 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 an embodiment wherein the second housing element 40 is furthermore connected to a separate, third housing element 230 (“heat exchanger”) on a second face 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]). PNG media_image2.png 710 1069 media_image2.png Greyscale Annotated Roh FIG. 8 As such, in seeking to maintain the 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 combine elements of Roh’s first and second embodiments to connect modified Roh’s second housing element 110 (Roh FIG. 1) to a separate, third housing element 610 (Roh FIG. 7) on a second face that is remote from the inner chamber 130 (see Annotated Roh FIG. 8, above). Such a combination would be done with a reasonable expectation of success as Kurosawa teaches a suitability of connecting the second and third housing element on a face remote from the inner chamber for the purpose of performing heat exchange with the battery cells (Kurosawa FIG. 11), and Roh discloses a suitability of providing a temperature control chamber on an outer face of the second housing element. Additionally, while modified Roh discloses the use of the housing elements to protect and support electrical components (Roh [0017]), Roh does not specify use of the third housing element 610 to receive a second element of the battery control system specifically. 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 172 (“DC/AC converter”) of the 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 (Annotated Roh FIG. 8). 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 is recognized as the second temperature control structure (Annotated Roh FIG. 8). Furthermore, a portion of the third housing element 610 covering and connected to the inner face which limits the second temperature control chamber 613’ (“hollow space”) is recognized as the second covering element (see Annotated Roh FIG. 7 below, Annotated Roh FIG. 8) connected to the third housing element. The temperature control fluid flows in a fluid-tight manner through the second temperature control chamber 613’ ([0068]). PNG media_image3.png 397 1153 media_image3.png Greyscale Annotated Roh FIG. 7 The second covering element, which extends in a plane along the length and width of the battery, is 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 as claimed ([0064], Annotated Roh FIG. 7). Regarding claims 2 and 6, modified Roh discloses the battery according to claim 1 wherein the first element of the battery control system comprises an electrical component (“connectors for electrical connection”, Roh [0018]) and/or an electronic component (“thermistors, controller”) of the battery module 102 ([0033]) and that the second element 172 (Ciaccio FIG. 1C) of the battery control system is an electrical voltage convertor (“DC/AC converter”, Ciaccio [0093]) (claim 2). Modified Roh further discloses that the electrical component of the battery control system is a cell connector (“connectors for electrical connection”, [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]) (claim 6). Regarding claim 13, modified Roh discloses the battery according to claim 1, wherein the first face (formed on the inside of first housing element 112) is remote from the second housing element 110, and the second face (formed on the top face of second housing element 110) is remote from the first housing element 112 (Annotated Roh FIG. 8) Regarding claim 14, modified Roh discloses the battery according to claim 13, wherein the first element of the battery control system comprises an electrical component (“connectors for electrical connection”, Roh [0018]) and/or an electronic component (“thermistors, controller”) of the battery module 102 ([0033]) and the second element 172 of the battery control system is a DC convertor 172 (“DC/AC converter”, Ciaccio [0093]). 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 (Annotated Roh FIG. 8). While Roh discloses metal as a preferable housing element material due to its thermal conductivity and mechanical rigidity ([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 this component through 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 discloses a general suitability of using 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]) (claims 4, 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 module cases (Roh FIGs. 1, [0055]) which are broadly and reasonably interpreted as prismatic battery cells (claims 5, 16). 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 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 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 (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 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]), (Annotated Roh FIG. 8). While Roh does not explicitly describe the radiator structure as being a flow guiding element (161) or as flow disturbing element (162), it would be recognized by a person having ordinary skill in the art that a fluid (i.e., temperature control fluid) necessarily comprises a laminar or turbulent flow regime, and 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], Annotated Roh FIG. 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], see copy of Annotated Roh FIG. 8 below) (claim 11). Roh in view of Ciaccio further discloses that the second element 172 of the battery control system is arranged in a thermally conductive manner to the inner face of the third housing element 610, said inner face of the third housing element 610 being arranged housing element being arranged directly adjacent to the second housing element 110 (Annotated Roh FIG. 8, Ciaccio [0093]) (claim 11). The portion of the third housing element 610 in thermal contact with the second element 172 of the battery control system, being configured for thermal conduction connection of the second element, is broadly and reasonably understood as the thermal contact area as claimed (Annotated Roh FIG. 8, Ciaccio [0093]) (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_image4.png 763 1150 media_image4.png Greyscale Copy of Annotated Roh FIG. 8 Claims 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 claims 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]) (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 (claims 7, 18) as taught by Ling. 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 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, or explicitly 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 (claim 18). 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 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. 8), 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, this configuration of passages reduces leakage ([0021]) and improves the battery’s durability and resistance to vibration by preventing a flywheel effect in the sealing flanges ([0017]), and 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 discloses a general suitability of providing coolant channels in hollow spaces of the housing elements ([0016]), e.g., the second housing element. Claims 1 and 23 are rejected under 35 U.S.C. 103 as being unpatentable over Roh in view of Lee, Ciaccio, Kurosawa, and Landerer. Regarding claim 1, 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]). 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 battery, teaches a first housing element 20 and a second housing element 10 which jointly form an inner chamber for 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 both the first and second housings of 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, and the first housing element 112 forms a first temperature control structure on a first face that is remote from the inner chamber 130 (see Annotated Roh FIG. 3 reproduced below, [0051], [0015]). PNG media_image1.png 318 882 media_image1.png Greyscale Annotated Roh FIG. 3 While Roh discloses a suitability of providing temperature control chambers (“refrigerant channels”) on outer faces of the housing elements ([0030]) and discloses a second embodiment (Roh FIGs. 7, 8) comprising a third housing element 610 (“first case member”) with a second temperature control chamber 613’ (FIG. 8) to improve uniformity and efficiency of heat exchange ([0065]), Roh fails to further disclose the first embodiment discussed above comprising a second housing element 110 jointly forming inner chamber 130 with the first housing element 112 (Roh FIG. 1) as having a second housing element 110 further connected to a separate third housing element as claimed. 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 an embodiment wherein the second housing element 40 is furthermore connected to a separate, third housing element 230 (“heat exchanger”) on a second face 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]). PNG media_image2.png 710 1069 media_image2.png Greyscale Annotated Roh FIG. 8 As such, in seeking to maintain the 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 combine elements of Roh’s first and second embodiments to connect modified Roh’s second housing element 110 (Roh FIG. 1) to a separate, third housing element 610 (Roh FIG. 7) on a second face that is remote from the inner chamber 130 (see Annotated Roh FIG. 8, reproduced above). Such a combination would be done with a reasonable expectation of success as Kurosawa teaches a suitability of connecting the second and third housing element on a face remote from the inner chamber for the purpose of performing heat exchange with the battery cells (Kurosawa FIG. 11), and Roh discloses a suitability of providing a temperature control chamber on an outer face of the second housing element. Additionally, while modified Roh discloses the use of the housing elements to protect and support electrical components (Roh [0017]), Roh does not specify use of the third housing element 610 to receive a second element of the battery control system specifically. 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 172 (“DC/AC converter”) of the 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 (Annotated Roh FIG. 8). 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 is recognized as the second temperature control structure (Annotated Roh FIG. 8). Furthermore, a portion of the third housing element 610 covering and connected to the inner face which limits the second temperature control chamber 613’ (“hollow space”) is recognized as the second covering element (see Annotated Roh FIG. 7 w/ Connections below, Annotated Roh FIG. 8) connected to the third housing element. The temperature control fluid flows in a fluid-tight manner through the second temperature control chamber 613’ ([0068]). The areas of the second covering element through which the temperature control fluid inlet/outlet 630/632 of the third housing element 610 passes are recognized as the connections as claimed ([0064], Annotated Roh FIG. 7 w/ Connections). PNG media_image5.png 700 2071 media_image5.png Greyscale Annotated Roh FIG. 7 with Connections While Roh envisions a general suitability of providing refrigerant channels to allow fluid conduction on any outer surface of the housing elements (“case members”) ([0029]), Roh fails to further indicate the connections may be connected to the second housing element 110 in a fluid conducting manner, or 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, this configuration of connections reduces leakage ([0021]) and improves the battery’s durability and resistance to vibration ([0017]), and 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 provide Roh’s second covering element with connections 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 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 ([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 (claims 1, 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, all the claimed elements were known in the prior art and one skilled in the art could have modified elements as claimed by known methods with no change in their respective functions, and would yield predictable results to one of ordinary skill in the art. Response to Arguments The abandonment of U.S. Application No. 16/848,948 in regards to the rejection of claims 1-11 and 13-20 on the ground of nonstatutory double patenting has been noted; the Double Patenting rejection has been withdrawn. Applicant’s arguments with respect to claim 1 and dependent claims 2-16, 18, and 21-23 have been considered but are moot because the arguments are drawn to the claim amendment which has necessitated new grounds of rejection discussed above. Conclusion 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 1/8/2026
Read full office action

Prosecution Timeline

May 10, 2022
Application Filed
Feb 03, 2025
Non-Final Rejection — §103, §DP
Apr 29, 2025
Examiner Interview Summary
Apr 29, 2025
Applicant Interview (Telephonic)
Apr 30, 2025
Response Filed
Jun 30, 2025
Final Rejection — §103, §DP
Aug 18, 2025
Request for Continued Examination
Aug 27, 2025
Response after Non-Final Action
Jan 07, 2026
Non-Final Rejection — §103, §DP (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12494537
BATTERY MODULE
2y 5m to grant Granted Dec 09, 2025
Patent 12381237
FUEL CELL STACK
2y 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

3-4
Expected OA Rounds
17%
Grant Probability
-2%
With Interview (-18.2%)
3y 7m
Median Time to Grant
High
PTA Risk
Based on 12 resolved cases by this examiner. Grant probability derived from career allow rate.

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