Prosecution Insights
Last updated: April 19, 2026
Application No. 17/745,956

BATTERY MODULE

Non-Final OA §101§103
Filed
May 17, 2022
Examiner
ARMSTRONG, KAREN JOYCE
Art Unit
1726
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Samsung Electronics
OA Round
3 (Non-Final)
79%
Grant Probability
Favorable
3-4
OA Rounds
3y 5m
To Grant
91%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allow Rate
15 granted / 19 resolved
+13.9% vs TC avg
Moderate +12% lift
Without
With
+11.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
58 currently pending
Career history
77
Total Applications
across all art units

Statute-Specific Performance

§101
1.2%
-38.8% vs TC avg
§103
59.1%
+19.1% vs TC avg
§102
25.7%
-14.3% vs TC avg
§112
12.2%
-27.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 19 resolved cases

Office Action

§101 §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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 10/20/2025 has been entered. Response to Amendments In view of the amendment to claim 1 the rejection of claims 1-13 under 35 U.S.C. 112(a) has been withdrawn and the claim objection has been withdrawn. The rejection of claims 1-13 under 35 U.S.C. 103 is maintained and the addition of claim 14 has been acknowledged. Response to Arguments The arguments filed on 10/20/2025 have been fully considered but are not persuasive. Applicant argues that the prior art does not teach a fixing part that fixes the holder to the seating part of a busbar, particularly arguing that first and second surfaces 15a/15b of An's busbar cannot be interpreted as the seating part, as they are not positioned on the holder. It is respectfully pointed out that the rejection does not rely on 15a/15b of An to be the seating part. Matsunaga is relied upon to teach the busbar shape that includes the seating part and connecting part, as pointed out in the final rejection. An is relied upon to teach the fixing part as recited in the claim, which extends in its entirety along an edge of the seating part, covering a portion of the edge of the seating part. In response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., the fixing part does not extend to the opening of the holder to connect to an electrode) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1-3, 6, and 9-13 are rejected under 35 U.S.C. 103 as being unpatentable over Seto et al., US 2015/0243947 A1 (hereinafter “Seto”) in view of Matsunaga et al., US 2022/0355406 A1 (hereinafter “Matsunaga”) and An et al., KR 2020 0102189 A (hereinafter “An”). Regarding claim 1, Seto discloses a battery module (i.e., power supply device) [ ¶ 0056], comprising: at least one battery cell (i.e., battery cell 1) [¶ 0057] including an electrode terminal (i.e., electrode terminals 21) [¶ 0061]; a holder (i.e., bus bar holder 8) adjacent to the at least one battery cell (note: Seto Figs. 1-2 show the bus bar holder 8 adjoining the cells 1), the holder having an opening at a position corresponding to the electrode terminal (i.e., the opening windows 24 are opened in order to expose and connect the electrode terminals 21), at least one busbar (i.e., bus bars 30) electrically connected to the electrode terminal through the opening of the holder (i.e., the bus bar 30 is welded to the electrode portion 20 [on terminals 21]) [¶ 0067]; Seto is silent regarding the busbar comprising a seating part and a connection part extending from the seating part, the seating part being positioned on the holder, and the connection part being electrically connected to the electrode terminal through the opening of the holder. However, in the same field of endeavor, Matsunaga discloses a battery module (i.e., battery pack 100) [Matsunaga at ¶ 0021], comprising a plurality of battery cells (i.e., battery cells 120) [¶ 0022] including an electrode terminal (i.e., terminals 121) [ ¶ 0024] and at least one busbar (i.e., plurality of bus bars 2) [¶ 0025], including: a seating part (see Annotated Figure 1 below) and a connecting part (see Annotated Figure 1 below) extending from the seating part (see Annotated Figure 1 below) PNG media_image1.png 513 979 media_image1.png Greyscale Annotated Figure 1: Bus bar 2 of Matsunaga (annotated form of Matsunaga Fig. 3) Seto and Matsunaga are analogous art because both are drawn to multi-cell battery packs wherein the individual cells are connected in series via busbars. One having ordinary skill in the art would have understood that substituting the bus bar of Matsunaga for the bus bar of Seto would have yielded the predictable result of a battery pack with multiple cells electrically connected via bus bars. See MPEP § 2143(I)(B). Therefore, it would have been obvious to have substituted the bus bar of Matsunaga for the bus bar of Seto in order to yield the predictable result of a battery pack with multiple cells electrically connected via bus bars. Seto is further silent regarding a fixing part that extends in its entirety along an edge of the seating part. However, in the same field of endeavor. An, related to battery modules with bus bars, discloses a battery module featuring a plurality of U-shaped busbars (15) [Fig. 1] slotted into a holder comprising a fixing part (i.e., assembly part 180) [Figs. 1 and 3] that extends, in its entirety, along an edge of the seating part of the busbar (i.e., the two coplanar surfaces on the left and right of the U-shaped busbar 15) [see Fig. 1]. The fixing part (assembly part 180) is integrated with the holder (100) [Fig. 1]. An also depicts that the fixing part (i.e., 180) directly contacts the busbar 15 and its seating part 15a [see Figs. 3-4]. An also teaches such an attachment method results in the reduction of stress between the connection points in the bus bar [¶ 0034]. Therefore, it would have been obvious to one of skill in the art, as of the effective filing date of the claimed invention, to install the fixing part (i.e., assembly parts) of An to the battery device of Seto with the expectation to produce a battery pack with a plurality of bus bars affixed into a holder with reduced stress. Regarding claim 2, modified Seto teaches all limitations of claim 1. Matsunaga further depicts that the busbar: has a U-shape (see Annotated Figure 1 above), two ends of the U-shape constituting the connection part (see Annotated Figure 1 above), and an intermediate portion between the two ends of the U-shape constituting the seating part (see Annotated Figure 1 above). Regarding claim 3, modified Seto teaches all limitations of claim 1. Matsunaga further teaches: the at least one battery cell includes a plurality of battery cells adjacent to each other along a first direction [Fig. 1 and ¶ 0022], a plurality of bus bars [Matsunaga at ¶ 0025], at least one busbar includes a plurality of plurality of busbars adjacent to each other along the first direction, the plurality of busbars being alternately arranged upside down vertically to cross each other (see Matsunaga Fig. 2, which shows the bus bars groups 2A and 2B arranged upside-down with reference to one another) Regarding claim 6, Seto as modified by Matsunaga teach all limitations of claim 1. Matsunaga further teaches: at least one busbar further includes a stress relaxation part (see Annotated Figure 1 above) between the seating part and the connection part, the stress relaxation part being an inwardly cut at an edge of the at least one busbar (see Annotated Figure 1 above). The stress relaxation part of Matsunaga is rectangular and therefore does not have “a predetermined curvature radius”; however, absent persuasive evidence that a particular shape or configuration is significant, the specific shape or configuration of the claimed device is a matter of choice which a person of ordinary skill in the art would have found obvious over the prior art device (In re Dailey, 357 F.2d 669, 149 USPQ 47 (CCPA 1966); see MPEP § 2144.04(IV)(B)). Therefore, claim 6 is rendered prima facie obvious over Matsunaga. Regarding claim 9, modified Seto teaches all the limitations of claim 1. An depicts that the entire length of the fixing part (i.e., 180) directly contacts the busbar 15 and its seating part 15a [see Figs. 3-4]. Furthermore, changes in size or proportion, in this case the length of the fixing part, does not render the claimed subject matter patentably distinct from the prior art. M.P.E.P. § 2144.05 IV. A. Regarding claim 10, modified Seto teaches all the limitations of claim 1. An depicts that the fixing part (i.e., 180) is disposed to contact only the edge of the seating part 15a of busbar 15 [Fig. 3]. Regarding claim 11, modified Seto teaches all the limitations of claim 1. An depicts that each one of the plurality of busbars 15 has its own fixing part 180, meaning that they would necessarily be separate [Fig. 2a]. Regarding claim 12, modified Seto teaches all the limitations of claim 1. An depicts that each of the busbars 13 spans across the top of three adjacent cells, connecting every other battery [Fig. 1]. Regarding claim 13, modified Seto teaches all the limitations of claim 1. Matsunaga depicts that one of the two ends of the U-shape constituting the connection part of one of the plurality of busbars is between the two ends of the U-shape constituting the connection part of an adjacent one of the plurality of busbars [see arrangement of busbars in Fig. 3; note that “adjacent” can apply in both the indicated x and y directions]. Claims 4-5 are rejected under 35 U.S.C. 103 as being unpatentable over Seto et al., US 2015/0243947 A1 (hereinafter “Seto”) in view of Matsunaga et al., US 2022/0355406 A1 (hereinafter “Matsunaga”) and An et al., KR 2020 0102189 A (hereinafter “An”), as applied to at least claim 1 above, and further in view of Silva et al., US 2022/0332619 A1 (hereinafter “Silva”). Silva qualifies as prior art under 35 USC § 101(a)(2) with its effectively filed date of 16 September 2020. Regarding claim 4, Seto as modified by Matsunaga teach all limitations of claim 1 but are silent regarding the trapezoidal shape of the busbar. Silva, battery cells connected via busbars, discloses a power storage and salt water cleaning system that comprises a plurality of battery cells (i.e., plurality of electrochemical cells) [¶ 0043] connected via busbars (i.e., metal busbar) [¶ 0053] to form a battery module [¶ 0043]. Silva continues to discuss that the dimensions of the busbar are a product of the current provided by the battery module [¶ 0053] and that the busbar may have a trapezoidal shape [¶ 0053]. One of ordinary skill in the art would have recognized providing a trapezoidal shape to the connecting portion of the busbar of Matsunaga would have created more uniform cross-section across the conduction path of the busbar in order to tailor the busbar to the current provided by the battery pack, as suggested by Silva [at ¶ 0053]. An example of such a modification is shown in Annotated Figure 2 below. Therefore, it would have been obvious to a skilled artisan, as of the effective filing date of the claimed invention, to provide a trapezoidal shape to the connecting portion of the busbar of Matsunaga to provide a more uniform structure. PNG media_image2.png 519 1161 media_image2.png Greyscale Annotated Figure 2: Busbar of Matsunaga with trapezoidal shape suggested by Silva. Regarding claim 5, Seto as modified by Matsunaga and Silva disclose all limitations of claim 4. As shown in Annotated Figure 2 above, the fixing part is disposed along both hypotenuses of the isosceles trapezoid of the seating part. Claim 5 is thereby rendered prima facie obvious over Seto, Matsunaga, and Silva. Claims 7-8 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Seto et al., US 2015/0243947 A1 (hereinafter “Seto”) in view of Matsunaga et al., US 2022/0355406 A1 (hereinafter “Matsunaga”) and An et al., KR 2020 0102189 A (hereinafter “An”), as applied to at least claim 1 above, and further in view of Kim et al., KR 2020-0109128-A (hereinafter “Kim”). Kim qualifies as prior art under 35 USC § 101(a)(1) with its publication (public availability) date of 22 September 2020. An English translation of Kim is attached to this Detailed Action; all quotations from and references to Kim refer to the attached provided English translation. Regarding claim 7, Seto as modified by Matsunaga teach all limitations of claim 1 but are silent regarding the positioning part and the engagement part. Kim, related to battery cells connected via busbars, discloses a bus bar (i.e., bus bar 201) [¶ 0038] having a recessed edge as shown in Fig. 7 (¶ 0056), disposed to engage with an overmolded insulation layer [¶ 0036] One of ordinary skill in the art would have recognized providing recesses in the seating part to positively engage with an overmolded fixing part would positively affix the overmolded layer and prevent slippage. Therefore would have been obvious to a skilled artisan, as of the effective filing date of the claimed invention, to provide recesses in the seating part of modified Seto to positively engage with an overmolded fixing part to prevent slippage. Regarding claims 8 and 14, Seto as modified by Matsunaga teach all limitations of claim 1 but are silent regarding an overmolded fixing part. As discussed in the context of claims 7 above, Kim discloses a bus bar that is overmolded [ ¶ 0056] with a resin (e.g., polyamide) [¶ 0036] with the resin extending onto the surrounding area, in this case the holder [¶ 0055, Fig. 2]. The artisan would have been motivated to add overmolding to the bus bar of Matsunaga in order to add a layer of electrical insulation to the busbar, as polyimide resins are not conductive. One of ordinary skill in the art would also have recognized the overmolding process would have caused the entirety of the fixing part to be directly connected to the busbar and holder and not be detachable without significant deformation as described in the instant specification [¶ 0039]. Therefore, claim 8 is rendered prima facie obvious over Seto, Matsunaga, and Kim. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to KAREN J. ARMSTRONG whose telephone number is (703)756-1243. The examiner can normally be reached Monday-Friday 10 am-6 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, Jeffrey Barton can be reached at (571) 272-1307. 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. /K.J.A./Examiner, Art Unit 1726 /JEFFREY T BARTON/Supervisory Patent Examiner, Art Unit 1726 12 January 2026
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Prosecution Timeline

May 17, 2022
Application Filed
Jan 06, 2025
Non-Final Rejection — §101, §103
Apr 11, 2025
Response Filed
Jul 16, 2025
Final Rejection — §101, §103
Sep 16, 2025
Response after Non-Final Action
Oct 20, 2025
Request for Continued Examination
Oct 21, 2025
Response after Non-Final Action
Jan 12, 2026
Non-Final Rejection — §101, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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ZINC-BROMINE FLOW BATTERY INCLUDING CONDUCTIVE INTERLAYER
2y 5m to grant Granted Jan 13, 2026
Patent 12519157
HOUSING FOR A TRACTION BATTERY
2y 5m to grant Granted Jan 06, 2026
Patent 12512502
METHOD OF MANUFACTURING BATTERY
2y 5m to grant Granted Dec 30, 2025
Patent 12492095
APPARATUS FOR MANUFACTURING ELECTRODE ASSEMBLY, ELECTRODE ASSEMBLY MANUFACTURED THERETHROUGH, AND SECONDARY BATTERY
2y 5m to grant Granted Dec 09, 2025
Patent 12482894
SEALING PLATE EQUIPPED WITH GAS DISCHARGE VALVE AND SECONDARY BATTERY USING THE SAME
2y 5m to grant Granted Nov 25, 2025
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
79%
Grant Probability
91%
With Interview (+11.9%)
3y 5m
Median Time to Grant
High
PTA Risk
Based on 19 resolved cases by this examiner. Grant probability derived from career allow rate.

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