Prosecution Insights
Last updated: May 29, 2026
Application No. 17/751,054

AIRCRAFT BATTERY SYSTEMS

Non-Final OA §103§112
Filed
May 23, 2022
Priority
Jun 16, 2021 — GB 2108573.3
Examiner
SMITH, NICHOLAS A
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Rolls-Royce
OA Round
2 (Non-Final)
63%
Grant Probability
Moderate
2-3
OA Rounds
0m
Est. Remaining
95%
With Interview

Examiner Intelligence

Grants 63% of resolved cases
63%
Career Allowance Rate
578 granted / 912 resolved
-1.6% vs TC avg
Strong +32% interview lift
Without
With
+31.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
5 currently pending
Career history
929
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
77.9%
+37.9% vs TC avg
§102
9.2%
-30.8% vs TC avg
§112
3.9%
-36.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 912 resolved cases

Office Action

§103 §112
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 . Claim Rejections - 35 USC § 112 Due to Applicant’s Amendment, the previous 35 USC 112(b) rejection has been withdrawn. Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claim(s) 1-2, 5, 7,12 and 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim (US 20130140101 A1) in view of Dawley (US 20200403197 A1). In regards to claim(s) 1, Lim discloses a battery pack (9; Fig. 8) for an aircraft ([0020]), comprising: a battery module (5; Fig. 8; [0031]); and an air channel (the entirety of 11, portions over the battery modules 5 and outlet duct 33, see dashed arrows in Fig. 8 below), the air channel being connectable to an aircraft air inlet (a cooling air providing means 7 (e.g., a cooling fan 27) provided to supply cooling air; [0021]) and an aircraft air outlet (outlet duct 33 to discharge the cooling air to the outside of the vehicle body; [0033]), wherein at least a portion of a surface of the air channel is in thermal contact the battery module, whereby air flowing through the air channel exchanges heat with the battery cells through the surface of the air channel (cooling air that has already passed over each of the individual battery modules; claim 1). In regards to functional language or intended use limitations, such language only limits the claim by the structures or arrangements of structures that are necessary to perform the functional language or intended use. See MPEP 2112.01 I & 2114. In the instant case, claim terms “for an aircraft”, “connectable to an aircraft air inlet and an aircraft air outlet,” and “whereby, during flight of the aircraft, air enters the aircraft through the air inlet, passes through the battery pack air channel and exits the aircraft through the air outlet,” such limitations are considered intended use and do not further limit the structure of the instantly claimed invention. Furthermore, Lim discloses use of its battery pack in an aircraft ([0020]). While Lim discloses that the cooling air passing through the air channel passes over the battery modules (claim 1) and that the battery pack includes a plurality of battery cells ([0008]), Lim does not explicitly disclose that the battery module is a housing enclosing a plurality of battery cells, nor that the cooling air does not enter the housing and contact the battery cells, and wherein the air flows from the air inlet to the air outlet without entering the housing and without contacting the battery cells. PNG media_image1.png 490 640 media_image1.png Greyscale Dawley pertains to battery packs for aircraft ([0039]-[0040]) and is therefore in the same field of endeavor as Lim. Dawley discloses a battery module (100) includes a housing (112) and multiple battery cells (120), wherein the battery cells are be mounted in the housing (abstract) as illustrated in Fig. 2. PNG media_image2.png 414 608 media_image2.png Greyscale It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery module of Lim to have Dawley’s housing with a plurality of batter cells in order to provide a high-voltage battery pack (Dawley, [0041]), which is useful for powering vehicles, including aircraft. As combined, the cooling air of Lim would not contact the plurality of battery cells inside the housing. In regards to claim(s) 2, Lim disclose the air channel (down arrows in Fig. 8) is separated by dividing walls (walls that go up and down and connected to the “inlet” of individual ducts 29), going to “the outlet” that connects to duct 33. In regards to claim(s) 5, Lim discloses one or more additional channels (down arrows in Fig. 8) that are in parallel Lim disclose the air channel (down arrows in Fig. 8) is separated by dividing walls (walls that go up and down and connected to the “inlet” of individual ducts 29), going to “the outlet” that connects to duct 33. In regards to functional language or intended use limitations, such language only limits the claim by the structures or arrangements of structures that are necessary to perform the functional language or intended use. See MPEP 2112.01 I & 2114. In the instant case, claim term “arranged to carry a flow of liquid” would mean the channel would be capable of having liquid flowing therethrough, and thus does not structurally distinguish the structure from the prior art. In regards to claim(s) 7, Lim in view of Dawley discloses wherein each of the plurality of battery cells exist between ends, the first end of each battery cell in proximity to the surface of the air channel. In regards to claim(s) 12, Lim discloses integral formation of the housing and the air channel (Figs. 1, 2, 4 and 7). In regards to claim(s) 14, Lim discloses the air channel extends the entire length of the battery pack (Fig. 7). Claim(s) 3-4, 13, 15-17 and 19-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim in view of Dawley, and in further view of Donovan (US 20220250508 A1). In regards to claim(s) 3, Lim does not disclose wherein an aspect ratio of each of the plurality of air channels height to width is between 1.1 and 1.6. Donovan pertains to cooling a battery module in an electric aircraft (abstract), and is therefore in the same field of endeavor as Lim and Dawley. Donovan discloses a thermal conduit 132 located between two arrays of battery cells (120, 124, Fig. 1; [0033]), where the conduit may be elongated rectangular, wherein the thermal conduit may include a plurality of passageways or lumen, which are created by dividing walls. The number of diving walls is not particularly limited, so the disclosed range is considered to be from 1 to any practicable number. Such a discloses range would range a low number aspect ratio (no dividing walls) to a higher number aspect ratio (many dividing walls). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the air channel of Lim with Donovan’s range of plurality of dividing walls because all claimed elements were known, each element merely performs the same function as it does separately (cooling) and one of ordinary skill in the art would have recognized that the results of the combination were predictable. See MPEP 2143 I (A). Furthermore, Donovan discloses the range of low to high aspect ratios which overlaps the instantly claimed range of 1.1 to 1.6 and therefore establishes a case of prima facie obviousness. See MPEP 2144.05 I. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to select the claimed range from the broader prior art range because prior art teaches the same utility over the entire range. In regards to claim(s) 4, Lim discloses a plurality of battery modules (reading on first and second arrays), but does not disclose the air channel going between the first and second arrays. Donovan pertains to cooling a battery module in an electric aircraft (abstract), and is therefore in the same field of endeavor as Lim and Dawley. Donovan discloses a thermal conduit 132 located between two arrays of battery cells (120, 124, Fig. 1; [0033]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the air channel of Lim with Donovan’s thermal conduit between 2 arrays of cells because all claimed elements were known, each element merely performs the same function as it does separately (cooling) and one of ordinary skill in the art would have recognized that the results of the combination were predictable. See MPEP 2143 I (A). In regards to claim(s) 13, Lim in view of Dawley does not disclose the air channel and housing are made of extruded aluminum. Donovan discloses utilizing aluminum, including using the process of extrusion ([0034]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the air channel of Lim with Donovan’s extruded aluminum because all claimed elements were known, each element merely performs the same function as it does separately (cooling) and one of ordinary skill in the art would have recognized that the results of the combination were predictable. See MPEP 2143 I (A). In regards to claim(s) 15, Lim in view of Dawley does not disclose an aircraft. Donovan discloses an aircraft (Fig. 9). Donovan discloses wherein the aircraft may include cowl flaps incorporated onto the media channel and/or the exterior of the battery pack and electric aircraft to circulate outside airflow during flight ([0024]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to place the battery pack of Lim in view of Dawley into Donovan’s aircraft because all claimed elements were known, each element merely performs the same function as it does separately (cooling) and one of ordinary skill in the art would have recognized that the results of the combination were predictable. See MPEP 2143 I (A). Additionally, Donovan teaches this allows for preconditioning during flight to expel high temperature media out ([0024]). In regards to claim(s) 16, Donovan’s cowl flaps can be activated and thus are an adjustable regulator ([0024]). In regards to claim(s) 17, Donovan discloses the thermal regulation system is reconfigurable with either a circulation (“The media channel is a hollow passage for which the media can be circulated in and out of the battery pack.” [0024]) or a flow through the channel (“This is so, at least in part, if the battery pack needs to be preconditioned during flight, the cowl flaps can be activated to open and expose the media channel for outside air to enter for airflow circulation and expel high temperature media out. In another embodiment, the supplemental cooling component that may be used to store excess media may reach its maximum capacity in which it must evacuate the excess media. The cowl flaps may allow for the excess media to evacuate the battery pack and the electric aircraft.”; [0024]). In regards to claim(s) 19, Donovan doesn’t explicitly disclose the location of the battery pack, however, due to the configuration shown in Fig. 9, the battery pack, with its relatively high weight, would necessarily need to coincide with the aircraft’s center of gravity in order to stably achieve flight. In regards to claim(s) 20, Donovan discloses eVTOL ([0003]). Claim(s) 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim in view of Dawley, and in further view of Rainville (US 20220285753 A1). In regards to claim(s) 6, Lim in view of Dawley does not disclose wherein a cross-sectional area of each of the one or more additional channels is smaller than a cross-sectional area of the air channel. Rainville pertains to aircraft battery pack (abstract) and is therefore in the same field of endeavor as Lim and Dawley. Rainville discloses liquid cooling channel (608; Figs. 10 and 12) which has a smaller cross-section than the air channel (116; Fig. 2; [0025]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery pack of Lim in view of Dawley to include the additional cooling channels of Rainville (which are smaller in cross-sectional area) because Rainville teaches such allows for effective cooling via a cooling loop (Rainville, [0035]). Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim in view of Dawley, and in further view of Hull (US 20220376363 A1). In regards to claim(s) 8, Lim in view of Dawley does not disclose wherein each battery cell is arranged to vent from its second end into a venting region. Hull pertains to battery systems for aircraft (abstract) and is therefore in the same field of endeavor as Lim and Dawley. Hull discloses a vent system ([0049]; Fig. 7; 236) for each of the battery cells. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery pack of Lim in view of Dawley with Hull’s vent system because such allows release of gas generated from a thermal runaway (Hull, [0049]). Claim(s) 9-11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim in view of Dawley, in further view of Hull and in further view of Wang (US 20220123423 A1). In regards to claim(s) 9, Lim in view of Dawley and Hull does not disclose wherein a vent is in a cap region. Wang pertains to aircraft battery systems ([0075]) and is therefore in the same field of endeavor as Lim, Dawley and Hull. Wang discloses a baffle plate (cap, [0008}). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery pack of Lim in view of Dawley and Hull with Wang’s baffle plate because Wang teaches that such allows for an exit of a state of sealing the exhaust vent when the explosion-proof valve of the battery bursts (Wang, [0010]). In regards to claim(s) 10, modified Lim discloses the a path that allows the thermal products to be vented from the second ends of the battery cells. In regards to claim(s) 11, Wang’s baffle plate with an explosion-proof valve is a pressure sensitive element configured to seal the venting region until a pressure in the venting region exceeds a threshold level. Claim(s) 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim in view of Dawley, and in further view of Demont (US 20210083255 A1). In regards to claim(s) 15, Lim in view of Dawley does not disclose an aircraft. Demont pertains to battery systems in aircraft ([0069]) and is therefore in the same field of endeavor as Lim and Dawley. Demont discloses an aircraft (100; Fig. 1a; [0069]) with inlets (106) and exhausts (108). Demont discloses that “during operation of the aircraft 100 or when the power sources 104 may be supplying power, the airflow 102 can flow into the aircraft 100 from one of the inlets 106 (which can be locations of relatively higher pressure), pass in or around one or more of the power sources 104, and next pass out one of the exhausts 108 (which can be locations of relatively lower pressure). The airflow 102 can cool the one or more the power sources 104 or facilitate expulsion of heat or combustion components from the aircraft 100 in the event of a fire at the one or more of the power sources 104.” ([0070]). See also fig. 1b ([0076]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to place the battery pack of Lim in view of Dawley into Demont’s aircraft because all claimed elements were known, each element merely performs the same function as it does separately (cooling) and one of ordinary skill in the art would have recognized that the results of the combination were predictable. See MPEP 2143 I (A). Claim(s) 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim in view of Dawley and Donovan, and in further view of Rainville. In regards to claim(s) 18, while Donovan discloses the battery pack in the aircraft as a eVTOL, it does not disclose that the battery pack is in a tiltable portion, along with additional channels arranged to carry a flow of liquid. Rainville pertains to aircraft battery pack (abstract) and is therefore in the same field of endeavor as Lim and Dawley. Rainville discloses liquid cooling channel (608; Figs. 10 and 12) in addition to the air channel (116; Fig. 2; [0025]). Rainville discloses tiltable/orientation VTOLs (Fig. 1, Fig. 8), and that the battery pack with cooling system is located in the tiltable thrust module (102; Fig. 2; [0024]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery pack of Lim in view of Dawley to include the additional cooling channels of Rainville (which are smaller in cross-sectional area) because Rainville teaches such allows for effective cooling via a cooling loop (Rainville, [0035]). As combined, the liquid channels would be capable of forming a non-zero angle to the horizontal. Response to Arguments Applicant's arguments filed 24 June 2025 have been fully considered. Due to Applicant’s Amendments, new prior art has been applied, please see new grounds of rejection above. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to NICHOLAS A SMITH whose telephone number is (571)272-8760. The examiner can normally be reached M-F 7:30am-3:30pm. 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, Srilakshmi Kumar can be reached at (571)272-7769. 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. /NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
Read full office action

Prosecution Timeline

May 23, 2022
Application Filed
Jun 05, 2025
Non-Final Rejection mailed — §103, §112
Jun 24, 2025
Response Filed
Oct 21, 2025
Final Rejection mailed — §103, §112
Jan 05, 2026
Response after Non-Final Action
May 04, 2026
Response after Non-Final Action

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Prosecution Projections

2-3
Expected OA Rounds
63%
Grant Probability
95%
With Interview (+31.8%)
3y 3m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 912 resolved cases by this examiner. Grant probability derived from career allowance rate.

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