Prosecution Insights
Last updated: July 17, 2026
Application No. 17/770,255

ENERGY STORAGE APPARATUS

Non-Final OA §102§103§112
Filed
Apr 19, 2022
Priority
Oct 23, 2019 — JP 2019-192444 +4 more
Examiner
NEDIALKOVA, LILIA V
Art Unit
1724
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Gs Yuasa International Ltd.
OA Round
3 (Non-Final)
55%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
78%
With Interview

Examiner Intelligence

Grants 55% of resolved cases
55%
Career Allowance Rate
240 granted / 434 resolved
-9.7% vs TC avg
Strong +22% interview lift
Without
With
+22.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
38 currently pending
Career history
481
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
80.7%
+40.7% vs TC avg
§102
7.0%
-33.0% vs TC avg
§112
2.3%
-37.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 434 resolved cases

Office Action

§102 §103 §112
DETAILED ACTION 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 November 11, 2025 has been entered. Claims 1-14, 20, 22 and 23 are currently amended. Claims 26 and 27 are newly added. Claims 1-14, 20, 22, 23, 26 and 27 are pending review in this action. The previous 35 U.S.C 112 rejections are withdrawn in light of Applicant’s corresponding amendments. New grounds of rejection necessitated by Applicant’s amendments are presented below. Election/Restrictions In view of applicant’s amendments and in pursuit of compact prosecution, the restriction requirement directed to claims 20, 22 and 23 is withdrawn. Claims 20, 22 and 23 are fully examined for patentability as detailed below. Claim Objections Claim 6 is objected to because of the following informalities. Line 5 of the claim recites the limitation “the substrate”. To maintain consistency with the rest of the claims, the limitation should be edited to read “the circuit substrate”. Claim 22 is objected to because of the following informalities. Lines 2-3 of the claim recite the limitation “a second direction”. Claim 22 depends on claim 20. Claim 20 defines “a second direction”. To avoid potential ambiguity, the limitation of lines 2-3 should be edited to read “the second direction”. Claim 23 is objected to because of the following informalities. Line 3 of the claim recite the limitation “a third direction”. Claim 23 depends on claim 20. Claim 20 defines “a third direction”. To avoid potential ambiguity, the limitation of line 3 should be edited to read “the third direction”. Appropriate correction is required. Claim Rejections - 35 USC § 112(b) The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claim 5 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 5 recites the limitation "the lower side" on line 3. There is insufficient antecedent basis for this limitation in the claim. Claim Rejections - 35 USC § 102 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 1-5 and 26 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by U.S. Pre-Grant Publication No. 2019/0036091, hereinafter Lee. Regarding claim 1, Lee teaches a battery pack (10, “energy storage apparatus”) (paragraph [0038]). The battery pack (10, “energy storage apparatus”) comprises a battery module (100, “energy storage unit”). The battery module (100, “energy storage unit”) includes a battery cell (“energy storage device”) (paragraphs [0039, 0041]). The battery pack (10, “energy storage apparatus”) comprises a second inner case (236, “substrate box”). The second inner case (236, “substrate box”) is a separate member from the battery module (100, “energy storage unit”). The second inner case (236, “substrate box”) includes a BMS (300, “circuit substrate”) accommodated inside an enclosure with the battery module (100, “energy storage unit”) disposed outside of the enclosure (paragraphs [0049, 0058] and figures 2 and 11). The enclosure is defined by case cover (250) and second inner case (236) (figure 11). BMS (300, “circuit substrate”) is electrically connected to the battery module (100, “energy storage unit”) to monitor the state of the battery cell (“energy storage device”) (paragraph [0062]). A first direction is defined as a direction in which the second inner case (236, “substrate box”) and the battery module (100, “energy storage unit”) are arranged. A second direction is defined as a direction orthogonal to the first direction and a third direction is defined as a direction orthogonal to the first direction and the second direction (Figure 1 below). PNG media_image1.png 743 734 media_image1.png Greyscale [AltContent: textbox (Figure 1 - Indicating the three directions in Lee's assembly.)] The battery pack (10, “energy storage apparatus”) may be rotated so that the second direction is a “vertical direction”. The enclosure includes a handle (700) to grip and move the battery pack (10, “energy storage apparatus”) (paragraphs [0039, 0087] and figures 9 and 10). The handle (700) includes a recess with an opening in the second direction. The handle (700) includes a first wall portion facing the battery module (100, “energy storage unit”) in the first direction and a second wall portion facing toward the third direction (Figure 2 below). The second wall portion is disposed between the first wall portion and the battery module (100, “energy storage unit”). The recess is formed by being surrounded by the first wall portion and the second wall portion (Figure 2 below). PNG media_image2.png 529 797 media_image2.png Greyscale [AltContent: textbox (Figure 2 – Close-up of the handle portion of Lee’s assembly. The figure is annotated to indicate claimed features related to the handle (700). (The second direction is “into the page”).)] When the battery pack (10, “energy storage apparatus”) is rotated such that the second direction is a vertical direction, the handle (700) is disposed at a lower end of the enclosure in the second direction. When the battery pack (10, “energy storage apparatus”) is rotated such that the second direction is a vertical direction, the handle (700) is located below the BMS (300, “circuit substrate”) in the second direction. Regarding claim 2, Lee teaches that the second inner case (236, “substrate box”) is attached to an end of outer case (234) in a longitudinal direction (along the second direction) of the battery module (100, “energy storage unit”) (figure 11). Regarding claim 3, Lee teaches that the handle (700) is disposed at a position closer to a bottom of the battery pack (10, “energy storage apparatus”) in the second direction than a part of the battery module (100, “energy storage unit”). Regarding claim 4, Lee teaches that the recess is formed in a surface facing the battery module (100, “energy storage unit”) (Figure 2 above). Regarding claim 5, Lee teaches that the handle includes an inclined surface in a surface facing the battery module (100, “energy storage unit”), that is away from the battery module (100, “energy storage unit”) and slopes toward a lower side in the second direction (Figure 3 below). PNG media_image3.png 721 703 media_image3.png Greyscale [AltContent: textbox (Figure 3 - Lee's assembly shown oriented such that the 2nd direction is a “vertical direction”. Also showing the inclined surface.)] Regarding claim 26, Lee teaches that the enclosure includes a second inner case (236, “substrate holder”) that is disposed between the battery module (100, “energy storage unit”) and the BMS (300, “circuit substrate”) to hold the BMS (300, “circuit substrate”). The enclosure also includes a case cover (250) attached to the second inner case (236, “substrate holder”) (paragraph [0058]). Lee teaches applying a sealant between the case cover (250) and the second inner case (236, “substrate holder”). Even with the sealant, the case cover (250) is capable of being removed to access the BMS (300, “circuit substrate”) and is thus considered “openably attached”. 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 6-14 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pre-Grant Publication No, hereinafter in view of U.S. Pre-Grant Publication No. 2019/0036091, hereinafter Lee as applied to claim 1 above and further in view of U.S. Pre-Grant Publication No. 2018/0151857, hereinafter Gang. Regarding claim 6, Lee teaches that the enclosure includes a second inner case (236, “substrate holder”) that is disposed between the battery module (100, “energy storage unit”) and the BMS (300, “circuit substrate”) to hold the BMS (300, “circuit substrate”). The enclosure also includes a case cover (250) attached to the second inner case (236, “substrate holder”) (paragraph [0058]). Lee’s figure 11 shows various openings, which suggest the use of screws or bolts to attach the case cover (250) to the second inner case (236, “substrate holder”). Lee fails to teach a first cover attaching part rotatably attached to the second inner case (236, “substrate holder”). The use of bolts to secure a case to a lid is well-known in the art. See, e.g. the Gang reference (commonly owned and sharing inventors with Lee) which teaches coupling a cover (30) to a case body (20) by using bolts (paragraphs [0070, 0073] and figure 4). Therefore it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to attach the case cover (250) to the second inner case (236, “substrate holder”) via bolts for the purpose of forming a secure connection. A bolt is secured by rotating – therefore, a bolt in the combination of Lee and Gang is a “first cover attaching part” rotatably attached to the second inner case (236, “substrate holder”). Regarding claim 7, Lee as modified by Gang teaches multiple bolts (“first cover attaching part”) along the periphery of the second inner case (236, “substrate holder”) and thus disposed at a position closer to a bottom of the battery pack (10, “energy storage apparatus”) than a center position of the case cover (250). Regarding claim 8, Lee as modified by Gang teaches that the second inner case (236, “substrate holder”) includes a hole (“holder attaching part”) to which the bolt (“first cover attaching part”) is attached. The bolt (“first cover attaching part”) is disposed in a direction from the case cover (250) toward the second inner case (236, “substrate holder”) with respect to the hole (“holder attaching part”). Regarding claim 9, Lee as modified by Gang teaches that the case cover (250) includes a second bolt (“second cover attaching part”) that is attached to the second inner case (236, “substrate holder”) by engaging the second inner case (236, “substrate holder”). Regarding claim 10, Lee as modified by Gang teaches a bolt screwed into the case cover (250). As such, an outside surface of the case cover (250) serves as a “rotation regulating unit part” because it limits the degree to which the bolt can progress through the case cover (250) and thus restricts rotation beyond a defined limit. Regarding claim 11, Lee teaches that the enclosure includes a second inner case (236, “substrate holder”) that is disposed between the battery module (100, “energy storage unit”) and the BMS (300, “circuit substrate”) to hold the BMS (300, “circuit substrate”). The second inner case (236, “substrate holder”) is attached to outer case (234) of the battery module (100, “energy storage unit”) (paragraph [0058]). Lee’s figures 2 and 11 shows various openings, which suggest the use of screws or bolts to attach the second inner case (236, “substrate holder”) to outer case (234) of the battery module (100, “energy storage unit”). Lee fails to teach a first substrate attaching part rotatably attached to the outer case (234) of the battery module (100, “energy storage unit”). The use of bolts to secure elements of a battery housing to each other is well-known in the art. See, e.g. the Gang reference (commonly owned and sharing inventors with Lee) which teaches coupling a cover (30) to a case body (20) by using bolts (paragraphs [0070, 0073] and figure 4). Therefore it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to attach the second inner case (236, “substrate holder”) to outer case (234) of the battery module (100, “energy storage unit”) via bolts for the purpose of forming a secure connection. A bolt is secured by rotating – therefore, a bolt in the combination of Lee and Gang is a “first substrate attaching part” rotatably attached to outer case (234) of the battery module (100, “energy storage unit”). Regarding claim 12, Lee as modified by Gang teaches multiple bolts (“first cover attaching part”) along the periphery of the outer case (234) and thus disposed at a position closer to a bottom of the battery pack (10, “energy storage apparatus”) than a center position of the second inner case (236, “substrate holder”). Regarding claim 13, Lee as modified by Gang teaches that the outer case (234) of the battery module (100, “energy storage unit”) includes a hole (“energy storage attaching part”) to which the bolt (“first substrate attaching part”) is attached. The bolt (“first substrate attaching part”) is disposed at a position closer to the bottom of the case cover (250) than the hole (“energy storage attaching part”). Regarding claim 14, Lee as modified by Gang teaches that the second inner case (236, “substrate holder”) includes a second bolt (“second substrate attaching part”) that is attached to the outer case (234) of the battery module (100, “energy storage unit”) by engaging with the outer case (234) of the battery module (100, “energy storage unit”). Claims 1, 3-10, 20, 22, 23, 26 and 27 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pre-Grant Publication No. 2011/029400, hereinafter Kim in view of U.S. Patent No. 4,752,543, hereinafter Andersen. Regarding claim 1, Kim teaches a battery pack (100, “energy storage apparatus”) (paragraph [0023] and figure 1A). The battery pack (100, “energy storage apparatus”) comprises a battery cell array (“energy storage unit”). The battery cell array (“energy storage unit”) includes a battery cell (170, “energy storage device”) (paragraph [0036] and figure 4). Housing (110) is a “substrate box” that is a separate member from the battery cell array (“energy storage unit”). The housing (110, “substrate box”) includes a BMS (160, “circuit substrate”) accommodated inside an enclosure with the battery cell array (“energy storage unit”) disposed outside of the enclosure (paragraphs [0030, 0036, 0038] and figures 2, 4 and 7B). BMS (160, “circuit substrate”) is electrically connected to the battery cell array (“energy storage unit”) to calculate the capacity of the battery cell (170, “energy storage device”) (paragraph [0030]). The enclosure is defined by end plate (150) and front cover (130) (paragraphs [0023, 0026, 0030, 0031] and figures 1B, 2 and 3). A first direction is defined as a direction in which the housing (110, “substrate box”) and the battery cell array (“energy storage unit”) are arranged. A second direction is a vertical direction orthogonal to the first direction and a third direction is defined as a direction orthogonal to the first direction and the second direction (Figure 4 below). The enclosure includes a handle (133) to grip and move the battery pack (100, “energy storage apparatus”) (paragraph [0024]). The handle (133) is disposed at a lower end of the enclosure in the second direction (figure 1B). The handle (133) is located below a portion of the BMS (160, “circuit substrate”) in the second direction (figures 1B and 2). The handle (133) appears to be pivotable, but Kim does not provide specifics on its geometry. PNG media_image4.png 483 847 media_image4.png Greyscale [AltContent: textbox (Figure 4 - Kim's assembly)] Kim fails to teach the claimed geometry of the handle. Anderson teaches a pivotable handle (22) for a battery. The handle (22) includes a recess with an opening. The handle (22) also includes a first wall portion facing the battery and legs (“second wall portion”) disposed between the first wall portion and the battery (col. 4, lines 66-68 and figures 1 and 5). The recess is formed by being surrounded by the first wall portion and the legs (“second wall portion”). It would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to use a handle with the geometry taught by Anderson for the purpose of implementing an ergonomically shaped handle. In the combination of Kim and Anderson, when the handle is in the extended state, the opening of the recess would be in the second direction, the first wall portion would face the battery cell array (“energy storage unit”) in the first direction and the legs (“second wall portion”) would face toward the third direction. Regarding claim 3, Kim teaches that the handle (133) is disposed at a position closer to a bottom of the battery pack (100, “energy storage apparatus”) than a portion of the battery cell array (“energy storage unit”) (figure 1B). Regarding claim 4, Kim as modified by Anderson teaches that the recess is formed in a surface of the handle facing the battery cell array (“energy storage unit”). Regarding claim 5, Kim as modified by Anderson teaches that the handle includes inclined surfaces formed in a surface of the handle facing the battery cell array (“energy storage unit”) (Anderson’s figure 5). Each inclined surface is away from the battery cell array (“energy storage unit”) and (the whole handle and thus the inclined surface) is positioned toward the lower end of the enclosure in the second direction. Regarding claim 6, Kim teaches that the enclosure includes vertical extending portion (117a, “substrate holder”). The vertical extending portion (117a, “substrate holder”) is disposed between the battery cell array (“energy storage unit”) and the BMS (160, “circuit substrate”) (paragraph [0038] and figures 4 and 7A). The enclosure further includes front cover (130) that is attached to the vertical extending portion (117a, “substrate holder”) (paragraph [0038]). The front cover (130) includes a bolt (131, “first cover attaching part”) attached to the vertical extending portion (117a, “substrate holder”) (paragraph [0024] and figure 1B). Bolts are attached by being rotated – therefore the bolt (131, “first cover attaching part”) is rotatably attached to the vertical extending portion (117a, “substrate holder”). Regarding claim 7, Kim teaches four bolts (131) (paragraph [0024] and figure 1B). Two of them are disposed at a position closer to a bottom of the battery pack (100, “energy storage apparatus”) than a center position of the front cover (130) (figure 1B). Regarding claim 8, Kim teaches that the vertical extending portion (117a, “substrate holder”) includes a hole (“holder attaching part”) to which the bolt (131, “first cover attaching part”) is attached. The bolt (131, “first cover attaching part”) is disposed in a direction from the front cover (130) toward the vertical extending portion (117a, “substrate holder”) with respect to the hole (“holder attaching part”). Regarding claim 9, Kim teaches four bolts (131) (paragraph [0024] and figure 1B). Each bolt is attached to the vertical extending portion (117a, “substrate holder”) by being screwed into it, therefore it is attached by “engaging” with the “substrate holder”. Regarding claim 10, Kim teaches an opening in the front cover (130) accommodating the bolt (131, “first cover attaching part”). The surface of the front cover (130) surrounding the opening is a “rotation regulating part that restricts rotation with respect to the “substrate holder”. Regarding claim 20, Kim teaches a battery pack (100, “energy storage apparatus”) (paragraph [0023] and figure 1A). The battery pack (100, “energy storage apparatus”) comprises a battery cell array (“energy storage unit”). The battery cell array (“energy storage unit”) includes a battery cell (170, “energy storage device”) (paragraph [0036] and figure 4). Housing (110) is a “substrate box” that is a separate member from the battery cell array (“energy storage unit”). The housing (110, “substrate box”) includes a BMS (160, “circuit substrate”) accommodated inside an enclosure with the battery cell array (“energy storage unit”) disposed outside of the enclosure (paragraphs [0030, 0036, 0038] and figures 2, 4 and 7B). BMS (160, “circuit substrate”) is electrically connected to the battery cell array (“energy storage unit”) to calculate the capacity of the battery cell (170, “energy storage device”) (paragraph [0030]). The enclosure is defined by end plate (150) and front cover (130) (paragraphs [0023, 0026, 0030, 0031] and figures 1B, 2 and 3). A first direction is defined as a direction in which the housing (110, “substrate box”) and the battery cell array (“energy storage unit”) are arranged. A second direction is a vertical direction orthogonal to the first direction and a third direction is defined as a direction orthogonal to the first direction and the second direction (Figure 4 above). The battery pack (100, “energy storage apparatus”) includes a bottom at an end part of the battery pack (100, “energy storage apparatus”) in the second direction. The battery cell (170, “energy storage device”) includes a case and an electrode terminal (171) protruding from the case (paragraph [0036] and figure 4). The case and the electrode terminal (171) are arranged in the second direction (figure 4). The battery cell (170, “energy storage device”) is arranged such that the case is interposed between the electrode terminal (171) and the bottom in the second direction (figure 4). The enclosure includes a handle (133) to grip and move the battery pack (100, “energy storage apparatus”) (paragraph [0024]). The handle (133) is disposed at a position closer to the bottom than the electrode terminal (171) in the second direction (figures 1B and 2). The handle (133) is disposed at a lower end of the enclosure in the second direction (figure 1B). The handle (133) is located below a portion of the BMS (160, “circuit substrate”) in the second direction (figures 1B and 2). The handle (133) appears to be pivotable, but Kim does not provide specifics on its geometry. Kim fails to teach that the handle includes an inclined surface, the inclined surface sloping away from the battery cell array (“energy storage unit”) in the first direction as the inclined surface moves away from the electrode terminal (171) in the second direction. Anderson teaches a pivotable handle (22) for a battery. The handle (22) includes a first wall portion facing the battery and legs (“second wall portion”) disposed between the first wall portion and the battery (col. 4, lines 66-68 and figures 1 and 5). The handle (22) also includes inclined surfaces (Anderson’s figure 5). It would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to use a handle with the geometry taught by Anderson for the purpose of implementing an ergonomically shaped handle. In the combination of Kim and Anderson, as the handle is lowered from the extended state downwards, each inclined surface moves downward in the second direction and thus away from the electrode terminal (171) in the second direction and simultaneously slopes in a direction away from the battery cell array (“energy storage unit”) in the first direction. Regarding claim 22, in the combination of Kim and Anderson, the handle includes a recess with an opening. When the handle is in the extended state, the opening of the recess is in the second direction. Regarding claim 23, in the combination of Kim and Anderson, when the handle is in the extended state, the first wall portion would face the battery cell array (“energy storage unit”) in the first direction and the legs (“second wall portion”) would face toward the third direction. Regarding claims 26 and 27, Kim teaches that the enclosure includes vertical extending portion (117a, “substrate holder”). The vertical extending portion (117a, “substrate holder”) is disposed between the battery cell array (“energy storage unit”) and the BMS (160, “circuit substrate”) to hold the BMS (160, “circuit substrate”) (paragraph [0038] and figures 4 and 7A). The enclosure further includes front cover (130) that is attached to the vertical extending portion (117a, “substrate holder”) using bolts (131) (paragraphs [0024, 0038] and figure 1B) – therefore it is openably attached. Response to Arguments Applicant’s newly added limitations have been considered. However, after further search and consideration, the Lee reference and the combination of the Kim and Anderson references have been provided, as recited above, to address the amended claims. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to LILIA V NEDIALKOVA whose telephone number is (571)270-1538. The examiner can normally be reached 8.30 - 5.00 PM. 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, Miriam Stagg can be reached at 571-270-5256. 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. LILIA V. NEDIALKOVA Examiner Art Unit 1724 /MIRIAM STAGG/Supervisory Patent Examiner, Art Unit 1724
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Prosecution Timeline

Show 5 earlier events
Jun 11, 2025
Final Rejection mailed — §102, §103, §112
Sep 09, 2025
Applicant Interview (Telephonic)
Sep 09, 2025
Examiner Interview Summary
Sep 11, 2025
Response after Non-Final Action
Nov 11, 2025
Response after Non-Final Action
Nov 11, 2025
Request for Continued Examination
Nov 12, 2025
Response after Non-Final Action
Jun 25, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
55%
Grant Probability
78%
With Interview (+22.4%)
3y 4m (~0m remaining)
Median Time to Grant
High
PTA Risk
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