Prosecution Insights
Last updated: April 19, 2026
Application No. 17/781,679

Supporting structure for receiving battery cells

Final Rejection §102§103§112
Filed
Jun 01, 2022
Examiner
RICKMAN, HOLLY C
Art Unit
1785
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Webasto SE
OA Round
2 (Final)
71%
Grant Probability
Favorable
3-4
OA Rounds
3y 0m
To Grant
94%
With Interview

Examiner Intelligence

Grants 71% — above average
71%
Career Allow Rate
403 granted / 571 resolved
+5.6% vs TC avg
Strong +23% interview lift
Without
With
+23.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
23 currently pending
Career history
594
Total Applications
across all art units

Statute-Specific Performance

§103
42.0%
+2.0% vs TC avg
§102
27.8%
-12.2% vs TC avg
§112
21.4%
-18.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 571 resolved cases

Office Action

§102 §103 §112
DETAILED ACTION Claim Rejections - 35 USC § 112 The rejections of claims 12-16 under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, are withdrawn in view of Applicant’s amendments and arguments. Claim Rejections - 35 USC § 102 The rejection of claim(s) 1-9 and 14-18 under 35 U.S.C. 102a1 as being anticipated by Shimizu et al. is withdrawn in view of Applicant’s amendments. 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) 1-9 and 11-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Shimizu et al. (see English machine translation of JP 08-058617) in view of Frohnmayer et al. (US 2016/0190664). With regard to claims 1-2 and 14-18, Shimizu et al. disclose a frame structure for holding a battery in an electric car application. The reference shows an embodiment wherein adjacent frame structures (50) are connected at a bottom plate portion via mating flange attachments (75A and 75B) and the sidewall portions of the self-supporting structure are connected via a separate flange structure (see 62A/62B in Figures 5 and 7). The reference fails to disclose the claimed “venting channel for receiving gases released from battery cells in case of thermal runaway” but does disclose an air space between the bottom plates 50 and 61 for cooling the structure (see Figures 2 and 8). The reference does not disclose how the portion 61 is sealed to base plate 50. Frohnmayer et al. teaches a battery assembly housing with a bottom plate (122) and side plates (352 and 356) that is similar to that taught by Shimizu et al. (see Fig 12 and description thereof). Like the Shimizu reference, Frohnmayer et al. teach the presence of cooling channels within a base plate supporting an assembly of battery cells. The reference also teaches that gaskets may be formed in between base plate (122) and side walls (112 and 114) wherein openings can be formed in the gaskets “corresponding to various fluid pathways.” The reference also discloses that through holes can be formed in a header to allow for the “escape of vented gases should a battery experience a critical failure” teaching that it was known in the art to be desirable to vent gases in case of thermal runaway (see para [0057]). While the Frohnmayer reference does not specifically disclose forming “a venting channel for receiving gases released from the battery cells in case of thermal runaway” in a base plate, the reference does clearly suggest forming holes in gaskets used to seal a base plate and side walls. It would have been obvious to one of ordinary skill in the art prior to the effective filing date of the claimed invention to add gaskets with openings to the connection between bottom plate layers 61 and side walls (112 and 114) in the structure taught by JP8-58617. Provisional of holes in the gasket would have been obvious in view of the explicit teaching by Frohnmayer to this effect. While the holes aren’t specifically for the purpose of gas venting, they would necessarily be able to function as gas venting channels into the air space between layers 61 and 50 in the event of thermal runaway. With regard to claim 3, the term “extruded” is a process limitation in an article claim. The limitation has been considered insofar as it materially affects the claimed “supporting structure.” The claim also requires that the bottom plate and at least one side plate of the structure are “integrally formed.” Extrusion does not impart any additional structure to the claims. In any case, Shimizu et al. disclose that support structure frames (50) are extruded and the side plates and bottom plates are integral (see Figures 5 and 7). With regard to claims 4-8 and 17, see Figures 5 and 7. With regard to claim 9 and 18, see Fig 2, para [0016]. The spacing in between bottom plate structure 61 and 50B includes a fluid cooling channel 72. With regard to claim 16, see Figures 5 and 7 and descriptions thereof. With regard to claims 11-13 and 19-20, see Figures 5 and 7 of Shimizu et al. Response to Arguments Applicant's arguments filed 11/20/25 have been fully considered but they are not persuasive. Applicant argues that Frohnmayer is limited to through holes formed in a header (i.e., side wall) of the structure and not a bottom plate as claimed. The Examiner agrees with Applicant with regard to the interpretation of the through holes for gas venting as being formed in a side wall and not the bottom plate(122). However, this disclosure does more broadly teach that it was known in the art to form openings within a battery housing to serve as gas vents in case of thermal runaway. Furthermore, paragraph [0057] of Frohnmayer also discloses forming holes in the gasket sealing a bottom plate (122) to the side walls (112 and 114) in order to provide access to “various fluid pathways.” Thus, provision of holes in the junction between the layer 61 and side walls 50C and 50D in Figure 2 of JP 8-58617 would have been obvious to provide access to cooling air channel between 61 and 50B as shown in Fig 8a. Applicant further argues that the Frohnmayer only discloses fluid pathways used as part of a temperature control system and not as gas vents as claimed. As noted above, the combination of references suggests a motivation to form holes in gaskets used to join the attachment point between bottom plate 61 and sidewalls in the structure taught by JP8-58617. While these holes are not specifically disclosed as being used for gas venting, the Examiner maintains that they are capable of functioning in the claimed capacity. There is no structural distinction between a channel for circulating air (i.e., gas) and the claimed “venting channel for receiving gases.” In the case of thermal runaway, gas would be capable of venting into air channels beneath the battery bottom plate 61 in the structure of JP8-58617. 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 HOLLY RICKMAN whose telephone number is (571)272-1514. The examiner can normally be reached Mon, Tues, Thurs, 9am-3pm 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, Mark Ruthkosky can be reached at 571-272-1291. 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. /Holly Rickman/Primary Examiner, Art Unit 1785
Read full office action

Prosecution Timeline

Jun 01, 2022
Application Filed
Aug 26, 2025
Non-Final Rejection — §102, §103, §112
Nov 20, 2025
Response Filed
Mar 17, 2026
Final Rejection — §102, §103, §112 (current)

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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
71%
Grant Probability
94%
With Interview (+23.3%)
3y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 571 resolved cases by this examiner. Grant probability derived from career allow rate.

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