Prosecution Insights
Last updated: October 01, 2026
Application No. 17/782,259

ENERGY STORAGE APPARATUS

Final Rejection §103
Filed
Jun 03, 2022
Priority
Jan 17, 2020 — JP 2020-005985 +1 more
Examiner
CORNO JR, JAMES ANTHONY JOHN
Art Unit
1722
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Gs Yuasa International Ltd.
OA Round
4 (Final)
38%
Grant Probability
At Risk
5-6
OA Rounds
0m
Est. Remaining
75%
With Interview

Examiner Intelligence

Grants only 38% of cases
38%
Career Allowance Rate
56 granted / 146 resolved
-26.6% vs TC avg
Strong +36% interview lift
Without
With
+36.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
39 currently pending
Career history
187
Total Applications
across all art units

Statute-Specific Performance

§101
0.8%
-39.2% vs TC avg
§103
68.0%
+28.0% vs TC avg
§102
12.4%
-27.6% vs TC avg
§112
15.6%
-24.4% vs TC avg
Black line = Tech Center average estimate • Based on career data from 146 resolved cases

Office Action

§103
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 Claim Objections The objections to claims 5, 8, and 20 have been overcome by the amendment and are withdrawn. Response to Arguments Applicant's arguments filed April 26, 2026, have been fully considered but they are not persuasive. Applicant contends that You20 and You21 require the restraint bodies to be connected to the outer case, which is inconsistent with the requirements of the instant claims (pp. 14-15, I A and B). However, the instant claims require only that the members be connected directly to each other between the cells. The members of You21 are in direct contact and held in place by the force between a screw and a beam, which is no different than being held in place between a screw and a nut; they are still directly connected to each other. Applicant contends that there is no motivation to add the lower restraint member of You21 to the device of You20, since You20 already incorporates is own such feature (pp. 15-16, I C). However, no reference to any exhaust passage could be found in You20. The lower exhaust passage (7) of You21 is in addition to passages (8) near the electrodes (You 21 Fig. 5), which are the only spaces to be seen in the device of You20, and You21 explicitly teaches that the combination of passages improves device safety. Applicant contends that the change to a single piece for the restraining member is more than an obvious engineering choice (p. 16, I D). However, as can be seen in Fig. 3 of You20, the two members are mated together between the cells. Making them a single piece instead would have no structural impact on the device. Applicant contends that the teachings of You928 would not specifically direct a POSITA to place a control device in the location required by the instant claims, as it gives only a generic placement principle (pp. 16-17, II). However, generic teachings are still teachings. The motivation to place the control device in the only empty space is clear. In response to applicant's argument that the examiner's conclusion of obviousness is based upon improper hindsight reasoning, it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin, 443 F.2d 1392, 170 USPQ 209 (CCPA 1971). Applicant contends that connecting blocks and directly joined bent portions are not equivalent, since the use of directly joined bent portions reduces design flexibility, and the connecting blocks are a separate piece (pp. 18-19, IV A and B). However, the two accomplish the same purpose (joining the restraining members), and there will always be advantages and disadvantages to any design choice, so that cannot be proof of non-equivalence. The rejections are maintained. 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 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, 4-8, 10-12, 15-17, 20, and 23-27 is/are rejected under 35 U.S.C. 103 as being unpatentable over You et al. (US 2020/0411817 A1, hereinafter referred to as “You20”) in view of You et al. (US 2021/0249731 A1, hereinafter referred to as “You21”). Regarding claim 1, You20 teaches an energy storage apparatus comprising energy storage devices (battery units 20B) comprising electrode assemblies (22) in a case (housing 21) (You20 Fig. 8 and [0048]), the devices arrayed in array directions (x and y) intersecting the stacking direction (z), with restraint bodies (3) formed by bending sheets (You20 [0084]). You20 does not teach that the case is made of any particular material. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional material for the case, including metal. You20 does not teach the use of matching lower restraint bodies. You21 teaches that matching upper restraint bodies 31 with lower restraint bodies 32 with bending portions (mounting portions 312 and 322) bending toward each other in the stacking direction and joined together by opposing faces of those bending portions (You21 Figs. 1- 2 and [0045]) allows for an exhaust passage to improve safety (You21 [0062]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to add the lower restraint member of You21 to the apparatus of You20 to improve safety. You20 does not teach that the electrode assembly must be made of stacked plates. You20 teaches gives only two options for the electrode assembly, one of which is stacked plates (You20 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any of the limited number of configurations suggested by You20, including stacked plates. PNG media_image1.png 1699 1440 media_image1.png Greyscale Modified You20 does not teach that the restraint members are attached between the batteries. Modified You20 teaches that multiple restraint members (3) are applied to multiple groups of batteries (20A and 20B) and attached between them (You20 Fig. 1 and [0048]-[0049]). The use of a one piece construction instead of the structure disclosed in You20 would be merely a matter of obvious engineering choice. See In re Larson, 340 F.2d 965, 968, 144 USPQ 347, 349 (CCPA 1965) and MPEP 2144.04 VB. Regarding claim 2, the restraint bodies of modified You20 are directly joined between the first energy storage device (batteries 20A) and the second energy storage device (batteries 20B) (You20 Fig. 1 and [0047]-[0051]; You21 Fig. 3 and [0043]-[0045]). Regarding claim 4, the restraint bodies of modified You20 have protrusions bent toward each other (mounting portions 312 and 322) and directly joined together by opposing faces of those bending portions (You21 Figs. 1-3 and [0045]) between the first energy storage device (batteries 20A) and the second energy storage device (batteries 20B) (You20 Fig. 1 and [0048]). Regarding claim 5, modified You20 teaches that the battery includes “at least two battery units” arranged in the accommodation cavities 13, which are separated by beams 12 (You20 Fig. 1, [0047], and [0009]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any number of battery units, including 3 or more, which would necessarily include attachment points between each, since You20 explicitly allows for more battery units. Regarding claim 6, the apparatus of modified You20 includes batteries stacked in the stacking direction z (You20 Fig. 1). Regarding claim 7, the apparatus of modified You20 includes an outer case (box body 11) that accommodates the batteries and to which the restraint members are attached (by beam 12) (You20 Fig. 1 and [0047]). Regarding claim 10, the housing of modified You20 includes a case body (housing 21) with a long side surface (the z faces) facing in the stacking direction and toward the bottom surface of the outer case (You20 Fig. 8 and [0048]). Regarding claim 11, the apparatus of modified You20 includes an outer case lid (outer cover 4) attached to the outer case 11 (You20 Fig. 3 and [0047]). Modified You20 does not teach that the lid includes terminals electrically connected to the batteries. However, the apparatus of modified You20 is a battery pack (You20 Abstract) and so must necessarily have terminals, and the only options for placing those terminals are on case 11 or case cover 4. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to provide the terminals anywhere on the battery pack, including on the case lid. Regarding claim 12, the housing of modified You20 includes a case lid (cover plate 241) attached to housing 21 in direction y, which intersects stacking direction z and array direction x, with terminals (242 and 243) on the case lid (You20 Fig. 8 and [0048]). Regarding claim 23, the restraint bodies are joined by a protrusion (mounting portions 312 and 322, You21 Figs. 1 and 2 and [0043]-[0047]). Regarding claim 24, the restraint bodies of modified You20 are formed by bending one plate-like member (see the rejection of claim 1 above) and joined to each other without any member mediating force between the bodies at the location of direct joinder (You21, Figs. 1 and 2). Regarding claim 25, the restraint bodies of modified You20 are formed by bending one plate-like member (see the rejection of claim 1 above) and joined to each other without any connecting block or intermediate joining element between them, and the bodies have a gap between them to accommodate the energy storage devices (You21, Figs. 1 and 2). Regarding claim 26, the restraint bodies of modified You20 have protrusions that extend toward each other and are joined together between adjacent cells (You21 Fig. 1 and You20 Figs. 3 and 4). Regarding claim 27, the restraint bodies of modified You20 have protrusions that extend toward each other and are joined together between adjacent cells (You21 Fig. 1 and You20 Figs. 3 and 4). Regarding claim 8, You20 teaches an energy storage apparatus comprising energy storage devices (battery units 20B) comprising electrode assemblies (22) in a case (housing 21) (You20 Fig. 8 and [0048]), the devices arrayed in array directions (x and y) intersecting the stacking direction (z), with restraint bodies (3) formed by bending sheets (You20 [0084]), and an outer case comprising first and second outer cases (box body 11 and outer cover 4) sandwiching the batteries in the stacking direction, with the restraint bodies directly connected to the box body 11 by beams 12 (You20 Figs. 1 and 2). You20 does not teach the use of matching lower restraint bodies. You21 teaches that matching upper restraint bodies 31 with lower restraint bodies 32 with bending portions (mounting portions 312 and 322) bending toward each other in the stacking direction and joined together by opposing faces of those bending portions (You21 Figs. 1- 2 and [0045]) allows for an exhaust passage to improve safety (You21 [0062]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to add the lower restraint member of You21 to the apparatus of You20 to improve safety. You20 does not teach that the electrode assembly must be made of stacked plates. You20 teaches gives only two options for the electrode assembly, one of which is stacked plates (You20 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any of the limited number of configurations suggested by You20, including stacked plates. Modified You20 does not teach that the restraint members are attached between the batteries. Modified You20 teaches that multiple restraint members (3) are applied to multiple groups of batteries (20A and 20B) and attached between them (You20 Fig. 1 and [0048]-[0049]). The use of a one piece construction instead of the structure disclosed in You20 would be merely a matter of obvious engineering choice. See In re Larson, 340 F.2d 965, 968, 144 USPQ 347, 349 (CCPA 1965) and MPEP 2144.04 VB. Regarding claim 15, the housing of modified You20 includes a case body (box assembly 1) with a long side surface (the z faces) facing in the stacking direction and toward the bottom surface of the outer case (You20 Fig. 1 and [0047]-[0051]). Regarding claims 16, the apparatus of You21 includes an outer case lid (outer cover 4) attached to the box body 11 (You20 Fig. 1 and [0047]-[0051]). Modified You20 does not teach that the lid includes terminals electrically connected to the batteries. However, the apparatus of You20 is a battery pack (You20 Abstract) and so must necessarily have terminals, and the only options for placing those terminals are on box body 11 or outer cover 4. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to provide the terminals anywhere on the battery pack, including on the outer cover. Regarding claim 17, the housing of modified You20 includes a case lid (cover plate 241) attached to housing 21 in direction y, which intersects stacking direction z and array direction x, with terminals (242 and 243) on the case lid (You20 Fig. 8 and [0048]). Regarding claim 20, You20 teaches an energy storage apparatus comprising energy storage devices (battery units 20B) comprising electrode assemblies (22) in a case (housing 21) (You20 Fig. 8 and [0048]), the devices arrayed in array directions (x and y) intersecting the stacking direction (z), with restraint bodies (3) formed by bending sheets (You20 [0084]), and an outer case comprising first and second outer cases (box body 11 and outer cover 4) sandwiching the batteries in the stacking direction, with the restraint bodies directly connected to the box body 11 by beams 12 (You20 Figs. 1 and 2). You20 does not teach the use of matching lower restraint bodies. You21 teaches that matching upper restraint bodies 31 with lower restraint bodies 32 with bending portions (mounting portions 312 and 322) bending toward each other in the stacking direction and joined together by opposing faces of those bending portions (You21 Figs. 1- 2 and [0045]) allows for an exhaust passage to improve safety (You21 [0062]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to add the lower restraint member of You21 to the apparatus of You20 to improve safety. You20 does not teach that the electrode assembly must be made of stacked plates. You20 teaches gives only two options for the electrode assembly, one of which is stacked plates (You20 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any of the limited number of configurations suggested by You20, including stacked plates. Modified You20 does not teach that the restraint members are attached between the batteries. Modified You20 teaches that multiple restraint members (3) are applied to multiple groups of batteries (20A and 20B) and attached between them (You20 Fig. 1 and [0048]-[0049]). The use of a one piece construction instead of the structure disclosed in You20 would be merely a matter of obvious engineering choice. See In re Larson, 340 F.2d 965, 968, 144 USPQ 347, 349 (CCPA 1965) and MPEP 2144.04 VB. Claim(s) 13 and 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over You20 in view of You21 as applied to claims 1 and 8 above, and further in view of You et al. (US 2020/0411928 A1; hereinafter referred to as You928). Regarding claims 13 and 18, modified You20 does not teach the use of an electronic device that controls the batteries arranged in an array direction. You928 teaches that cell supervision circuits (i.e., electronic devices that control the batteries) are typically placed wherever there is free space in the battery pack (You928 [0003]). The only space available for such a circuit in the battery of modified You20 is in the voids outside the beams 12 (You20 Fig. 2 and [0047]), which are arranged in an array direction (y) relative to the batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to place a cell supervision circuit in one of these voids, since You928 teaches that such placement is typical. Claim(s) 14 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over You20 in view of You21 as applied to claims 1 and 8 above, and further in view of You et al. (US 2021/0167441 A1; hereinafter referred to as You441) and Kim et al. (US 2016/0156004 A1). Regarding claims 14 and 19, modified You20 teaches an outer case fixing unit (beam 12) corresponding to the protrusions in the restraint members (You20 Figs. 1 and 2 and [0047]). Modified You20 does not teach a thermal insulator between the lower case and the battery cells or a spacer between the restraining members and the battery cells. You441 teaches that adding a thermal barrier layer (6) between the case and the battery cells along with a thermally conductive layer (9) (i.e., a spacer) between the cells and the upper restraining member allows for better control of temperature distribution through the beams and increases service life (You441 Fig. 1, [0041], and [0060]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to add the thermal barrier layer and thermally conductive layer (spacer) of You441 to the battery of modified You20 to increase service life. Modified You20 does not teach a reinforcing member on the upper case. Kim teaches that adding a shaped bead (i.e., a reinforcing member) to the inner face of a battery pack cover can improve rigidity without increasing the volume (Kim [0042] and [0008]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to add Kim’s reinforcing member to the inner surface of the lid of modified You20 (i.e., between the lid and the battery cells) in order to improve rigidity without increasing volume. Claim(s) 28 is/are rejected under 35 U.S.C. 103 as being unpatentable over You20 in view of You21 as applied to claims 7 above, and further in view of Casebolt et al. (US 2017/0069900 A1). Regarding claim 28, modified You20 does not teach that the restraint bodies are fixed to the case by a bolt-and-nut connection. Modified You20 teaches that the restraint bodies are fixed to the case by fasteners such as screws (You20 [0091]). Casebolt is directed to a case for a battery pack with stacked prismatic batteries (Casebolt Abstract and Fig. 1). Casebolt teaches that screws and nut/bolt sets are both suitable fasteners for assembling battery packs (Casebolt [0022]). Screws and nut/bolt sets are therefore art-recognized equivalents for the same purpose, and substituting equivalents known for the same purpose is prima facie obvious (MPEP 2144.06 II). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to use any conventional fastener, including nuts and bolts, to assemble the battery of modified You20. Claim(s) 1, 2, 4-8, 10-12, 15-17, and 20-23 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hisayuki et al. (WO 2018/143464 A1; citations refer to attached English translation) in view of You21. Regarding claim 1, Hisayuki discloses an energy storage apparatus comprising two energy storage devices (first battery group 11 and second battery group 12), a pair of restraint bodies (upper fastening plate 16 and lower fastening plate 17) that collectively sandwich the devices in the stacking direction, the restraint bodies formed by bending plate-like members so that the bent portions bend towards each other and joined together by opposing surfaces of the bending portions between the devices (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the case is made of any particular material. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional material for the case, including metal. Hisayuki does not teach that the electrode assembly must be made of stacked plates. You21 teaches that stacked plates are an acceptable configuration for the electrodes in prismatic batteries (You21 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any conventional electrode configuration, including stacked plates. Hisayuki teaches that the restraint bodies are joined at the bent portions by connecting blocks (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the restraint bodies are directly joined by opposing faces of the bent portions. You21 teaches that upper and lower restraint bodies by be joined by extending the bent portions such that they reach each other in the middle (You21 Figs. 1 and 2). Connecting blocks and directly joined, extended bent portions are therefore art-recognized equivalents for the same purpose, and substituting equivalents known for the same purpose is prima facie obvious (MPEP 2144.06 II). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any known configuration for joining the plates, including direct connection by extended bent portions. Regarding claim 2, the plates of modified Hisayuki are directly joined between the devices (Hisayuki Figs. 1 and 4). Regarding claim 4, the bent portions of modified Hisayuki are protrusions that protrude toward each other (Hisayuki Figs. 1 and 4) and are directly joined at the protrusions. Regarding claim 5, Hisayuki teaches that the apparatus may include a third battery group added next to the other battery groups with an appropriately extended restraining member and an additional interposed connection (Hisayuki [0030]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any of the configurations mentioned by Hisayuki, including a configuration with a third battery group. Regarding claim 6, the battery groups of Hisayuki include a plurality of battery cells (Hisayuki Figs. 1 and 4). Regarding claim 7, Hisayuki teaches that the device is enclosed in a housing (Hisayuki [0031]), and the lower plate includes tabs for attaching to the housing (Hisayuki Figs. 1 and 4). Regarding claim 10, the battery cells of Hisayuki include cases with long side surfaces in the stacking direction (top and bottom; Hisayuki Figs. 1 and 4). Hisayuki teaches that the device is enclosed in a housing (Hisayuki [0031]), and the top and bottom surfaces of the cells would face the top and bottom faces of the housing. Regarding claim 11, Hisayuki does not teach any particular structure for the housing. You21 teaches a housing comprising a first outer case (box 11) and a case lid (cover 13) arranged in the stacking direction (You21 Fig. 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional configuration for the housing, including the housing of You21. You21 does not teach that the lid includes terminals electrically connected to the batteries. However, the apparatus of modified Hisayuki is a battery pack (Hisayuki [0001]) and so must necessarily have terminals, and the only options for placing those terminals are on case 11 or case lid 13. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to provide the terminals anywhere on the battery pack, including on the case lid. Regarding claim 12, Hisayuki does not teach any particular structure for the cell cases. You21 teaches battery cells with a case lid (cover plate 241) attached to housing 21 in direction y, which intersects stacking direction z and array direction x, with terminals (242 and 243) on the case lid (You21 Fig. 8 and [0044]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional configuration for the cells, including the cells of You21. Regarding claim 23, the bent portions of modified Hisayuki are protrusions that protrude toward each other (Hisayuki Figs. 1 and 4) and are directly joined at the protrusions between the devices. Regarding claim 8, Hisayuki discloses an energy storage apparatus comprising two energy storage devices (first battery group 11 and second battery group 12), a pair of restraint bodies (upper fastening plate 16 and lower fastening plate 17) that collectively sandwich the devices in the stacking direction, the restraint bodies formed by bending plate-like members so that the bent portions bend towards each other and joined together by opposing surfaces of the bending portions between the devices (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the electrode assembly must be made of stacked plates. You21 teaches that stacked plates are an acceptable configuration for the electrodes in prismatic batteries (You21 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any conventional electrode configuration, including stacked plates. Hisayuki teaches that the restraint bodies are joined at the bent portions by connecting blocks (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the restraint bodies are directly joined by opposing faces of the bent portions. You21 teaches that upper and lower restraint bodies by be joined by extending the bent portions such that they reach each other in the middle (You21 Figs. 1 and 2). Connecting blocks and directly joined, extended bent portions are therefore art-recognized equivalents for the same purpose, and substituting equivalents known for the same purpose is prima facie obvious (MPEP 2144.06 II). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any known configuration for joining the plates, including direct connection by extended bent portions. Hisayuki teaches that the device is enclosed in a housing (Hisayuki [0031]). Hisayuki does not teach any particular structure for the housing. You21 teaches a housing comprising a first outer case (box 11) and a case lid (cover 13) arranged in the stacking direction (You21 Fig. 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional configuration for the housing, including the housing of You21, which would place the restraint bodies between the cells and outer case. Regarding claim 15, the battery cells of Hisayuki include cases with long side surfaces in the stacking direction (top and bottom; Hisayuki Figs. 1 and 4). Hisayuki teaches that the device is enclosed in a housing (Hisayuki [0031]), and the top and bottom surfaces of the cells would face the top and bottom faces of the housing. Regarding claim 16, Hisayuki does not teach any particular structure for the housing. You21 teaches a housing comprising a first outer case (box 11) and a case lid (cover 13) arranged in the stacking direction (You21 Fig. 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional configuration for the housing, including the housing of You21. You21 does not teach that the lid includes terminals electrically connected to the batteries. However, the apparatus of modified Hisayuki is a battery pack (Hisayuki [0001]) and so must necessarily have terminals, and the only options for placing those terminals are on case 11 or case lid 13. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to provide the terminals anywhere on the battery pack, including on the case lid. Regarding claim 17, Hisayuki does not teach any particular structure for the cell cases. You21 teaches battery cells with a case lid (cover plate 241) attached to housing 21 in direction y, which intersects stacking direction z and array direction x, with terminals (242 and 243) on the case lid (You21 Fig. 8 and [0044]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional configuration for the cells, including the cells of You21. Regarding claim 22, the terminals of modified Hisayuki do not face the each other or the restraining members (Hisayuki Figs. 1 and 4). Regarding claim 20, Hisayuki discloses an energy storage apparatus comprising two energy storage devices (first battery group 11 and second battery group 12), a pair of restraint bodies (upper fastening plate 16 and lower fastening plate 17) that collectively sandwich the devices in the stacking direction, the restraint bodies formed by bending plate-like members so that the bent portions bend towards each other and joined together by opposing surfaces of the bending portions between the devices (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the case is made of any particular material. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional material for the case, including metal. Hisayuki does not teach that the electrode assembly must be made of stacked plates. You21 teaches that stacked plates are an acceptable configuration for the electrodes in prismatic batteries (You21 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any conventional electrode configuration, including stacked plates. Hisayuki teaches that the restraint bodies are joined at the bent portions by connecting blocks (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the restraint bodies are directly joined by opposing faces of the bent portions. You21 teaches that upper and lower restraint bodies by be joined by extending the bent portions such that they reach each other in the middle (You21 Figs. 1 and 2). Connecting blocks and directly joined, extended bent portions are therefore art-recognized equivalents for the same purpose, and substituting equivalents known for the same purpose is prima facie obvious (MPEP 2144.06 II). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any known configuration for joining the plates, including direct connection by extended bent portions. Hisayuki teaches that the device is enclosed in a housing (Hisayuki [0031]). Hisayuki does not teach any particular structure for the housing. You21 teaches a housing comprising a first outer case (box 11) and a case lid (cover 13) arranged in the stacking direction (You21 Fig. 3). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional configuration for the housing, including the housing of You21, which would place the restraint bodies between the cells and outer case. Regarding claim 21, Hisayuki discloses an energy storage apparatus comprising two energy storage devices (first battery group 11 and second battery group 12), a pair of restraint bodies (upper fastening plate 16 and lower fastening plate 17) that collectively sandwich the devices in the stacking direction, the restraint bodies formed by bending plate-like members so that the bent portions bend towards each other and joined together by opposing surfaces of the bending portions between the devices, with the terminals facing out from the restraining members (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the case is made of any particular material. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any conventional material for the case, including metal. Hisayuki does not teach that the electrode assembly must be made of stacked plates. You21 teaches that stacked plates are an acceptable configuration for the electrodes in prismatic batteries (You21 Fig. 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to try any conventional electrode configuration, including stacked plates. Hisayuki teaches that the restraint bodies are joined at the bent portions by connecting blocks (Hisayuki Figs. 1 and 4). Hisayuki does not teach that the restraint bodies are directly joined by opposing faces of the bent portions. You21 teaches that upper and lower restraint bodies by be joined by extending the bent portions such that they reach each other in the middle (You21 Figs. 1 and 2). Connecting blocks and directly joined, extended bent portions are therefore art-recognized equivalents for the same purpose, and substituting equivalents known for the same purpose is prima facie obvious (MPEP 2144.06 II). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to select any known configuration for joining the plates, including direct connection by extended bent portions. Claim(s) 13 and 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hisayuki in view of You21 as applied to claims 1 and 8 above, and further in view of You et al. (US 2020/0411928 A1; hereinafter referred to as You928). Regarding claims 13 and 18, modified Hisayuki does not teach the use of an electronic device that controls the batteries arranged in an array direction. You928 teaches that cell supervision circuits (i.e., electronic devices that control the batteries) are typically placed wherever there is free space in the battery pack (You928 [0003]). The only space available for such a circuit in the battery of modified Hisayuki is in the voids outside the beams 12 (You21 Fig. 3 and [0043]), which are arranged in an array direction (y) relative to the batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to place a cell supervision circuit in one of these voids, since You928 teaches that such placement is typical. Claim(s) 14 and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hisayuki in view of You21 as applied to claims 1 and 8 above, and further in view of Kim et al. (US 2016/0156004 A1). Regarding claims 14 and 19, modified Hisayuki teaches an outer case fixing unit (beam 12) corresponding to the protrusions in the restraint members (You21 Figs. 1 and 2 and [0043]) with thermal insulators between the cells and the restraining members (insulating plates 23; Hisayuki [0013]-[0014] and Figs. 2 and 4), which would place them between the cells and the outer case. Modified Hisayuki does not teach a reinforcing member on the upper case. Kim teaches that adding a shaped bead (i.e., a reinforcing member) to the inner face of a battery pack cover can improve rigidity without increasing the volume (Kim [0042] and [0008]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to add Kim’s reinforcing member to the inner surface of the lid of modified Hisayuki (i.e., between the lid and the battery cells) in order to improve rigidity without increasing volume. 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 JAMES A CORNO JR whose telephone number is (571)270-0745. The examiner can normally be reached M-F 9:00 am - 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, Niki Bakhtiari can be reached at (571) 272-3433. 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. /J.A.C/ Examiner, Art Unit 1722 /ANCA EOFF/ Primary Examiner, Art Unit 1722
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Prosecution Timeline

Show 9 earlier events
Sep 16, 2025
Response after Non-Final Action
Oct 16, 2025
Request for Continued Examination
Oct 19, 2025
Response after Non-Final Action
Jan 27, 2026
Non-Final Rejection mailed — §103
Apr 16, 2026
Examiner Interview Summary
Apr 16, 2026
Applicant Interview (Telephonic)
Apr 26, 2026
Response Filed
Jul 24, 2026
Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

5-6
Expected OA Rounds
38%
Grant Probability
75%
With Interview (+36.2%)
3y 3m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 146 resolved cases by this examiner. Grant probability derived from career allowance rate.

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