Prosecution Insights
Last updated: October 02, 2026
Application No. 17/821,757

SECONDARY BATTERY

Final Rejection §103
Filed
Aug 23, 2022
Priority
Jan 14, 2022 — RE 10-2022-0005833
Examiner
YUAN, DAH WEI D
Art Unit
1717
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Samsung SDI Co., Ltd.
OA Round
4 (Final)
25%
Grant Probability
At Risk
5-6
OA Rounds
0m
Est. Remaining
36%
With Interview

Examiner Intelligence

Grants only 25% of cases
25%
Career Allowance Rate
11 granted / 44 resolved
-40.0% vs TC avg
Moderate +12% lift
Without
With
+11.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 9m
Avg Prosecution
2 currently pending
Career history
53
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
53.7%
+13.7% vs TC avg
§102
19.7%
-20.3% vs TC avg
§112
22.4%
-17.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 44 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 . The Applicant’s arguments filed on June 26, 2026 were received. The text of those sections of Title 35., U.S.C. code not included in this action can be found in the prior Office action issued March 18, 2025. Claim Rejections - 35 USC § 103 2. The claim rejections under 35 U.S.C 103 as being unpatentable over Zhang (US 20210074963) in view of Jeong et al. (KR 20200007273A) and Kim (US 20090136840) on claims 1-8,11 are maintained. Regarding claim 1, Zhang et al. disclose a secondary battery comprising: an electrode assembly comprising a first electrode tab (210) protruding from a first side of the electrode assembly and a second electrode tab (220) protruding from a second side of the electrode assembly; a case (300) accommodating the electrode assembly (200) and comprising a first opening at one side of the case and a second opening at another side of the case. Zhang et al. further disclose a first terminal (21) electrically coupled to the first electrode tab of the electrode assembly, a first cap plate (10) sealing the first opening of the case and exposing the first terminal to the outside; a second terminal (41) electrically coupled to the second electrode tab of the electrode assembly; and a second cap plate (10) sealing the second opening of the case and exposing the second terminal to the outside, wherein the first electrode tab and the second electrode tab have bent portions. See Fig. 2, 6, and abstract. Zhang et al. also teach the current collecting wiring board (30) (electrode tab) comprises a first connection portion (31), a second connection portion (32) and a bent portion (210a) in which there are two bent portions as shown in Figure 7. See Para. 72-78. However, Zhang et al. do not explicitly teach that one of the electrode tabs of the secondary battery is welded to a plurality of uncoated regions at a second end of the first electrode tab. Jeong teaches a secondary battery comprising an electrode assembly (220), a case (110), a first cap plate (131), a second cap plate (224), a first terminal (136a), a second terminal (225) in which a plurality of uncoated portions of the negative electrodes are welded to the negative collector tab (224) and a plurality of uncoated portions of the positive electrodes are welded to the positive collector tab (225). See para. 61,64, Figs 6,7a,7b. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have the first electrode tab welded to a plurality of uncoated regions of the first electrode (negative electrode) and the second electrode tab welded to a plurality of uncoated regions of the second electrode (positive electrode) of Zhang because Jeong teaches the resulting electrode assembly of the secondary battery facilities the flow of current and reduces the resistance caused by current concentration of the high performance secondary battery. See para.64. Furthermore, the combination of Zhang and Jeong does not teach the first electrode tab having at least two bent portions, the at least two bent portions facing in opposite directions along a width direction of the electrode assembly. Kim discloses a secondary battery comprising an electrode assembly including a first electrode plate connected to a first electrode tab, a second electrode plate connected to a second electrode tab, and a cap assembly that seals the opening. The first electrode tab has two bent portions facing in opposite directions along the width direction of the electrode assembly. See Figure 1. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to use an electrode tab having two bents in the opposite directions to the secondary battery of Zhang and Jeong because Kim teaches the bent portion can be easily cut, due movement to enhance the safety of the battery. See para. 11. Regarding claim 2, Zhang et al. disclose the secondary battery comprising the first electrode tab of plate shape (bent portion 210a and 31 are both plate-shaped), first tab coupling part in contact with the first side of the electrode assembly (portion 210), a first terminal coupling part welded (Fig. 7, upper portion of connection portion 31) to one surface of the first terminal and parallel to the first tab coupling part, a first connecting part that connects the first tab coupling part and the first terminal coupling part and a bent portion (including transition portion 33 connecting 31 to 210a and 210). Regarding claim 3, Zhang et al. disclose the secondary battery comprising a first electrode tab and a second electrode tab with the same length and shape (as shown in Figs. 2 and 6). Regarding claim 4, Zhang et al. disclose the secondary battery comprising a first connecting part (78, connection portion 32 in Fig. 7) having a region parallel to the first tab coupling part and the first terminal coupling part (first plate body 321.and second plate body 322), and the first connecting part comprising two bent portions (210a, 33) wherein a first bent portion of the two bent portions is connected to the first terminal coupling part and a second bent portion of the two bent portions is connected to the first terminal coupling part (each bent portion are connected to the terminal coupling part). See Figure 7. Regarding claim 5, Zhang et al. further disclose the secondary battery comprising the first connecting part with one bent portion connecting the first terminal coupling part and the first tab coupling part, wherein the first terminal coupling part and the first tab coupling part face each other (transition portion 33 and bent portion 210a). See Figs 6 and 7. Regarding claim 6, Zhang et al. teach the secondary battery as described above, but is silent with respect to the claimed embodiment wherein the first electrode tab and the second electrode tab have different lengths and shapes. No criticality of the claimed configuration is evidenced by Applicant's disclosure. The change in form or shape, without any new or unexpected results, is an obvious engineering design. See In re Dailey, 149 USPQ 47 (CCPA 1976) (see MPEP § 2144.04). Furthermore, the size of an article is not a matter of invention. See In re Rose, 105 USPQ 237 (CCPA 1955) (see MPEP § 2144.04). Accordingly, one of ordinary skill in the art would have found it obvious to modify Zhang such that the first electrode tab and the second electrode tab have different lengths and shapes in order to provide electrode tabs of reduced electrical resistance in one area and ease of connection in another. Regarding claim 7, Zhang et al. disclose the secondary battery comprising a second electrode tab of plate shape (upper and lower electrode tabs are the same, each having a plate shape including 210 and 210a), a second tab coupling part contacting the second side of the electrode assembly (210a), a second terminal coupling part welded to one surface of the second terminal and parallel to the second tab coupling part (31), and a second connecting part connecting the second tab coupling part wherein the second terminal coupling part having a bent portion (including bent portion 210a, transition portion 33 connecting 31 to 210a and 210). See Fig. 7. Regarding claim 8, Zhang et al. further disclose the secondary battery comprising a first connecting part of the first electrode tab having one bent portion (upper terminal assembly coupling structure including one bent portion such as transition portion 33) which connects the first terminal coupling part and the first tab coupling part (transition portion 33 coupling to the first tab coupling part 210 through 210a, and terminal coupling part at 31) wherein the first terminal coupling part and the first tab coupling part face each other; and the second connecting part of the second electrode tab has a region parallel to the second tab coupling part and the second terminal coupling part, and the second connecting part includes a first bent portion connected to the second terminal coupling part (transition portion 33) and a second bent portion connected to the second tab coupling part (bent portion 210a). See Figs 6 and 7. Regarding claim 11, Zhang et al. further disclose the secondary battery comprising an extension portion (212) (inside of the cap plate) of the terminal (21) is welded to the first connection portion (31, coupling part). See Fig. 4, para.55. 3. The claim rejections under 35 U.S.C 103 as being unpatentable over Zhang (US 20210074963) in view of Jeong et al. (KR 20200007273A) and Kim (US 20090136840) as applied to claim 1-8,11 above, and further in view of Samsung ‘828 on claim 9 are maintained. Regarding claim 9, the combination of Zhang, Jeong and Kim teaches the secondary battery as described in Paragraph 2 above. However, the modified Zhang does not teach that the plurality of uncoated regions is cut and stacked together. Samsung ’828 discloses a secondary battery comprising two electrode tabs, each comprising cut and stacked uncoated regions, protruding from opposite sides of the electrode assembly and having bent portions electrically connected to two terminals. See Fig. 3, col. 2, line 51 to col. 3, line 53; col. 5-6). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have the uncoated regions of the (positive or negative) electrode cut and stacked together in the battery of Zhang and Jeong because Samsung ‘828 teach the use of such configuration to facilitate the connection between the connecting portions (uncoated regions) and the electrode terminals. Furthermore, "[W]hen a patent 'simply arranges old elements with each performing the same function it had been known to perform’ and yields no more than one would expect from such an arrangement, the combination is obvious." KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398,417 (quoting Sakraida v. Ag Pro, Inc., 425 U.S. 273, 282 (1976)). 4. The claim rejections under 35 U.S.C 103 as being unpatentable over Zhang (US 20210074963) in view of Jeong et al. (KR 20200007273A) and Kim (US 20090136840) as applied to claims 1-8,11 above, and further in view of Samsung ‘242 on claim 10 are maintained. Regarding claim 10, the combination of Zhang, Jeong and Kim teaches the secondary battery as described in Paragraph 2 above. However, the modified Zhang does not teach with respect to the claimed configuration wherein the first electrode tab and the second electrode tab comprise separate auxiliary plates, each of which is coupled to the first side or the second side of the electrode assembly by welding, and has the shape of a plate extending and protruding from the first side or the second side of the electrode assembly. Samsung ’242 discloses a battery comprising auxiliary plates coupled to protruding electrode tabs. See Fig. 3. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to have separate auxiliary plates added to the first electrode tab and the second electrode tab of the battery of Zhang and Jeong because Samsung ‘242 teaches such configuration can facilitate the connection between the connecting portion and electrode terminals. Furthermore, [W]hen a patent ‘simply arranges old elements with each performing the same function it had been known to perform’ and yields no more than one would expect from such an arrangement, the combination is obvious." KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398,417 (quoting Sakraida v. Ag Pro, Inc., 425 U.S. 273, 282 (1976)). Response to Arguments Applicants’ arguments filed 6/26/2026 have been fully considered but they are not persuasive. Applicant’s principal arguments are: Some of the limitations in claim 1 are taught by Zhang. Thus, there is no reason to modify the Zhang reference by Jeong. Neither Zhang nor Jeong would provide the first electrode tab having at least two bent portions as recited in claim 1. The modification would change Zhang’s principle of operation and render it unsatisfactory for its intended purpose. In response to Applicant’s arguments, please consider the following comments: Zhang et al. indeed teach an uncoated region extending out from the coating region of the main body, as described in Paragraph 45 of Zhang. However, Figure 3 of Zhang never explicitly discloses one of the electrode tabs of the secondary battery is welded to a plurality of uncoated regions at a second end of the first electrode tab. This deficiency is cured by the Jeong reference which a plurality of uncoated portions of the position electrode are welded to the positive collector tab. See para. 61,64, Figures 7a and 7b. Applicants are reminded that one cannot show nonobviousness by attaching references individually where the rejections are based on combinations of reference. In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981). In this instance, the combination of Zhang and Jeong does not teach the first electrode tab having at least two bent portions, the at least two bent portions facing in opposite directions along a width direction of the electrode assembly. As described in Paragraph 2 above, the deficiency is cured by Kim reference in which Figure 1b shows the at least two bent portions that are facing in opposite directions along the width direction of the electrode assembly. It is evident from the drawings of Zhang that the electrode terminal and tab are bent to save space inside the top portion of the secondary battery. See Figure 6. Similarly, the Kim reference also shows similar configuration at the top portion of the secondary battery that space is sufficiently used to accommodate the electrode tab having at least two bent portions. Thus, it is evident from the references that it would have been obvious before the effective filing date of the invention to use an electrode tab having at least two bents in the opposite directions to the secondary battery of Zhang and Jeong because Kim teaches the bent portions can be easily cut, due movement to enhance the safety of the battery and similarly save space. The test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary referee… Rather the test is what the combined teachings of those references would have suggested to those of ordinary skill in the art. In re Ketler, 642 F.2d 413, 425, 208 USPQ 871, 881 (CCPA 1981). There is no evidence to suggest or show the claimed combination change the principle of operation of the primary reference or render the reference inoperable for its intended purpose as a rechargeable secondary battery. See MPEP 2145. Also, It is prima facie obvious to substitute equivalents known for the same purpose. See MPEP 2144.06 Conclusion 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 DAH-WEI YUAN whose telephone number is (571)272-1295. The examiner can normally be reached M-F 9am-5pm. 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. 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. /Dah-Wei D. Yuan/Supervisory Patent Examiner, Art Unit 1717
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Prosecution Timeline

Show 2 earlier events
Jun 17, 2025
Response Filed
Aug 18, 2025
Final Rejection mailed — §103
Sep 26, 2025
Response after Non-Final Action
Nov 07, 2025
Request for Continued Examination
Nov 10, 2025
Response after Non-Final Action
Apr 07, 2026
Non-Final Rejection mailed — §103
Jun 26, 2026
Response Filed
Sep 15, 2026
Final Rejection mailed — §103 (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

5-6
Expected OA Rounds
25%
Grant Probability
36%
With Interview (+11.5%)
3y 9m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 44 resolved cases by this examiner. Grant probability derived from career allowance rate.

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