Prosecution Insights
Last updated: July 17, 2026
Application No. 17/837,777

ELECTROCHEMICAL STACK ASSEMBLY

Non-Final OA §103
Filed
Jun 10, 2022
Priority
Dec 02, 2021 — RE 10-2021-0171242
Examiner
ESTES, JONATHAN WILLIAM
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Kia Corporation
OA Round
2 (Non-Final)
72%
Grant Probability
Favorable
2-3
OA Rounds
0m
Est. Remaining
77%
With Interview

Examiner Intelligence

Grants 72% — above average
72%
Career Allowance Rate
58 granted / 80 resolved
+7.5% vs TC avg
Minimal +4% lift
Without
With
+4.5%
Interview Lift
resolved cases with interview
Typical timeline
2y 12m
Avg Prosecution
42 currently pending
Career history
136
Total Applications
across all art units

Statute-Specific Performance

§103
92.2%
+52.2% vs TC avg
§102
6.2%
-33.8% vs TC avg
§112
1.3%
-38.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 80 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 . Response to Arguments The applicant’s amendment to claim 13 is sufficient to resolve the objection to said claim presented in the previous office action of record. The objection is accordingly withdrawn. Applicant's arguments filed 01/20/2026 have been fully considered but they are not persuasive. The applicant has presented an amendment which combines the features of claims 7 and 8 into independent claim 1. In response to applicant's argument that their overlapping holes of different sizes result in an unexpected benefit, the fact that the inventor has recognized another advantage which would flow naturally from following the suggestion of the prior art cannot be the basis for patentability when the differences would otherwise be obvious. See Ex parte Obiaya, 227 USPQ 58, 60 (Bd. Pat. App. & Inter. 1985). Here, the feature which the applicant is asserting provide the unexpected benefit, i.e. overlapping holes of different sizes, is present in the primary reference Heo, as depicted in their figure 5, where the size of the second hole TH1 is larger than the size of the first hole TH2. Accordingly, any benefit of such design would inherently flow once said design is disassembled. Further, where the applicant asserts that Heo in view of Park fails to teach or suggest the structural and functional features of the claimed application, the features which the applicant is discussing are not claimed. In response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., when the number of cells is changed, the enclosure cover can be repositioned to move the bus bar and terminal block without a need to newly provide or replace the bus bar and terminal block) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). These features, though they may be functional results of the structure presented in the applicant’s embodiments, cannot be read into the claims where they are not claimed. Further, even if claimed, the benefits in regards to assembly/disassembly would flow once the design is assembled/disassembled, as the structure of overlapping holes of different sizes is present in the primary reference Heo. This feature is depicted in their figure 5, where the size of the second hole TH1 is larger than the size of the first hole TH2. Accordingly, any benefit of such design would inherently flow once said design is disassembled. 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. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 1-6 and 9-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Heo (IS 20210126274 A1), in view of Park (US 20140349164 A1). Regarding Claim 1, Heo is an analogous art to the instant application, disclosing an electrochemical stack assembly comprising an enclosure in which a plurality of cells arranged in a reference direction are disposed, the enclosure including an opening (Abstract, “A fuel cell is disclosed. The fuel cell includes a cell stack including a plurality of unit cells stacked in a first direction, an enclosure surrounding side portions of the cell stack and including at least one opening to expose at least one of opposite end portions of the cell stack therethrough,”), as well as an enclosure cover seated on the enclosure to cover the opening (Abstract, “first and second end plates respectively disposed at the opposite end portions of the cell stack,”). Additionally, Heo discloses a fastening member (Paragraph 0077, “a coupling screw 160”) passing through a first hole of the enclosure and a second hole of the enclosure, as depicted in Heo’s figure 5, where the fastening member passes through a first through hole TH2 (Paragraph 0131, “In addition, according to the embodiment, the second portion P2 may include a second through-hole TH2. The second through-hole TH2 may be formed so as to allow the coupling screw 160 to pass therethrough,”) and a second through hole TH1 (Paragraph 0107, “Each of the partition walls SWA and SWB may include a first through-hole TH1 through which the coupling screw 160 passes.”), so as to fasten the enclosure and enclosure cover to each other (Paragraph 0107, “The coupling screw 160 may penetrate each of the partition walls SWA and SWB and the clamping member 130 and may be inserted into and fixed to the interior of each of the bodies BA and BB. To this end, each of the bodies BA and BB may include a blind hole BH formed therein.”; Paragraph 0131, “As such, since the coupling screw 160 passes through both the first and second through-holes TH1 and TH2, which are opposite each other, the fixing force of the coupling screw 160 may further increase.”). Additionally, in regards to the limitation of the instant claim, which further requires a terminal block coupled to the enclosure cover, wherein the enclosure cover includes a cover body and an insertion hole communicating with the opening wherein the terminal block is inserted into the insertion hole, though Heo discloses structure where the enclosure cover includes a cover body, depicted in their figure 4, they fail to disclose structure which comprises a terminal block coupled to said enclosure cover, as well as an insertion hole communicating with the opening which the terminal block is inserted into. Therefore, we look to Park, which is an analogous art to the instant application, disclosing a battery module comprising battery cells having a block structure with power terminal portions and associated connection portions (Abstract, “A battery module includes a first battery cell, the first battery cell having a first electrode terminal and a second electrode terminal, a first end block adjacent to the first battery cell, the first end block having a first power terminal portion, and a connection portion electrically connecting the first electrode terminal to the first power terminal portion.”). Here, Park discloses structure which comprises a terminal block (Paragraph 0052, “an extending region 145 bent at a bending portion 143 from the first connection region 141 and extended toward the power terminal portion 151;”), which have a connection portion which connects the terminal block to the battery array (Paragraph 0042, “and a connection portion electrically connecting a terminal portion 111a of the battery cell 110a disposed at the outermost side of the battery cells 110 to the power terminal portion 151.”; Paragraph 0052, “The connection portion 140 may include a first connection region 141 electrically connected to the terminal portion 111a of the battery cell 110a disposed at the outermost side of the battery cells 110;”). Additionally, Park’s terminal block comprises a current collection plate including a current collection terminal electrically connected to the plurality of cells to transmit power of the plurality of cells to a contact target (Paragraph 0052, “The connection portion 140 may include a first connection region 141 electrically connected to the terminal portion 111a of the battery cell 110a disposed at the outermost side of the battery cells 110”). Additionally, Park discloses that their cell terminal block further comprises bus bars which electrically connect the terminal block and current collection terminal to each other, disposed within the enclosure (Paragraph 0045, “The positive and negative electrode terminals 112 and 113 of two neighboring battery cells 110 may be electrically connected to each other by a bus-bar 130.”; Paragraph 0046, “According to the present example embodiment, an outermost bus-bar 131 is connected to the terminal portion 111a, to which the bus-bar 130 is not connected, of the terminal portions 111a”) Here, Park further discloses that their terminal structure allows for the interconnection of battery cells, as well as allowing for interconnectivity between the battery module and other external components such as another battery module, as well as acting to prevent swelling of the battery cells (Paragraph 0071, “As described above, embodiments may provide a battery module including a power terminal for connecting battery modules to each other. In a battery module according to an embodiment, end blocks each having a power terminal portion are respectively disposed at outermost sides of a plurality of battery cells, so that the battery module may be connected to, e.g., another battery module. Further, the end blocks may strongly press the plurality of battery cells, which may help prevent a swelling phenomenon of the battery cell.”). Accordingly, based on this, it would be obvious to one ordinarily skilled in the art to apply the structure of the terminal blocks of Park to the invention of Heo. Accordingly, this results in a terminal block coupled to the enclosure cover, as well as an insertion hole in the enclosure cover to allow for the entry of Park’s terminal’s connection portion, thereby resulting in structure which comprises an insertion hole communicating with the opening and wherein the terminal block is inserted into the insertion hole, reading upon and making obvious the limitation of the instant claim. Additionally, Heo discloses structure wherein a size of the second hole is different from a size of the first hole, depicted in their figure 5, where the size of the second hole TH1 is larger than the size of the first hole TH2. Regarding Claim 2, Heo anticipates the invention of Claim 1. Additionally, Heo discloses structure wherein an area of the cover is greater than the size of an area occupied by the opening, as depicted in their figure 5, where the enclosure cover extends past the bounds of the opening. Regarding Claim 3, Heo anticipates the invention of Claim 2. Additionally, Heo discloses structure wherein the second hole TH1 is located in an outer region of the enclosure which not overlapping the opening, as shown in Heo’s figure 5, where the second hole TH1 is located in an outer region of the enclosure, which does not overlap the opening along the z-axis direction of said figure 5. Regarding Claim 4, Heo anticipates the invention of Claim 2. Additionally, Heo discloses structure wherein the second hole TH1 has a shot shape extending in the reference direction, shown in Heo’s figure 5. Regarding Claim 5, Heo anticipates the invention of Claim 3. Additionally, Heo discloses structure where the enclosure cover is disposed to cover an entire area of the opening when a first end of the second hole in the reference direction, here a left end of the second hole TH1 overlaps the first hole TH2, where said covering of the opening is depicted as the standard state in figures 4 and 5, and where said overlapping is depicted in figure 5. Regarding Claim 6, Heo anticipates the invention of Claim 1. Additionally, Heo discloses structure wherein the enclosure cover is covers an entire area of the opening while being transited from a state in which the first end of the second hole in the reference direction and the first hole overlap each other to a state in which a second end of the second hole in a direction opposite to the reference direction and the first hole overlap each other, as depicted in their figure 5, where the default position of the first end of the second hole TH1 in the reference direction, here the left end of the hole along the x-axis, as well as a second end of the second hole in a direction opposite to the reference direction, here the right end of the second hole TH1, is such that both ends of the second hole TH1 overlap the first hole TH2. Additionally, Heo’s figures 4 and 5 depict structure where the enclosure cover is disposed to cover an entire area of the opening while this condition is met. Accordingly, where a process of transiting the state of the enclosure cover can be a state where no change occurs, the structure of Heo meets the requirements of the instant claim. Regarding Claim 9, modified Heo makes obvious the invention of Claim 1. Additionally, the structure of Park made obvious to apply to the structure of Heo as discussed above comprises a pair of end plates connected to the current collection plate, with a plurality of cells arranged in between the pair of end plates, with the end plates being end blocks 150, disposed at the ends of the battery cell stack shown in Park’s figure 2. Additionally, Park’s current collection terminal includes a positive terminal disposed in any one of the pair of end plates and a negative terminal disposed in a remaining one of the pair of end plates, where each current collection terminal includes a power terminal 153 (Paragraph 0049, “The power terminal portion 151 provides the battery module 100 with a power terminal 153 electrically connected to the terminal portion 111a of the battery cell 110a disposed at the outermost side of the battery cell 110, so that the battery module 100 may be connected to, e.g., another battery module through a power cable connected to the power terminal 153.”). Additionally, Park’s terminal structure’s bus bar comprises a first bus bar connected to the positive terminal (Paragraph 0053, “The first connection region 141 may be connected to the outermost bus-bar 131 connected to the terminal portion 111a of the battery cell 110a disposed at the outermost side of the battery cells 110, so as to be electrically connected to the terminal portion 111a through the outermost bus-bar 131.”), where the terminal structure has a respective instance which connects to both the positive and negative terminal respectively. Regarding Claim 10, modified Heo makes obvious the invention of Claim 9. Additionally, Park’s terminal block assembly made obvious to apply to the invention of Heo, as discussed above, comprises a first terminal block connected to the first bus bar and a second terminal block connected to the second bus bar, depicted in Park’s figure 2. Additionally, Heo discloses structure wherein their enclosure cover includes a first enclosure cover and a second enclosure cover, shown in Heo’s figure 4, where as discussed above each enclosure coupled to a respective terminal block, and where Heo’s figure 4 further shows a respective first opening covered by the first enclosure cover and a second opening covered by the second enclosure cover. Regarding Claim 11, modified Heo makes obvious the invention of Claim 10. Additionally, Heo discloses structure wherein the second opening is spaced apart from the first opening in the reference direction, as shown in figure 4, where the first and second openings are located at respective right and left sides of the battery assembly. Regarding Claim 12, modified Heo makes obvious the invention of Claim 11. Additionally, where the instant claim requires structure wherein the fastening member includes a first fastening member that passes through a (1-1)th hole of the enclosure and a (2-1)th hole of the enclosure cover to fasten the enclosure to and first enclosure cover to each other, where the (1-1)th hole is the hole TH2 of the enclosure and the (2-1)th hole is the hole TH1 of the enclosure cover, as shown in Heo’s figure 5, where the fastening member fastens the enclosure and first enclosure cover to each other (Paragraph 0107, “The coupling screw 160 may penetrate each of the partition walls SWA and SWB and the clamping member 130 and may be inserted into and fixed to the interior of each of the bodies BA and BB. To this end, each of the bodies BA and BB may include a blind hole BH formed therein.”; Paragraph 0131, “As such, since the coupling screw 160 passes through both the first and second through-holes TH1 and TH2, which are opposite each other, the fixing force of the coupling screw 160 may further increase.”). Additionally, the (2-1)th hole TH1 overlaps the (1-1)th hole TH2 and is larger, again depicted in Heo’s figure 5. Additionally, the (1-1)th hole TH2 overlaps a left end of the (2-1)th hole TH1 in a direction opposite to the reference direction. Here, where Heo does not disclose movement of their enclosure covers, the enclosure covers are therefore closest to each other in the reference direction in the state of the embodiment depicted in Heo’s figure 5, where said overlapping is depicted. Regarding Claim 13, modified Heo makes obvious the invention of Claim 1. Additionally, where Park’s terminal portion which extends from within the enclosure includes a portion which curves upwards, as shown in Park’s figure 3, the terminal block therefore includes a terminal opening which opens upward, additionally, where the bus bar 131 connects to the terminal block which comprises the terminal opening, the bus bar is therefore exposed transitively to an outside of the terminal block through the terminal opening, by means of contact with the terminal components, thereby allowing the results of external exposure, such as thermal and electrical energy exposure. Regarding Claim 14, modified Heo makes obvious the invention of Claim 13. Additionally, Park’ exposure part includes a region protruding outward from the terminal block, as shown in their figure 3, that being the part which arcs upwards from both the terminal part and the busbar. Regarding Claim 15, Heo anticipates the invention of Claim 1. Additionally, Heo discloses structure wherein the opening opens upward, the opening opening in the x-axis direction as depicted in Heo’s figures 4 and 5, which is here defined as an upward direction, and the enclosure cover is seated on an upper surface of the enclosure, shown in figure 4 where the enclosure cover extends to an upper side of the enclosure and is seated thereupon. Regarding Claim 16, Heo anticipates the invention of Claim 1. Additionally, Heo discloses structure wherein a size of the second hole TH1 is greater than a size of the first through hole TH2, as depicted in their figure 5, where the spatial bounds of the first through hole TH2 are encompassed by the bounds of the second through hole TH1. Conclusion THIS ACTION IS MADE FINAL. 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 JONATHAN W ESTES whose telephone number is (571)272-4820. The examiner can normally be reached Monday - Friday 8:00 - 5:30. 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, Basia Ridley can be reached at 5712721453. 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.W.E./Examiner, Art Unit 1725 /BASIA A RIDLEY/Supervisory Patent Examiner, Art Unit 1725
Read full office action

Prosecution Timeline

Jun 10, 2022
Application Filed
Oct 17, 2025
Non-Final Rejection mailed — §103
Jan 20, 2026
Response Filed
Apr 21, 2026
Final Rejection mailed — §103
Jun 22, 2026
Response after Non-Final Action

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

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Prosecution Projections

2-3
Expected OA Rounds
72%
Grant Probability
77%
With Interview (+4.5%)
2y 12m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 80 resolved cases by this examiner. Grant probability derived from career allowance rate.

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