Prosecution Insights
Last updated: April 19, 2026
Application No. 17/870,521

BATTERY MODULE AND BATTERY PACK INCLUDING BATTERY MODULES

Non-Final OA §103§112
Filed
Jul 21, 2022
Examiner
CORNO JR, JAMES ANTHONY JOHN
Art Unit
1722
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Subaru Corporation
OA Round
3 (Non-Final)
37%
Grant Probability
At Risk
3-4
OA Rounds
3y 5m
To Grant
75%
With Interview

Examiner Intelligence

Grants only 37% of cases
37%
Career Allow Rate
48 granted / 130 resolved
-28.1% vs TC avg
Strong +38% interview lift
Without
With
+38.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
52 currently pending
Career history
182
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
61.7%
+21.7% vs TC avg
§102
16.8%
-23.2% vs TC avg
§112
15.4%
-24.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 130 resolved cases

Office Action

§103 §112
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 . Continued Examination Under 37 CFR 1.114 A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on November 12, 2025, has been entered. Claim Rejections - 35 USC § 112 The following is a quotation of the first paragraph of 35 U.S.C. 112(a): (a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112: The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention. Claims 4, 5, 8, 9, 12, and 16-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Claims 4, 5, 16, and 18 include the limitation "wherein the second coupling protrusion includes at least two different types of coupling holes, with one type of coupling hole for fixing the cover plate to cover the upper surfaces of the battery stacks." There is no support in the instant specification for coupling the second coupling protrusion to the cover plate. The two types of coupling holes in the second coupling protrusions described in the instant specification are for (1) coupling to the side plates of the same battery and for (2) coupling to the first coupling protrusions of the battery module below (p. 11 and Fig. 3 of the instant specification). Claims 8, 9, 12, 17, 19, and 20 depend from these claims and therefore include the same unsupported limitation. For the purpose of examination, the limitations will be read as "wherein the second coupling protrusion includes at least two different types of coupling holes, with one type of coupling hole for fixing the side plate of the same battery module," consistent with p. 11 of the instant specification. 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) 1-8 and 13-19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lee et al. (US 2011/0151311 A1) in view of Wang et al. (US 2016/0315366 A1) and Handing et al. (US 2018/0212216 A1). Regarding claims 1 and 14, Lee teaches a battery module comprising a battery stack (unit cells 110), a bottom plate (lower frame 130), end plates (150) sandwiching the stack in the stacking direction, and side plates (140) covering the other sides, with coupling protrusions (vertical supports 140b) extending up from the side plates and coupling protrusions (bent portions 132) extending down from the bottom plate (Fig. 2). PNG media_image1.png 1956 2468 media_image1.png Greyscale The plates are attached at their ends to the end plates 150 and have therefore necessarily been adjusted in length (and therefore shape) based on the length of the stack. Lee does not teach that the first coupling protrusions extend from a hollow structure. Wang teaches a battery thermal management system comprising hollow side plates (manifolds 70 and 74; Wang Figs. 2 and 3). Wang teaches that this system allows for thermal regulation of the battery cells (Wang [0026]) with uniform temperature distribution (Wang [0033]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to incorporate the cooling system of Wang into the battery of Lee in order to uniformly regulate the temperature of the cells, including the hollow side plates from which the coupling protrusions would protrude. Lee does not teach that the second coupling protrusions extend from a hollow structure. Handing teaches a base plate for battery modules with a hollow structure (Handing Fig. 1 and [0065]). Handing teaches that this allows for reduced weight and increased strength (Handing [0016]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to make the base plate of Lee hollow as taught by Handing to allow for reduced weight and increased strength, and the second coupling protrusions would necessarily protrude downward from this structure. Regarding claim 2, modified Lee teaches that forming the plates by extrusion allows for a reinforced, light metal profile (Handing [0055]-[0058]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to form the plates by extrusion to achieve a reinforced, light metal profile Regarding claim 3, the thermal management system comprises side plates with air inlets (72) and outlets (74) forming two cooling paths flowing in the stacking direction and in communication with each other by gaps between adjacent battery cells (56) (Wang Fig. 5). Modified Lee gives examples in which the battery stacks are fixed to a lower surface (base frame 160, Lee Fig. 4 and [0076] or base frame 360, Lee Fig. 8 and [0096]). Lee teaches that the battery stacks may be coupled to an external or cover frame by means of the first protrusion (Lee [0096]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to couple the stacks to either or both of an upper and lower cover, since Lee teaches that either are acceptable options. Modified Lee does not teach the use of different coupling holes in the first protrusion for fixing the cover plate and fixing the battery stack. Modified Lee discloses two different types of coupling holes on the first protrusion: horizontal (Lee Fig. 4) and vertical (Lee Fig. 8). 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 combination of the listed options, including using horizontal coupling holes to fix the stacks to each other and vertical coupling holes to fix the stack to the supporting structure (i.e. the cover). PNG media_image2.png 869 2265 media_image2.png Greyscale Regarding claim 4, the thermal management system comprises side plates with air inlets (72) and outlets (74) forming two cooling paths flowing in the stacking direction and in communication with each other by gaps between adjacent battery cells (56) (Wang Fig. 5). The second protrusions of modified Lee include different coupling holes for fixing the battery stack and for fixing the side plate of the same battery module (Lee Fig. 4 below). PNG media_image3.png 831 1366 media_image3.png Greyscale Regarding claims 5, Modified Lee gives examples in which the battery stacks are fixed to a lower surface (base frame 160, Lee Fig. 4 and [0076] or base frame 360, Lee Fig. 8 and [0096]). Lee teaches that the battery stacks may be coupled to an external or cover frame by means of the first protrusion (Lee [0096]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to couple the stacks to either or both of an upper and lower cover, since Lee teaches that either are acceptable options. The battery modules are fixed vertically to one another to form stacks, and the stacks are fixed in parallel to each other by coupling the stacks to the frame (Lee Figs. 4 and 8). Modified Lee does not teach the use of different coupling holes in the first protrusion for fixing the cover plate and fixing the battery stack. Modified Lee discloses two different types of coupling holes on the first protrusion: horizontal (Lee Fig. 4) and vertical (Lee Fig. 8). 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 combination of the listed options, including using horizontal coupling holes to fix the stacks to each other and vertical coupling holes to fix the stack to the supporting structure (i.e. the cover). The second protrusions of modified Lee include different coupling holes for fixing the battery stack and for fixing the side plate of the same battery module (Lee Fig. 4). Regarding claims 6-8, Modified Lee gives examples in which the battery stacks are fixed to a lower surface (base frame 160, Lee Fig. 4 and [0076] or base frame 360, Lee Fig. 8 and [0096]). Lee teaches that the battery stacks may be coupled to an external or cover frame by means of the first protrusion (Lee [0096]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to couple the stacks to either or both of an upper and lower cover, since Lee teaches that either are acceptable options. The battery modules are fixed vertically to one another to form stacks, and the stacks are fixed in parallel to each other by coupling the stacks to the frame (Lee Figs. 4 and 8). Regarding claim 13, modified Lee teaches the use of the battery in a vehicle (Lee [0108]). Regarding claim 15, modified Lee teaches that forming the plates by extrusion allows for a reinforced, light metal profile (Handing [0055]-[0058]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to form the plates by extrusion to achieve a reinforced, light metal profile Modified Lee gives examples in which the battery stacks are fixed to a lower surface (base frame 160, Lee Fig. 4 and [0076] or base frame 360, Lee Fig. 8 and [0096]). Lee teaches that the battery stacks may be coupled to an external or cover frame by means of the first protrusion (Lee [0096]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to couple the stacks to either or both of an upper and lower cover, since Lee teaches that either are acceptable options. Modified Lee does not teach the use of different coupling holes in the first protrusion for fixing the cover plate and fixing the battery stack. Modified Lee discloses two different types of coupling holes on the first protrusion: horizontal (Lee Fig. 4) and vertical (Lee Fig. 8). 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 combination of the listed options, including using horizontal coupling holes to fix the stacks to each other and vertical coupling holes to fix the stack to the supporting structure (i.e. the cover). Regarding claims 16 and 17, the system of modified Lee includes a battery thermal management system comprising side plates with air inlets (72) and outlets (74) forming two cooling paths flowing in the stacking direction and in communication with each other by gaps between adjacent battery cells (56) (Wang Fig. 5). The second protrusions of modified Lee include different coupling holes for fixing the battery stack and for fixing the side plate of the same battery module (Lee Fig. 4). Regarding claims 18, Modified Lee gives examples in which the battery stacks are fixed to a lower surface (base frame 160, Lee Fig. 4 and [0076] or base frame 360, Lee Fig. 8 and [0096]). Lee teaches that the battery stacks may be coupled to an external or cover frame by means of the first protrusion (Lee [0096]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the instant invention to couple the stacks to either or both of an upper and lower cover, since Lee teaches that either are acceptable options. Modified Lee does not teach the use of different coupling holes in the first protrusion for fixing the cover plate and fixing the battery stack. Modified Lee discloses two different types of coupling holes on the first protrusion: horizontal (Lee Fig. 4) and vertical (Lee Fig. 8). 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 combination of the listed options, including using horizontal coupling holes to fix the stacks to each other and vertical coupling holes to fix the stack to the supporting structure (i.e. the cover). The second protrusions of modified Lee include different coupling holes for fixing the battery stack and for fixing the side plate of the same battery module (Lee Fig. 4). Regarding claim 19, the battery modules are fixed vertically to one another to form stacks, and the stacks are fixed in parallel to each other by coupling the stacks to the frame (Lee Figs. 4 and 8). Claim(s) 9-12 and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lee in view of Wang and Handing as applied to claims 5-8 and 18 above, and further in view of Sundararajan et al. (US 2014/0147717 A1) and Gunther et al. (US 2019/0273231 A1). Regarding claims 9-11, modified Lee does not teach any particular means for attaching the battery to a vehicle body. However, fixing portions extending from a covering component for the purpose of attaching a battery to a vehicle body are well known. See, for example, Sundararajan (feet 36, Fig. 3) and Gunther (mounting flange 11, Figs. 2 and 3). 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 means to attach the battery of modified Lee to the vehicle body, including by fixing portions extending from the cover. Regarding claims 12 and 20, modified Lee does not teach any particular means for attaching the battery to a vehicle body. However, fixing portions extending from a covering component for the purpose of attaching a battery to a vehicle body are well known. See, for example, Sundararajan (feet 36, Fig. 3) and Gunther (mounting flange 11, Figs. 2 and 3). 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 means to attach the battery of modified Lee to the vehicle body, including by fixing portions extending from the cover. The plates of modified Lee have a skeletal structure (Lee Fig. 2 and Handing Figs. 1-4). Conclusion 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 /NIKI BAKHTIARI/ Supervisory Patent Examiner, Art Unit 1722
Read full office action

Prosecution Timeline

Jul 21, 2022
Application Filed
Mar 20, 2025
Non-Final Rejection — §103, §112
May 30, 2025
Response Filed
Aug 06, 2025
Final Rejection — §103, §112
Oct 14, 2025
Response after Non-Final Action
Nov 12, 2025
Request for Continued Examination
Nov 13, 2025
Response after Non-Final Action
Feb 26, 2026
Non-Final Rejection — §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
37%
Grant Probability
75%
With Interview (+38.1%)
3y 5m
Median Time to Grant
High
PTA Risk
Based on 130 resolved cases by this examiner. Grant probability derived from career allow rate.

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