Prosecution Insights
Last updated: October 01, 2026
Application No. 17/870,755

RECHARGEABLE BATTERY

Final Rejection §103
Filed
Jul 21, 2022
Priority
Apr 21, 2020 — RE 10-2020-0048221 +2 more
Examiner
DISNEY, CHRISTINE CONLON
Art Unit
1723
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Samsung SDI Co., Ltd.
OA Round
4 (Final)
22%
Grant Probability
At Risk
5-6
OA Rounds
0m
Est. Remaining
48%
With Interview

Examiner Intelligence

Grants only 22% of cases
22%
Career Allowance Rate
6 granted / 27 resolved
-42.8% vs TC avg
Strong +26% interview lift
Without
With
+25.8%
Interview Lift
resolved cases with interview
Typical timeline
4y 0m
Avg Prosecution
19 currently pending
Career history
66
Total Applications
across all art units

Statute-Specific Performance

§103
66.0%
+26.0% vs TC avg
§102
15.4%
-24.6% vs TC avg
§112
9.8%
-30.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 27 resolved cases

Office Action

§103
DETAILED ACTION 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 Amendment This is a final office action in response to Applicant’s remarks and amendments filed on 01/28/2026. Claim 1 is currently amended. Claims 10-11, and 17 remain withdrawn. Claim 20 is new. Claims 1-4, 7-9, 12-16, and 18-20 are presented for examination. The 35 U.S.C. § 102 and 103 rejections in the previous office action are withdrawn. New grounds of rejection necessitated by Applicant's amendments are presented below. Response to Arguments Applicant’s arguments with respect to claim 1 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. The new ground of rejection does not rely on Katsumoto and does not rely on Eguchi to teach “an end of the terminal portion opposite to the flange portion forming an outermost end of the terminal plate, wherein a height of the end of the terminal portion from the electrode assembly is lower than a height of a surface of the cap plate from the electrode assembly” as required by amended claim 1. Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1-5, 8, and 12-16 are rejected under 35 U.S.C. 103 as being unpatentable over of Eguchi (US 2022/0311108 A1; priority to Japanese patent application JP2019-219432, filed 12/04/2019; previously cited) in view of Guo (US 2021/0408650 A1; previously cited). Regarding claim 1, Eguchi discloses a button cell (100, FIGS. 3A and 5B, [0116]) comprising: an electrode assembly (10, FIGS. 1 and 5B, [0039]) comprising a first electrode (1, FIG. 1, [0039]) and a second electrode (2, FIG. 1, [0039]) spaced from the first electrode (1), the first electrode (1) and the second electrode (2) being wound around an axis (FIG. 5B), and the electrode assembly (10) including an open cavity (open cavity in annotated figure 1 below) extending along the axis; a case (52, FIG. 5B, [0071]) having a bottom portion (bottom portion in annotated figure 1 below) and a side wall (side wall in annotated figure 1) extending from the bottom portion (bottom portion) to receive the electrode assembly (10), and including an opening (opening in annotated figure 1) for exposing the electrode assembly (10), the case (52) being connected to the first electrode (1) (the metal exterior body serves as a positive electrode and therefore is connected to the positive, or first, electrode, [0076]); a cap plate (54, FIG. 5B, [0071]) welded to an edge of the side wall (side wall) of the case (52) to cover a peripheral region of the opening (opening), and including a through-hole (opening portion 55, FIG. 5B, [0099]) for exposing a center region of the opening (opening), the cap plate (54) being electrically connected to the case (the metal exterior body includes both the case and the cap plate [0093] and serves as a positive electrode, [0076]); a terminal plate (60, FIG. 3A, [0059]) located between the cap plate (54) and the electrode assembly (10) to cover the center region of the opening (opening), and connected to the second electrode (2) (terminal plate includes a metal plate 62 that is connected to the negative electrode via tab 70, FIGS. 3A and 5B, [0059]-[0060]); and a sealing portion (insulating member 64, FIG. 5B, [0089]) located between the cap plate (54) and the terminal plate (60), and bonding between the cap plate (54) and the terminal plate (60) ([0089]), and wherein the terminal plate (60) comprises: a flange portion (62, FIG. 5B, [0092]) overlapping the cap plate (54). PNG media_image1.png 350 646 media_image1.png Greyscale Annotated figure 1 (Eguchi FIG. 5) Eguchi does not disclose wherein the terminal plate is located between the cap plate and the electrode assembly, wherein the terminal plate comprises a terminal portion protruding from the flange portion corresponding to the through-hole, an end of the terminal portion opposite to the flange portion forming an outermost end of the terminal plate, wherein a height of an end of the terminal portion from the electrode assembly is lower than a height of a surface of the cap plate from the electrode assembly, and wherein the end of the terminal portion is disposed in the through-hole. However, in the embodiment of FIG. 7, Eguchi teaches a button cell comprising a terminal plate (60, FIG. 7, [0080]) located between a top surface of the metal exterior body (analogous to the cap plate of the FIG. 5B embodiment because it includes a through-hole as depicted in annotated figure 2 below) and the electrode assembly (not depicted in the FIG. 7 embodiment), wherein the terminal plate (60) comprises a terminal portion (67) protruding from the flange portion (62) corresponding to the through-hole (through-hole), and wherein the end of the terminal portion (67) opposite to the flange portion (62) forming an outermost end the terminal plate (60) is disposed in the through-hole (through-hole). It would have been obvious to a person having ordinary skill in the art before the effective filing date of the invention before the effective filing date of the claimed invention to have modified button cell of Eguchi FIG. 5B to substitute the terminal plate 60 from the FIG. 7 embodiment of Eguchi, such that the terminal plate is located between the cap plate and the electrode assembly, the terminal plate comprises a terminal portion protruding from the flange portion corresponding to the through-hole, and an end of the terminal portion opposite to the flange portion forming an outermost end of the terminal plate, because Eguchi teaches that doing so improves the energy density of the battery and can contribute to an increase of the degree of freedom in designing the secondary battery ([0081]). In addition, Eguchi teaches that the button cell may be modified beyond the embodiments of the disclosure ([0155]) and it has been held that combining two embodiments disclosed adjacent to each other in prior art does not require a leap of inventiveness and involves only routine skill in the art. PNG media_image2.png 162 404 media_image2.png Greyscale Annotated figure 2 (Eguchi FIG. 7) Guo teaches a button cell (100, FIGS. 1-4, [0038]) comprising an electrode assembly (10, FIG. 3, [0038]), a cap plate (21, FIG. 3, [0050]), and a terminal (40, FIG. 3, [0038]), wherein a height of the outermost surface of the terminal (40) from the electrode assembly (10) is lower than a height of a surface of the cap plate (21) from the electrode assembly (10) (FIG. 3). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have modified the battery of Eguchi by reducing the height of the terminal portion, such that a height of the outermost surface of the terminal portion from the electrode assembly is lower than a height of a surface of the cap plate from the electrode assembly, because Guo teaches that doing so improves the energy density of the battery by reducing a thickness of the case ([0022]) and reduces the risk of short circuit ([0044]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments depicted in the disclosure ([0155]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results ([MPEP § 2143A]). Regarding claim 2, Eguchi in view of Guo teaches (see Eguchi) wherein the flange portion (62) has a greater area than the terminal portion (67) (the width of the flange portion is greater than the width of the terminal portion in FIG. 7). Regarding claim 3, Eguchi in view of Guo teaches (see Eguchi) wherein the flange portion (62) contacts the sealing portion (64), and the terminal portion (67) does not contact the sealing portion (64) (FIG. 7). Regarding claim 4, Eguchi in view of Guo teaches (see Eguchi) wherein the flange portion (62) is parallel to the cap plate (54) (FIG. 5B). Regarding claim 7, Eguchi in view of Guo teaches (see Eguchi) wherein the terminal portion (67) is integrally formed with (welded to, [0123]) the flange portion (62). Regarding claim 8, Eguchi in view of Guo teaches (see Eguchi) wherein a thickness of the terminal portion (67) is greater than a thickness of the flange portion (62) (FIG. 7). Regarding claim 12, Eguchi in view of Guo teaches (see Eguchi) wherein a first end (toward bottom of page in FIG. 5B) of the electrode assembly (10) faces the case (52), and a second end (toward top of page in FIG. 5B) of the electrode assembly (10) faces the flange portion (62). Regarding claim 13, Eguchi in view of Guo teaches (see Eguchi) wherein the electrode assembly (10) further includes: a separator (3, FIG. 1, [0039]) between the first electrode (1) and the second electrode (2); and a second electrode tab (70, FIGS. 3A and 5B, [0059]-[0060]) for connecting between the second electrode (2) and the terminal plate (60), and contacting the flange portion (62). Eguchi in view of Guo does not disclose a first electrode tab for connecting between the first electrode and the case, and contacting the case. However, Guo further teaches a case (22, FIG. 3, [0062]) connected to a first electrode (12, FIG. 3, [0065]) and a first electrode tab (102, FIG. 3, [0062]) for connecting between the first electrode (12) and the case (22), and contacting the case (22). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have further modified the battery of Eguchi in view of Guo by adding a first electrode tab for connecting between the first electrode and the case, and contacting the case, because Guo teaches such a tab may electrically connect between the case and the first electrode ([0062]). In addition, Eguchi teaches that the button cell may be modified beyond the embodiments depicted in the disclosure ([0155]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results ([MPEP § 2143A]). Regarding claim 14, Eguchi in view of Guo does not disclose wherein the flange portion is disposed between the second electrode tab and the sealing portion in the embodiment of Eguchi FIGS. 3A and 5B. However, in modifying the Eguchi FIG. 5B embodiment such that the terminal plate has the configuration of the Eguchi FIG. 7 embodiment as discussed in claim 1, a person having ordinary skill in the art before the effective filing date of the invention would find it obvious to adopt the configuration of Eguchi FIGS. 3B and FIG. 7 in which the flange portion (62) is disposed between the second electrode tab (70) and the sealing portion (64) because Eguchi teaches that doing so improves the energy density of the battery and can contribute to an increase of the degree of freedom in designing the secondary battery ([0081]). In addition, Eguchi teaches that the button cell may be modified beyond the embodiments of the disclosure ([0155]) and it has been held that combining two embodiments disclosed adjacent to each other in prior art does not require a leap of inventiveness and involves only routine skill in the art. Regarding claim 15, Eguchi in view of Guo teaches (see Eguchi) wherein the sealing portion (64) insulates between the cap plate (54) and the terminal plate (60) ([0069]). Regarding claim 16, Eguchi in view of Guo teaches (see Eguchi) wherein a surface of the terminal potion (67) facing the electrode assembly (10) has a flat shape (lower surface in FIG. 7). Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Guo (US 2021/0408650 A1), as applied to claim 8 above, and further in view of Aress High Duty Forgings (5 Reasons Why Aluminium Forging is Better Than Aluminum Casting, 2018; cited 11/13/2024). Regarding claim 9, Eguchi teaches wherein the terminal plate (60) includes aluminum ([0067]), but Eguchi in view of Guo does not disclose wherein the terminal plate includes forged aluminum. Aress High Duty Forgings teaches forged aluminum. A person having ordinary skill in the art before the effective filing date of the claimed invention would have found it obvious to have used forged aluminum for the terminal plate of Eguchi with a reasonable expectation of improving its strength and reducing production costs as taught by Aress High Duty Forgings (p. 1-2). Claims 18 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Guo (US 2021/0408650 A1), as applied to claim 1 above, and further in view of Jung (US 2017/0117516 A1; previously cited). Regarding claim 18, Eguchi in view of Guo does not disclose wherein the terminal portion is connected to the flange portion by a curved surface. Jung teaches a battery ([0008]) including an electrode assembly (100, FIG. 4, [0075]), a case (200, FIG. 4, [0075]) to receive the electrode assembly (100), and a terminal plate (cap assembly 270 serving as an electrode assembly, FIGS. 4 and 5, [0075] and [0077]), wherein the terminal plate (270) comprises: a flange portion (216, FIGS. 4 and 5, [0078]) and a terminal portion (217’, FIGS. 4 and 5, [0077]) protruding from the flange portion (216) corresponding to a through-hole (212, FIG. 4, [0078]), wherein the terminal portion (217’) is connected to the flange portion (216) by a curved surface (curved surface in annotated figure 3 below). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to modify the terminal plate of Eguchi in view of Guo such that the terminal portion is connected to the flange portion by a curved surface as taught by Jung (FIG. 4) because such a configuration is known in the art and therefore the modification would be considered a mere change in shape in shape [MPEP § 2144.04(IV)B]. Further, Eguchi teaches that the button cell may be modified beyond the embodiments of the disclosure ([0155]). PNG media_image3.png 244 556 media_image3.png Greyscale Annotated figure 3 – Jung FIG. 4 Regarding claim 19, Eguchi in view of Guo does not disclose wherein a distance between the terminal portion and a circumference of the through-hole is gradually decreased toward the flange portion. Jung teaches a battery ([0008]) including an electrode assembly (100, FIG. 4, [0075]), a case (200, FIG. 4, [0075]) to receive the electrode assembly (100), and a terminal plate (cap assembly 270 serving as an electrode assembly, FIGS. 4 and 5, [0075] and [0077]), wherein the terminal plate (270) comprises: a flange portion (216, FIGS. 4 and 5, [0078]) and a terminal portion (217’, FIGS. 4 and 5, [0077]) protruding from the flange portion (216) corresponding to a through-hole (212, FIG. 4, [0078]), wherein a distance between the terminal portion (217’) and a circumference of the through-hole (212) is gradually decreased toward the flange portion (216) (see annotated figure 3 above). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to modify the terminal plate of Eguchi in view of Guo such that a distance between the terminal portion and a circumference of the through-hole is gradually decreased toward the flange portion, as taught by Jung (FIG. 4), because such a configuration is known in the art and therefore the modification would be considered a mere change in shape in shape [MPEP § 2144.04(IV)B]. Further, Eguchi teaches that the button cell may be modified beyond the embodiments of the disclosure ([0155]). Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Guo (US 2021/0408650 A1), as applied to claim 1 above, and further in view of Ringel (DE-102018200159-A1, cited in the IDS filed 05/01/2026). Regarding claim 20, Eguchi in view of Guo teaches wherein the sealing portion (64) has a through-hole (see annotated figure 4 below), but does not disclose wherein the through-hole is coextensive with the through-hole in the cap plate. PNG media_image4.png 250 422 media_image4.png Greyscale Annotated figure 4 (Eguchi FIG. 5B) Ringel teaches a battery cell ([0001]) comprising a cap plate (114, FIG. 2, [0032]) including a through-hole (116, [0032]), a terminal plate (106, FIG. 2, [0032]) and a sealing portion (102, 110, and 112, FIG. 2, [0034]) located between and bonding between the cap plate (114) and the terminal plate (106), wherein the sealing portion (102/110/112) has a through-hole (around circumferential groove 118, FIG. 2, [0032]) that is coextensive with the through-hole (116) in the cap plate (114) (FIG. 2). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have modified the cell of Eguchi in view of Guo such that the through-hole in the sealing portion is coextensive with the through-hole in the cap plate because Ringel teaches that this configuration can yield a strong and insulating seal ([0024]-[0025]). In addition, Eguchi teaches that the button cell may be modified beyond the embodiments depicted in the disclosure ([0155]). 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 CHRISTINE C. DISNEY whose telephone number is (703)756-1076. The examiner can normally be reached M-F 8:30-5:30 MT. 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, Tiffany Legette-Thompson can be reached at (571) 270-7078. 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. /C.C.D./Examiner, Art Unit 1723 /TIFFANY LEGETTE/Supervisory Patent Examiner, Art Unit 1723
Read full office action

Prosecution Timeline

Show 2 earlier events
Feb 19, 2025
Response Filed
Jun 04, 2025
Final Rejection mailed — §103
Jul 31, 2025
Response after Non-Final Action
Aug 26, 2025
Request for Continued Examination
Aug 29, 2025
Response after Non-Final Action
Nov 05, 2025
Non-Final Rejection mailed — §103
Jan 28, 2026
Response Filed
Sep 21, 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
22%
Grant Probability
48%
With Interview (+25.8%)
4y 0m (~0m remaining)
Median Time to Grant
High
PTA Risk
Based on 27 resolved cases by this examiner. Grant probability derived from career allowance rate.

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