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 .
Claim Objections
Claims 1, 3-5, 7-11, and 14-16 objected to because of the following informalities: These claims contain references to figures. The examiner’s present opinion is that the claims as written are complete themselves and that an exceptional circumstance is not present that would deem references to figures necessary.
Where possible, claims are to be complete in themselves. Incorporation by reference to a specific figure or table "is permitted only in exceptional circumstances where there is no practical way to define the invention in words and where it is more concise to incorporate by reference than duplicating a drawing or table into the claim. Incorporation by reference is a necessity doctrine, not for applicant’s convenience." Ex parte Fressola, 27 USPQ2d 1608, 1609 (Bd. Pat. App. & Inter. 1993).
Appropriate correction is required.
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 05/20/2026 has been entered.
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, 3-5, 7-11, and 14-15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Saitou (US 20140038008 A1) in view of Masaryk (US 20200119418 A1) and Kopp (US20200176838A1).
Regarding claim 1, Saitou discloses a cooling device for cooling a circuit board (72) of a battery system comprising a plurality of battery cells (30) [0010-0014, 0041, 0063-0072, 0083 fig. 6 and 11, Saito], the cooling device having a cooling channel (72a/132) with a cooling channel base [0070, 0083, fig. 6 and 11, Saito describes a piping (72a) and a cooling mechanism for a coolant to flow through. Piping by nature has a base, top, and wall/side], with a cooling channel top [fig. 6 and 11, Saito], and with at least one cooling channel wall [fig. 6 and 11, Saito], wherein the circuit board is connectable in a heat-transferring manner to the cooling channel top on a side of the cooling channel top facing away from the cooling channel [0068-0072, 0083, fig. 6 and 11, Saito].
Saito discloses that the chip components (not shown) of the circuit board are mounted on a main surface opposite the main surface that the batteries are connected too. The examiner notes that the batteries are mounted on a main surface underneath of the circuit board (beneath 76). Therefore, the chip components would be on the other main surface, on top of 74. As such, the examiner notes that the chip components would be on a side of the cooling channel top facing away from the cooling channel. This reads on the applicant’s claim language.
In an effort to promote compact prosecution should it not be taken as above described, the examiner notes that Saito discloses two embodiments in which a circuit board is cooled by a cooling means (72a/132). In both instances the circuit board is connectable in a heat-transferring manner to the top side of the cooling means. In one embodiment the cooling means (72a) is within the circuit board and the second cooling means (132) the circuit board rests on top of the cooling means (“a side of the cooling channel top facing away from the cooling channel”). One of ordinary skill within the art prior to the time of filing would appreciate that one of ordinary skill within the art would find it obvious to mount the circuit board on top of the cooling means (72a) as this would still serve the same purpose of and yield a predictable result of cooling both the circuit board and batteries, see MPEP 2144.06.
Saitou further discloses the cooling device, wherein the cooling device has an inlet port (80) for inflow of a cooling liquid into the cooling channel and an outlet port (82) for outflow of the cooling liquid from the cooling channel [0072, Saito].
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Annotated figures of figs. 6 and 11 of Saito
Saito is silent to 1) a venting space and a venting interface. 2) The specifics of the cooling channel containing a first plane and a second plane arranged above the first plane and the venting space extending between the first and second plane. 3) A cooling channel with a plurality of flow disturbance devices extending from the base surface towards the cooling cannel base. 4) A cooling channel further including flow disturbance devices extending from an elevation surface toward the cooling channel base.
In regards to 1) and 2) Masaryk discloses a battery pack with a liquid cooling circuit (“cooling channel”) in thermal contact with the battery cells and a bypass tube having an inlet opening (“venting interface”) at the highest point of the liquid cooling circuit [abstract, 0016, Masaryk]. Masaryk discloses a carrier plate (31) with an integral liquid cooling circuit with two inlet openings (311) [0048-0049, Masaryk]. Wherein the cooling circuit includes a bypass tube having an inlet opening (81, “venting interface”) at a highest point of the cooling circuit for allowing air located above the liquid fluid (91, “venting space”) to pass through the inlet (81) [0055, 0058, fig. 5, Masaryk]. The cooling channel top of Masaryk has a first surface lying in a first plane (“E1”) and at least one elevation surface lying in a second plane (“E2”) defining an upper surface of a venting space [fig. 5, Masaryk]. Wherein, the second plane (“E2”) is arranged above the first plane (“E1”) and wherein the venting space extends between he first and second plane [fig. 5, Masaryk].
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Annotated fig. 5 of Masaryk depicting the venting space and interface
Prior to the effective filing date, one of ordinary skill within the arts would find it obvious to modify Saitou such that first include a venting interface was placed at a highest point in the cooling channel. Doing so would allow for air accumulated at the top of the cooling channel to pass through the venting interface [0058, Masaryk]. One of ordinary skill within the arts would additionally find it obvious to modify Saitou such that the venting interface had a first and second plane where the venting space extends between the two planes. This is a known structure that allows for air to pass through the venting interface [0058, fig. 5, Masaryk].
In regards to 3), Kopp discloses a battery module with a flow space (9, “cooling channel”) defined as the space between a receiving element (7, “base surface”) and cover plate (8, “cooling channel base”) and allowing for a temperature control fluid to flow [0012, 0084, fig. 2b, Kopp]. Wherein, a cooling channel (9) with a plurality of flow guidance elements (10, “flow disturbance devices”) extending from the base surface (7) towards the cooling cannel base (8) [0020, 0086, 2b, Kopp].
Prior to the effective filing date, one of ordinary skill within the arts would find it obvious to modify Saitou such that the cooling channel had a plurality of flow disturbance devices extending from the base surface towards the cooling channel base. Doing so would allow for improved heat transfer between the flow space and the heat temperature control fluid [0020-025, Kopp].
In regards to 4) Saitou as presently modified discloses a venting interface placed at a highest point in the cooling channel [see discussion of Masaryk above]. Wherein the venting interface has a venting space extending between a first and second plane [see discussion of Masaryk above]. The venting interface is located at an edge of the cooling channel [fig. 5, Masaryk]. Along with flow disturbance devices extending from the base surface towards the cooling channel base [see discussion of Kopp above].
Kopp depicts multiple embodiments of “flow disturbing devices” and the size, shape, and location on the “cooling channel top” [fig. 2b, 3b, 4a-5, Kopp]. Kopp further notes that by introducing these “flow disturbing devices” one can change the flow space from a laminar to a turbulent flow [0021-0023, Kopp], thereby increasing heat transfer between the coolant and battery cells [0041, Kopp].
Prior to the effective filing date, one of ordinary skill within the arts would appreciate that having the flow disturbing devices evenly distributed through the cooling channel would result in the flow disturbing devices being located on the cooling channel top and on the elevated surface.
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Examiners annotated figure of modified Saito showing the venting interface of Masaryk containing an elevated surface (“E2”) and the flow disturbance device of Kopp extending from the cooling channel top towards the cooling channel base. Along with a flow disturbance device extending from an elevated surface (“E2”).
Prior to the effective filing date, one of ordinary skill within the arts would find it obvious to modify Saito such that the cooling channel further including flow disturbance devices were evenly distributed throughout the cooling channel and extending from an elevation surface toward the cooling channel base. Doing so would allow for the coolant to be disturbed by the flow disturbance devices in order to increase the heat transfer between the coolant and the battery cells [0041, Kopp].
Regarding claim 3, modified Saitou discloses the cooling device, wherein the venting space rises along a flow path (46) of the cooling liquid at least in portions [0058, fig. 5, Masaryk].
Regarding claim 4, modified Saitou discloses the cooling device, wherein the venting space has an initial portion and an end portion along the flow path of the cooling liquid [fig. 5, Masaryk], wherein the venting interface is arranged in the end portion of the venting space [fig. 5, Masaryk].
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Annotated fig. 5, Masaryk depicting the venting interface being at an end portion of the venting space
Regarding claim 5, modified Saitou discloses the cooling device, wherein the inlet port (80) and/or the outlet port (82) are arranged below the base surface [fig. 6, Saito depicts the inlet and outlet port being arranged such that they are below the base surface of the cooling channel].
Regarding claim 7, modified Saitou discloses the cooling device, wherein the venting space is arranged in a U-shape around the base surface, at least in portions [0070, fig. 6, Saito].
The examiner notes that Saito discloses the cooling pipes “meander” wherein the piping 72a moves towards the viewer and then away from the viewer, and repeats. This meandering creates a “U-shape”. The examiner notes that based off of the BRI of “a U-shape” any shape with a bend in it can be considered a U-shape, at least in portion.
Regarding claim 8, modified Saitou discloses the cooling device, wherein the cooling device has a main body (76) [0066, Saito], wherein the cooling channel is configured in an integrally bonded manner in the main body [0064-0072, fig. 6, Saito].
Regarding claim 9, Masaryk does depict the first plane (“E1”) being horizontal while the second plane (“E2”) is angled. However Saito as presently modified is silent to the cooling device having first plane (“E1”) and the second plane (“E2”) are formed parallel to one another.
Prior to the effective filing date, one of ordinary skill would appreciate that the first and second plane would be parallel to one another as a matter of mere changes in shape, see MPEP 2144.04.IV.B. The first and second plane of the cooling device being parallel or not parallel would not provide a significant change in the function of the cooling device. However, if both planes are horizontal such that they are parallel to one another then one would have a cooling device with flat upper surfaces.
Prior to the effective filing date, one of ordinary skill within the arts would find it obvious to modify Saito such that the first and second plane were horizontal/parallel to one another. Doing so would provide a cooling device with flat surfaces.
Regarding claim 10, modified Saitou discloses the cooling device, wherein the venting space rises along a flow path of the cooling liquid at least in portions [fig. 5, Masaryk], up to the venting interface [fig. 5, Masaryk].
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Annotated fig. 5, Masaryk
Regarding claim 11, modified Saitou discloses the cooling device, wherein the venting space has an initial portion and an end portion along the flow path of the cooling liquid [fig. 5, Masaryk], wherein the venting interface is arranged in the end portion of the venting space [fig. 5, Masaryk].
Regarding claim 14, modified Saitou discloses the cooling device, wherein a battery system comprising a battery cell stack having a plurality of battery cells (30) [fig. 6, Saito], a circuit board (72) [fig. 6, Saito], and a cooling device [0070-0072, Saito], wherein the circuit board is connected in a heat-transferring manner to the cooling channel top on the side of the cooling channel top facing away from the cooling channel [0068-0072, 0083, fig. 6 and 11, Saito].
Regarding claim 15, modified Saitou discloses the battery system, wherein the circuit board comprise a logic device and a power device [0068, Saitou].
Saitou discloses chip components such as semiconductor devices, such as ICs (integrated circuits) and passive devices such as resistors and capacitors (reads on “power device”). Wherein the chip components constitutes a circuit section that monitors and controls aspects of the battery cell (reads on “logic device”).
Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over modified Saitou as applied to claim 14 above, and further in view of Andres (US 20140342197 A1).
In regards to claim 16, Saitou discloses that the chip components are mounted on a main surface of the circuit board while the battery cells are mounted on the other main surface of the circuit board [0068-0069, Saitou]. As noted in claim 1, because the batteries are depicted as being mounted on the bottom surface of circuit board, therefore the chip components are mounted on the other/top surface. This reads on the claim limitation of “the logic device is arranged on the side of the base surface of the cooling channel top facing away from the cooling channel”.
Saitou as currently modified is silent to a power device being arranged on the side of the venting space of the cooling channel top.
However, Andres notes that control electronics (circuit boards) may be located on the side of the venting space of the cooling channel top [fig. 2, Andres].
Prior to the effective filing date, one of ordinary skill within the arts would find it obvious to modify Saitou such that the power electronics were located on the side of the venting space of the cooling channel top as a matter of “obvious-to-try”, see MPEP 2143.I.E. There exists a finite number of identifiable locations for a “power device” to be located on a printed circuit board, either on the top (side that is not the “venting space”) or below the circuit board (same side as the “venting space”). In either case, because the circuit board is in thermal conductivity with the cooling device, one of ordinary skill within the arts would appreciate that in both instance the power device would experience a cooling effect.
Response to Arguments
Applicant's arguments filed 04/21/2026 have been fully considered but they are not persuasive. See below for additional details. For clarity of the record, no new remarks were uploaded with the Request for Continued Examination filed 5/20/2026. As such the most recent Remarks (filed 4/21/2026) are being responded to.
Applicant’s arguments with respect to Seitz have been considered but are moot because the new ground of rejection does not rely on Seitz applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Applicant argues that the bypass tube of Masaryk is not within the cooling region. However, the examiner respectfully disagrees with this as the bypass tube containing the inlet port (81) extends into and overlaps with the cooling region [fig. 5, Masaryk]. This overlap of the inlet port and cooling region is more clearly seen in the examiners annotated figure of modified Saito [see rejection of claim 1 above].
The applicant’s arguments are unpersuasive as they fail to address the features of Masaryk used to modify Saito. The features being 1) a venting interface was placed at a highest point in the cooling channel. 2) The venting interface had a first and second plane where the venting space extends between the two planes. The arguments put forth by the applicant do not address why the teachings of Masaryk, discussed in the rejection of claim 1, would not make obvious the above feature modifications to a cooling channel.
Applicant further argues that it is unclear why the bypass tube (80) would be modified to include flow disturbance devices. The examiner notes, that it is not the bypass tube (80) of Masaryk that is being modified. But rather the cooling channel of Saito modified to have a venting interface. As such, any arguments towards an alleged modification of the bypass tube are not persuasive as this has not been modified.
Applicant argues that the three finite number of possibilities for a flow disturbance device listed in the prior office action would not be obvious. While no longer relied upon in this office action, in the interest of expedited prosecution the examiner notes that Kopp does teach of these three possibilities [0020, 0086, 0091, Kopp]. For these above reasons the examiner did not find this argument to be persuasive.
The examiner maintains their rejection.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Seol (US20210028431A1) teaches of a battery pack with a cooling plate on top of a battery assembly with a circuit board on top of the cooling plate. Vallee (US20140216702A1) cooling plate with protrusions and a cooling fluid passing through. Chen (CN104733806B) cooling plate with protrusions and a cooling fluid passing through
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/QUINTIN D. ELLIOTT/Examiner, Art Unit 1724 /BRIAN R OHARA/Examiner, Art Unit 1724
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