DETAILED ACTION
Notice to Applicant
In the amendment dated 2026-02-16, the following has occurred: Claims 1 and 9 have been amended; Claims 11-20 have been canceled; Claims 5 and 21-30 have been added.
Claims 1-4, 6-10 and 21-30 are pending.
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
Claim 21 is rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention. Claim 21 requires that “the transverse beam is movable relative to a first end wall and a second wall.” Claim 22 requires that “the transverse beam is fixated to a first end wall or a second wall.” Claim 21 finds support in the instant specification at ¶ 0055, which refers to a transverse beam “configured to move axially relative to the first end wall 64, the second end wall 66, or both,” as well as at ¶ 0063, which says that “the transverse beam 68 may move relative to one or both of the end walls 64, 66 of each cell group assembly 62 as the compressive forces Fc are applied.”
The instant specification and figures appear to disclose a threaded tie rod, or “threaded portion,” of the “transverse beam” along which the end plates can be moved axially to apply and maintain a compressive force. Claims 21 and 22, however, appear to be written as opposite embodiments: one with a “movable” transverse beam and one with a “fixed” transverse beam, rather than the same embodiment at two different points in time during the assembly of the device. While it seems clear that the intended device has fixed end plates, and hence a fixed transverse beam, it is unclear how to interpret the requirement for a “movable” transverse beam in positive structural terms—an un-fixed transverse beam? Would a plate-like beam without any threaded portion, but which is ”movable” as a separate piece before it is fixed in position count? Does the claim require a beam that is “movable” at all times, and therefore cannot be “fixed” without being broken or defective? In other words, while it is possible to interpret “movable” in line with the specification, as simply a threaded portion of the transverse beam along which the end plates can be tightened, it is unclear what the metes and bounds of the claim as written are in terms of the required positive structural features of the apparatus (including whether the claim implies negative structural features, such as a lack of fixture). The Office has interpreted it broadly to refer to something in principle movable, i.e. a separate part.
Claim Rejections - 35 USC § 103
Claims 1-4, 7, 9-10, 22-24, 27, and 30 are rejected under 35 U.S.C. 103 as being unpatentable over He (US 2022/0102787 to He et al.) in view of Wolczak (US Patent No. 6,365,297 to Wolczak et al.).
Regarding Claim 1, He teaches:
a traction battery pack comprising an enclosure assembly 10 with a cell-to-pack battery system housed within the enclosure assembly and including first and second cell stacks 100 in a cell grouping assembly, wherein in the cell group assembly has a transverse beam 600 having two sides (abstract, ¶ 0064, Fig. 12)
wherein the two sides of the transverse beam each establish a common datum reference plane for aligning a first grouping of battery cells of the first cell stack, in virtue of providing a hypothetical reference line for alignment (Fig. 12)
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He is silent with respect to:
that the first and second groupings are aligned such that tolerance stack-ups of the battery cells are directed away from the transverse beam to sides of the first and second cell stacks opposite the transverse beam
Wolczak, however, from the same field of invention, regarding a battery enclosure with cell groupings aligned along either side of a transverse beam 20, with walls 66/68, that define a central datum plane for aligning cells (column 5 to top of column 6, Fig. 1A). In Wolczak, the provision of the walls on opposite sides of the transverse beam allows connection structures between adjacent stacks to have some “float” that buffets electrical buses and the like from tolerance stack-ups by fixing the cell bodies along the datum plane of the walls forming the cavity.
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A necessary implication of a fixed datum plane wall like 20 in Wolczak is that “tolerance stack-ups of the battery cells are directed away from” that wall, since the wall is fixed, as is the cell body wall of the stacked cells. It would have been obvious to provide the cells 100 of He along the two datum planes on either side of the central wall 600, with the motivation, for example, of connecting adjacent stacks through the side terminals, similar to that shown in Wolckzak. A structure or method step that is obvious to try— such as one that is chosen from a finite number of identified, predictable solutions, with a reasonable expectation of success, has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). It is just a necessary consequence of providing a datum plane along one side of a stack that “tolerance stack-ups” within the broadest reasonable interpretation of that phrase accumulate at the opposite side.
Regarding Claim 2, He teaches:
first and second cell rows of a cell matrix of the cell-to-pack battery system (Fig. 12)
“Pack” is interpreted loosely as an arbitrary (sub)grouping of cells, absent more specific definition within the claims, with the understanding that the ordinary skill in the art at the time of invention recognized that any particular series and/or parallel connections between stacks involved only ordinary application of engineering skill to arrive at a given power, voltage, amperage, etc. for a given load.
Regarding Claim 3, He teaches:
an opening in the enclosure assembly for accommodating the cell stacks and compressing them so that they remain fixed within the accommodation space (Figs.)
Regarding Claim 4, He teaches:
first and second end walls at either end of the transverse beam 600 extending between them (Fig. 12)
Regarding Claim 7, He teaches:
embodiments with openings formed through end walls configured to receive fasteners (Fig. 1)
Rearranging and/or duplicating parts has been found to be obvious. See In re Japikse, 181 F.2d 1019, 86 USPQ 70 (CPPA 1950) and In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960). Mere duplication of parts has no patentable significance unless a new and unexpected result is produced, while rearrangement of known parts is obvious when the device operates in the same fashion towards the same purpose. See MPEP 2144.04, VI [R-6].
Regarding Claim 9, He teaches:
four cell stacks, with an identifiable “second cell grouping” opposite wall 500, with identifiable third and fourth common datum reference planes for aligning the groupings (Fig. 12)
He generally renders obvious combinations and regroupings of groupings within the enclosure space. Rearranging and/or duplicating parts has been found to be obvious. See In re Japikse, 181 F.2d 1019, 86 USPQ 70 (CPPA 1950) and In re Harza, 274 F.2d 669, 124 USPQ 378 (CCPA 1960). Mere duplication of parts has no patentable significance unless a new and unexpected result is produced, while rearrangement of known parts is obvious when the device operates in the same fashion towards the same purpose. See MPEP 2144.04, VI [R-6].
Regarding Claim 10, He teaches:
the second cell grouping positioned to abut against the cell grouping assembly (Fig. 12)
Regarding Claim 22, He teaches:
wherein the transverse beam is fixed to the end walls (Fig. 12)
Regarding Claim 23, He does not explicitly teach:
how the transverse beam is fixed
Threaded fasteners and nuts were conventional in the art for fastening beams in an enclosure. Use of a known technique to improve similar devices, methods, or products in the same way, and applying a known technique to a known device, method, or product ready for improvement to yield predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). In the instant case, it would have been obvious to use nuts and bolts to fasten enclosure walls together.
Regarding Claim 24, He teaches:
minor sides of the cell groups are in contact with the sides of the transverse beam 600 (Fig. 12)
Regarding Claim 27, He teaches:
wherein the end walls are greater in width than a first cell grouping (Fig. 12)
Regarding Claim 30, He teaches:
a traction battery pack comprising an enclosure assembly 10 with a cell-to-pack battery system housed within the enclosure assembly and including first and second cell stacks 100 in a cell grouping assembly, wherein in the cell group assembly has a transverse beam 600 having two sides (abstract, ¶ 0064, Fig. 12)
wherein the two sides of the transverse beam each establish a common datum reference plane for aligning a first grouping of battery cells of the first cell stack, in virtue of providing a hypothetical reference line for alignment (Fig. 12)
wherein the cell-to-pack battery is received in the cell-compressing opening, the side walls apply perimeter compression to the first cell stack and the second cell stack to retain them without additional support structures (Fig. 12)
He is silent with respect to:
“datum reference planes,” such that the limitation of claim 1 requiring that the first and second groupings are aligned such that tolerance stack-ups of the battery cells are directed away from the transverse beam to sides of the first and second cell stacks opposite the transverse beam is not explicitly disclosed
Wolczak, however, from the same field of invention, regarding a battery enclosure with cell groupings aligned along either side of a transverse beam 20, with walls 66/68, that define a central datum plane for aligning cells (column 5 to top of column 6, Fig. 1A). In Wolczak, the provision of the walls on opposite sides of the transverse beam allows connection structures between adjacent stacks to have some “float” that buffets electrical buses and the like from tolerance stack-ups by fixing the cell bodies along the datum plane of the walls forming the cavity. A structure or method step that is obvious to try— such as one that is chosen from a finite number of identified, predictable solutions, with a reasonable expectation of success, has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). It would have been obvious to use a transverse beam as a common datum reference plane, as suggested by e.g. Wolczak, since the stack needs to be aligned in some way.
Claims 6, 26, and 28 are rejected under 35 U.S.C. 103 as being unpatentable over He (US 2022/0102787 to He et al.) in view of Wolczak (US Patent No. 6,365,297 to Wolczak et al.) and Stawiarski (US 2024/0157816 to Stawiarski et al.).
Regarding Claim 6, He does not teach:
particular materials for the enclosure, such as metallic end walls and polymeric transverse beams
Stawiarski teaches that frame components can be optionally metal or plastic (¶ 0071-0072), which are conventionally known as substitutable equivalents in the art, with obvious tradeoffs regarding strength, weight, insulation, and the like. Simple substitution of one known element for another to obtain predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). Beyond the substitutability of the materials for each other, it additionally would have been obvious to use metal for the end plates, such as a light-weight, strong material like aluminum, since they compress the cell stacks, and it would have been obvious to use a resin compatible with the adhesive injected between the cells and the transverse separators.
Regarding Claim 26, He does not teach:
two end plates from adjacent cell groupings abutting each other
Stawiarski, however, from the same field of invention, regarding a vehicle battery tray, teaches a tray enclosure 40/42/44 comprising a plurality of modules (Fig. 2, ¶ 0058).
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It would have been obvious to arrange the modules of He into a tray enclosure suitable for use in a vehicle, since assembling modules into larger battery systems, particularly since He teaches rearrangements of cell-to-pack groupings. It further would have been obvious to provide packs next to each other, with end plates abutting, as suggested by Stawiaraski, to economize on space.
Regarding Claim 28, He teaches:
a traction battery pack comprising an enclosure assembly 10 with a cell-to-pack battery system housed within the enclosure assembly and including first and second cell stacks 100 in a cell grouping assembly, wherein in the cell group assembly has a transverse beam 600 having two sides (abstract, ¶ 0064, Fig. 12)
wherein the two sides of the transverse beam each establish a common datum reference plane for aligning a first grouping of battery cells of the first cell stack, in virtue of providing a hypothetical reference line for alignment (Fig. 12)
wherein cell groupings and cell groupings are arrangeable in different configurations of arbitrary size and relation (Figs. 1-12)
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Wolczak, further, from the same field of invention, regarding a battery enclosure with cell groupings aligned along either side of a transverse beam 20, with walls 66/68, that define a central datum plane for aligning cells (column 5 to top of column 6, Fig. 1A). In Wolczak, the provision of the walls on opposite sides of the transverse beam allows connection structures between adjacent stacks to have some “float” that buffets electrical buses and the like from tolerance stack-ups by fixing the cell bodies along the datum plane of the walls forming the cavity.
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A necessary implication of a fixed datum plane wall like 20 in Wolczak is that “tolerance stack-ups of the battery cells are directed away from” that wall, since the wall is fixed, as is the cell body wall of the stacked cells. It would have been obvious to provide the cells 100 of He along the two datum planes on either side of the central wall 600, with the motivation, for example, of connecting adjacent stacks through the side terminals, similar to that shown in Wolckzak. A structure or method step that is obvious to try— such as one that is chosen from a finite number of identified, predictable solutions, with a reasonable expectation of success, has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007). It is just a necessary consequence of providing a datum plane along one side of a stack that “tolerance stack-ups” within the broadest reasonable interpretation of that phrase accumulate at the opposite side.
He does not teach:
first and second cell grouping assemblies arranged side-by-side, with end plates on opposite sides of adjacent cell grouping assemblies abutting each other
Stawiarski, however, from the same field of invention, regarding a vehicle battery tray, teaches a tray enclosure 40/42/44 comprising a plurality of modules or battery cell groupings (Fig. 2, ¶ 0058).
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It would have been obvious to arrange the modules of He into a tray enclosure suitable for use in a vehicle, since assembling modules into larger battery systems, particularly since He teaches rearrangements of cell-to-pack groupings. It further would have been obvious to provide packs next to each other, with end plates abutting, as suggested by Stawiaraski, to economize on space.
Regarding Claim 29, He teaches:
end plates with greater widths than the cell groupings (Fig. 12)
Claims 8 and 25 are rejected under 35 U.S.C. 103 as being unpatentable over He (US 2022/0102787 to He et al.) in view of Wolczak (US Patent No. 6,365,297 to Wolczak et al.) and Liu (CN 209016158 to Liu et al., the Office cites to provided machine English translation).
Regarding Claim 8, He is silent with respect to:
adhesive between the first cell stack and the cell grouping assembly
Liu, however, from the same field of invention, regarding a battery cell stack, teaches:
a traction battery module comprising a cell-to-pack battery system comprising first, second, and third cell stacks 1 in a cell grouping assembly comprising end plates 2 and transverse partitions 3 (pp. 1 and 3, Fig. 1)
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wherein the cell grouping assembly establishes a common datum reference plane for aligning a first grouping of cells in the first cell stack and a second grouping of cells in the second stack
providing a structural adhesive between the separator 3 and the cells (p. 3, etc.)
It would have been obvious to provide a structural adhesive between the transverse beam 600 and the cell stack groupings of He, with the motivation to affix them solidly within the enclosure assembly, as taught by Liu. Use of a known technique to improve similar devices, methods, or products in the same way, and applying a known technique to a known device, method, or product ready for improvement to yield predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
Regarding Claim 25, He is silent with respect to:
adhesive between the cells and the sides of the enclosure
Liu, renders obvious between cells and side walls. It would have been obvious to use an adhesive between the cell stack and any contact point with enclosure side walls, to affix the cells in the accommodation space. Use of a known technique to improve similar devices, methods, or products in the same way, and applying a known technique to a known device, method, or product ready for improvement to yield predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
Claim 21 is rejected under 35 U.S.C. 103 as being unpatentable over He (US 2022/0102787 to He et al.) in view of Wolczak (US Patent No. 6,365,297 to Wolczak et al.) and Arreola (US Patent No. 5,269,600 to Arreola et al.).
Regarding Claim 21, He does not explicitly teach:
a movable transverse beam
Adjustable or movable beams are conventional in enclosure arts. Arreola, for example, teaches an adjustable/movable transverse beam. Use of a known technique to improve similar devices, methods, or products in the same way, and applying a known technique to a known device, method, or product ready for improvement to yield predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007).
Response to Arguments
The arguments submitted 2026-02-16 have been considered but do not place the application in condition for allowance. In response to the claim amendments, the claims are now rejected over new references He and Wolczak.
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 Michael Dignan, whose telephone number is (571) 272-6425. The examiner can normally be reached from Monday to Friday between 10 AM and 6:30 PM. If any attempt to reach the examiner by telephone is unsuccessful, the examiner’s supervisor, Tiffany Legette, can be reached at (571)270-7078. Another resource that is available to applicants is the Patent Application Information Retrieval (PAIR). Information regarding the status of an application can be obtained from the (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAX. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, please feel free to contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). Applicants are invited to contact the Office to schedule an in-person interview to discuss and resolve the issues set forth in this Office Action. Although an interview is not required, the Office believes that an interview can be of use to resolve any issues related to a patent application in an efficient and prompt manner.
/MICHAEL L DIGNAN/Examiner, Art Unit 1723