Prosecution Insights
Last updated: October 01, 2026
Application No. 17/901,039

ADAPTIVE TUNING CIRCUIT FOR WIRELESS SIGNAL TRANSMISSION

Final Rejection §103
Filed
Sep 01, 2022
Examiner
KERNS, KEVIN P
Art Unit
1735
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
3 (Final)
79%
Grant Probability
Favorable
4-5
OA Rounds
0m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allowance Rate
1190 granted / 1507 resolved
+14.0% vs TC avg
Strong +21% interview lift
Without
With
+21.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 7m
Avg Prosecution
41 currently pending
Career history
1538
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
49.6%
+9.6% vs TC avg
§102
23.4%
-16.6% vs TC avg
§112
22.1%
-17.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1507 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 . 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. 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. 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. Claims 1, 5, 6, 10-13, 15, 17, and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Garelli et al. (US 2020/0076014) in view of Apostolos et al. (US 2019/0381902), and further in view of Kim (US 6,020,795). Regarding independent claim 1, Garelli et al. disclose a battery cell monitoring system (abstract; paragraphs [0003]-[0013] and [0019]-[0041]; and Figures 1-3), in which the battery cell monitoring system includes the following features: a battery cell monitoring unit (30), including a controller (electronic control unit (ECU), or host computer (25) serving as a battery controller), a battery monitoring sensor that senses a plurality of battery cells (14C) of one or more battery modules (14) via a cell sense circuit (35) (see paragraphs [0020], [0030], [0031], and [0036]; and Figures 2 and 3), and a radiofrequency (RF) signal manager that is electrically connected to an RF antenna via a transmission link (as a portion of an RF communications circuit (32) or (132)) and is operable to generate a signal having a parametric component and a control component (see Figures 1-3); and a battery management system (battery system manager (BSM) – see paragraph [0025]) in communication with either the same or another RF antenna (or group of RF antennas), wherein the battery monitoring sensor (cell sense circuit (35)) is arranged to monitor a parameter of a battery cell (14C) of each battery module (14), and wherein the RF signal manager wirelessly communicates the signal between the battery cell monitoring unit (30) and the battery management system (battery system manager (BSM)) via the RF antennas, which includes operation of wireless transceiver (R) configured to request transmission of RF battery data (19) from a rechargeable energy storage system (12) (see paragraphs [0019], [0023], [0025], and [0028]-[0030]; and Figures 2 and 3). Although not explicitly disclosed by Garelli et al., one of ordinary skill in the art would have recognized that the same or another RF antenna (or group of RF antennas) would be utilized in the battery cell monitoring system of Garelli et al., which would be optimized to have (at least) first and second RF antennas, as claimed. In this instance, one of ordinary skill in the art would have readily determined the number of required RF antennas based on design choice upon conducting routine experimentation with a reasonable expectation of success, in order to improve characteristics of the battery cell monitoring system, including enabling selective battery data collection and local storage of battery data during extended periods of dormancy of the battery module (see paragraph [0003]). Moreover, it has been held that mere duplication of the essential working parts (in this instance, the number of RF antennas) of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Garelli et al. do not disclose that the transmission link includes an adaptive tuning circuit that is dynamically controlled by the control component. However, Apostolos et al. disclose a charging station and monitoring system (paragraphs [0026], [0027], [0031]-[0033], [0036], [0038]-[0046]; and Figure 1-4), in which the charging station and monitoring system includes a charging station (200) having adaptive tuning circuits (219) that are dynamically controlled by a controller (230) as a control component, wherein each adaptive tuning circuit (219) feeds a transmit wire loop (RF) antenna (210) as part of a transmission link (see paragraphs [0036] and [0038]), in which the features of the transmission link with an adaptive tuning circuit that is dynamically controlled by the control component are advantageous for monitoring and allowing for dynamic changes in operation and data communications (see paragraphs [0041] and [0046]). It would have been obvious to one of ordinary skill in the art at the time the applicant’s invention was made to modify the battery cell monitoring system disclosed by Garelli et al., by including that the transmission link includes an adaptive tuning circuit that is dynamically controlled by the control component, as taught by Apostolos et al., in order to monitor and allow for dynamic changes in operation and data communications (Apostolos et al.; paragraphs [0041] and [0046]). In addition, the combined teachings of Garelli et al. and Apostolos et al. disclose and/or suggest that the battery cell monitoring system of Figure 2 includes diodes (see paragraph [0030] of Garelli et al.), in which Apostolos et al. disclose that the adaptive tuning circuit comprises a varactor diode that would be arranged in series between the RF signal manager and an RF antenna, wherein the varactor diode would be selectively electrically connected to ground (see paragraphs [0038] and [0040] of Apostolos et al.). The combined teachings of Garelli et al. and Apostolos et al. do not explicitly disclose that the varactor diode is directly electrically connected to ground. However, Kim discloses a controllable impedance matching device for use in an RF amplifier (abstract; column 2, lines 44-52; column 3, lines 20-55; column 4, lines 55-67; and Figures 4-6), in which the device includes a first varactor diode (31) directly connected between a coupling terminal and a ground terminal, and a second varactor diode (32) directly connected between a through terminal and a ground terminal, for the purpose of obtaining variable capacitance according to a control signal output from a controller (150) – see abstract; column 2, lines 44-52; and column 4, lines 55-67. It would have been obvious to one of ordinary skill in the art at the time the applicant’s invention was made to modify the battery cell monitoring system disclosed by the combined teachings of Garelli et al. and Apostolos et al., by further including the first and second varactor diodes that are directly connected to a ground terminal, as taught by Kim, in order to obtain variable capacitance according to a control signal output from a controller (Kim; see abstract; column 2, lines 44-52; and column 4, lines 55-67). Regarding claims 5 and 6, and in referring to the rejection of independent claim 1 above, the combined teachings of Garelli et al., Apostolos et al., and Kim disclose and/or suggest that the control component of the signal generated by the RF signal manager controls the varactor diode of the adaptive tuning circuit, wherein the signal generated by the RF signal manager would be based upon the control component of the signal generated by the RF signal manager (see paragraph [0030] and Figure 2 of Garelli et al.; and paragraphs [0038] and [0040] of Apostolos et al.). Regarding claim 10, Garelli et al. disclose that the battery monitoring sensor (cell sense circuit (35)) comprises a temperature sensor arranged to monitor a temperature of the battery cell (14C), and wherein the parametric component of the signal includes the temperature of the battery cell (14C) – see paragraphs [0020], [0024], [0030], [0031], and [0036]; and Figures 1-3. Regarding claim 11, Garelli et al. disclose that the battery monitoring sensor (cell sense circuit (35)) comprises a voltage sensor arranged to monitor a voltage of the battery cell (14C), and wherein the parametric component of the signal includes the voltage of the battery cell (14C) – see paragraphs [0020], [0024], [0030], [0031], and [0036]; and Figures 1-3. Regarding claims 12 and 13, and in referring to the rejection of independent claim 1 above, the combined teachings of Garelli et al., Apostolos et al., and Kim disclose and/or suggest that the control component dynamically controls the adaptive tuning circuit to match one or more RF antenna of the battery cell monitoring unit to the same or another RF antenna (or group of RF antennas) of the battery management system (battery system manager (BSM) – see paragraph [0025] of Garelli et al.), which would be based upon at least one of a location, structure, or environment of an RF antenna of the battery cell monitoring unit in relation to the same or another RF antenna (or group of RF antennas) of the battery management system (see paragraph [0025] and Figures 1-3 of Garelli et al.; and paragraphs [0038] and [0040] of Apostolos et al.). Regarding independent claim 15, Garelli et al. disclose a battery cell monitoring system (abstract; paragraphs [0003]-[0013] and [0019]-[0041]; and Figures 1-3), in which the battery cell monitoring system includes the following features: a battery cell monitoring unit (30), including a controller (electronic control unit (ECU), or host computer (25) serving as a battery controller), a battery monitoring sensor that senses a plurality of battery cells (14C) of one or more battery modules (14) via a cell sense circuit (35) (see paragraphs [0020], [0030], [0031], and [0036]; and Figures 2 and 3), and a radiofrequency (RF) signal manager that is electrically connected to an RF antenna via a transmission link (as a portion of an RF communications circuit (32) or (132)) and is operable to generate a signal having a parametric component and a control component (see Figures 1-3); and a battery management system (battery system manager (BSM) – see paragraph [0025]) in communication with either the same or another RF antenna (or group of RF antennas), wherein the battery monitoring sensor (cell sense circuit (35)) is arranged to monitor a parameter of a battery cell (14C) of each battery module (14), and wherein the RF signal manager wirelessly communicates the signal between the battery cell monitoring unit (30) and the battery management system (battery system manager (BSM)) via the RF antennas, which includes operation of wireless transceiver (R) configured to request transmission of RF battery data (19) from a rechargeable energy storage system (12) (see paragraphs [0019], [0023], [0025], and [0028]-[0030]; and Figures 2 and 3). Although not explicitly disclosed by Garelli et al., one of ordinary skill in the art would have recognized that the same or another RF antenna (or group of RF antennas) would be utilized in the battery cell monitoring system of Garelli et al., which would be optimized to have (at least) first and second RF antennas, as claimed. In this instance, one of ordinary skill in the art would have readily determined the number of required RF antennas based on design choice upon conducting routine experimentation with a reasonable expectation of success, in order to improve characteristics of the battery cell monitoring system, including enabling selective battery data collection and local storage of battery data during extended periods of dormancy of the battery module (see paragraph [0003]). Moreover, it has been held that mere duplication of the essential working parts (in this instance, the number of RF antennas) of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. In addition, Garelli et al. do not disclose a plurality of battery cell monitoring units arranged to monitor a plurality of battery cells, wherein each battery cell monitoring unit includes a respective plurality of battery cells, a respective controller, a respective battery monitoring sensor, and respective additional features that are provided in duplicate with respect to the (single) battery cell monitoring system disclosed and/or suggested by Garelli et al. for independent claim 1. However, one of ordinary skill in the art would have recognized that duplication of all essential parts within the battery cell monitoring system of claim 1 would be advantageous for providing additional efficiency to improve characteristics of the battery cell monitoring system, including enabling selective battery data collection and local storage of battery data during extended periods of dormancy of the battery module (see paragraph [0003]). Moreover, it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Garelli et al. do not disclose that the transmission link includes an adaptive tuning circuit that is dynamically controlled by the control component. However, Apostolos et al. disclose a charging station and monitoring system (paragraphs [0026], [0027], [0031]-[0033], [0036], [0038]-[0046]; and Figure 1-4), in which the charging station and monitoring system includes a charging station (200) having adaptive tuning circuits (219) that are dynamically controlled by a controller (230) as a control component, wherein each adaptive tuning circuit (219) feeds a transmit wire loop (RF) antenna (210) as part of a transmission link (see paragraphs [0036] and [0038]), in which the features of the transmission link with an adaptive tuning circuit that is dynamically controlled by the control component are advantageous for monitoring and allowing for dynamic changes in operation and data communications (see paragraphs [0041] and [0046]). It would have been obvious to one of ordinary skill in the art at the time the applicant’s invention was made to modify the battery cell monitoring system disclosed by Garelli et al., by including that the transmission link includes an adaptive tuning circuit that is dynamically controlled by the control component, as taught by Apostolos et al., in order to monitor and allow for dynamic changes in operation and data communications (Apostolos et al.; paragraphs [0041] and [0046]). In addition, the combined teachings of Garelli et al. and Apostolos et al. disclose and/or suggest that the battery cell monitoring system of Figure 2 includes diodes (see paragraph [0030] of Garelli et al.), in which Apostolos et al. disclose that the adaptive tuning circuit comprises a varactor diode (see paragraphs [0038] and [0040] of Apostolos et al.). Moreover, it has been held that mere duplication of the essential working parts of a device (including the adaptive tuning circuit) involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. The combined teachings of Garelli et al. and Apostolos et al. do not explicitly disclose that the varactor diode is directly electrically connected to ground. However, Kim discloses a controllable impedance matching device for use in an RF amplifier (abstract; column 2, lines 44-52; column 3, lines 20-55; column 4, lines 55-67; and Figures 4-6), in which the device includes a first varactor diode (31) directly connected between a coupling terminal and a ground terminal, and a second varactor diode (32) directly connected between a through terminal and a ground terminal, for the purpose of obtaining variable capacitance according to a control signal output from a controller (150) – see abstract; column 2, lines 44-52; and column 4, lines 55-67. It would have been obvious to one of ordinary skill in the art at the time the applicant’s invention was made to modify the battery cell monitoring system disclosed by the combined teachings of Garelli et al. and Apostolos et al., by further including the first and second varactor diodes that are directly connected to a ground terminal, as taught by Kim, in order to obtain variable capacitance according to a control signal output from a controller (Kim; see abstract; column 2, lines 44-52; and column 4, lines 55-67). Regarding claim 17, being similar in scope to claim 5 above, and in referring to the rejection of independent claim 15 above, the combined teachings of Garelli et al., Apostolos et al., and Kim disclose and/or suggest that the control component of the respective signal generated by the RF signal manager controls the varactor diode of the adaptive tuning circuit, wherein the signal generated by the RF signal manager would be based upon the control component of the signal generated by the RF signal manager (see paragraph [0030] and Figure 2 of Garelli et al.; and paragraphs [0038] and [0040] of Apostolos et al.). Moreover, it has been held that mere duplication of the essential working parts of a device (including the adaptive tuning circuit) involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Regarding claim 18, being similar in scope to claim 13 above, and in referring to the rejection of independent claim 15 above, the combined teachings of Garelli et al., Apostolos et al., and Kim disclose and/or suggest that the respective control component dynamically controls the respective adaptive tuning circuit to match one or more respective RF antenna of the battery cell monitoring unit to the same or another RF antenna (or group of RF antennas) of the battery management system (battery system manager (BSM) – see paragraph [0025] of Garelli et al.), which would be based upon at least one of a location, structure, and environment of a respective RF antenna of the respective battery cell monitoring unit in relation to the same or another RF antenna (or group of RF antennas) of the battery management system (see Garelli et al.; paragraph [0025] and Figures 1-3; and paragraphs [0038] and [0040] of Apostolos et al.). Moreover, it has been held that mere duplication of the essential working parts of a device (including the control component, the adaptive tuning circuit, and the battery monitoring unit) involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Allowable Subject Matter Claims 7-9 and 14 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. The following is a statement of reasons for the indication of allowable subject matter: the prior art fails to teach or suggest a battery cell monitoring system that includes all structural features of independent claim 1, and further includes the following features: the adaptive tuning circuit comprises a plurality of varactor diodes, and the plurality of varactor diodes includes the following: a first varactor diode arranged in series between the RF signal manager and the first RF antenna; a second varactor diode coupled to a first node arranged between the first varactor diode and the RF signal manager, wherein the second varactor diode is directly electrically connected to ground; and a third varactor diode coupled to a second node arranged between the first varactor diode and the first RF antenna, wherein the third varactor diode is directly electrically connected to the ground (of dependent claim 7, from which claims 8 and 9 further depend); and the transmission link includes the adaptive tuning circuit and a conductive lead composed as a meander line arranged between the RF signal manager and the first RF antenna (of dependent claim 14). Response to Arguments The examiner acknowledges the applicants’ amendment received by the USPTO on July 27, 2026. Although the applicants’ amendments to independent claims 1 and 15 overcome the prior 35 USC 103 rejection set forth in the non-final Office Action mailed April 28, 2026, a new 35 USC 103 rejection is provided in view of the new reference to Kim (US 6,020,795), including in the newly underlined portions in the above 35 USC 103 rejection. Although the applicants have added new claims 21-24 that are dependent from non-elected (withdrawn) independent claim 19, it is noted that the preambles of new claims 21-24 do not match with the preambles of independent claim 19 and claim 20. As a result, claims 19-24 would be withdrawn from consideration as drawn to a non-elected invention, and the applicants are requested to correct these non-elected claims to obtain the same preamble for consistency. After additional search and consideration, dependent claims 7-9 and 14 are newly indicated as allowable subject matter (see above section 6). Claims 1, 5-15, 17, and 18 are currently under consideration in the application. Applicants’ arguments with respect to claims 1, 5, 6, 10-13, 15, 17, and 18 have been considered but are moot because the new ground of rejection includes a new reference to Kim (US 6,020,795), and thus does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Applicants' amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicants are 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 KEVIN P KERNS whose telephone number is (571)272-1178. The examiner can normally be reached Monday-Friday 8am-430pm. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Keith Walker can be reached at (571)272-3458. 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. /KEVIN P KERNS/Primary Examiner, Art Unit 1735 September 22, 2026
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Prosecution Timeline

Show 4 earlier events
Jan 21, 2026
Examiner Interview Summary
Jan 26, 2026
Response Filed
Apr 28, 2026
Non-Final Rejection mailed — §103
Jun 10, 2026
Interview Requested
Jun 24, 2026
Examiner Interview Summary
Jun 24, 2026
Applicant Interview (Telephonic)
Jul 27, 2026
Response Filed
Sep 24, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

4-5
Expected OA Rounds
79%
Grant Probability
99%
With Interview (+21.2%)
2y 7m (~0m remaining)
Median Time to Grant
High
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