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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 11, 2025 has been entered.
Response to Amendment
In response to Applicant’s reply dated November 11, 2025, Claims 1, 9, and 15 are amended. Claims 1, 3-9, 11-15, and 17-20 are pending and examined.
Status of Application
The rejections set forth within the previous office action have been modified as necessitated by the Applicant’s amendments.
Claim Rejections - 35 USC § 102
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(s) 1, 3-6, is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Sode et al. [US20160149179A1], hereinafter Sode.
Regarding Claim 1, Sode discloses an explosion proof valve applicable to a battery [Sode abstract and throughout]:
a body [Sode abstract 0054 and throughout, valve body 4 with folded part 3];
a first notch groove defined on a side surface of the body [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B for interpretation of Sode’s first groove on the upper side of the body 4]; and
a plurality of second notch grooves [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B, grooves 45, 46 ], wherein the plurality of second notch grooves are entirely contained within groove walls of the first notch groove, and arranged at intervals in a length direction of the first notch groove [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B, The broadest reasonable interpretation of the claimed intervals is shown in annotated Fig. 2B. Since the intervals of the second notches 45/46 are within the circumference direction (length direction) of the first notch, the broadest reasonable interpretation of Sode is the notches 45/46 are arranged in intervals in a length direction of the first notch as indicated.].
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Regarding Claim 3, Sode discloses the explosion-proof valve of claim 1, wherein at least two of the plurality of second notch grooves have different lengths [Sode 0054 and throughout, Fig. 2A, Sode’s notches are circular as shown in Fig. 2A. The length of a circle is the circumference of the circle; therefore, second notch 45 would be considered to have a different length from notch 46.]
Regarding Claim 4, Sode discloses the explosion-proof valve of claim 1, wherein each of the plurality of second notch grooves has a width smaller than the first notch groove [Sode Figs. 2B, 3].
Regarding Claim 5, Sode discloses the explosion-proof valve of claim 1, wherein each of the plurality of second notch grooves has a polygonal cross-section or a semicircular cross-section [Sode, see annotated Fig. 3].
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Regarding Claim 6, Sode discloses the explosion-proof valve of claim 1, wherein the body is provided with a boss at an edge of the side surface of the body [Sode 0054 and throughout, Figs. 2A, 2B, 3, folded part 3 as the boss with edge side surface is the portions of 4 the left and right sides of folded part 3], the first notch groove is adjacent to the boss [Sode 0054 and throughout, Figs. 2A, 2B, 3], and the first notch groove is located at a radially inner side of the boss [Sode 0054 and throughout, Figs. 2A, 2B, 3].
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.
Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sode, as applied to claim 1 above.
Regarding Claim 8, Sode discloses the explosion-proof valve of claim 1, wherein the plurality of second notch grooves are defined on a bottom wall of the first notch groove, and a distance between the bottom wall of the first notch groove and a bottom wall of each of the plurality of second notch grooves is D [Sode 0061, Fig. 3, and throughout, see annotated Fig. below where D is M1 and/or M2].
Sode does not explicitly disclose D satisfying 0.015 mm<D<0.025 mm as claimed; however, it would have been obvious to one of ordinary skill in the art before the effective filing date that D is a result effective variable per Sode. Sode discloses that the distance M1 and/or M2 is set such that notch 45 and/or 46 ruptures at a predetermined pressure and the thicknesses of M1 and M2 are set as determined by the operational pressure [Sode 0061]. Further, the skilled artisan would recognize that the operable range for the distance between the bottom wall of the first notch groove and the bottom wall of the second notch groove would be dependent on design factors for the battery containing the valve, such as the thickness of the valve material, the materials properties of the valve material, and the volume of the battery, which would be related to the amount of gas that needs to vent. Therefore, the range for the distance between the bottom wall of the first notch groove and the bottom wall of the second notch groove is a result-effective variable that would account for the design factors. If the difference is too small or too large, the valve would not rupture at the predetermined pressure as taught by Sode. Determining the proper range would merely require routine experimentation in consideration of the design factors to ensure the valve ruptures as designed, which would be obvious per MPEP 2144.05II.
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Claim(s) 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sode, as applied to claim 1 and 6 above, in further view of Ogawa [US20200395582A1].
Regarding Claim 7, Sode discloses the explosion-proof valve of claim 6, wherein the first notch groove extends in an extension direction of the boss [Sode, Fig. 2A, The broadest reasonable interpretation of Sode is the first groove, as indicated above in claim 1, extends in the same direction as the boss 3, which is circumferentially]. Sode is silent to two ends of the first notch groove are spaced apart. Ogawa discloses a gas release valve for an energy storage device or battery [Ogawa abstract, 0040, 0044, and throughout], where a portion of the groove 430 is discontinuous [Ogawa 0065-0066 and throughout, Fig. 4(a)], thus two ends of the first notch groove 430 are spaced apart on both the left and right sides of Fig. 4(a). It would have been obvious to one of ordinary skill in the art before the effective filing date to combine Ogawa’s two ends of the notch groove are spaced apart to Sode’s battery by providing a discontinuity in Sode’s first notch, as described in claim 1, for the predictable result of a battery design in which the positioning of the discontinuity provides an area where the valve body remains attached in at least one region after rupture [Ogawa 0061 and throughout], which can support directing the released gas away from portions of the battery, such as preventing released gas from flowing near electrode terminals [Ogawa 0074, Fig. 5, and throughout]. See MPEP 2143 (A) Combining prior art elements according to known methods to yield predictable results.
Claim(s) 9 and 11-14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sode et al. [US20160149179A1], hereinafter Sode, in further view of Kim [US20050181272A1, as provided previously].
Regarding Claim 9, Sode discloses a battery comprising:
a body [Sode abstract 0054 and throughout, valve body 4 with folded part 3];
a first notch groove defined on a side surface of the body [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B for interpretation of Sode’s first groove on the upper side of the body 4]; and
a plurality of second notch grooves [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B, grooves 45, 46 ], wherein the plurality of second notch grooves are entirely contained within groove walls of the first notch groove, and arranged at intervals in a length direction of the first notch groove [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B, The broadest reasonable interpretation of the claimed intervals is shown in annotated Fig. 2B. Since the intervals of the second notches 45/46 are within the circumference direction (length direction) of the first notch, the broadest reasonable interpretation of Sode is the notches 45/46 are arranged in intervals in a length direction of the first notch as indicated.].
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a housing [Sode 0051, Fig. 1, battery case P with lid 1];
a top cover assembly sealing the housing [Sode 0051, Fig. 1, lid 1], wherein the explosion-proof valve is installed in the top cover assembly [Sode 0051, Fig. 1].
Sode is silent to a winding core located in the housing and the first notch groove is defined at the side of the top cover assembly close to the winding core. Kim discloses a battery with a safety vent including a winding core located in the housing [Kim 0017, 0027, 0051, and throughout] and a notched structure for venting gas [Kim 0053-0056 and throughout] where a notch groove is defined on a the side of the top cover assembly close to the winding core [Kim 0067-0068, Figs. 3A-3D]. It would be within the ambit of the skilled artisan to combine Kim’s teaching in Sode’s battery by providing a winding core within Sode’s housing. Further, while Sode discloses a first notch on the opposite side of the top cover assembly from the inside space of the battery where the internal pressure is applied [Sode Figs. 1, 2A, 2B], Kim’s teaches it is also possible to form a notch on the side of the top cover assembly close to the winding core for the predictable result of a controlled rupture of the valve notch groove [Kim 0067-0068 and throughout]. Therefore, it would be within the ambit of the skilled artisan to combine Kim’s teaching and apply Sode’s notches to the opposite side of the top cover assembly in consideration of design factors such as the thickness of the valve body, the depth of the notches, and the size of the battery, which is related to the amount of gas pressure provided by the winding core. See MPEP 2144 VI, A and C. It would have been obvious to one of ordinary skill in the art before the effective filing date to combine Kim’s teachings as described in the battery of Sode for the predictable result of a battery designed with notches for controlled rupture at a predetermined pressure [Kim 0067-0068 and throughout; Sode 0002 and throughout]. See MPEP 2143 (A) Combining prior art elements according to known methods to yield predictable results.
Regarding Claim 11, modified Sode discloses the battery of claim 9, wherein each of the plurality of second notch grooves has a width smaller than the first notch groove [Sode Figs. 2B, 3].
Regarding Claim 12, modified Sode discloses the battery of claim 9, wherein each of the plurality of second notch grooves has a polygonal cross-section or a semicircular cross-section [Sode, see annotated Fig. 3].
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Regarding Claim 13, modified Sode discloses the battery of claim 9, wherein the body is provided with a boss at an edge of the side surface of the body [Sode 0054 and throughout, Figs. 2A, 2B, 3, folded part 3 as the boss with edge side surface is the portions of 4 the left and right sides of folded part 3], the first notch groove is adjacent to the boss [Sode 0054 and throughout, Figs. 2A, 2B, 3], and the first notch groove is located at a radially inner side of the boss [Sode 0054 and throughout, Figs. 2A, 2B, 3].
Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sode in view of Kim, as applied to claim 9 and 13 above, in further view of Ogawa [US20200395582A1].
Regarding Claim 14, modified Sode discloses the battery of claim 13, wherein the first notch groove extends in an extension direction of the boss [Sode, Fig. 2A, The broadest reasonable interpretation of Sode is the first groove, as indicated above in claim 1, extends in the same direction as the boss 3, which is circumferentially]. Sode is silent to two ends of the first notch groove are spaced apart. Ogawa discloses a gas release valve for an energy storage device or battery [Ogawa abstract, 0040, 0044, and throughout], where a portion of the groove 430 is discontinuous [Ogawa 0065-0066 and throughout, Fig. 4(a)], thus two ends of the first notch groove 430 are spaced apart on both the left and right sides of Fig. 4(a). It would have been obvious to one of ordinary skill in the art before the effective filing date to combine Ogawa’s two ends of the notch groove are spaced apart to Sode’s battery by providing a discontinuity in Sode’s first notch, as described in claim 1, for the predictable result of a battery design in which the positioning of the discontinuity provides an area where the valve body remains attached in at least one region after rupture [Ogawa 0061 and throughout], which can support directing the released gas away from portions of the battery, such as preventing released gas from flowing near electrode terminals [Ogawa 0074, Fig. 5, and throughout]. See MPEP 2143 (A) Combining prior art elements according to known methods to yield predictable results.
Claim(s) 15 and 17-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sode et al. [US20160149179A1], hereinafter Sode, in further view of Kim [US20050181272A1, as provided previously] and in further view of Ogawa [US20200395582A1].
Regarding Claim 15, Sode discloses a battery comprising:
a body [Sode abstract 0054 and throughout, valve body 4 with folded part 3];
a first notch groove defined on a side surface of the body [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B for interpretation of Sode’s first groove on the upper side of the body 4]; and
a plurality of second notch grooves [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B, grooves 45, 46 ], wherein the plurality of second notch grooves are entirely contained within groove walls of the first notch groove, and arranged at intervals in a length direction of the first notch groove [Sode 0054 and throughout, Fig. 2A, 2B, 3, see annotated Fig. 2B, The broadest reasonable interpretation of the claimed intervals is shown in annotated Fig. 2B. Since the intervals of the second notches 45/46 are within the circumference direction (length direction) of the first notch, the broadest reasonable interpretation of Sode is the notches 45/46 are arranged in intervals in a length direction of the first notch as indicated.].
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a housing [Sode 0051, Fig. 1, battery case P with lid 1];
a top cover assembly sealing the housing [Sode 0051, Fig. 1, lid 1], wherein the explosion-proof valve is installed in the top cover assembly [Sode 0051, Fig. 1].
Sode is silent to a winding core located in the housing and the first notch groove is defined at the side of the top cover assembly close to the winding core. Kim discloses a battery with a safety vent including a winding core located in the housing [Kim 0017, 0027, 0051, and throughout] and a notched structure for venting gas [Kim 0053-0056 and throughout] where a notch groove is defined on a the side of the top cover assembly close to the winding core [Kim 0067-0068, Figs. 3A-3D]. It would be within the ambit of the skilled artisan to combine Kim’s teaching in Sode’s battery by providing a winding core within Sode’s housing. Further, while Sode discloses a first notch on the opposite side of the top cover assembly from the inside space of the battery where the internal pressure is applied [Sode Figs. 1, 2A, 2B], Kim’s teaches it is also possible to form a notch on the side of the top cover assembly close to the winding core for the predictable result of a controlled rupture of the valve notch groove [Kim 0067-0068 and throughout]. Therefore, it would be within the ambit of the skilled artisan to combine Kim’s teaching and apply Sode’s notches to the opposite side of the top cover assembly in consideration of design factors such as the thickness of the valve body, the depth of the notches, and the size of the battery, which is related to the amount of gas pressure provided by the winding core. See MPEP 2144 VI, A and C. It would have been obvious to one of ordinary skill in the art before the effective filing date to combine Kim’s teachings as described in the battery of Sode for the predictable result of a battery designed with notches for controlled rupture at a predetermined pressure [Kim 0067-0068 and throughout; Sode 0002 and throughout]. See MPEP 2143 (A) Combining prior art elements according to known methods to yield predictable results.
Modified Sode does not explicitly disclose “an energy storage device” comprising the battery described above; however, the skilled artisan would know that Sode’s lithium battery would store electrochemical energy and would be considered an energy storage device. Therefore, modified Sode as described reads on the claimed invention of Claim 15.
For purpose of compact prosecution, Ogawa discloses a gas release valve 400 for an energy storage device [Ogawa abstract, 0040, 0044, 0073, and throughout, Fig. 5, battery module 1] with notched groove 430 [Ogawa 0058 and throughout]. It would be within the ambit of the skilled artisan to use modified Sode’s battery in Ogawa’s energy storage device through simple substitution of an analogous device. It would have been obvious to one of ordinary skill in the art before the effective filing date to substitute the battery of modified Sode for the batteries 30 in Ogawa’s energy storage device 1 with an expectation of success for an energy storage device with batteries with explosion-proof valves for controlled rupture at a predetermined pressure [Sode 0002 and throughout; Kim abstract, Ogawa 0044]. See MPEP 2143 (B) Simple substitution of one known element for another to obtain predictable results.
Regarding Claim 17, modified Sode discloses the energy storage device of claim 15, wherein at least two of the plurality of second notch grooves have different lengths [Sode 0054 and throughout, Fig. 2A, Sode’s notches are circular as shown in Fig. 2A. The length of a circle is the circumference of the circle; therefore, second notch 45 would be considered to have a different length from notch 46.]
Regarding Claim 18, modified Sode discloses the energy storage device of claim 15, wherein the body is provided with a boss at an edge of the side surface of the body [Sode 0054 and throughout, Figs. 2A, 2B, 3, folded part 3 as the boss with edge side surface is the portions of 4 the left and right sides of folded part 3], the first notch groove is adjacent to the boss [Sode 0054 and throughout, Figs. 2A, 2B, 3], and the first notch groove is located at a radially inner side of the boss [Sode 0054 and throughout, Figs. 2A, 2B, 3].
Regarding Claim 19, modified Sode discloses the energy storage device of claim 18, wherein the first notch groove extends in an extension direction of the boss [Sode, Fig. 2A, The broadest reasonable interpretation of Sode is the first groove, as indicated above in claim 15, extends in the same direction as the boss 3, which is circumferentially]. Sode is silent to two ends of the first notch groove are spaced apart. Ogawa’s gas release valve for an energy storage device or battery [Ogawa abstract, 0040, 0044, and throughout] has a portion of the groove 430 that is discontinuous [Ogawa 0065-0066 and throughout, Fig. 4(a)], thus two ends of the first notch groove 430 are spaced apart on both the left and right sides of Fig. 4(a). It would have been obvious to one of ordinary skill in the art before the effective filing date to combine Ogawa’s two ends of the notch groove are spaced apart to Sode’s battery by providing a discontinuity in Sode’s first notch, as described in claim 15, for the predictable result of a battery design in which the positioning of the discontinuity provides an area where the valve body remains attached in at least one region after rupture [Ogawa 0061 and throughout], which can support directing the released gas away from portions of the battery, such as preventing released gas from flowing near electrode terminals [Ogawa 0074, Fig. 5, and throughout]. See MPEP 2143 (A) Combining prior art elements according to known methods to yield predictable results.
Regarding Claim 20, modified Sode discloses the energy storage device of claim 15, wherein the plurality of second notch grooves are defined on a bottom wall of the first notch groove, and a distance between the bottom wall of the first notch groove and a bottom wall of each of the plurality of second notch grooves is D [Sode 0061, Fig. 3, and throughout, see annotated Fig. below where D is M1 and/or M2].
Sode does not explicitly disclose D satisfying 0.015 mm<D<0.025 mm as claimed; however, it would have been obvious to one of ordinary skill in the art before the effective filing date that D is a result effective variable per Sode. Sode discloses that the distance M1 and/or M2 is set such that notch 45 and/or 46 ruptures at a predetermined pressure and the thicknesses of M1 and M2 are set as determined by the operational pressure [Sode 0061]. Further, the skilled artisan would recognize that the operable range for the distance between the bottom wall of the first notch groove and the bottom wall of the second notch groove would be dependent on design factors for the battery containing the valve, such as the thickness of the valve material, the materials properties of the valve material, and the volume of the battery, which would be related to the amount of gas that needs to vent. Therefore, the range for the distance between the bottom wall of the first notch groove and the bottom wall of the second notch groove is a result-effective variable that would account for the design factors. If the difference is too small or too large, the valve would not rupture at the predetermined pressure as taught by Sode. Determining the proper range would merely require routine experimentation in consideration of the design factors to ensure the valve ruptures as designed, which would be obvious per MPEP 2144.05II.
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Response to Arguments
Applicant’s amendments combined with Applicant’s arguments, see pages 7-8, filed November 11, 2025, with respect to rejection of claims 1, 3-9, 11-15, and 17-20 have been fully considered and are persuasive. The rejections in the Office Action dated August 13, 2025 have been withdrawn.
Applicant’s arguments with respect to claim(s) 1 and claims 9 and 15, which recite similar features, 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.
Contact Information
Any inquiry concerning this communication or earlier communications from the examiner should be directed to M. T. LEONARD whose telephone number is (571)270-1681. The examiner can normally be reached Mon-Fri 8:30-5 EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Miriam Stagg can be reached at (571)270-5256. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/M. T. LEONARD/ Examiner, Art Unit 1724
/STEWART A FRASER/ Primary Examiner, Art Unit 1724
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