DETAILED ACTION Notice of Pre-AIA or AIA Status The present application is being examined under the pre-AIA first to invent provisions. Election/Restrictions Applicant's election with traverse of Claims 21-30 in the reply filed on 02/23/26 is acknowledged. The traversal is on the ground(s) that there is no articulation why the claims to “related products” (i.e. Claims 21-30 and Claims 38-40) present an unreasonable search burden insofar as reasons for insisting on restriction have, allegedly, not been outlined (Pages 6-7 of Remarks) . Applicant does not traverse the restriction of the battery assembly method claims (Claims 31-37 Applicant’s arguments are not persuasive. Ultimately, Claims 21-30 and Claims 38-40 recite divergent subject matter not shared between the grou ps of claims , thereby rendering them distinct from one another (as outlined in Pages 3-4 of the 10/23/25 Restriction). As outlined in Pages 4-5 of the 10/23/25 Restriction, said distinct inventions present an undue search burden, at least, because the inventions have acquired a separate status in the art in view of their different classification, the inventions have acquired a separate state in the art due to their recognized divergent subject matter, and/or the inventions require a different field of search (e.g. searching different classes/subclasses or electronic resources, or employing different search strategies or search queries). The requirement is still deemed proper and is therefore made FINAL. Claim Objections Claim 21 is objected to because of the following informalities: for sake of clarity, it appears that the phrase “interfacing the upper surface of the thin-film substrate between the first region from the second region” should be written as “interfacing the upper surface of the thin-film substrate between the first region and the second region . ” Appropriate correction is required. 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. The following is a quotation of 35 U.S.C. 112 (pre-AIA), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the appl icant regards as his invention. Claim s 21-30 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 21 recites the limitation " the cathode material layer. " There is insufficient antecedent basis for this limitation in the claim. Claim s 22, 24 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 22 recites the limitation "the thin-film battery cell." There is insufficient antecedent basis for this limitation in the claim. Claim 22 recites the limitation "the at least three battery stacks." There is insufficient antecedent basis for this limitation in the claim. Claim 24 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 24 recites the limitation "the battery enclosure." There is insufficient antecedent basis for this limitation in the claim. Claim s 25-27 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 25 recites the limitation "the cathode layer." There is insufficient antecedent basis for this limitation in the claim. Claim 27 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 27 recites the limitation "the encapsulation material." There is insufficient antecedent basis for this limitation in the claim. Claim 29 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 29 recites the limitation "the thin firm substrate." There is insufficient antecedent basis for this limitation in the claim. Claim Rejections - 35 USC § 103 The following is a quotation of pre-AIA 35 U.S.C. 103(a) which forms the basis for all obviousness rejections set forth in this Office action: (a) A patent may not be obtained though the invention is not identically disclosed or described as set forth in section 102, if the differences between the subject matter sought to be patented and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a person having ordinary skill in the art to which said subject matter 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 pre-AIA 35 U.S.C. 103(a) 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 under pre-AIA 35 U.S.C. 103(a), the examiner presumes that the subject matter of the various claims was commonly owned at the time any inventions covered therein were made absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and invention dates of each claim that was not commonly owned at the time a later invention was made in order for the examiner to consider the applicability of pre-AIA 35 U.S.C. 103(c) and potential pre-AIA 35 U.S.C. 102(e), (f) or (g) prior art under pre-AIA 35 U.S.C. 103(a). Claim s 21, 28-29 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Laurent et al. (US 2007/0238019) , and further in view of Zhang et al . (US 2007/0099078). Regarding Claim 21, Laurent teaches a microbattery system (“thin-film battery system”) (Title, Abstract, Figure 2, [0022]). As illustrated in Figures 2 and 6 (and the annotated Figure 2 below) , Laurent teaches that the microbattery system comprises a microbattery (“battery cell”), wherein the microbattery comprises the following: (A) a planar support layer (1) (“thin-film substrate”) compris ing a n upper front face (2) ( “upper surface”), a lower rear face (3) (“lower surface”), a “first through-hole” (i.e. the leftmost through-hole to which numeral (10) points in Figure 2) defined through a “first region” of the planar support layer, and a “second through-hole” (i.e. the rightmost through-hole to which numeral (10) points in Figure 2) defined through a “second region” of the planar support layer, (B) a cathode current collector (5) (“first electrode”) disposed over at least a portion of the upper front face of the planar support layer and overlapping the first through-hole, (C) a cathode layer (8) (“cathode material”) disposed over at least a portion of the cathode current collector, (D) a solid electrolyte layer (7) (“thin-film solid electrolyte”) disposed over the cathode layer at least partially enclosing the cathode material against the planar support layer and the cathode current collector, the solid electrolyte layer at least partially interfacing the upper front face of the planar support layer between the first and second regions, (E) an anode layer (6) (“anode material”) disposed over the solid electrolyte layer, and (F) an anode current collector (4) (“second electrode”) which overlaps the second through-hole ([0022]-[0029]). Laurent teaches that the microbattery system further comprises a protective layer (9) (“encapsulation layer”) that encapsulates the microbattery . Laurent does not explicitly teach that anode current collector is disposed over the anode layer, at least a portion of the solid electrolyte layer, and at least a portion of the upper front face of the planar support member. However, Zhang teaches a thin film lithium battery (Abstract). As illustrated in Figure 1, Zhang teaches that the battery comprises a battery cell encapsulated by a passivation layer (19), wherein the battery cell comprises a substrate (13), a cathode current collector (18), a cathode layer (14), a solid electrolyte layer (15), an anode layer (16), and an anode current collector (17) ([0016]). As illustrated in Figure 1, the anode current collector is disposed over an entire length of the top of anode layer so as to be in physical contact with said entire length of the top, at least a portion of the solid electrolyte layer, and at least a portion of the upper (i.e. top) surface of the substrate. Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would construct the anode current collector of Laurent such that it is also disposed over an entire length of the top of the anode layer so as to be in physical contact with said entire length of the top, at least a portion of the solid electrolyte layer, and at least a portion of the upper front face of the planar support member, as taught by Zhang, given that such a modification would enhance/increase the degree to which the anode current collector and anode layer are in physical contact with one another inside the microbattery . Regarding Claim 28, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 21, as previously described. As previously described (See Claim 21 and the annotated Figure 2), the planar support layer includes the first and second region, wherein the second region is positioned opposite the first region. Regarding Claim 29, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 21, as previously described. As previously described (See Claim 21 and the annotated Figure 2), the planar support layer includes the first and second region, wherein the protective layer is at least partially disposed over the first region and the second region. Claims 2 3, 25-27 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Laurent et al. (US 2007/0238019), and further in view of Zhang et al. (US 2007/0099078) and Reynolds (US 2009/0065042) . Regarding Claim 23, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 2 1, as previously described. Laurent, as modified by Zhang, does not explicitly teach that the protective layer is a first encapsulation layer, wherein the microbattery comprises a second encapsulation layer encapsulating the cathode current collector, the cathode layer, the solid electrolyte layer, the anode layer, and the anode current collector over the planar support layer. However, Reynolds teaches a thin film battery (Abstract, [0002]). As illustrated in Figure 3, Reynolds teaches that the battery comprises an encapsulation layer (28) which is configured to hermetically seal the battery from the intrusion of moisture ([0034]). In particular, Reynolds teaches that the encapsulation layer comprises a n inner layer of silicon nitride having a second layer of silicon oxide formed thereon, wherein the silicon oxide layer ensures for the hermetical sealing of the battery ([0035]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would form the protective layer of Laurent, as modified by Zhang , as an inner layer of silicon nitride (“first encapsulation layer”) having an outer layer of silicon oxide formed thereon (“second encapsulation layer”), as taught by Reynolds, given that such a modification would help prevent intrusion of moisture into the microbattery and help ensure for hermetical sealing of the microbattery . Furthermore, given that the outer layer of silicon oxide is positioned as the outermost encapsulation layer of the microbattery , the outer layer of silicon oxide therefore encapsulates, at least, the cathode current collector, the cathode layer, the solid electrolyte layer, the anode layer, and the anode current collector over the planar support layer. Regarding Claim 25, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 21, as previously described. Laurent, as modified by Zhang, does not explicitly teach that the protective layer comprises a material selected to withstand a thermal crystallization temperature of the cathode layer. However, Reynolds teaches a thin film battery (Abstract, [0002]). As illustrated in Figure 3, Reynolds teaches that the battery comprises an encapsulation layer (28) which is configured to hermetically seal the battery from the intrusion of moisture ([0034]). In particular, Reynolds teaches that the encapsulation layer is formed of silicon nitride ([0035]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would form the protective layer of Laurent, as modified by Zhang, out of silicon nitride (“a material selected to withstand a thermal crystallization temperature of the cathode layer ”) , as taught by Reynolds, given that such a modification would help prevent intrusion of moisture into the microbattery and help ensure for hermetical sealing of the microbattery . Regarding Claim 26, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 25, as previously described. As previously described (See Claim 25), the protective layer is formed of silicon nitride (“a refractory material”). Regarding Claim 27, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 26, as previously described. As previously described (See Claim 26), the protective layer is formed of silicon nitride (“a ceramic”). Claim 2 2 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Laurent et al. (US 2007/0238019), and further in view of Zhang et al. (US 2007/0099078) and Johnson (US 2002/0110733) . Regarding Claim 22, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 21, as previously described. While the microbatter of Laurent, as modified by Zhang, is a first battery cell, Laurent, as modified by Zhang, does not explicitly teach that the microbattery system comprises at least three battery cel l s, the at least three battery cells comprising the first battery cell, wherein the protective layer encapsulates the a least three battery cells. However, Johnson teaches a multilayer thin film battery comprising a plurality of thin film battery cells (Abstract, [0002]). As illustrated in Figure 1, Johnson teaches that the battery comprises through thin film battery cells (12, 14, 16, 18) arranged in a stacked configuration which forms a thin film battery stack, wherein said thin film battery stack is attached to a planar substrate ([0022]-[0023]). Johnson teaches that the battery is no explicitly limited to only four thin film battery cells ([0022]). As illustrated in Figure 1, Johnson teaches that the battery cells are arranged in an alternating stacked configuration, wherein said configuration helps provide for high output characteristics ([0025]-[0025]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would construct the microbattery system of Laurent, as modified by Zhang, such that it comprises at least three (e.g. four, as taught by Johsnon ) microbatteries , including the microbattery which is the first battery cell, encapsulated by the protective layer and stacked on the planar support layer in an alternating stacked configuration, as also taught by Johnson, given that such a configuration would help provide for higher output characteristics due to the presence of a plurality of the microbatteries . Claim 24 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Laurent et al. (US 2007/0238019), and further in view of Zhang et al. (US 2007/0099078) and Johnson (US 2002/0110733) and Hong et al. (US 2006/0093896). Regarding Claim 24, Laurent, as modified by Zhang and Johnson , teaches the instantly claimed invention of Claim 21, as previously described. Laurent, as modified by Zhang and Johnson, does not explicitly teach a pouch enclosing the microbattery , and a flex circuit having one or more external connects at least partially through the pouch . However, Hong teaches a secondary battery comprising a case and a safety device attached to a surface of the case (Abstract). As illustrated in Figures 1-3B, Hong teaches that the case (110) is an aluminum pouch comprising a safety vent (114) that is adapted to fracture during excessive swelling to release internal gas, and also that the safety device (120) comprises a flexible wiring pattern (122) which connects at least partially through the battery ([0068]-[0069], [0073], [0075]). Hong teaches that the safety device functions as a strain gauge to measure surface deformation of the case ([0086]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would enclose the microbattery of Laurent, as modified by Zhang and Johnson, in an aluminum pouch (“pouch enclosing the battery cell”) comprising a safety vent, as taught by Hong, and further attach a safety device having a flexible wiring pattern (“external connectors”) extending at least partially through the aluminum pouch, as also taught by Hong, given that such an aluminum pouch would provide further protection for the microbattery from the environment while being adapted to fracture during excessive swelling to release internal gas, and also enhance safety characteristics by providing a means of measuring the surface deformation of the aluminum pouch. Claim 30 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Laurent et al. (US 2007/0238019), and further in view of Zhang et al. (US 2007/0099078) and Salot et al . (US 2006/0154141). Regarding Claim 30, Laurent, as modified by Zhang, teaches the instantly claimed invention of Claim 21, as previously described. Laurent, as modified by Zhang, does not explicitly teach that the protective layer is a polymer coating. However, Salot teaches a microbattery (Abstract). As illustrated in Figure 1G, Salot teaches that the microbattery comprises an encapsulation layer (9), wherein the encapsulation layer is configured to protect the active elements of the microbattery from the environment, and in particular, from moisture ([0049]). Salo t teaches that the encapsulation layer is formed, for example, as a hexamethyl disiloxane polymer coating or a parylene polymer coating ([0050]). Therefore, it would have been obvious before the effective filing date of the claimed invention that one of ordinary skill in the art would form the protective layer of Laurent, as modified by Zhang, as a hexamethyl disiloxane coating (“polymer coating”) or a parylene coating (alternatively, “polymer coating”), as taught by Salot , given that such a polymeric coating would help protect the active elements of the microbattery from the environment, and in particular, from moisture. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT MATTHEW W VAN OUDENAREN whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)270-7595 . The examiner can normally be reached FILLIN "Work Schedule?" \* MERGEFORMAT 7AM-3PM EST M-F . Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Matthew Martin can be reached at 5712707871. 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. /MATTHEW W VAN OUDENAREN/ Primary Examiner, Art Unit 1728