DETAILED ACTION
Notice to Applicant
In the amendment dated 2026-07-08, the following has occurred: Claims 1 and 11 have been amended; Claims 8-9 and 14-18 have been (previously) canceled.
Claims 1-7, 10-13 and 19-23 are pending and are examined herein. This is a Non-Final Rejection.
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 § 103
Claim 1 is rejected under 35 U.S.C. 103 as being unpatentable over Zhu (US 2022/0294048 to Zhu et al.) in view of Hermann (US 2011/0174556 to Hermann et al.).
Regarding Claim 1, Zhu teaches:
a battery pack comprising a pack housing and at least one battery module disposed inside the housing (Fig. 1, abstract)
a vent hole 1160 connecting inside and outside of the housing designed to prevent backflow (Fig. 1, ¶ 0035)
wherein the battery module includes a plurality of battery cells and a first thermal propagation (TP) blocking member 111 and/or 112 disposed between the plurality of battery cells that can comprise mica (Fig. 2, ¶ 0038)
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Zhu does not explicitly teach:
the structure of the venting hole, or whether the venting holes include “gas discharge units” that are detachably coupled to inner an outer sides of the side frame
Hermann, however, directed towards a battery pack housing with a venting system to safely vent gases released during thermal runaway (abstract), teaches a venting hole 703 in a side frame, with a first unit 805 that is detachably coupled to an inner side of the venting hole (see inner side protrusions to the right of the dark area in Fig. 8) and a second unit 803 detachably coupled to the outer surface of the side frame through an outer portion of the first unit 805 (Fig. 8, ¶ 0044).
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The term “coupled to” is interpreted broadly here to include intervening structure—item 803 is coupled to the outer surface of the side surface through mediating coupling surfaces on 805. Hermann further teaches that the discharge vent holes of the two units are smaller than the side frame venting hole, and overlap with it. It would have been obvious to use such a two-part discharge structure, as taught in Hermann, since Zhu does not explicitly the details of the venting holes. Furthermore, 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).
Claim 2 is rejected under 35 U.S.C. 103 as being unpatentable over Zhu (US 2022/0294048 to Zhu et al.) in view of Hermann (US 2011/0174556 to Hermann et al.), in further view of Lee (US 2021/0320374 to Lee et al.).
Regarding Claim 2, Zhu does not teach:
the bus bar structure, although a PHOSITA would have understood that a bus bar was a critical component of a battery pack and used conventional types in the art
Lee, from the same field of invention, regarding a battery pack with a thermal propagation blocking member, teaches an internal bus bar as part of a bus bar assembly 120 coupled to the plurality of battery cells and coupled to the blocking members 112 (Figs. 4 and 8-9, ¶ 0036, etc.). It would have been obvious to provide a bus like that in Lee that was coupled to the cells and blocking members in the stacks of Zhu, with the motivation to provide a conventional electrical connection system integrated with the stacked and interleaved cells and TP blocking members.
Claims 3-7 and 10-11 are rejected under 35 U.S.C. 103 as being unpatentable over Zhu (US 2022/0294048 to Zhu et al.) in view of Hermann (US 2011/0174556 to Hermann et al.) and Lee (US 2021/0320374 to Lee et al.), in further view of Chen (CN 20974623 to Chen et al., the Office cites to provided machine English translation.).
Regarding Claim 3, Zhu teaches:
TP blocking members 115 on the upper surfaces of the battery module(s) (Fig. 1, ¶ 0034)
Zhu does not explicitly teach:
a pack cover over the blocking members 115
Chen, however, from the same field of invention, regarding a battery module, teaches thermal blocking members 1, 2 and 3 at sides and tops of battery modules/cells, including a mica plate 2 between the cells/modules and the top cover (Fig. 1).
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It would have been obvious to provide a separate cover over the blocking members in Zhu, Chen teaches providing a thermal blocking member over at least the sides and tops of the cells/modules, as was conventional in the art with the motivation to prevent heat and fire from spreading between modules or outside of the battery pack. See also Lee (2021/0320374), cited above for evidence of ordinary skill in the art regarding covers for packs.
Regarding Claim 4, Chen renders obvious:
a second TP blocking member 1/2 formed to surround an upper portion and a side portion of the battery module (Fig. 1)
It would have been obvious to provide a second thermal blocking surrounding the tops and sides of the cells/modules since Zhu and Chen (not to mention Lee) are collectively taken to teach that providing a thermal blocking member over at least the sides and tops of the cells/modules was conventional in the art with the motivation to prevent heat and fire from spreading between modules or outside of the battery pack.
Regarding Claim 5, Zhu does not teach:
a total cross-sectional area of the vent hole(s)
Where the only difference between the prior art and the claims is a recitation of relative dimensions of the claimed device and a device having the claimed relative dimensions would not perform differently than the prior art device the claimed device is not patentably distinct from the prior art device. See Gardner v. TEC Systems, Inc., 725 F.2d 1338, 220 USPQ 777 (Fed. Cir. 1984); and MPEP 2144 IV. A. Furthermore, where in the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges in providing a vent hole cross-sectional area that allows for ingress/egress of fluids while still protecting the modules/cells involves only routine skill in the art, absence a showing of criticality. MPEP 2144.05 II. It would have been obvious to vary the area to any cross-sectional area, proportional to the size of the battery pack and the effective vent area, absent a showing of criticality for the claimed area.
Regarding Claims 6 and 7, Zhu teaches:
an air layer between the battery module(s) containing a plurality of cells and the pack cover(s) and/or blocking members so as not to press on the cells, as was conventional in the art
Chen further provides a gap in which to fit a mica sheet. It would have been obvious to provide a gap to prevent stress on the tops of the battery cells, and to size that area appropriately, given that there were known tradeoffs involving decreasing energy density of the pack assembly in exchange for cooling/venting/mechanical safety. Where in the general conditions of a claim are disclosed in the prior art, discovering the optimum or workable ranges for providing a gap between the top of the batteries and the cover involves only routine skill in the art absent a showing of criticality for the claimed air layer.
Regarding Claim 10, Zhu does not teach:
a steel pack cover
Steel was a conventional pack material in the art. See e.g. previously cited Yoon (US 2023/0126646), which teaches steel (¶ 0040 and 0042). 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).
Regarding Claim 11, Zhu does not explicitly teach:
a sealing member between the side frame and pack cover
Sealing members between covers and bottom frames were conventional in the art. Hermann, for example, teaches a sealing member provided at the junction between the pack cover and the side members of the frame (¶ 0037). 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 provide a sealing member in order to provide an elastic seal between the cover and the bottom frame to protect the battery modules from the elements.
Claims 12-13 are rejected under 35 U.S.C. 103 as being unpatentable over Zhu (US 2022/0294048 to Zhu et al.) in view of Hermann (US 2011/0174556 to Hermann et al.), in further view of Murakami (US 2018/0316104 to Murakami).
Regarding Claims 12-13, Zhu does not explicitly show:
external busbars connecting at least two modules to each other and a cover member for each external bus bar of an insulating material
It would have been obvious to provide a plurality of battery modules, as taught in Zhu, with external bus bars for linking adjacent stacks, with the motivation to increase the capacity of the overall battery pack. 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]. Further, while Zhu does not explicitly show the bus connections, it would have been obvious to use conventional external bus connectors between modules known in the art, in order to connect the modules.
Murakami, from the same field of invention, teaches an external bus between adjacent modules that is covered by an insulating layer 20 (Figs. 1A and 4, ¶ 0032).
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It would have been obvious to provide such an insulative cover over an external bus to prevent shorts and the like, as was conventional in the art, and taught by at least Murakami.
Claims 19-23 rejected under 35 U.S.C. 103 as being unpatentable over Zhu (US 2022/0294048 to Zhu et al.) in view of Hermann (US 2011/0174556 to Hermann et al.), in further view of Kim (US 2023/0327254 to Kim et al.).
Regarding Claim 19, Zhu teaches:
thermal blocking members that can be conventional composite thermal blocking sheets known in the art
Kim furthermore teaches sandwiching silicone pads 410 in a layered blocking member 400, which are “configured to be compressed” in response to deformation in virtue of silicone’s compressibility and its arrangement next to cells, and offering uniform compression that will be fitted to curved surfaces (Fig. 8). Kim further teaches mica sheet 420 in the middle of the composite (¶ 0077). It would have been obvious to use such a layered TP blocking layer because Kim teaches that is a conventional structure in the art, well-suited towards blocking heat and absorbing expansion and contraction of neighboring cells.
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Regarding Claims 21-22, Kim renders obvious:
silicone and mica materials, substantially the same as the instant invention, and known to have very low electrical and thermal conductivities, overlapping the instant range, absent a showing that the materials in the specification are themselves novel and non-obvious variants of mica and silicone
Regarding Claim 23, Kim renders obvious:
compression that results in uniform pressure on the battery cells (¶ 0068)
Response to Arguments
The arguments submitted 2026-07-08 have been considered but do not place the application in condition for allowance. In response to the amendments, the claims have been rejected in view of Zhu, Hermann, et al.
Conclusion
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
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