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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 05/29/2026 has been entered.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 1, 7-12 and 18-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention.
Specifically, Claim 1 recites “the sealing strip is made of an organic elastic material”. Although the instant specification supports that the sealing strip can be made of an “organic material” and that the sealing strip expands at higher temperatures [0031], the instant specification does not appear to support that the organic material is an organic elastic material, which appears to imply that the thermal expansion is reversible (i.e. elastic, not plastic). As such, Claim 1 and its dependents are rejected for introducing new matter. In order to overcome this rejection, Applicant can amend the claim to recite that “the sealing strip is made of an organic material, wherein the organic material expands at higher temperatures” as supported by the instant specification [0031].
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) 1, 7 and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poscharnig et al. (EP-3346518-A1) in view of Hashimoto et al. (US-20130004822-A1) and in view of Tajima et al. (US-20230155232-A1) as evidenced by The Columbia Encyclopedia (see NPL provided 09/26/2025 for citations) and in view of Nagamine (US-20150295215-A1) and in further view of Günther et al. (US-20190273231-A1).
Regarding Claim 1, Poscharnig discloses a battery case (housing 30; [0029]), comprising a base plate (31, Fig. 2) [0008, 0029]. Poscharnig discloses that a general battery module is comprised of multiple cells placed within a common housing which can be equipped with a thermal management system, and that the present invention is directed towards a battery module for use in a vehicle [0005, 0012, 0019]. Poscharnig does not teach that the base plate is a liquid cooling plate.
Hashimoto teaches that battery cells generate heat when charged/discharged, and that the heat generated by battery cells increases with the number of cells [0004]. Heat dissipating mechanisms are required which can efficiently thermally conduct and dissipate the heat generated by battery cells [0004]. Hashimoto teaches a power supply device which includes a battery assembly positioned on a cooling plate which is attached to a covering case via a sealing member [0010]. Liquified coolant flows through the cooling plate, thereby effectively transferring heat from the battery assembly [0010, 0101-0102].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have provided the base plate of Poscharnig as a cooling plate with a reasonable expectation that such a configuration would result in a battery module capable of successfully dissipating heat. Since the coolant circulating the cooing plate is liquified [Hashimoto: 0102], the cooling plate reads on a liquid cooling plate.
Modified Poscharnig therefore discloses:
a liquid cooling plate (base plate 31, Fig. 2) and a boundary beam (housing frame 32, Fig. 5) connected to the liquid cooling plate [0012, 0032], wherein
the boundary beam (housing frame 32) and the liquid cooling plate (base plate 31) form an accommodating space (interior space of the housing; [0012, 0032]) for accommodating batteries [0001, 0009-0010, 0027-0029, 0035].
Poscharnig discloses that the embodiment depicted in Figs. 5-7 complies with the embodiment of Fig. 2 except for the addition of a circumferential bulge (63, Fig. 6) provided in the groove (recess 60) [0035]. Therefore, although Figs. 5-6 only depict the groove between the boundary beam (housing frame 32) and a cover plate (33), it is understood that the same groove is formed between the boundary beam (housing frame 32) and the liquid cooling plate (base plate 31) [0012, 0030, 0032]. As such, it is understood that Poscharnig discloses that a groove (recess 60; [0030]) is disposed on a side surface of the boundary beam (base plate 31) facing the liquid cooling plate (base plate 31) [0030, 0032, 0035].
Although Poscharnig does not explicitly teach in the embodiment shown in Figs. 5-7 [0035] that “the groove is disposed around the accommodating space”, Poscharnig discloses an alternative embodiment (Figs. 3-4; [0033-0034]), wherein the groove is disposed around the accommodating space (see Figs. 3-4; [0033-0034]), which ensures the sealing of the accommodating space [0034].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have formed the groove such that it is disposed around the accommodating space, with a reasonable expectation that such a configuration would result in a successful seal around the accommodating space.
Poscharnig further discloses (see annotation of Poscharnig Fig. 5, below) that:
a sealing strip (gasket 50) is disposed in the groove along an extending direction of the groove [0030, 0035],
the sealing strip (gasket 50) is in contact with a groove bottom of the groove and the liquid cooling plate, respectively,
wherein the groove is disposed at an edge of the boundary beam, such that the groove has only one side wall,
a closed chamber is disposed between the only one side wall of the groove and one side of the sealing strip away from the edge of the boundary beam.
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Annotation of Poscharnig Fig. 5.
Poscharnig discloses that the arrangement of the gasket is not limited [0030], and that the illustrated embodiments are not meant to limit the invention [0022]. Therefore, although Poscharnig does not explicitly teach that the sealing strip extends to the edge of the boundary beam, such a configuration would have been obvious over the teachings of Hashimoto and Tajima.
Specifically, Hashimoto teaches that a sealing strip (sealing member 20) can be positioned such that it extends to the edges of a groove (see Figs. 8-9), and that such a configuration results in a successful waterproof seal between the bottom surface of a battery assembly and a cooling plate [0078-0082]. Similarly, Tajima teaches that a sealing strip (sealing portion 240) can be positioned such that it extends to the edge of a member (see Figs. 8 and 22), and that such a configuration results in a successful seal between the member and another member [0047-0050, 0065-0067].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have positioned the sealing strip such that it extends to the edge of the boundary beam, as taught by Hashimoto and Tajima, with a reasonable expectation that such a configuration would have resulted in a successful seal between the boundary beam and the liquid cooling plate. Additionally, absent showings of criticality, a rearrangement of parts normally requires only ordinary skill in the art (MPEP 2144.04, VI, C).
Poscharnig discloses that the sealing strip (gasket 50) may be formed of an elastic material such as polyolefin Ethylene-Propylene-Dien-Monomers (EPDM) [0031]. Although Poscharnig does not specifically teach that “the sealing strip has a first volume at a first temperature, the sealing strip has a second volume at a second temperature, the first temperature is less than the second temperature”, The Columbia Encyclopedia evidences that when heat is applied to a body, its volume increases. Therefore, it is understood that the sealing strip of Poscharnig inherently has a first volume at a first temperature and a second volume at a second temperature, wherein the first temperature is less than the second temperature. Furthermore, the instant specification evidences that when the sealing strip is made of organic materials, it may expand at increased temperature [instant specification: 0032]. The Examiner notes that EPDM is an organic material.
Poscharnig discloses “wherein the sealing strip is made of an organic elastic material” [0031]. The limitation “when the sealing strip expands from the first temperature to the second temperature, a thermal expansion volume is accommodated by the closed chamber such that a half of a difference between the second volume and the first volume is less than a volume of the closed chamber” is a contingent limitation. The broadest reasonable interpretation of a contingent limitation requires structure capable of performing the function should the condition occur. See MPEP 2111.04, II. Here, Poscharnig discloses a closed chamber to the side of the sealing strip (see Fig. 5), which is understood to inherently have a volume. Poscharnig further discloses that the sealing strip is formed of an elastic material such as EPDM [0031]. Since the instant application evidences that organic materials are suitable for use as the sealing strip [instant specification: 0032], it is understood that the prior art discloses structure capable of performing the claimed function should the condition occur.
Although Poscharnig does not explicitly teach the volume of the closed chamber or the expansion of the sealing strip, and therefore does not explicitly teach that “a ratio of the half of the difference between the second volume and the first volume to the volume of the closed chamber is 1/4 to 2/3, wherein the first temperature is 10 °C to 30 °C, and the second temperature is 40 °C to 70 °C”, the closed chamber of Poscharnig is understood to inherently have a volume, and Poscharnig discloses that the sealing strip is formed of an organic elastic material [0031] which is understood to inherently expand some amount at higher temperatures as previously discussed. Additionally, Poscharnig contemplates sizing the groove in view of the deformation of the sealing member [0017], and that a ratio of the width of the sealing strip and the width of the groove is about 1:2 [0032].
Accordingly, it is understood that Poscharnig inherently discloses a structure wherein a ratio of the half of the difference between the second volume and the first volume to the volume of the closed chamber falls somewhere within the range of about 0 (i.e. the sealing strip barely expands) to about 0.5 (i.e. the sealing strip expands to almost fill the closed chamber). It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have selected any portion of the range disclosed in the prior art, including the overlapping portion of the range, with a reasonable expectation that such a ratio would result in a successful seal between the boundary beam and the liquid cooling plate (MPEP 2144.05, I).
Assuming, arguendo, that Applicant is able to show criticality to the claimed range, the ratio would still have been obvious over the disclosure of Poscharnig. Specifically, this limitation is understood to depend on the volume of the closed chamber and the expansion of the sealing strip. Optimization of either of these variables can achieve the claimed ratio.
Regarding the volume of the closed chamber, Poscharnig discloses that a ratio of the width of the sealing strip (gasket) to the width of the groove (recess) is about 1:2 [0032]. If the ratio exceeds 1:3, the manufacturing cost for providing the recess may increase without having any further improvement with respect to sealing function, while if the ratio is below 1:1.2, a disarrangement of the sealing strip and the groove may occur [0016]. Poscharnig further discloses that a depth of the groove to the height of the sealing strip is in the range of 1:1.1 to 1:2 [0017]. Notably, Poscharnig contemplates such a ratio in view of the deformation of a sealing strip formed of an elastic material [0017]. If the ratio is below 1:1.1 the gasket might not sufficiently seal the housing, while if the ratio exceeds 1:2 a correct closure of the housing may be inhibited [0017]. The sealing strip is formed of an organic material [0031], which is understood to expand at higher temperatures [instant specification: 0032].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have optimized the area (i.e. the height and width) of the groove in relation to the area (i.e. height and width) of the sealing strip in view of the design constraints laid out above, thereby inherently optimizing the volume of the closed chamber and the volume of the sealing strip, including selecting an area of each which results in a volume of closed chamber and sealing strip such that “a ratio of the half of the difference between the second volume and the first volume to the volume of the closed chamber is 1/4 to 2/3, wherein the first temperature is 10 °C to 30 °C, and the second temperature is 40 °C to 70 °C” with a reasonable expectation that such a configuration would result in a successful balance between manufacturing cost and successful placement of the sealing strip within the groove to sufficiently seal the housing (MPEP 2144.05, II).
Poscharnig does not teach what gas is provided in the closed chamber, and therefore does not explicitly disclose that air is provided in the closed chamber.
Nagamine teaches that air can be successfully used as the medium inside a battery pack case (reads on battery case) [Abstract; 0035]. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have selected air as the medium within the battery case of modified Poscharnig with a reasonable expectation that such a selection would result in a successful battery case (MPEP 2144.07). Since Poscharnig discloses that the battery is assembled by interposing respective gaskets between the base plate / housing frame and cover plate / housing frame [0012], it is understood that the medium provided in the closed chamber is the same as the medium provided in the battery case (i.e. air).
Poscharnig discloses that the battery case can be applied to a battery module for a vehicle [0019], and that the gasket arrangement ensures sufficient sealing of the housing against leakage of liquid (e.g. water) from the outside to the battery module interior [0012]. Poscharnig does not teach that humidity in the closed chamber is less than or equal to 50%.
Günther teaches that battery modules used in vehicles require specific housings [0002]. Günther teaches that the battery module must be housed in a battery housing sealed against the ingress of moisture to prevent the formation of condensate inside the battery housing [0002]. Moisture penetrating into the battery compartment of the battery housing can cause a short circuit, which can cause a fire in the battery module [0002].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have reduced the content of moisture (i.e. humidity) within the battery housing to be as close to zero as possible, including selecting the humidity to be less than or equal to 50%, with a reasonable expectation that sealing the battery module against moisture and reducing the content of humidity within the battery housing would have a reasonable expectation of resulting in a successful battery module (MPEP 2144.05, I). By reducing the humidity within the battery housing, the humidity in the closed chamber is also reduced to less than or equal to 50%.
Regarding Claim 7, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig discloses that the closed chamber has a length in a first direction (see annotation of Poscharnig Fig. 6, below), wherein the first direction is perpendicular to the extending direction of the groove and parallel to a surface of the liquid cooling plate.
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Annotation of Poscharnig Fig. 6.
Although Poscharnig does not explicitly teach that “a length of the closed chamber in a first direction is greater than a half of magnitude of expansion of the sealing strip in the first direction”, the Examiner notes that this limitation depends on the width of the sealing strip in relation to the width of the groove, and the material of the sealing strip.
Regarding the width of the sealing strip and the width of the closed chamber, Poscharnig discloses that a ratio of the width of the sealing strip (gasket 50) to the width of the groove (recess 60) is about 1:2 [0032]. If the ratio exceeds 1:3, the manufacturing cost for providing the recess may increase without having any further improvement with respect to sealing function, while if the ratio is below 1:1.2 a disarrangement of the sealing strip and the groove may occur [0016].
Regarding the material of the sealing strip, Poscharnig discloses that the sealing strip can be formed of an organic elastic material [0032]. Although Poscharnig does not teach the change in volume of the sealing strip, Poscharnig does contemplate sizing the groove in view of the deformation of the sealing member [0017].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have selected the material of the sealing strip in view of the design considerations laid out above (e.g. such that the width of the sealing strip to the width of the groove remains within a ratio of 1:3 to 1:1.2 [0016], regardless of a change in temperature) and to have optimized the width of the groove in relation to the width of the sealing strip, thereby inherently optimizing the length of the closed chamber and the length of the sealing strip, including selecting a width of groove and a width of sealing member that results in “a length of the closed chamber in the first direction is greater than half of magnitude of expansion of the sealing strip in the first direction”, with a reasonable expectation that such a configuration would have resulted in a successful balance between manufacturing cost and successful placement of the sealing strip within the groove, even when the sealing strip undergoes deformation (MPEP 2144.05, II).
Regarding Claim 20, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig discloses a battery device (vehicle including a battery module; [0019; Claim 10]) comprising the battery case according to claim 1 (see rejection of Claim 1, above), and a battery (battery cells 10) disposed in the battery case [0027-0029, 0035; Claim 1].
Claim(s) 8 and 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poscharnig et al. (EP-3346518-A1) in view of Hashimoto et al. (US-20130004822-A1) in view of Tajima et al. (US-20230155232-A1) as evidenced by The Columbia Encyclopedia (see NPL provided 09/26/2025 for citations) and in view of Nagamine (US-20150295215-A1) and in further view of Günther et al. (US-20190273231-A1) as applied to Claims 1 and 7, above, and in view of Hayama et al. (US-6225778-B1).
Regarding Claim 8, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig discloses that the groove (recess) has a width of about 1/3 of the total width of the flange of the boundary beam (housing frame) [0029, 0032]. The width of the groove in relation to a total width of the flange is selected in view of securing mechanical integrity (i.e. preventing the groove from being so large as to deteriorate the mechanical integrity of the flange) while ensuring correct placement of the sealing strip (i.e. if the groove is too small, the sealing strip may be positioned incorrectly) [0015]. The width of the groove is also selected in view of the width of the sealing strip in order to ensure improvement in sealing function while preventing disarrangement of the sealing strip [0016]. Poscharnig does not explicitly teach that the length of the closed chamber in the first direction is 2 mm to 4 mm.
Hayama teaches a container housing a battery must be reduced in wall thickness in order to increase capacity, while taking into account that a limitation in a reduction of wall thickness exists from the viewpoint of ensuring sufficient strength of the container (Col. 2: lines 21-30). Hayama teaches that electronic devices require a reduction in size, thickness and weight as well as improved battery characteristics including a higher energy density (Col. 1: lines 9-15; Col. 2: lines 17-21).
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have taken into consideration the width (i.e. thickness) of the flange of the boundary beam, the width of the groove, and the width of the sealing strip in order to achieve a balance between increasing capacity while ensuring mechanical strength, and securing mechanical integrity while ensuring correcting positioning of the sealing strip, and ensuring improvement in sealing function while preventing disarrangement of the sealing strip, including selecting a total width of the flange of the boundary beam, a width of the groove, and a width of the sealing strip which results in a closed chamber with a length in the first direction of 2 mm to 4 mm (MPEP 2144.05, II).
Regarding Claim 9, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig further discloses that the groove (recess) is a width of about 1/3 of the total width of the flange of the boundary beam (housing frame) [0029, 0032]. The width of the groove in relation to a total width of the flange is selected in view of securing mechanical integrity (i.e. preventing the groove from being so large as to deteriorate the mechanical integrity of the flange) while ensuring correct placement of the sealing strip (i.e. if the groove is too small, the sealing strip may be positioned incorrectly) [0015]. The width of the groove is also selected in view of the width of the sealing strip (gasket) in order to ensure improvement in sealing function while preventing disarrangement of the sealing strip [0016]. Poscharnig does not explicitly teach that a cross-sectional area of the closed chamber in a direction perpendicular to the extending direction of the groove is 4 mm2 to 18 mm2.
Hayama teaches a container housing a battery must be reduced in wall thickness in order to increase capacity, while taking into account that a limitation in a reduction of wall thickness exists from the viewpoint of ensuring sufficient strength of the container (Col. 2: lines 21-30). Hayama teaches that electronic devices require a reduction in size, thickness and weight as well as improved battery characteristics including a higher energy density (Col. 1: lines 9-15; Col. 2: lines 17-21).
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have taken into consideration the width (i.e. thickness) of the flange of the boundary beam, the width of the groove, and the width of the sealing strip in order to achieve a balance between increasing capacity while ensuring mechanical strength, securing mechanical integrity while ensuring correcting positioning of the sealing strip, and ensuring improvement in sealing function while preventing disarrangement of the sealing strip, including selecting a total width of the flange of the boundary beam, a width of the groove, and a width of the sealing strip which results in a cross-sectional area of the closed chamber in a direction perpendicular to the extending direction of the groove which is 4 mm2 to 18 mm2 (MPEP 2144.05, II).
Claim(s) 10-12 and 18 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poscharnig et al. (EP-3346518-A1) in view of Hashimoto et al. (US-20130004822-A1) in view of Tajima et al. (US-20230155232-A1) as evidenced by The Columbia Encyclopedia (see NPL provided 09/26/2025 for citations) in view of Nagamine (US-20150295215-A1) and in further view of Günther et al. (US-20190273231-A1) as applied to Claims 1 and 7 above, and in view of You et al. (WO-2020133750-A1; see English equivalent US-20210328304-A1 for citations).
Regarding Claim 10, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig discloses that the boundary beam (housing frame 32) and the liquid cooling plate (base plate 31) each have an extending “flange” portion (see annotation of Poscharnig Fig. 2, below), and that the height of the sealing strip (gasket) can be selected in view of achieving tight sealing of the interior space of the battery case [0032, 0035].
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Annotation of Poscharnig Fig. 2.
Although Poscharnig contemplates the use of an adhesive between the sealing strip (gasket) and the liquid cooling plate (base plate) [0031], Poscharnig does not teach that a sealant is disposed between the boundary beam and the liquid cooling plate, on a side of the groove away from the accommodating space.
You teaches a battery pack including a box (reads on battery case) comprising a lower box and an upper box [0031]. The lower box includes a first edge portion and the upper box includes a second edge portion, and the first edge portion and the second edge portion are connected to each other “by such ways as rivet connection, bolt connection, buckle connection, or glue connection” [0031]. The first and second edge portions correspond to the flange portions of Poscharnig. Advantageously, the connection means taught by You results in sealing and fixing of the two members [0034].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have provided a glue connection between the flange portion of the liquid cooling plate and the flange portion of the boundary beam (see annotation of Poscharnig Fig. 2, above) with a reasonable expectation that providing glue between the flange portions would result in a successful seal between the two members as taught by You (MPEP 2144.07). The glue connection corresponds to a sealant disposed between the boundary beam and the liquid cooling plate, wherein the sealant is disposed on a side of the groove away from the accommodating space.
Regarding Claim 11, modified Poscharnig renders obvious all of the claim limitations as set forth above, including that the sealant (glue connection) is positioned between the flange portion of the liquid cooling plate and the flange portion of the boundary beam (see rejection of Claim 10, above). The location of the sealant (glue connection) can be visualized in the annotation of Poscharnig Fig. 2, below. As seen in the annotation of Poscharnig Fig. 2, there is a distance between the sealant and the groove.
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Annotation of Poscharnig Fig. 2.
Regarding Claim 12, modified Poscharnig renders obvious all of the claim limitations as set forth above, including that the sealant (glue connection) is positioned between the flange portion of the liquid cooling plate and the flange portion of the boundary beam (see rejection of Claim 10, above).
Although Poscharnig does not teach that the boundary beam and the liquid cooling plate are connected by a fastener, You teaches that the edge portions of the lower box and the upper box can be connected to each other “by such ways as rivet connection, bolt connection, buckle connection, or glue connection” [0031], and that such a connection results in sealing and fixing [0034]. A rivet, bolt or buckle reads on the recited limitation of a fastener.
Therefore, although not disclosed in a single embodiment, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have selected both a glue connection and a rivet, bolt, or buckle connection to secure the flange portion of the liquid cooling plate to the flange portion of the boundary beam, since each fastening means is individually known to be suitable for fixing two members (MPEP 2144.07), and since combining equivalents known for the same purpose supports a prima facie case of obviousness (MPEP 2144.06). One of ordinary skill in the art would have had a reasonable expectation that selecting a glue connection and a rivet connection, bolt connection, or buckle connection would result in a successful seal between the two members (MPEP 2144.06; MPEP 2144.07). Therefore, modified Poscharnig renders obvious that the boundary beam and the liquid cooling plate are connected by a fastener. Since the fastener is positioned between the flange portion of the liquid cooling plate and the flange portion of the boundary beam, the fastener is necessarily disposed on the side of the groove away from the accommodating space.
Although modified Poscharnig does not teach explicitly teach that sealant is disposed “at least between the fastener and the groove”, in seeking to maximize the sealing effect of the glue connection, one of ordinary skill in the art, before the effective filing date of the claimed invention would have found it obvious to have maximized the area that the glue is provided between the flanges of the liquid cooling plate and the boundary beam, including providing glue (i.e. sealant) between the fastener and the groove, with a reasonable expectation that disposing sealant between the fastener and the groove would result in a successful seal between the liquid cooling plate and the boundary beam.
Regarding Claim 18, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig discloses that the boundary beam (housing frame 32) and the liquid cooling plate (base plate 31) each have an extending “flange” portion (see annotation of Poscharnig Fig. 2, below), and that the height of the sealing strip (gasket) can be selected in view of achieving tight sealing of the interior space of the battery case [0032, 0035].
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Annotation of Poscharnig Fig. 2.
Although Poscharnig contemplates the use of an adhesive between the sealing strip (gasket) and the liquid cooling plate (base plate) [0031], Poscharnig does not teach that a sealant is disposed between the boundary beam and the liquid cooling plate, on a side of the groove away from the accommodating space.
You teaches a battery pack including a box (reads on battery case) comprising a lower box and an upper box [0031]. The lower box includes a first edge portion and the upper box includes a second edge portion, and the first edge portion and the second edge portion are connected to each other “by such ways as rivet connection, bolt connection, buckle connection, or glue connection” [0031]. The first and second edge portions correspond to the flange portions of Poscharnig. Advantageously, the connection means taught by You results in sealing and fixing of the two members [0034].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have provided a glue connection between the flange portion of the liquid cooling plate and the flange portion of the boundary beam (see annotation of Poscharnig Fig. 2, above) with a reasonable expectation that providing glue between the flange portions would result in a successful seal between the two members as taught by You (MPEP 2144.07). The glue connection corresponds to a sealant disposed between the boundary beam and the liquid cooling plate, wherein the sealant is disposed on a side of the groove away from the accommodating space.
Claim(s) 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Poscharnig et al. (EP-3346518-A1) in view of Hashimoto et al. (US-20130004822-A1) in view of Tajima et al. (US-20230155232-A1) as evidenced by The Columbia Encyclopedia (see NPL provided 09/26/2025 for citations) in view of Nagamine (US-20150295215-A1) in view of Günther et al. (US-20190273231-A1) and in view of Hayama et al. (US-6225778-B1) as applied to Claim 9, above, and in further view of You et al. (WO-2020133750-A1; see English equivalent US-20210328304-A1 for citations).
Regarding Claim 19, modified Poscharnig renders obvious all of the claim limitations as set forth above. Poscharnig discloses that the boundary beam (housing frame 32) and the liquid cooling plate (base plate 31) each have an extending “flange” portion (see annotation of Poscharnig Fig. 2, below), and that the height of the sealing strip (gasket) can be selected in view of achieving tight sealing of the interior space of the battery case [0032, 0035].
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Annotation of Poscharnig Fig. 2.
Although Poscharnig contemplates the use of an adhesive between the sealing strip (gasket) and the liquid cooling plate (base plate) [0031], Poscharnig does not teach that a sealant is disposed between the boundary beam and the liquid cooling plate, on a side of the groove away from the accommodating space.
You teaches a battery pack including a box (reads on battery case) comprising a lower box and an upper box [0031]. The lower box includes a first edge portion and the upper box includes a second edge portion, and the first edge portion and the second edge portion are connected to each other “by such ways as rivet connection, bolt connection, buckle connection, or glue connection” [0031]. The first and second edge portions correspond to the flange portions of Poscharnig. Advantageously, the connection means taught by You results in sealing and fixing of the two members [0034].
It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have provided a glue connection between the flange portion of the liquid cooling plate and the flange portion of the boundary beam (see annotation of Poscharnig Fig. 2, above) with a reasonable expectation that providing glue between the flange portions would result in a successful seal between the two members as taught by You (MPEP 2144.07). The glue connection corresponds to a sealant disposed between the boundary beam and the liquid cooling plate, wherein the sealant is disposed on a side of the groove away from the accommodating space.
Response to Arguments
Applicant's arguments filed 05/29/2026 have been fully considered but they are not persuasive. Specifically, Applicant has argued that the claimed ratio of 1/4 to 2/3 is not a mere matter of routine optimization (Remarks, Pg. 11), and submits that the claimed range is critical and yields unexpected results (Remarks, Pg. 13). Applicant submits that Embodiments 1-11 and Comparative Examples 1-2 summarized in Table 1 were “tested under identical baseline conditions, utilizing the same type of organic elastic material and subjected to the same temperature cycles” (Remarks, Pg. 11).
The Examiner has carefully considered this argument, but respectfully does not find it persuasive. In view of Applicant’s submission that the Embodiments and Comparative Examples were tested under identical baseline conditions using the same type of sealing strip material, it is unclear what factors are critical in achieving the allegedly unexpected results. For instance in Table 1 (annotated below), Embodiments 1, 9, 10 and 11 all use a sealing strip with an initial volume (V1) at 25 °C of 160 cm3 and a closed chamber with a volume (V0) of 32 cm3. Based on the information provided (i.e. in Applicant’s arguments and [0093-0097]), it appears that each of these embodiments should produce the same ratio, since the amount that the sealing strip expands is understood to be a fundamental property of the material (i.e. V2, the volume at 60 °C, should be the same if the initial volume (V1) and the testing conditions are the same between each embodiment). However, as seen in Table 1 (see annotation below), Embodiment 1 expanded to a volume of 172 cm3, thereby resulting in a ratio of 0.19 (i.e. outside the claimed range of 1/4 to 2/3), while Embodiments 9, 10 and 11 expanded to volumes of 200 cm3, 192 cm3, and 186 cm3, respectively, thereby resulting in ratios of 0.63, 0.50 and 0.41 (i.e. within the claimed range).
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Annotation of instant Table 1.
In view of Table 1, it appears that either additional variable(s) are altered between the Embodiments, or doubt is cast upon Applicant’s submission that the material of the sealing strip and testing conditions are identical between each Embodiment. Further clarification is required.
Additionally, the Examiner notes that any showing of unexpected results must be reviewed to see if the results occur over the entire claimed range. See MPEP 716.02(d). Assuming, arguendo, that Applicant is able to show that the instant application possesses unexpected results, the showing of evidence appears to require the following features which are currently not found in Claim 1:
a first temperature of 25 °C [0094];
a second temperature of 60 °C [0094];
humidity of 70% [0094];
an initial volume of the sealing strip of 140 cm3 to 160 cm3 (Table 1);
a volume of the closed chamber of 24 cm3 to 64 cm3 (Table 1).
Currently, Claim 1 is open to a larger range of first and second temperatures, requires the humidity to be below 50%, and is silent to an initial volume of the sealing strip and a volume of the closed chamber. For at least these reasons, Claim 1 appears broader in scope than the showing of evidence, and it is unclear whether any allegedly unexpected results based on the showing of evidence would occur through the entire scope of Claim 1.
Applicant has argued that Poscharnig fails to recognize or address the technical problem of dynamic thermal expansion kinematics of organic materials under operating battery temperatures, not to mention the failure mode that volumetric expansion forces the plates apart (Remarks, Pg. 11). Instead, Poscharnig’s spatial dimensions are explicitly designed to address static manufacturing tolerances and structural disarrangement during the assembly process, and therefore one of ordinary skill in the art would have had no recognition or motivation to optimize a volume ratio based on thermal expansion (Remarks, Pgs. 11-12).
The Examiner has carefully considered this argument, but respectfully does not find it persuasive. The fact that the inventor has recognized another advantage which would flow naturally from following the suggestion of the prior art cannot be the basis for patentability when the differences would otherwise be obvious. Although Poscharnig has different reasons to optimize the size of the groove in relation to the size of the sealing strip (as noted by the Applicant; see also rejection of Claim 1 above), the overall result is that one of ordinary skill in the art would have been motivated to optimize the width and depth of the groove and the width and height of the sealing strip, thereby inherently optimizing the volume of each [0016-0017, 0031-0032]. Although Applicant has argued that Poscharnig does not contemplate “the technical problem of dynamic thermal expansion kinematics of organic materials under operating battery temperatures”, the Examiner notes that the instant specification does not appear to focus on the “dynamic thermal expansion kinematics of organic materials”, since it is understood from Applicant’s argument that only one organic material is used for the sealing strip, and the instant specification recites that organic materials can be used, but does not appear to require organic materials [instant specification: 0032]. There is currently no evidence on record to suggest that the organic material of the sealing strip is critical to achieving a particular expansion rate.
Applicant has argued that the Examiner’s conflation of an “assembly tolerance space” with the claimed “thermal expansion buffer volume” is an impermissible exercise of hindsight analysis (Remarks, Pg. 12).
In response, the Examiner notes that it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. Here, Poscharnig discloses that the boundary beam includes a groove designed with an assembly tolerance space in order to accommodate deformation of the sealing strip [0011-0012, 0016-0017]. There does not appear to be any structural difference between an “assembly tolerance space” and a “thermal expansion buffer volume”. Thus, the assembly tolerance space reads on a thermal expansion buffer volume. For clarity of record, the Examiner notes that a “thermal expansion buffer volume” is not explicitly claimed.
Applicant has argued that the teachings of the cited art teach away from the proposed combination since Poscharnig’s entire inventive concept relies on maintaining a specific recess margin to accommodate assembly tolerances and prevent disarrangement during manufacturing (Remarks, Pg. 12). Applicant submits that if the gasket were modified to completely extend to and fill the outer edge of the boundary beam as taught by Tajima or Hashimoto, it would physically eliminate the precise tolerance buffer space that Poscharnig mandates (Remarks, Pg. 12).
The Examiner has carefully considered this argument, but respectfully does not find it persuasive. The Examiner notes that the inventive features of Poscharnig involve providing a recess into the top and bottom of a housing frame and a gasket within the recess in order to ensure sufficient sealing of the housing [0011-0012]. Poscharnig indicates that the arrangement of the gasket within the recess in not limited [0030]. Accordingly, the Examiner submits that providing the gasket such that it extends to the outer edge of the boundary beam does not teach away from the inventive features of Poscharnig, since a tolerance space is still provided between the sidewall of the recess and the gasket, thereby allowing any deformation of the gasket during assembly to be accommodated within the recess.
Applicant has argued the combination of Poscharnig with Nagamine and Günther (Remarks, Pg. 14). Applicant submits that Günther is exclusively concerned with electrical safety, and that the motivation in Günther is to eliminate moisture to prevent electrochemical short circuits and potential battery fires caused by condensation, while the claimed invention addresses mechanical sealing integrity and dynamic volume management problems (Remarks, Pg. 14). Applicant has argued that a person of ordinary skill in the art seeking to optimize the mechanical expansion properties of a sealing strip would have no reasonable incentive or motivation to look to a reference like Günther (Remarks, Pg. 14).
The Examiner has carefully considered this argument, but respectfully does not find it persuasive. It has been held that a prior art reference must either be in the field of the inventor’s endeavor or, if not, then be reasonably pertinent to the particular problem with which the inventor was concerned, in order to be relied upon as a basis for rejection of the claimed invention. In this case, the instant application is drawn to a battery case and a battery device, and indicates that it is desirable to control the humidity within the battery case [instant specification: 0003, 0034]. Günther is directed towards a battery housing, and provides motivation to reduce the humidity in the battery housing to prevent condensation which can cause a short circuit or fire [0001-0002, 0007-0008, 0024]. The teachings of Günther are broadly applicable to batteries housed within battery cases, and therefore Günther is understood to be in the field of the inventor’s endeavor. Additionally, in response to applicant's argument that in seeking to optimize the mechanical expansion properties of a sealing strip, one would have “no reasonable incentive or motivation to look to a reference like Günther”, the Examiner notes that the fact that the inventor has recognized another advantage which would flow naturally from following the suggestion of the prior art cannot be the basis for patentability when the differences would otherwise be obvious. As discussed, Günther provides motivation to reduce humidity to prevent condensation and increase safety [0002].
Applicant has argued that the active cooling of the boundary beam in combination with the dry microclimate (humidity less than or equal to 50%) results in a unique microclimate which ensures that the “breathing effect” (volumetric expansion and contraction) of the organic elastic strip remains perfectly elastic and mathematically predictable within the claimed critical ratio of 1/4 to 2/3 (Remarks, Pg. 14). Applicant submits that Poscharnig, Nagamine, and Günther all fail to recognize the technical problem of moisture-induced polymer over-expansion in the battery case seal (Remarks, Pg. 14).
The Examiner has carefully considered this argument, but respectfully does not find it persuasive. Although Applicant indicates that moisture-induced polymer over-expansion is a technical problem addressed by the instant application, the Examiner notes that the showing of evidence does not demonstrate that alternatives humidities result in deleterious effects. Indeed, the showing of evidence is performed at a humidity of 70% [instant specification: 0094], thereby casting doubt on whether a humidity of less than or equal to 50% is critical in obtaining the allegedly unexpected results depicted in Table 1. Furthermore, although the Applicant has argued that the claimed micro-climate results in volumetric expansion and contraction which is “mathematically predictable within the claimed critical ratio of 1/4 to 2/3”, the Examiner reiterates that the showing of evidence, specifically Embodiment 1 in relation to Embodiment 9-11, cast doubt on whether the expansion of the elastic material can indeed be mathematically predicted, since each of these Embodiments appears to have expanded a different, unpredictable, amount.
Additionally, the Examiner again notes that the fact that the inventor has recognized another advantage which would flow naturally from following the suggestion of the prior art cannot be the basis for patentability when the differences would otherwise be obvious. As previously discussed, Günther provides motivation to reduce humidity to prevent condensation and increase safety [0002].
Conclusion
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/D.C.N./Examiner, Art Unit 1751
/JONATHAN G LEONG/Supervisory Patent Examiner, Art Unit 1751 8/14/2026
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