Prosecution Insights
Last updated: May 29, 2026
Application No. 17/986,168

POSITIONING HIGH AND LOW ENERGY DENSITY CELLS TO REDUCE CELL BARRIER THICKNESS FOR ENHANCED THERMAL STABILITY

Non-Final OA §103
Filed
Nov 14, 2022
Examiner
MCNULTY, SEAMUS PATRICK
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
3 (Non-Final)
53%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
97%
With Interview

Examiner Intelligence

Grants 53% of resolved cases
53%
Career Allowance Rate
17 granted / 32 resolved
-11.9% vs TC avg
Strong +44% interview lift
Without
With
+43.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
43 currently pending
Career history
92
Total Applications
across all art units

Statute-Specific Performance

§103
93.1%
+53.1% vs TC avg
§102
5.8%
-34.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 32 resolved cases

Office Action

§103
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Response to Amendment Amendments filed 09/03/2025 have been entered. The application does not overcome the rejection as set forth in the non-final office action filed 07/07/2025. New rejections are set forth below as necessitated by amendment. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 1,6, 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, and in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’. Regarding Claim 1, Bhardwaj teaches a battery module (Bhjardwaj, “The present embodiments relate to batteries for portable electronic devices”, see [0002]) comprising: a plurality of groups (Bhardwaj, cells, 106 and 102 , Fig. 1), each group comprising one or more high energy density-based cells Bhardwaj on each side between one or more low energy density-based cells (Bhardwaj, “For example, cells 102-104 may each have a capacity of 3.2 Ah, cells 106-108 may each have a capacity of 1.5 Ah,”, see [0029],) wherein: each group comprises at least four cells (Bhardwaj, see Fig. 1) ; the one or more high energy density-based cells comprise at least two adjacent cells; and the one or more low energy density-based cells comprise two cells between which the two adjacent cells are disposed (Bhardwaj, “For example, cells 102-104 may each have a capacity of 3.2 Ah, cells 106-108 may each have a capacity of 1.5 Ah,”, see [0029]) (Bhardwaj, see Fig. 1). Bhardwaj does not teach a cell barrier disposed between each of the plurality of groups, a thickness of the cell barrier being reduced based at least in part on an increased onset temperature of a thermal runaway propagation (TRP) condition occurring in one or more of the plurality of groups. Becher teaches a teach a cell barrier disposed between each of the plurality of groups (Becher, “Different thicknesses of the thermal barrier are investigated after an initial characterization of the TR-onset temperature”, see Conclusion) a thickness of the cell barrier being reduced based at least in part on an increased onset temperature of a thermal runaway propagation (TRP) condition occurring in one or more of the plurality of groups (Becher, “These differences are shown in experiments 3, 4a) and 4b). Using a 2.9 mm thick thermal barrier, the maximum temperature on cell 2 surface was 130°C compared to the 1.9 mm thick barrier with maximum temperatures 192.5°C (test 1) and 183.4°C (test 2).”, Conclusion) Becher teaches that cell barrier can prevent propagation of thermal runaway and the thickness of the barrier can affect the temperature behavior (Becher, “The results illustrate the successful avoidance of propagation and the influence of the barrier thickness on the temperature behaviour”, see Abstract) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cells as taught in Bhardwaj with the cell barriers taught in Becher in order to reduce the propagation of heat in case of thermal runaway and protect the battery module. Regarding Claim 6, Modified Bhardwaj teaches the module of claim 1, wherein the high energy density-based cell comprises one of a nickel cobalt manganese (NCM) cell or a nickel cobalt manganese aluminum (NCMA) cell (Becher “ The experiments in this study are carried out with a PHEV-II cell nominal capacity of 37 Ah and a NMC-111 / graphite cell chemistry (details shown in table 1). This cell chemistry can be considered as state-of-the-art in the industry. ”, see 2.6 battery cells for characterization) Regarding Claim 17, Bhardwaj teaches a battery module (Bhardwaj, battery, 506, Fig. 5) , each group comprising one or more high energy density-based disposed on each side between one or more low energy density-based cells (Bhardwaj, cell groups, 100, Fig. 1) Bhardwaj does not teach a cell barrier disposed between each of the plurality of groups, a thickness of the cell barrier being reduced based at least in part on an increased onset temperature of a thermal runaway propagation (TRP) condition occurring in one or more of the plurality of groups. Becher teaches a teach a cell barrier disposed between each of the plurality of groups (Becher, “Different thicknesses of the thermal barrier are investigated after an initial characterization of the TR-onset temperature”, see Conclusion) a thickness of the cell barrier being reduced based at least in part on an increased onset temperature of a thermal runaway propagation (TRP) condition occurring in one or more of the plurality of groups (Becher, “These differences are shown in experiments 3, 4a) and 4b). Using a 2.9 mm thick thermal barrier, the maximum temperature on cell 2 surface was 130°C compared to the 1.9 mm thick barrier with maximum temperatures 192.5°C (test 1) and 183.4°C (test 2).”, Conclusion) Becher teaches that cell barrier can prevent propagation of thermal runaway and the thickness of the barrier can affect the temperature behavior (Becher, “The results illustrate the successful avoidance of propagation and the influence of the barrier thickness on the temperature behaviour”, see Abstract) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cells as taught in Bhardwaj with the cell barriers taught in Becher in order to reduce the propagation of heat in case of thermal runaway and protect the battery module. Regarding Claim 18, Modified Bhardwaj teaches the module of claim 17, wherein the high energy density-based cell comprises one of a nickel cobalt manganese (NCM) cell or a nickel cobalt manganese aluminum (NCMA) cell (Becher “ The experiments in this study are carried out with a PHEV-II cell nominal capacity of 37 Ah and a NMC-111 / graphite cell chemistry (details shown in table 1). This cell chemistry can be considered as state-of-the-art in the industry. ”, see 2.6 battery cells for characterization) Claims 3 and 4 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’ and in further view of (US-20030232238-A1) hereinafter referred to as ‘Fleming’ Regarding Claim 3, Modified Bhardwaj teaches a first group of the two adjacent groups and via two second tabs to two respective low energy density-based cells in a second group of the two adjacent groups. (Bhardwaj, see Fig. 1) Modified Bhardwaj does not teach a first bus bar on a front of the module and extending across an upper part of a first set of two adjacent groups the first bus bar coupled via two first tabs Fleming teaches a first bus bar on a front of the module (Fleming, positive busbar, 17, Fig. 1), and extending across an upper part of a first set of two adjacent groups, the first bus bar coupled via two first tabs (Fleming, “Referring back to FIG. 1, each of the tabs 16 attached to the positive plates are connected to positive busbars 17 and each of the tabs 14 attached to the negative plates are connected to negative busbars 18”, [0027]) Fleming teaches that the implementation of busbars minimizes the generation of heat (Fleming, “In operation, current is drawn from the top and the bottom of each plate through busbars on the top and the bottom of the cell through the busbars into respective positive and negative terminals, thereby providing a much shorter path on average from the plate to a terminal. This minimizes the generation of heat as a result of resistive effects”, see [0030]) Modified Bhardwaj and Fleming are analogous as they both relate to the field of battery modules. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cell arrangement taught in Bhardwaj with the busbar taught in Fleming in order to minimize the generation of heat. Regarding Claim 4, Modified Bhardwaj teaches the module of claim 3, further comprising: a second bus bar (Fleming, negative busbar, 18, Fig. 1) arranged on the front of the module and extending across a lower part of a second set of two adjacent groups including one of the two adjacent groups from the first set (see annotated figure below), the second bus bar coupled via two third tabs (Fleming, “negative busbars 27 connected to tabs 13 that are attached to the negative plates.”, see [0029]) to two respective high energy density-based cells in the one group from the first set and via two fourth tabs to two respective high energy density-based cells in a remaining group from the second set of two adjacent groups (Bhardwaj, cells, 106 and 102 , Fig. 1), PNG media_image1.png 612 404 media_image1.png Greyscale Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’, and in further view of (US-20030232238-A1), in further view of (US-20200075913-A1) hereinafter referred to as ‘Yongcai’ Regarding Claim 5, Modified Bhardwaj teaches two low energy density-based cells and to two high energy-density-based cells (Bhardwaj, cells, 106 and 102 , Fig. 1), Modified Bhardwaj does not teach a plurality of third bus bars on a back of the module, each bus bar extending across an upper portion and a lower portion of each respective one of at least two adjacent groups wherein each of the plurality of third bus bars is coupled to cells via two respective fifth tabs across the upper portion and to two cells via two respective sixth tabs across the lower portion. Yongcai teaches a plurality of third bus bars on a back of the module (Yongcai, busbar, 60, Fig. 2), each bus bar extending across an upper portion and a lower portion of each respective one of at least two adjacent groups (see annotated figure below), wherein each of the plurality of third bus bars is coupled to cells via two respective fifth tabs across the upper portion and to two cells via two respective sixth tabs across the lower portion (Yongcai, “Each busbar 60 may be used to connect to the positive terminals of a plurality of the battery cells 56 to negative terminals of an adjacent group of battery cells 56.”, see [0048]). Yongcai teaches that this busbar arrangement can be used to connect the various cells to the battery assembly (Yongcai, “a plurality of busbars 60 for electrically connecting battery cells 56 of the battery assembly 25”, see [0047]) PNG media_image2.png 560 642 media_image2.png Greyscale Yongcai teach this busbar arrangement can provide reduced cracking reduced stress and increased electrical conductivity (Yongcai, “Including avoiding crack propagation, reducing weld defects, reducing stress concentrations, improving connection strength, and increasing electrical conductivity”, see [0031]) Modified Bhardwaj and Yongcai are analogous as they both relate the field of battery pack and battery modules. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery pack as taught in modified Bhardwaj with a third busbar taught in Yongcai in order to electrically connect the batteries and reduce cracking reduce stress and increase electrical conductivity. Claims 7,8, 19, and 20 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1 ) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’, in further view of (US-20190386259-A1) hereinafter referred to as ‘Kim’ Regarding Claim 7, Modified Bhardwaj teaches the module of claim 1, including four groups per cell. Bhardwaj does not teach wherein a module configuration is a 2P12S configuration. Kim teaches a module configuration is a 2P12S configuration (Kim, “Hereinafter, in an embodiment of the present invention, a battery module for manufacturing a 2P12S module”, see [0065]). Kim teaches that the 2P12S configuration is needed for a high-efficiency, large capacity electric vehicle (Kim, “In addition, a battery module of a high-efficiency, large-capacity electric vehicle recently requires a 2P12S module formed by connecting two cells in parallel to each other and connecting 12 sets of a pair of cells connected in parallel to each other in series with each other”, see [0008]) Bhardwaj and Kim are analogous they are both of the same field of battery pack and battery modules. It would have been obvious to someone of ordinary skill before the effective filing date of the claimed invention to modify the arrangement as taught in Bhardwaj with the 2P12S configuration as taught in Kim in order to produce a battery module a high-efficiency, large capacity electric vehicle. Regarding Claim 8, Modified Bhardwaj teaches the module of claim 1. Modified Bhardwaj does not wherein a module configuration is a 2P12S configuration including six groups per cell. Kim teaches a module configuration is a 2P12S configuration (Kim, “Hereinafter, in an embodiment of the present invention, a battery module for manufacturing a 2P12S module”, see [0065]), including six groups per cell (Kim, unit modules, 4000a, Fig. 16). Kim teaches that the 2P12S configuration is needed for a high-efficiency, large capacity electric vehicle (Kim, “In addition, a battery module of a high-efficiency, large-capacity electric vehicle recently requires a 2P12S module formed by connecting two cells in parallel to each other and connecting 12 sets of a pair of cells connected in parallel to each other in series with each other”, see [0008]). Bhardwaj and Kim are analogous they are both of the same field of battery pack and battery modules. It would have been obvious to someone of ordinary skill before the effective filing date of the claimed invention to modify the arrangement as taught in Bhardwaj with the 2P12S configuration as taught in Kim in order to produce a battery module a high-efficiency, large capacity electric vehicle. Regarding Claim 19, Modified Bhardwaj teaches the module of claim 17, including four groups per cell. Bhardwaj does not teach wherein a module configuration is a 2P12S configuration. Kim teaches a module configuration is a 2P12S configuration (Kim, “Hereinafter, in an embodiment of the present invention, a battery module for manufacturing a 2P12S module”, see [0065]). Kim teaches that the 2P12S configuration is needed for a high-efficiency, large capacity electric vehicle (Kim, “In addition, a battery module of a high-efficiency, large-capacity electric vehicle recently requires a 2P12S module formed by connecting two cells in parallel to each other and connecting 12 sets of a pair of cells connected in parallel to each other in series with each other”, see [0008]) Bhardwaj and Kim are analogous they are both of the same field of battery pack and battery modules. It would have been obvious to someone of ordinary skill before the effective filing date of the claimed invention to modify the arrangement as taught in Bhardwaj with the 2P12S configuration as taught in Kim in order to produce a battery module a high-efficiency, large capacity electric vehicle. Regarding Claim 20, Modified Bhardwaj teaches the module of claim 17. Modified Bhardwaj does not wherein a module configuration is a 2P12S configuration including six groups per cell. Kim teaches a module configuration is a 2P12S configuration (Kim, “Hereinafter, in an embodiment of the present invention, a battery module for manufacturing a 2P12S module”, see [0065]). including six groups per cell (Kim, unit modules, 4000a, Fig. 16) Kim teaches that the 2P12S configuration is needed for a high-efficiency, large capacity electric vehicle (Kim, “In addition, a battery module of a high-efficiency, large-capacity electric vehicle recently requires a 2P12S module formed by connecting two cells in parallel to each other and connecting 12 sets of a pair of cells connected in parallel to each other in series with each other”, see [0008]) Bhardwaj and Kim are analogous they are both of the same field of battery pack and battery modules. It would have been obvious to someone of ordinary skill before the effective filing date of the claimed invention to modify the arrangement as taught in Bhardwaj with the 2P12S configuration as taught in Kim in order to produce a battery module a high-efficiency, large capacity electric vehicle. Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher, in further view of (US-20110189521-A1) hereinafter referred to as ‘Lee’ Regarding Claim 9, Modified Bhardwaj teaches The module of claim 1. Modified Bhardwaj does not teach wherein a module energy output is between 6 and 12 Kilowatt Hours (kWh). Lee teaches a module energy output is between 6 and 12 Kilowatt Hours (kWh) (Lee, “As previously described, the middle- or large-sized battery pack according to the present invention may have a battery capacity of at least 5 KWh, preferably from 10 KWh to 50 KWh.”, see [0029]). The examiner takes note of the fact that the prior art range of at least 5 kWh broadly overlaps the claimed range of between 6 and 12 kWh. Absent any additional and more specific information in the prior art, a prima facie case of obviousness exists. In re Peterson, 315F.3d 1325, 1330, 65 USPQ2d 1379 (Fed. Cir. 2003). MPEP 2144.05. Lee teaches that this high power is necessary for use as a power source of an electric vehicle or similar hybrid vehicle (Lee, “Consequently, the middle- or large-sized battery pack according to the present invention is preferably used as a power source for electric vehicles or plug-in hybrid electric vehicles in which a plurality of battery cells is included to achieve high power and large capacity”, see [0029]) Modified Bhardwaj and Lee are analogous as they both relate to the field of battery packs for electric vehicles. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery arrangement as taught in Bhardwaj to have a module energy output of between 6 to 12 kwh as taught in Lee in order to construct a high power and high-capacity module for use in an electric vehicle. Claims 10,11, 13, and 21 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’ and in further view of (US-20030232238-A1) hereinafter referred to as ‘Fleming’ in further view of (US-20240047759-A1) hereinafter referred to as ‘Han’ Regarding Claim 10, Modified Bhardwaj teaches a battery module comprising: a plurality of groups (Bhardwaj, cells, 106 and 102 , Fig. 1), each group comprising one or more high energy density-based cells disposed on each side between one or more low energy density-based cells (Bhardwaj, “For example, cells 102-104 may each have a capacity of 3.2 Ah, cells 106-108 may each have a capacity of 1.5 Ah,”, see [0029],) Bhardwaj does not teach a cell barrier disposed between each of the plurality of groups, a thickness of the cell barrier being reduced based at least in part on an increased onset temperature of a thermal runaway propagation (TRP) condition occurring in one or more of the plurality of groups. Becher teaches a teach a cell barrier disposed between each of the plurality of groups (Becher, “Different thicknesses of the thermal barrier are investigated after an initial characterization of the TR-onset temperature”, see Conclusion) a thickness of the cell barrier being reduced based at least in part on an increased onset temperature of a thermal runaway propagation (TRP) condition occurring in one or more of the plurality of groups (Becher, “These differences are shown in experiments 3, 4a) and 4b). Using a 2.9 mm thick thermal barrier, the maximum temperature on cell 2 surface was 130°C compared to the 1.9 mm thick barrier with maximum temperatures 192.5°C (test 1) and 183.4°C (test 2).”, Conclusion) Becher teaches that cell barrier can prevent propagation of thermal runaway and the thickness of the barrier can affect the temperature behavior (Becher, “The results illustrate the successful avoidance of propagation and the influence of the barrier thickness on the temperature behaviour”, see Abstract) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cells as taught in Bhardwaj with the cell barriers taught in Becher in order to reduce the propagation of heat in case of thermal runaway and protect the battery module. Modified Bhardwaj does not teach a first bus bar on a front of the module and extending across an upper part of a first set of two adjacent groups the first bus bar coupled via two first tabs Fleming teaches a first bus bar on a front of the module (Fleming, positive busbar, 17, Fig. 1), and extending across an upper part of a first set of two adjacent groups, the first bus bar coupled via two first tabs (Fleming, “Referring back to FIG. 1, each of the tabs 16 attached to the positive plates are connected to positive busbars 17 and each of the tabs 14 attached to the negative plates are connected to negative busbars 18”, [0027]) Fleming teaches that the implementation of busbars minimizes the generation of heat (Fleming, “In operation, current is drawn from the top and the bottom of each plate through busbars on the top and the bottom of the cell through the busbars into respective positive and negative terminals, thereby providing a much shorter path on average from the plate to a terminal. This minimizes the generation of heat as a result of resistive effects”, see [0030]) Modified Bhardwaj and Fleming are analogous as they both relate to the field of battery modules. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cell arrangement taught in Bhardwaj with the busbar taught in Fleming in order to minimize the generation of heat. Modified Bhardwaj does not teach in each group high energy density-based cells and the low energy density-based cell are consistent in height but variable in width. Han teaches in each group high energy density-based cells and the low energy density-based cell are consistent in height but variable in width (Han, “Alternatively, or in combination, at least one of the first plurality of electrodes has a different thickness than the corresponding electrode of the second plurality of electrodes.”, see [0003])(Han, “For example, the first cathode may have a different composition, loading, and/or thickness than the second cathode”, see [0006]) Han teaches that varying the thickness of the cells allows for the proliferation of a non-uniform current which is advantageous for cells in a stack (Han,“For example, lithium-ion battery stacks, conventionally, require a uniform current distribution throughout the stack because identical electrochemical cells are used throughout stack. But cells at different areas, portions, regions, segments, or locations of the stack usually experience different operating conditions making uniformity difficult.”, see [0023]))(Han,“ However, non-uniform current distribution may be possible if electrochemical cells having different attributes are used for different portions, regions, segments or locations. For example, the cells may have different compositions, different loading levels, packing densities, and/or different thicknesses”, see [0025])) (Han,“ In one variation, the electrochemical cells of stack 300 may form a gradient, as shown in FIG. 3 with shading, such that the outer most cells 302 may be configured for the lowest operating temperature and/or pressure while the inner most cell(s) … (e.g., composition, loading, packing density, thickness, and/or porosity).”, see [0043]). Modified Bhardwaj and Han are analogous as they are both of the same field of battery stacks. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the thickness of the cells in order to account for a non-uniform current and allow for better functioning of the cell stack. Regarding Claim 11, Modified Bhardwaj teaches the module of claim 3, further comprising: a second bus bar (Fleming, negative busbar, 18, Fig. 1) arranged on the front of the module and extending across a lower part of a second set of two adjacent groups including one of the two adjacent groups from the first set (see annotated figure below), the second bus bar coupled via two third tabs (Fleming, “negative busbars 27 connected to tabs 13 that are attached to the negative plates.”, see [0029]) to two respective high energy density-based cells in the one group from the first set and via two fourth tabs to two respective high energy density-based cells in a remaining group from the second set of two adjacent groups (Bhardwaj, cells, 106 and 102 , Fig. 1), Regarding Claim 13, Modified Bhardwaj teaches the module of claim 11, wherein the high energy density-based cell comprises one of a nickel cobalt manganese (NCM) cell or a nickel cobalt manganese aluminum (NCMA) cell (Becher “ The experiments in this study are carried out with a PHEV-II cell nominal capacity of 37 Ah and a NMC-111 / graphite cell chemistry (details shown in table 1). This cell chemistry can be considered as state-of-the-art in the industry. ”, see 2.6 battery cells for characterization) Regarding Claim 21, Modified Bhardwaj teaches The module of claim 17, wherein: in each group, the high energy density-based cells and the low energy density- based cell (Bhardwaj, cells, 106 and 102 , Fig. 1);each group comprises at least four cells ;the plurality of high energy density-based cells comprise at least two adjacent cells; and the at least one low energy density-based cells comprise two cells between which the two adjacent cells are disposed cells (Bhardwaj, “For example, cells 102-104 may each have a capacity of 3.2 Ah, cells 106-108 may each have a capacity of 1.5 Ah,”, see [0029],) Modified Bhardwaj does not teach in each group high energy density-based cells and the low energy density-based cell are consistent in height but variable in width. Han teaches in each group high energy density-based cells and the low energy density-based cell are consistent in height but variable in width (Han, “Alternatively, or in combination, at least one of the first plurality of electrodes has a different thickness than the corresponding electrode of the second plurality of electrodes.”, see [0003])(Han, “For example, the first cathode may have a different composition, loading, and/or thickness than the second cathode”, see [0006]) Han teaches that varying the thickness of the cells allows for the proliferation of a non-uniform current which is advantageous for cells in a stack (Han,“For example, lithium-ion battery stacks, conventionally, require a uniform current distribution throughout the stack because identical electrochemical cells are used throughout stack. But cells at different areas, portions, regions, segments, or locations of the stack usually experience different operating conditions making uniformity difficult.”, see [0023]))(Han,“ However, non-uniform current distribution may be possible if electrochemical cells having different attributes are used for different portions, regions, segments or locations. For example, the cells may have different compositions, different loading levels, packing densities, and/or different thicknesses”, see [0025])) (Han,“ In one variation, the electrochemical cells of stack 300 may form a gradient, as shown in FIG. 3 with shading, such that the outer most cells 302 may be configured for the lowest operating temperature and/or pressure while the inner most cell(s) … (e.g., composition, loading, packing density, thickness, and/or porosity).”, see [0043]). Modified Bhardwaj and Han are analogous as they are both of the same field of battery stacks. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the thickness of the cells in order to account for a non-uniform current and allow for better functioning of the cell stack. Claim 12 is rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’ and in view of (US-20030232238-A1) hereinafter referred to as ‘Fleming’, in further view of (US-20240047759-A1) hereinafter referred to as ‘Han’, in further view of (US-20200075913-A1) hereinafter referred to as ‘Yongcai’ Regarding Claim 12, Modified Bhardwaj teaches two low energy density-based cells and to two high energy-density-based cells (Bhardwaj, cells, 106 and 102 , Fig. 1), Modified Bhardwaj does not teach a plurality of third bus bars on a back of the module, each bus bar extending across an upper portion and a lower portion of each respective one of at least two adjacent groups, wherein each of the plurality of third bus bars is coupled to two low energy density-based cells via two respective fifth tabs across the upper portion and to two high energy-density-based cells via two respective sixth tabs across the lower portion. Yongcai teaches a plurality of third bus bars on a back of the module (Yongcai, busbar, 60, Fig. 2), each bus bar extending across an upper portion and a lower portion of each respective one of at least two adjacent groups (see annotated figure below), wherein each of the plurality of third bus bars is coupled to cells via two respective fifth tabs across the upper portion and to two cells via two respective sixth tabs across the lower portion (Yongcai, “Each busbar 60 may be used to connect to the positive terminals of a plurality of the battery cells 56 to negative terminals of an adjacent group of battery cells 56.”, see [0048]). Yongcai teaches that this busbar arrangement can be used to connect the various cells to the battery assembly (Yongcai, “a plurality of busbars 60 for electrically connecting battery cells 56 of the battery assembly 25”, see [0047]) Yongcai teach this busbar arrangement can provide reduced cracking reduced stress and increased electrical conductivity (Yongcai, “Including avoiding crack propagation, reducing weld defects, reducing stress concentrations, improving connection strength, and increasing electrical conductivity”, see [0031]) Modified Bhardwaj and Yongcai are analogous as they both relate the field of battery pack and battery modules. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery pack as taught in modified Bhardwaj with a third busbar taught in Yongcai in order to electrically connect the batteries and reduce cracking reduce stress and increase electrical conductivity. Claims 14 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher’, in view of (US-20030232238-A1) hereinafter referred to as ‘Fleming’, in further view of (US-20240047759-A1) hereinafter referred to as ‘Han’, in further view of (US-20190386259-A1) hereinafter referred to as ‘Kim’ Regarding Claim 14, Modified Bhardwaj teaches The module of claim 11, including four groups per cell. Bhardwaj does not teach wherein a module configuration is a 2P12S configuration. Kim teaches a module configuration is a 2P12S configuration (Kim, “Hereinafter, in an embodiment of the present invention, a battery module for manufacturing a 2P12S module”, see [0065]). Kim teaches that the 2P12S configuration is needed for a high-efficiency, large capacity electric vehicle (Kim, “In addition, a battery module of a high-efficiency, large-capacity electric vehicle recently requires a 2P12S module formed by connecting two cells in parallel to each other and connecting 12 sets of a pair of cells connected in parallel to each other in series with each other”, see [0008]) Bhardwaj and Kim are analogous they are both of the same field of battery pack and battery modules. It would have been obvious to someone of ordinary skill before the effective filing date of the claimed invention to modify the arrangement as taught in Bhardwaj with the 2P12S configuration as taught in Kim in order to produce a battery module a high-efficiency, large capacity electric vehicle. Regarding Claim 15, Modified Bhardwaj teaches The module of claim 11. Modified Bhardwaj does not wherein a module configuration is a 2P12S configuration including six groups per cell. Kim teaches a module configuration is a 2P12S configuration (Kim, “Hereinafter, in an embodiment of the present invention, a battery module for manufacturing a 2P12S module”, see [0065]). including six groups per cell (Kim, unit modules, 4000a, Fig. 16) Kim teaches that the 2P12S configuration is needed for a high-efficiency, large capacity electric vehicle (Kim, “In addition, a battery module of a high-efficiency, large-capacity electric vehicle recently requires a 2P12S module formed by connecting two cells in parallel to each other and connecting 12 sets of a pair of cells connected in parallel to each other in series with each other”, see [0008]) Bhardwaj and Kim are analogous they are both of the same field of battery pack and battery modules. It would have been obvious to someone of ordinary skill before the effective filing date of the claimed invention to modify the arrangement as taught in Bhardwaj with the 2P12S configuration as taught in Kim in order to produce a battery module a high-efficiency, large capacity electric vehicle. Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over (US-20120015223-A1) hereinafter referred to as ‘Bhardwaj’, in view of ‘Preventing thermal propagation in battery packs using enthalpy supported thermal barriers’ hereinafter referred to as ‘Becher, in view of (US-20030232238-A1) hereinafter referred to as ‘Fleming’, in view of (US-20240047759-A1) hereinafter referred to as ‘Han’ in further view of (US-20110189521-A1) hereinafter referred to as ‘Lee’ Regarding Claim 16, Modified Bhardwaj teaches The module of claim 11. Modified Bhardwaj does not teach wherein a module energy output is between 6 and 12 Kilowatt Hours (kWh). Lee teaches a module energy output is between 6 and 12 Kilowatt Hours (kWh) (Lee, “As previously described, the middle- or large-sized battery pack according to the present invention may have a battery capacity of at least 5 KWh, preferably from 10 KWh to 50 KWh.”, see [0029]). *overlapping ranges, Lee teaches that this high power is necessary for use as a power source of an electric vehicle or similar hybrid vehicle (Lee, “Consequently, the middle- or large-sized battery pack according to the present invention is preferably used as a power source for electric vehicles or plug-in hybrid electric vehicles in which a plurality of battery cells is included to achieve high power and large capacity”, see [0029]) Modified Bhardwaj and Lee are analogous as they both relate to the field of battery packs for electric vehicles. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery arrangement as taught in Bhardwaj to have a module energy output of between 6 to 12 kwh as taught in Lee in order to construct a high power and high-capacity module for use in an electric vehicle. Response to Arguments Arguments filed on 09/03/2025 have been entered. Arguments are fully considered. On pg. 9 of the applicants’ arguments, the applicant argues: “However, the cited conclusion section specifically states that ‘using a 2.9mm thick thermal barrier the maximum temperature on cell 2 surface was 130 C compared to the 1.9mm thick barrier with maximum temperatures 192.5 C (test 1) and 183.4 C (test 2)’ …There is no teaching, suggestion or motivation in Becher to reduce the thickness of a thermal barrier to improve thermal management ” However, this argument is not convincing. The examiner points to the specification which informs the claims. The specification states, “the use of high and low energy density batteries 312a. 304a, and 312b, and the 304b in groups 332a and 332b has the further advantage that TRP onset temperature for low density cells 312a and 312b is also higher. Thus the relative thickness of the cell barrier 308 can be reduced based on an overall higher temperature for TRP” (see [0039]) and “high energy density-based cells are included with low energy density-based cells, the onset temperature for TRP may be made higher, without an appreciable corresponding sacrifice in the energy storage and discharge capability of the module.”( see [0035]). The applicant is arguing here that in a combination of as pack the TRP is lower. They are not arguing that the individual cells are higher temperature and need smaller barriers to cool, but that a high energy cell with a TRP of 1000 degrees and several small less than 1000-degree cells as a package on average have a higher temperature than a pack of low energy cell, but need a thinner barrier than a single high energy cell or pack of high energy cells. Looking at Figure. 2A of the instant application, there are high energy cells with thicker barriers (“Examples of high energy density-based cells include cells using NCMA and NCM cathodes, among others. The cells 204 in module 200 are the same type”, see [0035]). Looking at 2B. the inverse is true for low energy cells (“Examples of low energy density-based cells (FIG. 2B) include, for example, cells using LFP cathodes”, see [0035]). In figure 3, the cell barrier is thicker than the cell barrier in Fig. 2B and smaller than that in Fig. 2A. The instant application is not teaching a thinner barrier for high temperatures, but a thinner temperature than a high energy package. It is thinner relatively. The relationship between thickness and temperature remains true. Becher teaches a linear relationship between thickness and onset temperature, as in the cited conclusion (Becher, “These differences are shown in experiments 3, 4a) and 4b). Using a 2.9 mm thick thermal barrier, the maximum temperature on cell 2 surface was 130°C compared to the 1.9 mm thick barrier with maximum temperatures 192.5°C (test 1) and 183.4°C (test 2).”, Conclusion). Therefore, it would have been obvious to one of ordinary skill in the art that set of cells that a mix of high temperature cells and lower temperature cells would need a cell barrier thickness that is greater than a pack of just lower temperature cells but thinner than a pack of just higher temperature cells, as the relationship is linear and predictable. On pg. 10-11, the applicant argues: “Fleming teaches a general bus bar arrangement for a prismatic cells to shorten the current path (please see par. [0030]). Fleming, however, does not contemplate the specific challenges of connecting a hybrid group of high energy density-based cells and low energy density-based cells as arranged in the claimed invention. Yongcai, on the other hand discloses bus bars designed to reduced stress and cracking in a pack of uniform cells…a person having ordinary skill in the art would not have been motivated to select and adapt Fleming’s and Youngcai’s general purpose bus bars to create the specific claimed front and back bus bar topology.” However, this argument is not convincing. It is not clear to the examiner how a hybrid cell would not also have the need to shorten a current path and reduce stress and cracking. One of ordinary skill in the art would find those problems applicable for most cells and combinations and be motivated to modify the primary reference. On pg. 11, the applicant argues: “New independent claim 21 recites select limitations deleted from independent claim 17 and adds a new limitation, ‘In each group, the high energy density-based cells and the low energy density-based cells are consistent in height and carriable in width’” However, this is not convincing. It would have been obvious to one of ordinary skill in the art that this modification would be obvious. If cells are constant in height and have varying densities then it would be obvious that they are varying in volume of some other dimension, such as length or width, as density is equal to mass times volume. However, for the sake of compact prosecution and further argumentation, the prior art teaches that the thickness and composition may be altered in order to affect the temperature gradient (Han,“For example, lithium-ion battery stacks, conventionally, require a uniform current distribution throughout the stack because identical electrochemical cells are used throughout stack. But cells at different areas, portions, regions, segments, or locations of the stack usually experience different operating conditions making uniformity difficult.”, see [0023]))(Han,“ However, non-uniform current distribution may be possible if electrochemical cells having different attributes are used for different portions, regions, segments or locations. For example, the cells may have different compositions, different loading levels, packing densities, and/or different thicknesses”, see [0025])) (Han,“ In one variation, the electrochemical cells of stack 300 may form a gradient, as shown in FIG. 3 with shading, such that the outer most cells 302 may be configured for the lowest operating temperature and/or pressure while the inner most cell(s) … (e.g., composition, loading, packing density, thickness, and/or porosity).”, see [0043]). Therefore, it would have been obvious to vary the thickness to allow for a non-uniform current density. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to SEAMUS PATRICK MCNULTY whose telephone number is (703)756-1909. The examiner can normally be reached Monday- Friday 8:00am to 5pm. 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, Nicholas A. Smith can be reached on (571) 272-8760. 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. /S.P.M./Examiner, Art Unit 1752 /NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
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Prosecution Timeline

Show 3 earlier events
Apr 25, 2025
Applicant Interview (Telephonic)
May 01, 2025
Response Filed
Jul 07, 2025
Non-Final Rejection mailed — §103
Jul 21, 2025
Examiner Interview Summary
Jul 21, 2025
Applicant Interview (Telephonic)
Sep 03, 2025
Response Filed
Nov 17, 2025
Final Rejection mailed — §103
Dec 26, 2025
Response after Non-Final Action

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Prosecution Projections

3-4
Expected OA Rounds
53%
Grant Probability
97%
With Interview (+43.7%)
3y 4m (~0m remaining)
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