Prosecution Insights
Last updated: April 19, 2026
Application No. 17/998,513

CASE FOR AN ELECTROCHEMICAL CELL FOR A BATTERY, ELECTROCHEMICAL CELL ARRANGEMENT FOR A BATTERY COMPRISING SUCH A CASE AND METHOD FOR MANUFACTURING SUCH A CELL ARRANGEMENT

Final Rejection §103
Filed
Nov 11, 2022
Examiner
MCNULTY, SEAMUS PATRICK
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Renault S A S
OA Round
2 (Final)
52%
Grant Probability
Moderate
3-4
OA Rounds
3y 5m
To Grant
94%
With Interview

Examiner Intelligence

Grants 52% of resolved cases
52%
Career Allow Rate
16 granted / 31 resolved
-13.4% vs TC avg
Strong +42% interview lift
Without
With
+41.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
60 currently pending
Career history
91
Total Applications
across all art units

Statute-Specific Performance

§103
63.5%
+23.5% vs TC avg
§102
22.8%
-17.2% vs TC avg
§112
13.3%
-26.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 31 resolved cases

Office Action

§103
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 . Response to Amendment Amendments filed 10/28/2025 have been received, overcome the 102 rejection but do not overcome the 103 rejection as set forth in non-final office action filed 08/11/2025. 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 14,16, 19, and 20-26 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20180219191-A1) hereinafter referred to as ‘Drews’, view of (US-20180205046-A1) hereinafter referred to as ‘Schmid-Schoenbein’ in view of (JP-2014078471-A1) hereinafter referred to as ‘Kuroda’ Regarding Claim 19, Drews teaches a row of electrochemical cells for a battery comprising: the case comprising at least one duct being arranged so as to be passed through by at least one electrical connector of each of the cells (Drews, channels, 244, Fig. 4A) (Drews, terminals, 234, Fig. 4A) (Drew, battery pack, 350, Fig. 5) the duct extending continuously and/or linearly in the longitudinal direction along at an edge of the case (Drew, channel, 244, Fig. 4A) (see annotated figure below); a fluid connection inserted into each end of the duct and extending in the longitudinal direction past an outer end of the case; and a bypass module attached to the fluid connection, the bypass module including a fluid transfer line to circulate the cooling fluid in a direction transverse to the longitudinal direction (see 244 in Fig. 4A below) PNG media_image1.png 430 688 media_image1.png Greyscale Drews does not teach at least two of the cells arranged side-by-side in a longitudinal direction; a case surrounding the cells Schmid-Schoenbein teaches at least two of the cells arranged side-by-side in a longitudinal direction; a case surrounding the cells (Schmid-Schoenbein, pouch cells, 10, see Fig. 1). Schmid-Schoenbein teaches that such an arrangement allows for more flexibility and makes it more resistant to damage (Schmid-Schoenbein, “It is advantageous in this case that the pouch film is very flexible, such that the structure with the coherent pockets can be produced very easily, since the pouch film can be bent, folded, heated and sealed without being damaged”, see [0016]). Drews and Schmid-Schoenbein are analogous as they are both of the same field of cell arrangements. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have rearranged the cells as taught in Drews to the arrangement as taught in Schmid-Schoenbein in order to improve the ductility of the cell arrangement. Drews teaches the case further comprising two shaped sheets welded to one another, walls of the duct being formed by said two welded sheets, the at least one electrical connector being disposed between the two welded sheets (Drews, terminals, 234, Fig. 4A) Drews doesn’t teach two shaped sheets welded to one another. Kuroda teaches two shaped sheets welded to one another (Kuroda, “The peripheries of the two laminated films are heat-sealed in an airtight manner by, for example, pressing (heat-sealing) with heating.”, see [0016]). Kuroda teaches that the welding creates an airtight seal (Kuroda, “The peripheries of the two laminated films are heat-sealed in an airtight manner by, for example, pressing (heat-sealing) with heating.”, see [0016]). Drews and Kuroda are analogous as they are both of the same field of batteries and battery construction. 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 construction of the two sheets to be welded to one another to create an airtight seal and prevent unwanted contamination of the interior of the cell. Regarding Claim 14, Modified Drews teaches the case as claimed in claim 19, wherein the case is a multilayer system of aluminum and polymer films (Drews, “The conductive portion 129 may be made from one or more metals such as aluminum”, see [0054])(Drews, “The cell cover 140 may be made from a polymeric material.”, see [0057]). Regarding Claim 16, Modified Drews teaches the row cells as claimed in claim 19 wherein the duct is symmetrical with respect to the at least one electrical connector passing through the duct (Drews , battery pack, 350, Fig. 5). Regarding Claim 20, Modified Drews teaches a battery module comprising: at least one of the row of cells as claimed in claim 19, the at least one duct forming a cooling circuit (Drew, channel, 244, Fig. 4A) (see annotated figure above). Regarding Claim 21, Modified Drews teaches a battery comprising: at least one of the module as claimed in claim 20 (Drew, cell, 200, Fig. 4A) (Drew, channel, 244, Fig. 4A). Regarding Claim 22, Modified Drews teaches a vehicle comprising: the battery as claimed in claim 21 (Drew, “But the cell alignment guides must allow for easy insertion into the modules during assembly, and thus may not fully constrain the cells, leaving the cells vulnerable to abrasion and damage from vibration during vehicle use”, see [0045]). Regarding Claim 23, Modified Drews teaches a method for manufacturing the row of cells as claimed claim 19, the method comprising: forming the at least one duct for the circulation of the cooling fluid by molding (Drews, “The frame of the battery cell may be molded, for example, using injection molding or formed by a similar method”, see [0086]) and heat-sealing two faces of the case of the cell the at least one electrical connector of the cell passing through the duct (Drews, “the terminals, and/or a portion of the thermal transfer device, are thus over-molded”, see [0086]). Drews doesn’t teach heat-sealing two faces of the case of the cell Kuroda teaches two shaped sheets welded to one another with heat-sealing two faces of the case of the cell (Kuroda, “The peripheries of the two laminated films are heat-sealed in an airtight manner by, for example, pressing (heat-sealing) with heating.”, see [0016]). Kuroda teaches that the welding creates an airtight seal (Kuroda, “The peripheries of the two laminated films are heat-sealed in an airtight manner by, for example, pressing (heat-sealing) with heating.”, see [0016]). Drews and Kuroda are analogous as they are both of the same field of batteries and battery construction. 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 construction of the two sheets to be welded to one another to create an airtight seal and prevent unwanted contamination of the interior of the cell. Regarding Claim 24, Modified Drews teaches the method as claimed in claim 23, further comprising: providing a first face (Drews, “For example, an upper half of the frame containing the terminals may be formed”, see [0090]) and a second face of the case (Drews, “and later connected to a separately formed lower half which does not contain the terminals”, see [0090]) ; shaping the first face and the second face of the case with a formation (Drews, “The frame of the battery cell may be molded, for example, using injection molding or formed by a similar method”, see [0086]), in the first face and in the second face, of a trench configured to receive a first rod and a second rod (Kuroda, cylindrical portion, 14a and 21a, Fig. 7) respectively, and at least one housing, each housing being configured to receive an active element (Kuroda, electrical coil, 12, Fig. 1A) ; positioning the first rod in the trench of the first face; positioning the active element provided with at least one electrical connector in each housing of the first face; positioning the second rod on the first rod (Kuroda, “and the stopper 15a are placed between the laminate films.”, see [0022]), with interposition of the at least one electrical connector (Kuroda, connection terminals, 13a, see Fig. 7) ; positioning the second face on the active elements and the second rod , the active elements being positioned in the housings of the second face and the second rod being positioned in the trench of the second face; welding the first face and the second face of the case so as to form the arrangement or the row and the at least one duct (Kuroda, “Next, the two laminate films 11a and 11b are pressed and heated from above and below”, see [0023]); and removing the first rod and the second rod (Kuroda, “When the secondary battery 10 is used, the plugging member 15 a is removed from the support frame”, see [0038]). Regarding Claim 25, Modified Drews teaches the method as claimed in claim 24, wherein the welding the first face and the second face of the case is done by thermowelding or heat sealing (Kuroda, “Thus, the lower surface side laminate film 11a and the upper surface side laminate film 11b are heat-sealed in a sealed manner”, see [0023]). Regarding Claim 26, Modified Drews teaches the method as claimed in claim 24, further comprising: attaching the fluid connection at each end of the at least one duct; and joining the bypass module to the fluid connection at each end of the at least one duct (Drews, “The inlet 520 and outlet 522 may accommodate a fluid 516 supplied from the cell exterior 514.”, see [0079]). Claims 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20180219191-A1) hereinafter referred to as ‘Drews’, further view of (US-20200266401-A1) hereinafter referred to as ‘Stuetz’ Regarding Claim 17, Drews teaches the row of cells as claimed in claim 19, wherein each of the electrical connectors comprises two plates and the cooling fluid is dielectric. Drews does not teach wherein the cooling fluid is dielectric Stuetz teaches wherein the cooling fluid is dielectric (Stuetz, “battery modules may be immersed in a dielectric fluid”, see [0006]). Stuetz teaches that the dielectric fluid allows for the battery to contact the fluid without a short-circuit (Stuetz, “which cools the modules without causing an electrical short.”, see [0006]). Drews and Stuetz are analogous as they are both related to the field of cooling of battery cells. 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 fluid of Drews to the dielectric fluid of Stuetz in order to cool the battery while preventing a short circuit. Regarding Claim 18, Drews teaches The row of cells as claimed in claim 17, wherein the two plates are made of polymer (Drews, “To improve the robustness of the seals around the electrical terminals, a thin coating of hot-melt polymer is typically applied to the terminals”, see [0042]). Response to Arguments On pg. 9, the applicant argues: “the Examiner relies on the batter [sic] pack shown in Fig. 5 of Drew. However, as can be seen in Fig. 5 below , the individual cells are not arranged in a side-by-side configuration in the longitudinal direction as recited in amended claim 19… Further, modifying the cells of Drew to be in such a side-by-side configuration would require an extensive modification to the arrangement of the cooling system disclosed therein.” However, this is not convincing. The examiner agrees that Drews does not teach the cells arranged side by side such as in the instant application. Although, (US-20180205046-A1) hereinafter referred to as ‘Schmid-Schoenbein’ teaches the arrangements of the cells as claimed. It would have been obvious to one of ordinary skill in the art to have modified Drews with such an arrangement, in order to make the cell stack more foldable (Schmid-Schoenbein, “It is advantageous in this case that the pouch film is very flexible, such that the structure with the coherent pockets can be produced very easily, since the pouch film can be bent, folded, heated and sealed without being damaged”, see [0016]). Regarding the contention that such a modification would be too extensive, the examiner argues that this would not be true. As picture in figure 4A, the cooling duct extends out of the bottom of the cell, modifying this embodiment to have the arrangement as taught in Schmid-Schoenbein would just require a simply change in the system as annotated below. Secondly, the examiner notes that a determination of obviousness does not require a physical substitution of elements, and only requires that the claimed invention is rendered obvious by the prior art (In re Mouttet, 686 F.3d 1322, 1332, 103 USPQ2d 1219, 1226 (Fed. Cir. 2012) (citing In re Etter, 756 F.2d 852, 859, 225 USPQ 1, 6 (Fed. Cir. 1985) (en banc))) (see MPEP 2145 (III)). In this case, it is moot whether the inventions would be physically combinable, as it is clear that the arrangement would have been obvious to one of ordinary skill in the art as the arrangement is taught as being advantageous in ‘Schmid-Schoenbein’ (Schmid-Schoenbein, “It is advantageous in this case that the pouch film is very flexible, such that the structure with the coherent pockets can be produced very easily, since the pouch film can be bent, folded, heated and sealed without being damaged”, see [0016]). PNG media_image2.png 409 430 media_image2.png Greyscale 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 at (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

Nov 11, 2022
Application Filed
Aug 07, 2025
Non-Final Rejection — §103
Oct 28, 2025
Response Filed
Jan 07, 2026
Final Rejection — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
52%
Grant Probability
94%
With Interview (+41.9%)
3y 5m
Median Time to Grant
Moderate
PTA Risk
Based on 31 resolved cases by this examiner. Grant probability derived from career allow rate.

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