Prosecution Insights
Last updated: August 17, 2026
Application No. 18/000,819

RECHARGEABLE BATTERY

Non-Final OA §103
Filed
Dec 05, 2022
Priority
Jun 18, 2020 — RE 10-2020-0074397 +1 more
Examiner
DISNEY, CHRISTINE CONLON
Art Unit
1723
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Samsung SDI Co., Ltd.
OA Round
2 (Non-Final)
24%
Grant Probability
At Risk
2-3
OA Rounds
2m
Est. Remaining
56%
With Interview

Examiner Intelligence

Grants only 24% of cases
24%
Career Allowance Rate
6 granted / 25 resolved
-41.0% vs TC avg
Strong +32% interview lift
Without
With
+32.0%
Interview Lift
resolved cases with interview
Typical timeline
3y 11m
Avg Prosecution
12 currently pending
Career history
59
Total Applications
across all art units

Statute-Specific Performance

§103
64.2%
+24.2% vs TC avg
§102
17.1%
-22.9% vs TC avg
§112
9.8%
-30.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 25 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 This is a final office action in response to Applicant’s remarks and amendments filed on 12/19/2025. Claims 1 and 4 are currently amended. Claim 3 is canceled. Claims 14 and 15 are new. Claims 1-2 and 14-15 are presented for examination. The 35 U.S.C. § 103 and double patenting rejections in the previous office action are withdrawn. New grounds of rejection necessitated by Applicant's amendments are presented below. Response to Arguments Applicant’s arguments with respect to claim 1 have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. The new rejection does not rely on Eguchi or Katsumoto to teach the new limitation “wherein the second electrode tab is extended from an outer border along a radial direction of an upper portion of the electrode assembly to a peripheral portion of the flange part so as to be coupled with the peripheral portion of the flange part” as recited in amended claim 1. 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. Claims 1-2, 4-7, and 9-13 are rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1; priority to Japanese patent application JP2019-219432, filed 12/04/2019; previously cited) in view of Watanabe (US 2022/0223872 A1; priority to Japanese patent application JP 2019-180789, filed 09/30/2019). Regarding claim 1, Eguchi discloses a rechargeable battery (100, see FIG. 5(B) for illustrative purposes, [0125]) comprising: an electrode assembly (10, FIG. 1, [0039]) including a first electrode (1, FIG. 1, [0039]), a second electrode (2, FIG. 1, [0039]), a separator (3, FIG. 1, [0039]) located between the first electrode (1) and the second electrode (2), and a second electrode tab (70, FIG. 3(B), [0060]) extended from the second electrode (2); a case (cup-shaped member 52 of exterior body 50, see FIG. 5(B) for illustrative purposes, [0071]) connected to the first electrode (1) (the metal exterior body 50 including the case 52 serves as the external terminal for the electrode that is not connected to the external output terminal 60, discussed below, [0076]) to accommodate the electrode assembly (10) and including an opening portion (opening portion in annotated figure 1 below) to expose the electrode assembly (10); a cap plate (lid-shaped member 54 of exterior body 50, see FIG. 5(B) for illustrative purposes, [0071]) coupled with the case (52) to cover an outer peripheral area of the opening portion (opening portion), and including a through-hole (opening portion 55, FIG. 3(B), [0099]) to expose a center region of the opening portion (opening portion); and a terminal plate (external output terminal 60, FIG. 3(B) [0059]) connected to the second electrode tab (70) to be insulation-bonded to the cap plate (54) (via insulating member 64 with bonding force, FIG. 3(B), [0060]), and including a flange part (metal plate 62, FIG. 3(B), [0082]) covering the through-hole (55), wherein the second electrode tab (70) is coupled with a peripheral portion (peripheral portion in annotated figure 2 below) of the flange part (62). PNG media_image1.png 231 375 media_image1.png Greyscale Annotated figure 1 (Eguchi FIG. 5B) PNG media_image2.png 235 445 media_image2.png Greyscale Annotated figure 2 (Eguchi FIG.3B) Eguchi does not disclose a protruding part passing through the through-hole (55) from a center portion of the flange part (62) in the embodiment of FIG. 5(B). However, Eguchi teaches an embodiment (FIG. 7, [0082]) in which the terminal plate (60) further comprises a protruding part (metal member 67) passing through the through-hole (55) from a center portion of the flange part (62). It would have been obvious to a person having ordinary skill in the art before the effective filing date of the invention to have modified the embodiment of battery of Eguchi FIG. 3(B) to include the metal member positioned on the metal plate and passing through the through-hole from a center portion of the metal plate, as depicted in FIG. 7, because Eguchi teaches that the metal member facilitates the connection between the rechargeable battery and external equipment ([0082]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments described in the disclosure ([0155]) and it has been held that combining two embodiments disclosed adjacent to each other in prior art does not require a leap of inventiveness and involves only routine skill in the art. Eguchi does not disclose a first electrode tab extended from the first electrode and connected to the case or wherein the second electrode tab is extended from an outer border along a radial direction of the upper portion of the electrode assembly to the peripheral portion of the flange part. Watanabe teaches a rechargeable battery (FIG. 13, [0180]) comprising an electrode assembly (70, FIG. 13, [0180]) including a first electrode tab (60, FIG. 13, [0033]) extended from a first electrode (72, FIG. 13, [0181]) and connected to a case (11, FIG. 13, [0181]) and a second electrode tab (50, FIG. 13, [0181]) extended from a second electrode (71, FIG. 13, [0181]); a terminal plate connected to the second electrode tab (50) and including a flange part (see annotated figure 3 below) and a protruding part, wherein the second electrode tab (50) is extended from an outer border along a radial direction of an upper portion of the electrode assembly (70) to a peripheral portion of the flange part so as to be coupled with a peripheral portion of the flange part (see annotated figure 3 below). PNG media_image3.png 301 483 media_image3.png Greyscale Annotated figure 3 (Watanabe FIG. 13) It would have been obvious to a person having ordinary skill in the art before the effective filing date of the invention to have modified the battery of Eguchi by adding a first electrode tab extended from the first electrode and connected to the case and by forming the second electrode tab such that it is extended from an outer border along a radial direction of the upper portion of the electrode assembly to the peripheral portion of the flange part with a reasonable expectation of successfully connecting the electrode tabs because Watanabe teaches an operable battery having this configuration (FIG. 13, [0180]-[0181]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results [MPEP § 2143A]. In addition, Eguchi teaches that the battery may be modified beyond the embodiments of the disclosure ([0155]). Regarding claim 2, Eguchi in view of Watanabe does not disclose wherein the second electrode tab does not overlap the protruding part. However, Watanabe teaches wherein the second electrode tab (50) does not overlap the protruding part (see annotated figure 3 above). A person having ordinary skill in the art before the effective filing date of the invention would therefore have found it obvious to have formed the battery of Eguchi in view of Watanabe such that the second electrode tab does not overlap the protruding part with a reasonable expectation of successfully connecting the electrode tab because Watanabe teaches an operable battery having this configuration (FIG. 13, [0180]-[0181]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results [MPEP § 2143A]. Regarding claim 4, Eguchi in view of Watanabe teaches (see Eguchi) the flange part (62) is located between the cap plate (54) and the electrode assembly (10) (FIG. 3(B); FIG. 5(B) illustrates that the upper surface of exterior body 50 in FIG. 3(B) is the cap plate 54). Regarding claim 5, Eguchi in view of Watanabe teaches (see Eguchi) wherein: the protruding part (67) passes through the through-hole (55) and is exposed to the outside (FIG. 7, through-hole is labeled in FIG. 3(B)). Regarding claim 6, Eguchi in view of Watanabe teaches (see Eguchi) wherein: the flange part (62) has a wider area than an area of the protruding part (67) (based on the relative diameters depicted in FIG. 7). Regarding claim 7, Eguchi in view of Watanabe teaches (see Eguchi) wherein: a thickness of the flange part (62) is smaller than a thickness of the protruding part (67) (FIG. 7). Regarding claim 9, Eguchi in view of Watanabe teaches (see Eguchi) a thermal fusion layer (64, FIG. 3(B), [0059], insulating material contains a thermoplastic resin [0069]) located between the cap plate (54, see FIG. 5(B) for illustrative purposes) and the flange part (62) and configured to insulation-bond the cap plate (54) and the flange part (62). Regarding claim 10, Eguchi in view of Watanabe teaches (see Eguchi) wherein: the second electrode tab (70) overlaps the thermal fusion layer (64) (see annotated figure 4 below). PNG media_image4.png 235 445 media_image4.png Greyscale Annotated figure 4 (Eguchi FIG. 3B) Regarding claim 11, Eguchi in view of Watanabe teaches (see Eguchi) wherein: the case (52) and the cap plate (54) have the same polarity as a polarity of the first electrode (1), and the terminal plate (60) has the same polarity as a polarity of the second electrode (2) (the metal exterior body 50, including the case 52 and the cap plate 54 [0071], serves as the external terminal for one electrode and the terminal plate 60 is the external terminal for the other electrode [0076]). Regarding claim 12, Eguchi in view of Watanabe teaches (see Watanabe) wherein: the first electrode tab (60) is coupled to a bottom portion of the case (11) (FIG. 13). Regarding claim 13, Eguchi in view of Watanabe teaches (see Watanabe) wherein: the first electrode tab (60) is extended from a border of a lower portion of the electrode assembly (70) to a bottom portion of the case (11) (FIG. 13). Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Watanabe (US 2022/0223872 A1), as applied to claim 7 above, and further in view of Satoh (US 2002/0004162 A1, previously cited). Regarding claim 8, Eguchi in view of Watanabe does not disclose wherein: the second electrode tab is welded to the flange part by ultrasonic welding. Satoh teaches a rechargeable battery comprising: an electrode assembly (4, FIG. 1, [0075]), an electrode tab (55, FIG. 1, [0076]) extended from the electrode assembly (4), a case (11, FIG. 1, [0075]) accommodating the electrode assembly (4), a cap plate (12, FIG. 1, [0075]) coupled with the case (11), a terminal (9, FIG. 1, [0075]) connected to the electrode tab (55) and including a flange part (92) and a protruding portion (91), wherein the electrode tab (55) is coupled with the flange part (92). The tab may (55) be welded to the flange part (92) by laser welding or ultrasonic welding ([0076]). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have modified the battery of Eguchi such that the second electrode tab is welded to the flange part by ultrasonic welding rather than laser welding because Satoh teaches that either type of welding is suitable for coupling an electrode tab and a terminal. Further, Eguchi teaches that the battery may be modified beyond the embodiments of the disclosure ([0155]) and it has been held that the simple substitution of one known element for another is likely to be obvious when predictable results are achieved [MPEP § 2143(B)]. Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Watanabe (US 2022/0223872 A1), as applied to claim 7 above, and further in view of Tamachi (US 2017/0207491 A1, cited in the IDS filed 11/17/2025). Regarding claim 14, Eguchi in view of Watanabe does not disclose wherein the protruding part protrudes from an upper surface of the center portion of the flange part such that an upper surface of the protruding part is lower than an upper surface of the cap plate. Tamachi teaches a rechargeable battery (301, Figs. 25-26, [0149]) comprising a cap plate (25a, Fig. 26, [0073]) and a terminal plate (340/306, Fig. 26, [0161]), the terminal plate (340/306) including a flange part (340, Fig. 26, [0160]) and a protruding part (306, Fig. 26, [0160]), the protruding part (306) protrudes from an upper surface of the center portion of the flange part (340) such that an upper surface of the protruding part (306) is lower than an upper surface of the cap plate (25a). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have modified the battery of Eguchi in view of Watanabe such that an upper surface of the protruding part is lower than an upper surface of the cap plate because Tamachi teaches an operable battery having this configuration (Fig. 26, [0161]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results [MPEP § 2143A]. Claim 15 is rejected under 35 U.S.C. 103 as being unpatentable over Eguchi (US 2022/0311108 A1) in view of Watanabe (US 2022/0223872 A1) and Tamachi (US 2017/0207491 A1). Regarding claim 15, Eguchi discloses a rechargeable battery (100, see FIG. 5(B) for illustrative purposes, [0125]) comprising: an electrode assembly (10, FIG. 1, [0039]) including a first electrode (1, FIG. 1, [0039]), a second electrode (2, FIG. 1, [0039]), a separator (3, FIG. 1, [0039]) located between the first electrode (1) and the second electrode (2), and a second electrode tab (70, FIG. 3(B), [0060]) extended from the second electrode (2); a case (cup-shaped member 52 of exterior body 50, see FIG. 5(B) for illustrative purposes, [0071]) connected to the first electrode (1) (the metal exterior body 50 including the case 52 serves as the external terminal for the electrode that is not connected to the external output terminal 60, discussed below, [0076]) to accommodate the electrode assembly (10) and including an opening portion (opening portion in annotated figure 1 below) to expose the electrode assembly (10); a cap plate (lid-shaped member 54 of exterior body 50, see FIG. 5(B) for illustrative purposes, [0071]) coupled with the case (52) to cover an outer peripheral area of the opening portion (opening portion), and including a through-hole (opening portion 55, FIG. 3(B), [0099]) to expose a center region of the opening portion (opening portion); and a terminal plate (external output terminal 60, FIG. 3(B) [0059]) connected to the second electrode tab (70) to be insulation-bonded to the cap plate (54) (via insulating member 64 with bonding force, FIG. 3(B), [0060]), and including a flange part (metal plate 62, FIG. 3(B), [0082]) covering the through-hole (55), wherein the second electrode tab (70) is coupled with a peripheral portion (peripheral portion in annotated figure 2 below) of the flange part (62). PNG media_image1.png 231 375 media_image1.png Greyscale Annotated figure 1 (Eguchi FIG. 5B) PNG media_image2.png 235 445 media_image2.png Greyscale Annotated figure 2 (Eguchi FIG.3B) Eguchi does not disclose a protruding part passing through the through-hole (55) from a center portion of the flange part (62) in the embodiment of FIG. 5(B). However, Eguchi teaches an embodiment (FIG. 7, [0082]) in which the terminal plate (60) further comprises a protruding part (metal member 67) passing through the through-hole (55) from a center portion of the flange part (62). It would have been obvious to a person having ordinary skill in the art before the effective filing date of the invention to have modified the embodiment of battery of Eguchi FIG. 3(B) to include the metal member positioned on the metal plate and passing through the through-hole from a center portion of the metal plate, as depicted in FIG. 7, because Eguchi teaches that the metal member facilitates the connection between the rechargeable battery and external equipment ([0082]). In addition, Eguchi teaches that the battery may be modified beyond the embodiments described in the disclosure ([0155]) and it has been held that combining two embodiments disclosed adjacent to each other in prior art does not require a leap of inventiveness and involves only routine skill in the art. Eguchi does not disclose a first electrode tab extended from the first electrode and connected to the case or wherein the protruding part protrudes from an upper surface of the center portion of the flange part such that an upper surface of the protruding part is lower than an upper surface of the cap plate. Watanabe teaches a rechargeable battery (FIG. 13, [0180]) comprising an electrode assembly (70, FIG. 13, [0180]) including a first electrode tab (60, FIG. 13, [0033]) extended from a first electrode (72, FIG. 13, [0181]) and connected to a case (11, FIG. 13, [0181]) and a second electrode tab (50, FIG. 13, [0181]) extended from a second electrode (71, FIG. 13, [0181]); a terminal plate connected to the second electrode tab (50) and including a flange part (see annotated figure 3 below), wherein the second electrode tab (50) is extended from an outer border along a radial direction of an upper portion of the electrode assembly (70) to a peripheral portion of the flange part so as to be coupled with a peripheral portion of the flange part (see annotated figure 3 below). PNG media_image3.png 301 483 media_image3.png Greyscale Annotated figure 3 (Watanabe FIG. 13) It would have been obvious to a person having ordinary skill in the art before the effective filing date of the invention to have modified the battery of Eguchi by adding a first electrode tab extended from the first electrode and connected to the case and by forming the second electrode tab such that it is extended from an outer border along a radial direction of the upper portion of the electrode assembly to the peripheral portion of the flange part with a reasonable expectation of successfully connecting the electrode tabs because Watanabe teaches an operable battery having this configuration (FIG. 13, [0180]-[0181]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results [MPEP § 2143A]. In addition, Eguchi teaches that the battery may be modified beyond the embodiments of the disclosure ([0155]). Eguchi in view of Watanabe does not teach wherein the protruding part protrudes from an upper surface of the center portion of the flange part such that an upper surface of the protruding part is lower than an upper surface of the cap plate. Tamachi teaches a rechargeable battery (301, Figs. 25-26, [0149]) comprising a cap plate (25a, Fig. 26, [0073]) and a terminal plate (340/306, Fig. 26, [0161]), the terminal plate (340/306) including a flange part (340, Fig. 26, [0160]) and a protruding part (306, Fig. 26, [0160]), the protruding part (306) protrudes from an upper surface of the center portion of the flange part (340) such that an upper surface of the protruding part (306) is lower than an upper surface of the cap plate (25a). A person having ordinary skill in the art before the effective filing date of the invention would have found it obvious to have modified the battery of Eguchi in view of Watanabe such that an upper surface of the protruding part is lower than an upper surface of the cap plate because Tamachi teaches an operable battery having this configuration (Fig. 26, [0161]) and it has been held that the combination of familiar elements is likely to be obvious when it does no more than yield predictable results [MPEP § 2143A]. 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 CHRISTINE C. DISNEY whose telephone number is (703)756-1076. The examiner can normally be reached M-F 8:30-5:30 MT. 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, Tiffany Legette-Thompson can be reached at (571) 270-7078. 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. /C.C.D./Examiner, Art Unit 1723 /TIFFANY LEGETTE/Supervisory Patent Examiner, Art Unit 1723
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Prosecution Timeline

Dec 05, 2022
Application Filed
Oct 02, 2025
Non-Final Rejection mailed — §103
Dec 19, 2025
Response Filed
Apr 16, 2026
Final Rejection mailed — §103
Jun 09, 2026
Response after Non-Final Action

Precedent Cases

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Prosecution Projections

2-3
Expected OA Rounds
24%
Grant Probability
56%
With Interview (+32.0%)
3y 11m (~2m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 25 resolved cases by this examiner. Grant probability derived from career allowance rate.

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