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
In response to the amendment received November 3, 2025:
Claims 2-7 have been canceled as per Applicant’s request. Claims 1 and 8-14 are pending.
The previous objection to the drawings has been withdrawn in light of the amendment.
The previous prior art rejection is maintained with slight changes made in light of het amendment.
All changes to the rejection are necessitated by the amendment. Thus the action is final.
Drawings
The drawings were received on November 3, 2025. These drawings are acceptable.
Claim Objections
Claim 1 objected to because of the following informalities: reciting “arranged in an annular shaped” wherein ‘arranged in an annular shape’ is meant instead (line 16). Appropriate correction is required.
Claim Rejections - 35 USC § 103
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.
Claim(s) 1, 9, and 11-14 is/are rejected under 35 U.S.C. 103 as being unpatentable over CN207282542 (Liu).
As to claim 1, Liu teaches a battery housing structure, comprising:
an upper cover (steel cap [1]); and
a bottom case (shell [7]), wherein the bottom case (shell [7]) cooperates with the upper cover (steel cap [1]) to form a sealing cavity, the sealing cavity is configured for a cell assembly (battery cell [6]) to be mounted therein, the bottom case is provided with a first blind groove (one of groove [73] or protrusion [72]) (figs. 1-2);
wherein the first blind groove (protrusion [72]) is arranged in an arc shape (circle; full arc) (fig. 2; para 0022);
wherein the bottom case (shell [7]) comprises a first bottom wall, a first side wall, and a first sealing edge (flanged edge [71]) (figs. 1-2); the first side wall is arranged in an annular shape, the first side wall is connected around a circumference of the first bottom wall (figs. 1-2; line preceding para 0001); the first sealing edge (flanged edge [71]) is arranged in an annular shape and corresponds to the first side wall, the first sealing edge (flanged edge [71]) is connected to the first side wall, and the first sealing edge (flanged edge [71]) is located at an end of the first side wall away from the first bottom wall, the first blind groove (protrusion [0072]) is opened on the first sealing edge (flanged edge [71]) (figs. 1-2; line preceding para 0001);
wherein the first blind groove is opened around a circumference of the first sealing edge to form an annular groove (figs. 1-2; para 0022);
wherein the first sealing edge comprises a first extending edge (bottom horizontal portion with protrusion [72]) and a second extending edge (part bent upwards from the bottom horizontal portion), both the first extending edge and the second extending edge are arranged in an annular shaped (figs. 1-2; cylindrical cell confirmed before para 0001); one end of the first extending edge is connected to the first side wall (of the shell [7]), the other end of the first extending edge is connected to the second extending edge (of the bent portion), and the first extending edge is located between the first side wall and the second extending edge, the first blind groove is opened around a circumference of the first extending edge, the second extending edge abuts against the upper cover (steel cap [1]);
wherein the first extending edge (bottom horizontal portion with protrusion [72]) has an inner ring end and an outer ring end (demarked by the protrusion [0072]; circle-shaped para 0022; fig. 2), the first extending edge is connected to the first side wall through the inner ring end (wall portion inside of the protrusion [72]), the first extending edge is extended from the first side wall toward an outer ring of the first side wall, the second extending edge is connected to the outer ring (wall portion outside of the protrusion [72]) end to enable the second extending edge to be connected to the first extending edge, and the second extending edge is extended from the first extending edge in a direction away from the first bottom wall (fig. 2).
Liu shows a distance between the first blind groove and the inner ring end is a first distance, a distance between the first blind groove and the outer ring end is a second distance, the first distance appears equal to the second distance (fig. 2).
Thus, Liu (a) does not teach the first blind groove is non-annular, and (b) does not teach specific distances (between the first blind groove and the inner ring and between the first blind groove and the outer ring) and does not state that fig. 2 is made to scale.
With respect to (a), having a non-annular groove is merely a change in shape. The Office has held a change in shape to be obvious. See MPEP §2144.04(IV)(B).
With respect to (b), the general teaching shows a general proportion between the distances, wherein any differences (if shown to exist) between the general teaching of Liu and the claimed invention would be minor, such that obviousness is achieved. It has been held that when the difference between a claimed invention and the prior art is the range or value of a particular variable, then a prima facie rejection is properly established when the difference in the range or value is minor. Titanium Metals Corp. of Am. v. Banner, 778 F.2d 775, 783, 227 USPQ 773, 779 (Fed. Cir. 1985). Generally, differences in ranges will not support the patentability of subject matter encompassed by the prior art unless there is evidence indicating such ranges is critical. In re Boesch, 617 F.2d 272, 205 USPQ 215 (CCPA 1980). In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955). In re Hoeschele, 406 F.2d 1403, 160 USPQ 809 (CCPA 1969). Claims that differ from the prior art only by slightly different (non-overlapping) ranges are prima facie obvious without a showing that the claimed range achieves unexpected results relative to the prior art. (In re Woodruff, 16 USPQ2d 1935,1937 (Fed. Cir. 1990)) Also see MPEP §2144.05(I).
As to claim 9, Liu teaches wherein the first blind groove (protrusion [72]) is opened on an outer wall of the first sealing edge (flanged edge [71]) (fig. 2);
wherein a cross-section of the first blind groove is triangular (fig. 2);
the battery housing structure further comprises a sealing ring (sealing pad [4]), the sealing ring (sealing pad [4]) is disposed between an outer edge of the upper cover (steel cap [1]) and the bottom case (shell [7]).
Thus, Liu does not teach wherein a cross-section of the first blind groove is rectangular. However, having a cross-section of the groove being rectangular is merely a change in shape. The Office has held a change in shape to be obvious. See MPEP §2144.04(IV)(B).
As to claim 11, Liu teaches the first blind groove is arranged in an arc shape; or the first blind groove (groove [73]) is arranged in a straight-line shape (fig. 1).
As to claim 12, Liu teaches the first blind groove (protrusion [72]) is opened around a circumference of the first sealing edge (flanged edge [71]) to form an annular groove (figs. 1-2; para 0022).
As to claim 13, Liu teaches wherein the first blind groove (protrusion [72]) is opened on an outer wall of the first sealing edge (flanged edge [71]) (fig. 2);
wherein a cross-section of the first blind groove is triangular (fig. 2);
the battery housing structure further comprises a sealing ring (sealing pad [4]), the sealing ring (sealing pad [4]) is disposed between an outer edge of the upper cover (steel cap [1]) and the bottom case (shell [7]).
Thus, Liu does not teach wherein a cross-section of the first blind groove is semicircular. However, having a cross-section of the groove being semicircular is merely a change in shape. The Office has held a change in shape to be obvious. See MPEP §2144.04(IV)(B).
As to claim 14, Liu teaches wherein the first blind groove (protrusion [72]) is opened on an outer wall of the first sealing edge (flanged edge [71]) (fig. 2);
wherein a cross-section of the first blind groove is triangular (fig. 2);
the battery housing structure further comprises a sealing ring (sealing pad [4]), the sealing ring (sealing pad [4]) is disposed between an outer edge of the upper cover (steel cap [1]) and the bottom case (shell [7]).
Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Liu, as applied to claim 1 above, and further in view of US 2018/0175333 (Sodeyama et al.).
As to claim 8, Liu teaches a first blind grove (protrusion [72]) and a second blind groove (groove [73]).
Liu does not teach the first bottom wall is provided with the second blind groove, the second blind groove is arranged in an arc shape; wherein the second blind groove is opened on an outer wall of the first bottom wall, and the second blind groove is opened around the circumference of the first bottom wall.
However, Sodeyama et al. teaches the first bottom wall is provided with a second blind groove [11Gv], the second blind groove is arranged in an arc shape (figs. 2A, 3-7); wherein the second blind groove is opened on an outer wall of the first bottom wall (figs. 10A, 10B), and the second blind groove is opened around the circumference of the first bottom wall (figs. 2A, 3-7, as applied to figs. 10A, 10B; para 0098-0100). The motivation for using the structure of Sodeyama et al. (figs. 2A, 3-7, as applied to figs. 10A, 10B) (the first bottom wall is provided with the second blind groove, the second blind groove is arranged in an arc shape; wherein the second blind groove is opened on an outer wall of the first bottom wall, and the second blind groove is opened around the circumference of the first bottom wall) is to provide a battery that is capable of improving safety when abnormal heat is applied while suppressing a decrease in mechanical strength (para 0008-0009). Therefore it would have been obvious to one having ordinary skill in the art at the time the claimed invention was made (as applicable to pre-AIA applications) or effectively filed (as applicable to AIA applications) to have the first bottom wall provided with a second blind groove, the second blind groove is arranged in an arc shape; wherein the second blind groove is opened on an outer wall of the first bottom wall, and the second blind groove is opened around the circumference of the first bottom wall (as taught by Sodeyama et al. and applied to Liu) in order to provide a battery that is capable of improving safety when abnormal heat is applied while suppressing a decrease in mechanical strength. At the very least, the substitution of the groove structure of Sodeyama et al. (have the first bottom wall provided with a second blind groove, the second blind groove is arranged in an arc shape; wherein the second blind groove is opened on an outer wall of the first bottom wall, and the second blind groove is opened around the circumference of the first bottom wall; seen in figs. 2A, 3-7, 10A, 10B) for the groove [73] of Liu (groove on the side wall) would yield the predictable result of providing a groove that breaks during abnormal temperature/pressure rise, wherein the substituted components and their functions are known in the art (i.e. vents in a battery casing). Therefore it would have been obvious to one having ordinary skill in the art at the time the claimed invention was made (as applicable to pre-AIA applications) or effectively filed (as applicable to AIA applications) to substitute a second blind groove provided on the first bottom wall, the second blind groove is arranged in an arc shape; wherein the second blind groove is opened on an outer wall of the first bottom wall, and the second blind groove is opened around the circumference of the first bottom wall (as in Sodeyama et al.) for a groove provided on the body (Liu), as the substitution would yield the predictable result of providing a groove that breaks during abnormal temperature/pressure rise, wherein the substituted components and their functions are known in the art (i.e. rupturable grooves for venting). “When considering obviousness of a combination of known elements, the operative question is thus "whether the improvement is more than the predictable use of prior art elements according to their established functions." Id . at ___, 82 USPQ2d at 1396.” See MPEP §2141(I).
Claim(s) 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Liu as applied to claims 1 above, and further in view of US 2004/0048153 (Sauer).
As to claim 10, Liu teaches a battery, comprising: a cell assembly (battery cell [6]);
and the battery housing structure according to claim 1 (the rejection of claim 1 incorporated herein but not reiterated herein for brevity’s sake), wherein the cell assembly is arranged in the sealing cavity.
Liu does not teach that the battery is a button battery.
However, Sauer, in the same field of endeavor, teaches a cylindrical battery that has venting considerations (guides gas to a vent hole [4]) (para 0019) is also a button battery (fig. 1 shows the short cell indicating a button cell). The substitution of the limitations of the housing structure of claim 1 (in Liu) as applied to a button cylindrical cell (Sauer) would yield the predictable result of providing a housing that holds a battery cell that addresses venting considerations, wherein the substituted components and their functions are known in the art (i.e. one housing structure that addresses venting for another). Therefore it would have been obvious to one having ordinary skill in the art at the time the claimed invention was made (as applicable to pre-AIA applications) or effectively filed (as applicable to AIA applications) to substitute the limitations of the housing structure of claim 1 (in Liu) as applied to a button cylindrical cell (Sauer), as the substitution would yield the predictable result of providing a housing that holds a battery cell that addresses venting considerations, wherein the substituted components and their functions are known in the art (i.e. one housing structure that addresses venting). “When considering obviousness of a combination of known elements, the operative question is thus "whether the improvement is more than the predictable use of prior art elements according to their established functions." Id . at ___, 82 USPQ2d at 1396.” See MPEP §2141(I).
Response to Arguments
Applicant's arguments filed November 3, 2025 have been fully considered but they are not persuasive.
Applicant argues that (a) Liu’s first distance is larger than the second distance rather than appearing equal, (b) that Liu’s circle protrusion [72] is for sealing and does not provide an arrangement that the first distance is less than the second distance, wherein (c) the claimed distances allows for breaking of the first blind groove to release pressure.
Examiner respectfully disagrees.
With respect to (a): Examiner provides an annotated figure where the two arrows of the same length are applied to both the first distance and the second distance. Thus Examiner reaffirms that as in the rejection the distances appear the same.
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With respect to (b): Examiner submits that it is uncertain how any slight differences between the placement of the protrusion would not be obvious as set forth in MPEP §2144.05(I), or how crimping for the purposes of Liu would negate the rejection set forth.
With respect to (c): Again, submits that it is uncertain how any slight differences between the placement of the protrusion would not be obvious as set forth in MPEP §2144.05(I), Applicant’s statement is not proof of criticality (burden to show criticality set forth in MPEP 716.02). It is unsure how if the placement regarding the distances is the same (close to having the first distance being less than the second distance) would yield patentable distinctness of the claimed invention in light of MPEP §2144.05(I).
Thus the argument is not persuasive, and the rejection of record is maintained.
Applicant argues that the dependent claims are distinct from the prior art of record for the same reason as the independent claim.
Examiner respectfully disagrees. The rejection with respect to the independent claim has been maintained, and thus the rejections to the dependent claims are maintained as well.
With respect to the arguments regarding the 103 rejections, Applicant argues that the prior art used to render obvious the rejected claims (Sodeyama and Sauer) do not cure the deficiencies of the rejection applied to the independent claim (Liu). Applicant does not argue how the combination is not proper. Therefore, the Examiner maintains the obviousness rejections and upholds the rejection to the independent claim, as above.
Conclusion
THIS ACTION IS MADE FINAL. 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 EUGENIA WANG whose telephone number is (571)272-4942. The examiner can normally be reached a flex schedule, generally Monday-Thursday 5:30 -7:30(AM) and 9:00-4:30 ET.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Duane Smith can be reached at 571-272-1166. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/EUGENIA WANG/Primary Examiner, Art Unit 1759
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