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 March 9, 2026:
Claims 3 and 14 have been canceled as per Applicant’s request. Claims 1-2, 4-13, and 15-20 are pending.
The core of the previous prior art rejection is maintained with slight changes made in light of the amendment.
All changes to the rejection are necessitated by the amendment. Thus, the action is final.
Claim Rejections - 35 USC § 103
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claim(s) 1-2, 4-7, 10-11, and 15-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over CN 106848123 (Li) in view of US 2017/0077467 (Kronke et al.) and US 2013/0288096 (Frutschy et al.).
As to claim 1, Li teaches an energy storage system, comprising: an anti-explosion housing (explosion proof frames) hermetically (waterproof box) accommodating a battery (abs).
Li does not teach (a) that housing accommodates at least one battery rack, or (b) the anti-explosion housing includes at least one guide pole (between the at least one door and the rear cover to guide the support of the at least one battery rack).
With respect to (a): Kronke et al. teach using racks [201] within a battery housing to hold energy storage devices [200] (includes grouping in modules) (para 0027, 0030; fig. 1, 4). The motivation for having a rack within the housing is to receive a plurality of energy storage devices (para 0027). 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 a rack within the housing (as taught by Kronke et al. and applied to Li) in order to easily house multiple energy storage devices within a housing. At the very least, combining the teaching of Kronke et al.’s rack for holding battery modules, within the housing of Li would have each element (rack that holds modules and housing for battery modules) perform the same function as they do separately, such that the combination and results would be predictable. 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 combine a rack within the housing, as the combination would have the rack and housing combination perform the same function as the rack and housing do separately, such that the combination yields the predictable result of providing a rack/housing combination to hold a plurality of battery modules. “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).
With respect to (b): Frutschy et al. teach of a system using structures such as [1080A, 1080B, 1150]) to support the battery racks (i.e. portions that the batteries are stacked thereon) (figs. 10A, 10B, 11C). These structures constitute a guide pole. The motivation for having a guide pole (ring structure to surround the “shelves” that make up the cabinets of a rack) is to facilitate stacking and access (para 0075-0076). 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) for having a guide pole (ring structure to surround the “shelves” that make up the cabinets of a rack) in order to facilitate stacking and access. (Note: The combination would have the at least one guide pole between the at least one door and the rear cover to guide the support of the at least one battery rack, as it is applied to Li in view of Kronke et al., which has the cabinet within the housing.)
In light structures rendered obvious above (i.e. cabinets rendered obvious by Kronke et al., and guide pole around the cabinets (thus separate therefrom and interpreted to be part of the anti-explosion housing), Li et al. further teaches the anti-explosion housing includes the following (in relation to the structures rendered obvious above):
a bottom cover (fig. 1) (configured to cover a bottom of the at least one battery rack, rendered obvious by the combination, as Kronke et al. render obvious the presence of a rack; see above for full details of the combination incorporated herein but not reiterated herein for brevity’s sake);
a pair of side covers coupled to the bottom cover (fig. 1), (and configured to cover two sides of the at least one battery rack, rendered obvious by the combination, as Kronke et al. render obvious the presence of a rack; see above for full details of the combination incorporated herein but not reiterated herein for brevity’s sake);
at least one door coupled to the pair of side covers, wherein the door the at least one door is open/closed on a front side of the at least one battery rack (fig. 1);
a rear cover provided on a rear side of the door unit opposite the at least one door (fig. 1) (to cover a rear side of the at least one battery rack, rendered obvious by the combination, as Kronke et al. renders obvious the presence of a rack; see the rejection to claim 1 for full details of the combination incorporated herein but not reiterated herein for brevity’s sake); and
a top cover provided on the opposite the rear cover and the at least one door (fig. 1) (to cover a top of the at least one battery rack, rendered obvious by the combination, as Kronk et al. render obvious the presence of a rack; see the rejection to claim 1 for full details of the combination incorporated herein but not reiterated herein for brevity’s sake).
As to claim 2, Li teaches the anti-explosion housing includes sheet of a predetermined thickness (fig. 1).
Li does not teach that the material of the sheet is steel.
However, Kronke et al. teach using steel as part of the frame assembly – specifically any rigid material that is suitable for supporting electronic components (para 0054). The motivation for using steel as a material for the fame is to use rigid materials suitable for supporting electronic components (para 0054). 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 use steel (as taught by Kronke et al., and as applied to the sheet of Li), in order to provide a rigid material that is suitable for supporting electronic components.
As to claim 4, Li teaches a base plate (base/feet [4]) to support a bottom of the bottom cover (figs. 1, 3; para 0029).
As to claim 5, Li teaches the base plate (base/feet [4]) includes at least one reinforcement rib (fixing block) on an upper surface to reinforce a strength of the base plate (base/feet [4]) (figs. 1, 3; para 0029).
As to claim 6, Li in view of Kronke et al. renders obvious that the pair of side covers include: a first side cover to cover a first side of the at least one battery rack; and a second side cover positioned opposite the first side cover to cover an opposite a second side of the at least one battery rack, as Li teaches the pair of side covers on opposite sides (fig. 1), and Kronke et al. rendes obvious the presence of the at least one battery rack (see the rejection to claim 1 for full details of the combination incorporated herein but not reiterated herein for brevity’s sake).
As to claim 7, Li teaches each of the first side cover and the second side cover includes a plurality of side panels stacked upon one another (from the box body and the explosion proof frame) (fig. 1).
As to claim 10, Li teaches that the at least one door is one door that is pivotably hinge-connected to a respective one of the pair of side covers (para 0008, 0026; fig. 1).
Li et al. do not teach that the at least one door is a pair of doors. However, the provision of a pair of doors hinged from one of the side covers rather than one door is a mere duplication of parts. It would have been obvious to one having ordinary skill in the art at the time the invention was made to have the at least one door (one door present) be a pair of doors, since it has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Also see MPEP §2144.04(VI)(B).
As to claim 11, Li teaches the at least one door is a door that connects to one of the pair of side covers (fig. 1).
Thus, Li does not teach the at least one door is a pair of doors, and each door unit of the pair of doors is connected to a respective one of the pair of side covers.
However, Kronke et al. in the same field of endeavor (battery storage system) teaches the at least one door is a pair of doors (pair of door assemblies [130]), and each door unit of the pair of doors is connected to a respective one of the pair of side covers (fig. 1; para 0028). The substitution of a single door connected to one of the pair of side covers (Li) with a pair of doors, each door unit of the pair of doors is connected to a respective one of the pair of side covers (Kronke et al.) would yield the predictable result of providing a door for the battery housing, as each door structure was known as a door structure in the art. 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 single door connected to one of the pair of side covers (Li) with a pair of doors, each door unit of the pair of doors is connected to a respective one of the pair of side covers (Kronke et al.), as the substitution would yield the predictable result of providing a door for the battery housing, as each door structure was known as a door structure in the art. “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).
As to claim 15, the combination renders the limitation obvious, as Frutschy et al., relied upon to render obvious the guide pole (see the rejection to claim 14 above for full details of the combination, incorporated herein but nor retethered herein for brevity’s sake) shows that the at least one guide pole comprises a ring (figs. 10A, 10B, 11C). Accordingly, the combination would have the ring extending around the bottom cover, the pair of side covers, and the top cover (as it is placed into the housing of Li with such a structure).
As to claim 16, the combination renders the limitation obvious, as Frutschy et al., relied upon to render obvious the guide pole (see the rejection to claim 14 above for full details of the combination, incorporated herein but nor retethered herein for brevity’s sake) shows the ring extends around the at least one battery rack (figs. 10A, 10B, 11C).
As to claim 17, the combination of Li and Kronke et al. renders obvious a rack within a housing (see the rejection to claim 1 for full details of the combination, incorporated herein but not reiterated herein for brevity’s sake).
Additionally, the combination with Frutschy et al. renders obvious the at least one guide pole comprises at least one ring between a front wall and a rear wall of the anti-explosion housing to guide the support of the at least one battery rack, the at least one ring extending around the at least one battery rack, as Frutschy et al. has been relied upon to render obvious the use of teach of a system using structures such as [1080A, 1080B, 1150]) to support the battery racks (i.e. portions that the batteries are stacked thereon) (figs. 10A, 10B, 11C), which are structures that constitute the at least one ring to guide the support of the at least one battery rack, the at least one ring extending around the battery rack. See the rejection to claim 1 for full details of the combination, incorporated herein but not reiterated for brevity’s sake. (Note: The combination would have the at least one at least one ring between a front wall and a rear wall of the anti-explosion housing, as it is applied to Li in view of Kronke et al., which has the cabinet within the housing.)
As to claim 18, the combination of Li and Kronke et al. renders obvious a rack within a housing (see the rejection to claim 1 for full details of the combination, incorporated herein but not reiterated herein for brevity’s sake), as Frutschy et al. render obvious a system using structures such as [1080A, 1080B, 1150]) to support the battery racks (i.e. portions that the batteries are stacked thereon) (figs. 10A, 10B, 11C), which are structures that constitute a ring around the battery rack. See the rejection to claim 1 for full details of the combination, incorporated herein but not reiterated for brevity’s sake. (Note: The combination would have the ring between a front wall and a rear wall of the anti-explosion housing, as it is applied to Li in view of Kronke et al., which has the cabinet within the housing.)
Note: Regarding the plurality of rings spaced a predetermined distance apart from each other, two interpretations are taken.
Interpretation 1: The teaching of Frutschy et al. is applied to each column of Kronke et al., yielding the claimed plurality.
Interpretation 2: Having a plurality is mere duplication of parts, which has been held by the office to be obvious. It has been held that mere duplication of the essential working parts of a device involves only routine skill in the art. St. Regis Paper Co. v. Bemis Co., 193 USPQ 8. Also see MPEP §2144.04(VI)(B).
As to claim 19, the combination renders the limitation obvious, as Kronke et al., relied upon to render obvious the rack (see the rejection to claim 1 for full details, incorporated herein but not reiterated herein for brevity’s sake) teaches a plurality of battery modules stacked on the at least one battery rack (each energy storage device [200] can be interpreted to be a module, or multiple energy storage devices [200] can constitute a module; see figs. 1, 4 for stacking with rack [201]; see also para 0027 and 0030).
As to claim 20, the combination renders the limitation obvious, as Kronke et al., relied upon to render obvious the rack (see the rejection to claim 1 for full details, incorporated herein but not reiterated herein for brevity’s sake), as the at least one battery rack comprises a rack case (wherein rack [201], as seen in figs. 1 and 4, can constitute a rack case barring specification regarding the structure of a rack case). Office personnel are to give claims their broadest reasonable interpretation in light of the supporting disclosure. In re Morris, 127 F.3d 1048, 1054-55, 44 USPQ2d 1023, 1027-28 (Fed. Cir. 1997). Also, limitations appearing in the specification but not recited in the claim are not read into the claim. See In re Zletz, 893F.2d 319, 321-22,13 USPQ2d, 1320, 1322 (Fed. Cir. 1989).
Claim(s) 8 is/are rejected under 35 U.S.C. 103 as being unpatentable over Li in view of Kronke et al., as applied to claims 1 and 6 above, further in view of US 2017/0012275 (Gouzin et al.).
As to claim 8, Li does not teach the first side cover and the second side cover include a thermal insulation panel positioned facing a respective side of the at least one battery rack.
However, Gouzin et al. teach a battery housing with walls [202, 203, 204, 205], wherein a first side cover and a second side cover (two opposing walls) include a thermal insulation panel (flexible insulating wall element [211], such as sueperwool) positioned facing a respective side of the at least one battery [104] (fig.2; para 0024-0025, 0028-0029). The motivation for providing a thermal insulation panel (flexible insulating wall element [211], such as superwool) to the side walls facing the battery is to prevent dielectric breakdown and to prevent short circuiting of the cell (para 0031, 0034). 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 provide a thermal insulation panel (such as superwool) to the side walls facing the battery (as taught by Gouzin et al., and as applied to Li in view of Park (a cabinet that faces a battery rack, rather than a battery)) is to prevent dielectric breakdown and to prevent short circuiting of the battery.
Claim(s) 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Li in view of Kronke et al., as applied to claims 1 and 6 above, further in view Gouzin et al., as applied to claim 8 above, as evidenced by “Morgan Advanced Materials: Superwool Prime Textiles Product data sheet” (Morgan).
As to claim 9, the combination renders obvious the claimed invention, as Gouzin et al., relied up to render obvious the thermal insulation panel teaches superwool (para 0029). See the rejection to claim 8 for full details of the combination, incorporated herein but not reiterated herein for brevity’s sake. At this point Morgan is relied upon to show that superwool is a glass wool (see p 1).
Claim(s) 12-13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Li in view of Kronke et al., as applied to claims 1 and 3 above, further in view of KR 102191291 (Seo et al.).
As to claim 12, Li teaches the rear cover includes: at least one rear panel (fig. 1) (positioned facing the rear side of the at least one battery rack, rendered obvious by the combination, as Park renders obvious the presence of a rack; see the rejection to claim 1 for full details of the combination incorporated herein but not reiterated herein for brevity’s sake).
Li in view of Park does not teach an air-conditioner provided in the at least one rear panel to control an amount of heat generated from the at least one battery rack in the anti-explosion housing.
However Seo teach an air-conditioner provided in the at least one rear panel to control an amount of heat generated from the at least one battery rack in the anti-explosion housing (discharge pipe [11] with its openings [11-4, 11-2], connected to the exhaust fan [11-3], opposite the door of a container; see fig. 12, wherein a single battery container can be seen in fig. 2; see also para 0101). The motivation for providing an air-conditioner provided in the at least one rear panel to control an amount of heat generated from the at least one battery rack in the anti-explosion housing is to us the air condition and exhaust as needed depending upon the situation – normal operation close the exhaust duct and open the air conditioning duct to circulate cool air; emergency when off-gas emission is detected, close the air conditioning duct to induce gas emission outside the battery room through the exhaust duct; sealing interior on signs of fire (dust/smoke/heat detection) (para 0102-104) – generally to prevent a fire and efficiently perform air conditioning (abs). 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 provide an air-conditioner provided in the at least one rear panel to control an amount of heat generated from the at least one battery rack in the anti-explosion housing is to use the air conditioner and exhaust as needed depending upon the situation, generally to prevent a fire and efficiently perform air conditioning.
As to claim 13, Li does not teach when an abnormal situation in the at least one battery rack occurs, the air-conditioner detects heat or smoke generated from the at least one battery rack and stops the operation of the at least one battery rack.
However, Seo et al. teaches closing the air conditioning duct to induce gas emission outside the battery room through the exhaust duct; sealing interior on signs of fire (dust/smoke/heat detection) (para 104) (constituting when an abnormal situation in the at least one battery rack occurs, the air-conditioner detects heat or smoke generated from the at least one battery rack and stops the operation of the at least one battery rack, as a abnormal (fire) situation is detected, and operation is stopped (via sealing the rack)). The motivation for acting such that when an abnormal situation in the at least one battery rack occurs, the air-conditioner detects heat or smoke generated from the at least one battery rack and stops the operation of the at least one battery rack is to use the air conditioner and exhaust as needed depending upon the situation, generally to prevent a fire and efficiently perform air conditioning (abs). 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 act such that when an abnormal situation in the at least one battery rack occurs, the air-conditioner detects heat or smoke generated from the at least one battery rack and stops the operation of the at least one battery rack, the air conditioner and exhaust are used as needed depending upon the situation, generally to prevent a fire and efficiently perform air conditioning.
Response to Arguments
Applicant's arguments filed March 9, 2026 have been fully considered but they are not persuasive.
Applicant argues that the claimed invention is drawn towards the guide pole [900] being part of the housing (showing fig. 4), while Frutschy’s guide pole is part of the cabinet.
Examiner respectfully disagrees. The rejection relies upon Kronke to render obvious the cabinet. Thus the argument that Frutschy’s teaching is the cabinet is not commensurate with the rejection and thus cannot be persuasive. Rather the guide pole of Frutschy is a separate portion from the cabinet, and thus can be considered to be part of the housing. Nothing in the claimed invention precludes the interpretation taken. 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 do not cure the deficiencies of the rejection applied to the independent claim. 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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/EUGENIA WANG/Primary Examiner, Art Unit 1759