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 .
Summary
The Applicant’s arguments and claim amendments received on July 20, 2026 have been entered into the file. Currently, claims 1 and 7-8 are amended; and claims 2-3, 10-13, and 17 are cancelled; resulting in claims 1, 4-9, and 14-16 pending for examination.
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.
The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention.
Claims 1, 4-9 and 14-16 are rejected under 35 U.S.C. 103 as being unpatentable over Kim, et al. (US 2014/0205889 A1), US equivalent to CN 103943808 A (cited on IDS), in view of Dudziak, et al. (EP 2 713 423).
Regarding claim 1, Kim teaches a battery module (100; assembly) including a plurality of battery cells (10; accumulators) aligned in a first direction (direction of connection) and each having respective first and second terminal portions (11 and 12) on a first surface (14; connection face) thereof (¶ [0040], Ln. 1-4; Fig. 2). Kim teaches that a terminal connection member (150; connection element) connects the terminal portions of first and second battery cells adjacent to each other (¶ [0040], Ln. 4-7). As shown in Figure 2, the first surfaces (14) of the battery cells extend in a plane parallel to the first direction and the terminal portions (11 and 12) protrude from the first surfaces along a thickness direction perpendicular to the first direction. Kim teaches that the terminal connection member may be made of aluminum (¶ [0046], Ln. 1-3) and includes a pair of contact portions (151; wings) and a support portion (152; central part) connecting the contact portions (¶ [0040], Ln. 8-12; Fig. 4A). The elongated part of the first contact portion is welded to first terminal portion and the elongated part of the second contact portion is welded to the second terminal portion (¶ [0024], Ln. 1-5). Shown in Figure 4A, the first contact portion and second contact portion (151) are welded to the lateral surfaces of the first terminal portion and second terminal portion (11 and 12), forming first and second contact surfaces. Also shown in Figure 4A, Kim teaches that the terminal connection member (150) is at the same level in the thickness direction as the first and second terminal portions (11 and 12).
Kim further teaches that the terminal connection member includes a c-shaped section (153) at the ends of the support portion (152), further teaching that the ends (153b) of the c-shaped section are connected perpendicular to the contact portion (151) at each corner of the terminal portions (11 and 12) (¶ [0045], Ln. 1-3, 12-18; Fig. 3). Kim teaches that the c-shaped section provides flexibility to the terminal connection member (150), improving contact between the terminal portions (11 and 12) and the terminal connection member and providing assembling tolerance (¶ [0046], Ln. 7-18). Additionally, Kim teaches that this orientation allows contact between the facing portions of the first and second terminal portions (11 and 12) and the contact portions (151) of the connection member through wide surfaces, which allows current to efficiently flow between the first and second battery cells (¶ [0049], Ln. 7-10). Kim does not expressly teach that the central part has a U-shape or V-shape in a view from a first transverse direction, that the contact portions include end-pieces fastened to a first and second leg of the U or V-shaped central part, or that the elongated parts of the first and second contact portions extend from the end-pieces along the first and second leg toward a base of the central part in a second transverse direction, wherein the elongated parts are spaced apart from the first and second leg of the U or V-shaped central part. Kim also does not expressly teach that a first extension of the first contact portion and a second extension of the second contact portion extend on the side opposite the U or V-shaped central part with respect to the contact portion and define first and second supplementary contact surfaces perpendicular to the first and second contact surfaces and which are welded to the first and second terminal portions.
Dudziak teaches a battery module including a first battery cell a second battery cell, and a connecting element, wherein the connecting element electrically connects the first battery cell to the second battery cell (¶ [0024], Ln. 1-4). Dudziak teaches that the connecting element is designed to be electrically connected to contact points of different battery cells (¶ [0011], Ln. 2-3). Shown in Figure 4, the connecting element also mechanically connects the contact points of the different battery cells and the connection is along a direction of connection. Dudziak teaches that the connecting element is punched in the desired shape from a metal sheet and, as shown in Figure 3, includes a second arch element (11; central part) and first arch elements (7; wings) (¶ [0012], Ln. 2-4). The connecting element has a welded connection to the battery cells (¶ [0032], Ln. 4-5). The second arch element (11; central part) of Figure 3 has the shape of the Greek letter omega (U-shape) (¶ [0045], Ln. 5-7) in a view perpendicular to the thickness direction and direction of connection. The first arch elements include a curvature (9; end-pieces) which connects them to the second arch element and the remaining portion of the first arch elements is the elongated part, which extends from the curvature (9; end-piece) along the outside of each leg of the omega-shape of the second arch element (11; central part) in a direction perpendicular to the direction of connection (Fig. 3). The elongated part is spaced apart from the legs of the U-shape of the second arch element along the direction of connection (Fig. 3, Fig. 4). Dudziak further teaches that the connecting element includes feet (3, 5; first and second extension) which, as shown in Figure 3, extend from the first arch elements (7; wings) on the side opposite the second arch element (11; central part). Dudziak teaches that the geometric shape provides sufficient flexibility to absorb forces acting on battery cells within the module without damaging the connecting points between battery cells (¶ [0008], Ln. 5-8), and compensates for manufacturing tolerances of individual battery cells (¶ [0009], Ln. 1-3).
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 terminal connection member of Kim to have first and second arch elements and feet as taught by Dudziak. It would be obvious to one of ordinary skill in the art that the connecting element of Dudziak performs the same function of electrically and mechanically connecting individual battery cells by their terminals. One would be motivated to include aspects of the cell connector of Dudziak in order to provide sufficient flexibility, as the shape makes the cell connector capable of absorbing forces acting on battery cells within the module without damaging the connecting points between battery cells and compensates for manufacturing tolerances of individual battery cells. In modifying the terminal connection member of Kim to include first and second art elements, the support portion (152) would include a U-shape similar to the second arch element of Dudziak. Thus, the contact portions (151) would have end-pieces connecting the elongated parts of the contact portions to the U-shaped support portion, and the elongated parts of the contact portions would extend from the end-pieces along the first and second leg of the U-shaped support portion toward a base of the central part in a second transverse direction and would be spaced apart from the first and second leg of the U-shaped central part. Given the teachings of Kim that the first contact portion and second contact portion (151) are welded to the lateral surfaces of the first terminal portion and second terminal portion (11 and 12) (Fig. 4A), and that the contact between the facing portions of the first and second terminal portions and the contact portions is completed through wide surfaces in order to allow current to efficiently flow between the first and second battery cells, one of ordinary skill in the art would find it obvious to maintain the contact between the contact portions (151) and the lateral surfaces of the first terminal portion and second terminal portion. Therefore, one of ordinary skill in the art would find it obvious to maintain the straight edges of the contact portions, such that they are parallel with the lateral surfaces of the terminal portions and contact the terminal portions through a wide surface.
In modifying the terminal connection member of Kim to include feet, the contact portions would include first and second extensions opposite the U-shaped support portion with respect to the first and second contact portions. Further, the feet would define a secondary contact surface perpendicular to the contact surface formed between the contact portions (151) and the lateral surfaces of the first terminal portion and second terminal portion. One of ordinary skill in the art would find it obvious to include feet to maintain the position of the terminal connection member and would find it obvious to position them at the end of the contact portions based on the orientation of the connecting element of Dudziak. Additionally, one of ordinary skill in the art would be motivated to include the feet such that they form a supplementary contact surface perpendicular to the contact surface formed between the contact portions (151) and the lateral surfaces of the first terminal portion and second terminal portion, as Kim teaches that contact completed through wide surfaces allows current to flow efficiently between battery cells.
Regarding claim 4, Kim in view of Dudziak teaches all of the limitations of claim 1 above and Kim further teaches that the connection member has symmetry with respect to a plane perpendicular to the direction of connection (Fig. 4A). Dudziak additionally teaches that the connecting element has symmetry with respect to a plane perpendicular to the direction of connection (Fig. 3, Fig. 4). Thus, the connection member of Kim in view of Dudziak would have symmetry with respect to a plane perpendicular to the direction of connection.
Regarding claim 5, Kim in view of Dudziak teaches all of the limitations of claim 1 above and Kim further teaches that the contact portions (151; wings) extend parallel to the second transverse direction, perpendicular to the thickness direction and direction of connection.
Regarding claim 6, Kim in view of Dudziak teaches all of the limitations of claim 1 above. As shown in Figure 3 of Dudziak, the second arch element (11; central part) extends towards the feet (3, 5; first and second extension). Dudziak does not expressly teach that the elongated parts of the first arch elements (7; wings) have, within 10%, the same extension as the second arch element in the direction perpendicular to the direction of connection (second transverse direction).
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 second arch element, forming the U-shape in the support portion of the connection member of Kim in view of Dudziak to extend within 10% of the extension of the contact portions (151; wings). The change in proportion would not impact the function of the connection member, as it would still provide a connection member with high flexibility. In a case where a device having the claimed relative dimensions would not perform differently than the prior art device, the claimed device is not patentably distinct from the prior art device (MPEP 2144.04 (IV)(A)).
Regarding claims 7-8 and 15, Kim in view of Dudziak teaches all of the limitations of claim 1 above. Dudziak further teaches that the first arch elements (7; wings) are curved, which allows the connecting element to be flexible (¶ [0025], Ln. 1-2). Although Dudziak does not expressly teach that the curvature (9; end-pieces) includes a chamfer, as the element is already curved, the curved section reads on the limitations of the chamfer. The curved section of the arch elements performs the same function as a chamfer in making the connecting element configured to be inserted.
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 connection member of Kim in view of Dudziak to include a curved portion where the elongated parts of the contact portions (151; wings) connect to the U-shaped central portion, reading on the claimed end-pieces, based on the teachings of Dudziak. Based on the teachings of Kim, one of ordinary skill in the art would maintain the straight edges of the contact portions, such that they are parallel with the lateral surfaces of the terminal portions and contact the terminal portions through a wide surface, however, the portion connecting the elongated parts of the contact portions may be curved in order to connect to the U-shaped central portion. One of ordinary skill in the art would be motivated to make this connecting part curved in order to allow for flexibility of the connection member and for easier insertion. Thus, each contact portion would include a curved section, reading on the limitations of the chamfer, configuring the connection member for insertion between the terminal portions. As shown in Figure 4A, the connection member is inserted between the terminal portions in the direction perpendicular to the direction of connection and in the thickness direction.
Regarding claim 9, Kim in view of Dudziak teaches all of the limitations of claim 1 above and Kim further teaches that the connection member is delimited in the first transverse direction by two surfaces perpendicular to the first transverse direction and formed by at least the contact portions and support portion.
Regarding claims 14 and 16, Kim in view of Dudziak teaches all of the limitations of claim 1 above and Kim further teaches that a gasket (15) made of an electrical insulation material is provided on the first surface (14) of the battery cells (¶ [0041], Ln. 14-16). Shown in Figure 1, the insulation is interposed between the first surface (14) of the battery cells and the connection member (150).
Response to Arguments
Response-Claim Objections
The previous objections of claims 2 and 7-8 over amendment status are overcome by Applicant’s cancellation of claim 2 and amendments to claims 7-8 in the response filed July 20, 2026.
Response-Claim Rejections – 35 U.S.C. 112
The previous rejection of claim 1, and by dependency claims 2, 4-9, and 14-16 under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention are overcome by the Applicant’s amendment to claim 1 in the response filed July 20, 2026.
Response-Claim Rejections – 35 U.S.C. 103
In light of the Applicant’s amendments to claim 1 to incorporate limitations of claim 2, the previous rejection of claim 1 under 35 U.S.C. 103 over Kim (US 2014/0205889 A1) in view of Dudziak, et al. (EP 2 713 423) has been modified above. Applicant's arguments filed July 20, 2026 have been fully considered but they are not persuasive. The Applicant argues that Kim does not describe a U-shaped or V-shaped central portion, nor a first extension and second extension defining additional contact surfaces that are also welded to the terminals and are perpendicular to the first contact surface and that modifying Kim in view of Dudziak would require dismantling the connector of Dudziak. The Applicant further argues that one of ordinary skill in the art would not be motivated to include the feet of Dudziak on the connection member of Kim. These arguments are not persuasive.
With respect to the argument that Kim does not teach the U-shaped or V-shaped central portion, nor a first extension and second extension defining additional contact surfaces that are also welded to the terminals and are perpendicular to the first contact surface, the teachings of Dudziak are relied upon to address these limitations. In response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
With respect to the argument that modifying Kim in view of Dudziak would require dismantling Dudziak and there is no motivation to do so, this argument is not persuasive. Dudziak teaches a connecting element that performs the same function as Kim of electrically and mechanically connecting individual battery cells by their terminals. The connecting element of Dudziak includes a second arch element (11; central part) having the shape of the Greek letter omega (U-shape), first arch elements (7; wings), and feet (3, 5; first and second extension) (¶ [0045], Ln. 5-7; Fig. 3). Dudziak teaches that this geometric shape provides sufficient flexibility to absorb forces acting on battery cells within the module without damaging the connecting points between battery cells (¶ [0008], Ln. 5-8) and compensates for manufacturing tolerances of individual battery cells (¶ [0009], Ln. 1-3). Therefore, one of ordinary skill in the art would be motivated to apply the geometric shape of the connecting element of Dudziak to the connection member of Kim in order to provide sufficient flexibility and compensate for manufacturing tolerances of individual battery cells. By including the geometric shape of the connecting element of Dudziak, the connecting member would include the U-shaped central portion in the support portion (152) and feet at the ends of contact portions (151). As Kim points out the benefit of contact between the facing portions of the first and second terminal portions (11 and 12) and the contact portions (151) of the connection member through wide surfaces (¶ [0049], Ln. 7-10), one of ordinary skill in the art would find it obvious to maintain the connection at the lateral surface of the contact portions (151) and the terminals (defining first and second contact surfaces) and would recognize that the inclusion of feet would serve to further increase the surface area of the contact between the terminals and connection member (defining supplementary contact surfaces). One of ordinary skill in the art would be motivated to make these modifications in order to allow current to efficiently flow between the first and second battery cells.
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 SARAH J JACOBSON whose telephone number is (703)756-1647. The examiner can normally be reached Monday - Friday 8:00am - 5:00pm.
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/SARAH J JACOBSON/Examiner, Art Unit 1785
/MARK RUTHKOSKY/Supervisory Patent Examiner, Art Unit 1785
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