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 .
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, 5, 13-15, and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Huo et al. (US PGPub 2023/0216103 A1) and further in view of Mastrandrea et al. (US PGPub 2018/0069280 A1).
Regarding Claims 1 and 20, Huo discloses in Fig. 1 battery cell system, comprising a cell module (100) ([0041]), comprising:
a cell fixing bracket (14) ([0053]);
a plurality of rows of cell groups, each row of cell group of the plurality of rows of cell groups comprises a plurality of cells (16), each row of cell group other than a first row of cell group and a last row of cell group has a first spacing H from an adjacent row of cell group, and has a second spacing h from another adjacent cell group, and the first spacing H is greater than the second spacing h ([0042],e.g. see annotated Fig. 1 provided below); and
a liquid cooling plate (22) disposed between two rows of the plurality of rows of cell groups spaced apart by the second spacing h, and configured to regulate temperature of a plurality of cells (16) near the liquid cooling plate (22) (Fig. 2, [0046], [0049]).
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Consequently, Huo does not disclose wherein the liquid cooling plate is disposed between two rows of the plurality of rows spaced apart by the first spacing H.
Though, Huo discloses wherein the arrangement of the plurality of rows of cell groups and the liquid cooling plate (22) is not particularly limited and may be spliced as required in order to achieve a battery cell system having a low cost, a simple assembling process, and a high assembling efficiency ([0048]).
Mastandrea teaches in Fig. 3 a cell module (300) comprising a plurality of rows of cell groups, each row cell group of the plurality rows of cell groups comprises a plurality of cells (310), each row of cell group other than a first row of cell group and a last row of cell group has a first spacing H from an adjacent row of cell group, and has a second spacing h from another adjacent cell group, and the first spacing H is greater than the second spacing h ([0040], see annotated Fig. 3 provided below); and a fluid cooling assembly (320) disposed between two rows of the plurality of rows of cell groups spaced apart by the first spacing H, and configured to regulate temperature of a plurality of cells (310) near the fluid cooling assembly (320) ([0041]-[0042]).
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It would have been obvious to one of ordinary skill in the art to modify the cell module of Huo such that the liquid cooling plate of Huo is disposed between two rows of the plurality of rows of cell groups of Huo spaced apart by the first spacing H, as taught by Mastandrea, as the arrangement of the plurality of rows of cell groups and the liquid cooling plate is not particularly limited and such is a known configuration in the art and therefore the skilled artisan would have reasonable expectation of successfully doing so in order to achieve a battery cell system having a low cost, a simple assembling process, and a high assembling efficiency, as desired by Huo.
Modified Huo further discloses:
wherein the cell fixing bracket (14 of Huo) comprises a plurality of bracket sets (e.g. 20 of Huo) arranged in a second direction Y, each of the plurality of bracket sets (e.g. 20 of Huo) comprises two adjacent bracket bodies arranged in the second direction Y, the two adjacent bracket bodies arranged in the second direction Y are detachably connected (Fig. 6, [0055] of Huo), each bracket body of two adjacent bracket bodies is provided with a plurality of mounting portions arranged in a first direction X, each of the plurality of mounting portions is configured to mount one cell (16 of Huo), and the second direction Y and the first direction X are set at an included angle (Figs. 1, 5-6 and [0053] of Huo, e.g. see mounting portions formed in the cell fixing bracket 14 in Figs. 13-14),
wherein a centerline of the plurality of mounting portions parallel to the first direction X is a first centerline b, and a centerline of each bracket body parallel to the first direction X is a second centerline a;
the first centerline b and the second centerline a are set at an internal; and
two first centerlines b of the mounting portions respectively disposed on the two adjacent bracket bodies of each bracket set (20 of Huo) are located on two sides of the two second centerlines a of the two adjacent bracket bodies (20 of Huo), respectively (e.g. see annotated Fig. 3 of Mastandrea provided below).
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Regarding Claim 5, modified Huo discloses all of the limitations as set forth above and further discloses wherein each of the plurality of mounting portions is a mounting groove, and an end portion of each of the plurality of cells (16 of Huo) is fixed in the mounting groove (Figs. 1, 5-6 and [0053] of Huo, e.g. see mounting grooves formed in the cell fixing bracket 14 in Figs. 13-14).
Regarding Claim 13, modified Huo discloses all of the limitations as set forth above and further discloses wherein the liquid cooling plate (22 of Huo) is in communication with a connecting tube (28 of Huo) (Figs. 2-4, [0049] of Huo).
Regarding Claim 14, modified Huo discloses all of the limitations as set forth above and further discloses wherein a number of the cell fixing brackets (14 of Huo) is two (58, 60 of Huo), and two end portions of each of the plurality of cells (16 of Huo) are connected in a one-to-one correspondence to two cell fixing brackets (14 of Huo) (Fig. 5, [0063]-[0065] of Huo).
Regarding Claim 15, modified Huo discloses all of the limitations as set forth above and further discloses wherein two end portions of each cell (16 of Huo) of the plurality of cells (16 of Huo) comprises a top end portion and a bottom end portion, the cell fixing bracket (14 of Huo), to which the top end portion of each cell (16 of Huo) is connected, is provided with, corresponding to each cell (16 of Huo), a first through hole (84 of Huo), and an electrode terminal (90 of Huo) of the top end portion of each cell (16 of Huo) protrudes out from the first through hole (84 of Huo) to be connected to a busbar (Fig. 1, 5 and [0073]-[0074] of Huo).
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Claims 6-8 and 11-12 are rejected under 35 U.S.C. 103 as being unpatentable over Huo et al. (US PGPub 2023/0216103 A1) in view of Mastrandrea et al. (US PGPub 2018/0069280 A1), as applied to Claim 1 above, and further in view of Zheng et al. (CN 206332064 U, cited on the IDS dated April 17, 2025, see also the previously provided EPO machine generated English translation).
Regarding Claim 6, modified Huo discloses all of the limitations as set forth above. However, modified Huo does not disclose wherein each bracket body comprises a plurality of splicing seats arranged in the first direction X, each two adjacent splicing seats are detachably connected, and each of the plurality of splicing seats is provided with one mounting portion.
Zheng teaches a cell fixing bracket that has good fastness, easy disassembly and installation, and can guarantee security when used in a cell module (P1, L17-19).
Specifically, Zheng teaches in Figs. 1-6 a cell fixing bracket (2) comprising a plurality of bracket bodies (3, 3), wherein each bracket body (3, 3) comprises a plurality of splicing seats (3) arranged in the first direction X, each two adjacent splicing seats (3) are detachably connected, and each of the plurality of splicing seats (3) is provided with one mounting portion (7) (P1, last paragraph-P2, paragraph 4).
It would have been obvious to one of ordinary skill in the art to form each bracket body of modified Huo to comprise a plurality of splicing seats arranged in the first direction X, wherein each two adjacent splicing seats are detachably connected and each of the plurality of splicing seats is provided with one mounting portion, as taught by Zheng, in order to form a cell fixing bracket that has good fastness, easy disassembly and installation, and can guarantee security when used in the cell module of modified Huo.
Regarding Claim 7, modified Huo discloses all of the limitations as set forth above and further discloses wherein each splicing seat of the plurality of splicing seat (3 of Zheng) is provided with an engaging portion (8, 9 of Zheng), and the two adjacent splicing seats (3 of Zheng) are engaged into each other through the engaging portions (8, 9 of Zheng) (Figs. 1-6 and P3, paragraph 5 of Zheng).
Regarding Claim 8, modified Huo discloses all of the limitations as set forth above and further discloses wherein each splicing seat (3 of Zheng) is of a regular prismatic structure, a sidewall on each side of each splicing seat (3 of Zheng) is provided with an engaging portion (8, 9 of Zheng), and two adjacent bracket bodies (3, 3 of Zheng) are engaged into each other through the engaging portions (8, 9 of Zheng) (Figs. 1-6 and P3, paragraph 5 of Zheng).
Regarding Claim 11, modified Huo discloses all of the limitations as set forth above and further discloses wherein each splicing seat (6 of Zheng) comprises:
a baseplate (4 of Zheng), wherein the baseplate (4 of Zheng) is a regular polygonal plate (Fig. 1, P1-2 bridging paragraph of Zheng); and
a plurality of side plates (6 of Zheng), wherein each side edge of the baseplate (4 of Zheng) is connected to a side plate (6 of Zheng) of the plurality of side plates (6 of Zheng), the baseplate (4 of Zheng) and the plurality of side plates (6 of Zheng) enclose to define the mounting groove (7 of Zheng), an end portion of each of the plurality of battery cells (16 of Huo, corresponding to 1 of Zheng) is disposed in the mounting groove (7 of Zheng), and each of the side plates (6 of Zheng) is provided with the engaging portion (8, 9 of Zheng) (Figs. 1-6 and P1, last paragraph-P2, paragraph 4 of Zheng).
Regarding Claim 12, modified Huo discloses all of the limitations as set forth above and further discloses wherein a number of the plurality of side plates (6 of Zheng) provided on each splicing seat (3 of Zheng) is an even number (Fig. 2 of Zheng, e.g. 4), and in oppositely disposed two side plates (6 of Zheng), the engaging portion (8, 9 of Zheng) is of a first side plate (6 of Zheng) is an engaging block (9 of Zheng), and the engaging portion (8, 9 of Zheng) of a second side plate (6 of Zheng) is an engaging groove (8 of Zheng) (Figs. 1-6 and P1, last paragraph-P2, paragraph 4 of Zheng).
Claim 9-10 are rejected under 35 U.S.C. 103 as being unpatentable over Huo et al. (US PGPub 2023/0216103 A1) in view of Mastrandrea et al. (US PGPub 2018/0069280 A1) and Zheng et al. (CN 206332064 U, cited on the IDS dated April 15, 2025, see also the previously provided EPO machine generated English translation), as applied to Claim 8, and further in view of Dai (CN 105226213 A, see also the previously provided EPO machine generated English translation).
Regarding Claim 9, modified Huo discloses all of the limitations as set forth above and further discloses wherein the cell fixing bracket that has good fastness, easy disassembly and installation, and can guarantee security when used in the cell module (P1, L17-19 of Zheng).
Specifically, modified Huo discloses wherein each splicing set (3 of Zheng) is a regular rectangular prismatic structure (Figs. 1-6 of Zheng) and consequently does not disclose wherein each splicing set is a rectangular hexagonal prismatic structure.
Dai teaches in Figs. 1-7 a cell fixing bracket comprising a plurality of splicing seats (10), wherein each splicing seat (10) is of a regular prismatic structure (P1, L15-7 and P2, L25-34).
Specifically, Dai teaches wherein a shape of the splicing seat (10) is not particularly limited so long as it is convenient to assemble, such as a square or a regular hexagon (P2, L35-37).
It would have been obvious to one of ordinary skill in the art to form each splicing seat of modified Huo to have a regular hexagonal prismatic structure, as taught by Dai, as such is a known configuration in the art that is convenient to assemble and therefore the skilled artisan would have reasonable expectation that such would successfully form a cell fixing bracket that has good fastness, easy disassembly and installation, and can guarantee security when used in the cell module of modified Huo, as desired by modified Huo
Regarding Claim 10, modified Huo discloses all of the limitations as set forth above and further discloses wherein the liquid cooling plate (22 of Huo) is a corrugated plate to allow the liquid cooling plate (22 of Huo) to cool each of the plurality of cells (16 of Huo) on two sides of the liquid cooling plate (22 of Huo) (Fig. 2, [0049]-[0050] of Huo).
Claims 16 and 19 are rejected under 35 U.S.C. 103 as being unpatentable over Huo et al. (US PGPub 2023/0216103 A1) in view of Mastrandrea et al. (US PGPub 2018/0069280 A1), as applied to Claims 1 and 15 above, and further in view of Koutari et al. (US PGPub 2020/0136110 A1).
Regarding Claim 16, modified Huo discloses all of the limitations as set forth above. However, modified Huo remains silent regarding the material of the cell fixing bracket and consequently does not disclose wherein such is made of an insulating material.
Koutari teaches in Fig. 1 a cell module (100) comprising a cell fixing bracket (2), wherein the cell fixing bracket (2) is made of a resin, such as thermoplastic resin which is an insulating material ([0032], [0037]).
Specifically, Koutari teaches wherein the cell fixing bracket (2) is preferably made of a resin excellent in flame-resistance and heat-resistance, such as polycarbonate, polypropylene, nylon, and the like ([0030]).
It would have been obvious to one of ordinary skill in the art to form the cell fixing bracket of modified Huo of polycarbonate, polypropylene, or nylon, as taught by Koutari, wherein such are insulating materials, in order to achieve a cell fixing bracket that is excellent in flame-resistance and heat-resistance.
The Examiner notes wherein the cell fixing bracket (14 of Hou) functions as a support ([0053] of Huo) and wherein the busbar is disposed on the cell fixing bracket (14 of Huo) (e.g. see annotated Fig. 1 of Hui provided below) and therefore modified Huo discloses wherein the cell fixing bracket (14 of Huo) supports the busbar.
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Regarding Claim 19, modified Huo discloses all of the limitations as set forth above and further discloses wherein two end portions of each cell (16 of Huo) of the plurality of cells (16 of Huo) comprise a top end portion and a bottom end portion (Fig. 1, 5 and [0073]-[0074] of Huo).
However, modified Huo does not disclose wherein, the cell fixing bracket, to which the bottom end portion of each cell is connected, is provided with, corresponding to the bottom end portion of each cell, a pressure relief chamber in communication with a mounting groove, and the cell fixing bracket to which the bottom end portion of each cell is connected, is further provided with a pressure relief hole in communication with the pressure relief chamber.
Koutari teaches in Fig. 1 a cell module (100) comprising a plurality of cells (1), wherein two end portions of each cell (1) of the plurality of cells (1) comprises a top end portion and a bottom end portion, wherein a cell fixing bracket (2), to which the bottom end portion of each cell (1) is connected, is provided with, corresponding to the bottom end portion of each cell (1), a pressure relief chamber (7) in communication with a mounting groove (e.g. see bottom portion of 2B), and the cell fixing bracket (2) to which the bottom end portion of each cell (1) is connected, is further provided with a pressure relief hole (6) in communication with the pressure relief chamber (7) in order to exhaust high-temperature and high-pressure discharge gas discharged from one of the plurality battery cells (1) when an internal pressure of one of the plurality of battery cells (1) becomes higher than a set pressure ([0035], [0042]).
It would have been obvious to one of ordinary skill in the art to form the cell fixing bracket of modified Huo to be provided with, corresponding to the bottom end portion of each cell of modified Huo, a pressure relief chamber in communication with the mounting groove of modified Huo, wherein the cell fixing bracket is further provided with a pressure relief hole in communication with the pressure relief chamber, as taught by Koutari, in order to exhaust high-temperature and high-pressure discharge gas discharged from the plurality battery cells of modified Huo when an internal pressure of one of the plurality of battery cells becomes higher than a set pressure.
Claims 17-18 are rejected under 35 U.S.C. 103 as being unpatentable over Huo et al. (US PGPub 2023/0216103 A1) in view of Mastrandrea et al. (US PGPub 2018/0069280 A1) and Koutari et al. (US PGPub 2020/0136110 A1), as applied to Claim 16 above, and further in view of Kwag et al. (US PGPub 2021/0075077 A1).
Regarding Claim 17, modified Huo discloses all of the limitations as set forth above. However, modified Huo does not disclose wherein the cell fixing bracket, to which the top end portion of each cell is connected, is provided with a flange around the first through hole, and the flange is configured to support the busbar.
Kwag teaches I Figs. 1-3 a cell module comprising a cell fixing bracket (110, 120) and a plurality of cells (10), wherein two end portions of each cell (10) of the plurality of cells (10) comprises a top end portion (11) and a bottom end portion (12), the cell fixing bracket (110, 120), to which the top end portion (11) of each cell (1) is connected, is provided with, corresponding to each cell (10), a first through hole (115), and an electrode terminal (11) of the top end portion (11) of each cell (1) protrudes out from the first through hole (115) to be connected to a busbar (B) ([0055]-[0057], [0059], [0065]).
Specifically, Kwag teaches wherein the cell fixing bracket (110, 120), to which the top end portion (11) of each cell (10) is connected, is provided with a flange (S) around the first through hole (115), and the flange (S) is configured to support the busbar (B) ([0089]).
It would have been obvious to one of ordinary skill in the art to form the cell fixing bracket of modified Huo, to which the top end portion of each cell of modified Huo is connected, to be provided with a flange around the first through hole of modified Huo, as taught by Kwag, in order to support the busbar of modified Huo.
Regarding Claim 18, modified Huo discloses all of the limitations as set forth above and further discloses wherein the flange (S of Kwag) is provided with a positioning column (Sb of Kwag), and the positioning column (Sb of Kwag) is configured to fix the busbar ([0091] of Kwag).
Response to Arguments
Applicant's arguments filed April 2, 2026 have been fully considered but they are not persuasive.
Regarding amended Claim 1, the Applicant argues that modified Huo does not disclose the specific relationship between the centerlines as claimed. However, the Examiner asserts that modifying Huo to include such a centerline arrangement would be a mere “design choice” based on the desired splicing of the cell module. The Applicant disagrees. In the present invention, the claimed specific arrangement of the first centerline b and the second centerline a (i.e. the specific offset and coinciding relationships) provide a unique structural solution to achieve the alternating spacings H and h with high precision. By utilizing this specific “eccentric/offset” structure, the present invention inherently forms the required larger spacing H for accommodating the liquid cooling plate and the smaller spacing h for compact arrangement without requiring any moving parts or external compression forces.
The Examiner respectfully disagrees and notes that that condition (i) was met by the cell module of modified Huo (e.g. see annotated Fig. 3 of Mastandrea provided with the rejection set forth above) while condition (ii) was rendered obvious by design choice rationale.
The Examiner further notes that Claim 1 has been amended to include the limitations of previous Claims 2-4, which require the first center b and the second centerline a to satisfy one of the following conditions: (i) wherein the first centerline b and the second centerline a are set at an interval; and (ii) wherein the first centerline b and the second centerline a coincide and therefore modified Huo reads on the claimed invention.
In other words, the configuration that was rendered obvious by the design choice rationale is not inherently required by the claimed invention.
The Examiner suggests that the Applicant could cancel condition (i) from Claim 1 in order to make the arguments commensurate with the scope of the claims.
The Applicant further argues that the proposed combination of Huo and Mastrandrea is improper because their physical mechanisms are fundamentally incompatible. Huo discloses a rigid fixing bracket where the battery cells are fixed in place (e.g., using rigid snap blocks). Once assembled, the spacing between the cells in Huo is statically fixed. In contrast, Mastrandrea relies on a dynamic compression mechanism to form the spacing ([0049]-[0050]). If one of ordinary skill in the art were to incorporate Mastandrea’s alternating spacing concept into Huo, they would have to abandon Huo’s rigid, snap-block design and instead adopt a sliding mechanism with external lateral forces. Such a modification would destroy Huo’s intended principle of operation.
The Examiner respectfully disagrees and notes that, as set forth above, Mastandrea was relied on to teach a known configuration in the art for spacing cells relative to a liquid cooling plate in a cell module.
In other words, Mastandrea has not been relied on to teach a modification to actual fixing mechanism (e.g., the rigid, static snap-block design) of Huo and therefore the arguments directed to such unpersuasive.
Thus, the Applicant’s arguments are not found to be persuasive.
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 KIMBERLY WYLUDA whose telephone number is (571)272-4381. The examiner can normally be reached Monday-Thursday 7 AM - 3 PM EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, BASIA RIDLEY can be reached at (571)272-1453. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/KIMBERLY WYLUDA/Primary Examiner, Art Unit 1725
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