Prosecution Insights
Last updated: April 19, 2026
Application No. 18/021,058

Electric Battery Assembly

Non-Final OA §103§112
Filed
Feb 13, 2023
Examiner
KRONE, TAYLOR HARRISON
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Lina Energy Ltd.
OA Round
1 (Non-Final)
65%
Grant Probability
Favorable
1-2
OA Rounds
3y 8m
To Grant
99%
With Interview

Examiner Intelligence

Grants 65% — above average
65%
Career Allow Rate
53 granted / 81 resolved
At TC average
Strong +52% interview lift
Without
With
+51.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
27 currently pending
Career history
108
Total Applications
across all art units

Statute-Specific Performance

§103
66.2%
+26.2% vs TC avg
§102
11.5%
-28.5% vs TC avg
§112
17.1%
-22.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 81 resolved cases

Office Action

§103 §112
DETAILED ACTION Claim Objections Claims 2-15 are objected to because of the following informalities: Each line 1 of claims 2-15, respectively, should recite “the electric battery assembly”. Line 4 of claim 2 should recite “electrically connected in series”. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claim 2 is rejected 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. Claim 2 recites the limitation "each cell has a case" in lines 2-3. There is insufficient antecedent basis for this limitation in the claim. Claim 2 should be amended to clarify that each cell having a metal case, as claimed in claim 1, includes the structure recited in claim 2, wherein the metal case of each cell includes opposed faces with opposite polarity. 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. 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. Claims 1-8 and 11-15 are rejected under 35 U.S.C. 103 as being unpatentable over WO 2019073260 A1 (Dawson ‘916 – citing to US 20200243916 A1 for paragraph citations) in view of US 20160365612 A1 (Bradwell ‘612). Regarding claim 1, Dawson ‘916 teaches an electric battery assembly (a battery 40; [0033] & Fig. 3) that comprises a multiplicity of cells (multiple cells 20; [0033] & Fig. 3) that operate at an elevated temperature (for the cell 20 to operate, it must be heated to a temperature above 157°C, such as 200°C; [0023]; corresponding to the modified type of ZEBRA cells described in [0004] of the PG Pub for this application – US 20230307744 A1), each cell having a metal case (the cell 20 comprises a stainless steel can 28; [0021] – [0022]) with a projecting flange (each cell has a projecting tab 26; [0033] & Fig. 3), the cells being arranged in at least one stack (the multiple cells 22 are electrically connected in series in a stack; [0033] & Fig. 3), and the assembly comprising at least one generally rectangular frame that defines a rectangular aperture to locate at least one stack of cells (the cells 20 are enclosed within a layer 48 of electrical and thermal insulation, the shape of the battery 40 being generally rectangular, wherein the layer 48 is defined to house the stack of cells 20; [0033] & Fig. 3). Dawson ‘916 discloses that the projecting tabs 26 are thinner than the remainder of the stainless steel can 28, wherein the projecting tabs 26 would be adjacent to a wall of the layer 48 of electrical and thermal insulation as shown in Fig. 3 when fully enclosed with gaps present between the projecting tabs 26 of adjacent cells 20 ([0033]). PNG media_image1.png 1006 632 media_image1.png Greyscale However, Dawson ‘916 does not disclose that the assembly also includes a pump to pass heat transfer fluid through each frame, so that the heat transfer fluid flows through the gaps between the flanges of the cells adjacent to the wall of the frame. Bradwell ‘612 discloses an energy storage system that includes providing a thermal management fluid to or from the energy storage system, wherein the thermal management fluid may be provided to (e.g., contacted with) the energy storage system as well as other portions of the system (e.g., a storage reservoir, condenser or other component of the system) ([0004]). For example, the thermal management fluid can flow through a frame of the energy storage system to maintain the system at an operating temperature ([0004]). The energy storage system can further include a fluid flow system that is configured and arranged to direct the thermal management fluid through one or more fluid flow paths of the frame ([0164]). The fluid flow system can include a pump, a fan, a blow, and/or any other suitable device for moving the thermal management fluid ([0164]). The energy storage system may comprise a plurality of electrochemical cells supported by a frame structure, wherein the frame structure comprises one or more fluid flow paths for bringing a thermal management fluid in thermal communication with at least a subset of the plurality of electrochemical cells ([0014]). Each battery 300 may comprises a housing 301, an electrically conductive feed-through (i.e., conductor, such as a conductor rod) 302 that passes through an aperture in the housing 301 ([0099] & Fig. 3). The battery 300 may comprise two or more conductors passing through one or more apertures in electrical communication with the liquid metal negative electrode 303 contained therein ([0100]). The housing 301 can be constructed from an electrically conductive material such as, for example, steel, iron, stainless steel, etc. ([0101]). Therefore, it would have been obvious to a person of ordinary skill in the art, prior to the effective filing date of the claimed invention, to modify the battery assembly, as taught by Dawson ‘916, to provide a fluid flow system with the frame structure that includes a pump for moving a thermal management fluid through the frame structure that contacts the plurality of cells therein, to maintain the battery assembly at an operating temperature, as suggested by Bradwell ‘612. PNG media_image2.png 2062 1738 media_image2.png Greyscale Regarding claim 2, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, wherein each cell has a case having opposed faces with opposite polarity, so that cells can be stacked directly in contact with each other, all with the same orientation, with all the cells of the stack being electrically connected in series (cells stacked vertically in series can be attached through a direct electrical connection; [0129] of Bradwell ‘612; see Fig. 1 and Fig. 6 of Bradwell ‘612 below showing a plurality of cells stacked with opposing faces in direct contact with each other, all with the same orientation). Regarding claim 3, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, wherein the heat transfer fluid does not undergo a phase change in the temperature range between ambient temperature and the operating temperature of the cells (the thermal management fluid may be air; [0006] of Bradwell ‘612; corresponding to the heat transfer fluid being air in [0010] of the PG Pub of this application). The selection of a known material, which is based upon its suitability for the intended use, is within the ambit of one of ordinary skill in the art. See In re Leshin, 125 USPQ 416 (CCPA 1960) (see MPEP § 2144.07). Regarding claim 4, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, also comprising a heater to heat the heat transfer fluid, for raising the temperature of the cells (in some cases, heat can be added to the system using heaters to keep the system above a minimum operating temperature during periods of resting and/or low intensity operation; [0149] of Bradwell ‘612). Regarding claim 5, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, wherein the heat transfer fluid is air (the thermal management fluid may be air; [0006] of Bradwell ‘612). Regarding claim 6, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, wherein each stack of cells is provided with endplates, each endplate incorporating at least one electrical contact (a cell pack 500 comprising 3 modules 505, wherein the modules are held in place with cell pack framing 515 that includes a top component of the frame 520, wherein the cells are stacked directly on top of each other with the negative terminal of one cell 525 contacted directly with the housing of another cell, wherein the top layer of cells is contacted to a negative busbar 535, corresponding to an endplate with at least one electrical contact, wherein more than one busbar may be used to provide pack-level electrical connections/interconnections; [0120], [0131], & Fig. 5 of Bradwell ‘612). Regarding claim 7, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, wherein each frame is an insulating frame of a thermally insulating material (the cells 20 are enclosed within a layer 48 of electrical and thermal insulation, the shape of the battery 40 being generally rectangular, wherein the layer 48 is defined to house the stack of cells 20; [0033] & Fig. 3 of Dawson ‘916; the system can be insulated, PNG media_image1.png 1006 632 media_image1.png Greyscale wherein thermal insulation surrounds the frame; [0160] of Bradwell ‘612). Regarding claim 8, Dawson ‘916 teaches the electric battery assembly as claimed in claim 7, wherein the wall of each insulating frame defines a recess or a wide groove open at one end but closed at the other end on two walls of the frame, the recess or wide groove locating edges of the cell stack, and the closed end of the recess preventing the stack from passing right through the insulating frame (the stack of cells 20 are enclosed within a recess defined by a layer 48 of electrical and thermal insulation, the shape of the battery 40 being generally rectangular; [0033] & Fig. 3 of Dawson ‘916; further, the layer 48 accommodates the stack of cells 20 within the recess formed by the layer 48, including the edges at the sides of the stack of cells 20, wherein the recess is closed at the bottom by the layer 48, and the stack of cells 20 would not pass through the insulating layer 48 of the battery 40; Fig. 3 of Dawson ‘916). Regarding claim 11, Dawson ‘916 teaches the electric battery assembly as claimed in claim 1, wherein the at least one frame is a metal frame adapted to enclose a plurality of stacks of cells, the stacks being arranged side by side (as shown in Fig. 5, the frame may include a plurality of stacks of cells 530, wherein the stacks are arranged side by side; [0120]; further cell pack framing (also “frame” herein) may be stainless steel; [0158] of Bradwell ‘612). Regarding claim 12, Dawson ‘916 teaches the electric battery assembly as claimed in claim 11, wherein the at least one frame is also provided with a pump for the heat transfer fluid (the fluid flow system can include a pump for moving the thermal management fluid; [0164] of Bradwell ‘612). Regarding claim 13, Dawson ‘916 teaches the electric battery assembly comprising a multiplicity of battery assemblies as claimed in claim 12, comprising a multiplicity of frames arranged to form a plurality of stacks of frames, wherein each frame encloses a plurality of stacks of cells, the stacks of cells being arranged side by side, and each frame is provide with a pump (the fluid flow system can include multiples pumps for moving the thermal management fluid through separate fluid flow channels or paths, for example, a pump can be provided for each separate fluid flow path of the four separate frames or quadrants of stacks of cells shown in Figs. 7 & 10; [0164] of Bradwell ‘612). Regarding claim 14, Dawson ‘916 teaches the electric battery assembly as claimed in claim 13, also comprising a thermally insulating chamber that defines a first space adjacent to one end of each frame (the system may include ducting 10005 that can be located between groups of electrochemical cells 1010 (e.g., enclosed by a frame) for passing thermal management fluid therethrough; [0162] & Fig. 10; thermal insulation inside of a fluid flow channel can provide thermal insulation between the thermal transfer fluid and one or more structural portions of the fluid flow channel; [0160] of Bradwell ‘612), a second space adjacent to the opposite end of each frame (four separate ducts 1005 are shown in Fig. 10 of Bradwell ‘612), a seal structure to inhibit flow outside the frames of the heat transfer fluid between the first space and the second space (in some cases, the thermal management fluid may flow through distinct thermal flow paths, each in communication with one or more distinct openings, separating the fluid in each path, and thus, enabling the system to separately control fluid flow rate through each path; [0157] of Bradwell ‘612), and ports for the heat transfer fluid communicating with the first space and the second space (the fluid may be moved through multiple fluid flow paths that are in fluid communication with each other; [0164] of Bradwell ‘612). Regarding claim 15, Dawson ‘916 teaches the electric battery assembly as claimed in claim 12, wherein each frame also comprises a thermal sensor, and the pump associated with a frame is controlled in response to measurements from the thermal sensor associated with that frame (one or more temperature sensors may be placed in the hot zone of the system and may provide measurement data to the computer system outside of the hot zone, wherein the temperature sensors can be in electronic communication with, for example, the computer processor to control the pump; [0028] & [0190] of Bradwell ‘612). Claims 9 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over WO 2019073260 A1 (Dawson ‘916 – citing to US 20200243916 A1 for paragraph citations) in view of US 20160365612 A1 (Bradwell ‘612), and further in view of US 20130323551 A1 (Lee ‘551). Regarding claim 9, Dawson ‘916 teaches the electric battery assembly as claimed in claim 7, but does disclose that the battery assembly is modular, comprising a plurality of battery modules, each battery module comprising a stack of the cells located within one such rectangular insulating frame, with the flanges of the cells in the stack adjacent to a wall of the insulating frame. Lee ‘551 discloses an apparatus for cooling a power storage device, i.e., cooling apparatus 1000, which includes a housing 200, a circulation driving module 300, an exhaust duct 400, and stack 500 formed by layering a plurality of battery pack containers 100 in which battery packs 10 are provided ([0046] & Fig. 1). The battery pack 10 includes a plurality of secondary electric cells ([0047]). Each battery pack container 100 may include one or more battery packs 10, wherein ([0048] & Fig. 2). The battery pack container 100 includes first and second side plates 110, 111, upper frames 130, lower frames 140, and a top plate 150 ([0055] & Fig. 2). The battery pack container and an apparatus for cooling a power storage battery pack allow a plurality of power storage battery packs to have a suitable structure for an air conditioning system and to be easily layered in a stack ([0027]). Therefore, it would have been obvious to a person of ordinary skill in the art, prior to the effective filing date of the claimed invention, to provide that the battery assembly, as taught by Dawson ‘916, comprises a plurality of battery containers, each battery container comprising a stack of cells therein (the cells having the claimed flanges taught by Dawson ‘916 and Bradwell ‘612), wherein the flanges of the cells contained therein are adjacent to a wall of the container, as suggested by Lee ‘551, to provide a suitable structure for an air conditioning system and to be easily layered in a stack. PNG media_image3.png 450 334 media_image3.png Greyscale Regarding claim 10, Dawson ‘916 teaches the electric battery assembly as claimed in claim 9, wherein the insulating frames of adjacent battery modules are shaped to fit together, and to be combined with a module that incorporates a pump for a heat transfer fluid (as shown in Fig. 4 of Lee ‘551, the adjacent battery containers 100 are shaped to fit together, because the uneven structures of the lower frames 141, 143 included in a first battery pack container 100-1 is mutually coupled to the uneven structures 153 of the top portion of the top plate 150, wherein the upper frames 131, 133 included in a second battery pack container 100-2 are coupled to the uneven structure 151 of the bottom portion of the top plate 150, and thus, the battery pack containers 100 are vertically layered to form the stack 500, as shown in Fig. 5; [0070] of Lee ‘551). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to TAYLOR H KRONE whose telephone number is (571)270-5064. The examiner can normally be reached Monday through Friday from 9:00 AM - 6:00 PM EST. 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, NICOLE BUIE-HATCHER can be reached at 571-270-3879. 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. /TAYLOR HARRISON KRONE/Examiner, Art Unit 1725 /NICOLE M. BUIE-HATCHER/Supervisory Patent Examiner, Art Unit 1725
Read full office action

Prosecution Timeline

Feb 13, 2023
Application Filed
Jan 08, 2026
Non-Final Rejection — §103, §112 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
65%
Grant Probability
99%
With Interview (+51.7%)
3y 8m
Median Time to Grant
Low
PTA Risk
Based on 81 resolved cases by this examiner. Grant probability derived from career allow rate.

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