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 § 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.
Claims 1-14 are 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.
With regard to independent claim 1, the limitation “a first venting-preventing part having an arrow shape or a block shape” is indefinite, as such types of shapes to be interpreted as shaped like an “arrow” or a “block” are unclear since these shapes (in particular the “block” shape) embody substantially broad coverage so as to be not limited to those particular shapes (310P) shown in applicants’ Figures 8 and 9. Since claims 2-14 depend from independent claim 1, these claims are rejected under 35 USC 112(b) for the same reason. Correction and clarification are required.
With regard to claim 10, the limitation “a second venting-preventing part having an arrow shape or a block shape” is indefinite, as such types of shapes to be interpreted as shaped like an “arrow” or a “block” are unclear since these shapes (in particular the “block” shape) embody substantially broad coverage so as to be not limited to those particular shapes (320P) shown in applicants’ Figure 14. Correction and clarification are required.
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.
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.
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.
Claims 1-4, 6, 7, 10, 11, and 14 are rejected under 35 U.S.C. 103 as being unpatentable over KR 2020-0061909 A, of which a complete copy of the Korean document with an English abstract was provided with the Information Disclosure Statement dated February 15, 2023, and with a machine translation provided with the Office Action mailed August 11, 2025.
Regarding independent claim 1 and claim 14, KR ‘909 discloses a battery pack for a battery module (abstract; pages 2-7 of translation under the heading DESCRIPTION-OF-EMBODIMENTS; and Figures 3-16), in which the battery module (1000) includes the following structural features:
a battery cell stack (105) comprising a plurality of battery cells (100), wherein each of the plurality of battery cells (100) comprises a pair of electrode leads (160) protruding in opposite directions (see Figures 4, 6, and 12-15);
a housing that includes a bottom, four side walls, and a top cover (400) for enclosing the battery cell stack (105) (see Figures 4, 5, and 13-15); and
a first busbar frame (500) arranged on a first surface of the battery cell stack (105) in a first protruding direction of the electrode leads (160), as shown in Figures 3-5 and 13-15.
Whether or not KR ’909 explicitly discloses that the first busbar frame (500) comprises a first venting-preventing part that protrudes between the electrode leads (160) of adjacent battery cells (100) of the plurality of battery cells (100) (see Figures 3-5 and 13-16), one of ordinary skill in the art would have recognized the desirability of providing such structural features (including a plurality of path guiders (260) and a corresponding number of lead slots (510) formed in the first busbar frame (500), as disclosed by KR ‘909 in Figure 16) to provide partitioned separation of electrode leads (160) of adjacent battery cells (100) in the first busbar frame (500) while improving control of ventilation and cooling of the battery pack (see abstract). Also, the first busbar frame (500) shown in Figure 16 of KR ‘909 includes solid structures that would be operable to restrict discharge of gas as a “venting-preventing part”. Although not explicitly named as such, the first busbar frame (500) of Figure 16 includes structures (defined at least in part by “path guiders (260)” adjacent the first busbar frame (500) – in referring to the 3rd, 4th, and 5th full paragraphs on page 7 of the translation under the heading DESCRIPTION-OF-EMBODIMENTS) that would be considered as a “block shape” configured to restrict discharge of gas, since the first busbar frame is a solid surface of plate-shape that would be substantially impermeable to gas flow, thus restricting discharge of gas. Moreover, it would have been obvious to one of ordinary skill in the art to modify the structure of the newly claimed “arrow shape” or “block shape”, since modification of shape is merely a design choice. In the absence of persuasive evidence to the contrary, any change in shape is merely a matter of choice which a person of ordinary skill in the art would have found obvious. See MPEP 2144.04(IV)(B) and referring to In re Dailey, 357 F.2d 669, 149 USPQ 7 (CCPA 1966).
Regarding claims 2 and 3, and in referring to the rejection of independent claim 1 above, KR ‘909 discloses that the first venting-preventing part fills a space between corresponding electrode leads (160) of adjacent battery cells (100), in which the first busbar frame (500) comprises a cushioning member (compression pad (200)) attached to a surface of the first venting-preventing part facing the battery cell stack (105), as shown in Figures 3-5 and 13-15.
Regarding claim 4, KR ‘909 discloses that the first busbar frame (500) further comprises at least one of a busbar, a terminal busbar, and a module connector mounted on the first busbar frame (500), as shown in Figures 3-5 and 13-16 (see the 2nd paragraph on page 4 of the translation).
Regarding claim 6, KR ‘909 discloses that the battery module (1000) further comprises a second busbar frame arranged on a second (opposite) surface of the battery cell stack (105), wherein the second surface is in a second protruding direction of the electrode leads (160), and the second protruding direction is opposite to the first protruding direction of the electrode leads (160), as shown in Figures 4, 5, and 13-16.
Regarding claims 7 and 11, and in referring to the rejection of claim 6 above, KR ‘909 discloses that the second busbar frame would also comprise at least one of a busbar, a terminal busbar, and a module connector mounted on the second busbar frame (see the 2nd paragraph on page 4 of the translation; and Figures 4, 5, and 13-16).
Regarding claim 10, and in referring to the rejection of independent claim 1 above and in view of the rejection of claim 6 above, KR ‘909 discloses that the second busbar frame comprises a second venting-preventing part (which would be configured in a similar manner as that of the first venting-preventing part) that protrudes in a direction between the electrode leads (160) of adjacent battery cells (100) of the plurality of battery cells (100), as shown in Figures 4, 5, and 13-16. Moreover, it would have been obvious to one of ordinary skill in the art to modify the structure of the newly claimed “arrow shape” or “block shape”, since modification of shape is merely a design choice. In the absence of persuasive evidence to the contrary, any change in shape is merely a matter of choice which a person of ordinary skill in the art would have found obvious. See MPEP 2144.04(IV)(B) and referring to In re Dailey, 357 F.2d 669, 149 USPQ 7 (CCPA 1966).
Claims 5, 8, 9, and 12 are rejected under 35 U.S.C. 103 as being unpatentable over KR 2020-0061909 A, and further in view of US 2019/0131596, cited in the Information Disclosure Statement dated February 15, 2023.
Regarding claims 5, 8, 9, and 12, KR ‘909 discloses/suggests the features of independent claim 1 and claims 4, 6, 7, 10, and 11 above, and further including that the battery module (1000) further comprises the first busbar frame (500) and a second busbar frame arranged on a second (opposite) surface of the battery cell stack (105), but does not explicitly disclose that first and second end plates covering respective first and second busbar frames are joined to the housing and comprise respective openings (including a hole operable for venting in the second end plate) where at least one of a terminal busbar and a module connector is exposed.
However, US ‘596 discloses a battery module (see abstract; paragraphs [0041], [0042], [0079], [0094]-[0096], [0101], [0106], and [0107]; and Figures 3, 4, and 24-27), in which the battery module (30) includes first and second end plates (160,162) that cover busbar frames at both ends of the battery module (30), as shown in Figures 3 and 4, wherein the first and second end plates (160,162) include respective openings (1150,1250) shown in Figures 24-27 that would be operable to not only expose at least one of a terminal busbar and a module connector, but would also serve as openings/holes to vent excess pressure (or otherwise provide equalized pressure on both sides of each opening/hole), in which these additional features are advantageous for more securely enclosing components of the battery module while facilitating feeding of electrical connectors and obtaining compact assembly thereof (abstract; and paragraphs [0041] and [0096]).
Therefore, it would have been obvious to one of ordinary skill in the art at the time the applicants’ invention was made to modify the battery module, as disclosed by KR ‘909, by further including first and second end plates covering respective first and second busbar frames, wherein the first and second end plates are joined to the housing and comprise respective openings (including a hole operable for venting and equalizing pressure on both sides of the second end plate) where at least one of a terminal busbar and a module connector is exposed, as taught by US ‘596, in order to more securely enclose components of the battery module while facilitating feeding of electrical connectors and obtaining compact assembly thereof (US ‘596; abstract; and paragraphs [0041] and [0096]).
Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over KR 2020-0061909 A, and further in view of KR 10-2091770 B1, of which a complete copy of the Korean document with an English abstract was provided with the Information Disclosure Statement dated February 15, 2023, and with a machine translation provided with the Office Action mailed August 11, 2025.
Regarding claim 13, KR ‘909 discloses/suggests the features of independent claim 1 above, but does not explicitly disclose a gas discharge port on an upper surface of the housing of the battery module.
However, KR ‘770 discloses a battery module (abstract; pages 2-5 of translation under the heading DESCRIPTION-OF-EMBODIMENTS; and Figures 1, 2, 5, and 6), in which the battery module (10) includes a housing in the form of a module case (200) that define gas outlets (255) and discharge openings (315) forming respective gas discharge ports, wherein the gas discharge ports are advantageous for increasing safety of the battery module by facilitating control of pressure within the module case, thus reducing the risk of high pressure and potential explosion (see pages 4 and 5 of translation beginning with “Referring to FIG. 6”). With regard to the location of the gas discharge port, selection of location would be limited to an upper surface or any of the four side surfaces, such that one of ordinary skill in the art would have found such a selection to be obvious to try with a finite number of predictable solutions under a reasonable expectation of success, for the purpose of further increasing safety of the battery module by facilitating control of pressure within the module case, thus reducing the risk of high pressure and potential explosion (see pages 4 and 5 of translation beginning with the paragraph starting with “Referring to FIG. 6”).
Therefore, it would have been obvious to one of ordinary skill in the art at the time the applicants’ invention was made to modify the battery module, as disclosed by KR ‘909, by using a gas discharge port on one or both of an upper surface and/or side surfaces of the housing of the battery module, as disclosed/suggested by KR ‘770, in order to further increase safety of the battery module by facilitating control of pressure within the module case, thus reducing the risk of high pressure and potential explosion (see KR ‘770 on pages 4 and 5 of translation beginning with the paragraph starting with “Referring to FIG. 6”).
Response to Arguments
The examiner acknowledges the applicants’ amendment received by the USPTO on October 27, 2025. Also, an Information Disclosure Statement dated September 30, 2025 has been considered and initialed, and a copy is provided with this Office Action. The amendments to the specification overcome the prior objection to the drawings. Although the amendments to the claims overcome the prior objections and 35 USC 112(b) rejections, new 35 USC 112(b) rejections are applied to claims 1 and 10. Claims 1-14 remain under consideration in the application.
Applicants' arguments filed October 27, 2025 have been fully considered but they are not persuasive.
With regard to the applicants’ remarks/arguments on pages 7-9 of the amendment, it is first noted that the newly underlined portions in the 35 USC 103 rejection of independent claim 1 (in view of KR ‘909 as the sole reference in section 6) address a substantial portion of the applicants’ arguments. In the last two paragraphs on page 8 and in the first two paragraphs on page 9 of the REMARKS section, the applicants argue that the path guiders (260) and lead slots (510) of KR ‘909 “serve an entirely different function” than “the first venting-preventing part” of claim 1. Although the examiner does not disagree with this statement, these structures ((260) and (510)) provided adjacent the first busbar frame (500) would not only be considered as a “block shape” configured to restrict discharge of gas, but the first busbar frame (500) would also provide a solid surface of plate-shape that would be substantially impermeable to gas flow, thus restricting discharge of gas (in also referring to the newly underlined portions in the 35 USC 103 rejection above).
In response to applicants' arguments that the teachings of KR ‘909 “serve an entirely different function” than “the first venting-preventing part” of claim 1, that “KR ‘909’s primary concern is preventing contact between electrode leads and cell terrace edges to avoid “cell life degradation or pouch corrosion””, and that there is “no technical reasoning explaining how or why the assembly-focused path guiders of KR ‘909 would be modified to serve a venting-prevention function”, as argued throughout pages 8 and 9 of the REMARKS section, a recitation of the intended use of the claimed invention must result in a structural difference between the claimed invention and the prior art in order to patentably distinguish the claimed invention from the prior art. If the prior art structure is capable of performing the intended use, then it meets the claim.
In view of the 35 USC 112(b) and 35 USC 103 rejections provided in above sections 2 and 6-8, and for these additional reasons, claims 1-14 remain rejected.
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 KEVIN P KERNS whose telephone number is (571)272-1178. The examiner can normally be reached Monday-Friday 8am-430pm.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Keith Walker can be reached at (571)272-3458. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/KEVIN P KERNS/Primary Examiner, Art Unit 1735 February 5, 2026