DETAILED ACTION
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 4/3/26 has been entered.
Response to Amendment
In the amendment dated 4/3/26, the following has occurred: Claims 1 and 20 have been amended.
Claims 1-20 are pending. This communication is a Non-Final Rejection in response to the "Amendment" and "Remarks" filed on 4/3/26.
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 Rejections - 35 USC § 103
Claims 1-9, 11-12, 14-16, and 18-20 are rejected under 35 U.S.C. 103 as being unpatentable over JP 2014-120390 A (hereinafter “JP’390”) in view of JP 2021-054951 A (hereinafter “JP’951”) and US 2014/0011060 A1 (US’060).
As to Claim 1:
JP’390 discloses:
a battery cell, namely, nonaqueous electrolyte battery 20 including a battery body having positive electrode 25, negative electrode 26, separator 27, and a nonaqueous electrolyte enclosed in laminate film 22 (JP’390 (Pg. 2, lines 14–19));
a battery case, namely, laminate film 22 or outer packaging material 37, having an accommodation portion in which the battery body including positive electrode 25, negative electrode 26, and separator 27 is mounted, and a sealing portion formed by heat sealing the outer periphery of laminate film 22 (JP’390 (Pg. 2, lines 14–19));
an electrode lead, namely, positive electrode lead terminal 23 or negative electrode lead terminal 24, connected to the corresponding positive electrode 25 or negative electrode 26 and protruding out of laminate film 22 through the thermal-bonding portion at the periphery of laminate film 22 (JP’390 (Pg. 2, lines 19–23); (Pg. 4, lines 9–17));
a lead film, namely, lead terminal bonding film 10, located at the portion corresponding to the peripheral thermal-bonding portion and contacting at least one of a first side and a second side of lead terminal 23, wherein lead terminal bonding film 10 is of sufficient size to cover both sides of lead terminal 23 and is thermally bonded between lead terminal 23 and outer packaging material 37 (JP’390 (Pg. 4, lines 9–22));
wherein lead terminal bonding film 10 includes a first adhesive layer and a second adhesive layer, namely, outer layer 11 and inner layer 13, respectively, and an intermediate base resin layer 12 disposed between outer layer 11 and inner layer 13 (JP’390 (Pg. 4, lines 18–22); (Pg. 4, lines 35–45); (Pg. 7, lines 45–47));
wherein inner layer 13 is preferably an acid-modified polyolefin having excellent adhesion to the metal lead terminal, and outer layer 11 is selected for adhesion to thermal bonding layer 36 of outer packaging material 37 (JP’390 (Pg. 4, lines 35–45)); and
wherein the intermediate base resin layer 12 contains inorganic filler particles dispersed in a polyolefin resin, and acid-modified polyolefin resin layers 11 and 13 are laminated on both surfaces of base resin layer 12 (JP’390 (Pg. 5, lines 30–45)).
However, JP’390 does not expressly disclose that the electrode lead is electrically connected to an electrode tab included in the electrode assembly. JP’390 also does not expressly disclose that intermediate base resin layer 12 is a moisture removal layer including a getter material or that at least one of adhesive layers 11 and 13 is configured to discharge gas generated inside the battery cell.
JP’951 discloses a transparent water-absorbing sealant film configured to absorb moisture from outside a package and moisture present in an internal packaged space and thereby suppress deterioration of the packaged contents due to moisture (JP’951 (Pg. 1, lines 21–29)). JP’951 further discloses a multilayer structure having a water-absorbing layer containing an inorganic water-absorbing agent and heat-sealing layers laminated on both sides of the water-absorbing layer (JP’951 (Pg. 2, lines 39–53)). The water-absorbing layer contains an inorganic water-absorbing agent dispersed in a thermoplastic resin (JP’951 (Pg. 3, lines 40–57)).
JP’951 further discloses that the inorganic water-absorbing agent may be one or more of zeolite, activated clay, and a metal-organic framework (MOF), thereby disclosing a moisture-removal layer including a getter material (JP’951 (Pg. 4, lines 11–16)). JP’951 provides specific examples of MOF water-absorbing materials, including aluminum fumarate, copper trimesate, aluminum trimesate, zirconium trimesate, and aluminum terephthalate (JP’951 (Pg. 4, lines 42–53); (Pg. 8, lines 19–38)). JP’951 also expressly discloses a three-layer arrangement of heat-sealing layer 1/water-absorbing layer/heat-sealing layer 2 (JP’951 (Pg. 7, lines 38–44); (Pg. 9, lines 9–15)).
US’060 discloses an electrode assembly 11 including cathode plate 11a, anode plate 11b, separator 11c, and electrode tab T, wherein electrode tab T is integrated with cathode plate 11a or anode plate 11b and is included in electrode assembly 11 (US’060 [0058]–[0061]). US’060 further discloses electrode lead 12 attached to electrode tab T and extending outward from electrode assembly 11, thereby teaching an electrode lead electrically connected to an electrode tab included in the electrode assembly (US’060 [0062]).
US’060 also discloses pouch case 14 accommodating electrode assembly 11 so that electrode lead 12 is drawn out, with the rims of pouch case 14 thermally bonded to form sealed area S (US’060 [0068]). Sealing tape 13 is interposed between electrode lead 12 and the inner surface of pouch case 14 and is formed of a heat-bondable film that may have a single-layer or multilayer structure (US’060 [0064]).
US’060 further discloses venting pattern portion 23a formed as a through-hole in sealing tape 23 at the sealed electrode-lead region. When gas is generated inside pouch case 24, pressure is concentrated at the region of weakened adhesion formed by through-hole 23a, thereby permitting the adhesion between sealing tape 23 and pouch case 24 to be released and the gas to be discharged (US’060 [0076]). US’060 additionally discloses punching the electrode lead having the sealing tape attached thereto so that opposite surfaces of the sealing tape are penetrated and expressly states that the resulting battery structure is capable of easily discharging gas generated inside the pouch case (US’060 [0084]–[0089]).
JP’390, JP’951, and US’060 are analogous arts. JP’390 and US’060 are in the same field of endeavor because both concern a pouch-type secondary battery having a heat-bondable sealing film or tape positioned between an electrode lead and the peripheral seal of a laminate pouch case (JP’390 (Pg. 3, lines 13–29; JP’951 (Pg. 1, lines 21–29); (Pg. 2, lines 39–53); US’060 [0018]–[0019]).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to modify intermediate base resin layer 12 of the three-layer lead terminal bonding film 10 of JP’390 to include the MOF water-absorbing agent of JP’951, while retaining adhesive outer layer 11 and adhesive inner layer 13 on opposite sides of the modified intermediate layer, in order to absorb moisture entering the battery package and thereby reduce the moisture-related deterioration of the lead-terminal sealing portion identified by JP’390.
It would have been further obvious to connect the electrode lead to an electrode tab as taught by US’060 and to form the through-hole venting pattern of US’060 through the modified multilayer lead terminal bonding film of JP’390, including through at least one of adhesive layers 11 and 13, because US’060 expressly teaches forming such a venting structure in a heat-bondable sealing tape at the pouch-cell lead exit to facilitate discharge of gas generated inside the pouch case. The resulting battery cell would include first and second adhesive layers, a getter-containing moisture-removal layer disposed between the adhesive layers, and at least one adhesive layer penetrated by the venting pattern and thereby configured to participate in discharging gas generated inside the battery cell.
As to Claim 2:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2). JP’390 also discloses a lead film located at a portion corresponding to the sealing portion and contacting at least one side of the electrode lead, the lead film including a first adhesive layer and a second adhesive layer (p. 6, lines 1–28; Fig. 3).
JP’390 does not disclose that the moisture removal layer includes at least one of calcium oxide (CaO), lithium chloride (LiCl), silica (SiO₂), barium oxide (BaO), barium (Ba), and calcium (Ca). JP’390 does not describe any getter material composition for a moisture removal layer disposed between the adhesive layers (p. 6, lines 16–28).
JP’951 discloses a moisture removal layer disposed between adhesive layers that includes getter materials, and expressly teaches that the getter materials may include silica (SiO₂), alkaline earth metal oxides, and metal-based moisture absorbents, which correspond to the recited materials of Claim 2 (p. 7, lines 19–32; p. 8, lines 1–12).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate the getter materials disclosed in JP’951, such as silica and alkaline earth metal oxides, into the moisture removal layer of the lead film of JP’390, in order to improve moisture absorption and sealing reliability.
As to Claim 3:
JP’390 discloses the battery cell and lead film structure as described above for Claim 2, including the first adhesive layer, second adhesive layer, and an intermediate layer in the lead film (p. 6, lines 16–28).
However, JP’390 does not disclose that the getter material has a structure of a metal organic framework (MOF). JP’390 does not describe the structural type of any getter material used in an intermediate layer of the lead film (p. 6, lines 16–28).
JP’951 expressly discloses that the getter material included in the moisture removal layer may be a metal organic framework (MOF), and explains that MOFs are suitable for moisture absorption due to their high surface area and pore structure (p. 7, lines 19–32).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to use a metal organic framework (MOF) as the getter material in the moisture removal layer of the lead film of JP’390, as taught by JP’951, in order to enhance moisture absorption performance.
As to Claim 4:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film located at a portion corresponding to the sealing portion and contacting at least one side of the electrode lead, wherein the lead film includes a first adhesive layer, a second adhesive layer, and an intermediate layer disposed between the adhesive layers (p. 6, lines 1–28; Fig. 3). JP’390 explains that the intermediate layer functions as a base resin layer for insulation and bonding (p. 6, lines 16–22).
Importantly, JP’390 expressly discloses that this intermediate base resin layer is formed of a polyolefin resin, specifically block polypropylene, selected for its insulating properties, heat resistance, and compatibility with adjacent adhesive layers (p. 6, lines 22–28).
However, JP’390 does not explicitly characterize the intermediate layer as a “moisture removal layer” in functional terms, nor does it expressly describe the intermediate layer as being configured to remove moisture, despite disclosing its polyolefin resin composition (p. 6, lines 16–28).
JP’951 discloses a laminate film structure including a moisture removal layer disposed between adhesive layers, wherein the moisture removal layer includes a getter material dispersed in a polyolefin-based resin matrix, such as polypropylene (p. 6, lines 10–22; p. 7, lines 5–18). JP’951 explains that polyolefin-based resins are particularly suitable for moisture removal layers due to their chemical stability, compatibility with heat sealing, and ability to uniformly disperse getter materials (p. 6, lines 18–22).
JP’390 and JP’951 are analogous art because both references relate to laminate film structures used at sealed peripheral portions of battery cells and both address material selection for layers disposed between adhesive films to ensure insulation, sealing reliability, and durability. A person skilled in the art of battery packaging would reasonably consult JP’951 to adapt the known polyolefin-based intermediate layer of JP’390 to additionally perform moisture removal.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to configure the polyolefin-based intermediate layer (block polypropylene) disclosed in JP’390 as a moisture removal layer, as taught by JP’951, by incorporating getter material therein. JP’390 already teaches the use of a polyolefin resin in the intermediate layer for insulation and bonding, and JP’951 teaches that the same class of polyolefin resins is suitable as a matrix for moisture removal layers. Modifying the known polyolefin intermediate layer of JP’390 to additionally provide moisture removal functionality represents a predictable use of known materials for their established properties and would have been well within the routine skill of a person in the art.
As to Claim 5:
JP’390 discloses the battery cell and lead film structure as described above for Claim 4, including first and second adhesive layers and an intermediate layer disposed therebetween (p. 6, lines 16–28).
However, JP’390 does not disclose that the moisture removal layer further includes polypropylene. JP’390 does not describe the resin composition of the intermediate layer as being polypropylene (p. 6, lines 16–28).
JP’951 expressly discloses that the polyolefin-based resin used in the moisture removal layer may be polypropylene, and identifies polypropylene as a preferred resin for forming the moisture removal layer containing getter materials (p. 6, lines 18–22).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to use polypropylene as the polyolefin-based resin in the moisture removal layer of the lead film of JP’390, as taught by JP’951, in order to achieve suitable processability and moisture-removal performance.
As to Claim 6:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted, and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film located at a portion corresponding to the sealing portion, wherein the lead film includes a first adhesive layer, a second adhesive layer, and an intermediate layer disposed between the adhesive layers (p. 6, lines 16–28; Fig. 3).
However, JP’390 does not disclose that the intermediate layer, corresponding to the moisture removal layer, has a thickness of 60 μm or more. JP’390 does not provide any numerical thickness range for the intermediate layer disposed between the adhesive layers (p. 6, lines 16–28).
JP’951 discloses a moisture removal layer disposed between adhesive layers in a laminate structure, and expressly teaches that the moisture removal layer may be formed with a thickness of 60 μm or more in order to ensure sufficient moisture absorption capacity and durability (p. 8, lines 13–24).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form the intermediate layer of the lead film of JP’390 with a thickness of 60 μm or more, as taught by JP’951, in order to improve moisture absorption performance and sealing reliability.
As to Claim 7:
JP’390 discloses the battery cell and lead film structure described above, including first and second adhesive layers with an intermediate layer disposed therebetween (p. 6, lines 16–28).
However, JP’390 does not disclose that the intermediate layer includes 0.01 percent weight to 80 percent weight of a getter material, based on the total weight of the moisture removal layer. JP’390 does not describe any getter content or weight percentage for the intermediate layer (p. 6, lines 16–28).
JP’951 expressly discloses that the moisture removal layer includes a getter material in an amount of 0.01 wt% to 80 wt%, based on the total weight of the moisture removal layer, in order to balance moisture absorption performance and mechanical properties (p. 9, lines 11–22).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate a getter material in an amount of 0.01 percent weight to 80 percent weight into the intermediate layer of the lead film of JP’390, as taught by JP’951, in order to achieve effective moisture removal while maintaining mechanical integrity.
As to Claim 8:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film located at a portion corresponding to the sealing portion, wherein the lead film includes a first adhesive layer and a second adhesive layer for bonding the electrode lead to the sealing portion of the battery case (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not disclose that the first adhesive layer includes a polyolefin-based resin. JP’390 describes the first adhesive layer as an adhesive resin layer but does not specify that the resin is polyolefin-based (p. 6, lines 1–15).
JP’951 discloses laminate structures used at sealing portions, wherein adhesive layers include polyolefin-based resins, such as polyethylene and polypropylene, due to their excellent adhesion to laminate films and chemical stability (p. 5, lines 18–30; p. 6, lines 1–12). JP’951 teaches that polyolefin-based adhesive layers are particularly suitable for sealed laminate interfaces requiring durability and moisture resistance.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form the first adhesive layer of the lead film in JP’390 from a polyolefin-based resin, as taught by JP’951, in order to improve adhesion and sealing reliability.
As to Claim 9:
JP’390 discloses the battery cell and lead film structure described above for Claim 8, including a first adhesive layer disposed on the electrode lead side of the lead film (p. 6, lines 1–15).
However, JP’390 does not disclose that the first adhesive layer includes polypropylene treated with maleic anhydride (MAH). JP’390 does not describe any surface-modified polypropylene or MAH-grafted resin in the first adhesive layer (p. 6, lines 1–15).
JP’951 discloses that polyolefin-based adhesive layers may be chemically modified, including maleic-anhydride–grafted polypropylene, in order to improve adhesion to metal components and laminate films (p. 6, lines 13–22). JP’951 explains that MAH-treated polypropylene is particularly effective for bonding to metal leads and laminate cases.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to use polypropylene treated with maleic anhydride as the material for the first adhesive layer of the lead film in JP’390, as taught by JP’951, in order to improve adhesion to the electrode lead and sealing portion.
As to Claim 11:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted, and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film located at a portion corresponding to the sealing portion, wherein the lead film includes a first adhesive layer and a second adhesive layer, the first adhesive layer being disposed on the electrode-lead side of the lead film (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not disclose that the first adhesive layer has a thickness of 60 μm or more. JP’390 does not provide any numerical thickness range for the first adhesive layer (p. 6, lines 1–15).
JP’951 discloses laminate structures used at sealed portions, wherein adhesive layers are formed with sufficient thickness to ensure sealing reliability, and teaches that adhesive layers may have a thickness of 60 μm or more to improve bonding strength and durability (p. 6, lines 23–30; p. 7, lines 1–8).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form the first adhesive layer of the lead film in JP’390 with a thickness of 60 μm or more, as taught by JP’951, in order to improve adhesion strength and sealing reliability.
As to Claim 12:
JP’390 discloses the battery cell and lead film structure described above, including a first adhesive layer on the electrode-lead side and a second adhesive layer on the sealing-portion side of the lead film (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not disclose that the second adhesive layer includes a polyolefin-based resin. JP’390 describes the second adhesive layer as an adhesive resin layer but does not specify the resin type (p. 6, lines 1–15).
JP’951 discloses that adhesive layers used in laminate sealing structures may include polyolefin-based resins, such as polyethylene or polypropylene, due to their excellent adhesion to laminate films and sealing portions (p. 5, lines 18–30; p. 6, lines 1–12).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form the second adhesive layer of the lead film in JP’390 from a polyolefin-based resin, as taught by JP’951, in order to improve adhesion and sealing reliability.
As to Claim 14:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted, and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film located at a portion corresponding to the sealing portion, wherein the lead film includes a first adhesive layer and a second adhesive layer disposed on opposite sides of the lead film (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not disclose that the second adhesive layer has a thickness of 60 μm or more. JP’390 does not provide any numerical thickness range for the second adhesive layer (p. 6, lines 1–15).
JP’951 discloses laminate sealing structures in which adhesive layers disposed at sealing portions are formed with sufficient thickness, and teaches that the adhesive layers may have a thickness of 60 μm or more to ensure bonding strength, sealing reliability, and durability (p. 6, lines 23–30; p. 7, lines 1–8).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to form the second adhesive layer of the lead film in JP’390 with a thickness of 60 μm or more, as taught by JP’951, in order to improve sealing reliability and mechanical durability.
As to Claim 15:
JP’390 discloses a battery cell including a lead film disposed at the sealing portion, wherein a first adhesive layer is arranged on the electrode-lead side of the lead film and a second adhesive layer is arranged on the sealing-portion side of the lead film (p. 6, lines 1–15; Fig. 3). JP’390 further discloses that the first adhesive layer bonds to the electrode lead, and the second adhesive layer bonds to the inner surface of the battery case sealing portion (p. 6, lines 16–28; Fig. 3).
However, JP’390 does not explicitly describe the bonding relationship using the exact terminology of “the first adhesive layer is adhered to an outer surface of the electrode lead, and the second adhesive layer is adhered to an inner surface of the sealing portion.” While JP’390 shows the positional relationship, it does not expressly articulate this limitation in claim-like form.
JP’951 discloses laminate sealing structures in which an adhesive layer on one side of a laminate film is adhered to a metal member, and another adhesive layer on the opposite side is adhered to an inner surface of a sealing film, expressly describing this opposing-surface adhesion configuration (p. 5, lines 18–30; p. 6, lines 1–12).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to configure the lead film of JP’390 such that the first adhesive layer is adhered to an outer surface of the electrode lead and the second adhesive layer is adhered to an inner surface of the sealing portion, as taught by JP’951, in order to achieve a stable and reliable sealing structure.
As to Claim 16:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film disposed at the sealing portion, wherein lead terminal bonding films are arranged on both surfaces of the electrode lead (p. 5, lines 15–28; Fig. 3). In particular, JP’390 discloses that a lead film is disposed on one surface of the electrode lead and another lead film is disposed on the opposite surface of the electrode lead, thereby sandwiching the electrode lead at the sealing portion (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not explicitly describe the first lead film as being located on an upper side of the electrode lead and the second lead film as being located on a lower side of the electrode lead using directional terminology corresponding to Claim 16.
JP’951 discloses laminate sealing structures in which adhesive films are disposed on opposite sides of a member, and explains that such films may be arranged on upper and lower surfaces of the member depending on assembly orientation (p. 5, lines 18–30; p. 6, lines 1–12). JP’951 teaches that describing laminate films as being disposed on upper and lower sides is a conventional positional designation based on installation orientation.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to interpret and implement the opposing lead films of JP’390 as being located on upper and lower sides of the electrode lead, as taught by the positional film arrangements in JP’951, since such directional designations depend on assembly orientation and do not alter the structure or function of the lead films.
As to Claim 18:
JP’390 discloses a battery cell structure as described above, including the electrode assembly, electrode lead, sealing portion, and lead film (p. 4, lines 1–22; p. 5, lines 3–28). JP’390 further discloses that a plurality of such battery cells may be assembled together to form a battery pack or module (p. 2, lines 10–20).
However, JP’390 does not explicitly recite the term “battery module” using claim-like language specifying that the battery module comprises the battery cell according to Claim 1.
JP’951 discloses that battery cells having sealed laminate structures are assembled into battery modules for use in larger power systems, and explicitly teaches forming a battery module comprising a plurality of battery cells (p. 2, lines 15–25).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to assemble the battery cell of JP’390 into a battery module, as taught by JP’951, since forming modules from individual battery cells is a routine and well-known practice in the battery art.
As to Claim 19:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted, and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film disposed at a portion corresponding to the sealing portion, wherein the lead film includes a first adhesive layer and a second adhesive layer, and is arranged between the electrode lead and the inner surface of the battery case sealing portion (p. 6, lines 1–15; Fig. 3). As shown in Fig. 3, the lead film is interposed so as to prevent direct contact between the electrode lead and the battery case.
However, JP’390 does not explicitly describe this interposed arrangement using the express claim language that “the lead film separates the battery case from the electrode lead.” While JP’390 depicts and implies physical separation, it does not recite this functional separation in explicit terms.
JP’951 discloses laminate sealing structures in which a laminate film is interposed between a metal member and a sealing film, and expressly teaches that such a laminate film functions to separate the metal member from the sealing film to prevent electrical shorting and to improve sealing reliability (p. 5, lines 18–30; p. 6, lines 1–12). JP’951 explicitly characterizes the laminate film as a separating layer between the metal component and the sealing film.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to configure and describe the lead film of JP’390 such that it separates the battery case from the electrode lead, as taught by JP’951, in order to prevent direct contact, improve electrical insulation, and enhance sealing reliability.
As to Claim 20:
JP’390 discloses:
a battery cell, namely, nonaqueous electrolyte battery 20 including a battery body having positive electrode 25, negative electrode 26, separator 27, and a nonaqueous electrolyte enclosed in laminate film 22 (JP’390 (Pg. 2, lines 14–19));
a battery case, namely, laminate film 22 or outer packaging material 37, having an accommodation portion in which the battery body including positive electrode 25, negative electrode 26, and separator 27 is mounted, and a sealing portion formed by heat sealing the outer periphery of laminate film 22 (JP’390 (Pg. 2, lines 14–23));
an electrode lead, namely, positive electrode lead terminal 23 or negative electrode lead terminal 24, connected to the corresponding positive electrode 25 or negative electrode 26 and protruding out of laminate film 22 through the thermal-bonding portion at the periphery of laminate film 22 (JP’390 (Pg. 2, lines 19–23); (Pg. 4, lines 9–16));
a lead film, namely, lead terminal bonding film 10, located at a portion corresponding to the peripheral sealing portion on at least one of a first side and a second side of lead terminal 23, wherein lead terminal bonding film 10 has a size capable of covering both sides of lead terminal 23 and is thermally bonded between lead terminal 23 and outer packaging material 37 (JP’390 (Pg. 4, lines 9–22));
wherein lead terminal bonding film 10 includes a first adhesive layer and a second adhesive layer, namely, outer layer 11 and inner layer 13, respectively, and an intermediate base resin layer 12 disposed between outer layer 11 and inner layer 13 (JP’390 (Pg. 4, lines 17–22); (Pg. 4, lines 35–45));
wherein inner layer 13 is an acid-modified polyolefin having excellent adhesion to the metal lead terminal, and outer layer 11 is selected for adhesion to thermal bonding layer 36 of outer packaging material 37 (JP’390 (Pg. 4, lines 35–45)); and
wherein base resin layer 12 contains inorganic filler particles dispersed in a polyolefin resin, and acid-modified polyolefin resin layers 11 and 13 are laminated on both surfaces of base resin layer 12 (JP’390 (Pg. 5, lines 30–44)).
However, JP’390 does not expressly disclose that the electrode lead is electrically connected to an electrode tab included in the electrode assembly. JP’390 also does not expressly disclose that intermediate base resin layer 12 is a moisture-removal layer including 30% to 70% by weight of a getter material based on the total weight of the moisture-removal layer, or that at least one adhesive layer selected from adhesive layers 11 and 13 is configured to discharge gas generated inside the battery cell.
JP’951 discloses a water-absorbing sealant film that absorbs moisture from outside a package and moisture present within an internal packaged space, thereby suppressing deterioration of the packaged contents due to moisture (JP’951 (Pg. 1, lines 21–29)). JP’951 further discloses a multilayer structure having a water-absorbing layer containing an inorganic water-absorbing agent and heat-sealing layers laminated on one or both sides of the water-absorbing layer (JP’951 (Pg. 2, lines 31–53)). The water-absorbing layer contains an inorganic water-absorbing agent dispersed in a thermoplastic resin (JP’951 (Pg. 3, lines 40–57)).
JP’951 further discloses that the inorganic water-absorbing agent may be a metal-organic framework (MOF), which absorbs gaseous or liquid water and thereby teaches the claimed getter material (JP’951 (Pg. 4, lines 11–16)). JP’951 identifies exemplary MOF materials including aluminum fumarate, zirconium fumarate, copper trimesate, aluminum trimesate, zirconium trimesate, and aluminum terephthalate (JP’951 (Pg. 4, lines 42–53)).
JP’951 further discloses that the content of the inorganic water-absorbing agent in the water-absorbing layer is 0.5% to 70% by mass, and more preferably 2% to 65% by mass, thereby expressly encompassing and substantially overlapping the claimed range of 30% to 70% by weight based on the total weight of the moisture-removal layer (JP’951 (Pg. 2, lines 56–58); (Pg. 3, lines 1–3)). JP’951 also teaches a preferred inorganic water-absorber concentration of 30% to 70% by mass in the masterbatch used to prepare the water-absorbing layer (JP’951 (Pg. 4, lines 6–9)) and expressly discloses a three-layer arrangement of heat-sealing layer 1/water-absorbing layer/heat-sealing layer 2 (JP’951 (Pg. 7, lines 38–44); (Pg. 9, lines 9–15)).
US’060 discloses an electrode assembly 11 including cathode plate 11a, anode plate 11b, separator 11c, and electrode tab T, wherein electrode tab T is integrated with cathode plate 11a or anode plate 11b and is included in electrode assembly 11 (US’060 [0058]–[0061]). US’060 further discloses electrode lead 12 attached to electrode tab T and extending outward from electrode assembly 11, thereby teaching an electrode lead electrically connected to an electrode tab included in the electrode assembly (US’060 [0062]).
US’060 also discloses pouch case 14 accommodating electrode assembly 11 so that electrode lead 12 is drawn out, with the rims of pouch case 14 thermally bonded to form sealed area S (US’060 [0068]). Sealing tape 13 is interposed between electrode lead 12 and the inner surface of pouch case 14 and is formed of a heat-bondable film that may include a single layer or multiple layers of polypropylene, polyethylene, or other disclosed film materials (US’060 [0064]).
US’060 further discloses venting pattern portion 23a formed as a through-hole in sealing tape 23 at the sealed electrode-lead region. When gas is generated inside pouch case 24, pressure is concentrated at the region having weakened adhesion due to through-hole 23a, thereby allowing the adhesion between sealing tape 23 and pouch case 24 to be released and permitting the generated gas to be discharged (US’060 [0076]). US’060 additionally discloses punching the electrode lead having the sealing tape attached thereto so that opposite surfaces of the sealing tape are penetrated, and expressly states that the resulting battery has a structure capable of easily discharging gas generated inside the pouch case (US’060 [0084]–[0089]).
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to modify intermediate base resin layer 12 of the three-layer lead terminal bonding film 10 of JP’390 to include the MOF water-absorbing agent of JP’951 in an amount of 30% to 70% by weight based on the total weight of the modified intermediate layer, while retaining adhesive outer layer 11 and adhesive inner layer 13 on opposite sides thereof, because JP’951 teaches an encompassing water-absorber range of 0.5% to 70% by mass, a preferred masterbatch range of 30% to 70% by mass, and the use of such a water-absorbing layer between two heat-sealing layers. The modification would absorb moisture entering the battery package and thereby reduce the moisture-related deterioration of the lead-terminal sealing portion identified by JP’390.
It would have been further obvious to connect the electrode lead to an electrode tab as taught by US’060 and to form the through-hole venting pattern of US’060 through the modified multilayer lead terminal bonding film of JP’390, including through at least one of adhesive layers 11 and 13, because US’060 expressly teaches forming such a venting structure in a heat-bondable sealing tape at the pouch-cell lead exit to facilitate discharge of gas generated inside the pouch case. The resulting battery cell would include first and second adhesive layers, a moisture-removal layer disposed therebetween and containing 30% to 70% by weight of a getter material, and at least one adhesive layer penetrated by the venting pattern and thereby configured to participate in discharging gas generated inside the battery cell.
Claims 10 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over JP 2014-120390 A (JP’390) in view of JP 2021-054951 A (JP’951) and US 2014/0011060 A1 (US’060), as applied to Claim 1 above, and further in view of US 2019/358902 A1 (US’902).
As to Claim 10:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2). JP’390 also discloses a lead film located at a portion corresponding to the sealing portion, wherein the lead film includes a first adhesive layer disposed on the electrode-lead side and a second adhesive layer disposed on the sealing-portion side (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not disclose that the first adhesive layer has a gas permeability of 20 Barrer to 60 Barrer at 60 °C, nor does JP’390 disclose any quantitative gas-permeability values or temperature-dependent permeability characteristics for the adhesive layers (p. 6, lines 1–28).
JP’951 discloses laminate sealing structures used in battery-related applications and teaches that adhesive layers disposed at sealed peripheral portions are selected in view of controlled gas transmission characteristics to balance sealing reliability and gas diffusion (p. 8, lines 13–24; p. 9, lines 1–10). JP’951 therefore establishes that gas permeability is a recognized design parameter for adhesive layers used in battery sealing regions.
US’902 expressly discloses polymer layers used in laminated structures and teaches that such polymer layers may have gas permeability values within a range of about 10 to 60 Barrer, including ranges overlapping 20 to 60 Barrer, as measured by standard gas-permeability testing methods ([0051]–[0053]). US’902 further explains that such permeability ranges are relevant for polymer layers functioning at elevated temperatures, including temperatures on the order of 60 °C, to allow controlled gas diffusion while maintaining mechanical integrity ([0062]).
JP’390, JP’951, and US’902 are analogous art because all three references relate to laminated structures used in battery or electrochemical device applications and address material selection for layers disposed at sealing portions, including considerations of gas transmission, durability, and reliability. A person skilled in the art of battery packaging would reasonably consult JP’951 and US’902 when selecting material properties for adhesive layers used in the lead film of JP’390.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to modify the first adhesive layer of the lead film in JP’390 to have a gas permeability of 20 Barrer to 60 Barrer at 60 °C, as taught by US’902 and suggested by the gas-management considerations described in JP’951, in order to permit controlled gas diffusion while maintaining sealing reliability and mechanical strength at the sealing portion.
As to Claim 13:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is mounted and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2). JP’390 also discloses a lead film including a second adhesive layer disposed on the sealing-portion side of the lead film and bonded to the inner surface of the battery case sealing portion (p. 6, lines 1–15; Fig. 3).
However, JP’390 does not disclose that the second adhesive layer has a gas permeability of 20 Barrer to 60 Barrer at 60 °C, nor does JP’390 provide any quantitative disclosure of gas-permeability values or temperature-dependent permeability for the second adhesive layer (p. 6, lines 1–28).
JP’951 discloses battery sealing structures in which adhesive layers disposed at sealing portions are selected to permit controlled gas transmission, and teaches that gas permeability is an important material property for adhesive layers used in sealed battery structures to balance sealing reliability and gas release (p. 8, lines 13–24; p. 9, lines 1–10).
US’902 expressly discloses laminated polymer layers used in functional sealing applications and teaches that such layers may have gas permeability values in a range of about 20 Barrer to 60 Barrer at elevated temperatures, including temperatures around 60 °C, to allow controlled gas diffusion while maintaining adhesion and structural integrity ([0051]–[0053], [0062]). US’902 further indicates that these permeability ranges are applicable to polymer layers used on either side of laminated structures.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to modify the second adhesive layer of the lead film disclosed in JP’390 to have a gas permeability of 20 Barrer to 60 Barrer at 60 °C, as taught by US’902 and suggested by the gas-management considerations described in JP’951, in order to achieve controlled gas diffusion while maintaining sealing reliability and structural integrity at the sealing portion.
Claim 17 is rejected under 35 U.S.C. 103 as being unpatentable over JP 2014-120390 A (hereinafter “JP’390”) in view of JP 2021-054951 A (hereinafter “JP’951”) and US 2014/0011060 A1 (US’060), as applied to Claim 16 above, and further in view of JP 2001-307777 A (hereinafter “JP’777”).
As to Claim 17:
JP’390 discloses a battery cell including a battery case having an accommodation portion in which an electrode assembly is configured to be mounted, and a sealing portion formed by sealing an outer periphery of the battery case (p. 4, lines 1–12; p. 4, lines 13–22; Fig. 2). JP’390 further discloses an electrode lead electrically connected to an electrode tab included in the electrode assembly and protruding out of the battery case via the sealing portion (p. 5, lines 3–14; Fig. 2).
JP’390 also discloses a lead film located at a portion corresponding to the sealing portion and contacting the electrode lead, the lead film including a first adhesive layer, a moisture removal layer, and a second adhesive layer (p. 6, lines 1–15; p. 6, lines 16–28; Fig. 3). JP’390 further teaches that the lead film may be disposed on opposite sides of the electrode lead, corresponding to an upper side and a lower side of the electrode lead, consistent with a configuration including multiple lead films (p. 6, lines 16–28; Fig. 3).
However, JP’390 does not explicitly disclose that an end of the first adhesive layer included in a first lead film is in contact with an end of the first adhesive layer included in a second lead film, as recited in Claim 17. While JP’390 discloses adhesive layers on opposite sides of the electrode lead, it does not expressly describe end-to-end contact between the first adhesive layers of the respective lead films.
JP’951 discloses battery sealing structures in which multiple sealing or adhesive films are disposed on opposite sides of a conductive member, and teaches that adjacent adhesive layers may be arranged so that their end portions contact each other to improve sealing reliability and moisture blocking at the penetration region (p. 10, lines 1–12; p. 10, lines 13–22; Fig. 6).
JP’777 further discloses laminated sealing members disposed on opposite sides of a lead or tab, wherein adhesive layers of the respective laminated members are arranged such that their end portions abut or contact each other, thereby forming a continuous adhesive barrier across the penetration region (p. 5, lines 8–20; p. 6, lines 1–12; Fig. 4). JP’777 explicitly teaches that contacting adhesive ends improves sealing performance and reduces leakage paths.
JP’390, JP’951, and JP’777 are analogous art because each reference relates to battery cells or sealed electrochemical devices having electrode leads or tabs passing through a sealing portion, and each addresses the structure and arrangement of adhesive or sealing layers at the lead-penetration region. A person of ordinary skill in the art of battery packaging would reasonably consult JP’951 and JP’777 when determining how to arrange multiple lead films and adhesive layers in JP’390 to enhance sealing performance.
It would have been obvious to a person skilled in the art before the effective filing date of the instant application to modify the lead-film structure of JP’390 so that an end of the first adhesive layer included in a first lead film contacts an end of the first adhesive layer included in a second lead film, as taught by JP’951 and JP’777, in order to improve sealing continuity, moisture blocking, and leakage prevention at the electrode-lead penetration region.
Response to Arguments
Applicant's arguments filed 4/3/26 have been fully considered but they are not persuasive.
New Limitations of Claims 1 and 20
Applicant argues that all claim elements must be considered and that the cited references fail to disclose an adhesive layer configured to discharge gas generated inside the battery cell.
The argument is not persuasive against the newly applied combination.
JP’390 discloses lead terminal bonding film 10 positioned between lead terminal 23 and outer packaging material 37 at the peripheral battery seal. Lead terminal bonding film 10 covers both sides of lead terminal 23 and includes outer layer 11, intermediate base resin layer 12, and inner layer 13. Outer layer 11 is selected for adhesion to the outer packaging material, and inner layer 13 is an acid-modified polyolefin having adhesion to the metal lead terminal. JP’390 therefore expressly provides first and second adhesive layers on opposite sides of an intermediate resin layer. JP’390 (Pg. 4, lines 6–19 and 30–40).
JP’951 discloses a water-absorbing layer containing an inorganic water-absorbing agent and positioned between heat-sealing layers. JP’951 expressly teaches a layer arrangement of heat-sealing layer 1/water-absorbing layer/heat-sealing layer 2. JP’951 (Pg. 2, lines 28–40); (Pg. 7, lines 29–34). JP’951 further discloses that the inorganic water-absorbing agent may be a metal-organic framework (“MOF”), including aluminum fumarate, copper trimesate, aluminum trimesate, zircon trimesate, and aluminum terephthalate. JP’951 (Pg. 4, lines 8–12 and 31–40); (Pg. 5, lines 17–25). Thus, JP’951 supplies the claimed getter-containing moisture-removal layer for the intermediate-layer position of JP’390.
US’060 expressly discloses a pouch-type secondary battery having electrode assembly 11, electrode lead 12, heat-bondable sealing tape 13, and pouch case 14. Electrode assembly 11 includes electrode tab T, and electrode lead 12 is attached to electrode tab T. US’060 [0058]–[0062]. Thus, US’060 expressly teaches the claimed electrode lead electrically connected to an electrode tab included in the electrode assembly.
US’060 further discloses venting pattern portion 13a or 23a formed in the heat-bondable sealing tape at the sealed electrode-lead region. The venting pattern may be a notch or a through-hole. When gas is generated inside the pouch case, pressure concentrates at the venting pattern and causes adhesion between the sealing tape and pouch case to be released so that the generated gas may be discharged. US’060 [0018]–[0019], [0064]–[0068], [0076].
US’060 additionally discloses punching the electrode lead after the sealing tape is attached so that opposite surfaces of the sealing tape are penetrated. US’060 [0042]–[0043], [0084]–[0085]. US’060 expressly states that the resulting battery has a structure capable of easily discharging gas generated inside the pouch case. US’060 [0089].
When the through-hole venting pattern of US’060 is applied to JP’390’s three-layer lead terminal bonding film, the through-hole penetrates the multilayer film, including at least one of adhesive surface layers 11 and 13. The resulting adhesive layer is therefore structurally provided with the venting pattern and participates in the pressure-responsive gas-discharge path taught by US’060.
Applicant’s argument that the references do not disclose an adhesive layer having “gas permeability” is not commensurate with the scope of claims 1 and 20. Claims 1 and 20 require that at least one adhesive layer be “configured to discharge gas generated inside the battery cell.” Claims 1 and 20 do not require:
a gas permeability of 20 Barrer to 60 Barrer;
molecular diffusion through uninterrupted adhesive resin;
carbon dioxide permeability;
a particular permeability test; or
discharge exclusively through the bulk material of the adhesive layer.
The more specific gas-permeability range is separately recited in dependent claims 10 and 13. The gas-discharge limitation of claims 1 and 20 is therefore not limited to the narrower permeability mechanism recited in those dependent claims. US’060’s venting pattern provides a structural configuration through the adhesive layer that permits discharge of internally generated gas and therefore satisfies the limitation under the broadest reasonable interpretation.
As to claim 20, JP’951 further discloses that the inorganic water-absorbing agent may constitute 0.5% to 70% by mass of the water-absorbing layer. JP’951 (Pg. 1, lines 18–20); (Pg. 2, lines 41–43). This disclosed range encompasses the claimed range of 30% to 70% by weight based on the total weight of the moisture-removal layer.
Accordingly, the new combination expressly accounts for the limitations emphasized by Applicant.
Teaching Away by JP’390
Applicant argues that JP’390 is intended to capture hydrogen fluoride and therefore “discourages the discharge of gaseous products generated inside of the battery.”
The argument is not persuasive.
JP’390 discloses reacting with and capturing hydrogen fluoride that is produced when moisture entering the package reacts with electrolyte. JP’390 (Pg. 3, lines 31–40). JP’390’s hydrogen-fluoride capture addresses chemical deterioration of the terminal surface and loss of adhesive strength.
JP’390 does not state that:
all gas generated within the battery must remain permanently enclosed;
pressure-responsive venting should be avoided;
a lead-sealing tape must remain sealed under every abnormal internal-pressure condition; or
the hydrogen-fluoride capture function is incompatible with a controlled safety vent.
US’060 addresses a different operating condition. US’060 discloses that the sealing tape maintains sealing and insulation during ordinary operation, but that adhesion is locally released at the venting pattern when internally generated gas produces sufficient pressure. US’060 [0064]–[0068].
Moreover, JP’390’s disclosure that the three layers of lead terminal bonding film 10 should remain firmly bonded when internal pressure rises concerns prevention of interlayer peeling between layers 11, 12, and 13. JP’390 (Pg. 5, lines 25–40). US’060 releases adhesion at a different interface—between the sealing tape and pouch case at the venting region. US’060 [0066]–[0068], [0076]. Maintaining the integrity of the multilayer tape while allowing controlled release of the tape-to-pouch interface is not inconsistent.
The combined structure may therefore retain JP’390’s hydrogen-fluoride capture and interlayer integrity while also providing US’060’s pressure-responsive gas-discharge feature. No express criticism, discrediting, or discouragement of the proposed US’060 modification is found in JP’390.
Applicant’s alleged teaching-away argument is therefore not persuasive.
Non-Analogous Art Argument
Applicant argues that JP’951 is directed to transparent water-absorbent packaging rather than battery lead films and is therefore non-analogous art.
The argument is not persuasive.
Even though JP’951 is not limited to battery lead-terminal films, JP’951 is reasonably pertinent to the moisture-ingress problem expressly addressed by JP’390.
JP’390 states that ingress of moisture reduces the sealing strength of the battery thermal-bonding portion. JP’390 further discusses a nonaqueous electrolyte battery in which a hygroscopic agent is sandwiched between laminate layers to prevent moisture from entering the battery. JP’390 (Pg. 3, lines 11–29). JP’390 therefore expressly directs a person skilled in the art toward hygroscopic material incorporated in a heat-sealable battery laminate as a solution to moisture ingress.
JP’951 teaches a heat-sealable multilayer film that absorbs moisture entering from outside a package and moisture present within the packaged internal space. JP’951 (Pg. 1, lines 12–20). JP’951 further identifies electrical parts among the products to which its moisture-protective packaging may be applied. JP’951 (Pg. 1, lines 23–28).
JP’951’s water-absorbing layer is positioned between heat-sealing layers and contains an inorganic water-absorbing agent dispersed in thermoplastic resin. JP’951 (Pg. 2, lines 28–43); (Pg. 3, lines 32–40). These teachings are directly pertinent to JP’390’s express problem of moisture entering a thermoplastic multilayer battery seal.
Thus, JP’951 would logically have commended itself to the attention of a person addressing JP’390’s moisture-ingress and seal-deterioration problem. JP’951 is therefore reasonably pertinent to the problem faced by the inventor and is analogous art for the proposed modification.
US’060 presents an even closer relationship to JP’390. JP’390 and US’060 are in the same field of endeavor because both concern:
pouch-type secondary batteries;
electrode leads extending through a peripheral pouch seal;
heat-bondable sealing films or tapes positioned between the lead and pouch case; and
preservation or controlled release of the lead-sealing interface.
US’060 [0018]–[0019], [0058]–[0068].
Accordingly, Applicant’s non-analogous art argument does not overcome the new rejection.
Absorption of Moisture Versus Discharge of Gas
Applicant argues that JP’951 merely absorbs gaseous or liquid moisture and does not disclose discharge of gas generated inside a battery cell.
Applicant is correct that moisture absorption by JP’951 is not itself the same as external discharge of internally generated battery gas. However, the new rejection does not rely upon JP’951 for the gas-discharge limitation.
The respective references are applied as follows:
JP’390 discloses the pouch-battery lead seal and the first adhesive layer/intermediate layer/second adhesive layer structure.
JP’951 discloses the getter-containing moisture-removal layer between heat-sealing layers.
US’060 discloses the electrode-tab connection and the pressure-responsive venting pattern formed in the heat-bondable lead sealing tape.
US’060, rather than JP’951, expressly teaches discharge of gas generated inside the pouch cell. US’060 [0018]–[0019], [0066]–[0068], [0076], [0089].
Accordingly, Applicant’s distinction between absorption and discharge does not identify an error in the new rejection.
Impermissible Hindsight Argument
Applicant argues that the rejection uses the present disclosure as a roadmap and that a person skilled in the art would not have combined the applied references.
The argument is not persuasive because the reasons for the modifications arise from the prior-art references themselves.
JP’390 identifies moisture ingress and moisture-generated hydrogen fluoride as causes of deterioration of the lead-terminal sealing bond. JP’390 (Pg. 1, lines 19–31); (Pg. 3, lines 11–40). JP’390 further discusses incorporating a hygroscopic agent between battery laminate layers to prevent moisture ingress. JP’390 (Pg. 3, lines 22–29).
JP’951 expressly teaches absorbing moisture entering from outside and moisture within a packaged internal space using an intermediate water-absorbing layer positioned between heat-sealing layers. JP’951 (Pg. 1, lines 12–20); (Pg. 2, lines 28–43); (Pg. 7, lines 29–34). Thus, the reason to incorporate JP’951’s MOF water absorber into JP’390’s intermediate layer is expressly supplied by the references: intercepting moisture that contributes to the seal-deterioration mechanism identified by JP’390.
US’060 expressly identifies gas generated inside a pouch case as a battery-safety problem and teaches solving that problem by forming a venting notch or through-hole in the heat-bondable sealing tape at the electrode-lead seal. US’060 [0018]–[0019], [0065]–[0068], [0076]. Thus, the reason to apply US’060’s venting pattern to JP’390’s lead terminal bonding film also arises expressly from the prior art: providing controlled discharge of internally generated gas at the same lead-sealing location.
The modification does not require knowledge of Applicant’s disclosure. The prior art itself identifies:
moisture ingress at the pouch-cell lead seal;
water-absorbing material between heat-sealing layers; and
pressure-responsive gas venting through a heat-bondable lead sealing tape.
The rejection therefore rests on express teachings and problems identified in the references, rather than on unsupported general knowledge or hindsight reconstruction.
For the reasons above, applicant’s arguments have been fully considered but are not persuasive against the newly applied combination.
Conclusion
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/JIMMY VO/
Primary Examiner
Art Unit 1723
/JIMMY VO/Primary Examiner, Art Unit 1723
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