Prosecution Insights
Last updated: April 19, 2026
Application No. 18/029,335

BATTERY RACK AND ENERGY STORAGE SYSTEM COMPRISING SAME

Non-Final OA §102§103§112
Filed
Mar 29, 2023
Examiner
GOULD, ANNA ELIZABETH
Art Unit
1726
Tech Center
1700 — Chemical & Materials Engineering
Assignee
LG Energy Solution, Ltd.
OA Round
1 (Non-Final)
42%
Grant Probability
Moderate
1-2
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 42% of resolved cases
42%
Career Allow Rate
5 granted / 12 resolved
-23.3% vs TC avg
Strong +66% interview lift
Without
With
+65.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
63 currently pending
Career history
75
Total Applications
across all art units

Statute-Specific Performance

§103
54.2%
+14.2% vs TC avg
§102
18.2%
-21.8% vs TC avg
§112
26.8%
-13.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 12 resolved cases

Office Action

§102 §103 §112
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 Objections Claim 1 is objected to because of the following informalities: Claim 1 recites “of which a predetermined capacity consumed”. Examiner believes this is meant to read “of which a predetermined capacity is consumed”. 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. 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. Claim 1 recites “at least one battery pack used for a predetermined period of time or of which a predetermined capacity consumed”. It is unclear what exactly Applicant is referring to as the “predetermined period of time” as there is no other limitation providing a definition for the “predetermined period of time”, and thus the claim is unclear and indefinite. Additionally, it is unclear what Applicant is referring to as the “predetermined capacity consumed” as there is no other limitation providing a definition for the “predetermined capacity consumed”, and thus the claim is unclear and indefinite. Examiner notes that in the absence of a definition for “a predetermined period of time” and “ a predetermined capacity consumed”, the claim was understood to mean that the battery pack is capable of use for a period of time or capable of capacity consumption. Appropriate correction is required. Claims 2-14, as they depend from Claim 1, are indefinite for the same reasons. Claim 2 recites “when an abnormal situation occurs”. It is unclear what exactly Applicant is referring to as an “abnormal situation”, and thus it is unclear under what conditions the coolant would be injected into the battery pack frame and submerge the battery pack. Thus, the claim is unclear and indefinite. Examiner notes that Claim 2 was understood to mean, in the absence of a more direct definition of “when an abnormal situation occurs”, that the battery rack is capable of having cooling injected into the battery pack frame and submerging the battery pack. Appropriate correction is required. Claim 2 recites “the at least one battery pack is submerged in the coolant at a predetermined depth”. It is unclear what exactly Applicant is referring to as “a predetermined depth”, and thus the claim is unclear and indefinite. Appropriate correction is required. Claim 6 recites “spaced a predetermined distance apart”. It is unclear what exactly Applicant is referring to as “a predetermined distance”, and thus the claim is unclear and indefinite. Appropriate correction is required. Claim 7 recites “the predetermined distance”. It is unclear what exactly Applicant is referring to as “the predetermined distance”, and thus the claim is unclear and indefinite. Appropriate correction is required. Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. Claims 1-2, 12 & 14 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Lee et al US 2018/0316070 A1 (herein referred to as “Lee ‘070”). Regarding Claim 1, as best understood by the examiner, Lee ‘070 discloses a battery rack (battery pack) [Abstract] comprising At least one battery pack (battery cell assembly having at least one battery cell) [Abstract] Lee ’070 discloses that the battery pack is capable of charge/discharge capacity [0004] A battery pack frame (battery pack casing) accommodating the at least one battery pack [Abstract, 0039] The battery pack frame has a greater height than the battery pack (as shown in Lee ‘070 Annotated Figures 2 & 3 below PNG media_image1.png 428 1161 media_image1.png Greyscale Lee ‘070 Annotated Figures 2 & 3 Regarding Claim 2, as best understood by the examiner, Lee ‘070 discloses that the battery pack frame (pack casing) comprises an input port and an output port so that coolant flows in and out of the pack casing to cool each battery cell [0011], see Figure 2 “inlet port” Item 211 and “outlet port” Item 212. Lee ‘070 further discloses that the battery pack frame accommodates the battery cell assembly and the coolant [0037], and when the coolant is supplied into the battery pack frame the battery cells are immersed in the coolant [0055]. Thus, Lee ‘070 discloses that the battery rack is capable of introducing a coolant into the battery pack frame wherein the battery pack is submerged in the coolant. Regarding Claim 12, Lee ‘070 discloses that the battery rack is used in a vehicle [0001, 0010]. Regarding Claim 14, Lee ‘070 discloses an energy storage system using the battery rack [0033]. Claims 1-4, 8, & 14 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Nakai et al. JP 2019/029245 A. Citations to Nakai are mapped to the English translation provided. Regarding Claim 1, as best understood by the examiner, Nakai discloses a battery rack (power storage device) [0023] comprising At least one battery pack (plurality of power storage elements) [0023] A battery pack frame (holding members Figure 1 Item 3) accommodating the at least one battery pack [0023] Nakai illustrates in Annotated Figure 1 that the frame (holding members) have a greater height than the battery pack (power storage elements): PNG media_image2.png 497 712 media_image2.png Greyscale Nakai Annotated Figure 1 Regarding Claim 2, as best understood by the examiner, Nakai discloses that the battery pack frame (pack casing) comprises a pipeline (Figure 1 Item 6) for supplying a fire extinguishing agent to the battery pack [0023, 0044], as shown in Nakai Annotated Figure 5 below. Nakai discloses that when a certain condition is met (in this case, when internal gas is ignited and a fire occurs), an extinguishing agent is released into the battery pack frame [0011]. As shown in Annotated Figure 5 below, Nakai discloses that the fire extinguishing agent is released into the battery pack frame, which would submerge the battery pack in the fire extinguishing agent. Thus, Nakai discloses that the battery rack is capable of introducing a coolant (fire extinguishing agent) into the battery pack frame wherein the battery pack is submerged in the coolant. PNG media_image3.png 558 801 media_image3.png Greyscale Nakai Annotated Figure 5 Regarding Claim 3, Nakai discloses that the battery pack comprises a gas discharge valve (Figure 9 Item 1321) that is configured to open when the pressure inside the battery pack reaches a certain level [0032]. Thus, Nakai discloses that the battery pack comprises a hole. Nakai further discloses that the hole (gas discharge valve) in the battery pack corresponds to the coolant pipeline (Figure 9 Item 6) [0044], more specifically the through-holes (Figure 9 Items 611) of the coolant pipeline correspond to the holes in the battery pack [0047], and thus the coolant (extinguishing agent) is supplied from the pipeline through the through-holes and injected into the battery through the hole (gas discharge valve) [0044, 0050]. Thus, Nakai discloses a coolant injection hole (gas discharged valve) configured to inject coolant into the battery pack when the coolant is injected into the battery pack frame, further shown in Nakai Annotated Figure 9 below. PNG media_image4.png 403 553 media_image4.png Greyscale Nakai Annotated Figure 9 Regarding Claim 4, Nakai discloses that the battery pack (plurality of battery cells) has a plurality of coolant injection holes (each battery cell of the battery pack has a gas discharge valve), as shown in Nakai Annotated Figure 6, wherein the plurality of coolant injection holes are in the upper surface of the battery pack. PNG media_image5.png 474 628 media_image5.png Greyscale Nakai Annotated Figure 6 Regarding Claim 8, Nakai discloses that there is a feed pipe (pipeline Figure 1 Item 6) configured to feed the coolant [0023], wherein the feed pipe is disposed above the battery pack frame, as shown in Figure 1. Regarding Claim 14, Lee discloses an energy storage system using the battery rack [0064]. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claim 5 is rejected under 35 U.S.C. 103 as being unpatentable over Nakai as applied to claim 4 above, and further in view of Lee US 2019/0351268 A1 (herein referred to as “Lee ‘268”). Regarding Claim 5, Nakai discloses that the plurality of coolant injection holes is disposed on the upper surface of the battery pack (see Figure 6), as mentioned above with regards to Claim 4. Nakai is silent as to the plurality of coolant injection holes disposed on the lower surface of the battery pack. Lee ‘268 discloses a battery pack comprising a fire extinguishing system [Abstract], similar to that of Nakai. Lee ‘268 discloses that the battery pack comprises a plurality of battery cells and a fire extinguishing system that includes a storage unit, an inflow passage, and a perforated plate [0021], wherein the fire extinguishing agent is injected into the battery pack and distributed amongst the battery cells [0021]. Lee ‘268 discloses that the perforated plate (Figure 1 Item 140) comprises a plurality of opening holes (Figure 1 Items 141) that allow the fire extinguishing agent to flow into and around the battery cells [0049]. Thus, Lee ‘268 discloses coolant injection holes (opening holes in the perforated plate) on the lower surface of the battery pack, which is further illustrated in Lee ‘268 Figure 1. PNG media_image6.png 483 710 media_image6.png Greyscale Lee ‘268 Annotated Figure 1 Lee ‘268 discloses that the perforated plate with the opening holes allows for a uniform distribution of fire extinguishing agent across the plurality of battery cells in the battery pack [0050-0051], which prevents the issue of poor fire extinguishing effect on cells distant from the fire extinguishing unit [0050]. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to incorporate the perforated plate with opening holes on the lower surface of the battery pack as suggested by Lee ‘268 in the battery pack of Nakai for the benefit of uniform distribution of the cooling liquid (fire extinguishing agent). Thus, modified Nakai discloses a plurality of coolant injection holes (perforated plate with opening holes) on the lower surface of the battery pack. Claims 6 & 7 are rejected under 35 U.S.C. 103 as being unpatentable over Nakai as applied to claim 3 above, and further in view of Yamamoto WO 2020/152858 A1. Citations to Yamamoto are mapped to the English machine translation provided. Regarding Claim 6, as best understood by the examiner, Nakai discloses that the battery pack is disposed in the battery pack frame (holding members), as shown in Figure 1. However, Nakai fails to specifically disclose that the battery pack frame has an inner lower surface, and the battery pack is spaced “a predetermined distance” apart from the inner lower surface of the frame. Yamamoto discloses a battery pack including a battery module and a frame [Page 1 Lines 30-32]. Yamamoto discloses that the frame of the battery pack comprises side wall portions (Figure 5 items 42 A & B) [Page 8 Lines 32-33], similar to the frame (holding members) of Nakai. Yamamoto further discloses that the frame comprises a bottom plate (Figure 5 Item 48) [Page 9 Lines 30-31], wherein bottom plate is below the bottom of the battery module. Thus, Yamamoto discloses a frame having an inner lower surface (bottom plate). Further, as shown in Annotated Figure 5 below, Yamamoto discloses that the battery module is space apart from the bottom plate, thus Yamamoto discloses that the battery pack (battery module) is spaced “a predetermined distance” apart from the inner lower surface of the frame (bottom plate). PNG media_image7.png 507 636 media_image7.png Greyscale Yamamoto Annotated Figure 5 Yamamoto discloses that this configuration allows for an insulative sheet to be placed between the battery module and the bottom plate [Page 9 Lines 22-28], and thus has an insulating structure that is capable of withstanding high operating voltage [Page 1 Lines 26-28]. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to incorporate the bottom plate of Yamamoto in the battery rack of Nakai, such that the bottom plate acts as the inner lower surface of the frame and thus the battery pack is spaced apart from the inner lower surface of the frame, for the benefit of having an insulating structure capable of withstanding high operating voltage. Regarding Claim 7, as best understood by the examiner, modified Nakai is relied upon for the reasons given above in Claim 6. Further, Nakai discloses that the frame has an inner side surface with a pack support, as shown in Nakai Annotated Figure 2: PNG media_image8.png 453 668 media_image8.png Greyscale Nakai Annotated Figure 2 In a similar disclosure, Yamamoto illustrates a frame (Item 40) similar to the holding members of Nakai, also having inner side surfaces with pack supports (frame protrusion portions 54) as shown in Yamamoto Annotated Figure 5 below: PNG media_image9.png 507 636 media_image9.png Greyscale Yamamoto Annotated Figure 5 Yamamoto discloses that the inner side surfaces with pack supports (protrusions 54) support the bottom of the battery pack [Page 8 Line 57-Page 9 Line 4], which as shown in Figure 5, is at a distance from the bottom of the frame (Item 48). Thus, modified Nakai discloses that the frame comprises inner side surfaces with pack supports that support the battery pack at a distance spaced apart from the bottom of the battery pack frame. Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Nakai as applied to claim 8 above, and further in view of Ling US 2017/0043194 A1. Regarding Claim 9, Nakai is relied upon for the reasons given above in addressing Claim 8, however is silent as to the feed pipe including a sprinkler to spray the coolant onto the battery pack. Ling discloses a thermal event suppression system for a battery pack [Abstract], wherein a battery pack is housing in a battery housing and comprises a fire extinguisher media, nozzle, and pipe (conduit) for distributing the fire extinguishing media to the battery cells of the battery pack [0019]. Examiner notes that Ling’s “conduit” is similar to Nakai’s coolant feed pipe as mentioned above. Ling discloses that the nozzle (shown in Figure 5 Item 106) sprays the fire extinguishing media onto the battery pack [0022], and has the shape of a “sprinkler” as shown in Figure 5, also described in [0054]. PNG media_image10.png 546 508 media_image10.png Greyscale Ling Figure 5 Ling discloses that a nozzle such as this allows for proper transfer and dispersion of the fire extinguishing media over the batteries in the battery pack [0027]. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to incorporate the “sprinkler” shaped nozzle of Ling onto the coolant feed pipe of Nakai for proper transfer and dispersion of coolant over the batteries of the battery pack. Claims 10-11 are rejected under 35 U.S.C. 103 as being unpatentable over Nakai as applied to claim 3 above, and further in view of Yoon US 2010/0215999 A1. Regarding Claim 10, Nakai is relied upon for the reasons given above in addressing Claim 3, however is silent as to the battery pack frame further comprising a cable through-hole portion and an electrical cable passing through the cable through-hole portion that is connected to the battery pack. Yoon discloses a battery module comprising a plurality of battery cells and a module frame [0008]. Yoon discloses that the battery module comprises temperature sensors on the surface of the batteries, a conducting wire connected to the temperature sensors, and wire holes in the module frame through which the conducting wire passes [0008], as shown in Figure 3 of Yoon. Thus, Yoon discloses that the battery pack frame (module frame) has a cable through-hole portion (wire hole) and an electrical cable (conducting wire) that passes through the cable through-hole portion to connect to the battery pack (connects to the temperature sensors on the batteries). Additionally, Yoon further discloses a sealing member as part of the wiring path (conducting wire and wire hole) that surrounds the conducting wire in the through-hole so as to seal the wire hole [0008]. This is illustrated in Yoon Figure 3 below: PNG media_image11.png 688 800 media_image11.png Greyscale Yoon Annotated Figure 3 Yoon discloses that the temperature sensors enhance the cooling efficiency of the battery module [0007]. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to incorporate the temperature sensors comprising the wiring path (conducting wire and wire hole) of Yoon in the battery rack of Nakai to enhance the cooling efficiency of the battery rack. Thus, modified Nakai comprises temperature sensors with a wiring path, as modified by Yoon, and thus discloses a cable through-hole portion (wire hole) and an electrical cable (conducting wire) that passes through the cable through-hole portion and connects to the battery pack. Regarding Claim 11, as mentioned with regards to Claim 10 above, modified Nakai with the modification of Yoon discloses a battery rack with a temperature sensor and wiring path, wherein the wiring path further comprises a sealing member for sealing the conducting wire in the wire hole [Yoon 0008, Figure 3 Item 150]. Thus, modified Nakai discloses a cable sealing member mounted in the cable through-hole portion. Claim 12 is rejected under 35 U.S.C. 103 as being unpatentable over Nakai as applied to claim 3 above, and further in view of Oh et al. US 2019/0097288 A1. Regarding Claim 12, Nakai is relied upon for the reasons given above in addressing Claim 3, however fails to specifically disclose that the battery rack is used in an electric vehicle or a hybrid vehicle. Oh discloses a battery module and a cooling system [Abstract]. Oh discloses more specifically that the battery module comprises multiple batteries accommodated in a casing [0041, 0044], and the cooling system comprises a flow tube and injection nozzles for distributing cooling liquid to the batteries [0043], similar to the battery pack and cooling system of Nakai described above. Oh discloses that the battery module is used in an electric vehicle [0038-0039]. Oh discloses that when an electric vehicle uses a battery module with a cooling system such as this, the mileage of the electric vehicle can be increased [0024]. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to use the battery of Nakai in an electric vehicle, as suggested by Oh, for the benefit of efficiently cooling the battery of an electric vehicle thereby increased the mileage capabilities of the electric vehicle. Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Nakai as applied to claim 3 above, and further in view of Lee US 2022/0376354 A1 (herein referred to as “Lee ‘354”). Regarding Claim 13, Nakai is relied upon for the reasons given above in addressing Claim 3, however fails to specifically disclose that the battery rack comprises a plurality of battery packs stacked on top of each other in a height direction and electrically connected to each other. Lee ‘354 discloses a battery pack comprising multiple battery modules, which each include multiple battery cells, and a fire extinguishing system that distributed fire extinguishing agent to each of the battery modules [Abstract], similar to the battery system of Nakai as mentioned above. Lee ‘354 further discloses that each of the battery modules, which Examiner points out is read similarly to Nakai’s battery pack, is stacked in the vertical direction [0086], as further shown in Lee ‘354’s Figure 1 below: PNG media_image12.png 645 688 media_image12.png Greyscale Lee ‘354 Annotated Figure 1 Lee ‘354 discloses that the battery pack is used in large-scale applications [0166], which Lee previously discloses includes vehicles [0005]. Lee ‘354 discloses that when multiple battery modules are connected such as illustrated above in Figure 1 (stacked on top of each other) to create a battery pack for large-scale applications such as a vehicle, the capacity and output increases [0005]. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to modify the configuration of Nakai to have the configuration of Lee ‘354 such that multiple battery packs are stacked on top of one another, as suggested by Lee ‘354, for the benefit of increased capacity and output of the battery pack. Thus, modified Nakai discloses that the battery rack comprises a plurality of battery packs (as shown in Lee ‘354 Figure 1 above) that are electrically connected to each other [Lee ‘354 0005] and the battery packs are stacked on top of each other in a height direction [Lee ‘354 0086], as further shown in Lee ‘354 Figure 1 above. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANNA E GOULD whose telephone number is (571)270-1088. The examiner can normally be reached Monday-Friday 9:00am-5:00pm. 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, Jeffrey T. Barton can be reached at (571) 272-1307. 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. /A.E.G./Examiner, Art Unit 1726 /DANIEL P MALLEY JR./Primary Examiner, Art Unit 1726
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Prosecution Timeline

Mar 29, 2023
Application Filed
Mar 16, 2026
Non-Final Rejection — §102, §103, §112 (current)

Precedent Cases

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2y 5m to grant Granted Feb 10, 2026
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Prosecution Projections

1-2
Expected OA Rounds
42%
Grant Probability
99%
With Interview (+65.7%)
3y 4m
Median Time to Grant
Low
PTA Risk
Based on 12 resolved cases by this examiner. Grant probability derived from career allow rate.

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