Prosecution Insights
Last updated: August 15, 2026
Application No. 18/029,335

BATTERY RACK AND ENERGY STORAGE SYSTEM COMPRISING SAME

Final Rejection §103
Filed
Mar 29, 2023
Priority
Jul 16, 2021 — RE 10-2021-0093531 +1 more
Examiner
NEWELL, ANNA GOULD
Art Unit
1726
Tech Center
1700 — Chemical & Materials Engineering
Assignee
LG Energy Solution Ltd.
OA Round
2 (Final)
52%
Grant Probability
Moderate
3-4
OA Rounds
2m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 52% of resolved cases
52%
Career Allowance Rate
12 granted / 23 resolved
-12.8% vs TC avg
Strong +48% interview lift
Without
With
+48.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
26 currently pending
Career history
73
Total Applications
across all art units

Statute-Specific Performance

§103
57.1%
+17.1% vs TC avg
§102
17.2%
-22.8% vs TC avg
§112
25.4%
-14.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 23 resolved cases

Office Action

§103
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 . Response to Amendment The amendment filed on May 11th 2026 is acknowledged. Claims 1-2, 4, & 7-14 remain pending in the application. Claims 3, 5, & 6 were cancelled by the Applicant. Applicants amendments to the claims have overcome the previous 112(b) rejections, thus those rejections have been withdrawn. Applicant’s amendments to Claim 1 have overcome the previous 102 rejection in view of Lee et al US 2018/0316070 A1 and in view of Nakai et al. JP 2019/029245 A, therefore those rejections have been withdrawn. Applicant’s arguments to the previous rejections of the claims were fully considered but are not persuasive. Upon further consideration, a new grounds of rejection is made in view of Nakai et al. JP 2019/029245 A, and further in view of Lee US 2019/0351268 A1 (herein referred to as “Lee ‘268”) and Yamamoto WO 2020/152858 A1. New rejections follow. 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. Claims 1-2, 4, 7, 8, & 14 is rejected under 35 U.S.C. 103 as being unpatentable over Nakai et al. JP 2019/029245 A, and further in view of Lee US 2019/0351268 A1 (herein referred to as “Lee ‘268”) and Yamamoto WO 2020/152858 A1. Citations to Nakai and Yamamoto are mapped to the English translations provided. Regarding Claim 1, 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_image1.png 497 712 media_image1.png Greyscale Nakai Annotated Figure 1 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_image2.png 403 553 media_image2.png Greyscale Nakai Annotated Figure 9 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_image3.png 474 628 media_image3.png Greyscale Nakai Annotated Figure 6 Nakai is silent as to the coolant injection holes disposed at a 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 to allow a coolant into the battery pack when injecting the coolant into the battery pack frame, which is further illustrated in Lee ‘268 Figure 1. PNG media_image4.png 330 485 media_image4.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, thereby allowing coolant into the battery pack when injecting coolant into the battery pack frame. Modified 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 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. This is shown in Annotated Nakai Figure 1 & Yamamoto Figure 5 below. PNG media_image5.png 882 1584 media_image5.png Greyscale Annotated Nakai Figure 1 (left) & Yamamoto Figure 5 (right) 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 spaced apart from the bottom plate due to the flange portions of the frame members, thus Yamamoto discloses that the battery pack (battery module) is spaced a distance apart from the inner lower surface of the frame (bottom plate). PNG media_image6.png 556 675 media_image6.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 frame of Nakai, such that the bottom plate acts as the inner lower surface of the frame and thus the battery pack is thus spaced apart from the inner lower surface of the frame due to the flange portions of the frame members (as shown in both Nakai and Yamamoto above), for the benefit of having an insulating structure capable of withstanding high operating voltage. Thus, modified Nakai discloses a structure for the battery pack wherein when a coolant fills the battery pack frame, the coolant is thus injected into the battery pack through the coolant injection holes, as modified by Lee ‘268 above. Regarding Claim 2, modified 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 an overheat occurs (in this case, when internal gas is ignited and a fire occurs, which generates heat), 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_image7.png 558 801 media_image7.png Greyscale Nakai Annotated Figure 5 Regarding Claim 4, as mentioned above with regards to Claim 1, modified Nakai with the modification of Lee ‘268 discloses that the battery pack has a plurality of coolant injection holes disposed in each of the upper surface (as disclosed by Nakai [Figure 6 above]) and the lower surface (As modified by the perforated plate of Lee ‘268). 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. 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, Nakai discloses an energy storage system using the battery rack [0064]. Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over Nakai, Lee ‘268, and Yamamoto 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, Lee ‘268, and Yamamoto as applied to claim 1 above, and further in view of Yoon US 2010/0215999 A1. Regarding Claim 10, modified 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, Lee ‘268, and Yamamoto as applied to claim 1 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 1, 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, Lee ‘268, and Yamamoto as applied to claim 1 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 1, 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. Response to Arguments Applicant argues that Yamamoto does not disclose or suggest that the battery pack is spaced apart from the inner lower surface of the battery pack frame, which Applicant specifies is due to a seat protrusion member being disposed in the through hole of the frame member. Examiner respectfully points out that as stated in the rejection of amended claim 1 above, the modification of Nakai with the disclosure of Yamamoto is simply to incorporate the bottom plate of the frame of Yamamoto into the battery pack frame of Nakai. Examiner points out that the modification is not incorporating the seat protrusion member or any other component of Yamamoto’s battery pack frame in the battery pack frame of Nakai. Thus, this argument is irrelevant to the rejection. Accordingly, for the reasons stated above, this argument is unpersuasive. Conclusion Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANNA G NEWELL 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.G.N./Examiner, Art Unit 1726 /DANIEL P MALLEY JR./Primary Examiner, Art Unit 1726
Read full office action

Prosecution Timeline

Mar 29, 2023
Application Filed
Mar 20, 2026
Non-Final Rejection mailed — §103
May 11, 2026
Response Filed
Jun 25, 2026
Final Rejection mailed — §103 (current)

Precedent Cases

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Prosecution Projections

3-4
Expected OA Rounds
52%
Grant Probability
99%
With Interview (+48.2%)
3y 7m (~2m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 23 resolved cases by this examiner. Grant probability derived from career allowance rate.

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