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
This office action is in response to the amendment and remarks filed 2/12/2026.
Claims 18-20 have been added; support is found in original claims and figure
Claim 16 has been amended.
Claims 1-20 are currently pending.
Claim Rejections - 35 USC § 102
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(s) 1, 2, 4, 6, 7, 11-13 and 16 is/are rejected under 35 U.S.C. 102a1 as being anticipated by Janarthanam et al. (US 2015/0263397 A1).
As to claim 1, Janarthanam et al. discloses a battery module assembly (figure 10), comprising:
a cell array (202 and 203) configured by stacking a plurality of cells (figure 10) in a same direction (figure 10); and a side plate (208) connected to one lateral side of the cell array (figure 10) to pressurize the cell array ([0042, 0046] discloses the thermal plate is in contact with the cell array thus configured to retain the battery cells which can pressurize the cell along with retainer segments), wherein plural ones (202 and 203) of the cell array are connected in a transverse direction to form a multi-row structure (figure 10).
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As to claim 2, Janarthanam et al. discloses the battery module assembly of claim 1, further comprising an inner guide bracket (center piece 206) disposed between the plural ones of the cell array (figure 10), wherein the inner guide bracket has an I-type cross-section with a top flange and a bottom flange (see annotated figure below).
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As to claim 4, Janarthanam et al. discloses the battery module assembly of claim 2, wherein the inner guide bracket comprises a cell contact part connected to a WEB to contact the cell array (figure 10b depicts the cell adjacent the inner guide bracket).
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As to claim 6, Janarthanam et al. discloses the battery module assembly of claim 2, wherein the bottom flange of the inner guide bracket is configured to support the cell array (since the flange touches the cell array it supporting the cell array), and a bottom side of the top flange is configured to contact the cell array (figure 10b).
As to claim 7, Janarthanam et al. discloses the battery module assembly of claim 2, further comprising side guide brackets disposed adjacent to outermost transverse surfaces of the plural ones of the cell array (see annotated figure below), wherein each of the side guide brackets comprises a bottom support portion (numbered 206) supporting a bottom side of the cell array (see figure below).
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As to claim 11, Janarthanam et al. discloses the battery module assembly of claim 2, wherein the cells comprise prismatic battery cells (figure 10a).
As to claim 12, Janarthanam et al. discloses a method of manufacturing a battery module, the method comprising:
configuring at least two cell arrays (202, 203) by stacking (Figure 10a), for each of the at least two cell arrays, a plurality of battery cells in a same direction (figure 10a);
forming a multi-row structure by connecting the at least two cell arrays in a transverse direction (figure 10a, [0041]; and
cinching sides of the at least two cell arrays disposed in the multi-row structure with a side plate (208-thermal plate [0042]-maximizing contract of the battery cell and thermal plate thus cinching the cells)).
As to claim 13, Janarthanam et al. discloses the method of claim 12, wherein the forming of the multi-row structure (figure 10a or 10b) comprises disposing an inner guide bracket having an I-type cross section (solid box in figure below) with a top flange and a bottom flange between the at least two cell arrays (see figure below).
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As to claim 16, Janarthanam et al. discloses a battery module assembly (figure 10a), comprising: a cell array (202, 203) having a plurality of cells stacked in a same direction (figure 10a);
a side guide bracket disposed adjacent to a lateral side of the cell array; and
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an inner guide bracket disposed between plural ones of the cell array (see figure below, inner guide within solid lined box),
wherein the plural ones (202,203) of the cell array are arranged in a transverse direction, wherein the inner guide bracket includes an I-type cross-section having a top flange and a bottom flange and extends in a longitudinal direction of the cell arrays (figure 10a), wherein the top flange is configured to contact a top side of the cell array, and wherein the bottom flange is configured to contact a bottom side of the cell array (see annotated figure below).
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Claim Rejections - 35 USC § 103
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(s) 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Janarthanam et al. (US 2015/0263397 A1).
As to claim 5, Janarthanam et al. discloses the battery module assembly of claim 4, with the contact part connected to the WEB as is shown in the figure below
but does not disclose the contact part is connected to the WEB in a range of 0.5 H to 1 H of a height (H) of the WEB.
However, it has been held that where the only difference between the prior art and the claims was a recitation of relative dimensions of the claimed device and a device having the claimed relative dimensions would not perform differently than the prior art device, the claimed device was not patentably distinct from the prior art device. In re Rose , 220 F.2d 459, 105 USPQ 237 (CCPA 1955); In re Rinehart, 531 F.2d 1048, 189 USPQ 143 (CCPA 1976); In Gardner v. TEC Systems, Inc., 725 F.2d 1338, 220 USPQ 777 (Fed. Cir. 1984), cert. denied, 469 U.S. 830, 225 USPQ 232 (1984). Also see MPEP 2144. In this case, it appears that the contact part and the WEB is the same height.
Claim(s) 3, 8-10, 14-15 and 17 is/are rejected under 35 U.S.C. 103 as being unpatentable over Janarthanam et al. (US 2015/0263397 A1) in view of Obasih et al. (US 2012/0244404 A1).
As to claim 3, Janarthanam et al. discloses the battery module assembly of claim 2, wherein the inner guide bracket with a WEB as is shown in figure below but does not disclose a rib protruding from a WEB to extend in a longitudinal direction of the inner guide bracket.
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Obasih discloses a battery module with a thermal management system (750) and disclose the WEB portion (base 754) of the heat sink with ribs (fins) extending from thereon (figure 13, [0154]) which allows the thermal management fluid to pass between the fins to cool or heat the heat sink and thus the battery cells [0155].
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the fins of Obasih to the thermal plates of Janarthanam et al. because this would allow for heating or cooling of the battery cells.
As to claim 8, Janarthanam et al. discloses the battery module assembly of claim 7, wherein each of the side guide brackets is configured to extend in a longitudinal direction of the cell array (see figure 10a) and comprises but does not disclose a plurality of ribs formed on an outer surface of each of the side guide brackets, and each of the ribs is spaced apart from another by a prescribed interval in a vertical direction.
Obasih discloses a battery module with a thermal management system (750) and disclose the WEB portion (base 754) of the heat sink with ribs (fins) extending from thereon (figure 13, [0154]) with vertical spacing which allows the thermal management fluid to pass between the fins to cool or heat the heat sink and thus the battery cells [0155].
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the fins of Obasih to the thermal plates of Janarthanam et al. because this would allow for heating or cooling of the battery cells.
As to claim 9, Janarthanam et al. discloses the battery module assembly of claim 8, wherein each of the side guide brackets comprises a cell contact part connected to an inner surface (172)to contact with the cell array [0037], and wherein the cell contact part is a semi-solid type ([0037] disclose the thermal interface material enhances heat transfer between the battery cell array and the thermal plates filling, for example, voids and/or air gaps between the battery cells thus being semi solid type.
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the thermal interface material because it enhances heat transfer between the battery cell array and the thermal plates filling, for example, voids and/or air gaps between the battery cells.
As to claim 10, Janarthanam et al. discloses the battery module assembly of claim 8, and Obasih further comprising a tightening band (734-bands) disposed outside of the side guide bracket along the prescribed interval of the ribs(figure 13 of Obasih) to enclose and tighten outer surfaces of the plural ones of the cell array ([0151], the bands 734 are placed in tension (stretched or tightened) to exert a clamping force), wherein the tightening band is made of a metal material ([0150]-spring steel).
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the bands of Obasih to exert a clamping force on the plurality of cells.
As to claim 14, Modified Janarthanam discloses the method of claim 13 with the inner guide bracket having a WEB, but is silent to the inner guide bracket comprises a rib protruding from a WEB to extend in a longitudinal direction of the inner guide bracket.
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Obasih discloses a battery module with a thermal management system (750) and disclose the WEB portion (base 754) of the heat sink with ribs (fins) extending from thereon (figure 13, [0154]) which allows the thermal management fluid to pass between the fins to cool or heat the heat sink and thus the battery cells [0155].
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the fins of Obasih to the thermal plates of Janarthanam et al. because this would allow for heating or cooling of the battery cells.
As to claim 15, Modified Janarthanam discloses the method of claim 14, wherein the inner guide bracket comprises a cell contact part connected to the WEB to contact with the cell array (see figure below).
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As to claim 17, Janarthanam et al. discloses the side guide bracket but does not disclose the side guide bracket comprises a guide on an outer surface to indicate a position of a tightening band, and wherein the tightening band cinches lateral sides of the cell arrays along the guide provided to the outer surface of the side guide bracket.
Obasih discloses a battery module with a thermal management system (750) and discloses a guide (735-groove or slot) on the outer surface to indicate a portion of a tightening band (734) and when the tightening band cinches lateral side of the cell arrays along the guide to the outer surface of the side guide bracket ([0151], the bands 734 are placed in tension (stretched or tightened) to exert a clamping force).
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the bands of Obasih to exert a clamping force on the plurality of cells.
As to claim 18. Janarthanam et al. discloses the battery module assembly of claim 1, but does not disclose a bind as is instantly claimed. Obasih further comprising a tightening band (734) configured to couple with the side plate to bind and pressurize the cell array, (Figure 12, [0151], the bands 734 are placed in tension (stretched or tightened) to exert a clamping force).
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the bands of Obasih to exert a clamping force on the plurality of cells.
As to claim 19, Janarthanam et al discloses the method of claim 12, but does not disclose wherein the cinching comprises disposing a tightening band around the multi-row structure to cooperate with the side plate to bind and pressurize the at least two cell arrays.
Obasih discloses a battery module with a thermal management system (750) and discloses a guide (735-groove or slot) on the outer surface to indicate a portion of a tightening band (734) and when the tightening band cinches lateral side of the cell arrays along the guide to the outer surface of the side guide bracket ([0151], the bands 734 are placed in tension (stretched or tightened) to exert a clamping force).
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the bands of Obasih to exert a clamping force on the plurality of cells.
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As to claim 20, Janarthanam et al discloses the battery module assembly of claim 16, but not further comprising a tightening band disposed externally around the cell arrays and configured to couple with the side guide bracket to pressurize the cell arrays.
Obasih discloses a battery module with a thermal management system (750) and discloses a guide (735-groove or slot) on the outer surface to indicate a portion of a tightening band (734) and when the tightening band cinches lateral side of the cell arrays along the guide to the outer surface of the side guide bracket ([0151], the bands 734 are placed in tension (stretched or tightened) to exert a clamping force).
Therefore it would have been obvious to one of ordinary skill in the art at the time the application was effectively filed to include the bands of Obasih to exert a clamping force on the plurality of cells.
Response to Arguments
Applicant's arguments filed 2/12/2026 have been fully considered but they are not persuasive.
Applicants’ argument is that the Prior art does not teach that the side plate connected to one lateral side of the cell array to pressurize the cell array or cinching side of the at least two cell arrays with a side plate ( page 5 of the arguments) and that the plate of Janarthanam is not used to function as a mechanical pressurizure or cinch for the stack.
The Examiner respectfully disagrees because Janarthanam discloses that the exo-support structure 200 with retainer segments 206 [0041] and thermal plate are used to support the cells thus would provide some pressurization otherwise the thermal contact would not occur which would then not allow for thermal communication. There for the side plate would provide some pressurization to the cells. Furthermore, it is well known that batteries expand at times therefore the side plate would provide pressurization.
Applicant also argues that the side plate works in cooperation with other components such as the band to apply pressure.
So applicant appears to be suggesting, that the side plate itself does not provide the pressure but the combination with the band would cause the pressurization, however the independent claims do not portray this feature.
In response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., band to apply pressure) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
Applicant argues that the center piece is not a I type cross section.
The Examiner disagrees as can be seen below there is an I beam with upper and lower flanges. (page 6)
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Applicant argues that the fins of Obasih are for thermal management and dot for a structural purpose.
In response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., rib is for providing structure or rigidity) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
Applicant argues that the contact part is connected to the WeB in a range of 0.5H to 1 H the where H is the height of the WEB (page 6-7).
From the figure it appears that the contact part and the WEB is the same height thus reading on the claim. Furthermore applicant has not provide and data to prove the criticality of the claimed range.
Applicant argues that combination of Janarthanam and Obasih would not yield the claimed invention because A. the ribs function as guides, B. applicant Tightening Band is a circumferential clamping system and C. The cell contact part is semi solid type.
With respect to the ribs, the ribs/fins would extend from the surface and thus provide guidance in addition to allowing thermal management fluid to pass between the fins to cool or heat the heat sink and thus the battery cells. In response to applicant's argument that the fins would not be for guiding, the fact that the inventor has recognized another advantage which would flow naturally from following the suggestion of the prior art cannot be the basis for patentability when the differences would otherwise be obvious. See Ex parte Obiaya, 227 USPQ 58, 60 (Bd. Pat. App. & Inter. 1985). In this case, the fins provide a protrusion from the surface which is the same structure as applicant thus can be used for guidance. The tightening band is circumferentially clamping the batteries In response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., the band is circumferentially place on the battery cells) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). In response to the semi solid contact part, there is a thermal interface material thus providing a semi solid type since it is there to go within the voids or air gaps.
Conclusion
THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the mailing date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MARIA J LAIOS whose telephone number is (571)272-9808. The examiner can normally be reached Monday-Thursday 10am-6pm.
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, Barbara Gilliam can be reached at 571-272-1330. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/Maria Laios/Primary Examiner, Art Unit 1727
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