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 .
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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 8/25/2026 has been entered.
Claim Status
Claims 1, 12, and 16 have been amended; support is found in figure 4b.
Claims 1-20 are currently pending.
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 2-11 and 13-15 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.
In claims 2 and 13, applicant recites further comprising an inner guide bracket and a top flange and a bottom flange however this are already stated in claims 1 and 12 respectively. It appears that the inner guide has been amended into claim 1, therefore this is redundant.
Claims 3-11 and 14-15 are rejected for dependency on claims 2 and 13 respectively.
Claim Rejections - 35 USC § 103
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.
Claim(s) 1, 2, 4-7, 11-13, 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over 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),
an inner guide bracket (center piece 206) disposed between plural one of the cell array (figure 10) having a top flange and a bottom flange
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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Janarthanam et al. discloses the center piece 206 to have an upper and lower flange see figure above but does not mention the width of the bottom flange is larger than the top flange.
It has been held that the configuration or shape of a claimed device is a matter of choice which a person of ordinary skill in the art would have found obvious absent persuasive evidence that the particular configuration of the claimed device is significant. In re Dailey, 357 F.2d 669, 149 USPQ 47 (CCPA 1966).
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 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.
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 the 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)).
an inner guide bracket (center piece 206) disposed between plural one of the cell array (figure 10) having a top flange and a bottom flange
Janarthanam et al. discloses the center piece 206 to have an upper and lower flange see figure above but does not mention the width of the bottom flange is larger than the top flange.
It has been held that the configuration or shape of a claimed device is a matter of choice which a person of ordinary skill in the art would have found obvious absent persuasive evidence that the particular configuration of the claimed device is significant. In re Dailey, 357 F.2d 669, 149 USPQ 47 (CCPA 1966).
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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 of 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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Janarthanam et al. discloses the center piece 206 to have an upper and lower flange see figure above but does not mention the width of the bottom flange is larger than the top flange.
It has been held that the configuration or shape of a claimed device is a matter of choice which a person of ordinary skill in the art would have found obvious absent persuasive evidence that the particular configuration of the claimed device is significant. In re Dailey, 357 F.2d 669, 149 USPQ 47 (CCPA 1966).
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.
.
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 with respect to claim(s) regarding the newly added limitation have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Applicant's arguments filed 7/29/2026 have been fully considered but they are not persuasive.
Applicant argues that a rib protruding from WEB to extend in the longitudinal direction of the inner guide bracket is not taught by Obashi’s fins because the fins are not used to reinforce the rigidity of the guide. (Page 8)
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).
Applicant argues that the contact part be connected to the WEB in the range of 0.5H to 1H of the WEB (page 8).
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 provided and date to prove the criticality of the claimed range.
Conclusion
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.
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/Maria Laios/Primary Examiner, Art Unit 1727