Prosecution Insights
Last updated: April 19, 2026
Application No. 18/090,116

BATTERY ENCLOSURES FOR ELECTRIC VEHICLES

Non-Final OA §103
Filed
Dec 28, 2022
Examiner
MCNULTY, SEAMUS PATRICK
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
2 (Non-Final)
52%
Grant Probability
Moderate
2-3
OA Rounds
3y 5m
To Grant
94%
With Interview

Examiner Intelligence

Grants 52% of resolved cases
52%
Career Allow Rate
16 granted / 31 resolved
-13.4% vs TC avg
Strong +42% interview lift
Without
With
+41.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
60 currently pending
Career history
91
Total Applications
across all art units

Statute-Specific Performance

§103
63.5%
+23.5% vs TC avg
§102
22.8%
-17.2% vs TC avg
§112
13.3%
-26.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 31 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 amendments filed 10/24/2025 have been entered. The amendments do overcome the prior 102 and 103 rejection as set forth in non-final office action mailed 07/24/2025. New grounds of rejection are outlined below. 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. Claims 1-5, and 7-12 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20200398652-A1) hereinafter referred to as ‘Stephens’ in view of (US-20240039076-A1) hereinafter referred to as ‘Kragh’ in further view of (US-20110244298-A1) hereinafter referred to as ‘Guener’. Regarding Claim 1, Stephens teaches a battery enclosure to house a battery pack of an electric vehicle, the battery enclosure comprising (Stephens, battery tray, 10, Fig. 2) : a bottom plate including at least a top surface and a bottom surface (Stephens, panel section, 32, Fig. 2A) ; a battery pack including multiple batteries or battery modules configured to store energy for the electric vehicle (Stephens, battery modules, 414, Fig. 11) ; a frame enclosure at least partially surrounding the battery pack, the frame enclosure connected with the bottom plate (Stephens, peripheral frame member, 26. Fig. 2A) , the frame enclosure including at least a first side wall and a second side wall opposite the first side wall (Stephens, peripheral frame member, 26. Fig. 2A); multiple cross members, each cross member extending between the first side wall and the second side wall (Stephens cross member portions, 48, Fig. 2A) ; and a top plate configured to cover the multiple structural cross members and at least a portion of the battery pack, the top plate connected with the frame enclosure (Stephens, “The battery support tray may also include a protective cover that is disposed over the tray floor to enclose a battery containment area for the battery modules.”, see [0007]) Stephens does not teach the top plate including multiple ridges protruding from a top surface of the top plate, each ridge defining a channel extending parallel to the top surface of the top plate, and each channel configured to facilitate flow of a heat transfer medium through the channel. Kragh teaches top plate including each ridge defining a channel extending parallel to the top surface of the top plate, and each channel configured to facilitate flow of a heat transfer medium through the channel (Kragh, “The main parts, i.e. a thermal structural element, utilize extruded profiles that function as structure, battery fixation and battery cooling with cooling channels”, see [0004]). Kragh teaches that this allows for heat to be successfully transferred in plane while allowing for material savings (Kragh, “cooling fluid/gas integrated and the profiles are thermally connected to the ends of the batteries, utilising the battery cells ability to efficiently transfer heat “in-plane”, i.e. from the top end or bottom end of the batteries… resulting in further savings of material, weight and cost, also resulting in quick assembly and disassembly.”, see [0004]) Stephens and Kragh are analogous as they both relate to a battery module and battery structures. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cover of Stephens with the channels of Kragh in order to improve the cooling and reduce costs. Modified Stevens does not teach wherein each ridge including two channel side walls extending upwards from the top surface of the top plate and an upper wall connected between the two channel side walls, the upper wall parallel to the top surface of the top plate, each ridge defining a channel between the upper wall, the two channel side walls and the top surface of the top plate. Guener teaches wherein each ridge including two channel side walls extending upwards from the top surface of the top plate and an upper wall connected between the two channel side walls, the upper wall parallel to the top surface of the top plate, each ridge defining a channel between the upper wall, the two channel side walls and the top surface of the top plate (Guener, Supply channel portion and discharge channel portion, 5 and 6, see Fig. 3)(see annotated figure below) . PNG media_image1.png 476 660 media_image1.png Greyscale Guener teaches that this allows for the cells to be cooled while allowing for good electrical insulation (Guener, “One particular advantage of the cell holder configured according to various embodiments consists in the fact that it ensures good electrical insulation of the individual cells, to be precise in conjunction with a cooling of the same. The rear wall of the cell holder, which rear wall is designed for cooling purposes, simultaneously ensures the desired electrical insulation”, see [0014](Guener, “On the top wall 20 are found a coolant supply channel portion 5 and a coolant discharge channel portion 6. These two portions are connected to a coolant channel (not shown) arranged in the rear wall 3 of the cell holder, so that a suitable coolant, for example water, can be supplied via the channel portion 5 and introduced into the coolant channel (not shown).”, see [0034]). Stephens and Guener are analogous as they are both of the same field of coolant system for batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cover of Stephens with the channels on the top ridges from Guener in order to introduce the coolant to various parts of the battery while allowing for desired insulation of the cells. Regarding Claim 2, Modified Stephens teaches the battery enclosure of claim 1, further comprising a tray on the top surface of the bottom plate (Stephens, tray floor structure, 20, Fig. 2A) the tray configured to house the battery pack, the tray including at least a first tray side wall and a second tray side wall opposite the first tray side wall (Stephens, peripheral frame members, 26, Fig. 2A) ; wherein the frame enclosure at least partially surrounds the tray, and each cross member extends from the first tray side wall to the second tray side wall (Stephens, cross member portions, 48, Fig. 2A). Regarding Claim 3, Modified Stephens teaches the battery enclosure of claim 1, wherein the heat transfer medium includes at least one of a coolant liquid and air (Stephens, “A plurality of coolant channels may be disposed within the tray floor structure that are configured to carry liquid coolant.”, see [0007]). Regarding Claim 4, Modified Stephens teaches the battery enclosure of claim 3, wherein: the bottom plate includes multiple ridges protruding from the bottom surface; each ridge of the bottom plate defines a channel extending parallel to the bottom surface; and each channel of the bottom plate is configured to facilitate flow of the heat transfer medium through the channel (Stephens, coolant channels, 22 Fig. 2A). Regarding Claim 5, Modified Stephens teaches the battery enclosure of claim 4, further comprising at least one air deflector angled to direct airflow from beneath the electric vehicle into at least one channel of the bottom plate (Stephens, “It is understood that the fins 168 may also or alternatively be oriented in a lateral direction relative to the vehicle and may be alternatively shaped and structured to increase surface area for airflow contact.”, see [0047]). Regarding Claim 7, Modified Stephens teaches the battery enclosure of claim 6, further comprising a tube extending through at least one channel to provide a flow of coolant liquid through the at least one of the channels (Kragh, Channels, 10, Fig. 3) (Kragh, “The thermal fluid medium can be any suitable gas or liquid that enables transport of heat to or from the batteries.”, see [0008]). Regarding Claim 8, Modified Stephens teaches the battery enclosure of claim 1, wherein: a first portion of the multiple ridges extend in a first direction parallel to a length dimension of the top plate; and a second portion of the multiple ridges extend in a second direction perpendicular to the first direction (see annotated figure below). PNG media_image2.png 405 502 media_image2.png Greyscale Regarding Claim 9, Modified Stephens teaches the battery enclosure of claim 8, wherein each of the multiple ridges in the first portion intersects at least one of the multiple ridges in the second portion (see annotated figure below). PNG media_image3.png 407 502 media_image3.png Greyscale Regarding Claim 10, Modified Stephens teaches the battery enclosure of claim 1, wherein the top plate is configured to connect to a floor pan of a body of the electric vehicle to provide structural support for the top plate (Stephens, “The battery tray 10 may be attached or mounted at or near the lower frame or rocker rails of the vehicle frame, such as shown in FIGS. 8 and 9, so as to locate the contained battery modules 14 (FIG. 3A) generally in a central location on the vehicle 12, away from probable impact locations, and also in a location that evenly distributes the weight of the battery modules 14”, see [0037]). Regarding Claim 11, Modified Stephens teaches the battery enclosure of claim 2, wherein the tray is configured to hermetically seal the battery pack within the battery enclosure (Stephens, “that attaches with the side reinforcement members 26 to further form a sealed peripheral sidewall.”, see [0042]). Regarding Claim 12, Modified Stephens teaches the battery enclosure of claim 1, wherein the frame enclosure is configured to fully enclose the battery pack with the bottom plate, to hermetically seal the battery pack (Stephens, “As shown in FIG. 3, the seams 30 may be an overlapping or interlocking connection, such as to assist in welding or attaching in a manner that provides a water-tight seal.”, see [0041]). Claims 13-17 are rejected under 35 U.S.C. 103 as being unpatentable over (US-20200398652-A1) hereinafter referred to as ‘Stephens’ in view of (US-20110244298-A1) hereinafter referred to as ‘Guener’. Regarding Claim 13, Stephens teaches a battery enclosure for a battery pack of an electric vehicle (Stephens, battery tray, 10, Fig. 2), the battery enclosure comprising: a bottom plate including at least a top surface and a bottom surface (Stephens, panel section, 32, Fig. 2A); a battery pack including multiple batteries or battery modules configured to store energy for the electric vehicle (Stephens, battery modules, 414, Fig. 11); a frame enclosure at least partially surrounding the battery pack, the frame enclosure connected with the bottom plate, the frame enclosure including at least a first side wall and a second side wall opposite the first side wall (Stephens, peripheral frame member, 26. Fig. 2A); multiple cross members, each cross member extending between the first side wall and the second side wall, each cross member defining multiple channels extending along the cross member (Stephens cross member portions, 48, Fig. 2A), and each channel configured to facilitate flow of a heat transfer medium through the channel (Stephens, integral cooling channels, 23”, Fig, 5) ; and a top plate configured to cover the multiple cross members and at least a portion of the battery pack, the top plate connected with the frame enclosure (Stephens, “The battery support tray may also include a protective cover that is disposed over the tray floor to enclose a battery containment area for the battery modules.”, see [0007]). Modified Stevens does not teach wherein each ridge including two channel side walls extending upwards from the top surface of the top plate and an upper wall connected between the two channel side walls, the upper wall parallel to the top surface of the top plate, each ridge defining a channel between the upper wall, the two channel side walls and the top surface of the top plate. Guener teaches wherein each ridge including two channel side walls extending upwards from the top surface of the top plate and an upper wall connected between the two channel side walls, the upper wall parallel to the top surface of the top plate, each ridge defining a channel between the upper wall, the two channel side walls and the top surface of the top plate (Guener, Supply channel portion and discharge channel portion, 5 and 6, see Fig. 3)(see annotated figure below) . PNG media_image1.png 476 660 media_image1.png Greyscale Guener teaches that this allows for the cells to be cooled while allowing for good electrical insulation (Guener, “One particular advantage of the cell holder configured according to various embodiments consists in the fact that it ensures good electrical insulation of the individual cells, to be precise in conjunction with a cooling of the same. The rear wall of the cell holder, which rear wall is designed for cooling purposes, simultaneously ensures the desired electrical insulation”, see [0014](Guener, “On the top wall 20 are found a coolant supply channel portion 5 and a coolant discharge channel portion 6. These two portions are connected to a coolant channel (not shown) arranged in the rear wall 3 of the cell holder, so that a suitable coolant, for example water, can be supplied via the channel portion 5 and introduced into the coolant channel (not shown).”, see [0034]). Stephens and Guener are analogous as they are both of the same field of coolant system for batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cover of Stephens with the channels on the top ridges from Guener in order to introduce the coolant to various parts of the battery while allowing for desired insulation of the cells. Regarding Claim 14, Modified Stephens teaches the battery enclosure of claim 13, further comprising a tray on the top surface of the bottom plate, the tray configured to house the battery pack, the tray including at least a first tray side wall and a second tray side wall opposite the first tray side wall (Stephens, peripheral frame member, 26. Fig. 2A); wherein each cross member (Stephens cross member portions, 48, Fig. 2A), extends from the first tray side wall to the second tray side wall (see Fig. 2A). Regarding Claim 15, Modified Stephens teaches the battery enclosure of claim 13, wherein the heat transfer medium includes at least one of a coolant liquid and air (Stephens, “A plurality of coolant channels may be disposed within the tray floor structure that are configured to carry liquid coolant.”, see [0007]). Regarding Claim 16, Modified Stephens teaches the battery enclosure of claim 13, wherein each of the multiple batteries or battery modules is between two of the multiple cross members (Stephens, battery modules, 414, Fig. 11). Regarding Claim 17, Modified Stephens teaches the battery enclosure of claim 14, wherein a height of each cross member between the tray and a bottom surface of the top plate is greater than a width of the cross member (Stephens, cross member portions, 48, see Fig. 3)(The examiner notes that the width is being interpreted as the direction perpendicular to the height, see annotated figure below) PNG media_image4.png 230 374 media_image4.png Greyscale Regarding Claim 20, Stephens teaches a battery enclosure for a battery pack of an electric vehicle Stephens, battery tray, 10, Fig. 2), the battery enclosure comprising: a bottom plate including at least a top surface and a bottom surface, the bottom plate including multiple ridges protruding from the bottom surface, each ridge defining a channel extending parallel to the bottom surface; a battery pack including multiple batteries or battery modules configured to store energy for the electric vehicle(Stephens, battery modules, 414, Fig. 11); a frame enclosure at least partially surrounding the battery pack, the frame enclosure connected with the bottom plate (Stephens, coolant channels, 22 Fig. 2A)., the frame enclosure including at least a first side wall and a second side wall opposite the first side wall; multiple cross members, each cross member extending between the first side wall and the second side wall (Stephens cross member portions, 48, Fig. 2A),; and a top plate configured to cover the multiple cross members and at least a portion of the battery pack, the top plate connected with the frame enclosure (Stephens, “The battery support tray may also include a protective cover that is disposed over the tray floor to enclose a battery containment area for the battery modules.”, see [0007]). Modified Stevens does not teach wherein each ridge including two channel side walls extending upwards from the top surface of the top plate and an upper wall connected between the two channel side walls, the upper wall parallel to the top surface of the top plate, each ridge defining a channel between the upper wall, the two channel side walls and the top surface of the top plate. Guener teaches wherein each ridge including two channel side walls extending upwards from the top surface of the top plate and an upper wall connected between the two channel side walls, the upper wall parallel to the top surface of the top plate, each ridge defining a channel between the upper wall, the two channel side walls and the top surface of the top plate (Guener, Supply channel portion and discharge channel portion, 5 and 6, see Fig. 3)(see annotated figure below) . PNG media_image1.png 476 660 media_image1.png Greyscale Guener teaches that this allows for the cells to be cooled while allowing for good electrical insulation (Guener, “One particular advantage of the cell holder configured according to various embodiments consists in the fact that it ensures good electrical insulation of the individual cells, to be precise in conjunction with a cooling of the same. The rear wall of the cell holder, which rear wall is designed for cooling purposes, simultaneously ensures the desired electrical insulation”, see [0014](Guener, “On the top wall 20 are found a coolant supply channel portion 5 and a coolant discharge channel portion 6. These two portions are connected to a coolant channel (not shown) arranged in the rear wall 3 of the cell holder, so that a suitable coolant, for example water, can be supplied via the channel portion 5 and introduced into the coolant channel (not shown).”, see [0034]). Stephens and Guener are analogous as they are both of the same field of coolant system for batteries. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the cover of Stephens with the channels on the top ridges from Guener in order to introduce the coolant to various parts of the battery while allowing for desired insulation of the cells. Claims 18 is rejected under 35 U.S.C. 103 as being unpatentable over (US20200398652A1) hereinafter referred to as ‘Stephens’ in view of (US-20110244298-A1) hereinafter referred to as ‘Guener’, in view of (US-20240213606-A1) hereinafter referred to a ‘Neigishi’ Regarding Claim 18, Stephens does not teach multiple side brackets, wherein: each side bracket is located between the frame enclosure and the first tray side wall or the second tray side wall; and each side bracket is aligned with an end of one or more of the multiple cross members to transfer load to one or more of the multiple cross members. Negishi teaches comprising multiple side brackets, wherein: each side bracket is located between the frame enclosure and the first tray side wall or the second tray side wall; and each side bracket is aligned with an end of one or more of the multiple cross members to transfer load to one or more of the multiple cross members (Neigishi, “Hence, since the brace portions 64 on the front and rear sides have a reinforcing function, the bracket 9 having a substantially triangular shape in a planar view can transmit a load to the cross member 10”, see [0109]). Negishi teaches that this can prevent interference between the battery structure and the cases (Neigishi, “even in a case of a local collision such as a pole collision, thereby preventing interference between the battery case structure 1 and the batteries 2.”, see [0109]) Stephens and Neigishi are analogous as they both relate to the field of battery casing and cross bars. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the ends of the crossbar as taught in Stephens with the brackets as taught in Neigishi in order to prevent collision between the battery cases and batteries. Claims 19 is rejected under 35 U.S.C. 103 as being unpatentable over (US-20200398652-A1) hereinafter referred to as ‘Stephens’ in view of (US-20110244298-A1) hereinafter referred to as ‘Guener’, in view of (US-20230041000-A1) hereinafter referred to a ‘Tandon’ Regarding Claim 19, Stephens does not teaches wherein the frame enclosure is on an outer periphery of the battery pack, and the frame enclosure defines a crumple zone configured to allow deformation of the frame enclosure in response to a side impact of the battery enclosure. Tandon teaches an outer periphery of the battery pack, and the frame enclosure defines a crumple zone configured to allow deformation of the frame enclosure in response to a side impact of the battery enclosure (Tandon, “In the case of an impact to the vehicle, the reinforcement frame 1 is designed to absorb part of the energy of the impact through the deformation of its outer part 1”, see [0073]) Tandon teaches that this protects the battery cells (Tandon, “impact through the deformation of its outer part 11 while protecting the battery cells 29 thanks to the anti-intrusion behavior of the inner part 10.”, see [0073]) Stephens and Tandon are analogous as they both relate to the field battery cases. It would have been obvious to one of ordinary skill in the art before the effective filing date of the clamed invention to have modified the battery casing as taught in Stephens to add a deformation zone or crumple zone in order to protect the battery cells from impact. Response to Arguments Applicant’s arguments, filed 10/24/2025 have been fully considered and are persuasive, on pg. 10, the applicant argues: “As mentioned above, agreement was reached during the telephone interview of October 22, 2025, that the amendments herein would overcome the current prior art rejections, subject to further search and consideration.” This is convincing. During the interview the proposed amendments and arguments were clear that Kragh did not teach the protruding ridges off of the top cell assembly. Further search and consideration has revealed “Guener” which teaches said protruding ridges and teaching that it allows for coolant to be effectively moved while allowing for insulation of the cells (Guener, see Abstract). The examiner notes that Kragh does teach the network of cooling lines as described in claim 8 and claim 9. One of ordinary skill in the art would have considered both the network of coolant as described in Kragh with the risen ridges as described in Guener and would have modified Stephens to have a network of risen ridges. Therefore, the application would remain rejected under the new grounds of rejection. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SEAMUS PATRICK MCNULTY whose telephone number is (703)756-1909. The examiner can normally be reached Monday- Friday 8:00am to 5pm. 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, Nicholas A. Smith can be reached at (571) 272-8760. 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. /S.P.M./Examiner, Art Unit 1752 /NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
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Prosecution Timeline

Dec 28, 2022
Application Filed
Jul 17, 2025
Non-Final Rejection — §103
Oct 07, 2025
Interview Requested
Oct 22, 2025
Applicant Interview (Telephonic)
Oct 22, 2025
Examiner Interview Summary
Oct 24, 2025
Response Filed
Jan 09, 2026
Non-Final Rejection — §103
Apr 07, 2026
Interview Requested
Apr 08, 2026
Applicant Interview (Telephonic)
Apr 08, 2026
Examiner Interview Summary

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Prosecution Projections

2-3
Expected OA Rounds
52%
Grant Probability
94%
With Interview (+41.9%)
3y 5m
Median Time to Grant
Moderate
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