Prosecution Insights
Last updated: April 19, 2026
Application No. 18/091,812

BATTERY MODULE AND MANUFACTURING METHOD OF BATTERY MODULE

Non-Final OA §102§103§112
Filed
Dec 30, 2022
Examiner
DIGNAN, MICHAEL L
Art Unit
1723
Tech Center
1700 — Chemical & Materials Engineering
Assignee
SK On Co. Ltd.
OA Round
1 (Non-Final)
57%
Grant Probability
Moderate
1-2
OA Rounds
3y 0m
To Grant
75%
With Interview

Examiner Intelligence

Grants 57% of resolved cases
57%
Career Allow Rate
410 granted / 716 resolved
-7.7% vs TC avg
Strong +17% interview lift
Without
With
+17.4%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
43 currently pending
Career history
759
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
53.9%
+13.9% vs TC avg
§102
20.5%
-19.5% vs TC avg
§112
20.1%
-19.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 716 resolved cases

Office Action

§102 §103 §112
DETAILED ACTION Notice to Applicant Claims 1-20 are pending and are examined herein. This is the first action on the merits. Note on Claim Interpretation The claims refer to singular objects: such “a coupling portion” and “a side plate” that are either later subdivided into “first” and “second […] portions” or are described in the specification and shown in the figures to be multiple parts — see “side plate” 131 shown in two parts, on both sides, in Fig. 2. All claimed parts are therefore interpreted to be composed of singular or plural parts, and are not necessarily integral pieces. Claim Objections Claim s 2 and 3 are objected to because of the following informalities: Claim 2 says, “wherein the coupling portion is configured such that the first frame and the second frame have the first coupling position and the second coupling position.” This has been interpreted to be a solecism meaning something: “the coupling portion is configured such that the first frame and the second frame can be arranged in the first coupling position or the second coupling position.” Claim 3 says, “wherein, in the second coupling position, the first frame and the second frame have a state of pressing the cell stack.” It is not usual to describe compression as “having a state of pressing.” The claim has been interpreted as a solecism for “in the second coupling position, the first frame and the second frame compress the cell stack”. Appropriate correction is required. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b ) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. Claims 1 -1 9 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor regards as the invention. Claim 1 requires “a cell stack in which a plurality of battery cells are stacked [and] a plurality of the cell stack .” Although the claims, as noted above, have several references to singular terms that appear to be used to refer to separate subcomponents , in this particular case, it is unclear what is intended: a cell stack with a plurality of cells? a plurality of cell stacks each having a plurality of cells? The claim refers to a plurality of a singular object that has already been defined by being comprised of a plurality of subcomponents, creating real ambiguity about whether “a plurality of the cell stack” refers to only a single stack of a plurality of cells or a plurality of stacks. The claim has been interpreted broadly to refer to at least one cell stack with a plurality of cells. Claim 2 requires “ a second coupling position, of which a gap between the first frame and the second frame is narrower than those in the first coupling position.” There is no clear antecedent basis for “those.” Presumably it refers to something like “a gap between the first frame and the second in the first coupling position,” but this is not clearly identified, and is further confused by the use of the plural. The claim has been interpreted as referring to a gap that closes from the first to the second coupling position. Claim 14 is rejected because the limitation “both ends of the first plate and both ends of the second plate” is indefinite because there is no clear definition of the “both ends” referred to. A plate would have at least four sides, and the “both ends” in the claim appear to implicitly select from those sides, at least based on the disclosure and figures, but the claim is actually open-ended about which ends are the “both ends.” Yet the language suggests definiteness, and that there can only be one set of “both ends.” The claim is therefore indefinite. Claims 3-19 are rejected for depending on claims 1 and/or 2 . Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale , or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim s 1-3 and 19-20 are rejected under 35 U.S.C. 102 (a)(1) as being anticipated by Ohshiba (US 2015/0280190 to Ohshiba et al.) . Regarding Claim 1 , Ohshiba teaches: a battery module comprising at least two stacks in which a plurality of cells are stacked, and a housing having a plurality of accommodation spaces separated by one or more partitioning walls (Fig. 4, abstract, ¶ 0061) the housing including first 2 and second 3 frames coupled to each other to form the plurality of accommodation spaces via coupling portions 7 that couple the frames in a fitting coupling manner (Fig. 4, ¶ 0067-0072) Regarding Claim 2 , Ohshiba teaches: coupling the first and second frames by moving them from a first position, abutting the coupling portions of 7 downward/upward to achieve a second, snap-fit position that locks the frames together, closing the gap between them (Fig. 4, ¶ 0067) Regarding Claim 3 , Ohshiba teaches: in the second, snap-fit position the first and second frames compress the cell stacks 4/5/6 along the snap-fit axis (Fig. 4) Regarding Claim 19 , Ohshiba teaches: a heat insulating member, such as 200c , between a partition member and the cells in the opposite stack (Figs. 12A-B, ¶ 0134-0136) Regarding Claim 20 , Ohshiba teaches: a method of manufacturing a battery module comprising preparing first 2 and second 3 frames, coupled to each other to form at least one accommodation space that contains at least one cell stack inserted therein (Fig. 4) coupling the first and second frames by moving them from a first position, abutting the coupling portions of 7 downward/upward to achieve a second, snap-fit position that locks the frames together, closing the gap between them (Fig. 4, ¶ 0067) Claims 1-8 and 19-20 are rejected under 35 U.S.C. 102(a)(2) as being FILLIN "Insert either --clearly anticipated-- or--anticipated-- with an explanation at the end of the paragraph." \d "[ 2 ]" anticipated by Jo (US 2023/0099554 to Jo et al.) . Regarding Claim 1 , Jo teaches: a battery module comprising at least two cell stacks 200 in which a plurality of battery cells are stacked and a housing having a plurality of accommodation spaces to accommodate the stacks (Fig. 3) the housing including a first frame 151 and a second frame 120 coupled to each other to form the plurality of accommodation spaces (Fig. 3, ¶ 0032) including a coupling portion 152’ and 111 that are slotted together in a fitting coupling manner to couple the frames (¶ 0032) Regarding Claim 2 , Jo teaches: wherein the insertion parts 152 slide into the receiving parts 111 along a range of positions that can be arbitrarily identified as “first” and “second” positions, the second, end-range position producing a narrower gap between the first frame and second frame, in virtue of the insertion motion to couple them (Fig. 3, ¶ 0032) Regarding Claims 3 and 4 , Jo teaches: in the fully coupled position, the first frame and the second frame press against the cell stacks in the stacking direction (Figs. 1-3) Regarding Claim 5 , Jo teaches: first and second coupling portions arranged on opposite frames (Fig. 3) the first coupling portion containing a protrusion, or “tongue portion” that fits into a second coupling portion that is a groove portion (Fig. 3, ¶ 0032) Regarding Claim 6 , Jo teaches: a through hole with a fastener on each coupling portion, comprising a “stopping member” within the broadest reasonable interpretation of that phrase (¶ 0032) Regarding Claim 7 , Jo teaches: wherein the tongue is maximally inserted into an inner space of the groove portion in what can be called the second coupling position (Fig. 3, ¶ 0032) Regarding Claim 8 , Jo teaches: a through hole with a fastener on each coupling portion, comprising a “fixing member” within the broadest reasonable interpretation of that phrase (¶ 0032) Regarding Claim 19 , Jo teaches: wherein a space S7 of insulative air is formed in the middle of the member, providing an insulating member between a cell stack and at least the far side of the partition member, reading on the broadest reasonable interpretation of the claims (Fig. 13, ¶ 0119-0122) Regarding Claim 20 , Jo teaches: a method of manufacturing a battery module comprising at least two cell stacks 200 in which a plurality of battery cells are stacked and a housing having a plurality of accommodation spaces to accommodate the stacks (Fig. 3) the housing including a first frame 151 and a second frame 120 coupled to each other to form the plurality of accommodation spaces (Fig. 3, ¶ 0032) including a coupling portion 152’ and 111 that are slotted together in a fitting coupling manner to couple the frames, including some arbitrarily definable “first coupling position” before full insertion of the protrusion into the receiving groove, and some arbitrarily definable “second coupling position” wherein it is fully slotted into the groove, the gap between the frames narrowing during the insertion (¶ 0032) 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. 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 9-10 and 12- 15 are rejected under 35 U.S.C. 103 as being unpatentable over Jo (US 2023/0099554 to Jo et al.) in view of Martensson (US Patent No. 7,131,242 to Martensson et al.), Kim (US 2019/0181405 to Kim et al.), and/or Bingeman (US Patent No. 3,320,095 to Bingeman et al.). Regarding Claim 9 , Jo teaches: at least a portion of the tongue portion would be exposed to an outside of the groove portion as it slides in (Fig. 3) Jo does not explicitly teach: the tongue portion and the groove portion have a shape in which a width cross-section decreases in a direction the tongue extends into the groove Martensson , however, from the same field of invention, regarding a panel structure serving as a wall (column 1), wherein the panels are joined together via coupling structures, teaches providing a tongue end that goes from a wide portion to a narrower portion further along the tongue in the insertion direction (Figs. 9 and 10). Kim, also from the same field of invention, teaches a partition wall between batteries, teaches forming the partition by joining an extending wall with a groove to a second extend wall projecting from a second frame structure with a tongue, the tongue being thinner than the extension wall ( e.g., Fig. 8B, among others). Likewise, the Office further points to Bingeman, which teaches that it has long been known to form a battery housing wall by fitting opposing ends together (Fig. 2). It would have been obvious to use a complementary coupling fit with a tongue that thins near the far end, as suggested by Martensson , since the prior art teaches and renders obvious forming housing walls by coupling fit between two extending plates, and the snap fit reduces the number of parts needed. Use of a known technique to improve similar devices, methods, or products in the same way, and applying a known technique to a known device, method, or product ready for improvement to yield predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc. , 550 U.S. 398 (2007). Regarding Claim 10 , Jo teaches: insertion through application of force into the groove portion Similarly, the prior art of Martensson , Kim, and Bingeman teaches the use of interference or snap fit ends that are coupled by application of force between tongue and groove. Use of a known technique to improve similar devices, methods, or products in the same way, and applying a known technique to a known device, method, or product ready for improvement to yield predictable results has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc. , 550 U.S. 398 (2007). Regarding Claim 12 , Jo teaches: a partition member extending from the first to the second frame , perpendicular to the frame surfaces (Fig. 3) Jo does not explicitly teach that the partition frame is provided in a first and a second plate. Martensson , Kim, and Bingeman, however teach forming partition walls in modular units of selectable length via complementary tongue/groove ends. It would have been obvious to form the partition wall in Jo from two, or more, modular walls with the tongue/groove coupling portions rendered obvious by the prior art, in order to accommodate a variety of cell stack heights. It also would have been obvious to use just two, as suggested by Bingeman, with the motivation of providing a handed-ness to first and second frames being coupled, to provide a definite orientation thereto, among other reasons. Regarding Claim 13 , Jo teaches: wherein the partition wall and the frames form an I- or H-Frame with two accommodation spaces for cell stacks on either side of the partition member Jo does not explicitly teach: the first and second frames having T-frames that are joined through the partition wall to make the I- or H-frame of the completed structure Martensson , Kim, and Bingeman, however teach forming partition walls in modular units of selectable length via complementary tongue/groove ends. It would have been obvious to form the partition wall in Jo from two, or more, modular walls with the tongue/groove coupling portions rendered obvious by the prior art, in order to accommodate a variety of cell stack heights. It also would have been obvious to use just two, as suggested by Bingeman, with the motivation of providing a handed-ness to first and second frames being coupled, to provide a definite orientation thereto, among other reasons. Providing a two-piece partition wall would inherently result in the claimed T-shaped cross-section for each frame structure. Regarding Claim 14 , Jo teaches: a cover plate structure comprising side plate 110 disposed opposite the partition and respectively connected to both ends of the first plate and both ends of the second plate (Fig. 3, ¶ 0061) an end plate 320 disposed on front and rear surfaces of the cell stack (Fig. 3, ¶ 0062 ) Regarding Claim 15 , Jo teaches: a busbar assembly 220 between the cell stack and the end plate that includes at least one busbar connected to the leads of the cells, and a busbar support member 130 on which the busbar is installed, wherein the side plate 110 is fastened to the busbar support member via the end plates (¶ 0018-0026) Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over Jo (US 2023/0099554 to Jo et al.) in view of Martensson (US Patent No. 7,131,242 to Martensson et al.), Kim (US 2019/0181405 to Kim et al.), and/or Bingeman (US Patent No. 3,320,095 to Bingeman et al.), in further view of Olofsson (US Patent No. 7,380,383 to Olofsson et al.). Regarding Claim 11 , Jo does not teach: use of adhesive to fix the tongue in the coupling position within the groove Olofsson , however, from the same field of invention, regarding a coupling fit between two panels, teaches providing an adhesive member 12 between a tongue and a groove to firmly couple the two panels together (Fig. 7, column 4). It would have been obvious to provide an adhesive in the complementary fit coupling structures rendered obvious by Martensson , Kim, and Bingeman with the motivation to firmly couple the two frame components together. Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Jo (US 2023/0099554 to Jo et al.) in view of Martensson (US Patent No. 7,131,242 to Martensson et al.), Kim (US 2019/0181405 to Kim et al.), and/or Bingeman (US Patent No. 3,320,095 to Bingeman et al.), in further view of Lee (US 2007/0072071 to Lee). Regarding Claim 16 , Jo teaches: pouch cells (¶ 0082) Jo is silent on: the pouch cells having a sealing portion on three sides, wherein the stack is disposed such that a non-sealing surface of the cells opposes the sides plates Pouch cells are well-known in the art, and are typically sealed around 1 or more edges, often with a folded edge. Lee teaches a pouch cell folded along the long side and sealed around the other three sides. It would have been obvious to use a cell like that in Lee, since Jo teaches use of conventionally known pouch cells but fails to specify the exact species being used. Furthermore, given that the cells in Lee have a long side that is folded, it would have been obvious to put the folded side either opposing the partition wall or the side walls of Jo, since there were only two main options. A structure or method step that is obvious to try— such as one that is chosen from a finite number of identified, predictable solutions, with a reasonable expectation of success, has been found to be obvious. See KSR Int'l Co. v. Teleflex Inc. , 550 U.S. 398 (2007). Claim s 17 and 18 are rejected under 35 U.S.C. 103 as being unpatentable over Jo (US 2023/0099554 to Jo et al.) in view of Martensson (US Patent No. 7,131,242 to Martensson et al.), Kim (US 2019/0181405 to Kim et al.), and/or Bingeman (US Patent No. 3,320,095 to Bingeman et al.), in further view of Lee (US 2007/0072071 to Lee) and Jeon (US 2021/0098760 to Jeon et al.). Regarding Claims 17 and 18 , Jo teaches: wherein the heat generated by the cell stack will be discharged through the side plate externally, just in virtue of being in contact with it Jo does not teach: a thermally conductive adhesive between the cell stack contact surfaces and the side plate an outer surface of the side plate is in contact with a cooling member Jeon, however, from the same field of invention, teaches a two-frame housing with sidewalls as part of the cover, wherein the side walls are provided with cooling components 60 , that are in thermal contact with the side walls 22 to carry away excess heat from the cell stacks (Fig. 2). It would have been obvious to provide such cooling components along the sidewalls of Jo with the motivation to improve the cooling of the cell stacks, and it further would have been obvious to provide a commercially available thermal adhesive to improve thermal contact between the cooling components, the sidewalls, and the cell stacks themselves, since thermal adhesive resins were well-known in the art. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Michael Dignan, whose telephone number is (571) 272-6425. The examiner can normally be reached from Monday to Friday between 10 AM and 6:30 PM. If any attempt to reach the examiner by telephone is unsuccessful, the examiner’s supervisor, Tiffany Legette, can be reached at (571)270-7078. Another resource that is available to applicants is the Patent Application Information Retrieval (PAIR). Information regarding the status of an application can be obtained from the (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAX. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, please feel free to contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). Applicants are invited to contact the Office to schedule an in-person interview to discuss and resolve the issues set forth in this Office Action. Although an interview is not required, the Office believes that an interview can be of use to resolve any issues related to a patent application in an efficient and prompt manner. /MICHAEL L DIGNAN/ Examiner, Art Unit 1723
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Prosecution Timeline

Dec 30, 2022
Application Filed
Mar 24, 2026
Non-Final Rejection — §102, §103, §112 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
57%
Grant Probability
75%
With Interview (+17.4%)
3y 0m
Median Time to Grant
Low
PTA Risk
Based on 716 resolved cases by this examiner. Grant probability derived from career allow rate.

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