Prosecution Insights
Last updated: April 19, 2026
Application No. 18/104,389

ELECTRODE FOILS FOR VEHICLE BATTERIES

Final Rejection §103
Filed
Feb 01, 2023
Examiner
WEST, ROBERT GENE
Art Unit
1721
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
2 (Final)
77%
Grant Probability
Favorable
3-4
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

Grants 77% — above average
77%
Career Allow Rate
76 granted / 99 resolved
+11.8% vs TC avg
Strong +25% interview lift
Without
With
+24.9%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
56 currently pending
Career history
155
Total Applications
across all art units

Statute-Specific Performance

§103
55.4%
+15.4% vs TC avg
§102
19.3%
-20.7% vs TC avg
§112
23.8%
-16.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 99 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 . If status of the application as subject to 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 a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. Status of Claims Claims 1-2, 4-5, 7-12, 14-16, 18, & 20 are pending in the application. Claims 1-2, 4-5, & 7-10 are presently examined. Claims 11-12, 14-16, 18, & 20 are withdrawn. Claims 1-10 were rejected in the 10/27/2025 office action. Applicant cancelled claims 3, 6, 13, 17, & 19. Response to Amendment / Arguments The amendment filed 1/27/2026, in response to the 10/27/2025 office action, has been entered. Applicant’s claim amendments overcame the objection, the 35 U.S.C. 112(b) rejection, and the 35 U.S.C. 103 rejections. Nevertheless, the claims remain rejected under 35 U.S.C. 103 due to additional prior art. Examiner notes that present figure 1 looks different from Park Figure 5. There may be some way to distinguish these structures in the claims. Present Figure 1 Park Figure 5 PNG media_image1.png 736 434 media_image1.png Greyscale PNG media_image2.png 870 602 media_image2.png Greyscale 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: Determining the scope and contents of the prior art. Ascertaining the differences between the prior art and the claims at issue. Resolving the level of ordinary skill in the pertinent art. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. The claims are in bold font, the prior art is in parentheses. Claims 1-2, 4-5, & 10 are rejected under 35 U.S.C. 103 as being unpatentable over US20190013506A1 (Park) in view of US8450006B2 (Shin) and US20040038124A1 (Hisamitsu), together “modified Park”. Park teaches the following claim 1 limitations: A… battery comprising: a pouch cell (paragraphs 4 & 49, figure 4: battery cell 200)… multiple electrode foils stacked together (paragraph 49; figure 4: first electrode group 210 and a second electrode group 220) at least partially within the pouch cell (200), wherein: each of the multiple electrode foils (210 & 220) includes a foil extension at an end of the electrode foil (paragraph 50; figure 5: electrode tabs 210a & 220a); a first group of foil extensions (paragraph 50; figure 5: electrode tabs 210a) are connected together via a first… weld (paragraph 51; figure 5: welding junction 231) to define a first foil extension weld portion; and a second group of foil extensions (paragraph 50; figure 5: electrode tabs 220a) are connected together via a second… weld (paragraph 51; figure 5: welding junction 241) to define a second foil extension weld portion Park also teaches the following claim 1 limitations, as illustrated in Figure A below: each foil extension includes a first end integral with a body of the one of the multiple electrode foils from which the foil extension extends, a second end opposite to the first end, a first side edge between the first end and the second end, and a second side edge between the first end and the second end, the first side edge opposite to the second side edge, Figure A: Annotated Park Figure 5 PNG media_image3.png 577 949 media_image3.png Greyscale Park fails to teach the following claim 1 limitations, which are taught by Shin: the first... weld includes a first... edge weld only along the first side edge of each foil extension in the first group and a second... edge weld only along the second side edge of each foil extension in the first group, without... welding in a center of each foil extension the second... weld includes a third... edge weld only along the first side edge of each foil extension in the second group and a fourth... edge weld only along the second side edge of each foil extension in second first group, without... welding in a center of each foil extension Shin is directed to improved manufacturability of a safe rechargeable battery (column 1, lines 8-37). Shin teaches welding only to terminal edges (claim 18). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to weld only the edges of Park’s electrodes, as taught by Shin, as part of a safe rechargeable battery with improved manufacturability. Claim 1 also states that the battery is a vehicle battery, and that the pouch cell is configured to provide power to a power system of a vehicle. Park fails to mention use of the battery cell 200 for a vehicle. Hisamitsu provides additional guidance. Hisamitsu describes a laminate cell 1 [claimed pouch cell] with a stacked electrode 2 with leads 4 or 6 welded together (paragraphs 29-31; figure 3), which can be used for an electric vehicle (paragraph 11). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to use Park’s battery cell 200 for an electric vehicle, as taught by Hisamitsu, in order to provide a practical use for Park’s battery cell 200. Claim 1 also states that the first and second welds are ultrasonic welds. Although Park teaches welded connections (paragraph 51), Park fails to teach ultrasonic welds. Hisamitsu teaches ultrasonic bonding (paragraphs 67-68) and welding (paragraph 31) as optional methods for connecting electrode tabs / foil extensions. Hisamitsu thus recognizes the equivalency of ultrasonic bonding (same as ultrasonic welding) and welding in the field of combining electrode tabs / foil extensions. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the invention to replace Park’s welding with Hisamitsu’s ultrasonic bonding. This replacement is merely the selection of functionally equivalent bonds recognized in the art. One of ordinary skill in the art would have a reasonable expectation of success in making this replacement. With regard to claim 2, modified Park teaches the limitations of claim 1 as described above. Park also teaches the following claim 2 limitation: the first foil extension weld portion and the second foil extension weld portion are connected together via a third ultrasonic weld (paragraph 51; figure 5: second welding junction 232) As discussed under claim 1, although Park fails to teach ultrasonic bonding, it would have been obvious to apply Hisamitsu’s ultrasonic bonding to Park’s welding junctions. With regard to claims 4-5, modified Park teaches the limitations of claim 1 as described above. Park also teaches the following limitations of claims 4-5: Claim 4 a lead tab configured to electrically connect the electrode foils (ordinary lead tab function) with the at least one power system of the vehicle (Hisamitsu paragraph 11), wherein the first group of foil extensions and the second group of foil extensions are connected to the lead tab via a fusion weld (Figure B below) Claim 5 the lead tab includes a first outer surface, and a second outer surface opposite to the first outer surface; the first foil extension weld portion is connected to the first outer surface of the lead tab via a fusion weld; and the second foil extension weld portion is connected to the second outer surface of the lead tab via a fusion weld (Figure B below) Figure B: Annotated Park Figure 5 PNG media_image4.png 574 896 media_image4.png Greyscale As discussed under claim 1, ultrasonic bonding and ordinary welding (i.e. fusion welding) are equivalents in the art. It would therefore have been obvious, to one of ordinary skill in the art, to select one or the other. Park teaches ordinary welding (i.e. fusion welding). With regard to claim 10, modified Park teaches the limitations of claim 1 as described above. Claim 10 recites: the multiple electrode foils include at least twenty electrode foils stacked together at least partially within the pouch cell Park discloses 18 electrode groups [claimed electrode foils], whereas claim 10 requires ≥ 20. MPEP 2144.05 (I) provides the law for this issue: “Similarly, a prima facie case of obviousness exists where the claimed ranges or amounts do not overlap with the prior art but are merely close. Titanium Metals Corp. of America v. Banner, 778 F.2d 775, 783, 227 USPQ 773, 779 (Fed. Cir. 1985)… ‘The proportions are so close that prima facie one skilled in the art would have expected them to have the same properties.’” Given that there is only a slight difference between Park’s 18 and ≥ 20 in claim 10, and further given the fact that no criticality is disclosed for the claimed range, the claimed range is an obvious variant of Park’s range. Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over US20190013506A1 (Park), US8450006B2 (Shin), and US20040038124A1 (Hisamitsu), as applied to claims 1 & 4, and further in view of US20220328942A1 (Counts). Park fails to teach the following claim 7 limitation, which is taught by Counts: at least one clamp including a curve portion, wherein the lead tab is bent around the curve portion of the at least one clamp Counts describes inserting anode tab groups 440 through openings 124 in an anode grating 120 (paragraphs 47-49). Each anode tab group 440 is then folded to improve contact with the anode grating 120 (paragraphs 50-51). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Park’s lead tab to be bent / folded at a clamp curve, as taught by Counts, for improved contact with the clamp. Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over US20190013506A1 (Park), US8450006B2 (Shin), and US20040038124A1 (Hisamitsu), as applied to claim 1, and further in view of US20240234972A1 (Kim). Park fails to teach the following claim 8 limitation, which is taught by Kim: a surface of each foil extension defines a wrinkle pattern having multiple wave oscillations Kim teaches a bent electrode tab to improve strength of electrode tab to busbar junction (paragraphs 7-9). Kim describes forming a bending groove 11d in the electrode tab 11 at a desired bending location to prevent electrode tab 11 cracking and to ensure the electrode tab 11 bend occurs at the desired location (paragraphs 57-58; figures 5A-5C). Electrode tab 11 bending results in wrinkles on the electrode tab 11 (paragraph 64; figure 6A: wrinkles with two wave oscillations). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Park’s electrode tabs 210a to have wrinkles, as taught by Kim, for improved junction strength. Claim 9 is rejected under 35 U.S.C. 103 as being unpatentable over US20190013506A1 (Park), US8450006B2 (Shin), and US20040038124A1 (Hisamitsu), as applied to claim 1, and further in view of WO2015115731A1 (Jung). Park fails to teach the following claim 9 limitation, which is taught by Jung: for each of the multiple electrode foils: a width of the foil extension of the electrode foil is less than a width of a body of the electrode foil; a curve is defined between an edge of the foil extension and an edge of the body of the electrode foil; and the curve is a C1-continuity curve Figure C: Annotated Jung Figure 4 PNG media_image5.png 646 411 media_image5.png Greyscale Jung teaches this structure for increased durability (page 5, line 43 through page 6, line 6). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Park’s electrode groups to have the structure of claim 9, as taught by Jung, for increased durability. 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 extension fee 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 date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROBERT WEST whose telephone number is 703-756-1363 and email address is Robert.West@uspto.gov. The examiner can normally be reached Monday-Friday 10 am - 7 pm ET. 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, Allison Bourke can be reached at 303-297-4684. 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. /R.G.W./Examiner, Art Unit 1721 /ALLISON BOURKE/Supervisory Patent Examiner, Art Unit 1721
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Prosecution Timeline

Feb 01, 2023
Application Filed
Sep 14, 2023
Response after Non-Final Action
Oct 23, 2025
Non-Final Rejection — §103
Jan 13, 2026
Interview Requested
Jan 26, 2026
Examiner Interview Summary
Jan 27, 2026
Response Filed
Mar 08, 2026
Final Rejection — §103 (current)

Precedent Cases

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

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Prosecution Projections

3-4
Expected OA Rounds
77%
Grant Probability
99%
With Interview (+24.9%)
3y 4m
Median Time to Grant
Moderate
PTA Risk
Based on 99 resolved cases by this examiner. Grant probability derived from career allow rate.

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