Prosecution Insights
Last updated: October 01, 2026
Application No. 18/114,636

BATTERY COOLING SYSTEM

Non-Final OA §102§103§112
Filed
Feb 27, 2023
Priority
Mar 18, 2022 — JP 2022-044168
Examiner
JACOBSON, SARAH JORDAN
Art Unit
1785
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Honda Motor Co., Ltd.
OA Round
3 (Non-Final)
52%
Grant Probability
Moderate
3-4
OA Rounds
1m
Est. Remaining
99%
With Interview

Examiner Intelligence

Grants 52% of resolved cases
52%
Career Allowance Rate
14 granted / 27 resolved
-13.1% vs TC avg
Strong +76% interview lift
Without
With
+76.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 8m
Avg Prosecution
44 currently pending
Career history
77
Total Applications
across all art units

Statute-Specific Performance

§103
51.1%
+11.1% vs TC avg
§102
27.1%
-12.9% vs TC avg
§112
19.1%
-20.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 27 resolved cases

Office Action

§102 §103 §112
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 . 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and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114.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 May 11, 2026 has been entered. Summary The Applicant’s arguments and claim amendments received on May 11, 2026 have been entered into the file. Currently, claim 1 is amended; and claims 5-6 are cancelled; resulting in claims 1-4 and 7-10 pending for examination. Claim Interpretation It is noted that in claim 1, the plurality of battery groups is set forth in an intended use limitation, such that the battery cooling system is configured to cool a plurality of battery groups, and the plurality of battery groups is not positive recited. Therefore, the plurality of battery groups is not considered to be part of the claimed battery cooling system. 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 7 and 9-10 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. Regarding claim 7, the limitation in claim requiring that the battery cooling system further comprises an upper battery cooling flow path and a lower battery cooling flow path in lines 1-4 is indefinite as it seems that one of the upper or lower battery cooling flow paths is the cooling flow path claimed in claim 1. The claim appears to further include two additional flow paths, resulting in three total flow paths, however, given the disclosure on page 10 of the specification, that the battery cooling system includes an upper battery cooling flow path disposed on an upper surface of the battery group and a lower battery cooling flow path disposed on a lower surface of the battery group, it seems that only two battery cooling flow paths are included. For the purposes of examination, the claim is interpreted as requiring one additional flow path, such that the flow path of claim 1 is one of the upper or lower flow paths. Regarding claims 9-10, these claims are rejected based on their dependency on claim 7. Regarding claims 9-10, the limitation “an other of the upper battery cooling flow path and the lower battery cooling flow path” in lines 3-4 of the claims is indefinite as it is not clear if the limitation is referring to either the upper battery cooling flow path or the lower battery cooling flow path, or if the limitation is referring to another battery cooling flow path altogether. As noted above, given the disclosure in the instant specification, it seems that two flow paths are included in the embodiment, one upper and one lower. For the purposes of examination, the claim is interpreted as limiting one of the upper or lower flow paths claimed in claim 7. 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. 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. 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. Claims 1-4 and 7-10 are rejected under 35 U.S.C. 103 as being unpatentable over Hee, et al. (KR 10-2020-0040127 A) in view of He, et al. (CN 214254533 U). Regarding claim 1, Hee teaches a secondary battery cooling device for cooling a secondary battery which may comprise a battery module including multiple battery cells (¶ [0069], Ln. 1-5). Hee teaches that the secondary battery cooling device (200) is installed adjacent to the secondary battery (¶ [0018], Ln. 1-4) and as shown in Figure 1, may be disposed above or below the secondary battery (100). The secondary battery cooling device (200) includes an inlet pipe (211), outlet pipe (212), first cooling pipe (213), second cooling pipe (214), first connecting pipe (215), and second connecting pipe (216) (¶ [0026], Ln. 5-8; Fig. 4-5). Further, the secondary battery cooling device (200) includes a first valve (217) and second valve (218), which determine the circulation direction of a cooling medium (refrigerant) (¶ [0027], Ln. 1-2; Fig. 4 and 6). The secondary battery cooling device (200) includes a first inlet and outlet portion, where the first cooling pipe (213) overlaps the secondary battery (100), and a second inlet and outlet portion, where the second cooling pipe (214) overlaps the secondary battery (100), as labelled in annotated Figure 1 below. PNG media_image1.png 380 474 media_image1.png Greyscale The first valve (217; inflow-side three-way valve) includes an inlet for the cooling medium and first and second outlet through which the cooling medium flows out. As shown in Figures 5 and 7, the cooling medium flows into the first valve (217) through the inlet pipe (211) and can flow out to the first cooling pipe (213; Fig. 5) or the first connecting pipe (215; Fig. 7). The second valve (218; outflow-side three-way valve) includes an outlet for the cooling medium and first and second inlet through which the cooling medium flows in. As shown in Figures 5 and 7, the cooling medium can flow into the second valve (218) through the second cooling pipe (214; Fig. 5) or the second connecting pipe (216; Fig. 7), and flows out to the outlet pipe (212). The configurations of the first valve (217) and second valve (218) result in a first supply flow path connecting the first outlet of the first valve (217) to the first inlet and outlet portion (Fig. 4 and 5), a second supply flow path connecting the second outlet of the first valve (217) to the second inlet and outlet portion (Fig. 6 and 7), a first discharge path connecting the first inlet of the second valve (218) to the second inlet and outlet portion (Fig. 4 and 5), and a second discharge path connecting the second inlet of the second valve (218) to the first inlet and outlet portion (Fig. 6 and 7). Hee further teaches that the secondary battery cooling device includes a first inlet and outlet flow path connected to the first inlet and outlet portion (shown in the annotated figure above). In this case, the first inlet and outlet flow path is the flow path where the cooling medium enters or exits the first region A. The secondary battery cooling device also includes a second inlet and outlet flow path connected to the second inlet and outlet portion (shown in the annotated figure above). In this case, the second inlet and outlet flow path is the flow path where the cooling medium enters or exits the first region B (Fig. 1). Hee also teaches that the flow path of the cooling medium weaves up and down, as shown in Figure 1, creating first flow paths and second flow paths away from and toward the first inlet and outlet portion and second inlet and outlet portion to cool the multiple battery cells. Hee does not expressly teach that a plurality of first flow paths to which the cooling medium is supplied from the first inlet and outlet flow path are branched from the first inlet and outlet flow path or that a plurality of second flow paths which discharge cooling medium to the second inlet and outlet flow path are branched from the second inlet and outlet flow path. He teaches a cooling device for a battery pack including an inlet module (1) and outlet module (2) (¶ [0047], Ln. 1-4; Fig. 3). The inlet module includes an inlet channel (11) and a plurality of first branch modules (12), one of which is connected to the inlet channel (¶ [0048], Ln. 1-3; Fig. 4). Each first branch module includes a plurality of first branch channels (1211), and adjacent first branch modules are connected through a first converging channel (¶ [0048], Ln. 4-6). As shown in Figure 4, the refrigerant flows away from the converging channel and then back towards the converging channel through the branch channels. He teaches that by including multiple first branch channels, the flow resistance of the refrigerant can be reduced, the evaporation temperature of the refrigerant can be uniformly distributed, and the cooling uniformity of the battery pack by the inlet module can be guaranteed as much as possible (¶ [0049], Ln. 10-13). It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify the first inlet and outlet flow path and the second inlet and outlet flow path of Hee to include a plurality of branched flow paths that are connected through a first converging channel and second converging channel, based on the teachings of He. One of ordinary skill in the art would recognize that the teaching of branched flow paths could be applied to the flow path of Hee, such that a plurality of branched first flow paths supply cooling medium from the first inlet and outlet flow path and a plurality of branched second flow paths discharge cooling medium to the second inlet and outlet flow path. One would be motivated to include this branched structure in order to reduce the flow resistance of the refrigerant and guarantee cooling uniformity of the battery cells by both the first inlet and outlet flow path and the second inlet and outlet flow path. In including the plurality of branched flow paths, the branch channels leading away from the main flow path (first flow paths) would include a proximal end to the first inlet and outlet flow path and a distal end opposite the proximate end. Similarly, the branch channels returning the cooling medium to the main flow path (second flow paths) would include a proximal end to the second inlet and outlet flow path and a distal end opposite the proximal end. In order to return cooling medium to the second inlet and outlet flow path, the distal ends of the branch channels must be connected. Regarding claim 2, Hee in view of He teaches all of the limitations of claim 1 above. Hee further teaches that the secondary battery cooling device further includes a control unit that controls the operation of the first valve and the second valve (¶ [0012], Ln. 1-2). According to the output of the first control signal, the first valve (217) can block the communication between the inlet pipe (211) and the first connecting pipe (215), such that the inlet and first outlet (213) of the first valve are caused to communicate with each other, and the second valve (218) can block the communication between the outlet pipe (212) and the second connecting pipe (216), such that the first inlet (214) of the second valve and the outlet are caused to communicate with each other (¶ [0013], Ln. 1-3; Fig. 5). According to the output of the second control signal, the first valve (217) can block the communication between the inlet pipe (211) and the first cooling pipe (213), such that the inlet and second outlet (215) of the first valve are caused to communicate with each other, and the second valve (218) can block the communication between the outlet pipe (212) and the second cooling pipe (214), such that the second inlet (216) of the second valve and the outlet are caused to communicate with each other (¶ [0014], Ln. 1-3; Fig. 7). Regarding claim 3, Hee in view of He teaches all of the limitations of claim 1 above, including a battery cooling device with a plurality of branch channels. Further, Figure 2 of He shows the battery pack (200) comprising multiple battery cells arranged in a row. Therefore, the battery cooling device is configured to cool battery groups divided and disposed in a plurality of rows and a plurality of columns, with the first and second flow paths cooling battery groups in each row. Regarding claim 4, Hee in view of He teaches all of the limitations of claim 1 above, including a battery cooling device with a plurality of branch channels. Further, Figure 2 of He shows the battery pack (200) comprising multiple battery cells arranged in a row. Therefore, the battery cooling device is configured to cool battery groups divided and disposed in a plurality of rows and a plurality of columns. The combination of references does not expressly teach that the plurality of first flow paths and second flow paths extend obliquely across the battery groups to cool the battery groups in a plurality of columns. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify the flow path of Hee in view of He so that the first and second branched flow paths extend obliquely, which would be configured to cross columns of battery groups. One of ordinary skill in the art would recognize that the purpose of the back and forth configuration of the flow path is to ensure that the cooling medium crosses the plurality of battery cells, effectively cooling the plurality of cells. Configuring the first and second paths to extend straight up and down or extend obliquely over the plurality of battery cells achieves the same function of cooling the plurality of battery cells. One of ordinary skill in the art would find the change in shape obvious absent persuasive evidence that the particular configuration is significant (MPEP 2144.04 (IV)(B)). Regarding claims 7-8 and 10, Hee in view of He teaches all of the limitations of claim 1 above. Hee further teaches that the secondary battery cooling device is configured to change the circulation direction of the cooling medium (¶ [0001], Ln. 1-6). Based on Figure 1, the secondary battery cooling device is interpreted as disposed above the battery (100). The combination of references does not expressly teach that the secondary battery cooling device includes a flow path disposed above the battery cells and below the battery cells. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify the secondary battery cooling device of Hee to include a second cooling path below the battery cells. One of ordinary skill in the art would recognize that, as the purpose of the secondary battery cooling device is to effectively cool the battery cells, an additional secondary battery cooling device on the other side of the battery would further cool the battery cells. The mere duplication of parts has no patentable significance unless a new and unexpected result is produced (MPEP 2144.04 (VI)(B)). In including an additional secondary battery cooling device below the battery, both the upper and lower secondary battery cooling device would be configured to change the circulation direction of the cooling medium (switch a flow direction of the refrigerant). Additionally, in including an additional secondary battery cooling device below the battery, the lower secondary battery cooling device would be expected to have the same flow path configuration as the upper secondary battery cooling device, such that the lower secondary battery cooling device would include a flow path wherein a third supply flow path is configured to connect the first outlet of the first valve to a third inlet and outlet portion, a fourth supply flow path is configured to connect the second outlet of the first valve to a fourth inlet and outlet portion, a third discharge path is configured to connect the first inlet of the second valve to the fourth inlet and outlet portion, and a fourth discharge path is configured to connect the second inlet of the second valve to the third inlet and outlet portion. Regarding claim 9, Hee in view of He teaches all of the limitations of claim 7 above. The combination of references does not expressly teach that the first cooling path above the battery cells and second cooling path below the battery cells are configured such that the cooling medium flows in one direction in the upper cooling path and the opposite direction in the lower cooling path. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to modify the secondary battery cooling device of Hee such that the cooling medium in the upper and lower cooling paths flow in opposite directions. One of ordinary skill in the art would recognize that the devices are configured to change the circulation direction of the cooling medium and recognize that having the flow of the upper and lower cooling paths being opposite would provide the most effective cooling to the battery cells, as the coolant is expected to heat up as it travels through the cooling path. Response to Arguments Response-Claim Rejections – 35 U.S.C. 102 and 103 In light of Applicant’s amendment to claim 1 the previous rejections of claims 1-4 and 7-10 under 35 U.S.C. 103 over Hee, et al. (KR 10-2020-0040127 A) in view of He, et al. (CN 214254533 U) have been modified above. Applicant's arguments filed May 11, 2026 regarding amended claim 1 have been fully considered but they are not persuasive. The Applicant argues that He does not teach first and second branch channels connected to each other. As detailed in the rejection above, the teachings of He have been modified based on the amendment to claim 1. He teaches a plurality of first branch channels (1211), with adjacent first branch modules connected through a first converging channel (¶ [0048], Ln. 4-6). As shown in Figure 4, the refrigerant flows away from the converging channel and then back towards the converging channel through the branch channels. He teaches that by including multiple first branch channels, the flow resistance of the refrigerant can be reduced, the evaporation temperature of the refrigerant can be uniformly distributed, and the cooling uniformity of the battery pack by the inlet module can be guaranteed as much as possible (¶ [0049], Ln. 10-13). Using this teaching, one of ordinary skill in the art would find it obvious to include branch channels in the flow path of Hee. Specifically, one would find it obvious to modify the first inlet and outlet flow path and the second inlet and outlet flow path of Hee to include a plurality of branched flow paths that are connected through a first converging channel and second converging channel, based on the teachings of He. In including the plurality of branched flow paths, the branch channels leading away from the main flow path would include a proximal end to the first inlet and outlet flow path and a distal end opposite the proximate end. Similarly, the branch channels returning the cooling medium to the main flow path would include a proximal end to the second inlet and outlet flow path and a distal end opposite the proximal end. In order to return cooling medium to the second inlet and outlet flow path, the distal ends of the branch channels must be connected. One would be motivated to include this branched structure in order to reduce the flow resistance of the refrigerant and guarantee cooling uniformity of the battery cells by both the first inlet and outlet flow path and the second inlet and outlet flow path. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SARAH J JACOBSON whose telephone number is (703)756-1647. The examiner can normally be reached Monday - Friday 8:00am - 5:00pm. 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, Mark Ruthkosky can be reached at (571) 272-1291. 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. /SARAH J JACOBSON/Examiner, Art Unit 1785 /MARK RUTHKOSKY/Supervisory Patent Examiner, Art Unit 1785
Read full office action

Prosecution Timeline

Feb 27, 2023
Application Filed
Sep 08, 2025
Non-Final Rejection mailed — §102, §103, §112
Dec 08, 2025
Response Filed
Feb 11, 2026
Final Rejection mailed — §102, §103, §112
May 11, 2026
Request for Continued Examination
May 13, 2026
Response after Non-Final Action
Aug 28, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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Prosecution Projections

3-4
Expected OA Rounds
52%
Grant Probability
99%
With Interview (+76.5%)
3y 8m (~1m remaining)
Median Time to Grant
High
PTA Risk
Based on 27 resolved cases by this examiner. Grant probability derived from career allowance rate.

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