Prosecution Insights
Last updated: October 27, 2026
Application No. 18/116,108

SPOT WELDING METHOD AND SPOT WELDING DEVICE

Final Rejection §103
Filed
Mar 01, 2023
Priority
Mar 25, 2022 — JP 2022-050344
Examiner
TRAN-LE, THAO UYEN
Art Unit
3761
Tech Center
3700 — Mechanical Engineering & Manufacturing
Assignee
SUBARU Corporation
OA Round
2 (Final)
43%
Grant Probability
Moderate
3-4
OA Rounds
3m
Est. Remaining
93%
With Interview

Examiner Intelligence

Grants 43% of resolved cases
43%
Career Allowance Rate
57 granted / 133 resolved
-27.1% vs TC avg
Strong +50% interview lift
Without
With
+50.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 11m
Avg Prosecution
47 currently pending
Career history
192
Total Applications
across all art units

Statute-Specific Performance

§101
0.6%
-39.4% vs TC avg
§103
50.6%
+10.6% vs TC avg
§102
15.7%
-24.3% vs TC avg
§112
32.2%
-7.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 133 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 This action is responsive to the amendments filed on 07/30/2026. Claims 1-20 are pending in this application. As directed, claims 3-4, 11-12 have been amended; claims 13-20 have been newly added. With respect to 35 U.S.C. 112 Claim Rejections: Applicant’s amendments to the Claims filed on 07/30/2026 have overcome the 35 U.S.C. 112(b) Claim Rejections set forth in the Non-Final Office Action dated 04/30/2026. Response to Arguments With respect to 35 U.S.C. 103 Claim Rejections: Applicant(s)’ arguments filed on 07/30/2026 have been fully considered but they are not persuasive for the following reasons: Applicant(s)’ Arguments: (Regarding independent claim 1 – see detail on pages 13-15 of the Remarks dated 07/30/2026) Applicant alleged: “The claimed invention is distinguishable from Kim and Barkhausen at least because it relates to a welding technique that does not use rivets, whereas the cited references are directed to rivet-based joining techniques. The Office Action rejects claim 1 over Kim in view of Barkhausen on the theory that it would have been obvious to substitute Kim's "resistance welding with rivet" steps with Barkhausen's "indirect resistance spot welding with rivet element" under the simple-substitution rationale of MPEP § 2143(I)(B) ("substitution of one known element for another with no change in their respective functions"). Applicant respectfully submits that this rationale is not supported by the references as the Office Action itself characterizes them. As quoted in the Office Action, Kim's first and second "assembling steps" join "the second steel material 210 and the second aluminum material 220" and "the first steel material 110 and the first aluminum material 120," respectively, "by resistance element welding." (Office Action at 4, quoting Kim Translated Document, p. 4, 4, 6 (emphasis added).) That is, each panel pair that Kim joins using a rivet is expressly a dissimilar-metal pair - steel to aluminum. Resistance element welding (sometimes called "resistance rivet welding") is a well-known joining technique in which a hole is formed in one sheet, a metal rivet/element is inserted into the hole, and the rivet is then resistance-welded to the sheet on the opposite side - a technique developed specifically because aluminum and steel cannot reliably be fusion-welded directly to one another (the dissimilar melting points and interfacial intermetallic compounds that form make a direct fusion weld between aluminum and steel weak and unreliable). The rivet in Kim's process is accordingly not an incidental or arbitrarily-substitutable design choice; it is the metallurgical bridge that makes joining of the dissimilar steel and aluminum sheets possible in the first place. Barkhausen, by contrast, is relied upon by the Office Action for an indirect spot welding arrangement that the Office Action's own quotation shows is directed to an unrelated problem. The quoted passage states that "a preferably perforated plastic washer can be used to deliberately create an insulating surface or gap between the two components for unilateral/indirect resistance spot welding with a rivet element, in order to prevent a shunt caused by, for example, cut sheet metal edges, especially with narrow flanges." (Office Action at 6-7, quoting Barkhausen Translated Document, p. 2 (last para.) - p. 3 (first para.).) This passage identifies Barkhausen's rivet-element arrangement as addressing shunting/current-leakage during welding - not the distinct problem of forming a workable joint between dissimilar steel and aluminum sheet metal that cannot otherwise be fusion-welded together, which is the problem Kim's rivet solves. The Office Action does not identify any disclosure in Barkhausen showing that the components Barkhausen joins are a dissimilar steel/aluminum pair of the type at issue in Kim, nor any disclosure that Barkhausen's rivet-element arrangement is even capable of performing the dissimilar-metal joining function that is the entire reason Kim's process uses a rivet. Where, as here, a secondary reference's rivet-based feature is shown to address a different technical problem than the primary reference's rivet-based feature, a finding that the two are "art-recognized equivalents" subject to simple substitution "with no change in function" is not supported. See MPEP § 2143(I)(B) (requiring that the substituted elements be known to perform the same function). Moreover, Kim's own disclosure indicates that its riveted assembly steps and its final direct-spot-welding step are not independent of one another: the rivets 130 and 230 must be present at fixed locations so that the final step can "plac[e] the first rivet 130 and the second rivet 230 between the two electrodes (E) as a spot weld." (Office Action at 3, quoting Kim Translated Document, p. 4, 7.) The Office Action does not explain how Kim's final direct- spot-welding step - which specifically depends on capturing the rivets between the opposed electrodes - would continue to operate as Kim intends if Kim's riveted joining steps are replaced by Barkhausen's differently-purposed arrangement. A proposed modification that is not shown to preserve the cited reference's own principle of operation does not, without further explanation, support a conclusion of obviousness. MPEP § 2143.01(VI).” – see pages 13-15 of the Remarks dated 07/30/2026. Examiner’s Response: Applicant’s arguments have been fully considered but they are not persuasive for the following reasons: In response to Applicant’s argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., the claimed invention relates to a welding technique that does not use rivets) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). In this case, claim 1 does not exclude rivets or require joining the panels without an intervening joining element. Claim 1 recites two indirect spot welding operations followed by a direct spot welding operation that joins the second and third panels. The absence of rivets from the claim does not, by itself, impose a rivet-free limitation on the claim. Accordingly, Applicant’s stated distinction therefore does not alone distinguish claim 1 from the references Kim and Barkhausen. Additionally, the rejection also does not propose removing Kim’s rivets or replacing its rivet-assisted joints with direct aluminum to steel fusion welds. Kim is relied upon for the four panels arrangement, the preliminary joining of the two panel pairs, and the subsequent direct spot welding operation. Barkhausen is relied upon for performing rivet-assisted joining using indirect resistance spot welding. The modification retains the joining elements and their function of connecting the dissimilar panels. Applicant’s discussion of different melting temperature and undesirable intermetallic formation does not demonstrate that the modification would fail, because the combination continues to employ rivet-assisted joining. Applicant alleged that Barkhausen does not teach joining a dissimilar steel/aluminum pair is contradicted by the reference. Barkhausen Translated Document on page 4, last paragraph to page 5, first paragraph explicitly teaches connecting a press-hardened sheet steel part to an aluminum structure through a rivet element and resistance spot welding. Specifically, Barkhausen Translated Document on page 4, last paragraph to page 5, first paragraph explicitly teaches aluminum sheet part 1 and press-hardened steel sheet part 2, connected through joining element 3, with weld nugget 9 joining the element head to steel part. Barkhausen Translated Document on page 5, paragraph 5 & Fig.5 teach performing the welding operation with laterally offset electrodes 23 and 25 positioned on the same side of the component arrangement. Barkhausen therefore teaches indirect rivet assisted resistance spot welding for the same material combination used in the primary reference Kim. Additionally, Barkhausen’s discussion of preventing current shunting does not establish that its joining technique serves an unrelated function. The joining element connects the aluminum and steel components, while the insulating element limits unintended electrical contact that could divert current from the intended weld interface. Barkhausen Translated Document on page 2 – paragraph 2 explains that such diversion reduces the heat available for weld nugget formation and can reduce joint strength or prevent formation of the joint. Current-shunt prevention consequently supports the formation of the rivet assisted dissimilar material joint. These are complementary functions of the disclosed process. Furthermore, the modification has a specific manufacturing rationale. Barkhausen Translated Document on page 2 – paragraph 2 identifies opposed electrode and one sided, laterally offset electrode arrangements as alternatives for rivet-assisted resistance spot welding. Barkhausen Translated Document on page 2 – last paragraph explicitly teaches indirect resistance spot welding with a rivet element and identifies benefits concerning joining sequence and vehicle body design. Applying that teaching to Kim’s preliminary joining operations would permit current delivery without requiring opposed welding-electrode access at each preliminary joint, while retaining the function of producing joined aluminum-steel subassemblies before final assembly. Therefore, in the instant case, the purpose of combining Kim and Barkhausen is not defeated, for, at least, the benefit of permitting current delivery without requiring opposed welding-electrode access at each preliminary joint, while retaining the function of producing joined aluminum-steel subassemblies before final assembly. As the obviousness can be established by combining or modifying the teachings of the prior art to produce the claimed invention where there is some teaching, suggestion, or motivation to do so. In re Kahn, 441 F.3d 977, 986, 78 USPQ2d 1329, 1335 (Fed. Cir. 2006). Moreover, MPEP § 2144.01, suggests that “[I]n considering the disclosure of a reference, it is proper to take into account not only specific teachings of the reference but also the inferences which one skilled in the art would reasonably be expected to draw therefrom.” In re Preda, 401 F.2d 825, 826, 159 USPQ 342, 344 (CCPA 1968); In re Lamberti, 545 F.2d 747, 750, 192 USPQ 278, 280 (CCPA 1976). Regarding Applicant’s contention that Kim’s final operation would no longer function, Examiner would like to note that the modification does not require adopting Barkhausen’s complete rivet geometry or its head to steel interface. It applies Barkhausen’s indirect current delivery teaching to Kim’s preliminary rivet assisted welding operations while retaining Kim’s rivet locations and the exposed heads used in the subsequent operation. For Kim’s upper subassembly, a welding electrode contacting the exposed head of rivet 230 and a laterally displaced return electrode contacting an accessible surface of steel panel 210 provide a current path through rivet 230, across its contact interface with steel panel 210, and through that steel panel to return electrode. The corresponding arrangement for the lower subassembly provides a current path through rivet 130, across its contact interface with steel panel 110, and through steel panel 110 to the displaced return electrode. This engineering application requires suitable electrode access, mechanical support, and control of competing current paths, but does not inherently require removal or relocation of the rivets. Contacting a rivet head with a welding electrode does not require welding that head to another panel during the preliminary operation. The head supplies electrical contact, while the intended joining interface remains the rivet end contacting the steel panel. Consequently, the preliminary operations can retain the exposed rivet heads needed for Kim’s subsequent assembly operation. Kim describes positioning the two subassemblies with rivet heads 130 and 230 in contact and subsequently joining those heads by spot welding. With the preliminary rivet steel joints and exposed heads retained, the final current path remains through the outer steel panels, the attached rivets, and their contacting heads. Kim’s final operation depends on that resulting conductive structure, rather than on the preliminary electrodes having been directly opposed. The modification preserves the final weld cooperation through aligned rivets. The preliminary operations continue to join the respective panel pairs, and the subsequent opposed electrode operation joins the assemblies through the retained rivets. For the Fig.3 mapping, the second and third aluminum panels are joined through the fused rivet heads; the rejection does not characterize that joint as an aluminum to aluminum fusion nugget. Applicant’s arguments therefore do not establish that changing the preliminary current delivery arrangement necessarily changes Kim’s principle of operation or prevents its final welding operation. For given above reasons, Applicant’s arguments regarding independent claim 1 are not persuasive. Applicant’s arguments regarding dependent claims 2, 5-6 – Kim in view of Barkhausen – are the same as those provided for independent claim 1, see detail on pages 13-15 of the Remarks dated 07/30/2026. Therefore, the Examiner’s response to Applicant’s arguments regarding independent claim 1 above generally applies to dependent claims 2, 5-6. Applicant(s)’ Arguments: (Regarding claim 3 – see detail on pages 15-16 of the Remarks dated 07/30/2026) Applicant alleged: “Applicant further notes, without conceding the propriety of the combination, that Gabbianelli's weld gun 30 is described as having been "developed to weld members to closed section members through indirect resistance spot welding." (Office Action at 9, quoting Gabbianelli 0034 (emphasis added).) The Office Action does not explain why a person of ordinary skill would import a welding gun purpose-built for accessing closed (e.g., box- or tube- shaped) structural sections into Kim's general stacked flat-panel arrangement, which the Office Action has not shown to involve any closed section.” – see pages 15-16 of the Remarks dated 07/30/2026. Examiner’s Response: Applicant’s arguments have been fully considered but they are not persuasive for the following reasons: Applicant’s argument that Gabbianelli’s weld gun was developed for closed section members does not establish that its electrode arrangement is unsuitable for the combination. Examiner would like to note that Par.0024 of Gabbianelli explicitly states that members may have other forms and specifically identifies an open-cross-section member as another application. Additionally, Par.0029 of Gabbianelli further explains that the welding parts may take different forms depending on members being welded. Therefore, Gabbianelli does not confine its electrode arrangement to a particular tubular geometry. In this case, the rejection of claim 3 relies on Gabbianelli’s teaching of opposed electrodes that apply pressure during successive indirect welding operations. Figs.4-6 of Gabbianelli show that electrodes 44 and 48 facing one another in alignment. Par.0039 of Gabbianelli explicitly teaches that both electrodes apply pressure throughout formation of both welds. Furthermore, Pars.0037-0038 of Gabbianelli explain that the electrodes are energized separately, with the current from each active electrode returning through grounding element 70. Thus, mechanical opposition of the electrodes does not require welding current to flow directly between them. Applying this arrangement to the preliminary indirect welding operations would provide opposing reaction forces while allowing the respective welding circuits to operate separately. It is noted that aligning the opposing forces along a common axis reduces the turning moment associated with offset loading and helps maintain the workpieces/panels in position. Maintaining engagement during successive operation also avoids releasing and reestablishing the clamping arrangement. Par.0041 of Gabbianelli explicitly identifies the time advantage of forming successive welds without physically moving the welding device after each weld. These benefits concern force application and welding sequence and do not depend on the workpiece having a closed cross-section. Accordingly, the reason for applying Gabbianelli’s teaching is to maintain opposed clamping during successive indirect welding operations and reduce repositioning between those operations. Applicant’s observation that Kim does not disclose a closed-section member does not address those benefits or establish that the relied-upon electrode arrangement requires such a member. For given above reasons, Applicant’s arguments regarding claim 3 are not persuasive. Applicant’s arguments regarding claims 4, 7-8 – Kim, Barkhausen, Gabbianelli, and Wang – are the same as those provided for claim 3, see detail on pages 15-16 of the Remarks dated 07/30/2026. Therefore, the Examiner’s response to Applicant’s arguments regarding claim 3 above generally applies to claims 4, 7-8. Applicant(s)’ Arguments: (Regarding claim 9 – see detail on pages 16-17 of the Remarks dated 07/30/2026) Applicant alleged: “the circuit-switching teaching of Tanigawa relied upon for the claimed first, second, and third circuits describes a switching architecture that is structurally different from what is claimed. As quoted in the Office Action, Tanigawa's spot welding device 1 comprises two separate, pre-existing "spot welded portions" 10 and 20, each having its own dedicated circuit (circuit 16 for the first spot welded portion 10, and circuit 26 for the second spot welded portion 20), together with an additional circuit 51 that is selectively connected - via switches 41 and 42 - only to link the first electrode 11 of the first portion to the third electrode 21 of the second portion. (Office Action at 21-23, quoting Tanigawa Translated Document, p. 4, 3, 5-6.) This is a fundamentally different switching topology from that of claim 9, in which a single welding power supply is selectively routed, via only two switches, among four coaxially-related electrodes of a single device to form three distinct circuits without requiring two independently-constructed welding "portions," each having its own complete circuit. The Office Action's rejection bodily imports Tanigawa's two-switch, two-portion arrangement onto Kim's single pair of opposed electrodes (as modified to add Barkhausen's and Gabbianelli's electrodes) without explaining how Tanigawa's portion-linking circuit 51 would translate into the claimed first, second, and third circuit arrangement among four electrodes that the Office Action treats as belonging to a single spot welding device.” – see pages 16-17 of the Remarks dated 07/30/2026. Examiner’s Response: Applicant’s arguments have been fully considered but they are not persuasive for the following reasons: In response to Applicant’s argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., “a single welding power supply is selectively routed, via only two switches”) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993). In this case, claim 9 does not specify the number of power supplies or switches. It requires four electrodes having the recited contact and positional relationships and three circuits configured to switch between current-carrying and non-current-carrying states for specified electrode pairs. The particular power supply and switch arrangement illustrated in the specification does not, by itself, restrict the claim to that implementation. Applicant also characterizes Tanigawa’s welding portions 10 and 20 as necessarily separate, independently constructed devices. However, Tanigawa Translated Document on page 4, paragraph 6 explicitly teaches that these portions can be physically integrated or physically separated, provided they are electrically connected through circuit 51; specifically, Tanigawa Translated Document on page 4, paragraph 6 teaches: “The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”. The rejection does not assert that Tanigawa’s unmodified circuit arrangement supplies all three claimed connections. Rather, it identifies two disclosed connections and proposes an additional connection. Under the correspondence used in the rejection, Tanigawa’s electrodes 11, 21, 22, and 12 correspond to the claimed first, second, third, and fourth electrodes, respectively. Circuit 51 connects electrodes 11 and 21 and supplies the teaching for the claimed first-second connection. Circuit 16 connects electrodes 11 and 12 and supplies the teaching for the claimed first-fourth connection. Tanigawa Translated Document on page 4, paragraphs 3, 5-6 describe these connections and their selectable connected and disconnected states. The rejection separately acknowledges that the claimed third-fourth connection is not explicitly disclosed and proposes adding that connection using the same switched-circuit technique. There is a specific engineering reason for the additional circuit. The Kim in view of Barkhausen method includes an indirect welding operation for each of two panel pairs, followed by final direct welding. Once the electrode arrangement has been established, the upper indirect operation requires a selectable first-second current path, and the corresponding lower indirect operation requires a selectable third-fourth current path. Providing the latter path applies the known circuit-selection technique to the second panel pair operation. Its purpose is to energize that operation without changing the electrode connections manually, while retaining the first-fourth path for final direct welding. The addition concerns a powered, switchable welding branch, including the connections needs to disconnect inactive branches. It does not merely add an unswitched conductor between the lower electrodes. For the respective welding operations, the switching arrangement would select the first-second path, the third-forth path, or the first-fourth path, with the other branches disconnected from the welding supply. Tanigawa Translated Document on page 4, paragraph 6 supplies the underlying teaching of selecting a welding circuit while disconnecting alternative circuits. Applying that technique to the additional lower operation would serve the same electrical function, which is establishing the selected welding connection and disabling competing supply connections. Therefore, the combination applies its selectable circuit teaching to the electrode arrangement and welding operations established by Kim in view of Barkhausen. Tanigawa explicitly identifies performing direct and indirect welding with one apparatus as a benefit of circuit switching. Providing a corresponding switched branch for the second indirect operation extends that benefit to the second panel pair. The difference between Tanigawa’s original circuit arrangement and the modified arrangement is thus acknowledged and addressed by the stated modification, rather than overlooked. Accordingly, Applicant’s arguments regarding claim 9 are not persuasive. Applicant’s arguments regarding claim 10 are the same as those provided for claim 9, see detail on pages 16-17 of the Remarks dated 07/30/2026. Therefore, the Examiner’s response to Applicant’s arguments regarding claim 9 above generally applies to claim 10. Furthermore, Applicant’s arguments regarding claims 11-12 are the same as those provided for claim 9, see detail on page 17 of the Remarks dated 07/30/2026. Therefore, the Examiner’s response to Applicant’s arguments regarding claim 9 above generally applies to claims 11-12. Claim Objections Claims 3-4, 7-8, 11-12 are objected to because of the following informalities: Claim 3 recites the limitations “each of the electrodes” in the last line of claim 3. This should be changed to “each of the second and the third electrodes” to properly refer to the corresponding limitations recited previously in claim 3 (lines 3, 4). Claims 7 and 11 are objected by virtue of their dependence on claim 3. Claim 4 recites the limitations “each of the electrodes” in the last line of claim 4. This should be changed to “each of the second and the third electrodes” to properly refer to the corresponding limitations recited previously in claim 4 (lines 3, 4). Claims 8 and 12 are objected by virtue of their dependence on claim 4. Appropriate correction is required. 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 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. Claims 1-2, 5-6 are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. (KR 102352109 B1, previously cited) in view of Barkhausen et al. (DE 102020108759 A1, previously cited). Regarding claim 1, Kim discloses a spot welding method (Kim Abstract discloses “spot welding”) of spot welding a workpiece (workpiece comprises materials 110, 120, 210, 220; Kim Fig.3) comprising a first panel (material 210, Kim Fig.3), a second panel (material 220, Kim Fig.3), a third panel (material 120, Kim Fig.3), and a fourth panel (material 110, Kim Fig.3) stacked in sequence (as shown in Kim Fig.3), the spot welding method comprising: conducting resistance welding with rivet for the first panel (material 210, Kim Fig.3) and the second panel (material 220, Kim Fig.3) to form a first weld zone (the first weld zone is the location where the rivet 230 is located in Kim Fig.3) where the first panel (material 210, Kim Fig.3) is joined to the second panel (material 220, Kim Fig.3) (Kim Translated Document on page 4, paragraph 6 discloses: “the second assembling step (S120) is a step of assembling the second steel material 210 and the second aluminum material 220 by resistance element welding”); conducting resistance welding with rivet for the third panel (material 120, Kim Fig.3) and the fourth panel (material 110, Kim Fig.3) to form a second weld zone (the second weld zone is the location where the rivet 130 is located in Kim Fig.3) where the third panel (material 120, Kim Fig.3) is joined to the fourth panel (material 110, Kim Fig.3) (Kim Translated Document on page 4, paragraph 4 discloses: “the first assembling step (S110) is a step of assembling the first steel material 110 and the first aluminum material 120 by resistance element welding”); and after forming the first weld zone (the first weld zone is the location where the rivet 230 is located in Kim Fig.3) and the second weld zone (the second weld zone is the location where the rivet 130 is located in Kim Fig.3), conducting direct spot welding for the workpiece (workpiece includes materials 110, 120, 210, 220; Kim Fig.3) to form a third weld zone (third weld zone, Kim annotated Fig.3 below) where the second panel (material 220, Kim Fig.3) is joined to the third panel (material 120, Kim Fig.3) (Kim Translated Document on page 3, paragraph 11 discloses: “the final assembly step (S200) is a step that proceeds after the first assembly step (S110)”, Kim Translated Document on page 3, second paragraph from the bottom of page 3 discloses: “The second assembling step (S120) is a step performed before the final assembling step (S200)”, Kim Translated Document on page 4, paragraph 7 discloses: “in the final assembly step (S200), the first assembly 100 and the second assembly 200 by placing the first rivet 130 and the second rivet 230 between the two electrodes (E) as a spot weld”, and Kim Translated Document on page 4, paragraph 8 discloses: “the portion where the first rivet 130 and the first steel material 110 are welded in the first assembling step S110, and the second rivet 230 and the second steel material 110 in the second assembling step S120 (S120) In a state where the welded portions 210 are overlapped with each other, the overlapped portions are spot-welded with two electrodes (E).”; it is known that direct spot welding (also known as two-sided welding) is a resistance welding process where two electrodes are positioned on opposite sides of stacked; in this case, Kim discloses the final welding step is spot welding and Kim Fig.3 shows two-sided welding where two electrodes are positioned on opposite sides of stacked; therefore, Kim discloses after forming the first weld zone and the second weld zone, conducting direct spot welding for the workpiece to form a third weld zone where the material 220 is joined to the material 120). PNG media_image1.png 729 1164 media_image1.png Greyscale Kim does not explicitly disclose: indirect spot welding for the first panel and the second panel; and indirect spot welding for the third panel and the fourth panel Barkhausen teaches a spot welding method for spot welding at least two components together (Barkhausen Translated Abstract): indirect spot welding with rivet element for joining two components (Barkhausen Translated Document from the last paragraph on page 2 to the first paragraph on page 3 teaches: “A welding process implemented on one side enables the improvement or redesign of future body concepts with regard to the joining sequence or optimization of the vehicle weight, for example by eliminating so-called steel adapters. The new idea can significantly improve the welding process. In a technical implementation, a preferably perforated plastic washer can be used to deliberately create an insulating surface or gap between the two components for unilateral / indirect resistance spot welding with a rivet element, in order to prevent a shunt caused by, for example, cut sheet metal edges, especially with narrow flanges. Furthermore, the components are stabilized in relation to one another (that is, tilting is prevented).”. It is noted that the primary reference Kim discloses conducting resistance welding with rivet for the first panel and the second panel, and conducting resistance welding with rivet for the third panel and the fourth panel, as cited and explained above; therefore, in this case, by substituting the Kim resistance welding with rivet for welding two components with the Barkhausen indirect resistance spot welding with rivet element for welding two components, in combination, Kim in view of Barkhausen teaches indirect spot welding for the first panel and the second panel, and indirect spot welding for the third panel and the fourth panel) It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to substitute the Kim resistance welding with rivet for welding two components with the Barkhausen indirect resistance spot welding with rivet element for welding two components, because the substitution of one known element for another with no change in their respective functions, and the modification would yield a predictable result of joining two components. MPEP 2143 I (B). Furthermore, the indirect resistance spot welding with rivet element improves welding process, specifically, allows one-sided welding configurations, improving accessibility and manufacturability; ensures controlled current flow through the intended weld interface, avoiding shunt paths; enables the improvement or redesign of future body concepts with regard to the joining sequence or optimization of the vehicle weight; and thus, the components are stabilized in relation to one another, as recognized by Barkhausen [Barkhausen, Translated Document from page 2, last paragraph to page 3, first paragraph]. Regarding claim 2, Kim in view of Barkhausen teaches the method set forth in claim 1, and Kim also discloses: wherein the first weld zone (the first weld zone is the location where the rivet 230 is located in Kim Fig.3), the second weld zone (the second weld zone is the location where the rivet 130 is located in Kim Fig.3), and the third weld zone (third weld zone, Kim annotated Fig.3 below) overlap one another in a stacking direction of the first panel (material 210, Kim Fig.3), the second panel (material 220, Kim Fig.3), the third panel (material 120, Kim Fig.3), and the fourth panel (material 110, Kim Fig.3) (as shown in Kim Fig.3 and Kim Translated Document on page 4, paragraph 7 discloses: “in the final assembly step (S200), the first assembly 100 and the second assembly 200 by placing the first rivet 130 and the second rivet 230 between the two electrodes (E) as a spot weld”, and Kim Translated Document on page 4, paragraph 8 discloses: “the portion where the first rivet 130 and the first steel material 110 are welded in the first assembling step S110, and the second rivet 230 and the second steel material 110 in the second assembling step S120 (S120) In a state where the welded portions 210 are overlapped with each other, the overlapped portions are spot-welded with two electrodes (E).”; therefore, the first, second, and third weld zones overlap one another in stacking direction of materials 210, 220, 120, 110). PNG media_image1.png 729 1164 media_image1.png Greyscale Regarding claim 5, Kim in view of Barkhausen teaches the method set forth in claim 1, Kim further discloses: wherein the workpiece (workpiece comprises materials 110, 120, 210, 220; Kim Fig.3) further comprises a fifth panel (additional material 300, Kim Fig.10) stacked between the second panel (material 220, Kim Fig.3) and the third panel (material 120, Kim Fig.3) (Kim Translated Document on page 6, paragraph 5 discloses: “in the final assembly step (S200), the first assembly 100 and the additional unit are assembled by spot welding, in the fourth embodiment, the additional unit may be an additional steel material (300).”, and see Fig.10 of Kim; in combination, by further adding additional material 300 to the workpiece, the additional material 300 is stacked between the material 220 and the material 120), and the second panel (material 220, Kim Fig.3), the fifth panel (additional material 300, Kim Fig.10), and the third panel (material 120, Kim Fig.3) are joined by the direct spot welding in the conducting direct spot welding for the workpiece (Kim Translated Document on page 6, last paragraph discloses: “in the same assembly method as described above, two or more assemblies are made by resistance element welding, and the additional steel material 300 is contacted, and 5 or more different materials are finally assembled by spot welding”; it is known that direct spot welding (also known as two-sided welding) is a resistance welding process where two electrodes are positioned on opposite sides of stacked; therefore, the material 220, the additional material 300 and the material 120 are joined by the direct spot welding in the conducting direct spot welding for the workpiece). Regarding claim 6, Kim in view of Barkhausen teaches the method set forth in claim 2, Kim further discloses: wherein the workpiece (workpiece comprises materials 110, 120, 210, 220; Kim Fig.3) further comprises a fifth panel (additional material 300, Kim Fig.10) stacked between the second panel (material 220, Kim Fig.3) and the third panel (material 120, Kim Fig.3) (Kim Translated Document on page 6, paragraph 5 discloses: “in the final assembly step (S200), the first assembly 100 and the additional unit are assembled by spot welding, in the fourth embodiment, the additional unit may be an additional steel material (300).”, and see Fig.10 of Kim; in combination, by further adding additional material 300 to the workpiece, the additional material 300 is stacked between the material 220 and the material 120), and the second panel (material 220, Kim Fig.3), the fifth panel (additional material 300, Kim Fig.10), and the third panel (material 120, Kim Fig.3) are joined by the direct spot welding in the conducting direct spot welding for the workpiece (Kim Translated Document on page 6, last paragraph discloses: “in the same assembly method as described above, two or more assemblies are made by resistance element welding, and the additional steel material 300 is contacted, and 5 or more different materials are finally assembled by spot welding”; it is known that direct spot welding (also known as two-sided welding) is a resistance welding process where two electrodes are positioned on opposite sides of stacked; therefore, the material 220, the additional material 300 and the material 120 are joined by the direct spot welding in the conducting direct spot welding for the workpiece). Claims 3-4, 7-8 are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. (KR 102352109 B1, previously cited) in view of Barkhausen et al. (DE 102020108759 A1, previously cited), and further in view of Gabbianelli et al. (U.S. Pub. No. 2004/0065641 A1, previously cited) and Wang (U.S. Pub. No. 2010/0019785 A1, previously cited). Regarding claim 3, Kim in view of Barkhausen teaches the method set forth in claim 1, Kim does not disclose: wherein a second electrode configured to pressurize and contact the second panel and a third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel are opposed coaxially, and in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel, an insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes. Barkhausen teaches the spot welding method (Barkhausen Fig.5): wherein a second electrode (electrode 25, Barkhausen Fig.5) configured to pressurize and contact the second panel (second component 2, Barkhausen Fig.5) 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 method of Kim in view of Barkhausen, by adding second electrode configured to pressurize and contact the second panel, as taught by Barkhausen, in order to provide electrical and mechanical engagement with the second panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Kim in view of Barkhausen does not explicitly teach: a third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and two electrodes are opposed coaxially, and in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel, an insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes. Gabbianelli teaches a spot welding method (Gabbianelli Fig.1): a third electrode (second electrode 48, Gabbianelli Fig.1) configured to pressurize and contact with the third panel (side 18, Gabbianelli Fig.1) in the conducting indirect spot welding for the third panel (side 18, Gabbianelli Fig.1) and the fourth panel (right side of member 14 that is in direct contact with side 18, Gabbianelli Fig.1), and two electrodes are opposed coaxially (first electrode 44 and second electrode 48 are opposed coaxially as shown in Gabbianelli Fig.1) (Gabbianelli Par.0034 teaches: “the weld gun 30 was developed to weld members to closed section members through indirect resistance spot welding. Indirect resistance spot welding is a process where a weld is created without the inside support of a weld tip.”. It is noted that since Kim in view of Barkhausen method already teaches the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the first panel and the second panel are welded to form a first component [see the upper component includes 210 and 220 in Kim Fig.3], and the third panel and the fourth panel are welded to form a second component [see the lower component includes 110 and 120 in Kim Fig.3], and further teaches an electrode configured to pressurize and contact the second panel, as cited and incorporated above; therefore, by adding the electrode that is opposed coaxially with the electrode 25 taught by Barkhausen; in combination, Kim in view of Barkhausen and Gabbianelli teaches an electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and the two electrodes are opposed coaxially) 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 method of Kim in view of Barkhausen, by adding a third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and two electrodes are opposed coaxially, as taught by Gabbianelli, in order to provide electrical and mechanical engagement with the third panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Furthermore, the modification also establishes a defined current path and balanced clamping forces across the workpiece stack, thereby concentrating heat at the intended interface between the third and the fourth panels; thus, improve weld strength. Kim in view of Barkhausen and Gabbianelli does not explicitly teach: in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel, an insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes. Wang teaches a spot welding method (Wang Fig.1): in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel (it is noted that the Kim in view of Barkhausen and Gabbianelli method already teaches the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the first panel and the second panel are welded to form a first component [see the upper component includes 210 and 220 in Kim Fig.3], and the third panel and the fourth panel are welded to form a second component [see the lower component includes 110 and 120 in Kim Fig.3]), an insulator (insulator 36, Wang Fig.1; Wang Par.0024 teaches: “The adhesive material 36, which is usually an electrical insulator”) is disposed between the second panel (work piece 32, Wang Fig.1) and the third panel (work piece 34, Wang Fig.1) and on an axis of each of the electrodes (vertical axis of the electrodes 20A and 20B, Wang Fig.1). 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 method of Kim in view of Barkhausen and Gabbianelli, by adding the insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes, as taught by Wang, in order to electrically isolate adjacent weld zones, thereby preventing unintended electrical contact/bonding and current bypass, thereby ensuring that welding current is concentrated at the intended weld interface, resulting in improved weld strength and weld quality. Regarding claim 4, Kim in view of Barkhausen teaches the method set forth in claim 2, Kim does not disclose: wherein a second electrode configured to pressurize and contact the second panel and a third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel are opposed coaxially, and in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel, an insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes. Barkhausen teaches the spot welding method (Barkhausen Fig.5): wherein a second electrode (electrode 25, Barkhausen Fig.5) configured to pressurize and contact the second panel (second component 2, Barkhausen Fig.5) 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 method of Kim in view of Barkhausen, by adding second electrode configured to pressurize and contact the second panel, as taught by Barkhausen, in order to provide electrical and mechanical engagement with the second panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Kim in view of Barkhausen does not explicitly teach: a third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and two electrodes are opposed coaxially, and in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel, an insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes. Gabbianelli teaches a spot welding method (Gabbianelli Fig.1): a third electrode (second electrode 48, Gabbianelli Fig.1) configured to pressurize and contact with the third panel (side 18, Gabbianelli Fig.1) in the conducting indirect spot welding for the third panel (side 18, Gabbianelli Fig.1) and the fourth panel (right side of member 14 that is in direct contact with side 18, Gabbianelli Fig.1), and two electrodes are opposed coaxially (first electrode 44 and second electrode 48 are opposed coaxially as shown in Gabbianelli Fig.1) (Gabbianelli Par.0034 teaches: “the weld gun 30 was developed to weld members to closed section members through indirect resistance spot welding. Indirect resistance spot welding is a process where a weld is created without the inside support of a weld tip.”. It is noted that since Kim in view of Barkhausen method already teaches the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the first panel and the second panel are welded to form a first component [see the upper component includes 210 and 220 in Kim Fig.3], and the third panel and the fourth panel are welded to form a second component [see the lower component includes 110 and 120 in Kim Fig.3], and further teaches an electrode configured to pressurize and contact the second panel, as cited and incorporated above; therefore, by adding the electrode that is opposed coaxially with the electrode 25 taught by Barkhausen; in combination, Kim in view of Barkhausen and Gabbianelli teaches an electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and the two electrodes are opposed coaxially) 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 method of Kim in view of Barkhausen, by adding third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and two electrodes are opposed coaxially, as taught by Gabbianelli, in order to provide electrical and mechanical engagement with the third panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Furthermore, the modification also establishes a defined current path and balanced clamping forces across the workpiece stack, thereby concentrating heat at the intended interface between the third and the fourth panels; thus, improve weld strength. Kim in view of Barkhausen and Gabbianelli does not explicitly teach: in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel, an insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes. Wang teaches a spot welding method (Wang Fig.1): in the conducting indirect spot welding for the first panel and the second panel and in the conducting indirect spot welding for the third panel and the fourth panel (it is noted that the Kim in view of Barkhausen and Gabbianelli method already teaches the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the first panel and the second panel are welded to form a first component [see the upper component includes 210 and 220 in Kim Fig.3], and the third panel and the fourth panel are welded to form a second component [see the lower component includes 110 and 120 in Kim Fig.3]), an insulator (insulator 36, Wang Fig.1; Wang Par.0024 teaches: “The adhesive material 36, which is usually an electrical insulator”) is disposed between the second panel (work piece 32, Wang Fig.1) and the third panel (work piece 34, Wang Fig.1) and on an axis of each of the electrodes (vertical axis of the electrodes 20A and 20B, Wang Fig.1). 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 method of Kim in view of Barkhausen and Gabbianelli, by adding the insulator is disposed between the second panel and the third panel and on an axis of each of the electrodes, as taught by Wang, in order to electrically isolate adjacent weld zones, thereby preventing unintended electrical contact/bonding and current bypass, thereby ensuring that welding current is concentrated at the intended weld interface, resulting in improved weld strength and weld quality. Regarding claim 7, Kim in view of Barkhausen, Gabbianelli and Wang teaches the method set forth in claim 3, Kim further discloses: wherein the workpiece (workpiece comprises materials 110, 120, 210, 220; Kim Fig.3) further comprises a fifth panel (additional material 300, Kim Fig.10) stacked between the second panel (material 220, Kim Fig.3) and the third panel (material 120, Kim Fig.3) (Kim Translated Document on page 6, paragraph 5 discloses: “in the final assembly step (S200), the first assembly 100 and the additional unit are assembled by spot welding, in the fourth embodiment, the additional unit may be an additional steel material (300).”, and see Fig.10 of Kim; in combination, by further adding additional material 300 to the workpiece, the additional material 300 is stacked between the material 220 and the material 120), and the second panel (material 220, Kim Fig.3), the fifth panel (additional material 300, Kim Fig.10), and the third panel (material 120, Kim Fig.3) are joined by the direct spot welding in the conducting direct spot welding for the workpiece (Kim Translated Document on page 6, last paragraph discloses: “in the same assembly method as described above, two or more assemblies are made by resistance element welding, and the additional steel material 300 is contacted, and 5 or more different materials are finally assembled by spot welding”; it is known that direct spot welding (also known as two-sided welding) is a resistance welding process where two electrodes are positioned on opposite sides of stacked; therefore, the material 220, the additional material 300 and the material 120 are joined by the direct spot welding in the conducting direct spot welding for the workpiece). Regarding claim 8, Kim in view of Barkhausen, Gabbianelli and Wang teaches the method set forth in claim 4, Kim further discloses: wherein the workpiece (workpiece comprises materials 110, 120, 210, 220; Kim Fig.3) further comprises a fifth panel (additional material 300, Kim Fig.10) stacked between the second panel (material 220, Kim Fig.3) and the third panel (material 120, Kim Fig.3) (Kim Translated Document on page 6, paragraph 5 discloses: “in the final assembly step (S200), the first assembly 100 and the additional unit are assembled by spot welding, in the fourth embodiment, the additional unit may be an additional steel material (300).”, and see Fig.10 of Kim; in combination, by further adding additional material 300 to the workpiece, the additional material 300 is stacked between the material 220 and the material 120), and the second panel (material 220, Kim Fig.3), the fifth panel (additional material 300, Kim Fig.10), and the third panel (material 120, Kim Fig.3) are joined by the direct spot welding in the conducting direct spot welding for the workpiece (Kim Translated Document on page 6, last paragraph discloses: “in the same assembly method as described above, two or more assemblies are made by resistance element welding, and the additional steel material 300 is contacted, and 5 or more different materials are finally assembled by spot welding”; it is known that direct spot welding (also known as two-sided welding) is a resistance welding process where two electrodes are positioned on opposite sides of stacked; therefore, the material 220, the additional material 300 and the material 120 are joined by the direct spot welding in the conducting direct spot welding for the workpiece). Claims 9-10, and 17 are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. (KR 102352109 B1, previously cited) in view of Barkhausen et al. (DE 102020108759 A1, previously cited), and further in view of Tanigawa et al. (JP 2021023945 A, previously cited). Regarding claim 9, Kim discloses a spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3) for use in the spot welding method according to claim 1 (see the rejection of claim 1 above), the spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3) comprising: a first electrode (upper electrode E, Kim Fig.3) configured to pressure and contact an outer surface of the first panel (top surface of the material 210, Kim Fig.3); a fourth electrode (lower electrode E, Kim Fig.3) that is opposed to the first electrode (upper electrode E, Kim Fig.3) coaxially (as shown in Kim Fig.3), the fourth electrode (lower electrode E, Kim Fig.3) being configured to pressurize and contact an outer surface of the fourth panel (bottom surface of the material 110, Kim Fig.3); Kim does not explicit disclose: a second electrode disposed at a position deviating from a central axis of the first electrode, the second electrode being configured to pressurize and contact an outer surface of the second panel; a third electrode that is opposed to the second electrode coaxially, the third electrode being configured to pressurize and contact an outer surface of the third panel; a first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode. Barkhausen teaches a spot welding device (Barkhausen Fig.5): a second electrode (electrode 25, Barkhausen Fig.5) disposed at a position deviating from a central axis of the first electrode (electrode 23, Barkhausen Fig.5), the second electrode (electrode 25, Barkhausen Fig.5) being configured to pressurize and contact an outer surface of the second panel (upper surface of the component 2, Barkhausen Fig.5) 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 spot welding device of Kim, by adding second electrode disposed at a position deviating from a central axis of the first electrode, the second electrode being configured to pressurize and contact an outer surface of the second panel, as taught by Barkhausen, in order to provide electrical and mechanical engagement with the second panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Kim in view of Barkhausen does not explicit teach: a third electrode that is opposed to the second electrode coaxially, the third electrode being configured to pressurize and contact an outer surface of the third panel; a first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode. Tanigawa teaches a spot welding device (spot welding device 1, Tanigawa Fig.5): a third electrode (electrode 22, Tanigawa Fig.5) that is opposed to the second electrode (electrode 21, Tanigawa Fig.5) coaxially (as shown in Tanigawa Fig.5), the third electrode (electrode 22, Tanigawa Fig.5) being configured to pressurize and contact an outer surface of the third panel (It is noted that since Kim in view of Barkhausen already teaches the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the first panel and the second panel are welded to form a first component [see the upper component includes 210 and 220 in Kim Fig.3], and the third panel and the fourth panel are welded to form a second component [see the lower component includes 110 and 120 in Kim Fig.3], and further teaches the second electrode configured to pressurize and contact the second panel, as cited and incorporated above; therefore, by adding the electrode that is opposed coaxially with the electrode 25 taught by Barkhausen; in combination, Kim in view of Barkhausen and Tanigawa teaches third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and the two electrodes are opposed coaxially); a first circuit (circuit 51, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 5 teaches: “Then, the spot welding device 1 includes a second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 and grounds the first electrode 11. As shown in FIG. 5, the second power supply device 27 described above is also connected to the second circuit 51.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”); a third circuit (circuit 16, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 3 teaches: “the first spot welded portion 10 includes a first circuit 16 that electrically connects the first electrode 11 and the second electrode 12 and grounds the second electrode 12. The first power supply device 17 is connected to the first circuit 16.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”). 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 spot welding device of Kim in view of Barkhausen, by adding third electrode that is opposed to the second electrode coaxially, the third electrode being configured to pressurize and contact an outer surface of the third panel; first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode, as taught by Tanigawa, in order to provide electrical and mechanical engagement with the third panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Additionally, the modification also establishes a defined current path and balanced clamping forces across the workpiece stack, thereby concentrating heat at the intended interface between the third and the fourth panels; thus, improve weld strength. Furthermore, the modification also allows direct spot welding and indirect spot welding to be performed by a single spot welding device, as recognized by Tanigawa [Tanigawa, Translated Document on page 4, paragraph 6]. Therefore, increase flexibility and provide cost and space efficiency. Kim in view of Barkhausen and Tanigawa does not explicit teach: a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode. However, the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced (MPEP 2144.VI.B). In this case, since Tanigawa teaches a circuit that electrically connects the two upper electrodes and circuit is provided with switches so that the circuit configured to switch between a current-carrying state between the two upper electrodes and non-current-carrying state between the two upper electrodes (see the second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 as shown in Tanigawa Fig.5 & Tanigawa Translated Document on page 4, paragraphs 5-6 and as cited and explained previously), therefore, 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 spot welding device of Kim in view of Barkhausen and Tanigawa, by adding the circuit that connects two lower electrodes so that the circuit configured to switch between a current-carrying state between the two lower electrodes and a non-current-carrying state between the two lower electrodes since the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced. See MPEP 2144.VI.B. Regarding claim 10, Kim discloses a spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3) for use in the spot welding method according to claim 2 (see the rejection of claim 2 above), the spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3) comprising: a first electrode (upper electrode E, Kim Fig.3) configured to pressure and contact an outer surface of the first panel (top surface of the material 210, Kim Fig.3); a fourth electrode (lower electrode E, Kim Fig.3) that is opposed to the first electrode (upper electrode E, Kim Fig.3) coaxially (as shown in Kim Fig.3), the fourth electrode (lower electrode E, Kim Fig.3) being configured to pressurize and contact an outer surface of the fourth panel (bottom surface of the material 110, Kim Fig.3); Kim does not explicit disclose: a second electrode disposed at a position deviating from a central axis of the first electrode, the second electrode being configured to pressurize and contact an outer surface of the second panel; a third electrode that is opposed to the second electrode coaxially, the third electrode being configured to pressurize and contact an outer surface of the third panel; a first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode. Barkhausen teaches a spot welding device (Barkhausen Fig.5): a second electrode (electrode 25, Barkhausen Fig.5) disposed at a position deviating from a central axis of the first electrode (electrode 23, Barkhausen Fig.5), the second electrode (electrode 25, Barkhausen Fig.5) being configured to pressurize and contact an outer surface of the second panel (upper surface of the component 2, Barkhausen Fig.5) 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 spot welding device of Kim, by adding second electrode disposed at a position deviating from a central axis of the first electrode, the second electrode being configured to pressurize and contact an outer surface of the second panel, as taught by Barkhausen, in order to provide electrical and mechanical engagement with the second panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Kim in view of Barkhausen does not explicit teach: a third electrode that is opposed to the second electrode coaxially, the third electrode being configured to pressurize and contact an outer surface of the third panel; a first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode. Tanigawa teaches a spot welding device (spot welding device 1, Tanigawa Fig.5): a third electrode (electrode 22, Tanigawa Fig.5) that is opposed to the second electrode (electrode 21, Tanigawa Fig.5) coaxially (as shown in Tanigawa Fig.5), the third electrode (electrode 22, Tanigawa Fig.5) being configured to pressurize and contact an outer surface of the third panel (It is noted that since Kim in view of Barkhausen already teaches the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the first panel and the second panel are welded to form a first component [see the upper component includes 210 and 220 in Kim Fig.3], and the third panel and the fourth panel are welded to form a second component [see the lower component includes 110 and 120 in Kim Fig.3], and further teaches the second electrode configured to pressurize and contact the second panel, as cited and incorporated above; therefore, by adding the electrode that is opposed coaxially with the electrode 25 taught by Barkhausen; in combination, Kim in view of Barkhausen and Tanigawa teaches third electrode configured to pressurize and contact with the third panel in the conducting indirect spot welding for the third panel and the fourth panel, and the two electrodes are opposed coaxially); a first circuit (circuit 51, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 5 teaches: “Then, the spot welding device 1 includes a second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 and grounds the first electrode 11. As shown in FIG. 5, the second power supply device 27 described above is also connected to the second circuit 51.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”); a third circuit (circuit 16, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 3 teaches: “the first spot welded portion 10 includes a first circuit 16 that electrically connects the first electrode 11 and the second electrode 12 and grounds the second electrode 12. The first power supply device 17 is connected to the first circuit 16.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”). 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 spot welding device of Kim in view of Barkhausen, by adding third electrode that is opposed to the second electrode coaxially, the third electrode being configured to pressurize and contact an outer surface of the third panel; first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode, as taught by Tanigawa, in order to provide electrical and mechanical engagement with the third panel, thereby completing the welding circuit and enabling controlled current flow and pressure at the intended weld interface for the indirect resistance welding configuration. Additionally, the modification also establishes a defined current path and balanced clamping forces across the workpiece stack, thereby concentrating heat at the intended interface between the third and the fourth panels; thus, improve weld strength. Furthermore, the modification also allows direct spot welding and indirect spot welding to be performed by a single spot welding device, as recognized by Tanigawa [Tanigawa, Translated Document on page 4, paragraph 6]. Therefore, increase flexibility and provide cost and space efficiency. Kim in view of Barkhausen and Tanigawa does not explicit teach: a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode. However, the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced (MPEP 2144.VI.B). In this case, since Tanigawa teaches a circuit that electrically connects the two upper electrodes and circuit is provided with switches so that the circuit configured to switch between a current-carrying state between the two upper electrodes and non-current-carrying state between the two upper electrodes (see the second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 as shown in Tanigawa Fig.5 & Tanigawa Translated Document on page 4, paragraphs 5-6 and as cited and explained previously), therefore, 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 spot welding device of Kim in view of Barkhausen and Tanigawa, by adding the circuit that connects two lower electrodes so that the circuit configured to switch between a current-carrying state between the two lower electrodes and a non-current-carrying state between the two lower electrodes since the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced. See MPEP 2144.VI.B. Regarding claim 17, Kim in view of Barkhausen and Tanigawa teaches the spot welding device set forth in claim 9, Kim does not disclose: wherein the first electrode and the fourth electrode constitute part of a first welding gun attached to a tip end of a first robot arm, and the second electrode and the third electrode constitute part of a second welding gun attached to a tip end of a second robot arm. Tanigawa teaches a spot welding device (spot welding device 1, Tanigawa Fig.2): wherein the first electrode (first electrode 11, Tanigawa Fig.2) and the fourth electrode (second electrode 12, Tanigawa Fig.2) constitute part of a first welding gun (first welding gun includes the first electrode gun 11b and the first electrode driving means 11c, Tanigawa Fig.2) attached to a tip end of a first robot arm (support portion 15, Tanigawa Fig.2) (Tanigawa Translated Document on page 5 – paragraph 3 teaches: “The first electrode driving means 11c is connected to the tip of the support portion 15. A columnar first electrode gun 11b is connected to the tip of the first electrode driving means 11c.”), and the second electrode (third electrode 21, Tanigawa Fig.2) and the third electrode (fourth electrode 22, Tanigawa Fig.2) constitute part of a second welding gun (second welding gun includes the third electrode gun 21b and the third electrode driving means 21c, Tanigawa Fig.2) attached to a tip end of a second robot arm (support portion 25, Tanigawa Fig.2) (Tanigawa Translated Document on page 6 – paragraph 6 teaches: “A third electrode driving means 21c is connected to the tip of the support portion 25. A columnar third electrode gun 21b is connected to the tip of the third electrode driving means 21c.”). 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 spot welding device of Kim in view of Barkhausen and Tanigawa, by adding the teachings of the first electrode and the fourth electrode constitute part of a first welding gun attached to a tip end of a first robot arm, and the second electrode and the third electrode constitute part of a second welding gun attached to a tip end of a second robot arm, as taught by Tanigawa, in order to independently position the two electrode pairs at their respective workpiece contact locations while maintaining coaxial alignment with each pair. Separate robot arms would permit adjustment of the relative spacing and approach of the welding guns to accommodate different panel geometries and welding locations, thereby improving electrode accessibility and enabling repeatable positioning without manually relocating the guns or repositing the workpiece for each location. Thus, the modification would improve welding quality, increase preciseness, and save time for calibration. Claims 11-12 are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. (KR 102352109 B1, previously cited) in view of Barkhausen et al. (DE 102020108759 A1, previously cited), Gabbianelli et al. (U.S. Pub. No. 2004/0065641 A1, previously cited), Wang (U.S. Pub. No. 2010/0019785 A1, previously cited), and further in view of Tanigawa et al. (JP 2021023945 A, previously cited). Regarding claim 11, Kim in view of Barkhausen, Gabbianelli and Wang teaches a spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3, and as modified by Barkhausen, Gabbianelli and Wang; as cited and incorporated in the rejection of claim 3 above) for use in the spot welding method according to claim 3 (see the rejection of claim 3 above), the spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3, and as modified by Barkhausen, Gabbianelli and Wang; as cited and incorporated in the rejection of claim 3 above) comprising: a first electrode (upper electrode E, Kim Fig.3) configured to pressure and contact an outer surface of the first panel (top surface of the material 210, Kim Fig.3); the second electrode (electrode 25, Barkhausen Fig.5; as cited and incorporated in the rejection of claim 3 above) disposed at a position deviating from a central axis of the first electrode (electrode 23, Barkhausen Fig.5), the second electrode (electrode 25, Barkhausen Fig.5; as cited and incorporated in the rejection of claim 3 above) being configured to pressurize and contact an outer surface of the second panel (upper surface of the component 2, Barkhausen Fig.5); the third electrode (second electrode 48, Gabbianelli Fig.1; as cited and incorporated in the rejection of claim 3 above) that is opposed to the second electrode coaxially (first electrode 44 and second electrode 48 are opposed coaxially as shown in Gabbianelli Fig.1), the third electrode (second electrode 48, Gabbianelli Fig.1; as cited and incorporated in the rejection of claim 3 above) being configured to pressurize and contact an outer surface of the third panel (as cited, explained and incorporated in the rejection of claim 3 above); a fourth electrode (lower electrode E, Kim Fig.3) that is opposed to the first electrode (upper electrode E, Kim Fig.3) coaxially (as shown in Kim Fig.3), the fourth electrode (lower electrode E, Kim Fig.3) being configured to pressurize and contact an outer surface of the fourth panel (bottom surface of the material 110, Kim Fig.3); Kim in view of Barkhausen, Gabbianelli and Wang does not teach: a first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode. Tanigawa teaches a spot welding device (spot welding device 1, Tanigawa Fig.5): a first circuit (circuit 51, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 5 teaches: “Then, the spot welding device 1 includes a second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 and grounds the first electrode 11. As shown in FIG. 5, the second power supply device 27 described above is also connected to the second circuit 51.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”); a third circuit (circuit 16, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 3 teaches: “the first spot welded portion 10 includes a first circuit 16 that electrically connects the first electrode 11 and the second electrode 12 and grounds the second electrode 12. The first power supply device 17 is connected to the first circuit 16.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”). 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 spot welding device of Kim in view of Barkhausen, Gabbianelli and Wang, by adding first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode, as taught by Tanigawa, in order to allow direct spot welding and indirect spot welding to be performed by a single spot welding device, as recognized by Tanigawa [Tanigawa, Translated Document on page 4, paragraph 6]. Therefore, increase flexibility and provide cost and space efficiency. Kim in view of Barkhausen, Gabbianelli, Wang and Tanigawa does not explicit teach: a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode. However, the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced (MPEP 2144.VI.B). In this case, since Tanigawa teaches a circuit that electrically connects the two upper electrodes and circuit is provided with switches so that the circuit configured to switch between a current-carrying state between the two upper electrodes and non-current-carrying state between the two upper electrodes (see the second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 as shown in Tanigawa Fig.5 & Tanigawa Translated Document on page 4, paragraphs 5-6 and as cited and explained previously), therefore, 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 spot welding device of Kim in view of Barkhausen, Gabbianelli, Wang and Tanigawa, by adding the circuit that connects two lower electrodes so that the circuit configured to switch between a current-carrying state between the two lower electrodes and a non-current-carrying state between the two lower electrodes since the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced. See MPEP 2144.VI.B. Regarding claim 12, Kim in view of Barkhausen, Gabbianelli and Wang teaches a spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3, and as modified by Barkhausen, Gabbianelli and Wang; as cited and incorporated in the rejection of claim 4 above) for use in the spot welding method according to claim 4 (see the rejection of claim 4 above), the spot welding device (spot welding device includes upper electrode E and lower electrode E as shown in Kim Fig.3, and as modified by Barkhausen, Gabbianelli and Wang; as cited and incorporated in the rejection of claim 4 above) comprising: a first electrode (upper electrode E, Kim Fig.3) configured to pressure and contact an outer surface of the first panel (top surface of the material 210, Kim Fig.3); the second electrode (electrode 25, Barkhausen Fig.5; as cited and incorporated in the rejection of claim 4 above) disposed at a position deviating from a central axis of the first electrode (electrode 23, Barkhausen Fig.5), the second electrode (electrode 25, Barkhausen Fig.5; as cited and incorporated in the rejection of claim 4 above) being configured to pressurize and contact an outer surface of the second panel (upper surface of the component 2, Barkhausen Fig.5); the third electrode (second electrode 48, Gabbianelli Fig.1; as cited and incorporated in the rejection of claim 4 above) that is opposed to the second electrode coaxially (first electrode 44 and second electrode 48 are opposed coaxially as shown in Gabbianelli Fig.1), the third electrode (second electrode 48, Gabbianelli Fig.1; as cited and incorporated in the rejection of claim 4 above) being configured to pressurize and contact an outer surface of the third panel (as cited, explained and incorporated in the rejection of claim 4 above); a fourth electrode (lower electrode E, Kim Fig.3) that is opposed to the first electrode (upper electrode E, Kim Fig.3) coaxially (as shown in Kim Fig.3), the fourth electrode (lower electrode E, Kim Fig.3) being configured to pressurize and contact an outer surface of the fourth panel (bottom surface of the material 110, Kim Fig.3); Kim in view of Barkhausen, Gabbianelli and Wang does not teach: a first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode. Tanigawa teaches a spot welding device (spot welding device 1, Tanigawa Fig.5): a first circuit (circuit 51, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the second electrode (electrode 21, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 5 teaches: “Then, the spot welding device 1 includes a second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 and grounds the first electrode 11. As shown in FIG. 5, the second power supply device 27 described above is also connected to the second circuit 51.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”); a third circuit (circuit 16, Tanigawa Fig.5) configured to switch between (i) a current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) and (ii) a non-current-carrying state between the first electrode (electrode 11, Tanigawa Fig.5) and the fourth electrode (electrode 12, Tanigawa Fig.5) (Tanigawa Translated Document on page 4, paragraph 3 teaches: “the first spot welded portion 10 includes a first circuit 16 that electrically connects the first electrode 11 and the second electrode 12 and grounds the second electrode 12. The first power supply device 17 is connected to the first circuit 16.”, and Tanigawa Translated Document on page 4, paragraph 6 teaches: “The spot welding device 1 includes a first switch 41 (switching device) capable of switching between a state in which the first electrode 11 is connected to the first circuit 16 and a state in which the first electrode 11 is connected to the second circuit 51. Further, the spot welding device 1 includes a second switch 42 (switching device) capable of switching between a state in which the third electrode 21 is connected to the third circuit 26 and a state in which the third electrode 21 is connected to the second circuit 51. The first switch 41 and the second switch 42 (hereinafter, these may be collectively referred to as “switches 41, 42”) have the first state shown in FIG. 4 and the second state shown in FIG. It is switchable. In the first state of FIG. 4, the second circuit 51 is disconnected and the first circuit 16 and the third circuit 26 can be energized. In the second state of FIG. 5, the first circuit 16 and the third circuit 26 are disconnected and the second circuit 51 can be energized. In the second state of FIG. 5, the second electrode 12 and the fourth electrode 22 are each insulated from the other electrodes. By providing the switches 41 and 42, direct spot welding and indirect spot welding can be performed by using a single spot welding device 1. The first spot welded portion 10 and the second spot welded portion 20 may or may not be physically integrated as long as they are electrically connected by the second circuit 51.”). 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 spot welding device of Kim in view of Barkhausen, Gabbianelli and Wang, by adding first circuit configured to switch between (i) a current-carrying state between the first electrode and the second electrode and (ii) a non-current-carrying state between the first electrode and the second electrode; and a third circuit configured to switch between (i) a current-carrying state between the first electrode and the fourth electrode and (ii) a non-current-carrying state between the first electrode and the fourth electrode, as taught by Tanigawa, in order to allow direct spot welding and indirect spot welding to be performed by a single spot welding device, as recognized by Tanigawa [Tanigawa, Translated Document on page 4, paragraph 6]. Therefore, increase flexibility and provide cost and space efficiency. Kim in view of Barkhausen, Gabbianelli, Wang and Tanigawa does not explicit teach: a second circuit configured to switch between (i) a current-carrying state between the third electrode and the fourth electrode and (ii) a non-current-carrying state between the third electrode and the fourth electrode. However, the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced (MPEP 2144.VI.B). In this case, since Tanigawa teaches a circuit that electrically connects the two upper electrodes and circuit is provided with switches so that the circuit configured to switch between a current-carrying state between the two upper electrodes and non-current-carrying state between the two upper electrodes (see the second circuit 51 that electrically connects the first electrode 11 and the third electrode 21 as shown in Tanigawa Fig.5 & Tanigawa Translated Document on page 4, paragraphs 5-6 and as cited and explained previously), therefore, 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 spot welding device of Kim in view of Barkhausen, Gabbianelli, Wang and Tanigawa, by adding the circuit that connects two lower electrodes so that the circuit configured to switch between a current-carrying state between the two lower electrodes and a non-current-carrying state between the two lower electrodes since the court has held that mere duplication of parts has no patentable significance unless a new and unexpected result is produced. See MPEP 2144.VI.B. Allowable Subject Matter Claims 13-16, 18-20 are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Regarding claim 13, Kim in view of Barkhausen teaches the spot welding method set forth in claim 1, Kim in view of Barkhausen also teaches wherein: the conducting indirect spot welding for the first panel and the second panel is performed by pressurizing and contacting the first panel with a first electrode and pressurizing and contacting the second panel with a second electrode. Kim in view of Barkhausen also teaches the conducting direct spot welding for the workpiece is performed by pressurizing and contacting the first panel with the first electrode and pressurizing and contacting the fourth panel with a fourth electrode. Furthermore, Kim in view of Barkhausen and Gabbianelli teaches the conducting indirect spot welding for the third panel and the fourth panel is performed by pressurizing and contacting the third panel with a third electrode and pressurizing and contacting the fourth panel with the fourth electrode. However, when consider Applicant(s)’ claimed invention as a whole, Applicant(s)’ claim 13 also encompasses an invention that the prior art does not disclose, teach, or otherwise render obvious. More specifically, Applicant(s)’ claim 13 recites: “the first electrode, the second electrode, the third electrode, and the fourth electrode remain in contact with the workpiece at the same positions relative to the workpiece throughout the conducting indirect spot welding for the first panel and the second panel, the conducting indirect spot welding for the third panel and the fourth panel, and the conducting direct spot welding for the workpiece”. Within the context of Applicant(s)’ claimed invention as a whole, these limitations do not appear to be disclosed, taught, nor otherwise rendered obvious by the prior art, alone or in combination. Accordingly, claim 13 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Claims 14-15 are objected by virtue of their dependence on claim 13. Regarding claim 16, Kim in view of Barkhausen teaches the spot welding method set forth in claim 1, but does not teach further comprising disposing an insulator between the second panel and the third panel prior to the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the insulator comprises a rubber material or a weld bond. Additionally, the prior art Wang (U.S. Pub. No. 2010/0019785 A1, previously cited) discloses a spot welding method comprising disposing an insulator between the second panel and the third panel prior to the conducting direct spot welding between the second panel and the third panel, wherein the insulator comprises a weld bond. However, Wang does not disclose the step of disposing the insulator between the second panel and the third panel prior to the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel. Furthermore, the prior art Matsushita et al. (U.S. Pub. No. 2016/0144449 A1, newly cited) discloses a spot welding method comprising disposing an insulator between the second panel and the third panel prior to the conducting indirect spot welding between the second panel and the third panel, wherein the insulator comprises a weld bond. However, Matsushita does not disclose the step of disposing the insulator between the second panel and the third panel prior to the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel. Accordingly, when consider Applicant(s)’ claimed invention as a whole, Applicant(s)’ claim 16 encompasses an invention that the prior art does not disclose, teach, or otherwise render obvious. More specifically, Applicant(s)’ claim 16 recites: “further comprising disposing an insulator between the second panel and the third panel prior to the conducting indirect spot welding for the first panel and the second panel and the conducting indirect spot welding for the third panel and the fourth panel, wherein the insulator comprises a rubber material or a weld bond”. Within the context of Applicant(s)’ claimed invention as a whole, these limitations do not appear to be disclosed, taught, nor otherwise rendered obvious by the prior art, alone or in combination. Accordingly, claim 16 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Regarding claim 18, Kim in view of Barkhausen and Tanigawa teaches the spot welding device set forth in claim 9, Kim does not disclose the positive side and negative side selector switches or routing the three electrode-pair circuits through both switches, as required by claim 18. Additionally, Barkhausen does not teach selectively connecting the positive side of a welding power supply to the first or third electrode and the negative side to the second or fourth electrode. Furthermore, Tanigawa teaches four electrodes, power supplies 17 and 27, circuits 16, 26, and 51, and switches 41 and 42. Tanigawa Translated Document on page 4, paragraphs 3, 5-6 and Figs.4-5 describe switch 41 connecting electrode 11 selectively to circuits 16 or 51, and switch 42 connecting electrode 21 selectively to circuits 26 or 51. These switches select circuit connections for particular electrodes rather than providing the claimed electrode selection at the two sides of the recited welding power supply. Accordingly, when consider Applicant(s)’ claimed invention as a whole, Applicant(s)’ claim 18 encompasses an invention that the prior art does not disclose, teach, or otherwise render obvious. More specifically, Applicant(s)’ claim 18 recites: “a first switch coupled to a positive electrode side of the welding power supply and configured to selectively couple the welding power supply to the first electrode or the third electrode; and a second switch coupled to a negative electrode side of the welding power supply and configured to selectively couple the welding power supply to the second electrode or the fourth electrode, wherein the first circuit electrically couples the first electrode to the second electrode via the first switch and the second switch, the second circuit electrically couples the third electrode to the fourth electrode via the first switch and the second switch, and the third circuit electrically couples the first electrode to the fourth electrode via the first switch and the second switch.”. Within the context of Applicant(s)’ claimed invention as a whole, these limitations do not appear to be disclosed, taught, nor otherwise rendered obvious by the prior art, alone or in combination. Accordingly, claim 18 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Claim 19 is objected by virtue of their dependence on claim 18. Regarding claim 20, Kim in view of Barkhausen teaches the spot welding method set forth in claim 5, but does not teach further comprising disposing a first insulator between the second panel and the fifth panel and a second insulator between the fifth panel and the third panel, in regions held between an electrode configured to pressurize and contact the second panel and an electrode configured to pressurize and contact the third panel, as required by claim 20. Additionally, the prior art Wang (U.S. Pub. No. 2010/0019785 A1, previously cited) discloses a spot welding method comprising disposing an insulator between a first panel and a second panel, in regions held between an electrode configured to pressurize and contact the first panel and an electrode configured to pressurize and contact the second panel. However, Wang does not disclose disposing a first insulator between the second panel and the fifth panel and a second insulator between the fifth panel and the third panel, in regions held between an electrode configured to pressurize and contact the second panel and an electrode configured to pressurize and contact the third panel, as required by claim 20. Furthermore, the prior art Matsushita et al. (U.S. Pub. No. 2016/0144449 A1, newly cited) discloses a spot welding method comprising disposing an insulator between a first panel and a second panel, in regions held between the first panel and the second panel. However, Matsushita does not disclose disposing a first insulator between the second panel and the fifth panel and a second insulator between the fifth panel and the third panel, in regions held between an electrode configured to pressurize and contact the second panel and an electrode configured to pressurize and contact the third panel, as required by claim 20. Further still, the prior art Fröhlich et al. (U.S. Pub. No. 2018/0281345 A1, newly cited) discloses a spot welding method comprising two insulating materials on opposite sides of an intermediate panel. However, Fröhlich does not disclose disposing a first insulator between the second panel and the fifth panel and a second insulator between the fifth panel and the third panel, in regions held between an electrode configured to pressurize and contact the second panel and an electrode configured to pressurize and contact the third panel, as required by claim 20. Accordingly, when consider Applicant(s)’ claimed invention as a whole, Applicant(s)’ claim 20 encompasses an invention that the prior art does not disclose, teach, or otherwise render obvious. More specifically, Applicant(s)’ claim 20 recites: “disposing a first insulator between the second panel and the fifth panel and a second insulator between the fifth panel and the third panel, in regions held between an electrode configured to pressurize and contact the second panel and an electrode configured to pressurize and contact the third panel”. Within the context of Applicant(s)’ claimed invention as a whole, these limitations do not appear to be disclosed, taught, nor otherwise rendered obvious by the prior art, alone or in combination. Accordingly, claim 20 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. Conclusion The following prior art(s) made of record and not relied upon is/are considered pertinent to Applicant’s disclosure. Yang et al. (U.S. Pub. No. 2018/0272457 A1) discloses a method of spot welding a workpiece stack-up that includes a steel workpiece and an aluminum alloy workpiece involving passing an electrical current through the workpieces and between welding electrodes that are constructed to affect the current density of the electrical current. The welding electrodes are constructed to render the density of the electrical current greater in the steel workpiece than in the aluminum alloy workpiece. This difference in current densities can be accomplished by passing, at least initially, the electrical current between a weld face of the welding electrode in contact with the steel workpiece and a perimeter region of a weld face of the welding electrode in contact with the aluminum alloy workpiece. Taniguchi et al. (U.S. Pub. No. 2016/0271719 A1) discloses a method of resistance spot welding, which is a type of lap resistance welding. The method forms a fused portion (nugget) of an appropriate size, without the occurrence of splashing or the like, even when a galvanized steel sheet having a galvanized surface or a high strength steel sheet with a tensile strength of 780 MPa or more is included in the sheets to be welded, or when an unintended gap (sheet gap) exists between the steel sheets. THIS ACTION IS MADE FINAL. 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 mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to THAO TRAN-LE whose telephone number is (571)272-7535. The examiner can normally be reached M-F 9:00 - 5:00 EST. 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, STEVEN CRABB can be reached at (571) 270-5095. 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. /THAO UYEN TRAN-LE/Examiner, Art Unit 3761 10/01/2026
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Prosecution Timeline

Mar 01, 2023
Application Filed
Apr 30, 2026
Non-Final Rejection mailed — §103
Jul 30, 2026
Response Filed
Oct 05, 2026
Final Rejection mailed — §103 (current)

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Prosecution Projections

3-4
Expected OA Rounds
43%
Grant Probability
93%
With Interview (+50.1%)
3y 11m (~3m remaining)
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