DETAILED ACTION
Response to Amendment
In the amendment dated 2/6/2026, the following has occurred: Claim 11 has been amended.
Claims 1-19 are pending. Claims 1-13 are examined in this office action. This communication is a Non-Final Rejection in response to the "Amendment" and "Remarks" filed on 2/6/2026.
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claim Rejections - 35 USC § 103
Claims 1-13 are rejected under 35 U.S.C. 103 as being unpatentable over US 2022/0223939 A1 (US'939) in view of US 8,920,955 B1 (US'955).
As to Claim 1:
US'939 discloses:
a battery pack including one or more battery modules used in applications such as electric vehicles ([0007]);
a pack housing including a lower frame and a side frame, wherein the battery module frame includes a lower frame (210) having a bottom portion (210a) and side surface portions (210b) extending upward from the bottom portion to house the battery cell stack ([0041]);
one or more battery modules accommodated in the pack housing ([0007]);
the battery module includes a plurality of cell stacks in which a plurality of battery cells are stacked in a first direction, wherein a plurality of battery cells are stacked along a direction (e.g., x-axis direction) to form the battery cell stack ([0038]–[0040]); and
the battery module includes a plurality of end plates (300) covering the front and rear surfaces of the battery cell stack to protect the battery cell stack from external impact ([0044]).
However, US'939 does not explicitly emphasize the structural rigidity of a multi-component enclosure defined by cooperating frame members that mechanically secure internal battery structures within a rigid housing assembly to the same degree as certain battery module frame designs.
US'955 teaches a battery module assembly including frame members that define accommodation chambers for housing battery cells, wherein the assembly includes a primary retaining frame and a secondary retaining frame that together secure battery cells in position within a structural frame assembly (pp. 5–366). US'955 further teaches that structural frame components are secured together using fasteners to hold battery cells and related components firmly within the module frame, thereby improving mechanical integrity and thermal conductivity of the battery assembly (pp. 6–7).
US'939 and US'955 are analogous art because both references are directed to battery module and battery pack structures for secondary batteries, particularly addressing the structural arrangement and mechanical retention of stacked battery cells within a protective housing to ensure mechanical stability, safety, and effective thermal management.
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to modify the battery pack structure of US'939 by incorporating the frame-based structural retention and enclosure arrangement taught by US'955, thereby providing a more mechanically robust housing and mounting structure for the battery cell stack and associated end plates. One would have been motivated to do so in order to improve the structural reliability, safety, and thermal performance of the battery pack, since securing battery components within a rigid frame enclosure reduces movement of stacked battery cells under vibration or impact and improves heat dissipation paths.
As to Claim 2:
US'939 discloses a battery pack comprising a pack housing including a lower frame and a side frame ([0041]); one or more battery modules accommodated in the pack housing ([0007]); wherein the battery module includes a plurality of cell stacks in which a plurality of battery cells are stacked in a first direction ([0038]–[0040]); a plurality of end plates (300) disposed at the front and rear surfaces of the battery cell stack ([0044]); and the plurality of end plates and the plurality of cell stacks arranged along the stacking direction within the battery module.
However, US'939 does not explicitly emphasize the structural details of a fastening member that penetrates through the end plate and is fixed to the lower frame to ensure a rigid mechanical fastening between the end plate and the lower frame.
US'955 teaches a battery module assembly including a primary retaining frame and a secondary retaining frame that together define accommodation chambers for battery cells, wherein structural components of the battery module are secured using fasteners to hold the components firmly relative to the frame assembly (pp. 5–6). US'955 further teaches that fasteners may secure structural members such as metallic sheets and other internal components to the retaining frame, thereby fixing components relative to the frame structure and improving mechanical rigidity and thermal conduction of the assembly (pp. 6–7).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to modify the battery module structure of US'939 by incorporating the frame-based fastening techniques taught by US'955 so that the end plates are secured to the lower frame using fastening members that penetrate through the end plate and are fixed to the lower frame. One would have been motivated to do so in order to improve the mechanical integrity and structural stability of the battery module, since securing module components to the frame using through-fasteners reduces the likelihood of movement or separation of the battery cell stack components during vibration or mechanical loading.
As to Claim 3:
US'939 further discloses that the battery module includes a heat dissipation member disposed between the cell stack and the lower frame, specifically a thermally conductive resin layer disposed between the battery cell stack and the bottom portion of the lower frame to transfer heat generated by the battery cells to the module frame ([0051]–[0052]).
However, US'939 does not explicitly emphasize the structural use of a heat dissipation member specifically configured with high thermal conductivity resilient materials or the use of pressurized contact structures designed to maximize thermal conduction and eliminate air gaps between the cell stack and the supporting frame.
US'955 teaches a battery module assembly designed for high thermal conductivity, including a heatsink device disposed adjacent the battery cells and coupled to the frame structure to dissipate heat generated by the battery cells (pp. 5–6). US'955 further teaches that the heatsink device may include thermally conductive resilient materials such as rubber or silicone containing carbon powder or metallic powder and may be compressed between structural members to improve thermal contact and reduce air gaps (pp. 7–8).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to incorporate the thermally conductive heatsink structures and resilient thermal interface materials taught by US'955 into the battery module configuration of US'939. One would be motivated to do so in order to improve the thermal interface between the battery cell stack and the lower frame, thereby enhancing heat transfer away from the battery cells, reducing thermal resistance caused by air gaps, and improving the safety and reliability of the battery pack during high-output operation.
As to Claim 4:
US'939 further discloses that the battery module includes a heat dissipation member disposed between the cell stack and the lower frame, specifically a thermally conductive resin layer located between the battery cell stack and the bottom portion of the lower frame for transferring heat generated by the battery cells to the module frame ([0051]–[0052]).
However, US'939 does not explicitly emphasize the precise surface-to-surface interface where the opposite side of the heat dissipation member is configured to directly contact the pack housing to ensure a highly efficient thermal conduction path in the exact manner specified.
US'955 teaches a battery module assembly designed for high thermal conductivity in which a heatsink device (heat dissipation member) is positioned between battery components and the module frame to facilitate heat transfer from the battery cells to the surrounding frame structure (pp. 5–6). US'955 further teaches that the heatsink device is arranged such that one side contacts the battery-related electrical components while the opposite side contacts the frame structure, and the heatsink device may be compressed between structural members to ensure intimate surface contact and eliminate air gaps that would otherwise impede thermal conduction (pp. 7–8).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to configure the heat dissipation member of US'939 such that the opposite surface of the dissipation member is in contact with the pack housing as taught by the high-conductivity heatsink interface arrangements of US'955. One would be motivated to do so to improve the thermal conduction path from the heat-generating battery cells to the pack housing, thereby reducing thermal resistance, eliminating insulating air gaps, and improving the overall thermal management and operational reliability of the battery pack.
As to Claim 5:
US'939 further discloses that the pack housing includes a cooling member (730), such as a cooling plate disposed on the lower frame, wherein the cooling member is positioned to dissipate heat transferred from the battery module through the thermally conductive resin layer ([0053]–[0054]).
However, US'939 does not explicitly emphasize the structural optimization of the interface between the cooling member and the heat dissipation member, particularly with respect to the use of resilient high-thermal-conductivity materials configured to be compressed to ensure improved thermal contact and elimination of air gaps.
US'955 teaches a battery module assembly featuring a heatsink device mounted relative to a secondary retaining frame that supports the battery cells (pp. 5–6). US'955 further teaches that the heatsink device may include thermally conductive resilient materials, such as rubber or silicone containing metallic or carbon powder, and that the heatsink device may be compressed between module components and the frame to ensure intimate contact and improve heat transfer efficiency (pp. 7–8).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to incorporate the heatsink interface techniques taught by US'955 into the cooling member arrangement of US'939 so that the cooling member disposed on the lower frame provides improved thermal contact with the heat dissipation member. One would be motivated to do so in order to maximize the thermal interface between the cooling member and the heat dissipation member, thereby reducing thermal resistance, eliminating insulating air gaps, and improving the overall heat dissipation efficiency of the battery pack during operation.
As to Claim 6:
US'939 further discloses that the battery module includes a heat dissipation member disposed between the cell stack and the lower frame, specifically a thermally conductive resin layer (740) disposed between the battery cell stack and the lower frame to transfer heat generated by the battery cells to the module frame ([0051]–[0052]). US'939 further teaches that the thermally conductive resin layer may include thermally conductive materials such as silicone or urethane resin to facilitate heat transfer between the battery cells and the frame structure ([0052]).
However, US'939 does not explicitly emphasize the structural use of a heat dissipation member specifically including a thermally conductive adhesive layer configured to be compressed to improve thermal contact between the battery cells and the supporting frame.
US'955 teaches a battery module assembly including a heatsink device disposed between battery components and a secondary retaining frame, wherein the heatsink device includes a thermally conductive interface material composed of resilient materials such as rubber or silicone combined with carbon powder or metallic powder to improve thermal conductivity (pp. 7–8). US'955 further teaches that the heatsink device may be compressed between structural components so that the material is deformed to eliminate air gaps and provide a highly conductive thermal path between the battery components and the frame structure (pp. 7–8).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to utilize the thermally conductive interface materials taught by US'955 as the heat dissipation member of US'939 so that the heat dissipation member includes a thermally conductive adhesive layer providing improved thermal contact between the battery cell stack and the lower frame. One would be motivated to do so in order to enhance heat transfer efficiency, reduce thermal resistance caused by air gaps, and improve the structural stability of the battery module under vibration and thermal cycling conditions.
As to Claim 7:
US'939 discloses a battery pack comprising a pack housing 700 including a lower frame 710 and a side frame 720a; one or more battery modules 100 accommodated in the pack housing 700; the battery module 100 includes a plurality of cell stacks 1000 in which battery cells 2100 are stacked in a first direction; and a plurality of end plates 300 fastened to the lower frame 710; wherein the plurality of end plates 300 and the plurality of cell stacks 1000 are alternately disposed in the first direction ([0011], [0046], [0078]).
US'939 further discloses that the side frame 720a includes a guide block 740 protruding in a second direction perpendicular to the first direction ([0054]–[0055]); and that at least one of the plurality of end plates 300 includes an insertion groove 320 into which the guide block 740 is inserted ([0054]–[0055]).
However, US'939 does not explicitly emphasize the structural reinforcement and rigid frame-retention characteristics of the guide block and insertion groove interface when integrated within a secondary retaining frame environment designed to maintain alignment of the battery module under vibration and mechanical loading conditions.
US'955 teaches a battery module assembly including a primary retaining frame and a secondary retaining frame that support and position battery cells within the module structure (pp. 5–6). US'955 further teaches that structural components of the module may include mating structures or complementary engagement features that align and secure components relative to the retaining frames to maintain mechanical rigidity and reduce displacement of internal battery components (pp. 6–7).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to incorporate the rigid frame-retention and component alignment principles taught by US'955 into the guide block and insertion groove interface of US'939 so that the engagement between the side frame and the end plate provides improved structural alignment and mechanical stability for the battery module within the pack housing. One would be motivated to do so in order to improve the assembly accuracy and vibration resistance of the battery module, thereby preventing displacement of the battery cell stacks and maintaining consistent positioning of the module components during operation.
As to Claim 8:
US'939 discloses a battery pack comprising a pack housing including a lower frame and a side frame ([0046]); the battery module includes cell stacks and end plates alternately disposed in a first direction ([0011]); the side frame 720a includes a guide block 740 and at least one end plate includes an insertion groove ([0054]).
US'939 further discloses that a venting passage 750 having at least a portion extending in the first direction is formed in the side frame 720a ([0056]); the side frame 720a includes a plurality of openings 760 communicating with the venting passage 750 and an internal space of the pack housing 700 ([0057]); and the guide block 740 is disposed between the plurality of openings 760 ([0057]).
However, US'939 does not explicitly emphasize the structural reinforcement and enclosure alignment characteristics of integrating the venting passage and openings within a rigid frame structure designed to maintain precise positioning of the battery modules and provide improved mechanical stability of the pack housing.
US'955 teaches a battery module assembly including structural retaining frames that form a rigid housing for battery cells and associated components (pp. 5–6). US'955 further teaches that the structural frame members are designed to maintain alignment of module components and provide a robust enclosure that supports internal components and maintains structural integrity during operation (pp. 6–7).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to incorporate the rigid frame reinforcement and alignment principles taught by US'955 into the side frame structure of US'939 including the venting passage and openings so that the housing maintains both structural rigidity and controlled gas venting pathways. One would be motivated to do so in order to maintain proper alignment and structural stability of the battery module while providing a dedicated pathway for venting gases generated during abnormal operating conditions, thereby improving the safety and reliability of the battery pack.
As to Claim 9:
US'939 further discloses that the battery module includes an insulating member disposed between battery cells or structural components to improve insulation and thermal isolation between battery components ([0046]). Accordingly, US'939 teaches a heat insulating member disposed between structural components of the battery module to prevent heat transfer.
However, US'939 does not explicitly emphasize the structural use of specialized resilient insulating materials configured to be compressed to ensure a complete insulating interface between the end plate and the cell stack.
US'955 teaches a battery module assembly utilizing resilient materials such as rubber or silicone as part of the internal structural and thermal interface assembly, wherein such materials are positioned between battery components and the retaining frames to improve structural seating and thermal management (pp. 7–8). US'955 further teaches that these resilient materials may be compressed between structural members so that the material deforms to eliminate air gaps and provide consistent contact across the interface surfaces.
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to utilize the resilient interface materials taught by US'955 as the insulating member in the battery module of US'939 so that the insulating member is positioned between the end plate and the cell stack to prevent heat transfer. One would be motivated to do so in order to improve the thermal insulation between the end plate and the battery cell stack, reduce thermal conduction between structural members, and enhance the safety and thermal stability of the battery pack during operation.
As to Claim 10:
US'939 further discloses that the battery module includes a busbar assembly (600) electrically connected to the battery cells of the cell stack, wherein the busbar assembly is arranged adjacent the cell stack to provide electrical connection between the battery cells ([0047]–[0049]). US'939 further teaches that the busbar assembly is disposed to oppose the cell stack in a direction perpendicular to the stacking direction of the battery cells, thereby electrically connecting the battery cells within the module.
However, US'939 does not explicitly emphasize the structural integration of the busbar connection assembly within a rigid frame structure to ensure stable electrical connections under mechanical loading conditions.
US'955 teaches a battery module including a top common electrode electrically connected to electrodes of the battery cells, which functions as a busbar assembly providing electrical interconnection between battery cells (pp. 5–6). US'955 further teaches that the electrical connection components are supported by a secondary retaining frame that secures the battery cells and associated electrical components within the module structure to improve mechanical rigidity and stability of the electrical connections (pp. 6–7).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to incorporate the rigid busbar mounting and frame integration techniques taught by US'955 into the battery module configuration of US'939 so that the busbar assembly electrically connected to the battery cells is structurally supported by the module frame. One would be motivated to do so to improve the mechanical stability and reliability of the electrical connections between battery cells, particularly under vibration and thermal cycling conditions commonly encountered in battery pack applications such as electric vehicles.
As to Claim 11:
US'939 further discloses that the cell stack includes a battery cell assembly comprising a plurality of battery cells stacked along a direction within a module structure ([0038]–[0040]). US'939 also discloses structural frame members associated with the battery module that support and position the battery cells within the module structure ([0041]). Accordingly, US'939 teaches a battery module including a battery cell assembly having a plurality of battery cells opposing each other in the first direction and structural members supporting the battery cells within the module assembly.
However, US'939 does not explicitly emphasize the structural use of multiple support members spaced apart from each other in a second direction that support the battery cells and provide structural mounting points for coupling the busbar assembly to the support members.
US'955 teaches a battery module assembly including a primary retaining frame and a secondary retaining frame that support and position battery cells within accommodation chambers of the frame structure (pp. 5–6). US'955 further teaches that electrical connection components such as electrodes or busbars are coupled to structural frame members that support the battery cells, thereby securing the electrical connection components relative to the cell assembly and maintaining mechanical stability (pp. 6–7).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to configure the structural members supporting the battery cells in the module of US'939 as spaced support members similar to the retaining frames taught by US'955 and to couple the busbar assembly to at least one of the support members. One would be motivated to do so in order to improve the structural stability and alignment of the electrical connection components relative to the battery cells, thereby enhancing the mechanical durability and electrical reliability of the battery module during operation.
As to Claim 12:
US'939 discloses a battery pack comprising a pack housing including a lower frame and a side frame ([0041]); one or more battery modules accommodated in the pack housing ([0007]); the battery module includes a plurality of cell stacks in which a plurality of battery cells are stacked in a first direction ([0038]–[0040]); and a plurality of end plates disposed relative to the battery cell stack ([0044]). US'939 further discloses that the battery module includes a busbar assembly electrically connected to the cell stack and arranged to oppose the cell stack in a direction perpendicular to the stacking direction ([0047]–[0049]).
US'939 also teaches the use of insulating members disposed between battery components to improve electrical insulation and thermal separation within the battery module ([0046]). Accordingly, US'939 teaches insulating members disposed between battery cells or between structural components associated with the battery cells.
However, US'939 does not explicitly emphasize the structural use of specialized resilient insulating materials configured to be compressed between adjacent battery cells to ensure a complete thermal barrier across the entire interface between the cells.
US'955 teaches a battery module assembly utilizing resilient materials such as rubber or silicone as part of the internal structural and thermal interface assembly, wherein such materials may be positioned between battery components and compressed during assembly to eliminate air gaps and ensure consistent contact between adjacent components (pp. 7–8). US'955 further teaches that these resilient materials may include thermally functional additives such as carbon powder or metallic powder to improve the thermal management characteristics of the interface material.
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to utilize the resilient interface materials taught by US'955 as insulating members between adjacent battery cells in the battery module of US'939. One would be motivated to do so in order to improve the thermal isolation between adjacent battery cells, reduce heat transfer between cells during operation or abnormal thermal events, and enhance the overall thermal stability and safety of the battery module.
As to Claim 13:
US'939 further discloses that the battery module includes a cover plate coupled to the module frame and positioned over the battery cell stack to protect and secure the battery cell assembly within the module structure ([0041]). Accordingly, US'939 teaches a cover plate associated with the battery module that is coupled to the structural frame surrounding the cell stacks and end plates.
However, US'939 does not explicitly emphasize the structural use of the cover plate as a primary retaining structural member cooperating with a lower frame to rigidly secure the internal battery cell assembly.
US'955 teaches a battery module including a primary retaining frame functioning as an upper structural member that covers the battery cell assembly and cooperates with a secondary retaining frame to enclose and secure the battery cells within the module structure (pp. 5–6). US'955 further teaches that the primary retaining frame may include complementary mating structures that couple with the secondary retaining frame so that the battery cells and associated components are securely retained within the module assembly (pp. 6–7).
It would have been obvious to a person having ordinary skill in the art before the effective filing date of the claimed invention to incorporate the retaining frame coupling techniques taught by US'955 into the cover plate arrangement of US'939 so that the cover plate more rigidly couples with the structural members surrounding the cell stacks and end plates. One would be motivated to do so in order to improve the structural rigidity and retention of the battery cell assembly within the battery module, thereby preventing displacement of battery cells during vibration or thermal expansion and improving the mechanical stability of the battery pack.
Response to Arguments
Applicant’s arguments with respect to claims 1-13 have been considered but are moot because the new ground of rejection does not rely on the combination of references applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JIMMY K VO whose telephone number is (571)272-3242. The examiner can normally be reached Monday - Friday, 8 am to 6 pm EST.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Tong Guo can be reached at (571) 272-3066. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/JIMMY VO/
Primary Examiner
Art Unit 1723
/JIMMY VO/Primary Examiner, Art Unit 1723