Prosecution Insights
Last updated: April 19, 2026
Application No. 18/127,769

LIQUID STATE BATTERY AND ELECTRONIC DEVICE CONTAINING SAME

Final Rejection §103
Filed
Mar 29, 2023
Examiner
FRANCIS, ADAM JOSEPH
Art Unit
1728
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Ningde Amperex Technology Limited
OA Round
2 (Final)
74%
Grant Probability
Favorable
3-4
OA Rounds
3y 0m
To Grant
99%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allow Rate
149 granted / 202 resolved
+8.8% vs TC avg
Strong +25% interview lift
Without
With
+24.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 0m
Avg Prosecution
45 currently pending
Career history
247
Total Applications
across all art units

Statute-Specific Performance

§101
0.1%
-39.9% vs TC avg
§103
57.6%
+17.6% vs TC avg
§102
17.2%
-22.8% vs TC avg
§112
20.0%
-20.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 202 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 . Claim Status Claim 1 has been amended; support for claim 1 is found in [0031]. Claims 1-16 are currently pending and have been examined on the merits in this office action. Information Disclosure Statement The information disclosure statement(s) (IDS) submitted on 12/04/2025 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. IDS statements of previous office actions have already been considered. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. Claims 1-16 are rejected under 35 U.S.C. 103 as being unpatentable over Holman et al. (US 2018/0233722 A1) in view of Noda (US 2016/0372717 A1). Regarding claims 1 and 11, Holman discloses an electronic device comprises liquid state battery ([0001-0004] battery cells used in devices as battery cells are used to power electrical devices), comprising: A housing, wherein the housing encloses a receiving space (Figure 2B; housing pouch 240); A separator disposed in the receiving space and configured to divide the receiving space into a first chamber and a second chamber (Figure 2B; separator 230); A first slurry and a first current collector disposed in the first chamber (Figure 2B-2C; anode material 220 and cathode material 210 in separator chambers having a current collectors 212/222 [0042] active material can be a slurry material; first slurry and first collector can be read as the anode material and collector); A second slurry and a second current collector disposed in the second chamber (Figure 2B-2C; anode material 220 and cathode material 210 in separator chambers having a current collectors 212/222 [0042] active material can be a slurry material; the second slurry and second collector can be read as the cathode material and collector); A first tab electrically connected to the first current collector and extending outside the housing (Figure 2A; tabs 215 and 225); and A second tab having a different polarity than the first tab, electrically connected to the second current collector and extending outside the housing (Figure 2A; tabs 215 and 225). Holman is silent with respect to the liquid state battery having full flexibility in three-dimensional directions for electronic products and wherein the current collectors are flexible. Noda discloses a power storage device and electronic device having an electrode assembly within a casing and wherein tabs protrude from the casing and is analogous with the instant invention as being within the same field of endeavor of batteries. Noda discloses in Figure 11 and Figure 12 wherein the tabs 511/510 can extend out of the same side or different side of the electrode assembly housing (Figure 11-12). Noda further discloses wherein the power storage device comprises an exterior body that is flexible and is shown to have the current collectors being curved and also having flexibility to provide a highly reliable power storage device and long life power storage device ([0017-0019], [0054], [0175-0176] and Figures 5A-5B, Figure 21A-21C). Therefore, it would have been obvious in view of a skilled artisan to modify the battery of Holman to be made of a flexible material that can be bent and have flexibility in three-dimensions for use within flexible electronic products as taught by Noda as a simple modification as flexible batteries are well known and common in the art thus the modification is within the skill of one having ordinary skill in the art. Regarding claims 2 and 12, modified Holman discloses all the claim limitations of claims 1 and 11. Holman further discloses wherein two ends of the housing are sealed to form a first sealing edge and a second sealing edge, respectively; both the first tab and the second tab extend out of the housing through the first sealing edge or the second sealing edged, and the separator is disposed between the first tab and the second tab (Figures 2A-2C; tabs 215 and 225 extend out of a first side sealing edge; the separator is shown to extend the length of the casing and is between the first and second tabs; [0032] first and second sealing regions). Regarding claims 3 and 13, modified Holman discloses all the claim limitations of claim 1 and 11. Holman discloses wherein two ends of the housing are sealed to form a first sealing edge and a second sealing end and wherein the first and second tab extend out of the sealing edges wherein the separator is located between the first and second tab (Holman Figure 2A-2C). Holman is silent with respect to wherein the first tab and second tab extend out of the housing through the different sealing edges. Noda discloses a power storage device and electronic device having an electrode assembly within a casing and wherein tabs protrude from the casing and is analogous with the instant invention as being within the same field of endeavor of batteries. Noda discloses in Figure 11 and Figure 12 wherein the tabs 511/510 can extend out of the same side or different side of the electrode assembly housing (Figure 11-12). Therefore, it would have been obvious in view of a skilled artisan to rearrange the tab arrangement of Holman such that tabs 225 and 215 can extend from opposite sealing edges such as one from the first sealing edge and one from the second sealing edge as taught by Noda as a simple rearrangement of the tabs. The mere rearrangement of parts, without any new or unexpected results, is within the ambit of one of ordinary skill in the art. See In re Japikse, 86 USPQ 70 (CCPA 1950) (see MPEP § 2144.04). Regarding claims 4 and 14, modified Holman discloses all the claim limitations of claims 2 and 12. Holman further discloses wherein the separator comprises a first end and a second end opposite to the first end; the first end is disposed inside the first sealing edge; and the second end is disposed inside the second sealing edge (Figure 2B separator 230 is provide in the sealing regions at the first and second sealing edges). Regarding claim 5, modified Holman discloses all the claim limitations of claim 1. Holman further discloses wherein the housing comprises a first housing body and a second housing body (Figure 2b-2c; pouch 240 has two housing bodies that are sealed together); the first housing body is connected to the second housing body so as to form the receiving space (Figure 2B) the separator is disposed between the first housing body and the second housing body (Figure 2B; the separator provided between the first and second housing pouch casings); the first housing body and the separator together form the first chamber and the second housing body and the separator together form the second chamber (Figure 2B; the separator and housing parts form the first and second chambers within the battery cell). Regarding claim 6, modified Holman discloses all the claim limitations of claim 1. Holman further discloses wherein the first current collector is connected to a surface of the first housing body, the surface of the first housing body being facing the separator; and the second current collector is connected to a surface of the second housing body, the surface of the second housing body being facing the separator (Figure 2B-2C; collectors 222 and 212 are in contact with the housing body and faces the separator). Regarding claims 7 and 15, modified Holman discloses all the claim limitations of claim 1 and 11. Holman discloses wherein the tabs are connected to the collectors, however, is silent with respect to wherein the tabs can be welded to the collectors. Noda discloses a power storage device and electronic device having an electrode assembly within a casing and wherein tabs protrude from the casing and is analogous with the instant invention as being within the same field of endeavor of batteries. Noda discloses wherein the electrode tabs are welded to the electrode current collectors to electrically connect the tabs to the current collectors in order to form a secure connection ([0163]). Therefore, it would have been obvious in view of a skilled artisan to connect the tab to the current collectors by welding to create a secure electrical connection between the tabs and the current collectors as taught by Noda. Thus the modification would render obvious all the claim limitations of claims 7 and 15. Regarding claims 8 and 16, modified Holman discloses all the claim limitations of claims 1 and 11. Holman further discloses wherein the first slurry is in a liquid or fluidized state and the second slurry is in a liquid or fluidized state ([0042] anode material can be in a semisolid or a condensed ion storing liquid and is referred to as the slurry). Regarding claim 9, Holman discloses all the claim limitations of claim 2. Holman discloses wherein the battery housing is sealed, however, is silent with respect to an insulator provided between the sealing edge of the pouch housing and the first and second tabs. Noda discloses a power storage device and electronic device having an electrode assembly within a casing and wherein tabs protrude from the casing and is analogous with the instant invention as being within the same field of endeavor of batteries. Noda discloses wherein the electrode tabs contain a sealing layer 2120 that is provided on both sides of the electrode tab and is positioned between the casing and the tab to electrically insulate the casing from the tab and to create a sealing effect to effectively seal the battery casing (Figure 11, Figures 15B-15C). Therefore, it would have been obvious in view of a skilled artisan to incorporate the sealing layer 2120 on the surfaces of the electrode tab of Holman such that the sealing layer 2120 is provided between the casing and the tabs to effectively seal the battery pouch as taught by Noda. The resulting modification would have an improved sealing effect and thus would render obvious all the claim limitations of claim 9. Regarding claim 10, modified Holman discloses all the claim limitations of claim 3. Holman further discloses wherein the separator comprises a first end and a second end opposite to the first end; the first end is disposed inside the first sealing edge; and the second end is disposed inside the second sealing edge (Figure 1B-2C the separator is disposed inside the sealing edge regions of the battery pouch housing). Response to Arguments Applicant's arguments filed 12/26/2025 have been fully considered but they are not persuasive. Applicant argues that the amended claims overcome the rejection of record as the prior art fails to disclose full flexibility in three dimensions. Examiner notes that the rejection has been updated rendering the arguments moot in view of the amendments to the claims as the secondary reference Noda shows and teaches wherein the battery and current collectors can be bent and have flexibility and thus through the updated rejection would read on the claimed invention. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Wang (CN 109103495 A-as cited in the IDS)-discloses a slurry energy storage structure having a heat dissipation structure. Chami et al. (US 2018/0191030 A1)- discloses a liquid battery having flexible adhesive current collectors. Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a). A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any nonprovisional extension fee (37 CFR 1.17(a)) 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 Adam J Francis whose telephone number is (571)272-1021. The examiner can normally be reached M-Th: 7 am-4 pm 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, Matthew Martin can be reached at (571)270-7871. 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. /ADAM J FRANCIS/Primary Examiner, Art Unit 1728
Read full office action

Prosecution Timeline

Mar 29, 2023
Application Filed
Sep 26, 2025
Non-Final Rejection — §103
Dec 26, 2025
Response Filed
Feb 18, 2026
Final Rejection — §103 (current)

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

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Prosecution Projections

3-4
Expected OA Rounds
74%
Grant Probability
99%
With Interview (+24.8%)
3y 0m
Median Time to Grant
Moderate
PTA Risk
Based on 202 resolved cases by this examiner. Grant probability derived from career allow rate.

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