Prosecution Insights
Last updated: April 19, 2026
Application No. 18/133,378

MODULAR BATTERY SYSTEM INCLUDING TAB-FREE BIPOLAR MODULES

Non-Final OA §102§103§112
Filed
Apr 11, 2023
Examiner
WEST, ROBERT GENE
Art Unit
1721
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
1 (Non-Final)
77%
Grant Probability
Favorable
1-2
OA Rounds
3y 4m
To Grant
99%
With Interview

Examiner Intelligence

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

Statute-Specific Performance

§103
55.4%
+15.4% vs TC avg
§102
19.3%
-20.7% vs TC avg
§112
23.8%
-16.2% vs TC avg
Black line = Tech Center average estimate • Based on career data from 99 resolved cases

Office Action

§102 §103 §112
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . If status of the application as subject to 35 U.S.C. 102 and 103 is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. Status of Claims Claims 1-20 are pending in the application and are presently examined. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. Claims 2-5, 9-11, & 15 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor(s) regard as the invention. Claim 2 states “the N-1 clad plates are arranged between adjacent ones of the N solid-state battery cells”. The meaning of “ones” is unclear. Claims 3-5 & 15 are rejected due to their dependence on claim 2. Claims 9-11 depend from claim 1. Claim 1 states: “a first terminal arranged on a first side of the enclosure; a second terminal arranged on a second side of the enclosure opposite to the first side of the enclosure” These terminals must be spaced apart, because they are on opposite sides of the enclosure. Also, although not explicitly stated in these claims, presumably one of these terminals is positive and the other is negative. Claims 9-11 then state that these terminals mate with each other; i.e. are connected to each other by a projection inserted into a recess or a bolt / screw threaded into a nut / internal threads. It is unclear how these terminals, on opposite sides of the enclosure with respect to each other, can mate with each other. Also, it is unclear how the battery could function as a battery with the positive and negative terminals shorted together. Claim 15 states: “the cathode active material includes one or more positive electroactive materials selected from a group consisting of LiCoO2, LiNixMnyCo1-x-yO2 (where 0 ≤ x ≤ 1 and 0 ≤ y ≤ 1), LiNixMn1-xO2 (where 0 ≤ x ≤ 1), Li1+xMO2 (where 0 ≤ x ≤ 1), LiMn2O4, LiNixMn1.5O4” The meaning of “M” in “Li1+xMO2” is unclear. Three of these chemical formulas define “0 ≤ x ≤ 1” for the variable “x”, but there is no such definition for “LiNixMn1.5O4”. The meaning of “x” is unclear in this chemical formula. Note that if the range is the same for all chemical formulas, then it can be defined once. For present examination, it is presumed that the range for “x” in all claim 15 chemical formulas is “0 ≤ x ≤ 1”. Claim Rejections - 35 USC § 102 The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. The claims are in bold font, the prior art is in parentheses. Claims 1 & 6 are rejected under 35 U.S.C. 102(a)(1) and 102(a)(2) as being anticipated by US20210320371A1 (Dunn). Dunn teaches the following claim 1 limitations: A modular bipolar solid-state battery (paragraph 44; figure 1: interconnected battery module system 10 with interconnected battery modules 100) comprising: T solid-state battery modules, where T is an integer greater than one (paragraph 44; figure 1: plurality of interconnected battery modules 100), and wherein each of the T solid-state battery modules includes: an enclosure (paragraph 57; figure 5: enclosure 500); a first terminal arranged on a first side of the enclosure (paragraph 87; figure 14: first electrical terminal 1810 on a first side 1402); a second terminal arranged on a second side of the enclosure opposite to the first side of the enclosure (paragraph 87; figure 14: second terminal on a second side 1404, the second side 1404 opposite the first side 1402); and N solid-state battery cells arranged and interconnected in the enclosure, where N is an integer greater than one (paragraph 61; figure 6: cells 405, N=20), wherein the T solid-state battery modules are connected in at least one of series and parallel (paragraph 45: series); a positive terminal of the modular bipolar solid-state battery is connected to at least one of the T solid-state battery modules; and a negative terminal of the modular bipolar solid-state battery is connected to at least another one of the T solid-state battery modules (paragraph 45: batteries in series are connected as required by this claim limitation) With regard to claim 6, Dunn teaches the limitations of claim 1 as noted above. Dunn also teaches the following claim 6 limitation: the T solid-state battery modules are arranged in a plurality of rows each including two or more of the T solid-state battery modules connected in series and further comprising connectors for connecting the T solid-state battery modules in the plurality of rows in series (paragraph 55, figures 4A-4B) Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: Determining the scope and contents of the prior art. Ascertaining the differences between the prior art and the claims at issue. Resolving the level of ordinary skill in the pertinent art. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. The claims are in bold font, the prior art is in parentheses. Claims 2-5 & 16-17 are rejected under 35 U.S.C. 103 as being unpatentable over US20210320371A1 (Dunn) in view of US20220367922A1 (Otani), US20130149592A1 (Hayashi), and US20190214650A1 (Sakamoto). With regard to claim 2, Dunn teaches the limitations of claim 1 as described above. Dunn fails to teach the following limitations of claim 2, which are taught by Otani: each of the N solid-state battery cells comprises: M solid-state cores each comprising a first current collector, cathode active material (paragraph 41; figure 1: positive electrode 21 is a positive electrode active material layer on a positive electrode foil 21A), a separator (paragraph 41; figure 1: separator 23), anode active material, and a second current collector (paragraph 41; figure 1: negative electrode 22 is a negative electrode active material layer on a negative electrode foil 22A), where M is an integer greater than one (figure 1: M=6), wherein the M solid-state cores are connected in parallel by connecting the first current collectors of the M solid-state cores in each of the N solid-state battery cells together and by connecting the second current collectors of the M solid-state cores in each of the N solid-state battery cells together (paragraph 42; figure 1: Positive electrode foil 21A non-covered portion 21C is connected at the top. Negative electrode foil 22A non-covered portion 22C connected at the bottom) Otani is directed to a battery with high rate discharge, that doesn’t cause an internal short circuit” (paragraph 7). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for each of Dunn’s cells 405 to have six cores with electrodes connected in parallel, as taught by Otani and discussed above, as part of a battery with high rate discharge and that doesn’t cause an internal short circuit. Dunn fails to teach the following limitations of claim 2, which are taught by Hayashi: N-1 clad plates (paragraph 46; figure 1: internal collection layer 4)… wherein the N-1 clad plates are arranged between (figure 1) adjacent ones of the N solid-state battery cells and the N solid-state battery cells are connected in series (paragraphs 48-50) by the N-1 clad plates Hayashi is directed to a battery structure for preventing battery characteristic deterioration (paragraph 9). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Dunn’s cells 405 to be connected in series, as taught by Hayashi and discussed above, as part of a battery structure for preventing battery characteristic deterioration. Dunn fails to teach the following limitations of claim 2, which are taught by Sakamoto: N-1 clad plates including a first side made of a first material and a second side made of a second material (paragraphs 12, 15-16, 38, & 46: layered current collector is bimetal with a first material contacting a solid-state electrolyte material and a second material contacting a cathode active material), Sakamoto is directed to a battery with a current collector that is compatible with a wide variety of materials (paragraphs 4-16). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for modified Dunn’s cells current collectors to have two materials, as taught by Sakamoto, for material compatibility. With regard to claim 3, Dunn teaches the limitations of claims 1-2 as described above. Dunn fails to teach the following limitations of claim 3, which are taught by Sakamoto: the first current collector comprises aluminum (paragraph 12: second material is aluminum) and the second current collector comprises copper (paragraph 12: second material is copper); and the first material of the N-1 clad plates comprises copper and the second material of the N-1 clad plates comprises aluminum With regard to claim 4-5, Dunn teaches the limitations of claims 1-3 as described above. Dunn also teaches the following limitations of claims 4-5: Claim 4 the enclosure includes a base portion (paragraph 57; figure 5: housing 510) and a cover (paragraph 57; figure 5: first side housing 511) Claim 5 the cover includes N vent holes (paragraphs 45, 57; figure 5: each battery module 100 has an enclosure with an aperture 530) arranged between the N-1 clad plates (battery modules 100 are between the clad plates, as discussed above, so the aperture 530 would also be between the clad plates) Claim 5 also states that the N vent holes are between a first one of the N-1 clad plates and one side of the enclosure, and between a last one of the N-1 clad plates and an opposite side of the enclosure. Dunn teaches that the apertures 530 can “extend through a first side housing 511 and a second side housing 513 of the housing 510” (paragraph 57). Thus, depending on battery module 100 arrangement between the clad plates, Dunn’s apertures 530 have a 1/3 chance of being arranged as claimed. MPEP 2144.05(II)(B) provides guidance for this issue: “When there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense. In that instance the fact that a combination was obvious to try might show that it was obvious under §103.” With only three reasonable options for battery module 100 arrangement between the clad plates, it would have been obvious, to try each option and to reach the claimed arrangement. With regard to claim 16, Dunn teaches the following claim 16 limitations: A modular bipolar solid-state battery (paragraph 44; figure 1: interconnected battery module system 10 with interconnected battery modules 100) comprising: T solid-state battery modules (paragraph 44; figure 1: plurality of interconnected battery modules 100), wherein each of the T solid-state battery modules includes an enclosure (paragraph 57; figure 5: enclosure 500), a first terminal arranged on a first side of the enclosure (paragraph 87; figure 14: first electrical terminal 1810 on a first side 1402), a second terminal arranged on a second side of the enclosure opposite to the first side of the enclosure (paragraph 87; figure 14: second terminal on a second side 1404, the second side 1404 opposite the first side 1402, and N solid-state battery cells arranged and interconnected in the enclosure, where N is an integer greater than one (paragraph 61; figure 6: cells 405, N=20)… wherein the T solid-state battery modules are connected in series in a plurality of rows and the plurality of rows are connected together in at least one of series and parallel (paragraph 45: series); a positive terminal of the modular bipolar solid-state battery is connected to at least a first one of the T solid-state battery modules; and a negative terminal of the modular bipolar solid-state battery is connected to at least a second one of the T solid-state battery modules Dunn fails to teach the following claim 16 limitations, which are taught by Otani: wherein each of the N solid-state battery cells comprises M solid-state cores each comprising a first current collector, cathode active material (paragraph 41; figure 1: positive electrode 21 is a positive electrode active material layer on a positive electrode foil 21A), a separator (paragraph 41; figure 1: separator 23), anode active material, and a second current collector (paragraph 41; figure 1: negative electrode 22 is a negative electrode active material layer on a negative electrode foil 22A), where M is an integer greater than one (figure 1: M=6), wherein the M solid-state cores are connected in parallel by connecting the first current collectors of the M solid-state cores in each of the N solid-state battery cells together and by connecting the second current collectors of the M solid-state cores in each of the N solid-state battery cells together (paragraph 42; figure 1: Positive electrode foil 21A non-covered portion 21C is connected at the top. Negative electrode foil 22A non-covered portion 22C connected at the bottom); and Dunn fails to teach the following claim 16 limitations, which are taught by Hayashi: N-1 clad plates (paragraph 46; figure 1: internal collection layer 4)… wherein the N-1 clad plates are arranged between (figure 1) adjacent ones of the N solid-state battery cells and the N solid-state battery cells are connected in series (paragraphs 48-50) by the N-1 clad plates Dunn fails to teach the following claim 16 limitations, which are taught by Sakamoto: N-1 clad plates including a first side made of a first material and a second side made of a second material (paragraphs 12, 15-16, 38, & 46: layered current collector is bimetal with a first material contacting a solid-state electrolyte material and a second material contacting a cathode active material), With regard to claim 17, Dunn teaches the limitations of claim 16 as described above. Dunn also teaches the following claim 17 limitations: a structural support member including cooling channels (paragraphs 70-71; figure 9: cold plate 920 has a fluid inlet 922 and a fluid outlet 924 connected by a cooling channel through the cold plate 920) Claim 17 requires the structural support member to be — arranged between a first row of the T solid-state battery modules and a second row of the T solid-state battery modules Dunn fails to state that the cold plate 920 is between rows of modules. It would have been obvious to have placed Dunn’s cold plates 920 between rows of modules because of the need to cool all battery modules. Claims 7 & 12 are rejected under 35 U.S.C. 103 as being unpatentable over US20210320371A1 (Dunn). With regard to claim 7, Dunn teaches the limitations of claim 1 as described above. Claim 7 states: the T solid-state battery modules are arranged in a plurality of rows each including two or more of the T solid-state battery modules connected in series and further comprising connectors for connecting the T solid-state battery modules in the plurality of rows in parallel Dunn doesn’t teach this specific series and parallel connection. Dunn, however, does teach that the battery modules may be connected in series or parallel (paragraph 7). Use of series and parallel connections is common knowledge for battery connections. Batteries in series is used to increase voltage. Batteries in parallel increases capacity without changing voltage. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to apply these principles to Dunn’s interconnected battery module system, to achieve desired battery module system voltage and capacity. With regard to claim 12, Dunn teaches the limitations of claim 1 as described above. Dunn also teaches the following claim 12 limitation: a structural support member including cooling channels (paragraphs 70-71; figure 9: cold plate 920 has a fluid inlet 922 and a fluid outlet 924 connected by a cooling channel through the cold plate 920) Claim 12 requires the structural support member to be — arranged between a first row of the T solid-state battery modules and a second row of the T solid-state battery modules Dunn fails to state that the cold plate 920 is between rows of modules. It would have been obvious to have placed Dunn’s cold plates 920 between rows of modules because of the need to cool all battery modules. Claims 8-11 are rejected under 35 U.S.C. 103 as being unpatentable over US20210320371A1 (Dunn), as applied to claim 1, and further in view of US20210296741A1 (Koetting). Claims 8-11 recite rectangular plates, with are connected to each other in claims 9-11. As discussed in the 35 U.S.C. 112(b) section above, this connection between the rectangular plates is unclear. Regardless of how this connection is interpreted, it seems to be taught by Koetting. Koetting teaches positive and negative terminals 102, 104, which are illustrated as rectangular plates, each connected to a busbar 202 with a fasteners 210, such as a screw or a bolt. Locations where the fasteners 210 pass into or through the busbars 202 are also rectangular plates. The screw or bolt would be a projection from one of the terminal or busbar into internal threads of the other, thus mating the terminal with the busbar. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to apply Koetting’s connections between rectangular plates to Dunn’s battery modules as a way to connect electrical components. Claims 13-14 are rejected under 35 U.S.C. 103 as being unpatentable over US20210320371A1 (Dunn), as applied to claim 1, and further in view of US20160049703A1 (Lobert). Dunn fails to teach the following limitations of claims 13-14, which are taught by Lobert: Claim 13 T sensors connected between the T solid-state battery modules, respectively Claim 14 the T sensors include at least one of a temperature sensor and a voltage sensor Lobert is directed to battery modules with heat exchanger fins for battery cooling (paragraph 59). Lobert also teaches temperature sensing components 84, between the battery modules 30, in contact with the heat exchanger fin 68 (paragraph 55; figures 5-6 & 8). Batteries have an optimal operating temperature. A temperature sensor can indicate actual battery temperature. This temperature can be input into the battery cooling system in a feedback loop in order to control the system for optimal battery temperature. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to use temperature sensors, as taught by Lobert, between Dunn’s battery modules, in order to maintain optimal battery operating temperature. Claims 15 & 20 are rejected under 35 U.S.C. 103 as being unpatentable over US20210320371A1 (Dunn) in view of US20220367922A1 (Otani), US20130149592A1 (Hayashi), and US20190214650A1 (Sakamoto), with regard to claims 1-2 & 16, and further in view of EP2814082B1 (Buqa). Dunn fails to teach the following limitations of claims 15 & 20, which are taught by Hayashi: the cathode active material includes one or more positive electroactive materials selected from a group consisting of… LiFePO4 (paragraph 67)… the anode active material is selected from a group consisting of… a lithium metal (paragraph 65)… Hayashi is directed to a battery with reduced battery characteristic deterioration (paragraph 9). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Dunn’s cells 405 to have LiFePO4 in the cathode and lithium in the anode, as taught by Hayashi, as part of a battery with reduced battery characteristic deterioration. Dunn fails to teach the following limitations of claims 15 & 20, which are taught by Buqa: the separator comprises a polymer layer that is coated with lithium aluminum titanium phosphate (LATP) and wherein the polymer layer is selected from a group consisting of polypropylene (PP) and polyethylene (PE) (claim 1) Buqa is directed to an electrochemical separator with improved wettability, electrochemical stability, and safety (paragraph 10). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for each of Dunn’s cells 405 to have a separator as described by Buqa for improved wettability, electrochemical stability, and safety. Claims 18-19 are rejected under 35 U.S.C. 103 as being unpatentable over US20210320371A1 (Dunn) in view of US20220367922A1 (Otani), US20130149592A1 (Hayashi), and US20190214650A1 (Sakamoto), as applied to claim 16, and further in view of US20160049703A1 (Lobert). Dunn fails to teach the following limitations of claims 18-19, which are taught by Lobert: Claim 18 T sensors connected between the T solid-state battery modules, respectively Claim 19 the T sensors include at least one of a temperature sensor and a voltage sensor Lobert is directed to battery modules with heat exchanger fins for battery cooling (paragraph 59). Lobert also teaches temperature sensing components 84, between the battery modules 30, in contact with the heat exchanger fin 68 (paragraph 55; figures 5-6 & 8). Batteries have an optimal operating temperature. A temperature sensor can indicate actual battery temperature. This temperature can be input into the battery cooling system in a feedback loop in order to control the system for optimal battery temperature. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, to use temperature sensors, as taught by Lobert, between Dunn’s battery modules, in order to maintain optimal battery operating temperature. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROBERT WEST whose telephone number is 703-756-1363 and email address is Robert.West@uspto.gov. The examiner can normally be reached Monday-Friday 10 am - 7 pm ET. Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Allison Bourke can be reached at 303-297-4684. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. /R.G.W./Examiner, Art Unit 1721
Read full office action

Prosecution Timeline

Apr 11, 2023
Application Filed
Feb 08, 2026
Non-Final Rejection — §102, §103, §112
Apr 13, 2026
Interview Requested

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12603286
CONDUCTIVE MATERIAL PASTE FOR ALL-SOLID-STATE SECONDARY BATTERY ELECTRODE
2y 5m to grant Granted Apr 14, 2026
Patent 12597648
BATTERY ASSEMBLY, METHOD OF PREPARATION, AND THERMAL CONTROL THEREOF
2y 5m to grant Granted Apr 07, 2026
Patent 12597594
LITHIUM MANGANESE COMPOSITE OXIDE FOR A LITHIUM SECONDARY BATTERY CATHODE ACTIVE MATERIAL
2y 5m to grant Granted Apr 07, 2026
Patent 12592414
SOLID ELECTROLYTE MEMBRANE, AND SOLID-STATE LITHIUM METAL BATTERY, BATTERY MODULE, BATTERY PACK, AND APPARATUS CONTAINING SUCH SOLID ELECTROLYTE MEMBRANE
2y 5m to grant Granted Mar 31, 2026
Patent 12586867
POROUS COMPOSITE SEPARATOR FOR SECONDARY BATTERY AND LITHIUM SECONDARY BATTERY INCLUDING THE SAME
2y 5m to grant Granted Mar 24, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

1-2
Expected OA Rounds
77%
Grant Probability
99%
With Interview (+24.9%)
3y 4m
Median Time to Grant
Low
PTA Risk
Based on 99 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month