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 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.
Claims 1 – 5, 10, 14-15, and 23 are rejected under 35 U.S.C. 102(a)(1) and (2) as being anticipated by Mardall, et. al. (US 20120237803 A1).
Regarding Claim 1, Mardall teaches a traction battery pack venting assembly (battery pack 103, “[0036] which is preferably mounted to the vehicle’s undercarriage 104”), comprising: an enclosure (“[0032] “battery pack” as used herein refers to multiple individual batteries contained within a single piece or multi-piece housing” ; wherein the housing is the enclosure); at least one cell stack within the enclosure (“cells 501” within each module, shown as “a plurality of batteries that are segregated into battery pack compartments 104,” such that the “stack” is the grouping of cells 501 packed together); a cross-member assembly within the enclosure (cross-members 301; “[0008] a plurality of cross-members”); and a valve assembly (valve assembly 805) that opens to provide a vent path from the at least one cell stack to a passageway of the cross-member assembly (“[0012] In at least one embodiment, the system also includes a ducted exhaust guide, for example fabricated from aluminum, an aluminum alloy, or steel, that is mounted within the battery pack and which surrounds and is spaced apart from at least a portion of the inside surface of the valve retention plate. The ducted exhaust guide is configured to direct the flow of hot gas and material expelled during thermal runaway through the plurality of retention plate ports to the ambient environment, for example directing the flow of gas and material in a forward direction and away from the vehicle in which the battery pack is incorporated. Preferably at least a portion of the ducted exhaust guide is angled away from the inside surface of the battery pack at an angle of between 10 and 40 degrees, and more preferably at an angle of between 15 and 30 degrees.”); as indicated by [0039 – 45], this recites exhaust port / valve assemblies 305/307 mounted upon the cross members 301, wherein the crossmembers provide a barrier between groups of cells or modules, and direct gas into the exhaust ports, and out via an exhaust path 119 comprising a ducted exhaust guide.”). Mardall at [0012, 32, 36, 39 – 45].
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Fig. 3 of Mardall, depicting the cross members 301, which form the compartments with the central member 303 and exhaust assemblies 305 and 307.
Regarding the meaning of “a passageway of the cross-member assembly,” this includes a passageway mounted upon or coupled to the cross-members, as “of the” includes a connector or sub-element.
Claim 1 is anticipated by Mardall.
Regarding Claim 2, Claim 2 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall recites the assembly of claim 1, wherein the cell stack includes a plurality of battery cells (“[0044] in the illustrated embodiment, each module 400 contains 370 individual cells”) and at least one divider (central member 303) distributed along a cell stack axis, the at least one divider compartmentalizing an interior of the enclosure into a plurality of compartments (”[008] The sealed battery pack may be divided into a plurality of compartments, for example using a central battery pack member and a plurality of cross-members, where the battery venting assembly is integrated into one of the plurality of sealed battery pack compartments”), each of the compartments holding at least one of the battery cells (“[0044] in the illustrated embodiment, each module 400 contains 370 individual cells”). Mardall at [0008, 44].
Claim 2 is anticipated by Mardall.
Regarding Claim 3, Claim 3 relies upon Claim 2. Claim 2 is anticipated by Mardall.
Mardall recites the valve assembly (valve assembly 805) is a first valve, and further comprising a second valve, the first valve assembly configured to open to provide a vent path from a first one of the plurality of compartments to the passageway (“[0008] The sealed battery pack may be divided into a plurality of compartments, for example using a central battery pack member and a plurality of cross-members, where the battery venting assembly is integrated into one of the plurality of sealed battery pack compartments”), the second valve assembly configured to open to provide a vent path from a second one of the plurality of compartments to the passageway (each compartment comprises its own valve and exhaust port; see “[0040] During a thermal runaway event, for example one arising in one or more of the illustrated batteries 113 within the front battery pack compartment, the gas and material generated by the event easily passes out of the module since the modules, as noted above, are not designed to contain the event, or even prevent moderate pressure changes. As the pressure within the compartment (e.g., compartment 107 A) containing the cell undergoing thermal runaway increases, one or more of the valves within that compartment open. Once valve or valves 117 open, the heated gas from the thermal event is exhausted out of the battery pack. In at least one embodiment, each valve and port assembly is designed as a two stage valve that provides increased throughput as the thermal event grows and generates more gas and material. Preferably an exhaust guide is used to guide the exhausted gas and material away from the vehicle.” Here, the “passageway,” is the space between the compartments formed by the cross-member assembly and its divider and the exhaust guide.
Claim 3 is anticipated by Mardall.
Regarding Claim 4, Claim 4 relies upon Claim 2. Claim 2 is anticipated by Mardall.
Mardall recites the valve assembly is configured to open in response to at least one battery cell of the battery cells venting (“[0040] During a thermal runaway event, for example one arising in one or more of the illustrated batteries 113 within the front battery pack compartment, the gas and material generated by the event easily passes out of the module since the modules, as noted above, are not designed to contain the event, or even prevent moderate pressure changes. As the pressure within the compartment (e.g., compartment 107 A) containing the cell undergoing thermal runaway increases, one or more of the valves within that compartment open. Once valve or valves 117 open, the heated gas from the thermal event is exhausted out of the battery pack. In at least one embodiment, each valve and port assembly is designed as a two stage valve that provides increased throughput as the thermal event grows and generates more gas and material. Preferably an exhaust guide is used to guide the exhausted gas and material away from the vehicle.) Mardall at [0040].
Claim 4 is anticipated by Mardall.
Regarding Claim 5, Claim 5 relies upon Claim 2. Claim 2 is anticipated by Mardall.
Mardall recites the valve assembly is a first valve assembly provided by a first perforated area within a sheet of material (“[0027] the perforated valve assembly cover), and further comprising a second valve assembly provide by a second perforated area within the sheet of material, the first valve assembly configured to open to provide a vent path from a first one of the plurality of compartments to the passageway, the second valve assembly opening to provide a vent path from a second one of the plurality of compartments to the passageway (as previously discussed, each compartment comprises at least one valve; see “[0050] Cover plate 1301 includes a plurality of perforations 1303 , thus insuring that air can flow through the valve assembly whenever the valves open. It will be appreciated that plate 1301 can also utilize slots or other configurations that provide air flow through the assembly.”).
Claim 5 is anticipated by Mardall.
Regarding Claim 10, Claim 10 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall teaches wherein the valve assembly is provided by a perforated area within a sheet of material. teaches “[0050] Cover plate 1301 includes a plurality of perforations 1303 , thus insuring that air can flow through the valve assembly whenever the valves open. It will be appreciated that plate 1301 can also utilize slots or other configurations that provide air flow through the assembly,” and that “[0049] Preferably valves 1003 are fabricated from an elastomer, such as fluorosilicone, that is resistant to solvents, oils and other contaminants and is capable of providing a good seal when compressed against the sealing surface of retention plate 901.”
Claim 10 is anticipated by Mardall.
Regarding Claim 14, Claim 14 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall recites “[0047] FIGS. 9-13 provide various views of the exhaust port and valve assembly 805 used in central, forward battery compartment 311 of the preferred embodiment of the invention. These views do not include an exhaust guide, such as duct 803 . . . Valve retention carrier 901 , also referred to herein as a valve retention plate or member, is preferably configured to hold three valves 1003 in place during normal operation. Valves 1003 are also referred to herein as sealing members or umbrella valves . . . [0051] In the cross-sectional view of FIG. 14A, one of the umbrella valves 1003 is shown captured within the corresponding portion of valve retention plate 901.”
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Fig. 14A of Mardall.
This presents a tapered (i.e., changing in width from the tip 1205) plug (a seal in the form of outer umbrella like portion 1201 that may be compressed against the sealing surface of retention plate 901) which inserts into the cross member assembly (i.e., the compartment 311 formed by the crossmembers 301 and central members 303).
Claim 14 is anticipated by Mardall.
Regarding Claim 15, Claim 15 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall recites the at least one cell stack includes a first cell stack and a second cell stack, the cross-member assembly disposed between the first and second cell stacks (a first and second of the “groups of cells,” disposed in the separate compartments 300 formed by cross-members 301 and central member 303), wherein the valve assembly is a first valve assembly within a plurality of first valve assemblies (“[0042] In this view the internal battery pack cross-members 301 are visible as well as the central member 303 and multiple exhaust port/valve assemblies 305 and 307”) that block flow through an plurality of first openings (as interpreted, the exhaust port comprises the opening and the valve assembly is the valve) on a first side of the cross-member assembly (see Fig. 3, wherein a first side includes the bottom of the compartment 300 formed by the cross-member assembly) the first valve assemblies each openable to provide a respective vent path from the at least one first cell stack to the passageway (the passageways including, for example, the “larger exhaust port,” described initially in [0042]), and, further comprising a plurality of second valve assemblies that block flow through a plurality of second openings on an opposite, second side of the cross-member assembly, the second valve assemblies each openable to provide a respective vent path from the second cell stack to the passageway (because a plurality comprises at least two, this can be any division of compartments; here, this is the other half of the compartments for simplicity – see previous analysis). Mardall at Fig. 3, [0042].
Regarding Claim 23, a traction battery pack venting assembly (“[0008] a battery venting assembly”), comprising: an enclosure (“[0032] “battery pack” as used herein refers to multiple individual batteries contained within a single piece or multi-piece housing” ; wherein the housing is the enclosure); a first cell stack and a second cell stack within the enclosure (see Fig. 5, cells 501, wherein the stack is the grouping of cells packed together); a cross-member assembly (cross-members 301; “[0008] a plurality of cross-members”) within the enclosure between the first cell stack and the second cell stack, the cross-member assembly comprising a first beam and a second beam that together define a passageway (wherein the first of the plurality being a first beam, and the second of the plurality being a second beam), the first beam including a plurality of first openings facing the first cell stack and the second beam including a plurality of second openings facing the second cell stack (“[0042] In a preferred embodiment, each side-by-side battery pack compartment 309 includes 6 exhaust port/valve assemblies 305 while the front, central battery pack compartment 311 includes 3 exhaust port/valve assemblies 307 that are integrated into a larger exhaust port as described in detail below” ; wherein the first and second openings are comprised within the respective valve assemblies of each beam) and a plurality of valve assemblies (see above), each valve assembly covering a respective one of the first openings or the second openings and configured to open to permit flow from the respective cell stack through the respective opening and into the passageway in response to at least one battery cell venting.
Claim 23 is anticipated by Mardall.
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:
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.
Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Mardall, in view of Katayama, et. al. (US2012121962A1).
Regarding Claim 6, Claim 6 relies upon Claim 5. Claim 5 is anticipated by Mardall. Mardall teaches “[0050] Cover plate 1301 includes a plurality of perforations 1303 , thus insuring that air can flow through the valve assembly whenever the valves open. It will be appreciated that plate 1301 can also utilize slots or other configurations that provide air flow through the assembly,” and that “[0049] Preferably valves 1003 are fabricated from an elastomer, such as fluorosilicone, that is resistant to solvents, oils and other contaminants and is capable of providing a good seal when compressed against the sealing surface of retention plate 901.” However, while the valves may comprise a fluorosilicone, the entirety of the cover plate is not described as silicone.
Katayama teaches a battery unit having a plate-like tray, and a plurality of battery modules 12 in said tray, such that the tray is separated by longitudinal frame members 22. Katayama at [0022 – 24]. Katayama teaches “[0059] The silicone sheets 48 interposed between the battery modules 12 and the heat exchange panels 45 are softer than the battery modules 12 and the heat exchange panels 45 . Therefore, since the silicone sheets 48 are deformed under the weight of the battery modules 12 and firmly attached to both the battery modules 12 and the heat exchange panels 45 , it is possible to improve efficiency of heat exchange from the battery modules 12 to the heat exchange panels 45 . At the same time, in the upper surface of each heat exchange panel 45 , there are many air vent grooves 45 b extending parallel to one another. The air vent grooves 45 b allow air to be sandwiched between the heat exchange panel 45 and the silicone sheet 48 and can prevent the efficiency of heat exchange from being lowered.” In other words, this silicone sheet making contact with the duct assemblies of the battery compartments improves heat exchange to permit the more efficient heat exchange between the battery modules and the flow of air. However, because a safety ventilation system comprises hot air being exhausted, and the transfer of heat along the vent path out of the system is the purpose of such a system, Katayama also provides a teaching of a benefit to using a sheet of silicone material in a valve assembly.
One of ordinary skill in the art prior to the effective filing date of the claimed invention would find it obvious to modify the venting assembly of Mardell, such that its fluorosilicone valve assembly comprises a sheet of material which is a sheet of silicone, because Katayama teaches a benefit to heat transfer out of the battery assembly.
Claim 6 is obvious over Mardell, in view of Katayama.
Claims 7 – 9, and 12 are rejected under 35 U.S.C. 103 as being unpatentable over Friesen, et. al. (US 20140227615 A1), as evidenced by Krugly, et. al., “Reed valve in a two stroke engine – what it is and how it works?”, CompoTec, Accessed February 3, 2026, https://compotec.pl/en/index.php/reed-valve-two-stroke-engine/#:~:text=Reed%20valve%20allows%20the%20mixture,of%20modern%20two%20stroke%20engines.
Regarding Claim 7, Claim 7 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall is silent as to a flap.
Friesen teaches a water recapture / recycling system for electrochemical cells, wherein during discharge air, which has previously been heated to free water “absorbed in the desiccator unit 270,” can be released via a valve 260 which is a “one-way valve configured to prevent backflow (e.g. a reed valve).” Friesen at [0062]. This is critical for preventing, for example, air or fluid from outside the system entering the ventilation system, or vented vapor re-entering the system. Further, a reed valve comprises a reed “petal” or flap, which opens due to a given pressure upon the petal, which is halted by a stop plate and block. See, e.g. Krugly, Pic. 1. This structure is ideal for configurations wherein backflow would be problematic, i.e. components within a vehicle (see Krugly, discussing the use of reed valves within a carburetor) where the introduction of air could increase the risk of uncontrolled combustion. For this reason, Friesen indicates a benefit to configuring a valve within a battery apparatus to act as a one-way reed valve comprising a flap.
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Pic. 1 An example of a reed valve disclosed by Krugly.
One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to modify the assembly of Mardall, such that the valve apparatus comprises a plurality of flaps that open into the passageway.
Claim 7 is obvious over Mardall, in view of Friesen.
Claim 8 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Friesen teaches a water recapture / recycling system for electrochemical cells, wherein during discharge air, which has previously been heated to free water “absorbed in the desiccator unit 270,” can be released via a valve 260 which is a “one-way valve configured to prevent backflow (e.g. a reed valve).” Friesen at [0062]. This is critical for preventing, for example, air or fluid from outside the system entering the ventilation system, or vented vapor re-entering the system.
Claim 8 is obvious over Mardall, in view of Friesen.
Regarding Claim 9, Claim 9 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall teaches a valve assembly, but is silent as to the configuration of the plurality of valves.
Friesen teaches a reed valve; a reed valve comprises a reed “petal” or flap, which opens due to a given pressure upon the petal, which is halted by a stop plate and block. See, e.g. Krugly, Pic. 1. This structure is ideal for configurations wherein backflow would be problematic, i.e. components within a vehicle (see Krugly, discussing the use of reed valves within a carburetor) where the introduction of air could increase the risk of uncontrolled combustion. The open configuration (wherein the flap is pushed open by the escaping fluid / vapor, and restricted by a stop plate which prevents backflow) is a “flow permitting” configuration, and the closed configuration is a “flow restricting” configuration.
For this reason, modified Mardall discloses the valve assembly opens to permit flow through an opening of the cross-member assembly to the passageway, and further comprising a baffle of the cross-member assembly that redirects flow through the opening to move toward an axial end of the cross-member assembly.
Claim 9 is obvious over Mardall, in view of Friesen.
Regarding Claim 12, Claim 12 relies upon Claim 1. Claim 1 is anticipated by Mardall.
Mardall teaches a valve assembly, but is silent as to the configuration of the plurality of valves.
Friesen teaches a reed valve; a reed valve comprises a reed “petal” or flap, which opens due to a given pressure upon the petal, which is halted by a stop plate and block. See, e.g. Krugly, Pic. 1. This structure is ideal for configurations wherein backflow would be problematic, i.e. components within a vehicle (see Krugly, discussing the use of reed valves within a carburetor) where the introduction of air could increase the risk of uncontrolled combustion. The open configuration (wherein the flap is pushed open by the escaping fluid / vapor, and restricted by a stop plate which prevents backflow) is a “flow permitting” configuration, and the closed configuration is a “flow restricting” configuration. Further, an inversion is demonstrated by Pic. 1 of Krugly shown above, wherein a flap valve “inverts” as it flexes backward into the stop plate, before snapping back to its original position.
For this reason, modified Mardall discloses the valve assembly comprises a plurality of flaps that open without inverting to permit flow through the valve assembly in a first direction, wherein inverting the plurality of flaps is necessary to permit flow through the valve assembly is an opposite, second direction.
Claim 12 is obvious over Mardall, in view of Friesen.
Regarding Claim 16, Claim 16 relies upon Claim 1.
Friesen teaches a one-way valve. Friesen at [0062]. Modified Mardall teaches the valve assembly is a one-way valve.
Claim 16 is obvious over Mardall, in view of Friesen.
Claims 11 and 24 are rejected under 35 U.S.C. 103 as being unpatentable over Mardall.
Regarding Claim 11, Claim 11 relies upon Claim 1. Claim 1 is anticipated by Mardall.
As previously noted, Mardall teaches an exhaust guide in the form of duct 803, wherein “[0039] exhaust guide is used to direct the flow forward along exhaust path 123 , thereby minimizing the risk of hot gas and material expelled from the forward compartment heating the rearward battery compartments.” However, Mardall also teaches a retention plate 901, which is a component of the back panel 903 wherein the duct 803 is located; this duct forms a wedge-like shape which reads upon a baffle. Mardall at Fig. 15. However, Mardall does not provide an interior view of the exhaust valves, providing only a depiction of the exterior baffle. Mardall teaches this exhaust duct provides the benefit of “helping to direct the flow of hot gas and material expelled during a thermal runaway event within the forward compartment to one side.” Id. at [0047].
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Fig. 15 of Mardall.
One of ordinary skill in the art before the effective filing date would find it obvious to modify Mardall, such that the exhaust guide disposed along the exhaust path 123 is the same baffle shown in Fig. 15, because Mardall teaches a benefit to directing the flow of hot gas and material during a thermal runaway event.
Claim 11 is obvious over Mardall.
Regarding Claim 24, Claim 24 relies upon Claim 23. Claim 23 is obvious over modified Mardall.
As previously noted, Mardall teaches an exhaust guide in the form of duct 803, wherein “[0039] exhaust guide is used to direct the flow forward along exhaust path 123 , thereby minimizing the risk of hot gas and material expelled from the forward compartment heating the rearward battery compartments.” However, Mardall also teaches a retention plate 901, which is a component of the back panel 903 wherein the duct 803 is located; this duct forms a wedge-like shape which reads upon a baffle. Mardall at Fig. 15. However, Mardall does not provide an interior view of the exhaust valves, providing only a depiction of the exterior baffle. Mardall teaches this exhaust duct provides the benefit of “helping to direct the flow of hot gas and material expelled during a thermal runaway event within the forward compartment to one side.” Id. at [0047].
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Fig. 15 of Mardall.
One of ordinary skill in the art before the effective filing date would find it obvious to modify Mardall, such that the cross-member assembly includes a baffle adjacent the opening, the baffle configured to redirect flow entering the passageway through the opening toward an axial end of the cross-member assembly, because Mardall teaches a benefit to directing the flow of hot gas and material during a thermal runaway event.
Claim 24 is obvious over Mardall.
Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Mardall as applied to claim 1 above, and further in view of Yamagami, et. al. (US2008152994A1).
Mardall is silent as to the use of adhesive tape.
Yamagami teaches a battery pack having an insulation cover 4, affixed to a sealing plate 11 of a battery 2 via “double coated adhesive tape . . . and also serves to protect the safety valve 12. When the safety valve opens, the double coated adhesive tape is peeled to release a gas to the outside.” Yamagami at [0037]. Further, “[0031] The illustrated battery pack has the insulation cover 4 disposed to cover the outlet port 13 of the safety valve 12.” Id. at [0031]. Further, Yamagami teaches, “[0037] the double coated adhesive tape 6 allows the insulation cover 4 to be bonded with the battery surface easily and readily. Also when the safety valve 12 opens, the tape quickly peels, so that the gas and others can be quickly released out of the opened safety valve 12.” Id. at [0037]. In other words, Yamagami teaches a benefit to connecting the overall cover such that it is not misaligned with the unit cell, while allowing a quick release of gas from the opened outlet port.
Mardall teaches a plurality of “outlet ports” in the form of its exhaust ports, but teaches that these are outfitted with safety valves.
One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to modify the exhaust ports of Mardall, such that the valve assembly is a piece of tape adhesively secured to the cross-member assembly, because Yamagami teaches a benefit to quick release of gas.
Claim 13 is obvious over Mardall, in view of Yamagami.
Claim 21 is rejected under 35 U.S.C. 103 as being unpatentable over Mardall, in view of Lanzl, et. al. (US2015362130A1).
Regarding Claim 21, Mardall recites an enclosure ;a plurality of battery cells within the enclosure (battery pack 103, “[0036] which is preferably mounted to the vehicle’s undercarriage 104”), comprising: an enclosure (“[0032] “battery pack” as used herein refers to multiple individual batteries contained within a single piece or multi-piece housing”; wherein the housing is the enclosure) ; a cross-member assembly within the enclosure(cross-members 301; “[0008] a plurality of cross-members”), the cross-member assembly defining a passageway (“[0012] In at least one embodiment, the system also includes a ducted exhaust guide, for example fabricated from aluminum, an aluminum alloy, or steel, that is mounted within the battery pack and which surrounds and is spaced apart from at least a portion of the inside surface of the valve retention plate. The ducted exhaust guide is configured to direct the flow of hot gas and material expelled during thermal runaway through the plurality of retention plate ports to the ambient environment, for example directing the flow of gas and material in a forward direction and away from the vehicle in which the battery pack is incorporated. Preferably at least a portion of the ducted exhaust guide is angled away from the inside surface of the battery pack at an angle of between 10 and 40 degrees, and more preferably at an angle of between 15 and 30 degrees”) and including an opening that faces the plurality of battery cells (Fig. 5 shows the plurality of cells, which as oriented indicates the opening to the valve assembly necessarily faces the cells) ; and a valve assembly (valve assembly 805), the valve assembly configured to open to permit flow from the plurality of battery cells through the opening and into the passageway in response to at least one of the battery cells venting (“[0005] While the safety pressure release vent built into many cells may help to release some of the gas generated by the reaction, eventually the increased temperature in concert with the increased internal cell pressure will lead to the formation of perforations in the cell casing. Once the cell casing is perforated, the elevated internal cell pressure will cause additional hot gas to be directed to this location, further compromising the cell at this and adjoining locations . . . [0038] In accordance with the invention, each battery pack compartment includes one or more gas exhaust ports 115 that are designed to activate during a battery thermal runaway event. Each port 115 is sealed, for example using a valve 117 , which prevents contaminants such as road debris and moisture from entering the battery pack, but is designed to open during a thermal runaway event in order to provide a controlled exhaust pathway for the hot gas and materials expelled during runaway.”. Mardall at [0012, 32, 36, 39 – 45].
However, Mardall is silent as to whether the valve assembly is secured via an adhesive, meaning Mardall is silent as to “adhesively secured to an interior surface of the cross-member assembly and covering the opening.”
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Fig. 3 of Mardall, depicting the cross members 301, which form the compartments with the central member 303 and exhaust assemblies 305 and 307, and Fig. 5 of Mardall, showing the opening leading to passageway as previously described face the plurality of cells.
Lanzl teaches a valve element 3, for use with “an energy storage device 50 . . . (e.g. a traction battery),” specifically configured for storage of a liquid or gaseous medium under pressure. Lanzl at [0059, 62]. Lanzl teaches “[0033] The medium container may be firmly connected to the valve connecting element outside the area of the collar or the restoring element, so that the advantage of a preferably adjacent flat area press fit is maintained. For this purpose, it may be provided that the medium container is firmly connected to the valve connecting element by means of a screw connection and/or by an adhesive layer.” In other words, the use of an adhesive layer may confer the advantage of a preferably adjacent flat area press fit upon a valve disposed over an opening, adhesively secured to a surface of a container, such as a compartment.
One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to further modify the battery of Mardall, such that the valve assembly is adhesively secured to an interior surface of the cross-member assembly and covering the opening, via an adhesive layer as in Lanzl, because Lanzl confers a benefit to flat area press fitting, and thereby a firm connection.
Claim 21 is obvious over Mardall, in view of Lanzl.
Regarding Claim 22, Claim 22 relies upon Claim 21. Claim 22 is obvious over modified Mardall.
Mardall teaches “[0010] A plurality of valve cover plate openings (e.g., perforations) allow air to pass through the valve cover plate.” This is “configured to tear in response to the at least one battery cell venting.” Mardall also teaches “[0012] In at least one embodiment, the system also includes a ducted exhaust guide, for example fabricated from aluminum, an aluminum alloy, or steel, that is mounted within the battery pack and which surrounds and is spaced apart from at least a portion of the inside surface of the valve retention plate. The ducted exhaust guide is configured to direct the flow of hot gas and material expelled during thermal runaway through the plurality of retention plate ports to the ambient environment, for example directing the flow of gas and material in a forward direction and away from the vehicle in which the battery pack is incorporated. Preferably at least a portion of the ducted exhaust guide is angled away from the inside surface of the battery pack at an angle of between 10 and 40 degrees, and more preferably at an angle of between 15 and 30 degrees.” One of ordinary skill in the art would find it obvious to further modify the perforated area of modified Mardall (“the perforated valve assembly cover”), the perforated area configured to tear in response to the at least one battery cell venting to form a flap that remains attached to the sheet of material (forming a secondary exhaust guide) and guides flow through the opening in a direction toward an axial end of the passageway, because Mardall teaches a beneficial effect to directing the flow of gas in a desired direction, and one of ordinary skill in the art would expect this effect to be improved by additional flow guidance formed by remaining material of the seal in the form of a flap.
Claim 22 is obvious over Mardall, in view of Lanzl.
Response to Arguments
Applicant's arguments filed 04/24/2026 have been fully considered but they are not persuasive.
Applicant’s arguments pertaining to the anticipation rejections of Claims 1-5, 10, and 14-15 are not commensurate with the scope of the claims, and are therefore unpersuasive. Applicant argues in relevant part “The Examiner reads the claimed "passageway of the cross-member assembly" as being taught by "a passageway mounted upon or coupled to the cross-members as 'of the' includes a connector or sub-element." Applicant respectfully disagrees. The ordinary meaning of "a passageway of the cross-member assembly" is a passageway that is part of, or defined by, the cross-member assembly itself - not a passageway that is merely associated with or adjacent to cross-members. . . .The Examiner also relies on paragraphs [0039]-[0045] and Figure 3, which show the cross- members 301 forming the walls between compartments, with exhaust port and valve assemblies 305 integrated into - but not into any passageway within - those cross-members. Looking carefully at Mardall's disclosure, the exhaust ports 115 and valve assemblies 305/307 are located in the outer wall (bottom panel 903) of the battery pack, not in or through the cross-members 301. The cross-members 301 separate the compartments from one another; the exhaust ports 115 and valves 305/307 are in the outer bottom panel 903 and vent gas out of the pack entirely rather than into any passageway of a cross-member. There is no passageway within the cross-members 301 of Mardall that receives vented gas from the cell stacks. The cross-members 301 are barriers, not conduits.” However, paragraph [0039], as acknowledged by Applicant, actually directly states that “internal battery pack walls 125 (also referred to herein as battery pack cross-members),” indicating that all of the internal walls of the enclosure constitute crossmembers of the plurality of cross members, each of which defines a “exhaust path 119,” which “is used to direct the flow along exhaust path 123” to a “minimizing pathways 1190, 123.” A pathway which travels between two compartment is a passageway. The words of a claim must be given their plain meaning unless such meaning is inconsistent with the specification; Applicant’s arguments are not commensurate in scope with the plain meaning of the terms claimed. MPEP 2111.01. For example, Applicant argues that Claim 5 does not teach perforations; Mardall recites “[0010] A plurality of valve cover plate openings (e.g., perforations).” Applicant argues “The cover plate 1301 does not function as a valve,” but “[0051] During the initial stages of a thermal runaway event within the module(s) contained in front battery pack compartment 311 , once the valves' crack pressure (e.g., 0.7 psi) is reached one or more of the flexible umbrella valves 1003 will expand slightly away from the sealing surface of retention plate 901 . As a result, air will flow out of the pack along pathways 1401 . . . As hot gas and material flow past seals 1003 , cover plate 1301 and retention plate 901 , both fabricated from polypropylene or other plastic, melt (or ignite) and are pushed out of large exhaust port 1001 , thereby substantially increasing the flow path for exhausting thermal runaway hot gas and material from the affected battery pack compartment.” The opening of a sealing portion of a valve in response to pressure is to “function as a valve.” Applicant argues “First, the umbrella valve 1003 of Mardall is not a tapered plug. It is an umbrella-shaped elastomeric seal with a barbed stem (barb 1203) that is captured within an aperture 907 of the valve retention carrier 901.” An umbrella shape tapers. Applicant argues “The valve 1003 does not fit within an opening.” Paragraph [0051] again teaches “0051] In the cross-sectional view of FIG. 14A, one of the umbrella valves 1003 is shown captured within the corresponding portion of valve retention plate 901.”
Further distinctions which are not supported by the claimed language are found within this argument. The compartment 311 is not the cross-member assembly - it is a battery pack compartment bounded by cross-members.” A compartment formed by a plurality of crossmembers is at least a part of a cross-member assembly. Applicant similarly argues, “The Examiner's reading that "a first side includes the bottom of the compartment 300 formed by the cross-member assembly" improperly equates the bottom of the compartment with a side of the cross-member assembly. These are different structural elements,” but this distinction is not claimed.
For these reasons, the anticipation rejections of Claims 1-5, 10, and 14-15 are maintained.
Regarding the obviousness rejections, Applicant relies in part on the asserted defectiveness of the previous rejections, which are discussed above. However, Applicant wrongly argues that presenting a teaching of a benefit found within a cited reference is “conclusory.” However, the strongest rationale for combining references is a recognition, expressly or impliedly in the prior art or drawn from a convincing line of reasoning based on established scientific principles or legal precedent, that some advantage or expected beneficial result would have been produced by their combination. MPEP 2144 (II). The presentation of evidence required is simply the material cited within an applied reference. For example, Applicant argues “Claim 6 was rejected as obvious over Mardall in view of Katayama. Claim 6 depends from claim 1 and is patentable for at least this reason. Further, claim 6 recites that the sheet of material of claim 5 is a sheet of silicone. Even if Mardall were assumed to anticipate claim 5, the Examiner's rationale for combining Katayama with Mardall is insufficient. Katayama's silicone sheets 48 are heat transfer members interposed between battery modules and heat exchange panels to improve cooling - they function by conducting heat from the battery modules to the cooling panels. The Examiner reasons that because a thermal venting system involves hot gas, the use of silicone in Katayama provides a teaching to use silicone in Mardall's valve assembly. This reasoning is conclusory.” However, Katayama teaches “[0059] [t]herefore, since the silicone sheets 48 are deformed under the weight of the battery modules 12 and firmly attached to both the battery modules 12 and the heat exchange panels 45 , it is possible to improve efficiency of heat exchange from the battery modules 12 to the heat exchange panels 45.” This is the requisite “express teaching of a benefit” required by MPEP 2144 (II). Applicant does not refute this citation. Applicant similarly does not refute the benefits cited by the subsequent dependent claim rejections on the merits. Applicant collaterally attacks Friesen, applied to Claims 7-9, 12, by arguing that “Friesen has nothing to do with traction battery pack venting, thermal runaway, cross-member assemblies, or directing vented gas from battery cells. Friesen's valve 260 is a backflow prevention valve.” Friesen is being presented for its teaching of a valve, which is pertinent art to a valve assembly. As a secondary reference, it is applied for the teachings it demonstrates to demonstrate the recognition in the prior art of a benefit based on established scientific principles, that a beneficial result would be produced by a given combination. Applicant does not dispute the functionality of the flap or petal of a reed valve or the principle presented within the Friesen and Krugly. What remains of Applicant’s argument relies upon “The "inward into the passageway" feature requires the claimed cross- member passageway architecture, which Mardall does not possess,” which has previously been disproven.
In the same vein, Applicant’s arguments pertaining to Claim 11 rely upon elements which are not claimed. Claim 11 requires simply “a baffle of the cross-member assembly that redirects flow through the opening to move toward an axial end of the crossmember assembly.” Applicant argues “Mardall's exhaust duct 803 is a free-standing duct mounted within the forward battery compartment 311, separate from and external to the valve retention plate 901. It is not "a baffle of the cross-member assembly." It is a separate structural component - an aluminum or steel duct - that happens to be located within one battery compartment.” This is not contradictory with the teaching of an “[0039] exhaust guide is used to direct the flow forward along exhaust path 123.” This “baffle” is not given further structural meaning beyond its function, indicating a “free standing” component is irrelevant. An exhaust guide redirects the flow of gas. Applicant’s arguments rely upon insinuated distinctions which are not commensurate in scope with the plain meaning of “a baffle of the cross-member assembly that redirects flow.”
This extends to Applicant’s arguments pertaining to Claim 13. Claim 13 recites that the valve assembly is a piece of tape adhesively secured to the cross- member assembly. Yamagami recites “When the safety valve opens, the double coated adhesive tape is peeled to release a gas to the outside.” Applicant’s contention that the tape itself is accompanied by additional components within the secondary reference is not persuasive, because the test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference; nor is it that the claimed invention must be expressly suggested in any one or all of the references. Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981). Only the tape, whose peeling and releasing action is taught within the secondary reference, is applied to the primary reference.
This selective interpretation of the references also applies to Claim 16, wherein Applicant argues in relevant part “Friesen's one-way valve operates in a water vapor recovery system for electrochemical cells - a context entirely different from a thermal runaway venting system using a cross-member assembly passageway. Transplanting the one-way valve concept from Friesen into Mardall does not produce the claimed structure.” This is not commensurate with Friesen and Krugly’s teaching of a reed valve, which is what is being applied within the modification.
Claims 21-24 are new in this action, and are rejected as discussed within the Final Rejection above.
Conclusion
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 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.
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/K.R.H./Examiner , Art Unit 1725
/NICOLE M. BUIE-HATCHER/Supervisory Patent Examiner, Art Unit 1725
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