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 .
Information Disclosure Statement
The information disclosure statement(s) (IDS) submitted on 03/09/2026 has been considered by the examiner.
Response to Amendment
Examiner notes the following amendments made to the claims:
Claims 1, 5, 8, 12, 15, and 18 amended
Claims 5, 12, 18 amended to overcome objection
Claims 1, 8, and 15 amended to incorporate proposed amendments
Response to Arguments
Applicant’s arguments, filed 12/18/2025, with respect to objections to claims 5, 6, 12, 13, and 18 have been fully considered and are persuasive. The objections of the aforementioned claims have been withdrawn.
Applicant’s arguments, filed 12/18/2025, with respect to rejections of claims 1-14 under 35 USC 103 have been fully considered and are persuasive. Specifically, the amendments made overcome the previously applied prior art. The rejections of the aforementioned claims have been withdrawn. However, the arguments with respect to claims 15-20 are not persuasive. Specifically, claims 15-20 are only drawn to the retention clip and not the cooling subsystem. Therefore, a clip that is analogous to that of the instant claims would meet the limitations even if it is used in a scenario that doesn’t exactly match the cooling subsystem that is actively part of the claims in independent claims 1 and 8. By teaching a clip that is analogous to the claimed clip and which could be used in a cooling subsystem, Sarraf teaches all of the limitations of claim 15. If applicant cancelled claim 15 and its dependent claims or amended them such that they actually include the cooling subsystem, then the application would be in condition for allowance.
Claim Rejections - 35 USC § 103
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(s) 15, 17-18, is/are rejected under 35 U.S.C. 103 as being unpatentable over Sarraf (US 10756498 B1).
Regarding claim 15, Sarraf teaches the following elements:
A retention clip (Sarraf clip 320)
for a cooling subsystem in an electric energy generation and storage system having a plurality of battery cells arranged in rows, wherein the cooling subsystem includes: a coolant header configured to extending proximately to and seat the battery cells sandwich the rows of battery cells, and maintain position thereof, and having an inlet fitting and an outlet fitting; an inlet manifold configured to connect with the inlet fitting and an outlet manifold configured to connect with the outlet fitting such that the inlet and outlet manifolds are together configured to circulate coolant through the coolant header; (This entire limitation describes a configuration in which the retention clip can be used. However, it is not actually part of the invention in this claim. Therefore, the clip of Sarraf meeting the below limitations would be capable of being used in a cooling subsystem as described above, and therefore is sufficient to meet the limitations of claim 15)
the retention clip comprising: a first snap-fit leg and a second snap-fit leg; (“The clip arms 322, 326 may be spread apart for loading the cable connectors 202 into the first and second bores 324, 328. The clip arms 322, 326 may snap or clip onto the cable connectors 202 to physically couple the clip 320 to the cable connectors 202.” Sarraf page 17 column 9 lines 1-5)
and a clip body connected to each of the first and second snap-fit legs and configured to engage and hold each of the inlet manifold and the outlet manifold; (See below comparison showing the clip body of Sarraf and how it is connected to snap fit legs in same manner as instant invention)
wherein the first snap-fit leg is configured to engage and lock onto the inlet fitting and the second snap-fit leg is configured to engage and lock onto the outlet fitting to thereby fix the inlet manifold relative to the outlet manifold and fix and seal the inlet manifold and the outlet manifold to the coolant header. (The clip of Sarraf is capable of performing these functions, given it is a configured to limitation and the inlet, outlet, and manifold are not physically required, the limitations are met.)
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Regarding claim 17, Sarraf teaches the following elements:
The retention clip of claim 15, wherein at least one of the inlet manifold and the outlet manifold is defined by an outer surface having a circular shape in a cross-sectional view of the respective manifold, and wherein the clip body includes an inner surface having at least one section characterized by a concave shape, in a side view of the retention clip, configured to engage and match the outer surface of the at least one of the inlet manifold and outlet manifold when the retention clip is snapped onto the coolant header. (The inlet and outlet manifolds are not actually part of claim 15, but rather part of what claim the retention clip of claim 15 is capable of being used for. Given that the inner surface of the clip of Sarraf is concave and circular [see Sarraf figure 8], it would be capable of snapping onto and engaging with a circular inlet/outlet manifold.)
Regarding claim 18, Sarraf teaches the following elements:
The retention clip of claim 15, wherein the clip body includes an outer surface having at least one press-pad configured to be engaged by an assembly device for snapping the retention clip onto the coolant header. (Sarraf fig. 8 teaches a clip 320 which has fastener 332 which is capable of functioning as a press-pad to snap the clip onto the cooling system and is opposite of the concave sections of the clip. “The clip arms 322, 326 may snap or clip onto the cable connectors 202 to physically couple the clip 320 to the cable connectors 202.” And “In an exemplary embodiment, the clip arms 322, 326 are compressed against the cable connectors 202 and/or the separators 308 positioned between the cable connectors 202 and the clip arms 322, 326. In an exemplary embodiment, a fastener 332 is used for securing and/or tightening the clip arms 322, 326 against the separators 308 and the cable connectors 202.” Sarraf page 16 column 8 lines 58-67)
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Claim(s) 16, 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sarraf (US 10756498 B1) in view of Burrows (US 20130164593 A1).
Regarding claim 16, Sarraf teaches all of the elements of claim 15, as shown above. Sarraf is silent on the following elements of claim 16:
The retention clip of claim 15, wherein each of the inlet and outlet fittings includes a respective tab projecting away from the corresponding fitting, and wherein each of the first and the second snap-fit legs defines an opening configured to engage one tab of the inlet and outlet fittings.
However, Burrows teaches all of the elements of claim 16 that aren’t found in Sarraf:
The retention clip of claim 15, wherein each of the inlet and outlet fittings includes a respective tab projecting away from the corresponding fitting, and wherein each of the first and the second snap-fit legs defines an opening configured to engage one tab of the inlet and outlet fittings. (“The manifold clip includes at least two tabs for engaging the first and second undercut recesses to provide a snap-fit for securing the two manifold segments together.” Burrows [0006] and “ As illustrated in FIG. 8, the manifold clip 18 includes a plurality of tabs 100. The tabs 100 may engage in a pair of retention features 64 located at diametrically opposed locations along the manifold segment 16. In another embodiment, the retention features may include a recess 68 formed as a groove and the tabs 100 may engage the groove at multiple locations.” Burrows [0054]. In this case, the undercut recesses and retention features function as the respective tabs projecting away and the tabs and teeth on the manifold clip function as the openings. The wording is different but the idea is the same.)
Burrows and Sarraf are considered to be analogous because they are both related to clips used in cooling systems related to batteries. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the clip of Sarraf to include the tabs/recesses of Burrows in order to improve retention/engagement. (“In one embodiment, the manifold clip 18 includes at least one tab 100. The tabs 100 may include a tooth 102. The tooth 102 may be angled to match the angle of the engagement wall 76 in the retention feature 64 in order to provide positive retention and greater engagement.” Burrows [0053]])
Regarding claim 19, Sarraf teaches all of the elements of claim 15, as shown above. Sarraf is silent on the following elements of claim 19:
The retention clip of claim 15, wherein the clip body includes an anti-rotation feature configured to extend between the inlet manifold and the outlet manifold.
However, Burrows teaches all of the elements of claim 19 that aren’t found in Sarraf:
The retention clip of claim 15, wherein the clip body includes an anti-rotation feature configured to extend between the inlet manifold and the outlet manifold. (“The manifold clip 18 may also include an anti-rotation claw 106. The anti-rotation claw 106 may extend in a direction generally perpendicular in relation to the retention tab 100. The anti-rotation claw 106 may engage an interface surface to minimize rotation of the manifold clip 18 with respect to the manifold segments 16.” Burrows [0055])
Burrows and Sarraf are considered to be analogous for the reasons provided above. it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the clip of Sarraf to have the anti-rotation feature of Burrows to provide additionally stability in support. As stated above in claim 15, the inlet and outlet manifold are not physically required to meet the claim limitation. Thus, by being capable of extending between and inlet and outlet manifold, the anti-rotation claw of Burrows would meet all of the limitations of claim 19 that are not found in Sarraf.
Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sarraf (US 10756498 B1) in view of Chang (US 20230307768 A1).
Regarding claim 20, Sarraf teaches all of the elements of claim 15, as shown above. Sarraf is silent on the following elements of claim 20:
The retention clip of claim 15, wherein the retention clip is constructed from a polymeric material.
However, Chang teaches all of the elements of claim 20 that are not found in Sarraf: Specifically, Chang teaches clips formed of a polymeric material used in a traction battery pack:
The retention clip of claim 15, wherein the retention clip is constructed from a polymeric material. (“Each clip 54 may be a metallic-based component. For example, the clip 54 could be constructed out of aluminum, stainless steel, etc. In other embodiments, the clip 54 could also be a polymer-based component.” Chang [0068])
Chang is considered to be analogous to Sarraf because they are both within the same field of battery/electrochemical devices containing retention clips. Therefore, it would have been obvious to one of ordinary skill before the effective filing date of the claimed invention to modify the clip of Sarraf to be made from a polymeric material. This would be obvious as clips made from polymeric material are a known material in the art, as taught by Chang, and the selection of a known material, which is based upon its suitability for the intended use, is within the ambit of one of ordinary skill in the art. See In re Leshin, 125 USPQ 416 (CCPA 1960) (see MPEP § 2144.07).
Allowable Subject Matter
Claims 1-14 allowed.
The following is an examiner’s statement of reasons for allowance: By amending the independent claims to further limit the structure of the coolant manifold retention clip, the rejections based on the previously applied prior art are overcome. After further search and consideration, there is no prior art or combination of prior art that teaches a coolant manifold retention clip that meets all of the limitations of the independent claims, including the sandwiching and seating of the battery cells, which are stacked in rows, nor is there motivation to modify the closest prior art to meet the limitations. Therefore, the subject matter of independent claims 1 and 8 is considered to be allowable, and all dependent claims of those claims are considered to be allowable given their dependence on allowable claims. The closest new prior art found was US 20180277808 A1, which teaches a similar structure where battery cells are surrounded, but not sandwiched in the same way by a coolant manifold retention device in the manner described in the instant claims. Independent claim 15 is not considered to be allowable despite the amendments made, given that it is only drawn to the retention clip configured to be used in a cooling subsystem, rather than claiming parts of the cooling subsystem as well, such as in claims 1 and 8.
Any comments considered necessary by applicant must be submitted no later than the payment of the issue fee and, to avoid processing delays, should preferably accompany the issue fee. Such submissions should be clearly labeled “Comments on Statement of Reasons for Allowance.”
Conclusion
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 BENJAMIN ELI KASS-MULLET whose telephone number is (571)272-0156. The examiner can normally be reached Monday-Friday 8:30am-6pm except for the first Friday of bi-week.
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, NICHOLAS SMITH can be reached at (571) 272-8760. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/BENJAMIN ELI KASS-MULLET/Examiner, Art Unit 1752
/NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752