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 .
Response to Amendment
The amendment filed on January 27th 2026 is acknowledged. Claims 1-5 & 7-8 remain pending in the application. Claim 6 was cancelled by the Applicant. Applicant’s arguments to the previous rejections of the claims were fully considered and are persuasive. The 103 rejections of the claims are withdrawn due to the Applicant’s amendments. However, upon further consideration, a new grounds of rejection is made in view of Oh et al. “The Effects of Laser Welding Direction on Joint Quality for Non-Uniform Part-to-Part Gaps”. New rejections follow.
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 1-2 & 7-8 are rejected under 35 U.S.C. 103 as being unpatentable over Tsutsumi et al. JP 2015/011785 A and further in view of Oh et al. “The Effects of Laser Welding Direction on Joint Quality for Non-Uniform Part-to-Part Gaps”. Citations to Tsutsumi are mapped to the English machine translations provided.
Regarding Claim 1, Tsutsumi discloses a bus bar connection structure comprising a terminal portion (external terminal Item 4) and a bus bar (Item 6) [0002], as shown in Figures 1 & 2. Tsutsumi discloses that the terminal portion has a first facing surface (first connection surface Figure 4a Item 4a) [0002, 0007], and the bus bar has a second facing surface (second connection surface Figure 4a Item 8a/6a) [0007, 0053] that faces the first facing surface, wherein the bus bar is laid on the terminal portion, which is all further shown in Annotated Figure 4a below:
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Annotated Figure 4a
Tsutsumi discloses a clearance (gap Figure 4a Item 8c) [0056] between the second facing surface and the first facing surface in a predetermined direction, as shown in Annotated Figure 4a. Tsutsumi further discloses a weld portion (weld Figure 5 Item 9) [0056] that connects the terminal portion and the bus bar [0061]. As shown in Annotated Figure 5, Tsutsumi discloses that the weld portion has a first weld layer in the bus bar and extending from the second facing surface in the predetermined direction, a second weld layer in the terminal portion and extending from the first facing surface in the predetermined direction, and an intermediate weld layer in the clearance and connecting the first and second weld layers:
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Annotated Figure 5
Tsutsumi fails to disclose that the minimum width of the intermediate weld layer in an orthogonal direction to the predetermined direction is larger than a minimum width of the first weld layer.
Tsutsumi additionally fails to disclose that the weld portion has a maximum width in the direction orthogonal to the predetermined direction at a position of a boundary between the first weld layer and the intermediate weld layer, and a width of the weld portion in the direction orthogonal to the predetermined direction at a position of a boundary between the intermediate weld layer and the second weld layer is larger than the minimum width of the intermediate weld layer.
Oh discloses the effects of laser welding when working with part-to part gaps, such as when two plates are welded with a gap between them [Abstract], similar to the instance of Tsutsumi’s bus bar plate and terminal plate comprising a gap between them. Oh discloses that the two plates are steel [Abstract], similar to the bus bar and terminal plate of Tsutsumi [0101]. Oh discloses that in laser welding, when two parts are joined and there is a gap between them, the width of the weld portion at a position of boundary between the middle section and the top plate (similar to the boundary of the intermediate layer and the first weld layer of Tsutsumi) and the width of the weld portion at a position of boundary between the middle section and the bottom plate (similar to the boundary of the intermediate layer and the second weld layer of Tsutsumi) are important factors in driving weld pool quality [Page 2 Par. 4], which is tied to tensile shear strength of the weld portion [Page 5 Par. 5]. Oh further represents this in Figure 4 showing the relationship between the weld pool quality and the TS (width of weld portion at boundary of intermediate weld layer and first weld layer) and BS (width of weld portion at boundary of intermediate weld layer and second weld layer) values in the weld pool quality formula:
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Oh Figure 4
As shown in the formula of Oh Figure 4, when the values of TS and/or BS are increased, the weld pool quality value increases, which Oh discloses is linked to the quality of the weld such as the tensile strength and fatigue resistance [Page 5 Par. 5]. Additionally, Oh illustrates in Figure 8 that the effect of laser welding two plates comprising a gap between them results in the cross section of weld portions having a minimum width of the intermediate weld layer greater than the minimum width of the first weld layer, a maximum width of the weld portion at a boundary of the intermediate weld layer and the first weld layer, and a width of the weld portion at a boundary of the intermediate weld layer and the second weld layer is larger than the minimum width of the intermediate weld layer, shown below:
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Oh Annotated Figure 8
Therefore, based on the teachings of Oh, one of ordinary skill in the art would have recognized particular shape of the weld portion is a result effective variable, and would seek to optimize this parameter, more specifically optimize the widths of the weld portions at the boundaries of the intermediate weld layer, the first weld layer, and the second weld layer, and would therefore arrive at the claimed weld portion to achieve a weld portion with increased quality and tensile strength. See MPEP 2144.05. Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to select a width of the intermediate weld layer at a boundary with the first weld layer, and a width of the intermediate weld layer at a boundary with the second weld layer to have the claimed limitations to provide a weld portion with improved weld pool quality and therefore improved tensile strength as suggested by Oh.
Therefore, modified Tsutsumi discloses a weld portion with an intermediate layer having a minimum width in an orthogonal direction to the predetermined direction that is larger than a minimum width of the first weld layer, has a maximum width in the direction orthogonal to the predetermined direction at a position of a boundary between the first weld layer and the intermediate weld layer, and a width of the weld portion in the direction orthogonal to the predetermined direction at a position of a boundary between the intermediate weld layer and the second weld layer is larger than the minimum width of the intermediate weld layer.
Regarding Claim 2, Tsutsumi discloses that the bus bar has a recess, as shown in Tsutsumi Annotated Figure 4B, that is recessed in a direction away from the first facing surface in the predetermined direction, and the second facing surface is the bottom surface of the recess:
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Tsutsumi Annotated Figure 4B
Regarding Claim 7, Tsutsumi discloses that the clearance (gap), which Tsutsumi also describes as the “separation distance X1”, is between 6.5 and 80 µm [0085], more preferably 10-20 µm [0091], which falls within the claimed range of more than or equal to 0.01mm (10 µm). In regards to the thickness of the clearance, the Examiner directs Applicant to MPEP 2131.03 I. In the case where the prior art “discloses a point within the claimed range, the prior art anticipates the claim”. UCB, Inc. v. Actavis Labs. UT, Inc., 65 F.4th 679, 687, 2023 USPQ2d 448 (Fed. Cir. 2023). Accordingly, the thickness disclosed in Tsutsumi anticipates the claimed range set forth in Claim 1. See MPEP 2131.03 I.
Regarding Claim 8, Tsutsumi discloses that the thickness of the bus bar is 0.6mm [0085], and as mentioned with regards to claim 7 above, Tsutsumi discloses that the clearance has a thickness of 6.5-80 µm [0085], more preferably 10-20 µm [0091], thus Tsutsumi discloses that the size of the clearance is less than or equal to a thickness of the bus bar.
Claims 3-5 are rejected under 35 U.S.C. 103 as being unpatentable over Tsutsumi and Oh, and further in view of Guen US 2020/0091570 A1.
Regarding Claim 3, modified Tsutsumi is relied upon for the reasons given above in addressing Claim 1, however is silent as to the clearing being constituted of a space that is opened to an exterior of the bus bar and the terminal portion.
Guen discloses a secondary battery comprising a bus bar connection structure [0071], seen in Figure 6. Guen discloses that the bus bar connection structure comprises a terminal portion (Figure 6 Item 120) and a bus bar (Figure 6 Item 160) [0071], wherein the bus bar further comprised a weld portion (Figure 6 Item 162, shown as a dashed line) [0075]. Figure 7 of Guen further illustrates the bus bar connection structure, comprising similar elements to that of Tsutsumi such as the terminal portion comprising a first facing surface, the bus bar comprising a second facing surface facing the first facing surface, a clearance between the first and second facing surfaces, and a weld portion that extends through the bus bar and second facing surface to the terminal portion and the first facing surface in an annular shape, as shown in Guen Annotated Figure 7 below:
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Guen Annotated Figure 7
Guen further discloses that there is a circular through-hole (Figure 7 Item 161) positioned in the middle of the weld portion and directly over the clearance (“position identification groove” Figure 7 Item 122a), thus Guen discloses a clearance in a bus bar connection structure that is open to an exterior of the bus bar and the terminal portion (via the through-hole).
Guen discloses that the through-hole enables accurate positioning of the bus bar on the terminal portion for welding [0072].
Therefore, it would have been obvious to one of ordinary skill in the art prior to the effective filing date of the present invention to incorporate the through-holes of Guen in the clearance of the bus bar connection structure of modified Tsutsumi to enable accurate positioning of the bus bar on the terminal portion for welding, thereby creating a clearance that is open to an exterior of the bus bar and the terminal portion.
Regarding Claim 4, Tsutsumi discloses that the weld portion (Figure 3 Item 9) extends in an annular shape when viewed in the predetermined direction (in this case, from a “bird’s eye view”):
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Tsutsumi Annotated Figure 3
As mentioned with regards to claim 3 above, modified Tsutsumi with the modification of Guen’s through-holes, discloses a bus bar with a through-hole that extends through the bus bar in the predetermined direction and opened to the second facing surface on an inner side with respect to the weld portion extending in the annular shape, as illustrated in Guen Figure 7 & Modified Tsutsumi Annotated Figure 6 below:
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Guen Figure 7 & Modified Tsutsumi Annotated Figure 6
Regarding Claim 5, as mentioned with regards to Claim 4, Tsutsumi discloses that the weld portion has a circular ring shape, as shown in Annotated Figure 3 above. Additionally, as mentioned with regards to Claim 4, modified Tsutsumi, with the modification of Guen’s through-hole, discloses that the through-hole extends on a central axis of the circular ring shape, as illustrated in Guen Figure 7 & Modified Tsutsumi Annotated Figure 6 copied below:
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Guen Figure 7 & Modified Tsutsumi Annotated Figure 6
Response to Arguments
Applicant’s arguments with respect to the claims have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure.
Song et al. KR 20150074404 A – discloses a method of laser welding two plates with a gap between.
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 ANNA E GOULD whose telephone number is (571)270-1088. The examiner can normally be reached Monday-Friday 9:00am-5:00pm.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Jeffrey T. Barton can be reached at (571) 272-1307. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/A.E.G./Examiner, Art Unit 1726
/JEFFREY T BARTON/Supervisory Patent Examiner, Art Unit 1726 22 May 2026
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