Prosecution Insights
Last updated: October 02, 2026
Application No. 18/178,884

ACTIVE HYDRAULIC ELEMENT IN A BATTERY MODULE FOR AN ELECTRIC VEHICLE

Final Rejection §103§112
Filed
Mar 06, 2023
Examiner
NEDIALKOVA, LILIA V
Art Unit
1724
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Fca US LLC
OA Round
2 (Final)
55%
Grant Probability
Moderate
3-4
OA Rounds
0m
Est. Remaining
78%
With Interview

Examiner Intelligence

Grants 55% of resolved cases
55%
Career Allowance Rate
241 granted / 436 resolved
-9.7% vs TC avg
Strong +22% interview lift
Without
With
+22.2%
Interview Lift
resolved cases with interview
Typical timeline
3y 4m
Avg Prosecution
43 currently pending
Career history
484
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
50.8%
+10.8% vs TC avg
§102
19.1%
-20.9% vs TC avg
§112
23.7%
-16.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 436 resolved cases

Office Action

§103 §112
DETAILED ACTION The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . This is a final office action in response to Applicant’s remarks and amendments filed on 24 June 2026. Claims 1, 3, 6, 7, 10, 12, 15, 18 and 20 are currently amended. Claims 5 and 16 are canceled. Claims 1-4, 6-15 and 17-20 are pending review in this action. The previous objections to the drawings, specification and the claims are withdrawn in light of Applicant’s corresponding amendments. The previous 35 U.S.C 112 rejections are withdrawn in light of Applicant’s corresponding amendments. New grounds of rejection necessitated by Applicant’s amendments are presented below. Specification The disclosure is objected to because of the following informalities. Applicant amended paragraph [0039], line 7, to replace reference character 80 with 80’ (denoting the relief valve). It appears that the correct reference character for the relief valve is 80’’ (see Fig 2C). Appropriate correction is required. Claim Objections Claim 18 is objected to because of the following informalities. Lines 1-3 of the claim read in part: “positioning the compressible element between a second compressible element between a third battery cell and a fourth battery cell”. It appears that the limitation is intended to read: “positioning Appropriate correction is required. Claim Rejections - 35 USC § 112(b) 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. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claims 1-11 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 1 recites the limitation "the pressure within the battery module" (lines 12-13). There is insufficient antecedent basis for this limitation in the claim. 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. Claims 1-4, 6-10, 12-15 and 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pre-Grant Publication No. 2013/0266832, hereinafter Shirasawa in view of U.S. Pre-Grant Publication No. 2022/0077550, hereinafter Lee. Regarding claim 1, Shirasawa teaches a system. The system comprises a battery module (10). The battery module (10) comprises a case (2). The case (2) includes a plurality of walls including a first end wall spaced apart from a second end wall. The battery module (10) further comprises a plurality of battery cells positioned between the first end wall and the second end wall (paragraphs [0026, 0028] and figure 1). The interior of the case (2) includes a space between the battery cells and the plurality of walls of the case (2) (figure 2). A supplying means communicates dry air (3, “dielectric fluid”) into the space from outside the battery module (10) (paragraphs [0040, 0062]). The system comprises multiple containers (4) (paragraphs [0026, 0050]). Each container (4) has a variable volume (paragraph [0052]) - therefore it is “compressible”. Each container (4, “compressible element”) has walls and is positioned adjacent to the battery cells in the case (2) (figure 2). Each container (4, “compressible element”) includes a pump (“element pump”) communicating dry air (3, “dielectric fluid”) from the space into the container (4, “compressible element”) and from the container (4, “compressible element”) into the space (paragraphs [0040, 0043, 0049]). The system includes a pressure sensor generating a pressure signal indicative of pressure within the battery module (10) (paragraph [0047]). A controller is coupled to the “element pump” and the pressure sensor and is configured to control the pressure within the container (4, “compressible element”) based on the pressure signal (paragraphs [0046, 0047]). Each container (4, “compressible element”) includes a valve (5) communicating the dry air (3, “dielectric fluid”) into the space when a pressure inside the container (4, “compressible element”) is above a predefined pressure (paragraph [0045]). Shirasawa fails to teach: 1) that the supplying means is a pump; and 2) a heat exchanger in communication with the supplying means. Regarding 1), given that Shirasawa teaches using a pump as a supplying means for supplying the dry air (3, “dielectric fluid”) into the container (4, “compressible element”), it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to use a pump (“inlet module pump”) as the supplying means into the space of the case (2) without undue experimentation and with a reasonable expectation of success. Regarding 2), it is known in the art to control the temperature of pressure-regulating fluids that are in thermal communication with battery cells – see, e.g. Lee (paragraph [0039]). Therefore it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to ensure that the temperature of the dry air (3, “dielectric fluid”) entering the space via the inlet module pump is within a desired range by communicating it with a heat exchanger. Regarding claim 2, Shirasawa teaches that the pressure sensor is disposed inside the container (4, “compressible element”) and generates a signal corresponding to a pressure inside the container (4, “compressible element”) (paragraph [0047]). Regarding claim 3, Shirasawa teaches that the pressure sensor is disposed in the space and generates a signal corresponding to a pressure inside the space (paragraph [0047]). Regarding claim 4, Shirasawa teaches controlling the flow of the dry air (3, “dielectric fluid”) through the supplying means (“inlet module pump”). Shirasawa fails to teach controlling the flow in response to a temperature signal. Lee teaches controlling the flow of a pressure regulating fluid in response to a temperature signal (paragraph [0039]). It would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to include a temperature measuring unit in Shirasawa’s assembly and to control the supply of dry air (3, “dielectric fluid”) through the supplying means (“inlet module pump”) in response to temperature readings from the temperature measuring unit. Regarding claim 6, Shirasawa as modified by Lee teaches a heat exchanger in thermal communication with the dry air (3, “dielectric fluid”), which is delivered to the space inside the walls of the case (2). As such, there necessarily is an opening (“outlet”) through which the dry air (3, “dielectric fluid”) enters the walls of the case (2) and which is fluidically coupled to the heat exchanger. Such an opening (“outlet”) would be capable of communicating the dry air (3, “dielectric fluid”) to the heat exchanger. Regarding claims 7 and 8, Shirasawa teaches that the battery module (10) can include multiple battery packs (1) (paragraph [0028]). Shirasawa also teaches that the battery module (10) includes multiple containers (4, “compressible elements”) for finely controlling the pressure inside the case (2) (paragraph [0050]). Shirasawa shows placing a container (4, “compressible element”) on each side of a battery pack (1) (figure 2). Shirasawa fails to teach a container (4, “compressible element”) between a first battery cell and a second battery cell and a second container (4, “compressible element”) between a third battery cell and a fourth battery cell. When accommodating multiple battery packs (1) within the case (2), it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to continue the pattern shown in figure 2 and to alternate the placing of containers (4, “compressible elements”) and battery packs (1) for the purpose of being able to control the pressure in the space between battery packs (1). In such an arrangement including three battery packs (1), there would be one container (4, “compressible element”) between a first battery cell from a first battery pack (1) and a second battery cell from a second battery pack (1). Similarly, there would be a second container (4, “compressible element”) between a third battery cell from a third battery pack (1) and a fourth battery cell from the first battery pack (1). Regarding claim 9, Shirasawa teaches that the container (4, “compressible element”) is disposed between all of the battery cells and the first end wall (figure 1). Therefore, the container (4, “compressible element”) is disposed between a “first cell” and the first end wall. Regarding claim 10, Shirasawa teaches a second container (4, “compressible element”) disposed between all of the battery cells and the second end wall (figure 1). Therefore, the second container (4, “compressible element”) is disposed between a “second battery cell” and the second end wall. Regarding claim 12, Shirasawa teaches a method of controlling a fluidic battery conditioning system including a battery module (10). The battery module (10) comprises a case (2). The case (2) includes a plurality of walls including a first end wall spaced apart from a second end wall. The battery module (10) further comprises a plurality of battery cells positioned between the first end wall and the second end wall (paragraphs [0026, 0028] and figure 1). The battery module (10) further comprises a container (4) (paragraphs [0026, 0050]). The container (4) has a variable volume (paragraph [0052]) - therefore it is “compressible”. The container (4, “compressible element”) has walls, is positioned adjacent to the battery cells in the case (2) (figure 2) and includes an element pump (paragraph [0049] and figure 2). The interior of the case (2) includes a space between the battery cells and the plurality of walls of the case (2) (figure 2). The method includes communicating dry air (3, “dielectric fluid”) into the space from outside the battery module (10) with a supplying means (paragraphs [0040, 0062]). The method further comprises using the element pump to communicate the dry air (3, “dielectric fluid”) into the container (4, “compressible element”) from the space and remove the dry air (3, “dielectric fluid”) from the container (4, “compressible element”) into the space to control a pressure within the container (4, “compressible element”) based on a pressure signal from within the battery module (10) (paragraphs [0043, 0046, 0047, 0049]). The container (4, “compressible element”) includes a valve (5) that releases the dry air (3, “dielectric fluid”) from the container (4, “compressible element”) into the space when a pressure inside the container (4, “compressible element”) is above a predefined pressure (paragraph [0045]). Shirasawa fails to teach: 1) that the supplying means is a pump; and 2) a heat exchanger. Regarding 1), given that Shirasawa teaches using a pump as a supplying means for supplying the dry air (3, “dielectric fluid”) into the container (4, “compressible element”), it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to use a pump as the supplying means into the space of the case (2) without undue experimentation and with a reasonable expectation of success. Regarding 2), it is known in the art to control the temperature of pressure-regulating fluids that are in thermal communication with battery cells – see, e.g. Lee (paragraph [0039]). Therefore it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to ensure that the temperature of the dry air (3, “dielectric fluid”) entering the space via the inlet module pump is within a desired range by communicating it with a heat exchanger. Regarding claim 13, Shirasawa teaches that the pressure sensor is disposed inside the container (4, “compressible element”) and generates a signal corresponding to a pressure inside the container (4, “compressible element”) (paragraph [0047]). Regarding claim 14, Shirasawa teaches that the pressure sensor is disposed in the space and generates a signal corresponding to a pressure inside the space (paragraph [0047]). Regarding claim 15, Shirasawa teaches controlling the flow of the dry air (3, “dielectric fluid”) through the supplying means (“inlet module pump”). Shirasawa fails to teach controlling the flow in response to a temperature signal. Lee teaches controlling the flow of a pressure regulating fluid in response to a temperature signal (paragraph [0039]). It would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to include a temperature measuring unit in Shirasawa’s assembly and to control the supply of dry air (3, “dielectric fluid”) through the supplying means (“inlet module pump”) in response to temperature readings from the temperature measuring unit. Regarding claims 17 and 18, Shirasawa teaches that the battery module (10) can include multiple battery packs (1) (paragraph [0028]). Shirasawa also teaches that the battery module (10) includes multiple containers (4, “compressible elements”) for finely controlling the pressure inside the case (2) (paragraph [0050]). Shirasawa shows placing a container (4, “compressible element”) on each side of a battery pack (1) (figure 2). Shirasawa fails to teach a container (4, “compressible element”) between a first battery cell and a second battery cell and a second container (4, “compressible element”) between a third battery cell and a fourth battery cell. When accommodating multiple battery packs (1) within the case (2), it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to continue the pattern shown in figure 2 and to alternate the placing of containers (4, “compressible elements”) and battery packs (1) for the purpose of being able to control the pressure in the space between battery packs (1). In such an arrangement including three battery packs (1), there would be one container (4, “compressible element”) between a first battery cell from a first battery pack (1) and a second battery cell from a second battery pack (1). Similarly, there would be a second container (4, “compressible element”) between a third battery cell from a third battery pack (1) and a fourth battery cell from the first battery pack (1). Regarding claim 19, Shirasawa teaches that the container (4, “compressible element”) is disposed between all of the battery cells and the first end wall (figure 1). Therefore, the container (4, “compressible element”) is disposed between a “first cell” and the first end wall. Regarding claim 20, Shirasawa teaches a second container (4, “compressible element”) disposed between all of the battery cells and the second end wall (figure 1). Therefore, the second container (4, “compressible element”) is disposed between a “second battery cell” and the second end wall. Claim 11 is rejected under 35 U.S.C. 103 as being unpatentable over U.S. Pre-Grant Publication No. 2013/0266832, hereinafter Shirasawa in view of U.S. Pre-Grant Publication No. 2022/0077550, hereinafter Lee as applied to claim 1 above and further in view of U.S. Pre-Grant Publication No. 2018/0212291, hereinafter Paramasivam. Regarding claim 11, Shirasawa teaches a battery pack (1) comprising a plurality of battery cells (paragraphs [0028, 0034]). Shirasawa fails to teach a spacer. The use of spacers as support structures for battery cells in battery cell assemblies is well-known in the art – see, e.g. Paramasivam (paragraph [0003]). Therefore it would have been obvious to the ordinarily skilled artist before the effective filing date of the claimed invention to include spacers as support structures for the battery cells in Shirasawa’s battery pack (1). Response to Arguments Applicant’s newly added limitations have been considered. However, after further search and consideration, the combination of the Shirasawa and Lee references has been provided, as recited above, to address the amended claims. 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 LILIA V NEDIALKOVA whose telephone number is (571)270-1538. The examiner can normally be reached 8.30 - 5.00 PM. 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, Miriam Stagg can be reached at 571-270-5256. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000. LILIA V. NEDIALKOVA Examiner Art Unit 1724 /MIRIAM STAGG/Supervisory Patent Examiner, Art Unit 1724
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Prosecution Timeline

Mar 06, 2023
Application Filed
Mar 24, 2026
Non-Final Rejection mailed — §103, §112
Jun 24, 2026
Response Filed
Sep 14, 2026
Final Rejection mailed — §103, §112 (current)

Precedent Cases

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

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Prosecution Projections

3-4
Expected OA Rounds
55%
Grant Probability
78%
With Interview (+22.2%)
3y 4m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 436 resolved cases by this examiner. Grant probability derived from career allowance rate.

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