Prosecution Insights
Last updated: April 19, 2026
Application No. 18/179,414

SYSTEM AND METHOD FOR A BATTERY CELL WITH COMBINED STIFFENING AND GAS EXTRACTION

Non-Final OA §103§112
Filed
Mar 07, 2023
Examiner
HAMMOND, KRISHNA R
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
1 (Non-Final)
58%
Grant Probability
Moderate
1-2
OA Rounds
4y 3m
To Grant
76%
With Interview

Examiner Intelligence

Grants 58% of resolved cases
58%
Career Allow Rate
38 granted / 66 resolved
-7.4% vs TC avg
Strong +18% interview lift
Without
With
+18.2%
Interview Lift
resolved cases with interview
Typical timeline
4y 3m
Avg Prosecution
51 currently pending
Career history
117
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
76.1%
+36.1% vs TC avg
§102
10.5%
-29.5% vs TC avg
§112
12.2%
-27.8% vs TC avg
Black line = Tech Center average estimate • Based on career data from 66 resolved cases

Office Action

§103 §112
DETAILED ACTION Notice of Pre-AIA or AIA Status The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Election/Restrictions Applicant’s election without traverse of Invention I, comprising claims 1-16, in the reply filed on 02/04/2026 is acknowledged. Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. 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. Claim 2 is 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. Specifically, “wherein the second portion of the frame includes an entirety of the frame,” appears to contradict the presence of the central hollow portion. Specifically, the use of “entirety” is described in the specification at [0055] as “the portion 348 in the embodiment of FIG. 4A which is porous or includes a gas diffusion membrane includes an entirety of the frame 340.” However, as presented here, the second portion in context makes it unclear if Claim 2 comprises a frame which is porous, or eliminates the feature “a central hollow portion.” 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. Claims 1-2, 6, 10, and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Voltering, et al. (JP 6013448 B2). See machine translation for citation. Regarding Claim 1, Voltering teaches a battery cell (“[0006]Gas diffusion electrodes have been used for many years in batteries, electrolysers and fuel cells.”), comprising: an electrode stack including at least one pair of an anode and a cathode and a separator disposed between the anode and the cathode (“[0028]Figures 1, 2 and 3 show an electrochemical cell according to the invention, said cell comprising an anode compartment (12) and a cathode compartment (11) separated by a membrane (5)”), wherein operation of the battery cell causes gas or moisture to form (“[0004]For example, in the case of electrolytically producing a halogen gas from an aqueous solution of an alkali halide . . . [h]ydrogen is also formed” ; this passage introduces halogen gas generation as known in the prior art, and that the invention of Voltering is an improvement upon a traditional gas diffusion electrode, see [0015]); a frame constructed with a stiff material (“[0030] flanged-shaped areas (14a, 14b, 15a, 15b) designed like a frame”), the frame including: a central hollow portion (the “shaped internal structure (1)”), wherein the electrode stack is disposed within the central hollow portion (“[0030] A seal (2) is attached which secures the electrode (3) within the shaped internal structure (1) . . . The seal (2) provided in the molded internal structure (1) at the upper edge (19) of the gas diffusion electrode (3) is a hollow section seal”), and a second portion of the frame that is porous or includes a gas diffusion membrane (“wherein a porous material (8) is arranged in parallel between the gas diffusion electrode (3) and said membrane (5)” ; the gas diffusion electrode is described as a “liquid permeable carrier,” and has a “[0019] bending radius,” strongly implying this electrode is a membrane); an electrolyte disposed within the frame and in contact with the electrode stack (“[0030] wherein a porous material (8) is arranged in parallel between the gas diffusion electrode (3) and said membrane (5) And a device for supplying and evacuating the gas, wherein the gas space (22) is separated from the electrolyte space (7) by appropriate means (23). 11) the electrolyte space (7) comprises a shaped internal structure (1).”) Voltering at [0028 – 30], Fig. 1. Regarding “and a functional material disposed within the battery cell and outside of the central hollow portion, the functional material being configured for absorbing the gas or the moisture; and wherein the second portion of the frame that is porous or includes a gas diffusion membrane enables the gas or the moisture to exit the central hollow portion and come into contact with the functional material while maintaining the electrolyte within the frame,” Voltering teaches “[0030] anode section (12) and cathode section (11) separated from one another by a membrane (5) . . . A gas diffusion electrode (3), a gas (20, 21) and an electrolyte (9, 10), wherein a porous material (8) is arranged in parallel between the gas diffusion electrode (3) and said membrane (5).” While this is a teaching of a functional material which absorbs gas (“[0028] the porous material acts as a percolator”) its position “between” the gas diffusion membrane and the membrane is not directly defined as within a second portion of the frame and outside of the central hollow position. However, the Office notes that because of its role as a “percolator,” its purpose is ultimately to maintain the electrolyte within the frame. Further, Voltering teaches “[0018] Furthermore, the design of the shaped internals is guaranteed not to damage the porous material (8) used as a percolator.” Regarding a “stiff material,” while the gas diffusion electrode 3 has a bending radius, it is held in the electrolysis cell by the support member 4 and the frame (flange shaped areas 14a,b and 15a,b) and is held “taut” [0029] due to being fixed at an upper end 18 and a lower end 17. Voltering at [0029]. This reads upon a “stiff” material, given that stiffness is required to provide tension that would make the bendable electrode “taut”. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to modify the battery cell of Voltering, such that the functional material (the porous material 8 of Voltering) is disposed within the battery cell and outside of the central hollow portion, such that the second portion of the frame that is porous or includes a gas diffusion membrane enables the gas or the moisture to exit the central hollow portion and come into contact with the functional material while maintaining the electrolyte within the frame, wherein the functional material (porous material 8) forms a concentric frame with the porous second portion (i.e. the gas diffusion membrane 3), which in turn surrounds the membrane 5, because the rearrangement of parts is obvious wherein shifting the position of the components would not modify the operation of the device. MPEP 2144.04 (VI)(C). Here, the repeated description of the porous material 8 being “between,” “parallel,” and projecting between the membrane and the gas diffusion electrode of Voltering indicates that shifting the porous material 8 (which acts as a percolator) to act as a frame surrounding the membrane 5, would not be expected to modify the operation of the device, given that the porous material 8 already absorbs and re-circulates moisture which cannot permeate the membrane 5. PNG media_image1.png 591 500 media_image1.png Greyscale Fig. 1 of Voltering. Claim 1 is obvious over Voltering. Regarding Claim 2, Claim 2 relies upon Claim 1. Claim 1 is obvious over modified Voltering. As understood (in spite of the 112 rejection above), “an entirety of the frame,” is taken to mean entirety of the second portion is porous or includes a gas diffusion membrane. Here, the previous modification presents the gas diffusion membrane as a frame. Claim 2 is obvious over Voltering. Regarding Claim 1, Claim 3 relies upon Claim 1. Claim 1 is obvious over modified Voltering. Voltering at Fig. 1 teaches a cross section of a battery, comprising a prism having two extending flanges. Voltering at Fig. 1. This strongly implies a pouch cell (wherein the pouch contains the flanges), particularly because Voltering teaches it is critical that the gas diffusion electrode be hermetically sealed ([0011]). One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to modify Voltering such that the battery cell is a pouch battery cell, because Voltering strongly implies the presence of an exterior seal which prevents the intrusion of liquid, and because of the shape of the configuration shown in Fig. 1. Claim 3 is obvious over Voltering. Regarding Claim 6, Claim 6 relies upon Claim 1. Claim 1 is obvious over modified Voltering. Voltering teaches a hollow section seal 2 provided in the shaped internal structure (1) at the upper edge (19) of the gas diffusion electrode. Voltering at [0020 – 23]. Further, the shaped internal structure (1) of the cathode compartment (11) “may be of any geometric shape . . . particularly preferably U shaped.” Voltering teaches frame-like flange portions 14a,b and 15a,b within each of the anode compartment and cathode compartment. In other words, the frame is a portion of the cathode compartment 11, which comprises a U shaped portion, which may be described as a “hollow area.” As previously modified, the functional material surrounds the porous or includes a gas diffusion membrane concentrically; this includes an embodiment wherein the functional material is disposed in the hollow area, wherein the frame portion is the outermost portion. For these foregoing reasons, modified Voltering teaches the frame includes a wall including a hollow area; and wherein the functional material is disposed within the hollow area. Claim 6 is obvious over Voltering. Regarding Claim 10, Voltering teaches a device (“[0001]The present invention can be regarded as in the technical field of electrochemical devices”), comprising: a battery cell (“[0006]Gas diffusion electrodes have been used for many years in batteries, electrolysers and fuel cells.”), including: an electrode stack including at least one pair of an anode and a cathode and a separator disposed between the anode and the cathode (“[0028]Figures 1, 2 and 3 show an electrochemical cell according to the invention, said cell comprising an anode compartment (12) and a cathode compartment (11) separated by a membrane (5)”), wherein operation of the battery cell causes gas or moisture to form (“[0004]For example, in the case of electrolytically producing a halogen gas from an aqueous solution of an alkali halide . . . [h]ydrogen is also formed” ; this passage introduces halogen gas generation as known in the prior art, and that the invention of Voltering is an improvement upon a traditional gas diffusion electrode, see [0015]); a frame constructed with a stiff material (“[0030] flanged-shaped areas (14a, 14b, 15a, 15b) designed like a frame”), the frame including: a central hollow portion (the “shaped internal structure (1)”), wherein the electrode stack is disposed within the central hollow portion (“[0030] A seal (2) is attached which secures the electrode (3) within the shaped internal structure (1) . . . The seal (2) provided in the molded internal structure (1) at the upper edge (19) of the gas diffusion electrode (3) is a hollow section seal”), and a second portion of the frame that is porous or includes a gas diffusion membrane (“wherein a porous material (8) is arranged in parallel between the gas diffusion electrode (3) and said membrane (5)” ; the gas diffusion electrode is described as a “liquid permeable carrier,” and has a “[0019] bending radius,” strongly implying this electrode is a membrane); an electrolyte disposed within the frame and in contact with the electrode stack (“[0030] wherein a porous material (8) is arranged in parallel between the gas diffusion electrode (3) and said membrane (5) And a device for supplying and evacuating the gas, wherein the gas space (22) is separated from the electrolyte space (7) by appropriate means (23). 11) the electrolyte space (7) comprises a shaped internal structure (1).”) Voltering at [0028 – 30], Fig. 1. Regarding “and a functional material disposed within the battery cell and outside of the central hollow portion, the functional material being configured for absorbing the gas or the moisture; and wherein the second portion of the frame that is porous or includes a gas diffusion membrane enables the gas or the moisture to exit the central hollow portion and come into contact with the functional material while maintaining the electrolyte within the frame,” Voltering teaches “[0030] anode section (12) and cathode section (11) separated from one another by a membrane (5) . . . A gas diffusion electrode (3), a gas (20, 21) and an electrolyte (9, 10), wherein a porous material (8) is arranged in parallel between the gas diffusion electrode (3) and said membrane (5).” While this is a teaching of a functional material which absorbs gas (“[0028] the porous material acts as a percolator”) its position “between” the gas diffusion membrane and the membrane is not directly defined as within a second portion of the frame and outside of the central hollow position. However, the Office notes that because of its role as a “percolator,” its purpose is ultimately to maintain the electrolyte within the frame. Further, Voltering teaches “[0018] Furthermore, the design of the shaped internals is guaranteed not to damage the porous material (8) used as a percolator.” Regarding a “stiff material,” while the gas diffusion electrode 3 has a bending radius, it is held in the electrolysis cell by the support member 4 and the frame (flange shaped areas 14a,b and 15a,b) and is held “taut” [0029] due to being fixed at an upper end 18 and a lower end 17. Voltering at [0029]. This reads upon a “stiff” material, given that stiffness is required to provide tension that would make the bendable electrode “taut”. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to modify the battery cell of Voltering, such that the functional material (the porous material 8 of Voltering) is disposed within the battery cell and outside of the central hollow portion, such that the second portion of the frame that is porous or includes a gas diffusion membrane enables the gas or the moisture to exit the central hollow portion and come into contact with the functional material while maintaining the electrolyte within the frame, wherein the functional material (porous material 8) forms a concentric frame with the porous second portion (i.e. the gas diffusion membrane 3), which in turn surrounds the membrane 5, because the rearrangement of parts is obvious wherein shifting the position of the components would not modify the operation of the device. MPEP 2144.04 (VI)(C). Here, the repeated description of the porous material 8 being “between,” “parallel,” and projecting between the membrane and the gas diffusion electrode of Voltering indicates that shifting the porous material 8 (which acts as a percolator) to act as a frame surrounding the membrane 5, would not be expected to modify the operation of the device, given that the porous material 8 already absorbs and re-circulates moisture which cannot permeate the membrane 5. Claim 10 is obvious over Voltering. Regarding Claim 13, Claim 13 relies upon Claim 10. Claim 10 is obvious over modified Voltering. Voltering teaches a hollow section seal 2 provided in the shaped internal structure (1) at the upper edge (19) of the gas diffusion electrode. Voltering at [0020 – 23]. Further, the shaped internal structure (1) of the cathode compartment (11) “may be of any geometric shape . . . particularly preferably U shaped.” Voltering teaches frame-like flange portions 14a,b and 15a,b within each of the anode compartment and cathode compartment. In other words, the frame is a portion of the cathode compartment 11, which comprises a U shaped portion, which may be described as a “hollow area.” As previously modified, the functional material surrounds the porous or includes a gas diffusion membrane concentrically; this includes an embodiment wherein the functional material is disposed in the hollow area, wherein the frame portion is the outermost portion. For these foregoing reasons, modified Voltering teaches the frame includes a wall including a hollow area; and wherein the functional material is disposed within the hollow area. Claim 13 is obvious over Voltering. Claims 4 – 5, 7, 12, and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Voltering, in view of Alday, et. al. (US 20080124611 A1). Regarding Claim 4, Claim 4 relies upon Claim 1. Claim 1 is obvious over modified Voltering. Voltering is silent as to a cylindrical can battery cell. Alday teaches a consumer battery, wherein the consumer battery comprises an electricity generating unit and a fuel unit, wherein this battery comprises two concentric membrane electrode assemblies (MEAs). Alday at [0012, 23]. The battery comprises catalysts / diffusers 114 and 116, as well as a cylindrical frame. Id. at [0079, 81]. Alday teaches that conventional fuel cells take place at high pressure and temperature conditions; in order to configure the battery to be operational at normal conditions, and so that the battery may have a cross section large enough to deliver the required power, “[0008] it becomes necessary to study other geometric configurations. A cylindrical arrangement seems adequate to the shape of a consumer battery.” Id. at [0008]. 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 cell of modified Voltering, such that it comprises a cylindrical can battery cell, because Voltering teaches an increase to cross section and thereby output which would permit the cell to be used in consumer applications at normal temperature and pressure. Claim 4 is obvious over Voltering, in view of Alday. Regarding Claim 5, Claim 5 relies upon Claim 4. Claim 4 is obvious over modified Voltering. Voltering is silent as to a pouch battery cell, a prismatic can battery cell, or a coin battery cell. Alday teaches a consumer battery, wherein the consumer battery comprises an electricity generating unit and a fuel unit, wherein this battery comprises two concentric membrane electrode assemblies (MEAs). Alday at [0012, 23]. The battery comprises catalysts / diffusers 114 and 116, as well as a cylindrical frame. Id. at [0079, 81]. Alday teaches that conventional fuel cells take place at high pressure and temperature conditions; in order to configure the battery to be operational at normal conditions, and so that the battery may have a cross section large enough to deliver the required power, “[0008] it becomes necessary to study other geometric configurations. A cylindrical arrangement seems adequate to the shape of a consumer battery.” Id. at [0008]. Alday teaches a “work housing” which encloses the battery. Alday at [0098]. As previously modified, the battery cell of Claim 4 is modified to be cylindrical. Further, Alday teaches a cylindrical shaped frame, and a hollow cylindrical portion; for this reason, Modified Voltering also teaches an electrode stack stack (which fits within the cylindrical assembly of Alday) is spiral shaped. Claim 5 is obvious over Voltering, in view of Alday. Regarding Claim 7, Claim 7 relies upon Claim 1. Claim 1 is obvious over modified Voltering. Voltering teaches an outer wall 13, and through its structure in Fig. 1, at least implies some kind of exterior covering, but is ultimately silent as to an exterior case. Voltering at [0030], Fig. 1. Alday teaches a consumer battery, wherein the consumer battery comprises an electricity generating unit and a fuel unit, wherein this battery comprises two concentric membrane electrode assemblies (MEAs). Alday at [0012, 23]. The battery comprises catalysts / diffusers 114 and 116, as well as a cylindrical frame. Id. at [0079, 81]. Alday teaches that conventional fuel cells take place at high pressure and temperature conditions; in order to configure the battery to be operational at normal conditions, and so that the battery may have a cross section large enough to deliver the required power, “[0008] it becomes necessary to study other geometric configurations. A cylindrical arrangement seems adequate to the shape of a consumer battery.” Id. at [0008]. Alday teaches a “work housing” which encloses the battery. Alday at [0098]. As modified within Claim 4 above, the battery cell of Voltering is modified to include a cylindrical shape as in Alday; this includes the cylindrical work housing of Alday, which reads upon an “exterior case.” As previously modified within Claim 1, the functional material surrounds the frame, indicating that as currently modified this exterior case in turn surrounds the functional material. Finally, as previously noted, Alday teaches a benefit to this modification in the form of a larger cross section to produce sufficient power for consumer applications. Id. at [0008]. For this reason, modified Voltering teaches the battery cell further includes an exterior case; and wherein the functional material is disposed between the frame and the exterior case. Claim 7 is obvious over Voltering, in view of Alday. Regarding Claim 12, Claim 12 relies upon Claim 10. Claim 10 is obvious over modified Voltering. Voltering is silent as to a cylindrical can battery cell. Alday teaches a consumer battery, wherein the consumer battery comprises an electricity generating unit and a fuel unit, wherein this battery comprises two concentric membrane electrode assemblies (MEAs). Alday at [0012, 23]. The battery comprises catalysts / diffusers 114 and 116, as well as a cylindrical frame. Id. at [0079, 81]. Alday teaches that conventional fuel cells take place at high pressure and temperature conditions; in order to configure the battery to be operational at normal conditions, and so that the battery may have a cross section large enough to deliver the required power, “[0008] it becomes necessary to study other geometric configurations. A cylindrical arrangement seems adequate to the shape of a consumer battery.” Id. at [0008]. 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 cell of modified Voltering, such that it comprises a cylindrical can battery cell, because Voltering teaches an increase to cross section and thereby output which would permit the cell to be used in consumer applications at normal temperature and pressure. Claim 12 is obvious over Voltering, in view of Alday. Regarding Claim 14, Claim 14 relies upon Claim 10. Claim 10 is obvious over modified Voltering. Voltering teaches an outer wall 13, and through its structure in Fig. 1, at least implies some kind of exterior covering, but is ultimately silent as to an exterior case. Voltering at [0030], Fig. 1. Alday teaches a consumer battery, wherein the consumer battery comprises an electricity generating unit and a fuel unit, wherein this battery comprises two concentric membrane electrode assemblies (MEAs). Alday at [0012, 23]. The battery comprises catalysts / diffusers 114 and 116, as well as a cylindrical frame. Id. at [0079, 81]. Alday teaches that conventional fuel cells take place at high pressure and temperature conditions; in order to configure the battery to be operational at normal conditions, and so that the battery may have a cross section large enough to deliver the required power, “[0008] it becomes necessary to study other geometric configurations. A cylindrical arrangement seems adequate to the shape of a consumer battery.” Id. at [0008]. Alday teaches a “work housing” which encloses the battery. Alday at [0098]. As modified within Claim 4 above, the battery cell of Voltering is modified to include a cylindrical shape as in Alday; this includes the cylindrical work housing of Alday, which reads upon an “exterior case.” As previously modified within Claim 1, the functional material surrounds the frame, indicating that as currently modified this exterior case in turn surrounds the functional material. Finally, as previously noted, Alday teaches a benefit to this modification in the form of a larger cross section to produce sufficient power for consumer applications. Id. at [0008]. For this reason, modified Voltering teaches the battery cell further includes an exterior case; and wherein the functional material is disposed between the frame and the exterior case. Claim 14 is obvious over Voltering, in view of Alday. Claims 8 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Voltering, in view of Stewart, et. al. (EP3257097B1). Regarding Claim 8, Claim 8 relies upon Claim 1. Claim 1 is obvious over modified Voltering. Voltering is silent as a frame constructed with a polymer including polytetrafluoroethylene (PTFE), poly (1,1,2,2 tetrafluoroethylene), or a sulfonated tetrafluoroethylene-based fluoropolymer-copolymer. Stewart teaches a seal for a membrane electrode assembly, wherein the frame and flow processable sealing material may be a thermoplastic material including PTFE. Stewart at [0011, 41]. Stewart teaches “[0041] by sealing the periphery of the MEA with a thermoplastic frame, and then providing an elastomeric seal bead on the frame so that the elastomeric material is physically separated from the MEA, MEA degradation related to the degradation of the elastomeric seal material is substantially reduced.” Id. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to further modify the frame of modified Voltering, such that the frame is constructed with a polymer including polytetrafluoroethylene (PTFE), because Stewart teaches a benefit to MEA degradation related to the degradation of the sealing material and the performance of the frame. Claim 8 is obvious over Voltering, in view of Stewart. Regarding Claim 15, Claim 15 relies upon Claim 10. Claim 10 is obvious over modified Voltering. Voltering is silent as a frame constructed with a polymer including polytetrafluoroethylene (PTFE), poly (1,1,2,2 tetrafluoroethylene), or a sulfonated tetrafluoroethylene-based fluoropolymer-copolymer. Stewart teaches a seal for a membrane electrode assembly, wherein the frame and flow processable sealing material may be a thermoplastic material including PTFE. Stewart at [0011, 41]. Stewart teaches “[0041] by sealing the periphery of the MEA with a thermoplastic frame, and then providing an elastomeric seal bead on the frame so that the elastomeric material is physically separated from the MEA, MEA degradation related to the degradation of the elastomeric seal material is substantially reduced.” Id. One of ordinary skill in the art before the effective filing date of the claimed invention would find it obvious to further modify the frame of modified Voltering, such that the frame is constructed with a polymer including polytetrafluoroethylene (PTFE), because Stewart teaches a benefit to MEA degradation related to the degradation of the sealing material and the performance of the frame. Claim 15 is obvious over Voltering, in view of Stewart. Claims 9 and 16 are rejected under 35 U.S.C. 103 as being unpatentable over Voltering, in view of Oh, et. al. (EP 3196975 A1). Regarding Claim 9, Claim 9 relies upon Claim 1. Claim 1 is obvious over modified Voltering. Voltering is silent as to the frame being constructed with a metal including stainless steel, aluminum, or copper. Oh teaches an electrochemical cell, wherein the battery comprises a gas diffusion layer 25, an electrolyte membrane 22, and a frame 11. Oh at [0054, 96 - 99]. Oh teaches “[0044] The frame 11 may use, for example, a metal plate such as stainless steel, nickel, and aluminum, and thereby the positive current collector 10 maintains a predetermined external shape and volume. However, the invention is not limited thereto. [0045] In such an embodiment, where the frame 11 may be continuously exposed to the air, an anti-oxidation film may be disposed or formed on a surface of the part of which the injection part 12 and the ejection part 13 are defined and an inner wall that defines the passage 14. The anti-oxidation film may be a film including or made of an organic material, an inorganic material, an organic/inorganic mixture, or an oxidation resistant metal or alloy.” Id. at [0044-45]. This indicates a benefit to protecting the predetermined shape of the frame, as well as providing oxidation resistance when utilizing, for example, a stainless steel plate comprising an anti-oxidation film or metal or alloy. Because this metal or alloy is not defined, and stainless steel has anti-oxidation properties, this further supports a benefit to utilizing stainless steel as a component of the frame. One of ordinary skill in the art before the filing date of the claimed invention would find it obvious to further modify the battery of Voltering such that the frame of Voltering is a stainless steel frame, because Oh teaches a benefit to maintaining the shape of the frame and oxidation resistance. Id. Claim 9 is obvious over Voltering, in view of Oh. Regarding Claim 16, Claim 16 relies upon Claim 10. Claim 10 is obvious over modified Voltering. Voltering is silent as to the frame being constructed with a metal including stainless steel, aluminum, or copper. Oh teaches an electrochemical cell, wherein the battery comprises a gas diffusion layer 25, an electrolyte membrane 22, and a frame 11. Oh at [0054, 96 - 99]. Oh teaches “[0044] The frame 11 may use, for example, a metal plate such as stainless steel, nickel, and aluminum, and thereby the positive current collector 10 maintains a predetermined external shape and volume. However, the invention is not limited thereto. [0045] In such an embodiment, where the frame 11 may be continuously exposed to the air, an anti-oxidation film may be disposed or formed on a surface of the part of which the injection part 12 and the ejection part 13 are defined and an inner wall that defines the passage 14. The anti-oxidation film may be a film including or made of an organic material, an inorganic material, an organic/inorganic mixture, or an oxidation resistant metal or alloy.” Id. at [0044-45]. This indicates a benefit to protecting the predetermined shape of the frame, as well as providing oxidation resistance when utilizing, for example, a stainless steel plate comprising an anti-oxidation film or metal or alloy. Because this metal or alloy is not defined, and stainless steel has anti-oxidation properties, this further supports a benefit to utilizing stainless steel as a component of the frame. One of ordinary skill in the art before the filing date of the claimed invention would find it obvious to further modify the battery of Voltering such that the frame of Voltering is a stainless steel frame, because Oh teaches a benefit to maintaining the shape of the frame and oxidation resistance. Id. Claim 16 is obvious over Voltering, in view of Oh. Regarding Claim 11, Claim 11 relies upon Claim 10. Claim 10 is obvious over modified Voltering. Voltering is silent as to the “[0001] electrochemical device” being a vehicle. Oh teaches “[0002] a large-capacity rechargeable battery is typically used as a motor-driving power source for hybrid vehicles and electric vehicles.” Claim 11 is obvious over Voltering, in view of Oh. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to KRISHNA RAJAN HAMMOND whose telephone number is (571)272-9997. The examiner can normally be reached 9:00 - 6:30 PM M-F. 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, Nicole Buie-Hatcher can be reached at (571) 270-3879. 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. /K.R.H./Examiner , Art Unit 1725 /NICOLE M. BUIE-HATCHER/Supervisory Patent Examiner, Art Unit 1725
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Prosecution Timeline

Mar 07, 2023
Application Filed
Mar 17, 2026
Non-Final Rejection — §103, §112 (current)

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Expected OA Rounds
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4y 3m
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