Prosecution Insights
Last updated: April 19, 2026
Application No. 18/209,845

DEVICES SYSTEMS AND METHODS FOR VEHICLE POWER STORAGE

Non-Final OA §102§103
Filed
Jun 14, 2023
Examiner
HA, STEVEN S
Art Unit
1735
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Volkswagen Aktiengesellschaft
OA Round
1 (Non-Final)
70%
Grant Probability
Favorable
1-2
OA Rounds
2y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 70% — above average
70%
Career Allow Rate
476 granted / 676 resolved
+5.4% vs TC avg
Strong +30% interview lift
Without
With
+30.4%
Interview Lift
resolved cases with interview
Typical timeline
2y 3m
Avg Prosecution
45 currently pending
Career history
721
Total Applications
across all art units

Statute-Specific Performance

§101
0.8%
-39.2% vs TC avg
§103
45.4%
+5.4% vs TC avg
§102
22.0%
-18.0% vs TC avg
§112
27.9%
-12.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 676 resolved cases

Office Action

§102 §103
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 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 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. Claim(s) 1-10 and 14-18 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Jost et al. (EP 3499603 A1; hereinafter “Jost”; using the attached English machine translation). Regarding claim 1, Jost teaches a modular vehicle power storage system, comprising: a number of power storage modules (A1-A4, see Figs. 37 and 38) comprising power storage materials (electrochemical cell C, see Figs. 16, 17, 28, and 38; [0177]), each power storage module including a housing (see Figs. 16-17) defining a power storage cavity therein (equated to cavity that stores electrochemical cell C, see Figs. 16-17) for receiving power storage materials, the housing including a casing (combination of housing 6 with hollow mandrel 34, see Figs. 16-17; [0174]-[0178]) and a cap (cover 9, see Figs. 16-17; [0173] and [0199]), the casing including an inner wall (equated to wall defined by hollow mandrel 34 in contact with electrochemical cell C and portion of hollow output terminal part 5 that is at and below cover 9, see Figs. 16 and 17; [0177]) and an outer wall (housing 6, see Figs. 16-17) spaced apart from each other to define the power storage cavity therebetween (see Figs. 16-17), the cap formed for engagement with the casing between the inner and outer walls (see Figs. 16-17) to enclose the power storage cavity with the power storage materials therein (see Figs. 16-17), wherein the casing defines a fluid passageway through the housing (combination of interior of hollow mandrel 34 and hollow output terminal part 5 in continuity with the hollow mandrel 34, see Figs. 16-17; [0174]), the fluid passageway being separate from the power storage cavity (see Figs. 16-17) and formed to pass fluid coolant in thermal communication to receive heat from the housing (see [0174]). Regarding the functional language (e.g., for receiving power storage materials, for engagement with the casing between the inner and outer walls to enclose the power storage cavity with the power storage materials therein, formed to pass fluid coolant in thermal communication to receive heat from the housing), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 2, Jost teaches wherein a module connector extends from the housing (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) for engagement with an adjacent power storage module. Regarding the functional language (e.g., for engagement with an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 3, Jost teaches wherein the modular connector (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) defines an extended portion of the fluid passageway (see Figs. 16-17 and [0174]) to pass fluid coolant with the adjacent power storage module. Regarding the functional language (e.g., to pass fluid coolant with the adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 4, Jost teaches wherein the housing defines a connector receptacle (threaded receptable 35 at bottom end 8 of housing 6, see Figs. 16, 26-28; [0178]) for receiving connection of the module connector of an adjacent power storage module. Regarding the functional language (e.g., for receiving connection of the module connector of an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 5, Jost teaches wherein the connector receptacle (threaded receptable 35 at bottom end 8 of housing 6, see Figs. 16, 26-28; [0178]) defines an opening of the fluid passageway (see Fig. 38) such that fluid coolant passing through the modular connector (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) of the adjacent power storage module engaged with the connector receptacle (threaded receptable 35 at bottom end 8 of housing 6, see Figs. 16, 26-28; [0178]) passes through the fluid passageway via the opening (see Fig. 38 and [0174]). Regarding claim 6, Jost teaches wherein the housing defines a connector receptacle (threaded receptable 35 at bottom end 8 of housing 6, see Figs. 16, 26-28; [0178]) for receiving connection of the module connector of an adjacent power storage module. Regarding the functional language (e.g., for receiving connection of the module connector of an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 7, Jost teaches wherein the module connector defines a nozzle (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) for engagement with the connector receptacle of an adjacent power storage module to fluidly seal therebetween (see Figs. 16-17). Regarding the functional language (e.g., for engagement with the connector receptacle of an adjacent power storage module to fluidly seal therebetween), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 8, Jost teaches wherein at least one of the nozzle (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) and the connector receptacle of the adjacent power storage module includes a seal receiver (groove 37, see Figs. 16-18; [0180]) for holding a seal (sealing gasket 38, see Figs. 16-17; [0180]) for engagement between the nozzle and the connector receptacle to form a fluid seal (see [0180] and [0207]). Regarding the functional language (e.g., for holding a seal for engagement between the nozzle and the connector receptacle to form a fluid seal), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 9, Jost teaches wherein the module connector defines a shoulder (see Fig. 27 – shoulder equated to portion of hollow output terminal part 5 just below gasket 38) for engagement with an end of the connector receptacle (see Fig. 27) of the adjacent power storage module while the nozzle is received therein (see Fig. 27), to define a gap (see Fig. 27 – depicted as “d”) between the power storage module and the adjacent power storage module. Regarding the functional language (e.g., for engagement with an end of the connector receptacle of the adjacent power storage module while the nozzle is received therein, to define a gap between the power storage module and the adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 10, Jost teaches wherein a plurality of the power storage modules are arranged laterally adjacent each other in an initial course, and electrically connected between anodes and between cathodes (see Figs. 38-39). Regarding claim 14, Jost teaches a vehicle (see [0038] and [0048]) comprising the modular vehicle power storage system of claim 1 (see rejection for claim 1 above). Regarding claim 15, Jost teaches a vehicle power storage module, comprising: a housing (see Figs. 16-17) defining a power storage cavity (equated to cavity that stores electrochemical cell C, see Figs. 16-17) therein for receiving power storage materials (electrochemical cell C, see Figs. 16, 17, 28, and 38; [0177]), the housing including a casing (combination of housing 6 with hollow mandrel 34, see Figs. 16-17; [0174]-[0178]) and a cap (cover 9, see Figs. 16-17; [0173] and [0199]), the casing including an inner wall (equated to wall defined by hollow mandrel 34 in contact with electrochemical cell C and portion of hollow output terminal part 5 that is at and below cover 9, see Figs. 16 and 17; [0177]) and an outer wall (housing 6, see Figs. 16-17) spaced apart from each other to define the power storage cavity therebetween (see Figs. 16-17), the cap formed for engagement with the casing between the inner and outer walls (see Figs. 16-17) to enclose the power storage cavity with the power storage materials (see Figs. 16-17), wherein the casing defines a fluid passageway through the housing (combination of interior of hollow mandrel 34 and hollow output terminal part 5 in continuity with the hollow mandrel 34, see Figs. 16-17; [0174]), the fluid passageway being separate from the power storage cavity (see Figs. 16-17) and formed to pass fluid coolant in thermal communication to receive heat from the housing (see [0174]). Regarding the functional language (e.g., for receiving power storage materials, for engagement with the casing between the inner and outer walls to enclose the power storage cavity with the power storage materials, formed to pass fluid coolant in thermal communication to receive heat from the housing), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 16, Jost teaches wherein a module connector extends from the housing (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) for engagement with an adjacent power storage module. Regarding the functional language (e.g., for engagement with an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 17, Jost teaches wherein the modular connector (portion of hollow output terminal part 5 above cover 9, see Figs. 16-17; [0174]) defines an extended portion of the fluid passageway (see Figs. 16-17 and [0174]) to pass fluid coolant with the adjacent power storage module. Regarding the functional language (e.g., to pass fluid coolant with the adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 18, Jost teaches wherein the housing defines a connector receptacle (threaded receptable 35 at bottom end 8 of housing 6, see Figs. 16, 26-28; [0178]) for receiving connection of the module connector of an adjacent power storage module. Regarding the functional language (e.g., for receiving connection of the module connector of an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. 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. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 1-7, 10, 11, and 14-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Gilbert et al. (US 2017/0324126; hereinafter “Gilbert”). Regarding claim 1, Gilbert teaches a modular vehicle power storage system, comprising: a number of power storage modules (battery cells 56B, see Fig. 5B; [0058]) comprising power storage materials (electrode assembly 78B inside each battery cell 56B, see Figs. 5B and 6; [0060]), each power storage module (battery cells 56B, see Fig. 5B; [0058]) including a housing (can assembly 76B and inner wall 80B, see Fig. 6; [0060]) defining a power storage cavity therein (space 84B, see Fig. 6; [0060]) for receiving power storage materials (electrode assembly 78B inside each battery cell 56B, see Figs. 5B and 6; [0060]), the housing including a casing (can assembly 76B and inner wall 80B, see Fig. 6; [0060]) and a cap (Gilbert is silent to specifically teaching a cap, however, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to include a cap in the housing in order to insert the electrode assembly 78B into each battery cell 56B, see Figs. 5B and 6; [058]-[0060]), the casing including an inner wall (inner wall 80B, see Fig. 6; [0060]) and an outer wall (outer wall 86B, see Fig. 6; [0060]) spaced apart from each other (see Fig. 6) to define the power storage cavity therebetween (space 84B, see Fig. 6; [0060]), the cap formed for engagement with the casing between the inner and outer walls to enclose the power storage cavity with the power storage materials therein (Gilbert is silent to specifically teaching a cap for engagement with the casing between the inner and outer walls, however, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to include a cap for engagement with the casing between the inner and outer walls in order to insert and hold the electrode assembly 78B into each battery cell 56B, see Figs. 5B and 6; [058]-[0060]), wherein the casing defines a fluid passageway through the housing (void 60B for cooling device 56B, see Figs. 5B and 6; [0060]), the fluid passageway being separate from the power storage cavity (see Figs. 5B and 6; [0060]) and formed to pass fluid coolant in thermal communication to receive heat from the housing (see [0057]-[0060]). Regarding the functional language (e.g., for receiving power storage materials, for engagement with the casing between the inner and outer walls to enclose the power storage cavity with the power storage materials therein, formed to pass fluid coolant in thermal communication to receive heat from the housing), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 2, Gilbert teaches wherein a module connector (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) extends from the housing (see Fig. 5B; [0058]-[0060]) for engagement with an adjacent power storage module (see Fig. 5B). Regarding the functional language (e.g., for engagement with an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 3, Gilbert teaches wherein the modular connector (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) defines an extended portion of the fluid passageway (see Fig. 5B) to pass fluid coolant with the adjacent power storage module. Regarding the functional language (e.g., to pass fluid coolant with the adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 4, Gilbert teaches wherein the housing defines a connector receptacle (recess on left side of the middle and rightmost battery cell 56B, but it would have been obvious to also include the recess on the leftmost battery in order to be able to further add modules, see Fig. 5B; [0058]-[0060]) for receiving connection of the module connector of an adjacent power storage module. Regarding the functional language (e.g., for receiving connection of the module connector of an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 5, Gilbert teaches wherein the connector receptacle (recess on left side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) defines an opening of the fluid passageway (see Fig. 5B) such that fluid coolant passing through the modular connector (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) of the adjacent power storage module engaged with the connector receptacle (recess on left side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) passes through the fluid passageway via the opening (see Fig. 5B). Regarding claim 6, Gilbert teaches wherein the housing defines a connector receptacle (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) for receiving connection of the module connector of an adjacent power storage module. Regarding the functional language (e.g., for receiving connection of the module connector of an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 7, Gilbert teaches wherein the module connector defines a nozzle (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) for engagement with the connector receptacle of an adjacent power storage module to fluidly seal therebetween. Regarding the functional language (e.g., for engagement with the connector receptacle of an adjacent power storage module to fluidly seal therebetween), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 10, Gilbert teaches wherein a plurality of the power storage modules (battery cells 56B, see Fig. 5B; [0058]) are arranged laterally adjacent each other in an initial course (see Fig. 5B), and electrically connected between anodes and between cathodes (see [0058]). Regarding claim 11, Gilbert is silent to wherein another plurality of the power storage modules are arranged laterally adjacent each other in another course, wherein each of the power storage modules of the other course are engaged with a corresponding power storage module of the initial course such that the module connector of each of the power storage modules of one of the initial course and the other course is engaged with the connector receptacle of the corresponding power storage module of the other one of the initial course and the other course. However, absent persuasive arguments to the contrary, the addition of another plurality of the power storage modules is merely a duplication of parts, and the mere duplication of parts has no patentable significance unless a new and unexpected result is produced. See MPEP §2144.04(VI)(B). Furthermore, the particular arrangement of the initial course and the other course, absent persuasive arguments to the contrary, is merely an obvious smatter of design choice. See MPEP §2144.04(IV)(C). Regarding claim 14, Gilbert teaches a vehicle (vehicle 12, see Fig. 1; [0038]) comprising the modular vehicle power storage system of claim 1 (see rejection for claim 1). Regarding claim 15, Gilbert teaches a vehicle power storage module, comprising: a housing (can assembly 76B and inner wall 80B, see Fig. 6; [0060]) defining a power storage cavity therein (space 84B, see Fig. 6; [0060]) for receiving power storage materials (electrode assembly 78B inside each battery cell 56B, see Figs. 5B and 6; [0060]), the housing including a casing (can assembly 76B and inner wall 80B, see Fig. 6; [0060]) and a cap (Gilbert is silent to specifically teaching a cap, however, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to include a cap in the housing in order to insert the electrode assembly 78B into each battery cell 56B, see Figs. 5B and 6; [058]-[0060]), the casing including an inner wall (inner wall 80B, see Fig. 6; [0060]) and an outer wall (outer wall 86B, see Fig. 6; [0060]) spaced apart from each other (see Fig. 6) to define the power storage cavity therebetween (space 84B, see Fig. 6; [0060]), the cap formed for engagement with the casing between the inner and outer walls to enclose the power storage cavity with the power storage materials (Gilbert is silent to specifically teaching a cap for engagement with the casing between the inner and outer walls, however, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to include a cap for engagement with the casing between the inner and outer walls in order to insert and hold the electrode assembly 78B into each battery cell 56B, see Figs. 5B and 6; [058]-[0060]), wherein the casing defines a fluid passageway through the housing (void 60B for cooling device 56B, see Figs. 5B and 6; [0060]), the fluid passageway being separate from the power storage cavity (see Figs. 5B and 6; [0060]) and formed to pass fluid coolant in thermal communication to receive heat from the housing (see [0057]-[0060]). Regarding the functional language (e.g., for receiving power storage materials, for engagement with the casing between the inner and outer walls to enclose the power storage cavity with the power storage materials, formed to pass fluid coolant in thermal communication to receive heat from the housing), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 16, Gilbert teaches wherein a module connector (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) extends from the housing (see Fig. 5B; [0058]-[0060]) for engagement with an adjacent power storage module (see Fig. 5B). Regarding the functional language (e.g., for engagement with an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 17, Gilbert teaches wherein the modular connector (protrusion on right side of each battery cell 56B, see Fig. 5B; [0058]-[0060]) defines an extended portion of the fluid passageway (see Fig. 5B) to pass fluid coolant with the adjacent power storage module. Regarding the functional language (e.g., to pass fluid coolant with the adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 18, Gilbert teaches wherein the housing defines a connector receptacle (recess on left side of the middle and rightmost battery cell 56B, but it would have been obvious to also include the recess on the leftmost battery in order to be able to further add modules, see Fig. 5B, see Fig. 5B; [0058]-[0060]) for receiving connection of the module connector of an adjacent power storage module. Regarding the functional language (e.g., for receiving connection of the module connector of an adjacent power storage module), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 19, Gilbert is silent to wherein the casing is uniformly formed as a canister having the outer wall and the inner wall defined from the same sheet of material, and the inner wall integrally defining the fluid passageway, the connector receptacle, and the module connector. However, absent persuasive evidence to the contrary, the use of a one piece construction instead of the multi-piece structure disclosed in Gilbert would be merely a matter of obvious engineering choice. See MPEP §2144.04(V)(B). Regarding claim 20, Gilbert is silent to wherein the cap is annularly shaped around at least a portion of the fluid passage. However, absent persuasive evidence to the contrary, the particular shape of the cap would have been a matter of choice which a person of ordinary skill in the art at the time the invention was filed would have found obvious. See MPEP §2144.04(IV)(B). Claim(s) 11 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jost (EP 3499603 A1; using the attached English machine translation). Regarding claim 11, Jost is silent to wherein another plurality of the power storage modules are arranged laterally adjacent each other in another course, wherein each of the power storage modules of the other course are engaged with a corresponding power storage module of the initial course such that the module connector of each of the power storage modules of one of the initial course and the other course is engaged with the connector receptacle of the corresponding power storage module of the other one of the initial course and the other course. However, absent persuasive arguments to the contrary, the addition of another plurality of the power storage modules is merely a duplication of parts, and the mere duplication of parts has no patentable significance unless a new and unexpected result is produced. See MPEP §2144.04(VI)(B). Furthermore, the particular arrangement of the initial course and the other course, absent persuasive arguments to the contrary, is merely an obvious smatter of design choice. See MPEP §2144.04(IV)(C). Claim(s) 12 and 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Jost as applied to claim 11 above, and further in view of Brinkmann et al. (US 4,007,315; hereinafter “Brinkmann”). Regarding claim 12, Jost is silent to wherein the corresponding power storage modules of the initial and other courses collectively define fluid coolant channels by communication of their fluid passageways, and the system further comprises a manifold for communication with the coolant channels to pass fluid coolant. Brinkmann teaches power storage modules (cells 2, see Fig. 5; 3:42-55) of initial and other courses (see Fig. 5) collectively defining fluid coolant channels by communication of their fluid passageways (cell cooling coils 3 connected in series with inlets and outlets 4, see Fig. 5; 3:42-55), and the system further comprises a manifold (manifolds 5, see Fig. 5; 3:42-55) for communication with the coolant channels to pass fluid coolant (see Fig. 5; 3:42-55). A circulating pump 7 causes a sufficient quantity of cooling liquid to flow continuously through the entire closed cooling system. The cooler or heat exchanger 6 can be forced-air cooled in conventional manner by a blower 8 (see Fig. 5; 3:42-55). In view of Brinkmann’s teachings, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify the system of Jost to include wherein the corresponding power storage modules of the initial and other courses collectively define fluid coolant channels by communication of their fluid passageways, and the system further comprises a manifold for communication with the coolant channels to pass fluid coolant, as taught by Brinkmann, because it is a known configuration for a closed cooling system. Regarding the functional language (e.g., for communication with the coolant channels to pass fluid coolant), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 13, the combination of Jost and Brinkmann teaches a cooling heat exchanger (Brinkmann: cooler or heat exchanger 6, see Fig. 5; 3:42-55) in communication with the manifold (Brinkmann: manifolds 5, see Fig. 5; 3:42-55) to receive warm fluid coolant for cooling and returning to the courses of power storage modules (Brinkmann: see Fig. 5; 3:42-55). Regarding the functional language (e.g., to receive warm fluid coolant for cooling and returning to the courses of power storage modules), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Claim(s) 12 and 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Gilbert as applied to claim 11 above, and further in view of Brinkmann et al. (US 4,007,315; hereinafter “Brinkmann”). Regarding claim 12, Gilbert is silent to wherein the corresponding power storage modules of the initial and other courses collectively define fluid coolant channels by communication of their fluid passageways, and the system further comprises a manifold for communication with the coolant channels to pass fluid coolant. Brinkmann teaches power storage modules (cells 2, see Fig. 5; 3:42-55) of initial and other courses (see Fig. 5) collectively defining fluid coolant channels by communication of their fluid passageways (cell cooling coils 3 connected in series with inlets and outlets 4, see Fig. 5; 3:42-55), and the system further comprises a manifold (manifolds 5, see Fig. 5; 3:42-55) for communication with the coolant channels to pass fluid coolant (see Fig. 5; 3:42-55). A circulating pump 7 causes a sufficient quantity of cooling liquid to flow continuously through the entire closed cooling system. The cooler or heat exchanger 6 can be forced-air cooled in conventional manner by a blower 8 (see Fig. 5; 3:42-55). In view of Brinkmann’s teachings, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to modify the system of Gilbert to include wherein the corresponding power storage modules of the initial and other courses collectively define fluid coolant channels by communication of their fluid passageways, and the system further comprises a manifold for communication with the coolant channels to pass fluid coolant, as taught by Brinkmann, because it is a known configuration for a closed cooling system. Regarding the functional language (e.g., for communication with the coolant channels to pass fluid coolant), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Regarding claim 13, the combination of Gilbert and Brinkmann teaches a cooling heat exchanger (Brinkmann: cooler or heat exchanger 6, see Fig. 5; 3:42-55) in communication with the manifold (Brinkmann: manifolds 5, see Fig. 5; 3:42-55) to receive warm fluid coolant for cooling and returning to the courses of power storage modules (Brinkmann: see Fig. 5; 3:42-55). Regarding the functional language (e.g., to receive warm fluid coolant for cooling and returning to the courses of power storage modules), the Examiner has considered it. However, the Applicant is reminded that apparatus claims are not limited by the function they perform, as per MPEP §2114. While features of an apparatus may be recited either structurally or functionally, claims directed to an apparatus must be distinguished from the prior art in terms of structure rather than function. As the apparatus of the prior art and the claimed apparatus are patentably indistinguishable in terms of structure, the apparatus of the prior art is reasonably expected to be able to perform the claimed functionalities. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to STEVEN HA whose telephone number is (571)270-5934. The examiner can normally be reached M-F 8:00-5:00 EST. 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, Keith Walker can be reached at 571-272-3458 . 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. /S.S.H/Examiner, Art Unit 1735 10 January 2026 /KEITH WALKER/Supervisory Patent Examiner, Art Unit 1735
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Prosecution Timeline

Jun 14, 2023
Application Filed
Jan 10, 2026
Non-Final Rejection — §102, §103 (current)

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Expected OA Rounds
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99%
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2y 3m
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