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 . If status of the application as subject to 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 a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
Status of Claims
Claims 1-14 & 16-21 are pending in the application and are presently examined. Claims 1-21 were rejected in the 3/12/2026 office action. Applicant cancelled claim 15.
Response to Amendment / Arguments
The 6/11/2026 amendment, in response to the 3/12/2026 office action, has been entered.
Applicant’s claim 14 amendment failed to overcome the 35 U.S.C. 112(b) rejection because Applicant addressed only one of the two antecedent basis issues.
Applicant’s claim amendments and arguments, regarding the 35 U.S.C. 102 and 35 U.S.C. 103 rejections, have been fully considered and they are partially persuasive. Claim 13 previously stated: “said holding portion is in the shape of a long groove or a long hole”. Claim 13 was rejected under 35 U.S.C. 102, because US20140322568A1 (Sakai) teaches a long hole. This claim limitation was added to claim 1, but without “a long hole”. Claim 1 is now rejected under 35 U.S.C. 103 instead of 35 U.S.C. 102 because amended claim 1 now states “the holding portion is formed in a shape of a long groove” (without “or a long hole”). Thus, the 35 U.S.C. 102 rejection is withdrawn, due to this claim 1 amendment, but all claims remain rejected under 35 U.S.C. 103.
Claim 1 states:
the holding portion is… arranged at a central position of the base plate in the width direction of the battery pack
Applicant argues that Sakai’s holding portion is not arranged at the central position in the width direction. Examiner disagrees.
Claim 1 fails to define “the width direction”. Examiner interprets “the width direction” to be the same direction as the second direction, which is illustrated in Figure A below.
The “central position” is not defined in the claim, except that it is central in “the width direction”. A definition of “central” is “situated at, in, or near the center”1. Sakai’s holding portion is not at the edge of the battery tray 38 in the width direction, and is “near the center” in the width direction, so it is located at a “central position”.
Applicant argues:
“Lim fails to teach or suggest a battery module comprising a plurality of first battery modules and a plurality of second battery modules, the plurality of first battery modules are arranged in a first direction along an upper surface of said base plate, and the plurality of second battery modules are arranged in the first direction, both the first battery modules and the second battery modules are spaced with a gap along the upper surface of the base plate in a second direction, and the second direction intersects with the first direction, and the holding portion formed in a shape of a long groove arranged at a central position of the base plate in the width direction of the battery pack at a position overlapping the gap in an up and down direction of the battery pack.”
Secondary reference Lim was not presented for teaching these components. It is irrelevant whether or not Lim teaches these components, because they are taught by other prior art. It is unclear what Applicant’s purpose is in presenting this argument.
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.
Claims 1-14 & 16-21 are rejected under 35 U.S.C. 112(b) as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor(s) regard as the invention.
Claim 1 states “the width direction”. There is insufficient antecedent basis for this limitation in this claim.
Claims 2-14 & 16-21 are rejected due to their dependence on claim 1.
Claim 14 states “the extension direction”. There is insufficient antecedent basis for this limitation in this claim.
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:
Determining the scope and contents of the prior art.
Ascertaining the differences between the prior art and the claims at issue.
Resolving the level of ordinary skill in the pertinent art.
Considering objective evidence present in the application indicating obviousness or nonobviousness.
The claims are in bold font, the prior art is in parentheses.
Claims 1-2, 5-6, 12-13, 16, & 21 are rejected under 35 U.S.C. 103 as being unpatentable over US20140322568A1 (Sakai).
Sakai teaches the following claim 1 limitations:
A battery pack (paragraph 42; figure 2: battery pack 31), comprising:
a housing comprising a base plate (paragraph 42; figures 2-3: battery tray 38), said base plate (38) being provided with a holding portion (Figure A below);
a battery module (paragraph 42; figures 2-3: battery modules 42) arranged above said base plate (38); and
an electrical connection component (paragraph 53; figures 2-3: high voltage connector 71), which is electrically connected to said battery module (42) and is housed in said holding portion (Figure A below)
wherein the battery module comprises a plurality of first battery modules and a plurality of second battery modules (Figure A below),
the plurality of first battery modules are arranged in a first direction along an upper surface of said base plate, and the plurality of second battery modules are arranged in the first direction, both the first battery modules and the second battery modules are spaced with a gap along the upper surface of the base plate in a second direction, and the second direction intersects with the first direction (Figure A below)
Figure A: Annotated Sakai Figure 2
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Claim 1 also states:
the holding portion is formed in a shape of a long groove
The word “groove” is defined as “a long, narrow, hollow space cut into a surface2”, which could be interpreted as a hole, such as is illustrated in Figure A above. If Sakai’s hole cannot be interpreted as a groove, then it would still have been obvious to replace Sakai’s hole with a groove. The purpose of Sakai’s hole is to pass an electrical connection through the battery tray 38. This can be accomplished with either a hole or an open groove. A hole provides a more secure structure, but a groove allows easier insertion.
Claim 1 also states:
the holding portion is… arranged at a central position of the base plate in the width direction of the battery pack
Claim 1 fails to define “the width direction”. Examiner interprets “the width direction” to be the same direction as the second direction. The “central position” is not defined in the claim. A definition of “central” is “situated at, in, or near the center”3. Sakai’s holding portion is not at the edge of the battery tray 38 in the width direction, and is “near the center” in the width direction, so it is located at a “central position”.
Claim 1 also states:
the holding portion… is configured at a position overlapping the gap in an up and down direction of the battery pack
The up and down direction is illustrated in Figure A above. Sakai’s holding portion overlaps the gap in this up and down direction.
With regard to claim 2, Sakai teaches the limitations of claim 1 as discussed above. Sakai also teaches the following claim 2 limitation:
some or all of said electrical connection component is located below the horizontal plane where the lowest point of said battery module is located (Figure A above)
With regard to claim 5, Sakai teaches the limitations of claim 1 as discussed above. Sakai also teaches the following claim 5 limitation:
said electrical connection component comprises a high-voltage connection component (paragraph 53; figures 2-3: high voltage connector 71)
With regard to claim 6, Sakai teaches the limitations of claim 1 as discussed above. Sakai also teaches the following claim 6 limitation:
said high-voltage connection component (71) comprises a high-voltage harness (Figure B below), and
said high-voltage harness is flat in a cross section (figures 2-3), and is accommodated in said holding portion such that its thickness direction is roughly consistent with the thickness direction of said base plate (figure 2)
Figure B: Annotated Sakai Partial Figure 3
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Claim 7 states:
said high-voltage connection component is in a long shape, extending from one end of said base plate to the other end
Sakai teaches the high-voltage connection component (paragraph 53; figures 2-3: high voltage connector 71). Sakai, however, fails to teach that it extends from one end of the base plate to the other end. MPEP 2144.04(IV)(A) provides guidance for this issue:
“In Gardner v. TEC Syst., Inc., 725 F.2d 1338, 220 USPQ 777 (Fed. Cir. 1984), cert. denied, 469 U.S. 830, 225 USPQ 232 (1984), the Federal Circuit held that, where the only difference between the prior art and the claims was a recitation of relative dimensions of the claimed device and a device having the claimed relative dimensions would not perform differently than the prior art device, the claimed device was not patentably distinct from the prior art device.
Here, there is no reason that extending the length of Sakai’s high voltage connector 71 would result in different performance; therefore, claim 7 is obvious over Sakai’s high voltage connector 71.
With regard to claim 8, Sakai teaches the limitations of claims 1 & 5 as discussed above. Claim 8 states:
said high-voltage connection component comprises a high-voltage harness and a high-voltage harness bracket,
said base plate is provided with an opening,
said high-voltage harness bracket covers said opening, forming the top of said holding portion, and
said high-voltage harness is arranged below said high-voltage harness bracket
Sakai teaches the high-voltage connection component (paragraph 53; figures 2-3: high voltage connector 71) and the opening (Figure C above: holding portion encircles the electrical connection where it exits the base plate). Sakai, however, fails to teach the other details of the high-voltage connection component and the opening required by claim 8. These details, however, are provided by a common EMT Pull Elbow4 (Figure G below), which have been used for at least 15 years5.
Figure G: EMT Pull Elbow
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The EMT Pull Elbow, connected to the opening, fulfills remaining claim 8 limitations. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Sakai’s high voltage connector 71 to include an EMT Pull Elbow for protecting an angle of the wires, and to allow pulling the wires through the angle.
With regard to claim 9, Sakai teaches the limitations of claims 1, 5, & 8 as discussed above. Claim 9 states:
the lowest point of said high-voltage harness bracket is located on a horizontal plane that is roughly the same as or lower than the upper surface of said base plate
Sakai’s base plate upper surface would be above Sakai’s opening. Use of the EMT Pull Elbow in Sakai’s opening, as discussed in claim 8, would result in the high-voltage harness bracket located roughly the same as or lower than the upper surface, especially if the elbow is rotated for wire direction parallel to the upper surface.
With regard to claim 10, Sakai teaches the limitations of claims 1, 5, & 8 as discussed above. Claim 10 states:
the high-voltage harness comprises a cladding layer and a conductive component arranged within said cladding layer, and said cladding layer is fixed on said high-voltage harness bracket
Steel conduit components, such as for example the EMT Pull Elbow described in claim 8, are commonly galvanized (i.e. zinc coating on steel exterior). Galvanized steel has been used for over 200 years6 for corrosion protection. The zinc coating is equivalent to the claimed cladding layer, and the conductive component within the cladding layer is steel. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, the EMT Pull Elbow discussed in claim 8 to be galvanized steel for corrosion protection.
With regard to claim 11, Sakai teaches the limitations of claims 1, 5, & 8 as discussed above.
Sakai also teaches the following claim 11 limitation:
the battery pack further comprises a low-voltage connection component electrically connected with said battery module (paragraphs 55; figures 2-3: low voltage connector 75)
Claim 11 also states:
said low-voltage connection component is arranged above said high-voltage harness bracket
“Above” requires a reference direction. Sakai’s low voltage connector 75 is above the high voltage connector 71, depending on rotation of the Sakai’s battery pack 31. MPEP 2144.04(VI)(C) provides additional guidance:
“In re Japikse, 181 F.2d 1019, 86 USPQ 70 (CCPA 1950) (Claims to a hydraulic power press which read on the prior art except with regard to the position of the starting switch were held unpatentable because shifting the position of the starting switch would not have modified the operation of the device.); In re Kuhle, 526 F.2d 553, 188 USPQ 7 (CCPA 1975) (the particular placement of a contact in a conductivity measuring device was held to be an obvious matter of design choice).”
Absent a showing of unexpected results, placement of the claimed low-voltage connection component in relation to the high-voltage harness bracket is considered to be obvious.
With regard to claims 12-13 & 16, Sakai teaches the limitations of claim 1 as discussed above. Sakai also teaches the following limitations of claims 12-13 & 16:
Claim 12
a reinforcing component is provided above said base plate (Figure C below: reinforcing component is along the outer edge, and is bolted to the base plate)
Claim 13
said reinforcing component extends across said holding portion (Figure C below)
Claim 16
said holding portion comprises a cavity arranged within said base plate, or an opening (Figure C below: holding portion encircles the electrical connection where it exits the base plate) formed on the upper or lower surface of said base plate
Figure C: Annotated Sakai Figure 2
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With regard to claim 21, Sakai teaches the limitations of claim 1 as discussed above. Sakai also teaches the following claim 21 limitation:
A vehicle comprising a battery pack according to claim 1 (abstract, figure 1)
Claims 3-4, 14, & 17-20 are rejected under 35 U.S.C. 103 as being unpatentable over US20140322568A1 (Sakai) in view of US20200127258A1 (Lim), together “modified Sakai”.
With regard to claim 3, Sakai fails to teach the following claim 3 limitation, which is taught by Lim:
a coolant channel (paragraph 230; figure 12: cooling channel 300) is provided in said base plate (Figure E below)
Figure E: Annotated Lim Figure 12
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Lim teaches a cooling channel 300 below battery cells 100 for efficient cooling (paragraph 233). It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Sakai’s battery tray 38 to include a cooling channel, as taught by Lim, for efficient battery cooling.
With regard to claim 4, Sakai and Lim teach the following claim 4 limitations:
in said base plate, viewed in the up and down directions, said coolant channel is configured at a position overlapped with said battery module (Figure E above), and
said holding portion is configured at a position staggered from said battery module (Figure A above)
With regard to claim 14, Sakai fails to teach the following claim 14 limitations, which are taught by Lim:
a first part of said coolant channel that is farther from the centerline of said base plate is located upstream along the liquid flow, while a second part of said coolant channel that is closer to the centerline of said base plate is located downstream along the liquid flow, wherein, the centerline extends in the extension direction of said base plate
In simpler language, this claims that coolant flows towards base plate centerline. As illustrated in figures 12-13, fluid flows through the cooling channels 300 from one side of the battery module to an opposite side. Thus, Lim’s fluid flows to the centerline, across the centerline, then away from the centerline.
With regard to claims 17-20, Sakai fails to teach the following limitations of claims 17-20, which are taught by Sakai combined with Lim:
Claim 17
said base plate comprises a first plate and a second plate (Figure F below),
said first plate is located above said second plate and arranged opposite to and separated from said second plate (Figure F below), and
said opening is arranged on said first plate or said second plate (Applying Lim to Sakai would result in the opening of Sakai in the holding portion, which extends from the first plate. The opening is thus on the first plate of Lim. See Figure F below.)
Claim 18
said holding portion further comprises a partitioning wall extending from the edge of said opening and extending from one of said first plate and said second plate to the other (Figure F below)
Claim 19
said partitioning wall comprises a first partition wall and a second partition wall (The partitioning wall is elongated, extending into sheet of Figure F below, as illustrated in Lim figure 13. Part of this extension is the first partition wall, part is the second partition wall, and a middle part is the bottom wall.), and
said first partitioning wall and said second partition wall are arranged at the edges of both sides of said opening (Applying Lim to Sakai, Lim’s first partitioning wall is defined on one edge of Sakai’s opening and Lim’s second partitioning wall is defined on an opposite edge of Sakai’s opening), and
said holding portion also has a bottom wall, which is connected between said first partitioning wall and said second partitioning wall (The bottom wall is elongated, extending into sheet of Figure F below. This connects the first partition wall to the second partition wall.)
Claim 20
said bottom wall contacts or is separated from the other of said first plate and said second plate (Figure F below: The bottom wall boundaries can be defined to contact both the first plate and the second plate.)
Figure F: Annotated Lim Figure 12
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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 extension fee 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 date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROBERT WEST whose telephone number is 703-756-1363 and email address is Robert.West@uspto.gov. The examiner can normally be reached Monday-Friday 10 am - 7 pm ET.
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, Allison Bourke can be reached at 303-297-4684.
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/R.G.W./Examiner, Art Unit 1721
/ALLISON BOURKE/Supervisory Patent Examiner, Art Unit 1721
1 https://www.merriam-webster.com/dictionary/central
2 https://dictionary.cambridge.org/dictionary/english/groove
3 https://www.merriam-webster.com/dictionary/central
4 https://www.homedepot.ca/product/iberville-zinc-alloy-1-2-in-emt-pull-elbow/1000138556
5 https://www.youtube.com/watch?v=L8qgR0lNK4o
6 https://steeltubeinstitute.org/resources/steel-conduit-tech-talk-corrosion-protection/
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