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 Group I, claims 1-13 in the reply filed on 6/11/26 is acknowledged.
Claim Rejections - 35 USC § 102
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) 1-3 and 5-13 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Guo et al. (WO 2013/106821 A1, hereinafter Guo, cited by applicant) and evidenced by ASM Material Data Sheet – Titanium Grade 2 (https://asm.matweb.com/search/specificmaterial.asp?bassnum=mtu020, hereinafter ASM, cited by applicant).
Re Claim 1. Guo teaches a casing (Fig. 2 & 3) for an electrochemical coin cell (intended use), the casing comprising:
a housing (item 20) having a flat wall (item 25) and a side wall (item 24) extending from one or more edges of the flat wall of the housing to form a housing can; and
a planar conductive portion (item 21) joined to the side wall of the housing to form an inner cavity configured to hold active components of the electrochemical coin cell (intended use), the planar conductive portion comprises greater than about 95 wt.% titanium (para. 69 & 70), wherein, in an instance (optional limitation) in which a bend is formed in the planar conductive portion, the bend having a bend radius between about 100% and about 500% of a thickness of the planar conductive portion, the planar conductive portion is free or substantially free of cracking and microcracking.
If the body of a claim fully and intrinsically sets forth all of the limitations of the claimed invention, and the preamble merely states, for example, the purpose or intended use of the invention, rather than any distinct definition of any of the claimed invention’s limitations, then the preamble is not considered a limitation and is of no significance to claim construction. See MPEP 2111. 02.
"[W]hen, as by a recitation of ranges or otherwise, a claim covers several compositions, the claim is ‘anticipated’ if one of them is in the prior art." Titanium Metals Corp. v. Banner, 778 F.2d 775, 227 USPQ 773 (Fed. Cir. 1985). See MPEP 2131.03.
Re Claim 2. Guo teaches wherein the housing or the planar conductive portion comprises greater than about 99 wt.% titanium (para. 69 & 70, see ASM).
Re Claim 3. Guo teaches wherein the housing or the planar conductive portion comprises less than about 0.5 wt.% iron, less than about 0.5 wt.% oxygen, less than about 0.5 wt.% carbon, less than about 0.5 wt.% nitrogen, and less than about 0.5 wt.% hydrogen (para. 69 & 70, see ASM).
Re Claim 5. Guo teaches wherein the housing or the planar conductive portion has an ultimate tensile strength of between about 49,900 psi (para. 69 & 70, see ASM).
Re Claim 6. Guo teaches wherein the housing or the planar conductive portion has a breaking elongation of 20% (para. 69 & 70, see ASM).
Re Claim 7. Guo teaches wherein the housing or the planar conductive portion is a positive can that has an elongation of 20% at room temperature (para. 69 & 70, see ASM).
Re Claim 8. Guo teaches wherein the housing or the planar conductive portion has an electrical resistivity of 50 µΩ∙cm (para. 69 & 70, see ASM).
Re Claim 9. Guo teaches wherein an exterior circumferential portion of the planar conductive portion is bent about 90 degrees out of plane with a remainder of the planar conductive portion when being joined with the side wall of the housing (Fig. 2 & 3).
Re Claim 10. Guo teaches wherein one or more of the housing or the planar conductive portion comprises a surface portion comprising one or more of: TiN (para. 85).
Re Claim 11. Guo teaches wherein one or more of the housing or the planar conductive portion comprises a surface coating comprising nickel (para. 87) such that the electrical resistivity is reduced to less than about 50 µΩ∙cm.
Re Claim 12. Guo teaches wherein the housing or the planar conductive portion comprises a material (titanium, grade 2 titanium, para 69 & 70) that is resistant to reactions that cause hydroxide formation.
Re Claim 13. Guo teaches wherein the housing or the planar conductive portion further comprises one or more of: less than or equal to about 0.3 wt.% iron about less than or equal to 0.03 wt.% nitrogen, and less than or equal to about 0.015 wt.% hydrogen (para 69 & 70, see ASM).
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) 4 is/are rejected under 35 U.S.C. 103 as being unpatentable over Guo and evidenced by ASM.
Guo teaches wherein the housing or the planar conductive portion comprises about 0.3 wt.% iron, about 0.25 wt.% oxygen, less than or equal to about 0.1 wt.% carbon, about 0.03 wt.% nitrogen, and about 0.015 wt.% hydrogen (para 69 & 70, see ASM).
In the case where the claimed ranges “overlap or lie inside ranges disclosed by the prior art” a prima facie case of obviousness exists. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). "[A] prior art reference that discloses a range encompassing a somewhat narrower claimed range is sufficient to establish a prima facie case of obviousness." In re Peterson, 315 F.3d 1325, 1330, 65 USPQ2d 1379, 1382-83 (Fed. Cir. 2003). See MPEP § 2144.05, I.
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. See PTO-892.
The rejections above rely on the references for all the teachings expressed in the text of the references and/or one of ordinary skill in the art would have reasonably understood from the texts. Only specific portions of the texts have been pointed out to emphasize certain aspects of the prior art, however, each reference as a whole should be reviewed in responding to the rejection, since other sections of the same reference and/or various combinations of the cited references may be relied on in future rejections in view of amendments.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to KEVIN E YOON whose telephone number is (571)270-5932. The examiner can normally be reached Monday-Friday 9 AM- 5 PM.
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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.
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/KEVIN E YOON/Primary Examiner, Art Unit 1735
6/16/2026
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