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 .
Response to Amendment
In response to the amendment received on 05/22/2026:
Claims 1 and 3-12 are pending in the current application. Claims 1 and 3-10 have been amended.
Response to Arguments
Applicant’s arguments, see Remarks Page 6, filed 05/22/2026, with respect to the objection to the drawings have been fully considered. The objections have been withdrawn in light of the replacement drawings.
Applicant’s arguments, see Remarks Page 6, filed 05/22/2026, with respect to the objection to claim 10 have been fully considered. The objection has been withdrawn in light of the amendments to claim 10.
Applicant’s arguments, see Remarks Page 7, filed 05/22/2026, with respect to the rejections under 35 U.S.C. 112(b) have been fully considered. The rejections have been withdrawn in light of the amendments to claims 7-8.
Applicant's arguments filed 05/22/2026 with regards to prior art Tanaka have been fully considered but they are not persuasive.
Applicant alleges Tanaka fails to disclose, expressly or inherently, that a minimum distance between an edge of the weak region of each of the two cleave valves and the welding seam is greater than or equal to 3 mm (Remarks Page 7).
The Office respectfully disagrees.
In Table 1 after P41 of Tanaka, Example 7 shows a battery having two safety valves (cleavage valves) wherein the safety valve diameter is 33 mm. The figure showing the embodiment of Tanaka’s battery having two safety valves is Fig. 3.
As seen in the annotated Fig. 3 provided by Examiner below, the cleavage valve has four quadrants. In one cleavage valve, quadrant 1 has two edges made of the cleavage grooves that meet to form a corner. This corner sits at the middle point of the cleavage valve.
Given in Example 7 the diameter of the safety valves (cleavage valves) is 33 mm, the radius of the safety valves would be 16.5 mm. Given the corner of quadrant 1 sits at the middle point of the cleavage valve, the edges and corner are at least 16.5 mm from the edge of the lid plate that would be welded. The same analysis can be done for the edge of quadrant 2 seen in annotated Fig. 3 below, and this minimum distance of at least 16.5 mm lies within the range of greater than or equal to 3 mm.
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Annotated Tanaka Fig. 3
Therefore, prior art Tanaka has been used below to meet the amended claims.
Applicant's arguments filed 05/22/2026 with regards to the rejections under 35 U.S.C 103 over Uruno in view of Kinuta have been fully considered and are persuasive. The rejections utilizing Uruno in view of Kinuta have been withdrawn.
After further search and consideration, a new rejection of Uruno et al (US 20210013483 A1 as given in the 05/19/2025 IDS) in view of Tyler et al (US 20160093854 A1) in view of Kinuta (US 6180279 B1) has been set forth below.
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 1, thus 3-12, claim 6, and claim 8 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention.
Regarding claim 1, claim 1 recites the limitation "the weak region of each of the plurality of pressure relief structures" in lines 10-11. There is insufficient antecedent basis for this limitation in the claim.
Claim 1 sets forth a pressure relief structure disposed on the cover plate wherein this “pressure relief structure” includes a weak region.
Claim 1 later sets forth a plurality of pressure relief structures comprised in the battery cell. These plurality of pressure relief structures are only required to be comprised in the battery cell and are not required to be a plurality of previously set forth pressure relief structure disposed on the cover plate. These plurality of pressure relief structures could be on another side of the battery cell, such as on the bottom of the battery cell rather than the cover plate.
Therefore, since these plurality of pressure relief structures are not required by the claim to be a plurality of the previously disclosed pressure relief structure and could instead be other, differently configured pressure relief structures, they do not necessarily have “the weak region” as required by the previously disclosed pressure relief structure.
In order to advance prosecution, the Examiner is interpreting the claims as if it states “a plurality of pressure relief structures are disposed on the cover plate, each of the pressure relief structures being provided with a weak region that is configured to be broken and release internal pressure when the internal pressure or temperature of the battery cell reaches a threshold, wherein a minimum distance between an edge of the weak region of each of the plurality of pressure relief structures and the welding seam is greater than or equal to 3 mm”.
Given claims 3-12 depend from claim 1, they are rejected for the same reasons.
Regarding claim 6, claim 6 depends from claim 2 which has been canceled, therefore, claim 6 is rendered indefinite.
Claims 7-8 depend from claim 6, therefore they are rejected for the same reason.
Claim 6 is being interpreted as if it were dependent upon claim 1.
Regarding claim 8, claim 8 recites the limitations “the plurality of pressure relief apparatuses” and "the same side" in lines 4-5. There is insufficient antecedent basis for this limitation in the claim.
In previous claims a “plurality of pressure relief apparatuses” is not set forth, therefore, the claim is rendered unclear.
Also, it is unclear which side of the liquid injection port is “the same side”.
In order to advance prosecution, the Examiner is interpreting claim 8 to recite “the plurality of pressure relief structures are disposed on a same side of the liquid injection port”.
Claim Objections
Claim 6 is objected to because of the following informalities:
Claim 6 states “a line connecting a center of the positive electrode terminal and a center the negative electrode terminal intersects each of weak regions of the plurality of pressure relief structures” when it should state “a line connecting a center of the positive electrode terminal and a center of the negative electrode terminal intersects each
The Examiner notes claim 6’s suggest changed claim language comes in light of the Examiner’s interpretation of claim 1 above.
Appropriate correction is required.
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.
Claims 1, 4, 6-7, 10-12 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Tanaka et al (US 20130316201 A1, equivalent to EP2677565A1 given in the 05/19/2025 IDS).
Regarding claim 1, Tanaka discloses a battery cell (lithium-ion secondary battery; see entire disclosure and especially P29-30), comprising: a case with an opening (battery case body 2 in Fig. 1; see entire disclosure and especially P30);
a cover plate covering the opening, the cover plate being welded with the case to form a welding seam (lid plate 3 in Fig. 1; see entire disclosure and especially P30, 43); and
a plurality of pressure relief structures are disposed on the cover plate (two cleavage valves 10’ in Fig. 3 which forms the safety valve; see entire disclosure and especially P35, 37, 39-40),
each of the pressure relief structures being provided with a weak region (cleavage grooves 13’ in Fig. 3), that is configured to be broken and release internal pressure when the internal pressure or temperature of the battery cell reaches a threshold (see entire disclosure and especially P37, 39-40),
wherein a minimum distance between an edge of the weak region of each of the plurality of pressure relief structures and the welding seam is greater than or equal to 3 mm (in Table 1 after P41, Example 7 shows a battery having two safety valves (cleavage valves) wherein the safety valve diameter is 33 mm; as seen in annotated Fig. 3 below, the cleavage valve has four quadrants; in one cleavage valve, quadrant 1 has two edges made of the cleavage grooves that meet to form a corner; this corner sits at the middle point of the cleavage valve; given in Example 7 the diameter of the safety valves (cleavage valves) is 33 mm, the radius of the safety valves would be 16.5 mm; given the corner of quadrant 1 sits at the middle point of the cleavage valve, the edges and corner are at least 16.5 mm from the edge of the lid plate that would be welded; the same analysis can be done for the edge of quadrant 2 seen in annotated Fig. 3 below; this minimum distance of at least 16.5 mm lies within the range of greater than or equal to 3 mm).
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Annotated Tanaka Fig. 3
Regarding claim 4, Tanaka discloses wherein the minimum distance between the edge of the weak region of each of the pressure relief structures and the welding seam is the same (see the rejection of claim 1 above; the edge of the weak region of each of the pressure relief structures (the edge of Q1 and the edge of Q2) are both at minimum 16.5 mm).
Regarding claim 10, Tanaka discloses wherein an area size of the weak region of each of the pressure relief structures has a predetermined value (each cleavage valve 10’ has its own area, therefore, each weak region would have its own area), area sizes of weak regions of at least some of the pressure relief structures have a first predetermined value, and area sizes of weak regions of at least some of the pressure relief structures have a second predetermined value (the weak region of the cleavage valve 10’ near negative electrode terminal portion 8’ has a first predetermined value; the weak region of the cleavage valve 10’ near positive electrode terminal portion 6’ has a second predetermined valve; the claim does not state both of these predetermined valves are different; in Tanaka, both areas of each cleavage valve 10’ are the same, therefore, the area of the weak regions and the predetermined values would also be the same (as set forth in P40 and Example 7 in Table 1 at the end of P41)).
Regarding claims 11-12, Tanaka discloses an electrical apparatus, wherein the electrical apparatus comprises a battery comprising the battery cell of claim 1, and wherein the battery is used to provide electric energy (“As has been described above, the present invention is applicable to stacked secondary batteries with large capacities, and particularly suitably applicable to those with battery capacities of 100 Ah or more. The usage of the batteries is not limited, and the batteries according to the present invention are suitable for applications that need a battery with a large capacity, including not only mobile objects such as hybrid electric vehicles (HEVs), electric vehicles (EVs), forklifts, and excavators but also industrial applications such as uninterruptible power supplies (UPS's) and storage of electric power generated by solar power generation”, P47).
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.
Claims 1, 3-8, and 10 are rejected under 35 U.S.C. 103 as being unpatentable over Uruno et al (US 20210013483 A1 as given in the 05/19/2025 IDS) in view of Tyler et al (US 20160093854 A1) in view of Kinuta (US 6180279 B1).
Regarding claim 1, Uruno discloses a battery cell (battery 1B in Figs. 8-9; see entire disclosure and especially P57), comprising: a case with an opening (case 21 with chamber 20r in Fig. 1; see entire disclosure and especially P31);
a cover plate covering the opening, the cover plate being welded with the case to form a welding seam (sealing lid 22 in Figs. 8-9; see entire disclosure and especially P57; case can be combined to the sealing lid by welding, P32); and
a plurality of pressure relief structures are disposed on the cover plate (pressure release valve 5 and one of the liquid inlets 6 that can release gas after aging in Figs. 8-9; see entire disclosure and especially P57-59),
each of the pressure relief structures being provided with a weak region (groove 5b/fragile part 5c and groove 6b/fragile part 6c in Figs. 8-9), that is configured to be broken and release internal pressure when the internal pressure or temperature of the battery cell reaches a threshold (see entire disclosure and especially P44-45, 59).
However, Uruno does not disclose wherein a minimum distance between an edge of the weak region of each of the plurality of pressure relief structures and the welding seam is greater than or equal to 3 mm.
In a similar field of endeavor, Tyler teaches a lithium ion battery cell including a prismatic cell casing enclosing electrochemically active components (P8). Tyler teaches the cell thickness of the prismatic cell casing corresponds to a distance between the first and second faces of the prismatic cell casing (P8). Tyler teaches battery cells can have a cell thickness between 13 mm and 15 mm (P78).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to utilize the teaching of Tyler and modified the battery cell case of Uruno to have a thickness between 13 mm and 15 mm, given Tyler teaches this is a known thickness to utilize for a prismatic battery cell case, given the combination of familiar elements is likely to be obvious when it does no more than yield predictable results. See KSR, 550 U.S. at 416, 82 USPQ2d at 1395; Sakraida v. AG Pro, Inc., 425 U.S. 273, 282, 189 USPQ 449, 453 (1976); Anderson’s-Black Rock, Inc. v. Pavement Salvage Co., 396 U.S. 57, 62-63, 163 USPQ 673, 675 (1969); Great Atl. & P. Tea Co. v. Supermarket Equip. Corp., 340 U.S. 147, 152, 87 USPQ 303, 306 (1950). (see MPEP § 2143, A.).
Further, the Supreme Court decided that a claim can be proved obvious merely by showing that the combination of known elements was obvious to try. In this regard, the Supreme Court explained that, “[w]hen there is a design need or market pressure to solve a problem and there are a finite number of identified, predictable solutions, a person of ordinary skill in the art has a good reason to pursue the known options within his or her technical grasp.” An obviousness determination is not the result of a rigid formula disassociated from the consideration of the facts of the case. Indeed, the common sense of those skilled in the art demonstrates why some combinations would have been obvious where others would not. Therefore, choosing from a finite number of identified, predictable solutions, with a reasonable expectation for success, is likely to be obvious to a person if ordinary skill in the art. See KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398, 415-421, 82 USPQ2d 1385, 1395-97 (2007) (see MPEP § 2143, E.).
Also in a similar field of endeavor, Kinuta teaches a square battery explosion prevention safety device having a length of 9 mm along each side (C2 / L8-12; C3 / L14-18). Kinuta teaches the center of the square battery explosion prevention safety device includes, in the center, a safety valve annular groove with an outside diameter of 3.5 mm (C3 / L19-22). Kinuta teaches the safety valve annular groove is of a smaller thickness than the rest of the a square battery explosion prevention safety device (C3 / L18-26, 51-52). Kinuta teaches their square battery explosion prevention safety device operates with high reliability when pressure within a battery casing reaches a prescribed pressure (C2 / L8-12).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Kinuta and substituted the pressure relief structures (pressure release valve 5 and one of the liquid inlets 6 that can release gas after aging) of Uruno with the square battery explosion prevention safety device of Kinuta, given Kinuta teaches their square battery explosion prevention safety device operates with high reliability when pressure within a battery casing reaches a prescribed pressure.
Modified Uruno now meets the limitation wherein a minimum distance between an edge of the weak region of each of the plurality of pressure relief structures and the welding seam is greater than or equal to 3 mm (see the Annotated Interpretation of Modified Uruno below; the minimum distance between an edge of the weak region and the welding seam is 3.25 mm which lies within the range of greater than 3 mm).
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Annotated Interpretation of Modified Uruno
Regarding claim 3, modified Uruno has both pressure relief structures (pressure release valve 5 and one of the liquid inlets 6 that can release gas after aging in Figs. 8-9) the same size (as it is the square battery explosion prevention safety device of Kinuta).
However, Uruno discloses that the plurality of pressure relief structures can be of the same size (P42), or one the pressure relief structures can be smaller than the other (one of the liquid inlets 6 that can release gas after aging can be smaller than the pressure relief valve; see Figs. 8-9 and P42).
Therefore, it would have been obvious to change the form/shape of the pressure relief structures such that one of the pressure relief structures (one of the liquid inlets 6 that can release gas after aging) is smaller than the other pressure relief structure (pressure relief valve 5) because, one, Uruno says one can have a size smaller than the other, and, two, in order to, for example, shorten the time of manufacturing by shrinking the size of one of the pressure relief structures to be made because the change in form or shape, without any new or unexpected results, is an obvious engineering design. See In re Dailey, 149 USPQ 47 (CCPA 1976) (see MPEP § 2144.04).
Given one of the pressure relief structures is smaller than the other, the limitation “wherein at least two of the pressure relief structures have weak regions with different areas” is met by modified Uruno.
Regarding claim 4, modified Uruno has both pressure relief structures (pressure release valve 5 and one of the liquid inlets 6 that can release gas after aging in Figs. 8-9) the same size (as it is the square battery explosion prevention safety device of Kinuta). Further, Uruno discloses that the plurality of pressure relief structures can be of the same size (P42). Therefore, modified Uruno meets the limitation wherein the minimum distance between the edge of the weak region of each of the pressure relief structures and the welding seam is the same.
Regarding claim 5, modified Uruno includes two pressure relief structures that are each one of the square battery explosion prevention safety device of Kinuta. Given Kinuta teaches their safety valve annular groove (drawn to the claimed “weak region) has an outside diameter of 3.5 mm, and Kinuta teaches the square battery explosion prevention safety device has a length of 9 mm on each side, the maximum distance between the outer diameter of the safety valve annular groove and a side of the square battery explosion prevention safety device is 2.75 mm.
Therefore, the minimum distance between both weak regions the two pressure relief structures is at least 5.5 mm, which lies within the range of the minimum distance being greater than or equal to 3 mm, given each annular groove sits in its own square safety device.
Regarding claim 6, modified Uruno meets the limitation a positive electrode terminal (positive electrode terminal 23 in Figs. 8-9 of Uruno) and a negative electrode terminal (negative electrode terminal 24 in Figs. 8-9 of Uruno) disposed on the cover plate, wherein the plurality of pressure relief structures are all located between the positive electrode terminal and the negative electrode terminal (see Figs. 8-9 of Uruno; see entire disclosure and especially P33-34 of Uruno), and
a line connecting a center of the positive electrode terminal and a center of the negative electrode terminal intersects each weak region of the plurality of pressure relief structures (see the Annotated Interpretation of Modified Uruno below).
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Annotated Interpretation of Modified Uruno
Regarding claim 7, modified Uruno meets the limitation a liquid injection port disposed on the cover plate and located between the positive electrode terminal and the negative electrode terminal (the other one of the liquid inlets 6 having valve 6a that is used to inject electrolytic solution in Figs. 8-9; see entire disclosure and especially P58-59).
While modified Uruno does not meet the limitation wherein along a direction of the line connecting the center of the positive electrode terminal and the center of the negative electrode terminal, the plurality of pressure relief structures are respectively disposed on both sides of the liquid injection port, this is merely a rearrangement of the parts of modified Uruno. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have rearranged the parts of modified Uruno as claimed in order to, for example, move the liquid injection port to the center of the battery cell thereby ensuring even distribution of the liquid across the electrode assembly before it reaches the outer sides, because the mere rearrangement of parts, without any new or unexpected results, is within the ambit of one of ordinary skill in the art. See In re Japikse, 181 F.2d 1019, 86 USPQ 70 (CCPA 1950) (see MPEP § 2144.04).
Regarding claim 8, modified Uruno meets the limitation a liquid injection port disposed on the cover plate and located between the positive electrode terminal and the negative electrode terminal (the other one of the liquid inlets 6 having valve 6a that is used to inject electrolytic solution in Figs. 8-9; see entire disclosure and especially P58-59), wherein along a direction of the line connecting the center of the positive electrode terminal and the center of the negative electrode terminal, the plurality of pressure relief structures are disposed on the same side of the liquid injection port (see the Annotated Interpretation of Modified Uruno below).
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Annotated Interpretation of Modified Uruno
Regarding claim 10, modified Uruno meets the limitation wherein an area size of the weak region of each of the pressure relief structures has a predetermined value (each safety valve device of Kinuta used as the pressure release valve 5 and one of the liquid inlets 6 that can release gas after aging of Uruno has its own predetermined area size), area sizes of weak regions of at least some of the pressure relief structures have a first predetermined value, and area sizes of weak regions of at least some of the pressure relief structures have a second predetermined value (the safety valve annular groove of the safety valve device of Kinuta used in modified Uruno as the pressure relief valve 5 has a first predetermined value; the safety valve annular groove of the safety valve device of Kinuta used in modified Uruno as the one of the liquid inlets 6 that can release gas after aging has a second predetermined valve; the claim does not state both of these predetermined values are required to be different).
Claim 9 are rejected under 35 U.S.C. 103 as being unpatentable over Uruno et al (US 20210013483 A1 as given in the 05/19/2025 IDS) in view of Tyler et al (US 20160093854 A1) in view of Kinuta (US 6180279 B1) as applied to claim 1, further in view of Kaplan (US 20090068548 A1).
Regarding claim 9, Uruno discloses wherein the battery cell comprises two pressure relief structures (pressure release valve 5 and one of the liquid inlets 67 that can release gas after aging in Figs. 8-9; see entire disclosure and especially P57-59; each of these two has been modified to be the safety valve device described by Kinuta).
However, modified Uruno does not meet the limitation wherein a lower limit ratio of explosion pressures of the weak regions of the two pressure relief structures is greater than or equal to 1.2 and less than or equal to 1.5.
In a similar field of endeavor, Kaplan teaches a battery can include an elongated vent (101 in Figs. 6) and a secondary vent (107 in Fig. 7A, P31-32). Kaplan teaches the elongated vent is configured to burst at a different pressure than the secondary vent (P32). Kaplan teaches that the secondary battery is configured to burst when, despite the venting provided by the elongated vent, the pressure of the battery continues to rise (P32). Kaplan teaches this continued rise in internal pressure, which may be due to overheating or other abusive conditions, produces a potentially dangerous condition due to the potential for explosion of the cell, therefore, secondary vent is selected to burst at a high pressure but before the dangerous condition is reached (P32).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have utilized the teaching of Kaplan and modified the pressure relief structures of modified Uruno such that one of the pressure relief structures is configured to burst at a different pressure than the other pressure relief structure, given Kaplan teaches this can improve the safety of a battery by having a vent that can burst at a one pressure to relieve pressure buildup and another vent that can burst at a higher pressure in the instance the internal pressure in the battery continues to rise after the first vent bursts.
However, while the two pressure relief structures of modified Uruno have different pressures, these pressures are not set numerically, therefore, modified Uruno does not meet the limitation wherein a lower limit ratio of explosion pressures of the weak regions of the two pressure relief structures is greater than or equal to 1.2 and less than or equal to 1.5.
Kinuta further teaches their square explosion prevention device can include a floor of the safety annular groove in a thickness of 10 µm or 20 µm (C3 / L22-30). Kinuta teaches if the groove floor has a thickness of 10 µm, the groove will blow when the pressure in the battery casing reaches 13.4 kg/cm2 (C3 / L22-30). Kinuta teaches if the groove floor has a thickness of 20 µm, the groove will blow when the pressure in the battery casing reaches 22.5 kg/cm2 (C3 / L22-30).
Therefore, from the teaching of Kinuta, one of ordinary skill in the art would recognize the explosion pressures of a pressure relief structures is a result-effective variable dependent upon the desired thickness of a groove of the pressure relief structures. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have optimized, through routine experimentation, the two different explosion pressures of the two pressure relief structures based upon their desired thickness for each pressure relief structure. “[W]here the general conditions of a claim are disclosed in the prior art, it is not inventive to discover the optimum or workable ranges by routine experimentation.” See In re Aller, 220 F.2d 454, 456, 105 USPQ 233, 235 (CCPA 1955). The discovery of an optimum value of a known result effective variable, without producing any new or unexpected results, is within the ambit of a person of ordinary skill in the art. See In re Boesch, 205 USPQ 215 (CCPA 1980) (see MPEP § 2144.05, II.).
Conclusion
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/MARY GRACE BYRAM/Examiner, Art Unit 1729
Prosecution Insights