Prosecution Insights
Last updated: April 19, 2026
Application No. 18/248,117

COOLING SYSTEM

Non-Final OA §103
Filed
Apr 06, 2023
Examiner
VO, JIMMY
Art Unit
1723
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Renault S A S
OA Round
2 (Non-Final)
73%
Grant Probability
Favorable
2-3
OA Rounds
2y 11m
To Grant
96%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allow Rate
468 granted / 645 resolved
+7.6% vs TC avg
Strong +23% interview lift
Without
With
+23.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 11m
Avg Prosecution
64 currently pending
Career history
709
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
55.1%
+15.1% vs TC avg
§102
26.6%
-13.4% vs TC avg
§112
12.4%
-27.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 645 resolved cases

Office Action

§103
DETAILED ACTION Response to Amendment In the amendment dated 2/6/26, the following has occurred: new Claim 19 has been added. Claims 10-19 are pending. Claims 10-19 are examined in this office action. This communication is a Non-Final Rejection in response to the "Amendment" and "Remarks" filed on 2/6/26. The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claim Rejections - 35 USC § 103 Claims 10-19 are rejected under 35 U.S.C. 103 as being unpatentable over US 20140220397 A1 (“US'397”) in view of US 20120009455 A1 (“US'455”). As to Claim 10: US'397 discloses: a cooling system for a battery (energy store 101) in an electric or hybrid vehicle (HEV or EV) ([0003], [0013]); a cooling device (cooling plate 103) and a thermal interface (thermal transfer device 105) ([0012], [0041]); the cooling device generates a movement of a coolant fluid between an inlet point (TFluidin) and an outlet point (TFluidout) in a cooling direction (flow path length 107) ([0042]); the thermal interface has a first surface (electrical insulation layer 421) that is at least substantially in contact with the cooling device (cooling plate 103) and a second surface (tolerance compensating layer 424), the second surface being a thermal exchange surface, opposite the first surface, that is configured to come into contact with or to be close to a battery (battery cells 101) ([0045], [0041]); and the dimension of said thermal-exchange surface in a secondary direction, perpendicular to the cooling direction of the cooling system, increases in the cooling direction (disclosing a structured insulation layer 423 with strips that “taper in the direction of the flow path length [107]” and are “triangular in shape,” such that the interspaces between the strips increase along the flow direction, thereby increasing the effective heat-transfer region across the transverse direction) ([0047], [0061]). However, US'397 does not explicitly disclose implementing the thermal interface as a discrete, modular set of heat-conductive sheets configured as unitary surfaces for insertion between individual battery cells within a stacked battery module. US'455 discloses a battery module architecture for electric vehicles comprising a stack of adjoining battery cells and heat conductive sheets positioned between at least some adjacent battery cells, wherein the sheets are in thermal co-operation with the battery cells and are coupled with a heat dispersion member to facilitate heat dissipation from interior cells of the stack ([0020], [0023], [0030]). US’397 and US’455 are analogous arts because both are directed toward the field of thermal management systems for battery modules in electric or hybrid vehicles and address the common problem of achieving uniform temperature distribution across multiple cells to improve performance and longevity ([0003] of US'397; [0002] of US'455). It would have been obvious to a person of ordinary skill in the art before the effective filing date of the instant application to incorporate the variable-dimension thermal exchange geometry of US'397 into the modular heat-conductive sheet arrangement taught by US'455. A skilled artisan would have been motivated to do so in order to provide a modular battery configuration (US'455) that also achieves spatially controlled thermal resistance along the coolant flow path (US'397), thereby compensating for temperature gradients in the coolant and improving temperature uniformity across the battery cells without requiring increased coolant flow rate, which is an expressly desired outcome in US'397 ([0009], [0011]). As to Claim 11: US'397 discloses the cooling system as claimed in claim 10 (as described in the rejection of claim 10) ([0003], [0012], [0041], [0042]); wherein an orthogonal projection of the thermal-exchange surface (the high-conductivity tolerance compensating layer 424 located in the interspaces of the structured insulation layer 423) onto a plane parallel to the first surface is substantially in a shape of a funnel oriented along an axis parallel to the cooling direction (disclosing that the insulation material features a plurality of strips that “taper in the direction of the flow path length [107]” and are “triangular in shape,” such that the interspaces between adjacent strips widen along the flow direction, thereby forming a progressively expanding thermal-exchange region corresponding to a funnel-like projection aligned with the flow direction) ([0047], [0061]). However, US'397 does not explicitly disclose implementing the thermal interface as a discrete, modular set of heat-conductive sheets configured as unitary surfaces for insertion between individual battery cells within a stacked battery module. US'455 discloses a battery module architecture for electric vehicles comprising a stack of adjoining battery cells and heat conductive sheets positioned between at least some adjacent battery cells, wherein the sheets are in thermal co-operation with the battery cells to facilitate heat dissipation and are thermally coupled to a heat dispersion structure for transferring heat away from inner cells ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate US'397's variable-dimension thermal exchange geometry into the modular heat-conductive sheets taught by US'455. A person of ordinary skill would have been motivated to combine these teachings to create a modular battery stack (US'455) that utilizes locally-adapted thermal interfaces (US'397) to precisely compensate for the temperature gradient of the coolant along the flow path, thereby ensuring uniform cooling performance across all cells in the module without requiring an increased coolant flow rate, which is an expressly recognized benefit in US'397 ([0009], [0011]). As to Claim 12: US'397 discloses the cooling system as claimed in claim 11 (see rejection of claim 11) ([0003], [0012], [0041], [0042], [0047], [0061]); wherein a contour of said funnel shape is defined by a mathematical law (disclosing that the surface portion and/or material thickness of the insulation layer can vary along the flow path length, including embodiments where the variation occurs continuously and may follow non-linear relationships such as exponential behavior to adapt thermal resistance along the flow direction) ([0021], [0060], [0061]). However, US'397 does not explicitly name the specific mathematical law 1/X1/X1/X to define the contour of the funnel shape, nor does it explicitly disclose the implementation of the thermal interface as a discrete, modular set of heat-conductive sheets configured as unitary surfaces for insertion between individual battery cells within a stacked battery module. US'455 discloses a battery module architecture for electric vehicles comprising a stack of adjoining battery cells and heat conductive sheets positioned between at least some adjacent battery cells, wherein the sheets are in thermal co-operation with the battery cells and are thermally coupled to a heat dispersion structure to facilitate heat dissipation from the interior of the stack ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate US'397's variable-dimension thermal exchange geometry into the modular heat-conductive sheets taught by US'455. Specifically, a person of ordinary skill would have been motivated to define the contour of the exchange surface using a mathematical relationship such as 1/X1/X1/X, as US'397 expressly teaches that continuous and non-linear variations (including exponential-type relationships) in the distribution or thickness of insulation material along the flow path are effective for compensating temperature gradients in the coolant and achieving uniform cooling performance across the battery module, which is a predictable and desirable result recognized by both references ([0009], [0011], [0021]). As to Claim 13: US'397 discloses the cooling system as claimed in claim 10 (see the rejection of claim 10) ([0003], [0012], [0041], [0042]); wherein the thermal interface (thermal transfer device 105) includes functional layers such as a tolerance compensating layer (424) and a thermal insulation layer (423) arranged in a stack between a cooling device (103) and a battery (101) ([0045], [0041]). However, US'397 does not explicitly disclose that the thermal interface has a constant thickness, as it teaches that the material thickness of the thermal insulation layer varies along the flow path length, including embodiments where the thickness declines continuously or follows non-linear relationships to modulate thermal resistance along the coolant flow direction ([0021], [0046], [0060]). US'455 discloses a battery module comprising a plurality of battery cells and heat conductive sheets positioned between at least some adjacent battery cells, wherein the sheets are configured as discrete thermal interface elements having a defined thickness, for example on the order of about 0.1 mm to 1 mm, thereby indicating a substantially uniform or constant thickness across the sheet to facilitate consistent thermal conduction and assembly within the stacked battery configuration ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to utilize a thermal interface with a constant thickness as taught by US'455 in the cooling system of US'397. A person of ordinary skill would have been motivated to use such a constant-thickness interface (e.g., a uniform sheet or layer) to simplify manufacturing and assembly of the thermal interface and to ensure consistent mechanical and thermal contact between the battery cells and the cooling plate, while still achieving desired thermal management performance through the spatial distribution and structuring of materials as taught by US'397, which aims to control temperature gradients along the flow path ([0009], [0011]). As to Claim 14: US'397 discloses an electrical power supply system (energy storage device) for an electric or hybrid vehicle (HEV or EV) comprising a battery (energy store 101) and the cooling system as claimed in claim 10 (temperature-control plate 103 and thermal transfer device 105) ([0003], [0028], [0041]); wherein the battery is in contact with or close to the thermal interface (thermal transfer device 105) of the cooling system (battery cells 101 arranged on a surface of the thermal transfer device between the cells and the cooling plate) ([0041], [0045]). However, US'397 does not explicitly disclose the implementation of the electrical power supply system in a modular architecture where the thermal interface is provided as a discrete set of unitary heat-conductive surfaces specifically arranged between individual battery cells within a module stack. US'455 discloses an electrical power supply system (battery module) for electric or hybrid vehicles comprising a plurality of adjoining battery cells arranged in a stacked configuration and heat-conductive sheets positioned between at least some adjacent battery cells, wherein the sheets are in thermal co-operation with the cells and are configured to transfer heat away from the battery interior toward a heat dissipation structure ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate US'397's variable-dimension thermal exchange surface into the modular power supply system architecture taught by US'455. A person of ordinary skill would have been motivated to combine these teachings to create a modular battery system (US'455) that utilizes locally-adapted thermal interfaces (US'397) to compensate for temperature gradients along the coolant flow path and thereby improve temperature uniformity across the battery cells without requiring an increased coolant flow rate, which is an expressly recognized objective in US'397 ([0009], [0011]). As to Claim 15: US'397 discloses the electrical power supply system as claimed in claim 14 (see rejection of claim 14); wherein the energy store (battery) comprises a plurality of battery cells (101) arranged next to one another as part of an energy storage device ([0013], [0041]); and the thermal-exchange surface (tolerance compensating layer 424) is configured to be close to or in contact with the battery cells (battery cells arranged on a surface of the thermal transfer device positioned between the cells and the cooling plate) ([0041], [0045]). However, US'397 does not explicitly disclose that the battery comprises several identical modules distributed in the secondary direction, nor that the thermal-exchange surface of the cooling system comprises a set of discrete unitary surfaces arranged between each module and the cooling device. US'455 discloses a modular battery architecture for electric vehicles comprising a plurality of adjoining battery cells arranged in a stacked configuration, wherein the cells may be considered identical units distributed along a stacking direction; and further discloses heat-conductive sheets positioned between at least some adjacent battery cells, the sheets having a longitudinal extent aligned with the direction of heat transfer and being thermally coupled to a heat dispersion structure to provide a thermal exchange path from each cell ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to arrange the power supply system of US'397 in the modular configuration taught by US'455. A person of ordinary skill would have been motivated to utilize a set of unitary surfaces (conductive sheets) as taught by US'455 to provide discrete and scalable thermal paths for each battery unit in a stacked configuration, while applying the spatially varying thermal interface characteristics of US'397 to those unitary surfaces to compensate for temperature gradients along the coolant flow path and thereby achieve more uniform cooling across the battery cells, which is an expressly recognized objective in US'397 ([0009], [0011]). As to Claim 16: US'397 discloses the electrical power supply system as claimed in claim 15 (see rejection of claim 15) ([0013], [0041], [0045]); and within a given module (stack of cells 101), a contact area between a first cell and the at least one unitary surface (tolerance compensating layer 424) is smaller than a contact area between a second cell, located further downstream than the first cell, and the at least one unitary surface (disclosing that the insulation material features a plurality of strips that “taper in the direction of the flow path length [107]” and are “triangular in shape,” such that the surface portion of insulation material decreases along the flow path and the conductive exchange region correspondingly increases for cells located further downstream to compensate for temperature gradients) ([0047], [0061]). However, US'397 does not explicitly disclose the specific geometric arrangement where each module has a longitudinal axis of symmetry parallel to the cooling direction and comprises a set of cells arranged perpendicularly to and distributed uniformly along said longitudinal axis. US'455 discloses a battery module architecture for electric vehicles comprising a plurality of adjoining battery cells arranged in a stacked configuration along an axis, wherein the cells are distributed in an orderly and uniform manner within the module to facilitate modular assembly and effective thermal management, and further includes heat-conductive sheets positioned between adjacent cells for transferring heat toward a heat dissipation structure ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to arrange the battery cells of US'455 such that they are distributed along an axis parallel to the cooling direction of US'397. A person of ordinary skill would have been motivated to combine these teachings to create a modular battery stack where the individual cell interfaces utilize the tapering and spatially varying thermal interface geometry of US'397 to provide a progressively larger effective heat-transfer area for downstream cells, thereby compensating for the temperature increase of the coolant along the flow path and achieving a more uniform temperature distribution across all cells in the stack, which is an expressly recognized objective in US'397 ([0009], [0011]). As to Claim 17: US'397 discloses the electrical power supply system as claimed in claim 15 (see rejection of claim 15); wherein the energy storage device comprises a plurality of battery cells (101) arranged within an energy storage system ([0013], [0041]); and a thermal interface (thermal transfer device 105) is configured to be in thermal contact with the battery cells, the thermal transfer device being arranged between the battery cells and the cooling plate to provide heat transfer ([0041], [0045]). However, US'397 does not explicitly disclose that all of the unitary surfaces of the thermal interface are identical in a modular stack. US'455 discloses a modular battery architecture for electric vehicles comprising a plurality of adjoining battery cells arranged in a stacked configuration and a set of heat-conductive sheets positioned between adjacent battery cells, wherein the sheets are configured as repeatable, standardized components within the module to provide consistent thermal pathways between cells and toward a heat dissipation structure ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to utilize identical unitary surfaces (heat-conductive sheets) as taught by US'455 in the system of US'397. A person of ordinary skill would have been motivated to use identical unitary surfaces to reduce manufacturing complexity and cost by employing standardized, modular components, while ensuring consistent thermal coupling between adjacent cells, thereby improving assembly efficiency and maintaining uniform thermal performance across the battery module, which is a predictable and desirable result in the field of modular battery system design. As to Claim 18: US'397 discloses an electric or hybrid vehicle (mentioning “hybrid electric vehicles (HEV) or electric vehicles (EV)”) ([0003]); comprising the electrical power supply system as claimed in claim 14 (disclosing an energy storage device comprising a temperature-control plate 103 and a thermal transfer device 105 arranged in a stack with battery cells 101) ([0028], [0041], [0045]). However, US'397 does not explicitly disclose the implementation of the electrical power supply system in a modular architecture where the thermal interface is provided as a discrete, standardized set of unitary heat-conductive sheets specifically arranged between individual battery cells within a module stack as part of the vehicle's power source. US'455 discloses a battery module architecture specifically for use as a power source in hybrid cars and electric vehicles, which comprises a stack of adjoining battery cells and a plurality of heat-conductive sheets positioned between adjacent battery cells, wherein the sheets are in thermal co-operation with the battery cells and facilitate heat dissipation from the interior of the stack to support high power output and capacity required for vehicle operation ([0020], [0023], [0030]). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate US'397's variable-dimension thermal exchange system into the modular battery architecture of US'455 and install the resulting system within an electric or hybrid vehicle. A person of ordinary skill would have been motivated to combine these teachings to provide a vehicle with a power supply system that ensures improved temperature uniformity across battery cells through locally adapted thermal interfaces that compensate for temperature gradients along a coolant flow path, thereby enhancing battery life, performance, and safety, which are expressly recognized objectives in US'397 ([0009], [0011]). As to Claim 19: US'397 discloses the cooling system as claimed in claim 11 (see the rejection of claim 11) ([0003], [0012], [0041], [0042], [0047], [0061]); wherein the dimension of said thermal-exchange surface in the secondary direction increases continuously in the cooling direction from the inlet point to the outlet point (disclosing that a surface portion of the insulation material relative to the conductive material can decline continuously along the thermal insulation layer, and that the insulation material features a plurality of strips that are triangular in shape and taper in the direction of the flow path length, such that the conductive interspaces defining the thermal-exchange surface progressively increase in width along the flow direction to locally adapt thermal resistance) ([0021], [0047], [0061]). However, US'397 does not explicitly disclose the implementation of the thermal interface as a discrete, modular set of heat-conductive sheets configured as unitary surfaces specifically for insertion between individual battery cells within a stacked battery module. US'455 discloses a battery module architecture for electric vehicles comprising a stack of adjoining battery cells and heat conductive sheets positioned between at least some adjacent battery cells, wherein the sheets are provided as unitary surfaces in thermal co-operation with the battery cells and facilitate heat dissipation from the interior of the stack toward a heat dissipation structure ([0020], [0023], [0030]). The primary reference (US'397) and secondary reference (US'455) are analogous art because both are directed to the same technical field of thermal management systems for energy storage modules in electric and hybrid vehicles and address the common challenge of achieving temperature homogeneity across a cell stack to prevent safety risks and improve service life ([0003] of US'397; [0002] of US'455). It would have been obvious to a person skilled in the art before the effective filing date of the instant application to incorporate US'397's variable-dimension thermal exchange geometry into the modular heat-conductive sheets taught by US'455. A person of ordinary skill would have been motivated to combine these teachings to create a modular battery stack (US'455) that utilizes locally adapted thermal interfaces (US'397) to precisely and continuously compensate for the temperature gradient of the coolant along the flow path, thereby ensuring uniform cooling performance across all cells in the module without requiring an increased coolant flow rate, which is an expressly recognized objective in US'397 ([0009], [0011]). Response to Arguments Applicant’s arguments with respect to claims have been considered but are moot because the new ground of rejection does not rely on the combination of references applied in the prior rejection of record for any teaching or matter specifically challenged in the argument. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to JIMMY K VO whose telephone number is (571)272-3242. The examiner can normally be reached Monday - Friday, 8 am to 6 pm 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, Tong Guo can be reached at (571) 272-3066. 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. /JIMMY VO/ Primary Examiner Art Unit 1723 /JIMMY VO/ Primary Examiner, Art Unit 1723
Read full office action

Prosecution Timeline

Apr 06, 2023
Application Filed
Nov 05, 2025
Non-Final Rejection — §103
Feb 06, 2026
Response Filed
Mar 24, 2026
Non-Final Rejection — §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

2-3
Expected OA Rounds
73%
Grant Probability
96%
With Interview (+23.1%)
2y 11m
Median Time to Grant
Moderate
PTA Risk
Based on 645 resolved cases by this examiner. Grant probability derived from career allow rate.

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