Prosecution Insights
Last updated: April 19, 2026
Application No. 18/266,097

METHOD FOR PRODUCING POSITIVE ELECTRODE SLURRY AND METHOD FOR PRODUCING POSITIVE ELECTRODE

Final Rejection §103
Filed
Jun 08, 2023
Examiner
NGUYEN, HAIDUNG D
Art Unit
1761
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Panasonic Intellectual Property Management Co., Ltd.
OA Round
2 (Final)
65%
Grant Probability
Favorable
3-4
OA Rounds
3y 2m
To Grant
93%
With Interview

Examiner Intelligence

Grants 65% — above average
65%
Career Allow Rate
401 granted / 616 resolved
At TC average
Strong +28% interview lift
Without
With
+28.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
39 currently pending
Career history
655
Total Applications
across all art units

Statute-Specific Performance

§101
0.6%
-39.4% vs TC avg
§103
46.4%
+6.4% vs TC avg
§102
27.2%
-12.8% vs TC avg
§112
19.3%
-20.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 616 resolved cases

Office Action

§103
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 This action is responsive to applicant’s amendment filed 2/11/2026. Claims 1-7 are pending. The previous rejection of claims 1-7 under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, is withdrawn in view of applicant’s amendment. The previous rejection of claims 1-7 under 35 U.S.C. 103 as being unpatentable over Ryu et al (US 20080063939) in view of Wang et al. (CN109354033) and Goodman (CN85103356) is withdrawn in view of applicant’s amendment. Response to Arguments Applicant's arguments filed 2/11/2026 have been fully considered but they are not persuasive. Applicant argues that the combination of Ryu, Wang and Goodman references does not provide for all the aspects of the claims, nor is there any rationale prompting a skilled artisan to modify the combination so as to derive the current invention. Applicant further argues that Wang nowhere teaches, suggests, or motivates the combination of the technique disclosed therein with the technique disclosed by Ryu. Specifically, the skilled artisan readily ascertains that this technique of Wang is not similar to the technique of an electrode for a secondary battery disclosed by Ryu. Most specifically, the feature that the expanded montmorillonite has low bulk density and high adsorption performance is completely unrelated to improved energy density of the positive electrode. The examiner respectfully disagrees with applicant’s arguments. The law held that one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986) and "The test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference.... Rather, the test is what the combined teachings of those references would have suggested to those of ordinary skill in the art." In re Keller, 642 F.2d 413, 425, 208 USPQ 871, 881 (CCPA 1981). See also In re Sneed, 710 F.2d 1544, 1550, 218 USPQ 385, 389 (Fed. Cir. 1983) ("[I]t is not necessary that the inventions of the references be physically combinable to render obvious the invention under review."); and In re Nievelt, 482 F.2d 965, 179 USPQ 224, 226 (CCPA 1973) ("Combining the teachings of references does not involve an ability to combine their specific structures."). In addition, the rationale to modify or combine the prior art does not have to be expressly stated in the prior art; the rationale may be expressly or impliedly contained in the prior art or it may be reasoned from knowledge generally available to one of ordinary skill in the art, established scientific principles, or legal precedent established by prior case law. In re Fine, 837 F.2d 1071, 5 USPQ2d 1596 (Fed. Cir. 1988); In re Jones, 958 F.2d 347, 21 USPQ2d 1941 (Fed. Cir. 1992) and "[w]hen a work is available in one field of endeavor, design incentives and other market forces can prompt variations of it, either in the same field or a different one." KSR, 550 U.S. at 417, 82 USPQ2d at 1396. Ryu does not disclose the method comprising forming the smectite-containing solid mass mixing a smectite (montmorillonite), and an N-methyl-2-pyrolidone (NMP)-containing solvent, to prepare a smectite-NMP aqueous solution; subjecting the smectite-NMP aqueous solution to thermal dehydration, to obtain a smectite-containing solid mass. However, Wang discloses same method steps to obtain expanded montmorillonite having low bulk density and high adsorption performance comparable to that of expanded graphite (abstract and para 0024). It is well known in the art the expanded graphite and expanded montmorillonite are used in electrochemical applications, such as electrode materials. One of ordinary skill in the art would have been motivated to use the expanded montmorillonite produced by the method of Wang with a reasonable expectation that this would result in providing the positive electrode having improved energy storage efficiency. A reference need not be from the same field of endeavor as the claimed invention in order to be analogous art. Bigio, 381 F.3d at 1325, 72 USPQ2d at 1212.; and "For obviousness under § 103, all that is required is a reasonable expectation of success." In re O'Farrell, 853 F.2d 894, 904 (Fed. Cir. 1988). Also See MPEP 2143. With respect to Goodman, applicant argues that Goodman discloses rendering the smectite organophilic by using a quaternary ammonium compound but nowhere discloses adding smectite to water to obtain an aqueous solution of smectite. It is clearly state in the reference that “An organo-clay is prepared by mixing a quaternary ammonium compound with an aqueous suspension of a smectite clay; thereafter subjecting the smectite clay/quaternary ammonium compound/water mixture to high shear mixing for a time sufficient to dissipate in the mixture at least 100 KJ of energy per kg. of dry solids in the mixture; and then dewatering the product thus obtained” (see the abstract), and therefore smectite must be add to water to form an aqueous solution of smectite. Claims 1-7 remain unpatentable for the reasons of record. Conclusion THIS ACTION IS MADE FINAL. 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action. Any inquiry concerning this communication or earlier communications from the examiner should be directed to HAIDUNG D NGUYEN whose telephone number is (571)270-5455. The examiner can normally be reached M-Th: 10a-3p. 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, Angela Brown-Pettigrew can be reached at 571-272-2817. 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. /HAIDUNG D NGUYEN/ Primary Examiner, Art Unit 1761 3/27/2026
Read full office action

Prosecution Timeline

Jun 08, 2023
Application Filed
Nov 06, 2025
Non-Final Rejection — §103
Feb 11, 2026
Response Filed
Mar 28, 2026
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

3-4
Expected OA Rounds
65%
Grant Probability
93%
With Interview (+28.1%)
3y 2m
Median Time to Grant
Moderate
PTA Risk
Based on 616 resolved cases by this examiner. Grant probability derived from career allow rate.

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