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. In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 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 considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. Information Disclosure Statements The Information Disclosure Statement s filed on 13 June 202 3 and 8 July 2025 have been received and considered by the E xaminer. 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: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness . 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 1-3 and 5-8 are rejected under 35 U.S.C. 103 as being unpatentable over Nemkov et al. ( Theor . Found. Chem. Eng. 2020 , 54 (4), 710-718) in view of Wu et al. (NPL document 2 on the IDS filed 13 June 2023) , and with respect to claim 5, as evidenced by Pedersen et al. ( Front. Plant Sci ., 2013 , Vol. 4 , Article 140, DOI: 10.3389/fpls.2013.00140 ). Regarding claim 1, Nemkov teaches a method for producing lithium hydroxide (title and abstract) comprising: an acid solution dissolution step of dissolving lithium carbonate in an acid solution to obtain a first lithium containing solution ( dissolving salt … Li 2 CO 3 in a 4 N solution of sulfuric acid ; p. 710, col. 2, ¶ 2 ) ; an impurity removal step of removing a part of metal ions from the first lithium containing solution to obtain a second lithium containing solution ( t o completely eliminate the negative effect of Ca and Mg impurities on the electrolysis process and the quality of the alkali produced … it is advisable to provide the ion-exchange purification of the sulfate solution in the technological scheme before feeding it to electrolysis , p. 714, col. 2, ¶ 5, and: ion-exchange purification from Ca and Mg; Fig. 7 ) ; and, a conversion step of converting lithium salt contained in the second lithium containing solution into lithium hydroxide by electrodialysis to obtain a lithium hydroxide containing solution in which the lithium hydroxide is dissolved ( the conversion of a Li 2 SO 4 solution into a LiOH solution was carried out in an electrolyser , the anode and cathode spaces of which were separated by a cation-exchange membrane; p. 711, col. 1, ¶ 2, and membrane electrolysis, Fig. 7). Nemkov does not teach the hydrocarbonating or decarbonation steps, recited in claim 1. However, Wu teaches a method of purifying lithium carbonate by c arbonation-decarbonation at low cost, high efficiency and low pollution (p. 594, ¶ 2). In particular, Wu teaches a method comprising: a hydrocarbonating step of blowing carbon dioxide to a slurry of a mixture of water and rough lithium carbonate to obtain a lithium hydrogen carbonate solution ( 10g sample [of industrial grade lithium carbonate] was accurately weighed and immersed in 300ml deionized water in a three-necked flask with agitation to form slurry … CO 2 gas was joined into the reactor by the rubber tube in agitating condition about 30 minutes. …converting into water-soluble LiHCO 3 ; p. 596, “Carbonation Process”) ; and, a decarbonation step of heating the lithium hydrogen carbonate solution to obtain a purified lithium carbonate ( LiHCO 3 solution obtained by the last step was evaporated … 9 0 °C was controlled by water bath in this process. The Li 2 CO 3 precipitat [e] was rinsed several times and obtained by filtering ; p. 596, “Decomposition process”) ; Wu further teaches that this purification procedure of carbonation-decarbonation cycles decreases the impurity content of K, Na, Ca and Mg ( Conclusions, ¶ 1), some of the same impurities identified by Nemkov as undesirable and potentially interfering with their method (p. 714, col. 1, ¶ 3-col. 2, ¶ 1). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to first treat the lithium carbonate used in the method of Nemkov with the carbonation-decarbonation steps taught by Wu. One of ordinary skill in the art would have been motivated to do so in order purify the lithium carbonate entering the method of Nemkov . Specifically, one would be motivated to use the low-cost method taught by Wu in order remove impurities in the feedstock that are identified by Nemkov as undesirable . Regarding claim 2 , modified Nemkov teaches the method of claim 1, where Nemkov further teaches a crystallization step of solid if ying the lithium hydroxide dissolved in the lithium hydroxide containing solution after the conversion step ( p. 715, “Crystallization and Washing of Lithium Hydroxide Monohydrate” and Fig. 7, “Crystallization”). Regarding claim s 3 and 6 , modified Nemkov teaches the method of claim 1 where Nemkov teaches adding lithium carbonate to an acidic solution to obtain a lithium-containing solution (a s olution of lithium sulfate was prepared by dissolving … Li 2 CO 3 in a 4 N solution of sulfuric acid ; p. 710, col. 2, ¶ 2 and Fig. 7, top left) and Nemkov further teaches adjusting the pH of this solution in a pH adjustment step (neutralization) by the addition of an alkali to the lithium-containing solution , where the alkali is lithium carbonate ( neutralization of H 2 SO 4 in the spent anolyte is carried out by its contact with solid lithium carbonate ; p. 712, ¶ 4). Nemkov additionally teaches an ion-exchange step where the post-pH adjustment liquid is brought into contact with an ion-exchange resin ( Lewatit TP-208; p. 714, col. 2, ¶ 5) to obtain a second lithium containing solution, which is then sent to an electrodialysis step (membrane electrolysis; Fig. 7) . Nemkov therefore teaches all the further limitations of claims 3 and 6. Regarding claim 5 , modified Nemkov teaches the method of claim 3, where the post-pH adjustment liquid after the pH adjustment step is between 7 and 8 ( pH 7-8 , Fig. 7 top left ) , which lies in the instantly claimed range. Regarding claim 7 , modified Nemkov teaches the method of claim 6, but Nemkov does not teach the lithium carbonate added in the pH adjustment step being the purified lithium carbonate obtained in the decarbonation step. However Wu teaches that their method of treating lithium carbonate removes impurities that Nemkov teaches are undesirable (Wu: Conclusions, ¶ 1; Nemkov : p. 714, col. 1, ¶ 3-col. 2, ¶ 1), and does so at low-cost and high efficiency (p. 594, ¶ 2) . Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to use the purified lithium carbonate from the decarbonation step taught by Wu in the pH adjustment step taught by Nemkov , thereby arriving at the invention of claim 7. One of ordinary skill in the art would have been motivated to do so in order to avoid introducing more impurities while incurring little additional cost . Regarding claim 8 , modified Nemkov teaches the method of claim 1, where Wu teaches in the decarbonation step the lithium hydrogen carbonate (lithium bicarbonate) is heated at 90 °C ( LiHCO 3 solution obtained by the last step was evaporated … 90 °C was controlled by water bath in this process ; p. 596, “Decomposition Process”) , which falls in the instantly claimed range. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Nemkov et al. ( Theor . Found. Chem. Eng. 2020 , 54 (4), 710-718) in view of Wu et al. (NPL document 2 on the IDS filed 13 June 2023), as applied to claim 1 above, and further in view of Snydacker et al. (US 2019/0256987 A1). Regarding claim 4 , modified Nemkov teaches the process of claim 1 , as analyzed above, where Nemkov teaches adding lithium carbonate to an acidic solution to obtain a lithium-containing solution (a s olution of lithium sulfate was prepared by dissolving … Li 2 CO 3 in a 4 N solution of sulfuric acid ; p. 710, col. 2, ¶ 2 and Fig. 7, top left) . Nemkov further teaches adjusting the pH of this solution in a pH adjustment step (neutralization) by the addition of an alkali ( neutralization of H 2 SO 4 in the spent anolyte is carried out by its contact with solid lithium carbonate ; p. 712, ¶ 4) . Nemkov additionally teaches an ion-exchange step where the post-pH adjustment liquid is brought into contact with an ion-exchange resin ( Lewatit TP-208; p. 714, col. 2, ¶ 5) to obtain a second lithium containing solution, which is then sent to an electrodialysis step (membrane electrolysis; Fig. 7). N either Nemkov nor Wu explicitly teach a step of adding an oxidant to the first lithium-containing solution to obtain a post-oxidation liquid. However , Snydacker also teaches a process for the recovery of lithium from liquid resources (abstract) and further teaches that transition metals in such lithium -con tain ing solutions (brine) can be removed by adding an oxidant ( transition metals are removed from the brine using oxidative processes, including chlorine gas, ozone gas, sodium metabisulfite, sodium hypochlorite, hydrogen peroxide, air, combinations thereof, or other oxidants ; [0394]). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to add an oxidant to the first lithium-containing solution to obtain a post oxidation liquid, as taught by Snydacker , and to follow this with the pH adjustment and ion-exchange steps taught by Nemkov . One of ordinary skill in the art would have been motivated to do so because such a step would facilitate the removal of any transition metal impurities in the lithium-containing solution , which helps to achieve the same goal as Nemkov of producing lithium products of high purity (title) . Double Patenting The nonstatutory double patenting rejection is based on a judicially created doctrine grounded in public policy (a policy reflected in the statute) so as to prevent the unjustified or improper timewise extension of the “right to exclude” granted by a patent and to prevent possible harassment by multiple assignees. A nonstatutory double patenting rejection is appropriate where the conflicting claims are not identical, but at least one examined application claim is not patentably distinct from the reference claim(s) because the examined application claim is either anticipated by, or would have been obvious over, the reference claim(s). See, e.g., In re Berg , 140 F.3d 1428, 46 USPQ2d 1226 (Fed. Cir. 1998); In re Goodman , 11 F.3d 1046, 29 USPQ2d 2010 (Fed. Cir. 1993); In re Longi , 759 F.2d 887, 225 USPQ 645 (Fed. Cir. 1985); In re Van Ornum , 686 F.2d 937, 214 USPQ 761 (CCPA 1982); In re Vogel , 422 F.2d 438, 164 USPQ 619 (CCPA 1970); In re Thorington , 418 F.2d 528, 163 USPQ 644 (CCPA 1969). A timely filed terminal disclaimer in compliance with 37 CFR 1.321(c) or 1.321(d) may be used to overcome an actual or provisional rejection based on nonstatutory double patenting provided the reference application or patent either is shown to be commonly owned with the examined application, or claims an invention made as a result of activities undertaken within the scope of a joint research agreement. See MPEP § 717.02 for applications subject to examination under the first inventor to file provisions of the AIA as explained in MPEP § 2159. See MPEP § 2146 et seq. for applications not subject to examination under the first inventor to file provisions of the AIA. A terminal disclaimer must be signed in compliance with 37 CFR 1.321(b). The filing of a terminal disclaimer by itself is not a complete reply to a nonstatutory double patenting (NSDP) rejection. A complete reply requires that the terminal disclaimer be accompanied by a reply requesting reconsideration of the prior Office action. Even where the NSDP rejection is provisional the reply must be complete. See MPEP § 804, subsection I.B.1. For a reply to a non-final Office action, see 37 CFR 1.111(a). For a reply to final Office action, see 37 CFR 1.113(c). A request for reconsideration while not provided for in 37 CFR 1.113(c) may be filed after final for consideration. See MPEP §§ 706.07(e) and 714.13. The USPTO Internet website contains terminal disclaimer forms which may be used. Please visit www.uspto.gov/patent/patents-forms. The actual filing date of the application in which the form is filed determines what form (e.g., PTO/SB/25, PTO/SB/26, PTO/AIA/25, or PTO/AIA/26) should be used. A web-based eTerminal Disclaimer may be filled out completely online using web-screens. An eTerminal Disclaimer that meets all requirements is auto-processed and approved immediately upon submission. For more information about eTerminal Disclaimers, refer to www.uspto.gov/patents/apply/applying-online/eterminal-disclaimer . Claims 1- 7 are provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-6 of copending Application No. 18/691,381 in view of Nemkov et al. ( Theor . Found. Chem. Eng. 2020 , 54 (4), 710-718). Regarding instant claim 1, claims 1 and 4 of the ‘381 application recite a method for producing lithium hydroxide comprising a hydrocarbonating step of blowing carbon dioxide to a slurry of a mixture of water and rough lithium carbonate to obtain a lithium hydrogen carbonate solution (claim 1, step 3B) ; (2) a decarbonation step of heating the lithium hydrogen carbonate solution to obtain a purified lithium carbonate (claim 1, step 3C) ; (3) an acid solution dissolution step of dissolving the purified lithium carbonate in an acid solution to obtain a first lithium containing solution (claim 1, step 3D) ; (4) an impurity removal step of removing a part of metal ions from the first lithium containing solution to obtain a second lithium containing solution (claim 4) ; and (5) a conversion step of converting lithium salt contained in the second lithium containing solution into lithium hydroxide (claim 1, step 4). The claims of the ‘381 application do not include the method by which lithium hydroxide is produced. However, Nemkov teaches a process for producing a lithium hydroxide containing solution by converting a lithium salt in a solution formed from lithium carbonate into lithium hydroxide by electrodialysis (membrane electrolysis; abstract and Fig. 7). Nemkov further teaches that many industries that use lithium products are in dire need of lithium hydroxide, as its monohydrate (p. 710, ¶ 2). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention convert the lithium containing solution obtained from the method of claims 1 and 4 of the ‘381 application using the electrodialysis steps taught by Nemkov . One of ordinary skill in the art would have been motivated to do so because while claim 1 of the ‘381 application recites a step to convert lithium in solution into lithium hydroxide it does not provide the details required to do so, while Nemkov provides these details. Regarding instant claim 2, the further limitations of this claim are recited in claim 5 of the ‘381 application and it would have been obvious to combine this crystallization step with the ion-exchange step recited in claim 4 in order to afford a solid product. Regarding instant claims 3 and 5-7, modified claim 4 of the ‘381 application includes all the limitations of instant claim 1, and Nemkov further teaches a pH adjustment step where t he pH of the solution obtained by adding lithium carbonate t o an acid solution is raised to pH 7-8 by the addition of an alkali ( neutralization of H 2 SO 4 in the spent anolyte is carried out by its contact with solid lithium carbonate ; p. 712, ¶ 4 and Fig.7 ) prior to ion-exchange and electrodialysis steps (membrane electrolysis; Fig. 7). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to perform a pH adjustment to pH 7-8 by adding lithium carbonate to the solution obtained in step 3 of claim 1 of the ‘381 application , as taught by Nemkov , and to perform an ion-exchange step by bringing the post-pH adjustment liquid into contact with an ion exchange resin to obtain a second lithium containing solution, as taught by Nemkov and by claim 4 of the ‘381 application , thereby arriving at the invention of claims 3, 5, and 6 . It would have been further obvious to use to purified lithium carbonate obtained from step 3B of claim 1 of the ‘381 application because it would introduce fewer impurities that other unpurified sources of lithium carbonate, thereby arriving at the limitations of instant claim 7. One of ordinary skill in the art would have been motivated to dissolve the purified lithium carbonate in an acid solution, perform a pH adjustment step by adding more lithium carbonate to the solution, and perform an ion-exchange step by bringing the post-pH adjustment liquid into contact with an ion exchange resin because Nemkov teaches these as precursor steps that convert lithium carbonate to lithium sulfate and deep clean this solution of lithium sulfate prior to its electrodialysis (p. 714, col. 2, ¶ 5). One of ordinary skill would have been further motivated to use the purified lithium carbonate obtained by Wu in the pH adjustment step in order to avoid introducing more impurities while incurring little additional cost because Wu teaches that their lithium carbonate is of high purity and obtained at low cost (p. 594, ¶ 2). Regarding instant claim 4, modified claim 4 of the ‘381 application teaches all the limitations of instant claim 1, and claim 3 of the ‘381 application recites an oxidation step being included in the process to produce lithium hydroxide. Though claim 3 indicates that the oxidation step occur before the carbonating step, the courts have held that any order of performing process steps is prima facie obvious in the absence of new or unexpected results ( In re Gibson , 39 F.2d 975, 5 USPQ 230 (CCPA 1930); Ex parte Rubin , 128 USPQ 440 (Bd. App. 1959)). See MPEP §2144.04 IV C. Thus, the instantly claimed order of steps is an obvious variant of the steps recited in the claims of the ‘381 application . This is a provisional non-statutory double patenting rejection. Claim 8 is provisionally rejected on the ground of nonstatutory double patenting as being unpatentable over claims 1-6 of copending Application No. 18/691,381 in view of Nemkov et al. ( Theor . Found. Chem. Eng. 2020 , 54 (4), 710-718), as applied to claim 1 above, and further in view of Wu et al. (NPL document 2 on the IDS filed 13 June 2023). While claim 1 of the ‘381 application recites a decarbonation step (3C) utilizing heating, it does not specify the temperature to which the lithium hydrogen carbonate should be heated. However, Wu teaches a similar process for carbonating and decarbonating lithium carbonate to purify it and further teaches that the decarbonation occurs at 90 °C ( LiHCO 3 solution obtained by the last step was evaporated … 90 °C was controlled by water bath in this process. The Li 2 CO 3 precipitat [e] was rinsed several times and obtained by filtering ; p. 596, “Decomposition process”). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to carry out step 3C of claim 1 in the ‘381 application at 90 °C, as taught by Wu. One of ordinary skill in the art would have been motivated to do so because while claim 1 of the ‘381 application is silent on this detail, Wu teaches that this temperatures is effective for carrying out the desired transformation. This is a provisional non-statutory double patenting rejection. Pertinent Prior Art The following prior art made of record and not relied upon is considered pertinent to applicant's disclosure: US 2012 / 0100056 A1 discloses method of producing lithium carbonate and lithium hydroxide involving carbonation, decarbonation, ion-exchange, and electrolysis steps ([0009] and [0020]). US 2011 / 0203929 A1 discloses the preparation of lithium hydroxide from lithium carbonate via electrodialysis (abstract and [0032]) . US 6,048,507 A discloses the purification of lithium carbonate by a carbonation/decarbonation cycle with ion exchange (col. 4, lines 26-38). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT Nicholas A Piro whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)272-6344 . The examiner can normally be reached FILLIN "Work Schedule?" \* MERGEFORMAT Mon-Fri, 8:00 am-5:00 pm . 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, FILLIN "SPE Name?" \* MERGEFORMAT Sally Merkling can be reached at FILLIN "SPE Phone?" \* MERGEFORMAT (571) 272-6297 . 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. /NICHOLAS A. PIRO/ Assistant Examiner, Art Unit 1738 /PAUL A WARTALOWICZ/ Primary Examiner, Art Unit 1735