Prosecution Insights
Last updated: April 19, 2026
Application No. 18/270,555

Electrical Energy Store Having a Lateral Cell Contact System, and Motor Vehicle

Non-Final OA §102§103§112
Filed
Jun 30, 2023
Examiner
ERWIN, JAMES M
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
BAYERISCHE MOTOREN WERKE AKTIENGESELLSCHAFT
OA Round
1 (Non-Final)
82%
Grant Probability
Favorable
1-2
OA Rounds
2y 8m
To Grant
88%
With Interview

Examiner Intelligence

Grants 82% — above average
82%
Career Allow Rate
478 granted / 583 resolved
+17.0% vs TC avg
Moderate +6% lift
Without
With
+6.1%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
20 currently pending
Career history
603
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
42.2%
+2.2% vs TC avg
§102
31.3%
-8.7% vs TC avg
§112
22.7%
-17.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 583 resolved cases

Office Action

§102 §103 §112
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 . Priority Applicant’s claim for the benefit of a prior-filed application under 35 U.S.C. 119(e) or under 35 U.S.C. 120, 121, 365(c), or 386(c) is acknowledged. Applicant has complied with all of the conditions for receiving the benefit of an earlier filing date under 35 U.S.C. 119(e). Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statement (IDS) submitted on 06/30/2023 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. Drawings The drawings are objected to under 37 CFR 1.83(a). The drawings must show every feature of the invention specified in the claims. Therefore, the feature of “the conductor tracks are formed by a punched comb” (claim 14) must be shown or the feature(s) canceled from the claim(s). No new matter should be entered. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Specification The specification filed on 06/30/2023 was reviewed and is acceptable. 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(s) 16-18 is/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. Claim(s) 16-17 recites the limitation “a terminal region”. It is unclear whether this is the same terminal region previously recited in claim 12, or another separate and distinct terminal region. For purposes of this Office Action, it will be assumed that this was intended to be the same terminal region previously recited, consistent with the claim’s dependency. Claim 17 recites the limitation “the first cell terminal” in line 3. There is insufficient antecedent basis for this limitation in the claim. Appropriate correction is required. Claim Rejections - 35 USC § 102 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. 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 12, 14, 19, and 22 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Kim et al. (US 2015/0155533 A1; hereinafter “Kim”). Regarding claim 12, Kim discloses an electrical energy store (Title) comprising: a plurality of energy storage cells (100), each having a cell housing (as shown in Fig 1) and two cell terminals (110); and a cell contact connection system for interconnecting the energy storage cells (as shown in Fig 1, collectively 200/300/500/600/700), wherein the cell contact connection system has a support (500) and conductor tracks (200) that are connected to the support (as shown in Figs 6 and 7) and have conductor track portions (bent portions of 200, as shown in Fig 7), which form contact regions for contact connection to the cell terminals of the energy storage cells (as shown in Fig 7), and the cell terminals at least partially have terminal regions that are to be contact connected laterally (as shown in Fig 7), and the contact regions are at least partially in a form of lateral pressure contacts (as implied in Fig 7), which in a course of contact connection exert a lateral force on the terminal regions that are to be contact connected laterally (as implied in Fig 7). Regarding claim 14, Kim discloses all of the claim limitations as set forth above. Kim further discloses that the conductor tracks are formed by a punched comb (absent a special definition of “punched comb” it is submitted that the structure of the elastic connector portions 220 of the socket terminals 200, i.e. conductor tracks, appear to be in a “punched comb” form, as shown in Fig 5, because the elastic connection portions appear to be punched from metal and form a “comb” which surrounds the terminals 110), which is joined to an insulating material forming the support (as shown in Figs 5-7). Regarding claim 19, Kim discloses all of the claim limitations as set forth above. Kim further discloses that the contact regions have a fold (bent part 221) which is in the form of a turned up portion and is formed by folding over an edge region of the conductor track portion (as shown in Fig 7), and the fold is pressed laterally against a terminal region of the respective cell terminal that is to be contact connected laterally (as shown in Fig 7). Regarding claim 22, Kim discloses all of the claim limitations as set forth above. Kim further discloses a motor vehicle (hybrid vehicle, [0002]) comprising the recited electrical energy store (as noted above). Claim Rejections - 35 USC § 103 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. 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) 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. (US 2015/0155533 A1; hereinafter “Kim”), as applied to claim 12 above, in view of Enomoto et al. (US 2018/0205048 A1; hereinafter “Enomoto”). Regarding claim 13, Kim discloses all of the claim limitations as set forth above. Kim discloses the plurality of energy storage cells (modules 100), but does not disclose which individual battery cells make up the modules, and therefore does not explicitly disclose a form of round cells. Enomoto teaches battery modules (Title). Enomoto teaches that, conventionally, a battery module includes a plurality of cylindrical cells and a battery holder ([0002]). Kim and Enomoto are analogous prior art to the current invention because they are concerned with the same field of endeavor, namely electrical energy stores. Before the effective filing date of the current invention, it would have been obvious to one having ordinary skill in the art that the battery modules of Kim must necessarily have individual battery cells making up the battery module, and would thus find it obvious to utilize conventional cylindrical batteries, i.e. round cells, as doing so would amount to nothing more than to use a known component for its intended use in a known environment to accomplish an entirely predictable result. Claim(s) 21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Kim et al. (US 2015/0155533 A1; hereinafter “Kim”), as applied to claim 12 above, in view of Krantz et al. (DE 196 48 353 A1; hereinafter “Krantz”). Regarding claim 21, Kim discloses all of the claim limitations as set forth above. Kim discloses a store housing (sub pack case 700) with a housing upper part and a housing lower part (as shown in Fig 4), but does not appear to be particularly concerned with the particulars of the housing, and therefore does not disclose that the housing has a double walled form to form a respective cooling channel. Krantz teaches an electrochemical storage battery (Abstract). Krantz teaches that the battery has a double walled evacuated housing having an inner wall space (2,3) which serves as a heat exchanger of an air heating/cooling device (Abstract). Kim and Krantz are analogous prior art to the current invention because they are concerned with the same field of endeavor, namely electrical energy stores. Before the effective filing date of the current invention, it would have been obvious to one having ordinary skill in the art to utilize the double walled evacuated housing of Krantz with the reasonable expectation that doing so would provide for heating/cooling, as suggested by Krantz. Accordingly, the skilled artisan would find it obvious that modified Kim discloses that the housing upper part and the housing lower part have a double walled form to form a respective cooling channel (Krantz: as shown in Fig 1, note that Krantz does not show the bottom surface; see paragraph beginning with “Some areas, e.g. B the lid 3 and the bottom surface (not shown)…”), and to cool the energy storage cells, the housing upper part is disposed on cell housing covers of the cell housings and the housing lower part is disposed on cell housing bottoms of the cell housings (Kim: as shown in Fig 4, but with the incorporated double walled evacuated housing of Krantz). Allowable Subject Matter Claim(s) 15-18 and 20 is/are objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. The following is a statement of reasons for the indication of allowable subject matter: The present invention is related to, inter alia, an electrical energy store wherein a first cell terminal is disposed on a cell housing cover and a second cell terminal is disposed on a cell housing side wall. Kim et al. (US 2015/0155533 A1; hereinafter “Kim”) is considered to be the closest relevant prior art to dependent claim 15. Kim discloses most of the claim limitations as set forth above. However, Kim does not disclose, teach, fairly suggest, nor render obvious the recited second terminal being disposed on a cell housing side wall. To the contrary, Kim discloses that both terminals are disposed on the same portion of the cell housing (interpreted to be the “cover”, as shown in Figs 1 and 3; also as shown in Fig 8) such that the battery modules may be connected in series ([0029]), and thus there does not appear to be any reasonable basis for the skilled artisan to abandon the structure of Kim and be directed towards the recited structure because such would reasonably appear to require substantial rearrangement and complicate connecting the battery modules in series. Conclusion The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: Dawson (US 2021/0351523 A1) discloses a boltless busbar system; Reider et al. (US 2021/0265750 A1) discloses a pluggable module connector; and Patterson et al. (US 2020/0313139 A1) discloses a battery bus bar module. Any inquiry concerning this communication or earlier communications from the examiner should be directed to JAMES M ERWIN whose telephone number is (571)272-3101. The examiner can normally be reached Monday-Friday: 6am-3pm PDT. 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, Nicole Buie-Hatcher can be reached at 571-270-3879. 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. /JAMES M ERWIN/Primary Examiner, Art Unit 1725 03/02/2026
Read full office action

Prosecution Timeline

Jun 30, 2023
Application Filed
Mar 04, 2026
Non-Final Rejection — §102, §103, §112 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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ELECTROCHEMICAL CELLS WITH LITHIUM ALLOY ANODES
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2y 5m to grant Granted Mar 17, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
82%
Grant Probability
88%
With Interview (+6.1%)
2y 8m
Median Time to Grant
Low
PTA Risk
Based on 583 resolved cases by this examiner. Grant probability derived from career allow rate.

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