Prosecution Insights
Last updated: April 19, 2026
Application No. 18/280,550

SEALED BATTERY

Non-Final OA §103
Filed
Sep 06, 2023
Examiner
NEWMAN, DREW C
Art Unit
1751
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Panasonic Energy Co., Ltd.
OA Round
1 (Non-Final)
42%
Grant Probability
Moderate
1-2
OA Rounds
3y 5m
To Grant
75%
With Interview

Examiner Intelligence

Grants 42% of resolved cases
42%
Career Allow Rate
23 granted / 55 resolved
-23.2% vs TC avg
Strong +33% interview lift
Without
With
+33.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 5m
Avg Prosecution
45 currently pending
Career history
100
Total Applications
across all art units

Statute-Specific Performance

§101
0.4%
-39.6% vs TC avg
§103
48.4%
+8.4% vs TC avg
§102
14.8%
-25.2% vs TC avg
§112
29.0%
-11.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 55 resolved cases

Office Action

§103
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. 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. Claim(s) 1- 2 and 4- 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Shinya et al. ( WO - 2019177081 - A1 ; cited in IDS filed 01/29/2025; see attached English translation for citations) in view of Chen et al. (Microstructural Characteristics of a Stainless Steel/Copper Dissimilar Joint Made by Laser Welding; see attached NPL for citations) and as evidenced by The Hutchinson Unabridged Encyclopedia with Atlas and Weather Guide (hereinafter “The Hutchinson Unabridged Encyclopedia”; see attached NPL for citations). Regarding Claim s 1 -2 , Shinya discloses a sealed battery (20, Fig. 1) [0 010 , 0014 ] , comprising: an electrode assembly (22, Fig. 1) obtained by winding a positive electrode (23, Fig. 1) and a negative electrode (24, Fig. 1) with an interposed separator (25, Fig. 1) [0010 , 0016 , 0023 ] ; a bottomed cylindrical outer can (50, Fig. 1) that houses the electrode assembly [0010 , 0021 ] ; and a sealing assembly (sealing body, not shown) that closes an opening of the outer can [0022] , wherein the outer can (50, Fig. 5) and a negative electrode lead (26, Fig. 5) connected to the negative electrode [0018] are welded together at a welded portion (54, Fig. 5) formed from an outer surface of the outer can into the negative electrode lead [0020 , 0035-0036 , 0041 ] , and the outer can is made of a metal containing Fe [0021]. Shinya discloses that the negative electrode lead can be made from a metal containing nickel or copper as a main component, or a metal containing both nickel and copper [0019]. Therefore, although not disclosed in a specific embodiment, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have selected the material of the negative electrode lead to be copper with a reasonable expectation that such a configuration would result in a successful negative electrode lead. Therefore, Shinya renders obvious that “ the negative electrode lead is made of a metal containing Cu as a main component ”. Shinya discloses that the welded portion (54, Fig. 5) is formed of a first molten portion (56, Fig. 5) which does not penetrate the negative electrode lead, and a second molten portion (58, Fig. 5) which penetrates the negative electrode lead and joins the negative electrode lead to the battery can [0020, 0035-0039, 0041-0042]. Shinya also discloses that laser lights are used to form the weld portion [0020, 0037, 0041]. Shinya does not teach the composition of Cu in the weld portion, and therefore does not teach that the “ Cu concentration in the welded portion is 10 % by mass or less ” as required by Claim 1 , or that the “ Cu concentration in the welded portion is 8.6 % by mass or less ” as required by Claim 2 . Chen teaches the microstructural characteristics of a stainless steel/copper dissimilar joint formed by laser welding (Title). Stainless steel is understood to be primarily composed of iron, as evidenced by The Hutchinson Unabridged Encyclopedia (see attached NPL; see also Chen: Pg. 3691: Microstructures of the Welding-Brazing Mode, last paragraph; Pg. 3695: Fig. 9). Chen teaches that microcracks, which have bad effects on mechanical properties, form between stainless steel and copper during laser welding due to a thermal stress mismatch between the differing metals (Pg. 3696: Left column, last two paragraphs). The tendency of microcrack formation is related to the amount of fused copper in the weld zone (Pg. 3696: Left column, last paragraph). When less melted copper is present, the tendency of microcrack formation is lower, while if more melted copper is present, stress mismatch occurs inside the fusion zone which can lead to microcrack formation (Pg. 3696: Left column, last paragraph; Pg. 3696: Conclusions). Chen teaches that it is important to restrict the quantity of fused copper during the laser welding of stainless steel/copper in order to prevent microcrack formation (Pg. 3696: Left column, last paragraph; Pg. 3696: Conclusions). I t would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have restricted the concentration of copper is the weld zone of Shinya in order to prevent microcrack formation as taught by Chen . One of ordinary skill in the art would have been motivated to optimize the concentration of copper in the weld zone, including selecting the concentration of copper to be 8.6 % by mass or less, in order to achieve a balance between minimiz ing the amount of copper present in the weld zone to prevent microcrack formation while ensuring sufficient mixing of the metals such that a reliable joint is formed (MPEP 2144.05, II) . A concentration of copper which is 8.6 % by mass or less is within the range recited in Claim 1 and corresponds to the range recited in Claim 2 . Regarding Claims 4-5 , modified Shiny renders obvious all of the claim limitations as set forth above. Shinya further discloses that the welded portion (54, Fig. 5) is a melted and solidified portion as required by Claim 4 formed by irradiating a laser on the outer surface of the outer can as required by Claim 5 [0020]. Claim(s) 3 is/are rejected under 35 U.S.C. 103 as being unpatentable over Shinya et al. ( WO - 2019177081 - A1 ; cited in IDS filed 01/29/2025; see attached English translation for citations) in view of Chen et al. (Microstructural Characteristics of a Stainless Steel/Copper Dissimilar Joint Made by Laser Welding; see attached NPL for citations) and as evidenced by The Hutchinson Unabridged Encyclopedia with Atlas and Weather Guide (see attached NPL for citations) as applied to Claim 1 above, and in further view of Jeong et al. ( WO-2018056483-A1 ; see English equivalent US-20190198882-A1 cited in IDS filed 01/29/2025 for citations). Regarding Claim 3 , modified Shinya renders obvious all of the limitations as set forth above, including that the negative electrode lead is formed of copper (see rejection of Claim 1 above). Shinya further contemplates that the negative electrode lead can be formed of a metal containing both nickel and copper [0019]. Shinya does not teach that the negative electrode lead has a Ni plating layer on its surface. Jeong teaches a similar sealed battery [0030, 0032, 0041, 0043] including a negative electrode lead (anode tab 125) which is welded to the bottom surface of a battery can [ 0043]. Jeong teaches that a negative electrode lead formed of copper is easily dissolved and is highly brittle, thereby increasing the chance of a short circuit and the defective rate [0045]. In order to overcome the shortcomings of a copper negative electrode lead, Jeong teaches that the negative electrode lead (anode tab 125) can be formed of copper plated with nickel [0046, 0048, 0051, 0055, 0057]. It would have been obvious to one of ordinary skill in the art, before the effective filing date of the claimed invention, to have formed the negative electrode lead of Shinya to have a Ni plating layer on its surface as taught by Jeong with a reasonable expectation that such a configuration would result in a successful negative electrode lead for use in a sealed battery. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT DREW C NEWMAN whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)272-9873 . The examiner can normally be reached FILLIN "Work Schedule?" \* MERGEFORMAT M - F: 10:00 AM - 6:00 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 Jonathan Leong can be reached at FILLIN "SPE Phone?" \* MERGEFORMAT (571)270-1292 . 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. /D.C.N./ Examiner, Art Unit 1751 /JONATHAN G LEONG/ Supervisory Patent Examiner, Art Unit 1751 3/23/2026
Read full office action

Prosecution Timeline

Sep 06, 2023
Application Filed
Mar 13, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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TERMINAL FOR SECONDARY BATTERY AND METHOD FOR MANUFACTURING TERMINAL FOR SECONDARY BATTERY
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POLYMER ELECTROLYTE MEMBRANE AND MEMBRANE ELECTRODE ASSEMBLY COMPRISING SAME
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2y 5m to grant Granted Oct 07, 2025
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
42%
Grant Probability
75%
With Interview (+33.3%)
3y 5m
Median Time to Grant
Low
PTA Risk
Based on 55 resolved cases by this examiner. Grant probability derived from career allow rate.

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