Prosecution Insights
Last updated: April 19, 2026
Application No. 18/281,368

SEALED BATTERY, AND BATTERY PACK USING SAME

Non-Final OA §102§103
Filed
Sep 11, 2023
Examiner
WILLS, MONIQUE M
Art Unit
1723
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Panasonic Energy Co., Ltd.
OA Round
1 (Non-Final)
86%
Grant Probability
Favorable
1-2
OA Rounds
2y 10m
To Grant
54%
With Interview

Examiner Intelligence

Grants 86% — above average
86%
Career Allow Rate
1354 granted / 1580 resolved
+20.7% vs TC avg
Minimal -32% lift
Without
With
+-31.7%
Interview Lift
resolved cases with interview
Typical timeline
2y 10m
Avg Prosecution
53 currently pending
Career history
1633
Total Applications
across all art units

Statute-Specific Performance

§101
0.2%
-39.8% vs TC avg
§103
58.8%
+18.8% vs TC avg
§102
19.4%
-20.6% vs TC avg
§112
17.3%
-22.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 1580 resolved cases

Office Action

§102 §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. Information Disclosure Statement The information disclosure statements filed September 11, 2023 has/have been received and complies with the provisions of 37 CFR 1.97, 1.98 and MPEP § 609. Accordingly, the information disclosure statement(s) is/are being considered by the examiner, and an initialed copied is attached herewith. Claim Rejections - 35 USC § 102 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. Claim(s) 1 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Hermann et al. US-20100316894 -A1 . With respect to claim 1 , Hermann teaches a sealed battery (400; Fig. 4 below) , comprising: a bottomed cylindrical outer housing can ( cylindrical outer housing can ; Fig. 4 below) that houses an electrode assembly ( electrode assembly inside cylindrical outer housing can ; Fig. 4 below) ; and a sealing assembly that closes an opening of the outer housing can ( sealing assembly ; Fig. 4 below) , wherein the sealing assembly has a current interruption mechanism ( current interruption mechanism is the interruptible electrical connector ; [0008]) that seals the electrode assembly in cooperation with the outer housing can and is activated sensitive to a gas pressure in the battery ( current interruption mechanism ; [0008]) and a cap that forms a sealed space above the current interruption mechanism ( cap is scored at 403; [0039] and thus sealed and ruptures under pressure; region to which the interconnect is coupled is scored as described to promote venting; [0039] – [0040] ; Fig. 4 below) , and the cap has an explosion-proof vent that opens sensitive to a gas pressure in the sealed space ( explosion-proof vent ; [0039] – [0040] ; Fig. 4 below) . Therefore, Hermann anticipates the instant claim. 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. Claim (s) 2 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hermann et al. US-20100316894 -A1 . Hermann teaches a sealed battery , wherein a sealing assembly has a current interruption mechanism ( current interruption mechanism is the interruptible electrical connector ; [0008]) ,, as described in the rejection above. Hermann does not expressly disclose: sensitive characteristics of the current interruption mechanism and the explosion-proof vent are adjusted so that the explosion-proof vent is activated after the current interruption mechanism is activated ( claim 2 ) . However , it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to employ sensitive characteristics of the current interruption mechanism and the explosion-proof vent are adjusted so that the explosion-proof vent is activated after the current interruption mechanism is activated in the sealing assembly of Hermann in order to increase the s pee d of cell deactivation. The skilled artisan recognizes that t he pressure sensitivity ma y b e controlled by thickness of scoring, thickness and type of materials , with three outcomes : simultaneous rupture, first current interruption rupture or first explosion-proof vent rupture. Therefore, unless there is some unobvious benefit, the order of rupture is obvious. A change in size is generally recognized as being within the level of ordinary skill in the art. In re Rose, 105 USPQ 237 (CCPA 1955). 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. Claim (s) 3 -5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hermann et al. US-20100316894-A1 in view of ZHAO et al . CN-110071245-A. Hermann teaches a sealed battery, wherein a sealing assembly has a current interruption mechanism ( current interruption mechanism is the interruptible electrical connector ; [0008]) ,, as described in the rejection above. Hermann does not expressly disclose: positive electrode terminals of the plurality of sealed batteries are aligned and arranged in one direction in the battery pack ( claim 3 ); a closed gas discharge pathway is further included in the battery pack in which the positive electrode terminals of the plurality of sealed batteries are arranged ( claim 4 ); . the gas discharge pathway includes a gas discharge vent that opens when gas is discharged from the sealed battery and a pressure in the battery pack rises ( claim 5 ). H owever, ZHAO teaches that it is well known in the art to employ: positive electrode terminals of the plurality of sealed batteries are aligned and arranged in one direction in the battery pack ( all the batteries are oriented in the same direction; It is reasonable to expect all terminals similarly positioned: Fig. 1; claim 3 ); a closed gas discharge pathway is further included in the battery pack in which the positive electrode terminals of the plurality of sealed batteries are arranged ( a closed gas discharge pathway 7 i ncludes waterproof ventilation valve (6) : Fig. 1 & teaching claim 10; Examiners Note: valves function by opening and closing; waterproof implies some close off function; claim 4 ); the gas discharge pathway includes a gas discharge vent that opens when gas is discharged from the sealed battery and a pressure in the battery pack rises ( a closed gas discharge pathway 7 i ncludes waterproof ventilation valve (6) : Fig. 1 & teaching claim 10; Examiners Note: valves function by opening and closing; waterproof implies some close off function; claim 5 ). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to employ positive electrode terminals of the plurality of sealed batteries are aligned and arranged in one direction in the battery pack (all the batteries are oriented in the same direction; It is reasonable to expect all terminals similarly positioned: Fig. 1; claim 3 ); as suggested by ZHAO , in the battery pack of Hermann , in order to incase accessibility of power. The skilled artisan recognizes that orientation of terminals facilitates access to load demands. Also, rearrangement of essential working parts of a device is prima facie obvious. See In re Japikse , 181 F.2d 1019, 86 USPQ 70 (CCPA 1950). The Courts have held that claims directed to apparatus must be distinguished from the prior art in terms of structure rather than function. In re Danly , 263 F.2d 844, 847, 120 USPQ 528, 531 (CCPA 1959); Hewlett-Packard Co. v. Bausch and Lomb, Inc. , 15 USPQ2d 1525, 1528 (Fed. Cir. 1990); See also MPEP §§2114 and 2173.05(g). Furthermore, the manner of operating the device does not differentiate an apparatus claim from the prior art. A claim containing a “recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus” if the prior art apparatus teaches all the structural limitations of the claim. Ex parte Masham , 2 USPQ2d 1647 (Bd. Pat. App. & Inter. 1987). Therefore, because the structure of the terminal of Hermann in view of ZHAO teach all the structural limitations of the claim, one of ordinary skills in the art can use the terminal of Hermann in view of ZHAO to operate it in the manner disclosed by the Applicant. 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. Claim (s) 3 -5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Hermann et al. US-20100316894-A1 in view of KIM et al . KR-20180039986-A . Hermann teaches a sealed battery, wherein a sealing assembly has a current interruption mechanism ( current interruption mechanism is the interruptible electrical connector ; [0008]) ,, as described in the rejection above. Hermann does not expressly disclose: positive electrode terminals of the plurality of sealed batteries are aligned and arranged in one direction in the battery pack ( claim 3 ); a closed gas discharge pathway is further included in the battery pack in which the positive electrode terminals of the plurality of sealed batteries are arranged ( claim 4 ); . the gas discharge pathway includes a gas discharge vent that opens when gas is discharged from the sealed battery and a pressure in the battery pack rises ( claim 5 ). However, KIM teaches that it is well known in the art to employ: a closed gas discharge pathway is further included in the battery pack in which the positive electrode terminals of the plurality of sealed batteries are arranged ( venting valve 40 connected to the venting part 15 normally closes the venting part 15 and is opened when the venting gas leaks from the secondary battery and the internal pressure of the battery pack 50 rises above the maximum reference value ; DESCRIPTION-OF-EMBODIMENTS, paragraph 9, Fig. 11 below: claim 4 ); the gas discharge pathway includes a gas discharge vent that opens when gas is discharged from the sealed battery and a pressure in the battery pack rises ( venting valve 40 connected to the venting part 15 normally closes the venting part 15 and is opened when the venting gas leaks from the secondary battery and the internal pressure of the battery pack 50 rises above the maximum reference value ; DESCRIPTION-OF-EMBODIMENTS, paragraph 9, Fig. 11 below: claim 5 ). Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to employ gas discharge pathway includes a gas discharge vent that opens when gas is discharged from the sealed battery and a pressure in the battery pack rises ( claim 5 ); as suggested by KIM , in the battery pack of Hermann , in order to relieve pressure from individual cells to the outside of the battery back. With respect to the positive electrode terminals of the plurality of sealed batteries being aligned and arranged in one direction in the battery pack ( claim 3 ); it would have been obvious in the battery pack of Hermann in view of KIM, in order to incase accessibility of power. The skilled artisan recognizes that orientation of terminals facilitates access to load demands. Also, rearrangement of essential working parts of a device is prima facie obvious. See In re Japikse , 181 F.2d 1019, 86 USPQ 70 (CCPA 1950). The Courts have held that claims directed to apparatus must be distinguished from the prior art in terms of structure rather than function. In re Danly , 263 F.2d 844, 847, 120 USPQ 528, 531 (CCPA 1959); Hewlett-Packard Co. v. Bausch and Lomb, Inc. , 15 USPQ2d 1525, 1528 (Fed. Cir. 1990); See also MPEP §§2114 and 2173.05(g). Furthermore, the manner of operating the device does not differentiate an apparatus claim from the prior art. A claim containing a “recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus” if the prior art apparatus teaches all the structural limitations of the claim. Ex parte Masham , 2 USPQ2d 1647 (Bd. Pat. App. & Inter. 1987). Therefore, because the structure of the terminal of Hermann in view of KIM teach all the structural limitations of the claim, one of ordinary skills in the art can use the terminal of Hermann in view of KIM to operate it in the manner disclosed by the Applicant. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to FILLIN "Examiner name" \* MERGEFORMAT MONIQUE M WILLS whose telephone number is FILLIN "Phone number" \* MERGEFORMAT (571)272-1309 . The Examiner can normally be reached on Monday-Friday from 8:30am to 5:00 pm. If attempts to reach the examiner by telephone are unsuccessful, the Examiner's supervisor, Tiffany Legette, may be reached at 571-270-7078 . The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://portal.uspto.gov/external/portal. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). /Monique M Wills/ Examiner, Art Unit 172 2 /TIFFANY LEGETTE/ Supervisory Patent Examiner, Art Unit 1723
Read full office action

Prosecution Timeline

Sep 11, 2023
Application Filed
Mar 12, 2026
Non-Final Rejection — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12603269
CATHODE ACTIVE MATERIAL DEHYDRATION APPARATUS USING ELECTROOSMOSIS, AND DEHYDRATION EQUIPMENT COMPRISING DEHYDRATION APPARATUS
2y 5m to grant Granted Apr 14, 2026
Patent 12597651
Hydrometallurgical Recycling of Lithium-Ion Battery Electrodes
2y 5m to grant Granted Apr 07, 2026
Patent 12592453
Multi-Layer Solid Electrolyte Separator for a Lithium Secondary Battery and Manufacturing Method
2y 5m to grant Granted Mar 31, 2026
Patent 12586820
ELECTROLYTE FOR LITHIUM SECONDARY BATTERIES COMPRISING IONIC LIQUID AND COSOLVENT AND LITHIUM SECONDARY BATTERY COMPRISING THE SAME
2y 5m to grant Granted Mar 24, 2026
Patent 12583988
Crosslinked Polyolefin Separator and Manufacturing Method Therefor
2y 5m to grant Granted Mar 24, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

AI Strategy Recommendation

Get an AI-powered prosecution strategy using examiner precedents, rejection analysis, and claim mapping.
Powered by AI — typically takes 5-10 seconds

Prosecution Projections

1-2
Expected OA Rounds
86%
Grant Probability
54%
With Interview (-31.7%)
2y 10m
Median Time to Grant
Low
PTA Risk
Based on 1580 resolved cases by this examiner. Grant probability derived from career allow rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month