Prosecution Insights
Last updated: April 19, 2026
Application No. 18/281,869

Stored Energy Source Housing, Motor Vehicle, Stored Electrical Energy Source, and Class

Non-Final OA §103
Filed
Sep 13, 2023
Examiner
COCHENOUR, ZACKARY RICHARD
Art Unit
1752
Tech Center
1700 — Chemical & Materials Engineering
Assignee
BAYERISCHE MOTOREN WERKE AKTIENGESELLSCHAFT
OA Round
1 (Non-Final)
79%
Grant Probability
Favorable
1-2
OA Rounds
3y 3m
To Grant
99%
With Interview

Examiner Intelligence

Grants 79% — above average
79%
Career Allow Rate
38 granted / 48 resolved
+14.2% vs TC avg
Strong +33% interview lift
Without
With
+33.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
30 currently pending
Career history
78
Total Applications
across all art units

Statute-Specific Performance

§103
61.5%
+21.5% vs TC avg
§102
16.7%
-23.3% vs TC avg
§112
11.4%
-28.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 48 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 . Election/Restrictions Claim 25-27 and 30-33 withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected group 1, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 11/05/2025. 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) 15-20, 22-24, and 28 is/are rejected under 35 U.S.C. 103 as being unpatentable over Takashina (US 20120164504 A1). Regarding claim 15, Takashina discloses a method for producing an energy store housing (title discloses a power source apparatus, [0010] discloses battery cells, thus reading on energy store, title and [0017] discloses a case for the power source apparatus, thus reading on housing) for a motor vehicle (title), the housing having a top housing part and a bottom housing part (the housing/case for the battery cells can be seen in fig. 4. It can be seen that there is a bottom housing part/baseplate 4 (abstract) and a top housing part/top cover 7 [0043]), the method comprising: Shaping, via bending, a middle portion of the bottom housing part, wherein the middle portion comprises a base element with lateral wall elements that extend along a longitudinal axis, as a result of which, together with the base element, an arrangement space is formed in regions (fig. 4 depicts the various portions of the energy store housing. Notably, base-plate 4 can be understood to be the claimed middle portion of the bottom housing part because it rests on the bottom (as opposed to say, top cover 7 [0043]), comprises a base element with lateral wall elements (4a) that extend along a longitudinal axis and, together with the base element, form the arrangement space for the battery cells 1 ([0010] and fig. 4), and which is shaped via bending ([0054] discloses that the base-plate side walls are bent outward (thus reading on shaping via bending, see also [0059] and [0073])); and including two end portions of the bottom housing, wherein the end portions are arranged at respective longitudinal ends of the middle portion and have wall elements which also form the arrangement space (as can be seen in fig. 4 and is also disclosed by [0011], the housing includes two side plates 6, positioned as end portions of the bottom housing and arranged at respective longitudinal ends of the middle portions and have wall elements which also form the arrangement space, thus reading on the claimed limitation. Takashina does not explicitly disclose the method used to produce the side-plates. As a result, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to turn to known methods in of manufacturing components. While Takashina does not disclose the method of forming the side-plates, Takashina does disclose methods of forming other portions of the housing. For example, [0052] discloses making the cover 8 from die-cast aluminum. [0052] discloses that die-cast aluminum can be made in a complex shape, and thus this method enables the component to be formed into an optimal shape. Takashina additionally discloses that the die-cast aluminum possesses superior thermal emission characteristics, effectively dissipating heat from the internal electrical components. As a result, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to employ the same method of using die-cast aluminum to construct the end plates. A person of ordinary skill in the art before the effective filing date of the claimed invention would have been motivated to do this to obtain a method capable shaping the material into the desired end plates, as well as to obtain a material possessing superior thermal emission characteristics, enabling the effective dissipating of heat from the internal electrical components, and doing this would result in a method meeting all limitations of the instant claim. Regarding claim 16, Takashina discloses the method according to claim 15, wherein the middle portion is a bent plastic and/or metal part ([0052] discloses that the base-plate 4/middle portion can be a metal plate). Regarding claim 17, Takashina discloses the method according to claim 16, wherein the middle portion is an edge-bent metal sheet ([0052] discloses that the middle portion/base-plate 4 may be metal, such as iron or aluminum, and as can be seen in fig. 4, the base-plate as the form of a sheet. [0054] discloses that the base-plate side walls are bent outward, which can be considered bending the edges of the base-plate, thus reading on the middle portion being an edge-bent metal sheet, see also [0059], [0073], and fig. 4). Regarding claim 18, Takashina discloses the method according to claim 15, wherein flange elements are formed adjoining the wall elements and are oriented parallel to the base element and extend away from the arrangement space parallel to the base element ([0054] discloses that the base-plate 4 side wall edges are bent outward (flanged) to establish cover-attachment surfaces 4a in a horizontal plane, these surfaces reading as the claimed flange elements and which are formed adjoining the wall elements and are oriented parallel to the base element and extend away from the arrangement space parallel to the base element, thus satisfying the limitations of the instant claim). Regarding claim 19 and 20, Takashina discloses the method according to claim 18, wherein at least one fastening element is formed on the flange elements (abstract discloses a sealing material 15 formed on the flanges/cover-attachment-surfaces 4a. The sealing material serves the purpose of sealing the base-plate and the cover-plate together, and therefore can be considered a fastening element. This arrangement results in the top housing being fastened to the wall elements and/or flange elements, also satisfying the limitations of claim 20). Regarding claim 22 and 23, Takashina discloses the method according to claim 15, wherein the end portions are connected to the middle portion in a materially bonded manner along a joining plane, and the joining plane is sealed ([0011] discloses that the end portions/side plates 6 are provided to close off open ends of the cover-plate and the base-plate, thus reading on connected to the middle portion. [0011] further discloses sealing pieces which seal gaps between the side-plates and the attachment surfaces of the cover and base plates, resulting in a sealed arrangement dust cannot penetrate, thus reading on the joining plane being sealed. The side plates themselves extend perpendicular to the base element and are flat. The sealing occurs along the surfaces of the side plates, which can be reasonably interpreted as the claimed joining plane, thus reading on the limitations of claims 22 and 23). Regarding claim 24, Takashina discloses the method according to claim 15, wherein the arrangement space is formed free of barriers, and a multiplicity of energy storage cells are arranged in the arrangement space so as to fill the space (see fig. 4, where it can be seen that the arrangement space is free of barriers, and that battery cells 1 fill the arrangement space). Regarding claim 28, Takashina discloses an electrical energy store comprising an energy store housing produced to claim 15 ([0010] discloses an electrical energy store which is, for example, a plurality of battery blocks having a plurality of battery cells). Claim(s) 21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Takashina (US 20120164504 A1), in view of Isern (ES 2750579 T3). Regarding claim 21, Takashina discloses the method according to claim 15, and discloses producing the end portions via die casting (see claim 1 rejection above), but does not disclose that the end portions are produced as one part, by die casting. However, producing multiple die cast components as one part and then separating them later is known in the die casting art and would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention. For example, Isern discloses a process of forming partition walls via a die casting process, wherein the partition walls are all formed in one piece and are later separated by a cutting process after the casting is complete (pg. 3, paragraph 2). As a result of this disclosure, It would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to do the same when creating the end plates of Takashina. The end plates of Takashina are similar to walls, serving as vertical plates to block (seal) the inside of the case from the outside, and further, performing the die casting in one step with later separation would come with inherent motivating advantages, such as being able to perform the die casting in one step (avoiding the need to obtain additional molds to perform separate die castings at the same time or to spend extra time reusing the first mold to create the second end plate after waiting for the first die casting to finish), and would have been obvious in light of the fact that such practices were known in the die casting art. Isern is considered analogous to the claimed invention because they both address the same problem, namely efficient die casting of multiple pieces via a one piece formation which is later separated. Claim(s) 29 is/are rejected under 35 U.S.C. 103 as being unpatentable over Takashina (US 20120164504 A1), in view of Rittner (US 20180183114 A1). Regarding claim 29, Takashina discloses a method for producing an energy store housing (title discloses a power source apparatus, [0010] discloses battery cells, thus reading on energy store, title and [0017] discloses a case for the power source apparatus, thus reading on housing), the method comprising: Shaping, via bending, a middle portion of the bottom housing part, wherein the middle portion comprises a base element with lateral wall elements that extend along a longitudinal axis, as a result of which, together with the base element, an arrangement space is formed in regions (fig. 4 depicts the various portions of the energy store housing. Notably, base-plate 4 can be understood to be the claimed middle portion of the bottom housing part because it rests on the bottom (as opposed to say, top cover 7 [0043]), comprises a base element with lateral wall elements (4a) that extend along a longitudinal axis and, together with the base element, form the arrangement space for the battery cells 1 ([0010] and fig. 4), and which is shaped via bending ([0054] discloses that the base-plate side walls are bent outward (thus reading on shaping via bending, see also [0059] and [0073])); and including two end portions of the bottom housing, wherein the end portions are arranged at respective longitudinal ends of the middle portion and have wall elements which also form the arrangement space (as can be seen in fig. 4 and is also disclosed by [0011], the housing includes two side plates 6, positioned as end portions of the bottom housing and arranged at respective longitudinal ends of the middle portions and have wall elements which also form the arrangement space, thus reading on the claimed limitation. Takashina does not explicitly disclose the method used to produce the side-plates. As a result, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to turn to known methods in of manufacturing components. While Takashina does not disclose the method of forming the side-plates, Takashina does disclose methods of forming other portions of the housing. For example, [0052] discloses making the cover 8 from die-cast aluminum. [0052] discloses that die-cast aluminum can be made in a complex shape, and thus this method enables the component to be formed into an optimal shape. Takashina additionally discloses that the die-cast aluminum possesses superior thermal emission characteristics, effectively dissipating heat from the internal electrical components. As a result, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to employ the same method of using die-cast aluminum to construct the end plates. A person of ordinary skill in the art before the effective filing date of the claimed invention would have been motivated to do this to obtain a method capable shaping the material into the desired end plates, as well as to obtain a material possessing superior thermal emission characteristics, enabling the effective dissipating of heat from the internal electrical components, and doing this would result in a method meeting all limitations of the instant claim. Takashina does not explicitly disclose producing a series of energy store housings, however, it would be obvious to the skilled artisan having produced one satisfactory energy store housing as disclosed by Takashina to, should need arise, produce another by the same method. A person of ordinary skill would find this obvious and would be motivated to do it in order to enable easy construction of multiple battery modules via a known and verified method. Takashina does not explicitly disclose adjusting a width and length of the series of energy store housings by differently bent middle portions, however this is known in the prior art and would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention. First, it is a common and known practice in the art to adjust the size of power storage elements according to the needs of the manufacturer. For example, an electric vehicle would require a larger power storage element than comparatively smaller motorized bike. Therefore, when designing a energy store housing, a person of ordinary skill in the art would seek to adjust the size and scope of the housing, depending on the amount and volume of the power storage elements to be included within. Because the accommodation space of Takashina is formed and defined by bending a metal sheet to form the bottom housing part, including wall and base elements, by adjusting the locations where the bottom housing is bent, it would be possible to adjust the size of the accommodation space, including selecting different widths and lengths for the space. Further, such practice was known in the art before the effective filing date of the claimed invention. For example, Rittner discloses a method of sizing a hollow section of a battery module to receive cells, including bending the hollow section such that the complete length and width of the battery cell can be inserted into the individual compartments [0064]. As a result of this teaching, a person of ordinary skill in the art before the effective filing date of the claimed invention would similarly find it obvious to alter the way the housing of Takashina is bent, as it is formed and shaped by bending, in order to adjust the size and scope of the housing to fit the needs at hand. Rittner is considered analogous to the claimed invention because they are both in the same field of endeavor, namely energy storage element housing construction. A person of ordinary skill in the art before the effective filing date of the claimed invention would be motivated to do this to obtain an easy way to adjust the method of Takashina to accommodate differently sized and shaped electric storage elements, and doing so would result in a method meeting the limitations of the instant claim. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZACKARY R COCHENOUR whose telephone number is (703)756-1480. The examiner can normally be reached 1-9:00PM ET. 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, Nicholas Smith can be reached at (571) 272-8760. 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. /ZACKARY RICHARD COCHENOUR/Examiner, Art Unit 1752 /NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
Read full office action

Prosecution Timeline

Sep 13, 2023
Application Filed
Feb 02, 2026
Non-Final Rejection — §103 (current)

Precedent Cases

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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
79%
Grant Probability
99%
With Interview (+33.3%)
3y 3m
Median Time to Grant
Low
PTA Risk
Based on 48 resolved cases by this examiner. Grant probability derived from career allow rate.

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