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 .
Continued Examination Under 37 CFR 1.114
A request for continued examination under 37 CFR 1.114, including the fee set forth in 37 CFR 1.17(e), was filed in this application after final rejection. Since this application is eligible for continued examination under 37 CFR 1.114, and the fee set forth in 37 CFR 1.17(e) has been timely paid, the finality of the previous Office action has been withdrawn pursuant to 37 CFR 1.114. Applicant's submission filed on 16 March 2026 has been entered.
Claim Objections
Claim 13 is objected to because of the following informalities: Regarding Claim 13, at line 2, “including” should read “includes”. Appropriate correction is required.
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 16 is 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.
Regarding Claim 16, it is unclear what is the “%” basis being claimed at line 2. Is this by volume, by mass, or something else?
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:
Determining the scope and contents of the prior art.
Ascertaining the differences between the prior art and the claims at issue.
Resolving the level of ordinary skill in the pertinent art.
Considering objective evidence present in the application indicating obviousness or nonobviousness.
Claim(s) 6-14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Smith et al. in “Hot-Dip Coatings” in Reference Module in Materials Science and Materials Engineering, 1 Jan. 2017, pages 2556-2576 (cited on IDS filed 20240307, NPL No. A26) in view of Weber USPA 2011/0162820. Smith teaches galvalume coated steel sheet having 55 wt. % Al, 43.5 wt. % Zn, and 1.5 wt. % Si (Sec. 5.1, page 9, lines 8-15). Bethlehem Steel Data Sheet explains that percentages are weight percentages (page 1, middle). Smith teaches sheets can be used in variety of applications that would be expected to have sizes suitable for battery (Table 5) although Smith may not teach battery applications and Smith teaches that zinc/aluminum coatings provide protection from wide variety of types of corrosion, including corrosion due to liquid exposures (Section 2). Weber teaches cooling plate for battery pack (Figures 4 and 6; and paragraphs 4, 8, and 9). Weber teaches that aluminum, coated steel, stainless steel, galvanized steel, and corrosion resistant steel may be used to prepare fin (118) and frame (120) (Paragraph 24; Figure 5). The frame 118 surrounds the coolant channel 108 in Figure 5 (paragraphs 19 and 20). The coolant that flows through channel (108) can be a liquid coolant (paragraphs 20 and 34). This may be considered cooling system for battery pack. It would have been obvious to one of ordinary skill in the art before the time of filing to prepare Smith’s sheet for battery pack cooling system (Claim 6) and battery pack (Claim 10) since Smith teaches that Smith’s sheet are suitable for vast array of applications and provide protection from a vast array of corrosive agents and since Weber teaches that comparable coated steel sheets are suitable for battery pack cooling system and battery pack. Regarding Claim 8, Smith teaches range of coating thicknesses 7 to 42 microns (Sec. 1). It would have been obvious to one of ordinary skill in the art before the time of filing to prepare coating with any of suggested thicknesses as providing effective protection. Regarding Claim 9, Bethlehem steel teaches that galvalume coating having 0.50 oz/sq ft coating weight both sides equates to 0.8 mil per side (20 microns). This coating weight is equivalent to 157 grams per square meter. Thus, the suggested thicknesses of ca. 20 microns on one or on both sides leads to claimed coating weight. Regarding Claim 11, Weber teaches that effective thickness can be 0.05 to 1.0 mm (paragraph 20; 118), which substantially overlaps claimed range, rendering it obvious. Regarding Claim 12, Weber teaches that both 118 and 120 can be galvanized steel (paragraph 24), which renders obvious claimed limitation since the claimed alloy for the galvanized steel coating layer is rendered obvious for the reasons addressed above with respect to Claim 6. Regarding Claim 13, Weber teaches that channels 108 can be effectively formed by stamping (paragraph 35). This is understood to suggest that 120 and 118 at the channel 108 can be shaped by stamping (Figure 5). Accordingly, the stamped duct feature is rendered obvious in Weber with respect to either 120 or 118. Even if the channel were not formed by stamping, as is evident in the structure of Figure 5, the channel would be indistinguishable from a stamped channel. Furthermore, the requirement that the “further metallic coated steel sheet” being flat to close the duct is evident in the channel structure of Figure 5. Associating 120 with the “further” sheet, it is clear that 120 is flat where it is joined to 118 and where the arrow for “108” is positioned. Thus, the claimed feature is rendered obvious. Regarding Claim 14, the claimed contact line is evident at 122 in Figure 5 (paragraph 23), rendering obvious this feature.
Claim(s) 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Smith et al. in “Hot-Dip Coatings” in Reference Module in Materials Science and Materials Engineering, 1 Jan. 2017, pages 2556-2576 (cited on IDS filed 20240307, NPL No. A26) in view of Weber USPA 2011/0162820 in view of Mizrahi USPN 9,115,264. Smith in view of Weber is relied upon as set forth above in the section 103 rejection over Smith in view of Weber. Smith in view of Weber does not suggest resistance seam welding, although Weber teaches that seam can be laser welded or by other means (paragraph 23). Mizrahi teaches that resistance seam welding is an effective manner of conventional joining as an alternative to laser welding, particularly due to speed of application (col, 9, lines 40-58). It would have been obvious to one of ordinary skill in the art before the time of filing to join the plates in Smith in view of Weber by resistance seam welding since Weber specifically suggests laser welding, since Weber suggests other means as desired can be used, and since Mizrahi teaches that conventional alternatives to laser welding include resistance welding. It would be expected that the sheets would be effectively joined by utilizing resistance seam welding.
Claim(s) 13, 14, and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Smith et al. in “Hot-Dip Coatings” in Reference Module in Materials Science and Materials Engineering, 1 Jan. 2017, pages 2556-2576 (cited on IDS filed 20240307, NPL No. A26) in view of Weber USPA 2011/0162820 in view of Tasiopoulos USPA 2019/0229384. Smith in view of Weber is relied upon as set forth above in the section 103 rejection over Smith in view of Weber. Regarding Claim 13, Smith in view of Weber does not suggest completely flat “further” sheet structure. Tasiopoulos teaches such completely flat “further” sheet is effective for forming cooling channel (Figure 2; paragraph 18). It would have been obvious to one of ordinary skill in the art before the time of filing to provide the “further” sheet as completely flat as Tasiopoulos teaches effective cooling channel can have this form. In other words, in Weber Figure 5, 120 can be completely flat without bulge to 108. Regarding Claim 14, the claimed contact line is evident at 122 in Figure 5 (paragraph 23), rendering obvious this feature. Regarding Claim 16, Smith in view of Weber does not suggest glycol coolant although Weber teaches gas or liquid coolants can be used (paragraph 34). Tasiopoulos teaches that battery coolant can effectively be glycol (paragraph 18) or any other coolant. This teaching is understood to mean 100 % glycol or a suggestion to use 100% glycol since only glycol is referred to. It would have been obvious to one of ordinary skill in the art before the time of filing to use known coolant in the battery of Smith in view of Weber since Weber teaches that any effective liquid coolant can be used and since Tasiopoulos teaches or suggests that glycol (100% glycol) can be used effectively as well as any other coolant desired. It would be expected that use of 100% glycol in the battery of Smith in view of Weber would effectuate cooling.
Claim(s) 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Smith et al. in “Hot-Dip Coatings” in Reference Module in Materials Science and Materials Engineering, 1 Jan. 2017, pages 2556-2576 (cited on IDS filed 20240307, NPL No. A26) in view of Weber USPA 2011/0162820 in view of Tasiopoulos USPA 2019/0229384 in view of Mizrahi USPN 9,115,264. Smith in view of Weber in view of Tasiopoulos is relied upon as set forth above in the section 103 rejection over Smith in view of Weber in view of Tasiopoulos. Smith in view of Weber in view of Tasiopoulos does not suggest resistance seam welding, although Weber teaches that seam can be laser welded or by other means (paragraph 23). Mizrahi teaches that resistance seam welding is an effective manner of conventional joining as an alternative to laser welding, particularly due to speed of application (col, 9, lines 40-58). It would have been obvious to one of ordinary skill in the art before the time of filing to join the plates in Smith in view of Weber in view of Tasiopoulos by resistance seam welding since Weber specifically suggests laser welding, since Weber suggests other means as desired can be used, and since Mizrahi teaches that conventional alternatives to laser welding include resistance welding. It would be expected that the sheets would be effectively joined by utilizing resistance seam welding.
Response to Amendment
In view of applicant’s amendments and arguments, applicant traverses the section 112, paragraph (b) rejection of the Office Action mailed on 16 December 2025. Rejection is withdrawn.
In view of applicant’s amendments and arguments, applicant traverses the section 103 rejection over Smith in view of Weber of the Office Action mailed on 16 December 2025. Applicant argues that Smith does not teach use in battery pack. Smith teaches that Smith’s coatings are effective for corrosion resistance in numerous environments including for exposure to water and organic liquid (Sections 2.3 and 2.5). While Smith teaches a handful of Zn-based coatings, Smith teaches they are all generally effective, the highlighted alloy (55Al-43.5Zn-1.5Si) is taught as being especially suitable for coating strips (Section 5.1), which is what would be used in making Weber’s coated steel channel material. Weber’s channel is described as containing liquid coolant (paragraph 20), which would be expected to be water and/or organic liquid based. Weber teaches that the corrosion resistant material (120) that forms the channel (108) can be galvanized steel (paragraph 24). Weber teaches that galvanized steel is suitable as corrosion resistant material for battery pack. So, Smith can be viewed as providing blaze marks to a specific coating composition for corrosion resistant galvanized steel to be exposed to liquid as taught as being required in Weber. As well, obviousness is supported by KSR Rationale B. See MPEP 2143(I)(B). In this case Weber contains the claimed battery pack except for galvanized steel composition element for corrosion protection in liquid environment. Smith teaches galvanized steel composition element for corrosion protection in liquid environment. One of ordinary skill could have readily substituted the generic galvanized steel with the specific galvanized steel of Smith with the confident prediction that the substituted steel would provide comparable structural and corrosion protection performance. Applicant argues that Smith in view of Weber fails to recognize any benefit which applicant’s evidence demonstrates. Applicant’s evidence is not commensurate with the breadth of the claims. For example, the claims are not limited by alloy composition, not limited by presence of alloy composition in contact with liquid, at least for many claims, and not limited by liquid composition. Rejections are maintained.
In view of applicant’s amendments and arguments, applicant traverses the section 103 rejection over Bethlehem Steel Data Sheet in view of Weber of the Office Action mailed on 16 December 2025. Rejection is withdrawn.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MICHAEL E. LA VILLA whose telephone number is (571)272-1539. The examiner can normally be reached Mon. through Fri. from 9:00 a.m. ET to 5:30 p.m. ET.
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/MICHAEL E. LA VILLA/Primary Examiner, Art Unit 1784
22 April 2026
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