Prosecution Insights
Last updated: October 25, 2026
Application No. 18/301,472

BATTERY MODULE

Non-Final OA §103§112
Filed
Apr 17, 2023
Examiner
BROWN, SANDRA LASHAUN
Art Unit
1726
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Fca US LLC
OA Round
1 (Non-Final)
Grant Probability
Favorable
1-2
OA Rounds

Examiner Intelligence

Grants only 0% of cases
0%
Career Allowance Rate
0 granted / 0 resolved
-65.0% vs TC avg
Minimal +0% lift
Without
With
+0.0%
Interview Lift
resolved cases with interview
Typical timeline
Avg Prosecution
10 currently pending
Career history
11
Total Applications
across all art units
This examiner has no resolved cases yet (career too new); statute-level performance unavailable. The Grant Probability card shows Tech Center averages instead.

Office Action

§103 §112
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 Applicant’s election without traverse of Invention I, in the reply filed on 08 June 2026 is acknowledged. Claims 9-19 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected solid-state battery module, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 08 June 2026. Status of Claims Claims 1-8 are pending in the current application and under consideration on the merits. 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 5 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 5 recites the limitation “a chosen thickness to accommodate manufacturing variability” renders the claim indefinite. It is unclear what the chosen thickness of the spacer plates and/or housing needs to be to accommodate the manufacturing variability and what manufacturing variability is being controlled based on the thickness. Given the broadest reasonable interpretation in view of DeKeuster as discussed below regarding claim 5, the retaining walls are used to fill the gaps between the cell stack and the housing and to maintain a sufficient compression force on the cell stack (col. 10, lines 36-42). The retaining walls also may not necessarily be the same size, shape, or material depending on their location within the battery module (col. 10, lines 57-59). The housing may be sized to a maximum allowable tolerance for a desired number of battery cells (col. 9, lines 59-66) in order to maintain a desired compression force on the battery cell stack (col. 10, lines 21-26) or may be sized such that there is a gap present between the interior surface of the housing and the cell stack (col. 10, lines 31-34). For examination on the merits, claim 5 is interpreted wherein the spacer plates and/or housing can have any thickness in order to provide a sufficient amount of compression force to the solid-state battery cell stack. In order to overcome the indefiniteness issue, it is suggested to clarify a chosen thickness and what manufacturing variability the thickness related to. Appropriate correction is required. 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: 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. Claims 1-2 and 5-6 is rejected under 35 U.S.C. 103 as being unpatentable over DeKeuster et al. (US 9911951 B2, "DeKeuster"), in view of Lee et al. (US 20240234901 A1, "Lee"). Regarding claim 1, DeKeuster discloses a method for manufacturing a battery module including providing a housing (see FIG. 3, housing 62, col. 8, lines 11-19) for packing or containing a plurality of battery cells that are arranged in a cell stack (see FIG. 4, cell stack 92, col. 9, lines 12-13) before introduction into the housing (col. 9, lines 12-13). The cell stack is compressed by a clamping mechanism (col. 15, lines 31-61). Once compressed, the cell stack is inserted into the housing (col. 15, lines 62-67) and the clamping mechanism is removed from the battery module (col. 16, lines 1-7). The method further includes maintaining a compression force on the compressed cell stack using the housing (col.3, lines 13-20). DeKeuster is silent regarding the module being a solid-state battery module. Lee discloses solid-state battery module (see FIG. 2, battery module 100, para. [0057]) comprising a pack case (see FIG. 2, pack case 1100, e.g. housing, para. [0057], para. [0112]). Lee further discloses that compression is useful for solid-state batteries as the degree of swelling is greater in order to exhibit battery performance (para. [0011]). DeKeuster and Lee each disclose each constitute prior art which is analogous to the claimed invention – a method for manufacturing a battery module and a solid-state battery module. It would have been obvious, before the effective filing date of the claimed invention, to have modified the battery module of DeKeuster by using solid-state batteries in order to realize a higher capacity battery pack (Lee, para. [0011]). Regarding claim 2, DeKeuster discloses that the top portion of the battery module is fitted with a top cover (e.g. reinforcement cover, ref. #73, col. 8, lines 15-19). As shown in FIG. 3, the top cover encloses the battery cell stack. Given that the top cover encloses the battery cell stack, it is inherent that the cover would also protect that battery cell stack and provide more structural rigidity as any covering would naturally facilitate enclosing, protecting, and providing rigidity. Regarding claim 5, DeKeuster discloses one or more spacers and/or retaining walls (see FIG. 4, spacer 94 and/or retaining walls 100, e.g. spacer plates, col. 9, lines 57-67, col. 10, lines 31-48, and col. 13, lines 1-11) that are arranged between each battery cell and at the end (shown below in FIG. 4, ends 102, col. 9, lines 13-16) of the cell stack before being compressed and inserted into the housing (col. 9, lines 57-67). Regarding claim 6, Lee further discloses that a high pressure of at least 1-5 MPa is applied to the solid-state battery to exhibit battery performance (para. [0103]). DeKeuster and Lee each disclose each constitute prior art which is analogous to the claimed invention – a method for manufacturing a battery module and a solid-state battery module. It would have been obvious, before the effective filing date of the claimed invention, to apply a pressure in a range of 1 MPa to 5 MPa to the solid-state battery as that it’s the typical force required to compress solid-state batteries. PNG media_image1.png 544 726 media_image1.png Greyscale Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over DeKeuster in view of Lee as applied to claim 2 above, and further in view of Ge et al. (US 20060121338 A1, "Ge"). Regarding claim 3, DeKeuster in View of Lee discloses the method of claim 2 as discussed above. DeKeuster in view of Lee is silent regarding wherein said attaching the reinforcement cover includes inserting a flange of the reinforcement cover into a slot formed in the housing. Ge discloses a battery assembly comprising a housing (see FIG. 1, housing 40, para. [0021]) and a cover (see FIG. 2, cover 10, e.g. top reinforcement cover, para. [0021]) wherein the cover includes catches (see FIG. 2, catch 221, e.g. flange, para. [0021]). The housing comprises catch slots (see FIG. 2, catch slots 422, e.g. slots, para. [0021]). The cover is pressed downwardly so that the catches are engaged in the catch slots (para. [0021]). DeKeuster, Lee, and Ge each disclose each constitute prior art which is analogous to the claimed invention – a method for manufacturing a battery module and a battery module. It would have been obvious, before the effective filing date of the claimed invention, to have modified the top cover of Lee and the housing of DeKeuster to comprise the catches and catch slots of Ge in order to securely attach the housing (Ge, para. [0021]). Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over DeKeuster in view of Lee as applied to claim 2 above, and further in view of Matecki et al. (US 20180050607 A1, "Matecki"). Regarding claim 4, DeKeuster in View of Lee discloses the method of claim 2 as discussed above. DeKeuster in view of Lee is silent regarding wherein said attaching the reinforcement cover includes attaching a top reinforcement cover to a top side of the housing and attaching a bottom reinforcement cover to a bottom side of the housing. Matecki discloses a battery support structure (see FIG. 3, battery support structure 10, e.g. housing, para. [0038]) for supporting and protecting battery modules (para. [0038]) comprising a battery containment area (see Fig. 3, battery containment area 24, para. [0041]) that is bound on four sides (see FIG. 3, para. [0041]) that houses electrical components (para. [0042]). The battery support structure further comprises a top cover and a bottom cover (see FIG. 10, bottom cover 18, e.g. bottom reinforcement cover, para. [0042]) that are attached to the battery support structure (para. [0042]). DeKeuster, Lee, and Matecki each disclose each constitute prior art which is analogous to the claimed invention – a method for manufacturing a battery module, a battery module, and a battery housing. It would have been obvious, before the effective filing date of the claimed invention, to have modified the battery module of DeKeuster to comprise the top and bottom cover of Matecki in order to seal the upper and lower portions of the battery containment area (Matecki, para. [0042]). Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over DeKeuster in view of Lee as applied to claim 1 above, and further in view of Melack et al. (US 20180083306 A1 , “Melack”). . Regarding claim 7, DeKeuster in View of Lee discloses the method of claim 1 as discussed above. DeKeuster in view of Lee is silent regarding pre-compressing being performed with a plurality of assembly rods and/or assembly beams squeezing opposite sides of the solid-state battery cell stack. Melack discloses a method for manufacturing a battery assembly including the step of providing a can (see FIG. 2, can 200, e.g. housing, para. [0026]) and providing battery cells (see FIG. 3B, battery cells 310, para. [0023]) that are stacked in a stacking fixture (e.g. battery cell stack, para. [0031], [FIG. 3B]). The battery assembly comprises pneumatic cylinders (see FIGS. 3B – 3E and 4A – 4B, pneumatic cylinders 302, 306 314, 316, 400, 402, 404, 412, 414, 416, ,e.g. assembly rods/beams, para. [0037]) that compresses the battery cells (para. [0034]) before the battery cells are inserted into the can (see FIG. 5, note that pneumatic cylinders may be considered to be rods within the broadest reasonable interpretation of the term). DeKeuster, Lee, and Melack each disclose each constitute prior art which is analogous to the claimed invention – a method for manufacturing a battery module and a battery module. It would have been obvious, before the effective filing date of the claimed invention, to have modified the method of DeKeuster to include the pneumatic cylinders of Melack to provide a way to quickly insert or preserve the alignment of cells. (Melack, para. [0037]). Claim 8 is rejected under 35 U.S.C. 103 as being unpatentable over DeKeuster in view of Lee, and further in view of Melack as applied to claim 7 above, and further in view of Park et al. (US 20150079452 A1 , “Park”). DeKeuster in view of Lee, and further in view of Melack discloses the method of claim 7 as discussed above. DeKeuster in view of Lee, and further in view of Melack is silent regarding the housing including a plurality of cutouts configured to provide clearance to the plurality of assembly rods and/or assembly beams such that the housing can be inserted over the solid-state battery cell stack while being pre-compressed. Park discloses a battery module (see FIG. 1, battery module 100, para. [0032]) including a plurality of battery cells (see FIG. 1, battery cells 1100, para. [0032-0033], [FIG. 5]) that are stacked in a battery case (e.g. housing, para. [0033]). The battery module further comprises a pair of side plates (see FIG. 1, side plates 170, para. [0035]) that are connected to a side of end plates that are adjacent to the battery cells (para. [0035]). The side plates includes a compression area (see FIG. 5, compression area 290, e.g. assembly rods/beams, para. [0037]) that curves toward the battery cell to compress the battery cell through a cut-away portion (se FIG.. 5, cur-away portion 273, e.g. cutouts, para. [0045]). DeKeuster, Lee, Melack, and Park each disclose each constitute prior art which is analogous to the claimed invention – a method for manufacturing a battery module and a battery module. Park provides that is it know to include openings for the passage of a compression mechanism and that doing so permits the fitting of the battery under compression to a case or housing. Therefore, it would have been obvious, before the effective filing date of the claimed invention, to have modified the housing structure of DeKeuster to provide openings so as to better permit the fitting of the battery under compression to the case (Park, [0045]). Pertinent Prior Art The prior art made of record and not relied upon is considered pertinent to the applicant’s disclosure. Maini (WO-2013046230-A1) discloses a battery pack including a plurality of battery modules (see FIG. 1A, battery module 102, para. [0029]), a bottom cover (see FIG. 1A, bottom cover 104, e.g. bottom reinforcement cover, para. [0029]), and a top cover (see FIG. 1A, top cover 106, e.g. top reinforcement cover, para. [0029]). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to SANDRA BROWN whose telephone number is (571)270-0345. The examiner can normally be reached Monday through Thursday 6 am - 4:45 pm EST. 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, Aaron Austin can be reached at (571) 272-8935. 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. /SANDRA BROWN/Examiner, Art Unit 1782 /ANTHONY J FROST/Primary Examiner, Art Unit 1782
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Prosecution Timeline

Apr 17, 2023
Application Filed
Oct 05, 2026
Non-Final Rejection mailed — §103, §112 (current)

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Prosecution Projections

1-2
Expected OA Rounds
Grant Probability
Low
PTA Risk
Based on 0 resolved cases by this examiner. Grant probability derived from career allowance rate.

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