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 . If status of the application as subject to 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 a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
Status of Claims
Claims 1 & 3 are pending in the application and are presently examined. Claims 1-4 were rejected in the 2/18/2026 office action. Applicant cancelled claims 2 & 4.
Response to Amendment / Arguments
The 5/15/2026 amendment, in response to the 2/18/2026 office action, has been entered. Applicant made the following claim 1 amendment, which overcame the 35 U.S.C. 103 rejections:
“the resin safety valve member is configured to… open by breakage of a portion with a minimum width between an inner perimeter and an outer perimeter of the part of the annular joined portion made from the resin, which entered into the pits of the annular roughened surface”
This is a new claim limitation, which was not in the claims rejected in the 2/18/2026 office action. This claim limitation is different from Figure A below, which was asserted against the claims in the 2/18/2026 office action.
Figure A: Annotated Inoue Figure 7
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It doesn’t seem likely or obvious that Inoue’s pressure relief vent 20 would break between the inner perimeter and the outer perimeter of Inoue’s joint surface 10c in Figure A above, because this joint surface 10c is parallel to hole depth.
Nevertheless, the claims remain rejected under 35 U.S.C. 103 due to a different Inoue embodiment. See discussion and Figure B below.
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.
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.
The claims are in bold font, the prior art is in parentheses.
Claims 1 & 3 are rejected under 35 U.S.C. 103 as being unpatentable over JP2016126989A machine translation (Inoue).
Inoue teaches the following claim 1 limitations:
A sealed battery (paragraphs 18-19; figure 2: electric component 200 can be a lithium ion secondary battery) comprising:
a battery case (paragraph 16; figure 2: lid body 100 & case main body 70) including a metal wall portion (paragraph 16; Figure A below: lid body 100 includes a metallic lid body 10) formed with a gas vent hole (paragraph 16; figure 3: hole 12), the metal wall portion (10) having an outer surface (Figure B below) including a hole-surrounding surface (Figure B below)… surrounding an opening edge (Figure B below) of the gas vent hole (12); and
a safety valve member (paragraph 16; Figure B below: pressure relief vent 20) closing the gas vent hole (12) by covering the hole-surrounding surface (Figure B below), wherein
the safety valve member (20) is a resin safety valve member made of resin (paragraph 16: resin-made pressure relief vent 20),
Figure B: Annotated Inoue Figure 3
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Claim 1 also states:
the hole-surrounding surface (Figure B above) includes an annular roughened surface (paragraph 30; Figure C below: joint surfaces 10c) that surrounds the opening edge (Figure B above) of the gas vent hole (12), the annular roughened surface having an uneven shape with pits and protrusions (Figure C below),
the resin safety valve member (20) includes an annular joined portion (Figure C below) hermetically joined (paragraph 30: sufficient bonding strength) to the annular roughened surface (Figure C below),
the resin safety valve member is hermetically joined to the annular roughened surface by the part of the annular joined portion made from the resin, which entered into the pits of the annular roughened surface (paragraph 30; Figure C below)
Figure C: Annotated Inoue Figure 4
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Claim 1 also states:
the resin safety valve member is configured to, in response to an internal pressure of the battery case reaching a valve opening pressure, open by breakage of a portion with a minimum width between an inner perimeter and an outer perimeter of the part of the annular joined portion made from the resin, which entered into the pits of the annular roughened surface
Inoue states that the pressure release valve 20 breaks when internal pressure exceeds a certain value (paragraph 31); however, Inoue doesn’t state that the annular joined portion of the pressure release valve 20 breaks. Inoue’s pressure release valve 20 has the same structure as the presently-claimed safety valve member, so presumably Inoue’s pressure release valve 20 will break the claimed location. Also, Inoue’s pressure release valve 20 is expected to break in that location because of its reduced thickness, due to the pits.
Inoue, however, fails to teach that the hole-surrounding surface has an annular shape. An annular shape, however, is the most common shape for connections and vents on metal components because it is the easiest shape to make, and the easiest shape to connect to with a pipe or tubing. It would have been obvious, to one of ordinary skill in the art, before the effective filing date of the invention, for Inoue’s hole 12 to have an annular shape, for ease of manufacture.
With regard to claim 3, modified Inoue teaches the limitations of claim 1, as described above. Inoue also teaches the following limitations of claim 3:
the battery case (100 & 70) comprises:
a case body (paragraph 16; figure 2: case main body 70) having an opening (paragraph 16; figure 2: opening 70a); and
a metal lid (paragraph 16; figure 2: lid body 100) closing the opening (70a) of the case body (70), and
the metal lid (100) includes the metal wall portion (paragraph 16: lid body 100 includes a metallic lid body 10)
Conclusion
Applicant's amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. See MPEP § 706.07(a). Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any extension fee pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to ROBERT WEST whose telephone number is 703-756-1363 and email address is Robert.West@uspto.gov. The examiner can normally be reached Monday-Friday 10 am - 7 pm ET.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Allison Bourke can be reached at 303-297-4684.
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/R.G.W./Examiner, Art Unit 1721
/ALLISON BOURKE/Supervisory Patent Examiner, Art Unit 1721
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