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 .
Response to Amendment and Claim Status
The amendment filed on 04/20/2026 has been entered. Applicants’ amendments to the
specification and claims have overcome each and every objections set forth in the Office Action
mailed 01/28/2026.
Further, applicant’s disagreement with examiner’s assertion that the phrase “translating” be replaced with “moving” is acknowledged. As applicant has provided specific arguments showing that the phrase is known to a person of ordinary skill in the art of mechanical and electrical engineering, applicant’s argument is persuasive and examiner’s assertion set forth in previous Office action is dropped.
Claim Rejections - 35 USC § 102
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 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.
(a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention.
Claims 20-23 are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Fees (WO 2018071850 A1).
Regarding Claim 20, Fees discloses an electrical connection system (see annotated Figure 3B and [0036]-[0038); for a battery pack (battery cells grouped within battery modules and mounted into a battery housing wherein the battery modules are electrically connected via busbars; see [0002]); comprising a first battery array (first set of battery module compartments arranged along a first lateral side of the battery module mounting area, see [0004] and annotated Figure 3B); a second battery array (second set of battery module compartments arranged along a second lateral side of the module mounting area, see [0004] and annotated Figure 3B). Fees further discloses that the first battery array is electrically connected to the second battery array by disclosing a module-to-module power connector configured to form an electrical connection between battery modules, see [0038] – [0039] and 325B of annotated Figure 3B) and a plug-and-socket coupler (electrical interfaces such as plugs and sockets on battery modules on both sides of the battery mounting area, see [0042]-[0043]) that electrically connects the first battery array (as set forth above) to the second battery array (as set forth above) when in an engaged position (see [0042] of Fees which discloses that when the battery module is inserted into the battery module compartment, electrical interfaces comprising plug and socket on the battery module aligns with the electrical interfaces of the module-to-module power connector to couple the battery module to the module-to-module power connector wherein module-to-module power connector interfaces with the battery modules in both first and second array) wherein the plug-and-socket coupler is configured to be transitioned from a disengaged position to the engaged position by moving the first battery array and the second battery array relative to each other (see [0042] which describes insertion of the battery module in battery module compartment aligns electrical interfaces on the battery module with the electrical interfaces of the module-to-module power connector to enable coupling and wherein removing the battery module from the battery module compartment disconnects or decouples the electrical interfaces) , and wherein a first connector assembly (plug and socket of electrical interface on battery module, see [0042]) of the plug-and-socket coupler is carried by the first battery array and a second connector assembly (plug and socket of electrical interface of battery module, [0042]) of the plug-and-socket coupler is carried by the second battery array (see [0042] which discloses that battery module each have electrical interfaces comprising plugs and sockets).
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Regarding Claim 21, Fees teaches all of the limitations as set forth above and further teaches wherein the first battery array and the second battery array are each electrically connected to the plug-and-socket coupler by an insertion of the respective first and second battery arrays into the battery pack in a direction transverse to a direction of engagement of the plug-and-socket coupler (see [0042] which describes a lateral adjacent battery module arrangement wherein electrical interfaces comprising of plugs and sockets are inserted into a hole and aligned perpendicular to the direction in which the battery module is inserted or removed).
Regarding Claim 22, Fees teaches all of the limitations as set forth above and further teaches wherein the first connector assembly (plug and socket of electrical interface of battery module, [0042]) is mounted to a wall of the first battery array that faces the second battery array and the second connector assembly is mounted to a wall of the second battery array that faces the first battery array (see [0087] & Figure 6F which show electrical interfaces 605F & 600F directly attached to the battery module in battery module compartments A & F respectively facing each other).
Regarding Claim 23, Fees teaches all of the limitations as set forth above and further teaches wherein the first battery array and the second battery array are arranged on opposite lateral sides of a battery module mounting area (see [0004] which describes a mounting area wherein a first set of battery module compartments are arranged along a first lateral side of the battery mounting area and a second set of battery module compartments are arranged along a second lateral side of the battery module mounting area), and wherein the plug-and-socket coupler is configured to be transitioned from the disengaged position to the engaged position by translating the second battery array horizontally toward the first battery array (see [0004] which describes a mounting area wherein a first set of battery module compartments are arranged along a first lateral side of the battery mounting area and a second set of battery module compartments are arranged along a second lateral side of the battery module mounting area).
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.
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 1-3 are rejected under 35 U.S.C. 103 as being unpatentable over Fees (WO 2018071850 A1) in view of Rath (DE 102020006705 A1, see attached machine translation).
Regarding Claim 1, Fees discloses an electrical connection system (see annotated Figure 3B and [0036]-[0038); for a battery pack (battery cells grouped within battery modules and mounted into a battery housing wherein the battery modules are electrically connected via busbars; see [0002]); comprising a first battery array (first set of battery module compartments arranged along a first lateral side of the battery module mounting area, see [0004] and annotated Figure 3B); a second battery array (second set of battery module compartments arranged along a second lateral side of the module mounting area, see [0004] and annotated Figure 3B). Fees further discloses that the first battery array is electrically connected to the second battery array by disclosing a module-to-module power connector configured to form an electrical connection between battery modules, see [0038] – [0039] and 325B of annotated Figure 3B).
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While Fees teaches a module-to-module connector for connecting adjacent battery modules to the module-to-module power connector (see [0042]), it does not explicitly disclose a plug-and-socket coupler that electrically connects the first battery array to the second battery array when the plug-and-socket coupler is in an engaged position.
Rath discloses a traction battery pack (modular traction battery 1 comprised of battery module 2 wherein each battery module comprises galvanic cells 4 (see [0019] – [0020] and Figure 1-2). Rath further discloses that the battery modules are interconnected via contact elements 5 which are designed as plugs and sockets which reads on the plug-and-socket coupler (see [0009] & [0020]) and teaches that fixing the plugs into the socket results in connecting the battery modules which reads on an engaged position (see [0024])Rath further discloses that the contact elements can have various configurations such as circular, square, rectangular, triangular, star-shaped, elliptical, or any other cross-sectional shape (see [0024]).
KSR Rationale B (MPEP § 2141) states that it is obvious to perform “simple substitution of one known element for another to obtain predictable results”. In the instant case, both couplers, module-to-module power connector of Fees and plug and socket contact elements of Rath are known to electrically couple battery modules in a traction battery pack (see Fees [0003] and Rath [0009] & [0020]). Fees and Rath are analogous art to the claimed invention as both references are in the same field of traction battery pack for electric vehicles. It would therefore have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to substitute the module-to-module power connector 325B which connects laterally-adjacent battery module compartments in series of Fees with the contact element having a plug and socket configuration of Rath and obtain the predictable result of electrically connecting battery modules in a traction battery pack.
Regarding Claim 2, modified Fees discloses the limitations as set forth above and further discloses an electrical connection system (see annotated Figure 3B and [0036]-[0038] of Fees), the plug-and-socket coupler (contact elements 5, see Rath [0020]); a first connector assembly (socket, see Rath [0020]) and a second connector assembly (plug, see Rath [0020]).
the first connector assembly directly connected to the first battery array and electrically connected to a first busbar of the first battery array, the second connector assembly directly connected to the second battery array and electrically connected to a second busbar of the second battery array
Fees discloses a busbar 365B which connects module A to module B of the first battery array and thus by replacing 325B with a plug-and-socket connector where socket is the first connector assembly connected to module A, an electrical connection to busbar 365B is established and thus to the other busbars and modules of the first array. Accordingly, Fees discloses another busbar 360B, wherein busbar 360B connects module F to module G of the second battery array and thus by replacing 325B with a plug-and-socket connector where plug is the second connector assembly connected to module F, an electrical connection to 360B is established and thus to the other busbars of the second battery array. Fees further teaches that an HV busbar could be bolted to an electrical interface on a battery module wherein electrical interface comprises plugs and socket (see [0042]).
Modified Fees, however, does not explicitly teach the first connector assembly directly connected to the first battery array and electrically connected to a first busbar of the first battery array, the second connector assembly directly connected to the second battery array and electrically connected to a second busbar of the second battery array.
Rath discloses that the battery modules 2 have the contact elements i.e. the plugs or sockets (see Rath, [0020]) and further teaches that such configuration enables connection of individual components (Rath, [0020]).
It therefore would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have directly connected the plug and socket of Rath to each battery module of Fees as taught by Rath wherein the plug and socket elements enable connection of individual components.
Regarding Claim 3, modified Fees discloses the limitations as set forth above and further discloses an electrical connection system (see Figure 3B and [0036]-[0038] of Fees); a first connector assembly (socket, see Rath [0020]) and a second connector assembly (plug, see Rath [0020]).
wherein the first connector assembly comprises a cylindrical terminal that receives a pin-style terminal of the second connector assembly when the plug-and-socket coupler is in the engaged position, modified Fees further discloses that the contact elements 5 comprising of the plug and sockets are cylindrical in shape (see [0024] and Figure 6 of Rath) wherein the cylindrical socket reads on the cylindrical terminal of the first connector assembly and the cylindrical plug reads on the pin-style terminal of the second connector assembly.
Claims 4-7, 10, 13 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Fees (WO 2018071850 A1) in view of Rath (DE 102020006705 A1, see attached machine translation) as applied to claims 1-3 above, and further in view of Silk (WO 2014066601 A1) as evidenced by Amphenol ‘20.
Regarding Claims 4-5, modified Fees discloses the limitations as set forth above but does not explicitly disclose any specific structure of the plug and socket connector, such as a guard of the first connector assembly, the guard extending into an opening of the cylindrical terminal and wherein the guard is pin-shaped.
Silk discloses a plug-and-socket connector ([0048]) used for electrical connections in a traction battery pack (battery assembly 1000 comprising of a plurality of battery cells 104 housed in support structure 1002 and stacked to form a battery module 1500; see [0020] – [0021] & [0036]) comprising a coupler (pin 1518 and socket 1550, see lines 1-2 of [0048]). Silk further teaches that disclosed plug & socket connector can be a SurLok™ type RADSOK® connector available from Amphenol (see lines 2-5 of [0048]) and as such, the plug and socket connector of Silk comprises a first connector assembly comprising a pin-shaped guard and a cylindrical terminal (see annotated Figure 1 from Amphenol ’20 included below) and a second connector assembly comprising of a hollow pin-style terminal (see annotated Figure 1 from Amphenol ’20 included below). When electrically coupled, the plug-and-socket connector of Silk are locked via a locking mechanism between positive pin and socket components - internal protrusion and engraved groove (see Silk, lines 8-11 of [0051]). Silk further teaches that the design of the pin of the plug-and-socket connector ensures protection against accidental contact by a user (see lines 1-2 of [0052] of Silk).
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KSR Rationale B (MPEP § 2141) states that it is obvious to perform “simple substitution of one known element for another to obtain predictable results”. In the instant case, both plug and socket contact elements of modified Fees and plug-and-socket connector of Silk are known to effectively establish electrical connections in battery modules (see Rath [0009] and [0020] and Silk [0048]). Fees and Silk are analogous art to the claimed invention as both references are in the same field of traction battery pack for electric vehicles. It would therefore have been obvious to a person of ordinary skill in the art prior to the effective filing date of the claimed invention to substitute the plug and socket contact element of modified Fees with the plug-and socket connector with a specific guard structure of Silk, and obtain the predictable result of effectively connecting battery modules.
Regarding claims 6 & 7, modified Fees discloses all of the limitations as set forth above and further discloses a pin-style terminal (see second connector assembly in Annotated Fig. 1 from Amphenol ‘20).
when the plug-and-socket coupler is in the engaged position, the guard is received within an opening of the pin-style terminal such that the pin-style terminal is radially between the guard and the cylindrical terminal; when the first connector assembly and second assembly of Figure 1 are coupled together, this would ultimately result in the pin-style terminal to be radially between the guard and the cylindrical terminal.
wherein the cylindrical terminal is a radial socket, first connector assembly of Annotated Figure 1 teaches a cylindrical terminal which extends radially inside the first connector assembly and is designed to receive the pin-style terminal of the second connector assembly. Modified Fees further teaches a cylindrical terminal disclosed as socket (1550 in Silk) which is designed to receive positive pin (1518 in Silk) which has an engraved annular groove (1574; see Silk [0051]).
Regarding Claim 10, modified Fees discloses the limitations as set forth above and further discloses a first housing (see Silk, insulating housing 1558 covers socket 1550; see [0049] of Silk) and a second housing (see Silk cover 1530 may serve as a covering means for positive pin 1518; see [0051] of Silk).
wherein the first housing and the second housing are snap-fit to each other when the plug-and-socket coupler is in the engaged position, modified Fees discloses that coupling between a first connector assembly (Silk, positive terminal connector 1516 enclosure) and a second connector assembly (Silk, positive pin 1518) occurs within the second housing (Silk, cover 1530). In particular, the couplings occur when first housing (Silk, insulating cover 1558) of first connector assembly (Silk, positive terminal connector 1516) is keyed to first and second openings (Silk, 1532, 1534) of second housing (Silk, cover 1530). With this keyed configuration, positive terminal connector is prevented from spinning or separating from the second housing (see Figure 3 and [0045] of Silk).
Regarding Claim 13, modified Fees discloses the limitations as set forth above and further discloses a wedge (side-mounted bars 620C-625C; see [0084] and Figure 6C of Fees) and an enclosure (battery housing 305A; see [0027] of Fees).
the wedge inhibiting movement of the first battery array away from the second battery array, modified Fees further teaches side-mounted bars which act as reinforcement for the battery module mounting area, see [0084] of Fees). Accordingly, these side-mounted bars which support the sides of each lateral battery array will keep the first and second battery arrays in a fixed position thus preventing movement of the first battery array from the second battery array.
Regarding Claim 15, modified Fees discloses the limitations as set forth above and further discloses an enclosure (battery housing 305A; see [0027] of Fees) of the battery pack enclosing the first battery array, the second battery array, and the plug-and-socket coupler (Fees discloses that the battery cells grouped within battery modules (arrays) and their connectors are mounted into a battery housing; see [0002] of Fees).
Claims 8, 11-12 are rejected under 35 U.S.C. 103 as being unpatentable over Fees (WO 2018071850 A1) in view of Rath (DE 102020006705 A1, see attached machine translation) as applied to claims 1-3 above, and further in view of Kim (KR 20170073331 A, see attached machine translation).
Regarding Claims 8, 11 and 12, modified Fees discloses the limitations as set forth above but does not explicitly disclose the connection system wherein the first connector assembly faces horizontally outward from the first battery array and is configured to receive the second connector assembly horizontally (as required by Claim 8) and wherein the plug-and-socket coupler is configured to be transitioned from a disengaged position to the engaged position by moving the first battery array and the second battery array relative to each other (as required by claim 11) and wherein the plug-and-socket coupler is configured to be transitioned from a disengaged position to the engaged position by translating the second battery array horizontally relative to the first battery array (as required by claim 12).
Kim discloses a battery rack system comprising a guide rail 100, a plurality of battery modules 220, a connector device 300 for electrically connecting the plurality of battery rack devices 200, battery control unit 230 for controlling the battery modules 220, bus bar units 240 electrically connected to the battery control unit 230, rack housing 210, positive electrode terminal 231, negative electrode terminal 232, positive bus bar 241 and negative busbar 242 wherein the busbars are used for connecting the battery control unit 230 and the battery modules 220 (see [0028] – 0037]). Kim further teaches connector device comprising of male connector portions 310 and 320 for electrically connecting neighboring battery devices which read on the plug-and-socket coupler (see [0040], Figure 1 of Kim). Accordingly, these male connector portions face horizontally outward form their respective battery array (see Figure 1 of Kim) and are configured to be coupled horizontally as required by Claim 8. In addition, the connector device 300 which includes a plurality of battery rack devices 200 mounted on the guide rail 100 are electrically connected to each other without a separate cable so that the battery rack devices 200 mounted on the guide rails 100 are connected to adjacent battery rack devices 200 (see [0040] of Kim). Accordingly, the guide rails 100 which have a predetermined width, predetermined length and moving wheels 211 are installed on the bottom of the battery assembly to help facilitate the installation and movement of the battery rack apparatus for ease of operation and maintenance (see [0029] – [0030], [0039] of Kim). As a result, the configuration of the guard rails would ensure that the transition of the plug-and-socket coupler from a disengaged position to an engaged position would require the horizontal movement of a second battery array relative to a first battery array as required by Claims 11 and 12.
Fees and Kim are analogous art to the claimed invention as both references are in the same field of electrical connection for traction battery systems. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery electrical connection system of Fees such that the guide rails of Kim are incorporated to facilitate the horizontal movement of battery arrays to transition from a disengaged state to an engaged state and to facilitate easy installation and movement of the battery arrays for ease of operation and maintenance.
Claims 9, 14 are rejected under 35 U.S.C. 103 as being unpatentable over Fees (WO 2018071850 A1) in view of Rath (DE 102020006705 A1, see attached machine translation) as applied to claims 1-3 above, and further in view of Grass (DE 102022123879 A1, see attached machine translation).
Regarding Claims 9 and 14, modified Fees discloses the limitations as set forth above but does not explicitly disclose the connection system wherein the first connector assembly faces vertically upward from the first battery array and is configured to receive the second connector assembly vertically (as required by claim 9) and wherein the plug-and-socket coupler is configured to be transitioned from a disengaged position to the engaged position by translating the second battery array vertically relative to the first battery array (as required by claim 14).
Grass teaches a traction battery module 10 with a housing in which cell packs 20 are accommodated. The cell packs are electrically connected via an electrical plug arrangement 430 comprising of a plug 30 of one cell pack 20 and a complementary mating plug 40 of another cell pack 20 (see [0016]). Grass further teaches the mating pug 40 has a body 42 which has a hollow cylindrical bore 44 (see [0018]). Upon coupling the plug 30 with the mating plug 40 a reliable electrical connection between two cell packs is created (see [0022]). According to Figure 2, the plug 30 and mating plug 40 are aligned in a vertical (y-axis) orientation (as required by claim 9) and further implying that a transition from a disengaged to an engaged position would require a vertical moving of the second battery array relative to the first battery array (as required by claim 14). Grass further teaches that a plug contact body defines a plug axis that is parallel to the plug axis of a plug mating contact body. The plug contact body is guided in a plug holder which is transverse to the plane of the plug axis and ensures that the plug contact body is laterally movable but immovable in the direction of the plug axis with respect to the cell pack (see [0007]). Such configuration would ensure exact alignment of the plug axis of the plug contact body with the plug axis of the mating plug contact body and thus avoid any bending and tilting of either contact bodies as well as compensate for manufacturing and assembly-related deviations (see [0008]).
KSR Rationale B (MPEP § 2141) states that it is obvious to perform “simple substitution of one known element for another to obtain predictable results”. In the instant case, the plug-and socket-couplers of Silk (positive terminal connector 1516 and positive pin 1518, see [0045] and Fig 7) and Grass (plug 30 and mating plug 40) electrically connect battery arrays when in an engaged position. Fees and Grass are analogous art to the claimed invention as both references are in the same field of electrical connection for traction battery systems. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have substituted the horizontal configuration of the plug-and-socket coupler of Silk which requires a horizontal moving to transition from a disengaged to an engaged position with the vertical configuration of the plug-and-socket coupler of Grass to obtain the predictable result of electrically connected battery arrays wherein the first connector assembly vertically receives the second assembly for electrical connection and avoid bending and tilting of the plug contact body and/or the mating plug contact body.
Response to Arguments
Applicant's arguments filed 4/10/2026 have been fully considered but they are not persuasive.
Regarding first rejection under 103 for Claims 1-3, applicant asserts that the structural architecture of Fee’s connector is a fixed tunnel-mounted busbar assembly into which battery modules electrically connect upon their vertical or lateral insertion into the housing and further asserts that Rath’s contact elements are integral to the battery module wherein said elements are distributed between the upper housing and lower housing as plug and sockets respectively. Applicant further asserts that such modification of Fee’s architecture with that of Rath would result in Fee’s architecture not being able to accommodate positional tolerances during lateral insertion and thus combination of both references are incompatible.
In response to applicant's argument that the architecture of Fee is not compatible with that of Rath, the test for obviousness is not whether the features of a secondary reference may be bodily incorporated into the structure of the primary reference; nor is it that the claimed invention must be expressly suggested in any one or all of the references. Rather, the test is what the combined teachings of the references would have suggested to those of ordinary skill in the art. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981).
Fees’ module-to-module power connector consists of electrical interfaces that enable connection to the battery module. In contrast, Rath contact elements which are configured as plugs and sockets enable direct contact between battery modules without the need of a module-to-module power connector as taught by Fees. The motivation for substituting the module-to-module power connector 325B with the contact elements of Rath which are configured as plugs and sockets is to show that battery modules can be connected directly via the plug and socket elements as taught by Rath and further reduce the need for an additional element such as the module-to-module connector box between laterally adjacent battery modules and thus simplifying the interconnection between battery modules ([0010], Rath). Further, Rath discloses that the contacts elements can be configured to be screwed together which ensures improved, lower resistance current flow across the contact elements ([0010], Rath).
Still regarding first rejection under 103 for claims 1-3, applicant further argues that analogous field is not sufficient reason for combination of references. In response to applicant's argument that analogous field is insufficient to combine art, it has been held that a prior art reference must either be in the field of the inventor’s endeavor or, if not, then be reasonably pertinent to the particular problem with which the inventor was concerned, in order to be relied upon as a basis for rejection of the claimed invention. See In re Oetiker, 977 F.2d 1443, 24 USPQ2d 1443 (Fed. Cir. 1992). In this case, Rath is in the same field of a modular battery and thus a person of ordinary skill should be able to use such a reference for a motivation to improve an invention. Further, in response to applicant's arguments against the references individually, one cannot show nonobviousness by attacking references individually where the rejections are based on combinations of references. See In re Keller, 642 F.2d 413, 208 USPQ 871 (CCPA 1981); In re Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
Applicant argues that the configuration for achieving electrical connection in Fees is specifically tailored to the lateral-insertion battery pack architecture whereas Rath’s configuration is tailored to a longitudinal structural arrangement of battery modules. Fees, however, discloses that other battery modules mounting area configurations are possible such as vertically-inserted battery module mounting area configurations wherein battery modules are inserted into a battery module mounting area from the top or bottom sides of an electric vehicle [0048]. Thus, a person of ordinary skill in the art would be motivated to look to Rath for establishing electrical connection between longitudinally stacked battery modules.
Regarding amended Claim 2, applicant argues that the busbar 365B is not a busbar of the alleged first battery array because it is located outside Module A & B and further assert that busbar 360B is not a busbar of the second battery array.
Fees, however, discloses that 360B and 365B are busbars included in the module to module power connector of the battery module wherein the battery modules of each battery array are plugged into the module-to-module power connector. Further, Fees discloses that HV busbars in the module-to-module power connector could be manually secured to electrical interfaces comprising plugs and sockets on the battery modules (see Fees, [0042]).
Additionally, Rath discloses that the contact elements comprising of plugs or sockets are installed on the battery modules (Rath, [0020]), thus a substitution of the module-to-module power connector with the plug and socket elements of Rath would result in a direct connection of the plug and socket elements to the battery array wherein the module-to-module power connector in Fees is directly connected to the battery module in Fees.
Regarding second rejection under 103 for claims 4-7, 10, 13 & 15, applicant asserts that examiner uses hindsight reasoning for failing to disclose a deficiency in the combination of Fees and Rath. In response to applicant's argument that the examiner's conclusion of obviousness is based upon improper hindsight reasoning, it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin, 443 F.2d 1392, 170 USPQ 209 (CCPA 1971).
The motivation to combine Fees and Rath is aimed at directly connecting battery modules as set forth above, however, neither Fees nor Rath disclose any specific structure of the plug and socket elements thus the reliance on Silk’s disclosure of a SurLokTM type RADSOK connector from Amphenol. Amphenol discloses a similar plug and socket connector to that of instant application (see annotated Figure 1 of Amphenol’ 20). Thus, such disclosure is not based on hindsight reasoning but on the deficiency of the combination of Rath and Fees to disclose a specific structure of the plug and socket connector.
Further, regarding claim 10, applicant asserts that Silk does not disclose features of a snap-fit structure as interpreted by the applicant. In response to applicant's argument that the references fail to show certain features of the invention, it is noted that the features upon which applicant relies (i.e., “a self-locking engagement as achieved by the deflection and recovery of a resilient member) are not recited in the rejected claim(s). Although the claims are interpreted in light of the specification, limitations from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
In addition to the keyed coupling as set forth in previous rejection, Silk gives a detailed description of a flexible internal protrusion in the positive terminal connector 1516 which may be biased radially inward from the socket 1550 toward positive pin 1518 [0048] and further teaches that the internal protrusion which has a complementary groove may serve as a locking means between the positive pin 1518 and the socket 1550 when the internal protrusion has engaged the groove to lock the socket onto the positive pin. Accordingly, this locking mechanism between the internal protrusion and the groove ensures sufficient connection between the positive pin and the socket to the extent that electrical connection is achieved between battery modules and thus reads on the broadest reasonable interpretation of a “snap-fit” connection.
Further, regarding claim 13, applicant asserts that examiners uses broad reasoning as motivation to use reinforcement bars to read on wedges to inhibit movement. In response to applicant's argument that side-mounted bars are merely reinforcement members, the broadest reasonable interpretation of a wedge in light of instant specification is a structural member capable of inhibiting movement of the first battery array from the second battery array ([0015], Instant specification). The plain meaning of a “wedge” is an object with a particular shape intended to separate two objects. Accordingly, while the shape of the side-mounted bars of Fees is not a wedge, it serves as a reinforcement bar which defines the module mounting area and further prevents the movement of the battery arrays. Further, it would have been obvious to one of ordinary skill in the art to have configured the shape of the side-mounted bar into various shapes including a wedge.
Regarding third rejection under 103 for claims 8, 11 and 12, applicant asserts that the motivation to combine references is based on limitations from said claims. In response to applicant's argument that the examiner's conclusion of obviousness is based upon improper hindsight reasoning, it must be recognized that any judgment on obviousness is in a sense necessarily a reconstruction based upon hindsight reasoning. But so long as it takes into account only knowledge which was within the level of ordinary skill at the time the claimed invention was made, and does not include knowledge gleaned only from the applicant's disclosure, such a reconstruction is proper. See In re McLaughlin, 443 F.2d 1392, 170 USPQ 209 (CCPA 1971).
Fees disclosure of a laterally inserted battery module into the battery compartment establishes a connection between adjacent battery modules via a module-to-module power connector. Fees further highlights that other battery module configurations are possible [0042]. As established above, the electrical connection is established with the aid of the said power connector whereas Kim discloses a direct connection between adjacent battery devices via a male connector with the aid of a guide rail which enables horizontal movement of the battery devices toward and away from each other to establish and de-establish electrical connection respectively as required by the limitations of claim 12 in particular. Further, said guide rails to assist with horizontal movement of the battery devices facilitate easy installation and movement of battery devices ([0029]-[0030] & [0039]).
Regarding fourth rejection under 103 for claims 9 & 14, applicant asserts that the total number of references used for the rejection does not provide a reason for obviousness. In response to applicant's argument that the examiner has combined an excessive number of references, reliance on a large number of references in a rejection does not, without more, weigh against the obviousness of the claimed invention. See In re Gorman, 933 F.2d 982, 18 USPQ2d 1885 (Fed. Cir. 1991).
As stated above, Fees discloses other battery mounting configurations and further discloses a vertically-inserted battery module mounting area configuration [0048] but does not explicitly discuss a vertical connection of the electrical interfaces to form an electrical connection or a horizontal translation of battery modules to establish an electrical connection between battery modules. Kim is relied upon to teach a means for horizontally connecting battery modules which ultimately simplifies the connection process between modules. Grass, further teaches that the plug and mating plug of the battery connector assembly, each having a vertical orientation, ensures that said connector elements form a force-fit connection and creates a reliable electrical connection between cell packs. Both Grass and Kim are analogous art to the claimed invention as both references are directed towards electrical connectors in battery modules and thus one of ordinary skill would necessarily look to both references to improve features of Fees to meet claim limitations.
Conclusion
Applicant's amendment necessitated the new grounds 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 nonprovisional extension fee (37 CFR 1.17(a)) 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 mailing date of this final action.
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/F.V.O./Examiner, Art Unit 1725
/JONATHAN G LEONG/ Supervisory Patent Examiner, Art Unit 1751 7/24/2026
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