Prosecution Insights
Last updated: October 04, 2026
Application No. 18/326,186

BATTERY CELL SUPPORT ASSEMBLY WITH INTEGRATED THERMAL RUNAWAY MITIGATION

Final Rejection §103§112§Other
Filed
May 31, 2023
Examiner
FREEMAN, EMILY ELIZABETH
Art Unit
1724
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
2 (Final)
73%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
87%
With Interview

Examiner Intelligence

Grants 73% — above average
73%
Career Allowance Rate
109 granted / 150 resolved
+7.7% vs TC avg
Moderate +14% lift
Without
With
+14.3%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
29 currently pending
Career history
195
Total Applications
across all art units

Statute-Specific Performance

§101
0.7%
-39.3% vs TC avg
§103
53.6%
+13.6% vs TC avg
§102
26.6%
-13.4% vs TC avg
§112
16.3%
-23.7% vs TC avg
Black line = Tech Center average estimate • Based on career data from 150 resolved cases

Office Action

§103 §112 §Other
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 . This is a final office action in response to Applicant's remarks and amendments filed on 06/01/2026. Claims 1, 4, 6, 9, 11-12, 15, 17, and 20 are currently amended. Claims 1-20 are pending review in this action. The previous objections regarding the Claims are withdrawn in light of Applicant's amendment to the Claims. The previous 35 U.S.C. 103 rejections are withdrawn in light of Applicant's amendment to Claims 1, 11, and 17. New grounds of rejection necessitated by Applicant's amendments are presented below. Claim Objections Claims 4 and 20 are objected to because of the following informalities: Claim 4 recites “each of the thermal-barrier strips is constructed from FRB paper” in lines 1-2. The examiner suggests amending the limitation to read “each Claim 20 recites “each of the thermal-barrier strips is constructed from FRB paper” in line 5. The examiner suggests amending the limitation to read “each . Appropriate correction is required. Claim Rejections - 35 USC § 112 (b) 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. Claims 17-20 are 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 17 recites the limitation "the thermal-barrier strips" in lines 11-12. There is insufficient antecedent basis for this limitation in the claim. Nowhere in the claim prior to line 11 is there a recitation of “a thermal-barrier strip(s)”. As such, the skilled artisan would not find it obvious what feature is being referred to as “the thermal-barrier strips”. For purposes of examination, the broadest reasonable interpretation will be used to examiner the claim. Claims 18-20 are also rejected due to their dependency upon Claim 17. Claim Rejections - 35 USC § 103 The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action. Claims 1-3, 5-6, and 11-12 are rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) further in view of Yang et al. (US 2022/0320651 A1). In Regards to Claim 1: Georgiadis discloses a multi-cell rechargeable energy storage system (RESS) (battery cell arrangement, 1) comprising: a plurality of battery cells (2), wherein each battery cell (2) includes a respective cell vent (degassing valve) configured to expel gases; and a cell support assembly (separating elements, 4, and potting compound, 13) with thermal runaway mitigation (Figures 1 and 10A, [0079-0080, 0100]). Georgiadis further discloses that the cell support assembly (separating elements, 4, and potting compound, 13) includes: a cell holder (separating elements, 4) configured to support the plurality of battery cells (2) and having a holder body defining a plurality of apertures (vent channels, 5) arranged in rows, wherein each aperture (vent channels, 5) is configured to align and be in fluid communication with the cell vent (degassing valve) of one of the plurality of battery cells (2) (Figures 1 and 10B, [0080-0081]). Georgiadis further discloses that the cell support assembly (separating elements, 4, and potting compound, 13) includes a plurality of potting elements (potting compound, 13), wherein each potting element (potting compound, 13) is arranged in one of the plurality of apertures (vent channels, 5) (Figure 10A, [0100, 0101]). Georgiadis further discloses that each potting elements (potting compound, 13) is filled in the gaps (4b) formed between the cell holder (separating elements, 4) and the battery cells (2), thus the potting elements (potting compound, 13) are configured to adhere to the battery cell (2) and the cell holder (separating elements, 4) (Figure 10b, [0101]). Georgiadis further discloses a RESS enclosure (housing, 3, and cover elements, 6) having a tray (cover elements, 6) and a mating cover (housing, 3) and configured to house the plurality of battery cells (2), the cell holder (separating elements, 4), and the plurality of potting elements (potting compound, 13) (Figure 10A, [0080, 0083]). Georgiadis is deficient in disclosing 1) a plurality of thermal-barrier strips adhered to the cell holder, wherein each thermal-barrier strip extends parallel to a respective row of apertures and is configured to thermally insulate corresponding battery cells from gases expelled by neighboring battery cells during a thermal runaway; 2) wherein at least a region of the cell holder is not in contact with the thermal-barrier strips; and 3) that each potting element is arranged in one of the plurality of apertures such that it is between a respective battery cell and a corresponding thermal-barrier strip and configured to adhere to the battery cell and to the corresponding thermal-barrier strip to maintain position of the battery cell on the cell holder. Yang discloses a multi-cell rechargeable energy storage system (RESS) (battery, 10) comprising: a plurality of battery cells (20), wherein each battery cell (20) includes a respective cell vent (pressure relief mechanism, 213) configured to expel gases (Figures 2 and 5, [0111, 0116-0117]). Yang further discloses that in a situation wherein gas is expelled from the RESS (battery, 10), the emissions may be released from the cell vent (pressure relief mechanism, 213) to a collection chamber (11b) defined by a thermal management component (13) and then follow an exhaust path to be discharged from the battery box (11) (Figure 6, [0143, 0188]). Yang further discloses that heat-resisting material may be pasted on the surface of the thermal management component (13) forming the exhaust path, wherein the heat-resisting material may be mica paper (Figure 6, [0046]). Yang further discloses that the use of a heat-resisting material serves to protect the surface of the exhaust path [0046]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to modify the RESS of Georgiadis to include the heat-resisting material of Yang on the surfaces of the plurality of apertures and the RESS enclosure wherein gas travels during venting, as it is known in the art that coating such interior surfaces of a RESS where gas is exhausted serves to protect surfaces of the exhaust path, as taught by Yang. By doing so, the skilled artisan would have a reasonable expectation of success in improving the overall safety and lifespan of the RESS as well as prevent thermal damage to the RESS, as taught by Yang. Upon the above modification, the skilled artisan would appreciate that the heat-resisting material may be considered a thermal barrier strip as Yang teaches it may be mica paper. Additionally, the skilled artisan would appreciate that it may be considered to extend parallel to a respective row of apertures as it would have some dimension (i.e., thickness) in a direction parallel to a respective row of apertures and would thermally insulate corresponding battery cells from gases expelled by neighboring battery cells during a thermal runaway. Likewise, the skilled artisan would appreciate that when the heat-resisting material is applied only to surfaces of the exhaust path, there would indeed be regions of the cell holder which is not in contact with the thermal barrier strips, for example the portions of the cell holder which are located “below” the cell vent. Upon the above modification, the skilled artisan would appreciate that a plurality of thermal-barrier strips are adhered to the cell holder, each potting element is arranged in one of the plurality of apertures such that it is between a respective battery cell and a corresponding thermal-barrier strip and configured to adhere to the battery cell and to the corresponding thermal-barrier strip to maintain position of the battery cell on the cell holder. Thus, all of the limitations of Claim 1 are met. In Regards to Claim 2 (Dependent Upon Claim 1): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 1 as set forth above. As detailed above in the rejection of Claim 1, modified Georgiadis discloses an RESS enclosure (housing, 3, and cover elements, 6) having a tray (cover elements, 6) and a mating cover (housing, 3) and configured to house the plurality of battery cells (2), the cell holder (separating elements, 4), the plurality of thermal-barrier strips, and the plurality of potting elements (potting compound, 13) (Figure 10A, [0080, 0083]). Georgiadis further discloses that the cell holder (separating elements, 4) is configured to engage and fit together with the enclosure tray (cover elements, 6) (Figure 10A, [0083]). Thus, all of the limitations of Claim 2 are met. In Regards to Claim 3 (Dependent Upon Claim 2): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 2 as set forth above. Georgiadis further discloses that the enclosure tray (cover elements, 6) includes multiple channels (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4) and the cell holder (separating elements, 4) includes multiple integral projection portions (portion of separating elements, 4, in contact with groove portion, 6b) (Figure 9A, [0088, 0097]). Georgiadis further discloses that each of the cell holder projection portions (portion of separating elements, 4, in contact with groove portion, 6b) is configured to engage one of the enclosure tray channels (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4), thereby establishing a plurality of longitudinal fluid passages (region of vent channels, 5, corresponding to cover elements, 6) (Figures 9A and 10A, [0095, 0097]). Georgiadis further discloses that each fluid passage (region of vent channels, 5, corresponding to cover elements, 6) extends along at least one of the rows of apertures (vent channels, 5) to direct the gases expelled by corresponding battery cells (2) (Figure 10A, [0079, 0083]). Thus, all of the limitations of Claim 3 are met. In Regards to Claim 5 (Dependent Upon Claim 3): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 3 as set forth above. Georgiadis further discloses an adhesive arranged inside the enclosure tray channel (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4) between the enclosure tray (cover elements, 6) and the corresponding holder projection portion (portion of separating elements, 4, in contact with groove portion, 6b) to thereby fix the cell holder (separating elements, 4) of the cell support assembly (separating elements, 4, and potting compound, 13) which forms the plurality of apertures (vent channels, 5) to the enclosure tray (cover elements, 6) (Figure 10A, [0083]). Thus, all of the limitations of Claim 5 are met. In Regards to Claim 6 (Dependent Upon Claim 3): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 3 as set forth above. Georgiadis does not explicitly teach that each of the potting elements (potting compound, 13) is configured to separate from the respective aperture (vent channels, 5) under a force of the expelled gases and thereby break away a portion of the corresponding barrier strip into the corresponding fluid passage (region of vent channels, 5, corresponding to cover elements, 6). However, the examiner notes that the term “a force” as written is a broad limitation and is subject to the broadest reasonable interpretation during the review of prior art. As such, the skilled artisan would appreciate that there is necessarily a force the expelled gases may achieve which would result in the separation of the potting elements (potting compound, 13) from the respective aperture (vent channels, 5) and the “breaking away” of the corresponding barrier strip into the corresponding fluid passage (region of vent channels, 5, corresponding to cover elements, 6). Thus, all of the limitations of Claim 6 are met. In Regards to Claim 11: Georgiadis discloses a cell support assembly (separating elements, 4, and potting compound, 13) with thermal runaway mitigation for a multi-cell rechargeable energy storage system (RESS) (battery cell arrangement, 1) having a plurality of battery cells (2) with respective cell vents (degassing valve) for expelling gases (Figures 1 and 10A, [0079-0080, 0100]). Georgiadis further discloses that the cell support assembly (separating elements, 4, and potting compound, 13) comprises: a cell holder (separating elements, 4) configured to support the plurality of battery cells (2) and having a holder body defining a plurality of apertures (vent channels, 5) arranged in rows, wherein each aperture (vent channels, 5) is configured to align and be in fluid communication with the cell vent (degassing valve) of one of the plurality of battery cells (2) (Figures 1 and 10B, [0080-0081]). Georgiadis further discloses that the cell support assembly (separating elements, 4, and potting compound, 13) includes a plurality of potting elements (potting compound, 13), wherein each potting element (potting compound, 13) is arranged in one of the plurality of apertures (vent channels, 5) (Figure 10A, [0100, 0101]). Georgiadis further discloses that each potting elements (potting compound, 13) is filled in the gaps (4b) formed between the cell holder (separating elements, 4) and the battery cells (2), thus the potting elements (potting compound, 13) are configured to adhere to the battery cell (2) and the cell holder (separating elements, 4) (Figure 10b, [0101]). Georgiadis further discloses a RESS enclosure (housing, 3, and cover elements, 6) having a tray (cover elements, 6) and a mating cover (housing, 3) and configured to house the plurality of battery cells (2), the cell holder (separating elements, 4), and the plurality of potting elements (potting compound, 13) (Figure 10A, [0080, 0083]). Georgiadis is deficient in disclosing 1) a plurality of thermal-barrier strips adhered to the cell holder, wherein each thermal-barrier strip extends parallel to a respective row of apertures and is configured to thermally insulate corresponding battery cells from gases expelled by neighboring battery cells during a thermal runaway; 2), that at least a region of the cell holder is not in contact with the thermal-barrier strips; and 3) that each potting element is arranged in one of the plurality of apertures such that it is between a respective battery cell and a corresponding thermal-barrier strip and configured to adhere to the battery cell and to the corresponding thermal-barrier strip to maintain position of the battery cell on the cell holder. Yang discloses a multi-cell rechargeable energy storage system (RESS) (battery, 10) comprising: a plurality of battery cells (20), wherein each battery cell (20) includes a respective cell vent (pressure relief mechanism, 213) configured to expel gases (Figures 2 and 5, [0111, 0116-0117]). Yang further discloses that in a situation wherein gas is expelled from the RESS (battery, 10), the emissions may be released from the cell vent (pressure relief mechanism, 213) to a collection chamber (11b) defined by a thermal management component (13) and then follow an exhaust path to be discharged from the battery box (11) (Figure 6, [0143, 0188]). Yang further discloses that heat-resisting material may be pasted on the surface of the thermal management component (13) forming the exhaust path, wherein the heat-resisting material may be mica paper (Figure 6, [0046]). Yang further discloses that the use of a heat-resisting material serves to protect the surface of the exhaust path [0046]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to modify the RESS of Georgiadis to include the heat-resisting material of Yang on the surfaces of the plurality of apertures and the RESS enclosure wherein gas travels during venting, as it is known in the art that coating such interior surfaces of a RESS where gas is exhausted serves to protect surfaces of the exhaust path, as taught by Yang. By doing so, the skilled artisan would have a reasonable expectation of success in improving the overall safety and lifespan of the RESS as well as prevent thermal damage to the RESS, as taught by Yang. Upon the above modification, the skilled artisan would appreciate that the heat-resisting material may be considered a thermal barrier strip as Yang teaches it may be mica paper. Additionally, the skilled artisan would appreciate that it may be considered to extend parallel to a respective row of apertures as it would have some dimension (i.e., thickness) in a direction parallel to a respective row of apertures and would thermally insulate corresponding battery cells from gases expelled by neighboring battery cells during a thermal runaway. Likewise, the skilled artisan would appreciate that when the heat-resisting material is applied only to surfaces of the exhaust path, there would indeed be regions of the cell holder which is not in contact with the thermal barrier strips, for example the portions of the cell holder which are located “below” the cell vent. Upon the above modification, the skilled artisan would appreciate that a plurality of thermal-barrier strips are adhered to the cell holder, each potting element is arranged in one of the plurality of apertures such that it is between a respective battery cell and a corresponding thermal-barrier strip and configured to adhere to the battery cell and to the corresponding thermal-barrier strip to maintain position of the battery cell on the cell holder. Thus, all of the limitations of Claim 11 are met. In Regards to Claim 12 (Dependent Upon Claim 11): Georgiadis as modified by Yang discloses the cell support assembly of Claim 11 as set forth above. Georgiadis does not explicitly teach that each of the potting elements (potting compound, 13) is configured to separate from the respective aperture (vent channels, 5) under a force of the expelled gases and thereby break away a portion of the corresponding barrier strip. However, the examiner notes that the term “a force” as written is a broad limitation and is subject to the broadest reasonable interpretation during the review of prior art. As such, the skilled artisan would appreciate that there is necessarily a force the expelled gases may achieve which would result in the separation of the potting elements (potting compound, 13) from the respective aperture (vent channels, 5) and the “breaking away” of the corresponding barrier strip. Thus, all of the limitations of Claim 12 are met. Claim 4 is rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) as modified by Yang et al. (US 2022/0320651 A1), as applied to Claim 3 above, further in view of Turpin et al. (US 2013/0337246 A1). In Regards to Claim 4 (Dependent Upon Claim 3): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 3 as set forth above. Upon the modification detailed above in the rejection of Claim 1, modified Georgiadis discloses that the thermal-barrier strips are present on the interior surfaces of the plurality of apertures (vent channels, 5) which define the exhaust path and the RESS enclosure (housing, 3, and cover elements, 6), including the tray (cover elements, 6). Modified Georgiadis further discloses that the thermal-barrier strips are formed from mica paper. As such, the skilled artisan would appreciate that when the thermal-barrier strips are present on the interior surfaces of the tray (cover elements, 6), each of the thermal-barrier strips may be considered to include a strip section extending into a respective enclosure tray channel (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4) between the enclosure tray (cover elements, 6) and the corresponding holder projection portion (portion of separating elements, 4, in contact with groove portion, 6b) (Figure 10A, [0095, 0097]). Modified Georgiadis is deficient in disclosing that the thermal-barrier strips are formed from FRB paper. Turpin discloses a flexible electrical insulation article which comprises a nonwoven paper [0004, 0019]. Turpin further discloses that the nonwoven paper may be selected from a list which includes FRB paper and mica paper [0023, 0025]. Turpin further discloses that the flexible electrical insulation article can possess desirable thermal conductivity properties [0004]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to select for the material of the thermal-barrier strips, FRB paper, as FRB paper is known in the art to be a suitable alternative to mica paper for use as a nonwoven paper in a material having thermal conductivity properties, as taught by Turpin. The substitution of known equivalent structures involves only ordinary skill in the art. In re Fout 213 USPQ 532 (CCPA 1982); In re Susi 169 USPQ 423 (CCPA 1971); In re Siebentritt 152 USPQ 618 (CCPA 1967); In re Ruff 118 USPQ 343 (CCPA 1958). When a patent claims a structure already known in the prior art that is altered by the mere substitution of one element for another known in the field, the combination must do more than yield a predictable result. Upon the above modification, all of the limitations of Claim 4 are met. Claims 7 and 13 are rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) as modified by Yang et al. (US 2022/0320651 A1), as applied to Claims 1 and 11 above, with evidentiary support from Hamdani et al. (Polymer Degradation and Stability 94 (2009) 465–495). In Regards to Claim 7 (Dependent Upon Claim 1): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 1 as set forth above. Georgiadis further discloses that the potting elements (potting compound, 13) may be formed from silicone (Figure 10A, [0057]). Georgiadis is deficient in disclosing that each of the potting elements includes a flame-retardant material. Hamdani teaches that silicon materials have low heat release rates, minimal sensitivity to external heat flux, and exhibit a slow burning rate, therefore are known to offer significant advantages for flame retardant applications (p. 465, Introduction, Column 2). As such, the skilled artisan would appreciate that the silicone potting elements (potting compound, 13) of Georgiadis may be considered a flame-retardant material. Thus, all of the limitations of Claim 7 are met. In Regards to Claim 13 (Dependent Upon Claim 11): Georgiadis as modified by Yang discloses the cell support assembly of Claim 11 as set forth above. Georgiadis further discloses that the potting elements (potting compound, 13) may be formed from silicone (Figure 10A, [0057]). Georgiadis is deficient in disclosing that each of the potting elements includes a flame-retardant material. Hamdani teaches that silicon materials have low heat release rates, minimal sensitivity to external heat flux, and exhibit a slow burning rate, therefore are known to offer significant advantages for flame retardant applications (p. 465, Introduction, Column 2). As such, the skilled artisan would appreciate that the silicone potting elements (potting compound, 13) of Georgiadis may be considered a flame-retardant material. Thus, all of the limitations of Claim 13 are met. Claims 8 and 14 are rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) as modified by Yang et al. (US 2022/0320651 A1), as applied to Claims 1 and 11 above, further in view of Kawakami et al. (US 2020/0076022 A1). In Regards to Claim 8 (Dependent Upon Claim 1): Georgiadis as modified by Yang discloses the multi-cell RESS of Claim 1 as set forth above. Georgiadis further discloses that the potting elements (potting compound, 13) may be formed from silicone or a non-conductive thermally isolating potting compound (Figure 10A, [0057]). Georgiadis further teaches that covering the cell vents (degassing valve) of the plurality of battery cells (2), which are located around the positive poles of the battery cells (2), with the potting elements (potting compound, 13) serves to thermally and/or mechanically shield the battery cells (2) from neighboring battery cells (2) (Figure 10A, [0057]). Georgiadis is deficient in disclosing that each of the potting elements is formed from a non-self-leveling paste applied into the respective one of the plurality of apertures and cured to harden therein. Kawakami discloses a multi-cell rechargeable energy storage system (RESS) (battery pack) comprising a plurality of battery cells (1) and a heat insulating member (8) accommodated in a housing (external case, 11) (Figure 1, [0042-0043]). Kawakami further discloses that the heat insulating member (8) is disposed on the surface of bus bars (3) connected with electrode poles (electrode terminals, 1x/1y) and serves to insulate neighboring components of the RESS (battery pack) from heat generated from the plurality of battery cells (1) (Figure 1, [0065]). Kawakami further discloses that the heat insulating member (8) is formed from a potting resin, wherein the potting resin may be urethane resin which is applied to positioning hollows (2D) and cured (Figure 1, [0066-0067, 0069]). Kawakami further discloses that the uncured potting resin may be in paste form, and that the potting resin is continuously supplied cured over time to form the heat insulating member (8) (Figure 1, [0066, 0074]). Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to select for the potting element of Georgiadis, the urethane potting resin taught by Kawakami, as such a resin is known in the art as suitable for a potting resin being in contact with an electrode pole of a battery cell in a RESS, as taught by Kawakami. Furthermore, the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination (MPEP 2144.07). By doing so, the skilled artisan would have a reasonable expectation of success in providing a potting element which successfully insulates neighboring components of the RESS (battery pack) from heat generated from the plurality of battery cells, as taught by Kawakami and as is desired by Georgiadis as noted above. Upon such a modification, all of the limitations of Claim 8 are met. In Regards to Claim 14 (Dependent Upon Claim 11): Georgiadis as modified by Yang discloses the cell support assembly of Claim 11 as set forth above. Georgiadis further discloses that the potting elements (potting compound, 13) may be formed from silicone or a non-conductive thermally isolating potting compound (Figure 10A, [0057]). Georgiadis further teaches that covering the cell vents (degassing valve) of the plurality of battery cells (2), which are located around the positive poles of the battery cells (2), with the potting elements (potting compound, 13) serves to thermally and/or mechanically shield the battery cells (2) from neighboring battery cells (2) (Figure 10A, [0057]). Georgiadis is deficient in disclosing that each of the potting elements is formed from a non-self-leveling paste applied into the respective one of the plurality of apertures and cured to harden therein. Kawakami discloses a multi-cell rechargeable energy storage system (RESS) (battery pack) comprising a plurality of battery cells (1) and a heat insulating member (8) accommodated in a housing (external case, 11) (Figure 1, [0042-0043]). Kawakami further discloses that the heat insulating member (8) is disposed on the surface of bus bars (3) connected with electrode poles (electrode terminals, 1x/1y) and serves to insulate neighboring components of the RESS (battery pack) from heat generated from the plurality of battery cells (1) (Figure 1, [0065]). Kawakami further discloses that the heat insulating member (8) is formed from a potting resin, wherein the potting resin may be urethane resin which is applied to positioning hollows (2D) and cured (Figure 1, [0066-0067, 0069]). Kawakami further discloses that the uncured potting resin may be in paste form, and that the potting resin is continuously supplied cured over time to form the heat insulating member (8) (Figure 1, [0066, 0074]). Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to select for the potting element of Georgiadis, the urethane potting resin taught by Kawakami, as such a resin is known in the art as suitable for a potting resin being in contact with an electrode pole of a battery cell in a RESS, as taught by Kawakami. Furthermore, the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination (MPEP 2144.07). By doing so, the skilled artisan would have a reasonable expectation of success in providing a potting element which successfully insulates neighboring components of the RESS (battery pack) from heat generated from the plurality of battery cells, as taught by Kawakami and as is desired by Georgiadis as noted above. Upon such a modification, all of the limitations of Claim 14 are met. Claims 9-10 and 15-16 are rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) as modified by Yang et al. (US 2022/0320651 A1) and Kawakami et al. (US 2020/0076022 A1), as applied to Claims 8 and 14 above, further in view of Capati et al. (US 2019/0081294 A1) and Savaria et al. (US 2004/0137321 A1). In Regards to Claim 9 (Dependent Upon Claim 8): Georgiadis as modified by Yang and Kawakami discloses the multi-cell RESS of Claim 8 as set forth above. As detailed above in the rejection of Claim 8, modified Georgiadis discloses that the potting elements (potting compound, 13) may be formed from a urethane resin. Georgiadis is 1) silent to the material of the cell holder, and 2) deficient in disclosing that the potting element paste includes additives configured to match a thermal expansion coefficient of the potting elements with a coefficient of thermal expansion of the cell holder. Regarding 1), Capati discloses a multi-cell rechargeable energy storage system (RESS) (battery module, 100) comprising: a plurality of battery cells (110) and a cell holder (first cell holder, 130) configured to support the plurality of battery cells (110) (Figures 1 and 2, [0020, 0025]). Capati further discloses that the cell holder (first cell holder, 130) may be formed from a nylon material with glass filler (Figure 2, [0063]). Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to select for the material of the cell holder of Georgiadis, a glass-filled nylon material, as it is known in the art that such a material is suitable for forming a cell holder for a RESS, as taught by Capati. Furthermore, the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination (MPEP 2144.07). Regarding 2), Savaria discloses a composite thermoset material for use in an energy storage device, wherein the composite thermoset material may be urethane which is reinforced with additives such as glass fillers [0031, 0054]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to modify the urethane of the potting elements of modified Georgiadis to include glass fillers, as it is known in the art that a urethane material comprising glass fillers is a suitable selection as a composite thermoset material for use in an energy storage device, as taught by Savaria. Furthermore, the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination (MPEP 2144.07). The examiner notes that the term “a thermal expansion coefficient” as written is a broad limitation and is subject to the broadest reasonable interpretation during the review of prior art. As such the skilled artisan would appreciate that upon the above modifications, the additive (glass filler) of the potting element paste and the cell holder (comprising glass filler) would be expected to have a matching thermal expansion coefficient (i.e., the thermal expansion coefficient of the glass filler in both the potting element paste and the cell holder would be expected to match). Thus, upon all of the above modifications all of the limitations of Claim 9 are met. In Regards to Claim 10 (Dependent Upon Claim 9): Georgiadis as modified by Yang, Kawakami, Capati, and Savaria discloses the multi-cell RESS of Claim 9 as set forth above. As detailed above in the rejection of Claim 9, modified Georgiadis discloses that the cell holder (separating elements, 4) is constructed from a glass-filled nylon material. Thus, all of the limitations of Claim 10 are met. In Regards to Claim 15 (Dependent Upon Claim 14): Georgiadis as modified by Yang and Kawakami discloses the cell support assembly of Claim 14 as set forth above. As detailed above in the rejection of Claim 14, modified Georgiadis discloses that the potting elements (potting compound, 13) may be formed from a urethane resin. Georgiadis is 1) silent to the material of the cell holder, and 2) deficient in disclosing that the potting element paste includes additives configured to match a thermal expansion coefficient of the potting elements with a coefficient of thermal expansion of the cell holder. Regarding 1), Capati discloses a multi-cell rechargeable energy storage system (RESS) (battery module, 100) comprising: a plurality of battery cells (110) and a cell holder (first cell holder, 130) configured to support the plurality of battery cells (110) (Figures 1 and 2, [0020, 0025]). Capati further discloses that the cell holder (first cell holder, 130) may be formed from a nylon material with glass filler (Figure 2, [0063]). Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to select for the material of the cell holder of Georgiadis, a glass-filled nylon material, as it is known in the art that such a material is suitable for forming a cell holder for a RESS, as taught by Capati. Furthermore, the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination (MPEP 2144.07). Regarding 2), Savaria discloses a composite thermoset material for use in an energy storage device, wherein the composite thermoset material may be urethane which is reinforced with additives such as glass fillers [0031, 0054]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to modify the urethane of the potting elements of modified Georgiadis to include glass fillers, as it is known in the art that a urethane material comprising glass fillers is a suitable selection as a composite thermoset material for use in an energy storage device, as taught by Savaria. Furthermore, the selection of a known material based on its suitability for its intended use supports a prima facie obviousness determination (MPEP 2144.07). The examiner notes that the term “a thermal expansion coefficient” as written is a broad limitation and is subject to the broadest reasonable interpretation during the review of prior art. As such the skilled artisan would appreciate that upon the above modifications, the additive (glass filler) of the potting element paste and the cell holder (comprising glass filler) would be expected to have a matching thermal expansion coefficient (i.e., the thermal expansion coefficient of the glass filler in both the potting element paste and the cell holder would be expected to match). Thus, upon all of the above modifications all of the limitations of Claim 15 are met. In Regards to Claim 16 (Dependent Upon Claim 15): Georgiadis as modified by Yang, Kawakami, Capati, and Savaria discloses the cell support assembly of Claim 15 as set forth above. As detailed above in the rejection of Claim 15, modified Georgiadis discloses that the cell holder (separating elements, 4) is constructed from a glass-filled nylon material. Thus, all of the limitations of Claim 16 are met. Claims 17-19 are rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) further in view of Yang et al. (US 2022/0320651 A1) and Capati et al. (US 2019/0081294 A1). In Regards to Claim 17: Georgiadis discloses a multi-cell rechargeable energy storage system (RESS) (battery cell arrangement, 1) comprising: a plurality of battery cells (2), wherein each battery cell (2) includes a respective cell vent (degassing valve) configured to expel gases; and a cell support assembly (separating elements, 4, and potting compound, 13) with thermal runaway mitigation (Figures 1 and 10A, [0079-0080, 0100]). Georgiadis further discloses that the cell support assembly (separating elements, 4, and potting compound, 13) includes: a cell holder (separating elements, 4) configured to support the plurality of battery cells (2) and having a holder body defining a plurality of apertures (vent channels, 5) arranged in rows, wherein each aperture (vent channels, 5) is configured to align and be in fluid communication with the cell vent (degassing valve) of one of the plurality of battery cells (2) (Figures 1 and 10B, [0080-0081]). Georgiadis further discloses that the cell support assembly (separating elements, 4, and potting compound, 13) includes a plurality of potting elements (potting compound, 13), wherein each potting element (potting compound, 13) is arranged in one of the plurality of apertures (vent channels, 5) (Figure 10A, [0100, 0101]). Georgiadis further discloses that each potting elements (potting compound, 13) is filled in the gaps (4b) formed between the cell holder (separating elements, 4) and the battery cells (2), thus the potting elements (potting compound, 13) are configured to adhere to the battery cell (2) and the cell holder (separating elements, 4) (Figure 10b, [0101]). Georgiadis further discloses a RESS enclosure (housing, 3, and cover elements, 6) having a tray (cover elements, 6) and a mating cover (housing, 3) and configured to house the plurality of battery cells (2), the cell holder (separating elements, 4), and the plurality of potting elements (potting compound, 13) (Figure 10A, [0080, 0083]). Georgiadis further discloses that the RESS (battery cell arrangement, 1) may be used to power a motor vehicle [0005-0006]. Georgiadis is deficient in disclosing 1) a plurality of thermal-barrier strips adhered to the cell holder, wherein each thermal-barrier strip extends parallel to a respective row of apertures and is configured to thermally insulate corresponding battery cells from gases expelled by neighboring battery cells during a thermal runaway; 2) that at least a region of the cell holder is not in contact with the thermal-barrier strips; 3) that each potting element is arranged in one of the plurality of apertures such that it is between a respective battery cell and a corresponding thermal-barrier strip and configured to adhere to the battery cell and to the corresponding thermal-barrier strip to maintain position of the battery cell on the cell holder; and 4) a motor vehicle comprising: a power-source configured to generate power-source torque, wherein the RESS is configured to supply electrical energy to the power-source. Regarding 1)-3), Yang discloses a multi-cell rechargeable energy storage system (RESS) (battery, 10) comprising: a plurality of battery cells (20), wherein each battery cell (20) includes a respective cell vent (pressure relief mechanism, 213) configured to expel gases (Figures 2 and 5, [0111, 0116-0117]). Yang further discloses that in a situation wherein gas is expelled from the RESS (battery, 10), the emissions may be released from the cell vent (pressure relief mechanism, 213) to a collection chamber (11b) defined by a thermal management component (13) and then follow an exhaust path to be discharged from the battery box (11) (Figure 6, [0143, 0188]). Yang further discloses that heat-resisting material may be pasted on the surface of the thermal management component (13) forming the exhaust path, wherein the heat-resisting material may be mica paper (Figure 6, [0046]). Yang further discloses that the use of a heat-resisting material serves to protect the surface of the exhaust path [0046]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to modify the RESS of Georgiadis to include the heat-resisting material of Yang on the surfaces of the plurality of apertures and the RESS enclosure wherein gas travels during venting, as it is known in the art that coating such interior surfaces of a RESS where gas is exhausted serves to protect surfaces of the exhaust path, as taught by Yang. By doing so, the skilled artisan would have a reasonable expectation of success in improving the overall safety and lifespan of the RESS as well as prevent thermal damage to the RESS, as taught by Yang. Upon the above modification, the skilled artisan would appreciate that the heat-resisting material may be considered a thermal barrier strip as Yang teaches it may be mica paper. Additionally, the skilled artisan would appreciate that it may be considered to extend parallel to a respective row of apertures as it would have some dimension (i.e., thickness) in a direction parallel to a respective row of apertures and would thermally insulate corresponding battery cells from gases expelled by neighboring battery cells during a thermal runaway. Likewise, the skilled artisan would appreciate that when the heat-resisting material is applied only to surfaces of the exhaust path, there would indeed be regions of the cell holder which is not in contact with the thermal barrier strips, for example the portions of the cell holder which are located “below” the cell vent. Upon the above modification, the skilled artisan would appreciate that a plurality of thermal-barrier strips are adhered to the cell holder, each potting element is arranged in one of the plurality of apertures such that it is between a respective battery cell and a corresponding thermal-barrier strip and configured to adhere to the battery cell and to the corresponding thermal-barrier strip to maintain position of the battery cell on the cell holder. Regarding 4), Capati discloses a multi-cell rechargeable energy storage system (RESS) (battery module, 100) comprising: a plurality of battery cells (110) and a cell holder (first cell holder, 130) configured to support the plurality of battery cells (110) (Figures 1 and 2, [0020, 0025]). Capati further discloses that the RESS (battery module, 100) may be utilized within a motor vehicle to supply electrical energy to a high-torque motor (Figure 5, [0002, 0066]). Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to utilize the RESS of modified Georgiadis in a motor vehicle with a high-torque motor being powered by the RESS, as it is known in the art that such an RESS is suitable for application in a motor vehicle, as taught by Capati, and furthermore as Georgiadis teaches the RESS may be suitable for use in a vehicle. Upon the above modifications, all of the limitations of Claim 17 are met. In Regards to Claim 18 (Dependent Upon Claim 17): Georgiadis as modified by Yang and Capati discloses the motor vehicle of Claim 17 as set forth above. As detailed above in the rejection of Claim 17, modified Georgiadis discloses an RESS enclosure (housing, 3, and cover elements, 6) having a tray (cover elements, 6) and a mating cover (housing, 3) and configured to house the plurality of battery cells (2), the cell holder (separating elements, 4), the plurality of thermal-barrier strips, and the plurality of potting elements (potting compound, 13) (Figure 10A, [0080, 0083]). Georgiadis further discloses that the cell holder (separating elements, 4) is configured to engage and fit together with the enclosure tray (cover elements, 6) (Figure 10A, [0083]). Thus, all of the limitations of Claim 18 are met. In Regards to Claim 19 (Dependent Upon Claim 18): Georgiadis as modified by Yang and Capati discloses the motor vehicle of Claim 18 as set forth above. Georgiadis further discloses that the enclosure tray (cover elements, 6) includes multiple channels (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4) and the cell holder (separating elements, 4) includes multiple integral projection portions (portion of separating elements, 4, in contact with groove portion, 6b) (Figure 9A, [0088, 0097]). Georgiadis further discloses that each of the cell holder projection portions (portion of separating elements, 4, in contact with groove portion, 6b) is configured to engage one of the enclosure tray channels (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4), thereby establishing a plurality of longitudinal fluid passages (region of vent channels, 5, corresponding to cover elements, 6) (Figures 9A and 10A, [0095, 0097]). Georgiadis further discloses that each fluid passage (region of vent channels, 5, corresponding to cover elements, 6) extends along at least one of the rows of apertures (vent channels, 5) to direct the gases expelled by corresponding battery cells (2) (Figure 10A, [0079, 0083]). Thus, all of the limitations of Claim 19 are met. Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Georgiadis (US 2024/0128583 A1) (disclosed by Applicant on IDS dated 03/12/2026) as modified by Yang et al. (US 2022/0320651 A1) and Capati et al. (US 2019/0081294 A1), as applied to Claim 19 above, further in view of Turpin et al. (US 2013/0337246 A1). In Regards to Claim 20 (Dependent Upon Claim 19): Georgiadis as modified by Yang and Capati discloses the motor vehicle of Claim 19 as set forth above. Georgiadis further discloses an adhesive arranged inside the enclosure tray channel (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4) between the enclosure tray (cover elements, 6) and the corresponding holder projection portion (portion of separating elements, 4, in contact with groove portion, 6b) to thereby fix the cell holder (separating elements, 4) of the cell support assembly (separating elements, 4, and potting compound, 13) which forms the plurality of apertures (vent channels, 5) to the enclosure tray (cover elements, 6) (Figure 10A, [0083]). Upon the modification detailed above in the rejection of Claim 17, modified Georgiadis discloses that the thermal-barrier strips are present on the interior surfaces of the plurality of apertures (vent channels, 5) and the RESS enclosure (housing, 3, and cover elements, 6) which form the exhaust path, including the tray (cover elements, 6). As such, the skilled artisan would appreciate that when the thermal-barrier strips are present on the interior surfaces of the tray (cover elements, 6), each of the thermal-barrier strips may be considered to include a strip section extending into a respective enclosure tray channel (groove portion, 6b, of cover elements, 6, which defines vent channels, 5, alongside separating elements, 4) between the enclosure tray (cover elements, 6) and the corresponding holder projection portion (portion of separating elements, 4, in contact with groove portion, 6b) (Figure 10A, [0095, 0097]). Modified Georgiadis further discloses that the thermal-barrier strips are formed from mica paper. Georgiadis does not explicitly teach that each of the potting elements (potting compound, 13) is configured to separate from the respective aperture (vent channels, 5) under a force of the expelled gases and thereby break away a portion of the corresponding barrier strip into the corresponding fluid passage (region of vent channels, 5, corresponding to cover elements, 6). However, the examiner notes that the term “a force” as written is a broad limitation and is subject to the broadest reasonable interpretation during the review of prior art. As such, the skilled artisan would appreciate that there is necessarily a force the expelled gases may achieve which would result in the separation of the potting elements (potting compound, 13) from the respective aperture (vent channels, 5) and the “breaking away” of the corresponding barrier strip into the corresponding fluid passage (region of vent channels, 5, corresponding to cover elements, 6). Modified Georgiadis is deficient in disclosing that the thermal-barrier strips are formed from FRB paper. Turpin discloses a flexible electrical insulation article which comprises a nonwoven paper [0004, 0019]. Turpin further discloses that the nonwoven paper may be selected from a list which includes FRB paper and mica paper [0023, 0025]. Turpin further discloses that the flexible electrical insulation article can possess desirable thermal conductivity properties [0004]. Therefore, it would be obvious to one of ordinary skill in the art at the time of the filing of the invention to select for the material of the thermal-barrier strips, FRB paper, as FRB paper is known in the art to be a suitable alternative to mica paper for use as a nonwoven paper in a material having thermal conductivity properties, as taught by Turpin. The substitution of known equivalent structures involves only ordinary skill in the art. In re Fout 213 USPQ 532 (CCPA 1982); In re Susi 169 USPQ 423 (CCPA 1971); In re Siebentritt 152 USPQ 618 (CCPA 1967); In re Ruff 118 USPQ 343 (CCPA 1958). When a patent claims a structure already known in the prior art that is altered by the mere substitution of one element for another known in the field, the combination must do more than yield a predictable result. Upon the above modification, all of the limitations of Claim 20 are met. Response to Arguments Applicant’s arguments, filed 06/01/2026, with respect to the rejection of Claims 1-20 under 35 U.S.C. have been fully considered and are persuasive. Therefore, the rejection has been withdrawn. However, upon further consideration, a new grounds of rejection is made in view of Georgiadis (US 2024/0128583 A1), Yang et al. (US 2022/0320651 A1), Turpin et al. (US 2013/0337246 A1), Hamdani et al. (Polymer Degradation and Stability 94 (2009) 465–495), Kawakami et al. (US 2020/0076022 A1), Capati et al. (US 2019/0081294 A1), and Savaria et al. (US 2004/0137321 A1). 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 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. Any inquiry concerning this communication or earlier communications from the examiner should be directed to EMILY E FREEMAN whose telephone number is (571)272-1498. The examiner can normally be reached Monday - Friday 8:30AM-5:00PM. 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, Miriam Stagg can be reached at (571)-270-5256. 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. /E.E.F./ Examiner, Art Unit 1724 /STEWART A FRASER/ Primary Examiner, Art Unit 1724
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Prosecution Timeline

May 31, 2023
Application Filed
Apr 09, 2026
Non-Final Rejection mailed — §103, §112, §Other
May 27, 2026
Applicant Interview (Telephonic)
May 27, 2026
Examiner Interview Summary
Jun 01, 2026
Response Filed
Aug 24, 2026
Final Rejection mailed — §103, §112, §Other (current)

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