Prosecution Insights
Last updated: October 02, 2026
Application No. 18/337,916

LASER-WELDING OF EXTERNAL TABS OF ELECTRODES TO INTERNAL TERMINALS OF BATTERY CELLS

Final Rejection §102§103
Filed
Jun 20, 2023
Examiner
LEE, JAMES
Art Unit
1725
Tech Center
1700 — Chemical & Materials Engineering
Assignee
GM Global Technology Operations LLC
OA Round
2 (Final)
74%
Grant Probability
Favorable
3-4
OA Rounds
0m
Est. Remaining
94%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allowance Rate
542 granted / 730 resolved
+9.2% vs TC avg
Strong +20% interview lift
Without
With
+19.5%
Interview Lift
resolved cases with interview
Typical timeline
3y 2m
Avg Prosecution
36 currently pending
Career history
764
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
48.1%
+8.1% vs TC avg
§102
22.1%
-17.9% vs TC avg
§112
23.5%
-16.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 730 resolved cases

Office Action

§102 §103
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 . Claim Rejections - 35 USC § 102 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. Claim(s) 1-2, 5, 11-13, 15 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Lim et al. (KR100754918B1, refer to English machine translation). Regarding claim 1, Lim discloses a method for manufacturing a battery cell (see Title, Fig. 5-16), comprising: providing a stack (stack, see p.3, Fig. 5-16) including: C cathode electrodes each including a cathode current collector, a cathode active layer arranged on the cathode current collector, and an external tab extending from the cathode current collector (positive electrode including electrode active material, current collector and pole tab 20, see p.3, Fig. 5-16); A anode electrodes including an anode current collector, an anode active layer arranged on the anode current collector, and an external tab extending from the anode current collector (negative electrode including electrode active material, current collector and pole tab 20, see p.3, Fig. 5-16); and S separators, where C, S and A are integers greater than one (separator, see p.3, Fig. 5-16 show C, S, A are greater than one); and providing a terminal including a first portion connected to a second portion at a predetermined angle less than or equal to 100° (current collector plate 60 including flap 62, see p.4, Fig. 8-9 show flap 62 bent about 90 degrees); positioning external tabs of one of the A anode electrodes and the C cathode electrodes in contact with an inner surface of the first portion of the terminal such that the external tabs of one of the A anode electrodes and the C cathode electrodes are between the inner surface of the terminal and the stack (see Fig. 8-9 which show pole tab 20 in contact with an inner surface of the current collector plate 60); and laser welding ends of the external tabs of one of the A anode electrodes and the C cathode electrodes to the inner surface of the first portion of the terminal (weld with laser beam, see p.4). Regarding claim 2, Lim discloses all of the claim limitations as set forth above. Lim further discloses the predetermined angle is in a range from 80° to 100° (current collector plate 60 including flap 62, see p.4, Fig. 8-9 show flap 62 bent about 90 degrees). Regarding claim 5, Lim discloses all of the claim limitations as set forth above. Lim further discloses the first portion of the terminal has a height that is greater than or equal to a height of the stack (Fig. 8 shows current collector plate 60 having a height greater than a height of the stack 50). Regarding claim 11, Lim discloses all of the claim limitations as set forth above. Lim further discloses cutting the external tabs of the one of the A anode electrodes and the C cathode electrodes at a predetermined angle prior to laser welding (cut, see p.3). Regarding claim 12, Lim discloses all of the claim limitations as set forth above. Lim further discloses the predetermined angle of the external tabs that have been cut is within +/−10° of an angle formed between the first portion and the second portion of the terminal (cut to form connection portion 25, see p.3, Fig. 5-6 show the cut forms a connection portion 25 and tap 20 forming a right angle that is 90 degrees and, thus, within 10 degrees of the angle formed between the first portion and the second portion of the current collector plate 60). Regarding claim 13, Lim discloses all of the claim limitations as set forth above. Lim further discloses the laser welding is performed through the first portion of the terminal (welded, see p.3-4, Fig. 8-9). Regarding claim 15, Lim discloses all of the claim limitations as set forth above. Lim further discloses pressing the external tabs of the one of the A anode electrodes and the C cathode electrodes against the terminal prior to laser welding (interposed and then joined by welding, see p.4). Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. The factual inquiries for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows: 1. Determining the scope and contents of the prior art. 2. Ascertaining the differences between the prior art and the claims at issue. 3. Resolving the level of ordinary skill in the pertinent art. 4. Considering objective evidence present in the application indicating obviousness or nonobviousness. This application currently names joint inventors. In considering patentability of the claims the examiner presumes that the subject matter of the various claims was commonly owned as of the effective filing date of the claimed invention(s) absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and effective filing dates of each claim that was not commonly owned as of the effective filing date of the later invention in order for the examiner to consider the applicability of 35 U.S.C. 102(b)(2)(C) for any potential 35 U.S.C. 102(a)(2) prior art against the later invention. Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim et al. (KR100754918B1, refer to English machine translation), as applied to claims 1-2, 5, 11-13, 15 above, in view of Okuda et al. (US 2015/0017509A1). Regarding claim 14, Lim discloses all of the claim limitations as set forth above. Although Lim further discloses spot welding (see p.4), the reference does not further disclose the laser welding forms a butt weld between the terminal and the external tabs of the one of the A anode electrodes and the C cathode electrodes. Okuda discloses negative lead 25 may be welded by various methods including spot welding, butt welding, and projection welding. Also, welding is not restricted to resistance welding but any other suitable welding method may be employed. ([0078]) An obviousness determination is not the result of a rigid formula disassociated from the consideration of the facts of a case. Indeed, the common sense of those skilled in the art demonstrates why some combinations would have been obvious where others would not. Leapfrog Enterprises Inc. v. Fisher-Price Inc., 82 USPQ2d 1687 (Fed. Cir. 2007); see also KSR v. Teleflex, 82 USPQ2d 1385, 127 S. Ct. 1727 (2007). The claim would have been obvious because a particular known technique was recognized as part of the ordinary capabilities of one skilled in the art. The claim would have been obvious because “a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If the leads to the anticipated success, it is likely the product not of innovation but of ordinary skill and common sense.” It has been held that choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success is generally within the skill of the art. Claim(s) 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Lim et al. (KR100754918B1, refer to English machine translation), as applied to claims 1-2, 5, 11-13, 15 above, in view of Tao et al. (US 2019/0305285A1). Regarding claim 16, Lim discloses all of the claim limitations as set forth above. However, Lim does not further disclose pressing the external tabs of the one of the A anode electrodes and the C cathode electrodes against the terminal and clamping the stack to at least one of the terminal and a supporting surface during laser welding. Tao discloses a clamping system and method for laser welding battery foils to a battery tab (see Title, Abstract, Fig. 16), wherein battery foils are stacked and a clamping force is used to eliminate or minimize the size of gaps between battery foils to create a structurally strong and efficient battery tab-to-foil weld ([0028]). Lim and Tao are analogous art because they are concerned with the same field of endeavor, namely method of welding battery tabs. It would have been obvious to one having ordinary skill in the art before the effective filing date of the claimed invention to incorporate a clamping system for pressing/clamping during welding because Tao teaches creating a structurally strong and efficient weld. Response to Arguments Applicant's arguments filed 6/17/2026 have been fully considered but they are not persuasive. With respect to applicant’s arguments directed to KR20140125862A failing to teach or suggest new limitation recited in claim 1 (see Remarks filed 6/17/2026), said reference is no longer relied upon to teach or suggest any of the instant claims. Instead, a new reference Lim et al. (KR100754918B1, refer to English machine translation) is relied upon to teach at least claim 1 as set forth above. 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 JAMES LEE whose telephone number is (571)270-7937. The examiner can normally be reached M-F: 9AM - 5PM. 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, NICOLE BUIE-HATCHER can be reached at (571)270-3879. 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. /James Lee/Primary Examiner, Art Unit 1725 8/25/2026
Read full office action

Prosecution Timeline

Jun 20, 2023
Application Filed
Mar 17, 2026
Non-Final Rejection mailed — §102, §103
May 22, 2026
Applicant Interview (Telephonic)
May 26, 2026
Examiner Interview Summary
Jun 17, 2026
Response Filed
Aug 27, 2026
Final Rejection mailed — §102, §103 (current)

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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

3-4
Expected OA Rounds
74%
Grant Probability
94%
With Interview (+19.5%)
3y 2m (~0m remaining)
Median Time to Grant
Moderate
PTA Risk
Based on 730 resolved cases by this examiner. Grant probability derived from career allowance rate.

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