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 .
Election/Restrictions
Applicant’s election of Invention 1, Species A1, B1, C1, and D1 in the reply filed on 2/17/2026 is acknowledged. Because applicant did not distinctly and specifically point out the supposed errors in the restriction requirement, the election has been treated as an election without traverse (MPEP § 818.01(a)).
Claims 3-4, 6, 9-10, 17-20 are withdrawn from further consideration pursuant to 37 CFR 1.142(b) as being drawn to a nonelected invention and/or species, there being no allowable generic or linking claim. Election was made without traverse in the reply filed on 2/17/2026.
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
Claims 1-2, 5, 7-8, 11-16 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 1 recites the limitation "the external tabs" in line 15. There is insufficient antecedent basis for this limitation in the claim. The limitation renders the claim indefinite because it is unclear as to which among the external tabs of the C cathode electrodes and external tabs of the A anode electrodes said limitation refers to.
Claim 12 recites the limitation "the predetermined angle". There is insufficient antecedent basis for this limitation in the claim. The limitation renders the claim indefinite because it is unclear whether the limitation refers to the predetermined angle of the terminal recited in claim 1 or the predetermined angle of the cut external tabs of the one of the A anode electrodes or the C cathode electrodes recited in claim 11.
Further, dependent claims 2, 5, 7-8, 11-16 are rendered indefinite due to their dependency on any of the indefinite claims as set forth above.
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, 7-8 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by KR20140125862A, refer to English machine translation by EPO.
Regarding claim 1, KR20140125862A discloses a method for manufacturing a battery cell (method of manufacturing battery [0023], Fig. 1-9), comprising:
providing a stack (stack [0024]) 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 (double coated electrode on current collector [0024], tabs 25 [0025], Fig. 1-5,7-8);
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 (double coated electrode on current collector [0024], tabs 25 [0025], Fig. 1-5,7-8); and
S separators, where C, S and A are integers greater than one (separator 23 interposed between anode electrode 21 and cathode electrode 22, repeatedly stacked [0024], Fig. 1-5,7-8); and
providing a terminal including a first portion connected to a second portion at a predetermined angle less than or equal to 100° (busbar plate 14 [0025], Fig. 1, 6-8 show busbar plate 14 including a first portion connected to a second portion at an angle of about 90°);
positioning external tabs of one of the A anode electrodes and the C cathode electrodes in contact with one of an inner surface and an outer surface of the first portion of the terminal (busbar plate 14 disposed on both right and left sides of tab 25, busbar plate 14 is provided with slits having a welding plate 63 that can be bent upwards to form a flat surface [0025], Fig. 1, 6-8); and
laser welding ends of the external tabs to the one of an inner surface and an outer surface of the first portion of the terminal (tab 25 is welded by ultrasonic spot welding [0025]; ultrasonic spot welder or other suitable welding technique/the like [0029], claim 10 recites welding by ultrasonic spot welding, laser welding, or the like).
Regarding claim 2, KR20140125862A discloses all of the claim limitations as set forth above. KR20140125862A further discloses the predetermined angle is in a range from 80° to 100° (busbar plate 14 [0025], Fig. 1, 6-8 show busbar plate 14 including a first portion connected to a second portion at an angle of about 90°).
Regarding claim 5, KR20140125862A discloses all of the claim limitations as set forth above. KR20140125862A further discloses the first portion of the terminal has a height that is greater than or equal to a height of the stack (Fig. 1,7-8 show busbar plate 14 having a height that is greater than or equal to a height of the stack).
Regarding claim 7, KR20140125862A discloses all of the claim limitations as set forth above. KR20140125862A further discloses the external tabs of the one of the A anode electrodes and the C cathode electrodes are laser welded to an outer surface of the terminal (Fig. 6B shows a busbar plate 14 having no welding plate 63. Tab 25 is folded and welded onto the busbar plate 14 to connect the electrode structure to the terminal. [0029]; The process describes welding tabs 25 to an outer surface of busbar plate 14.).
Regarding claim 8, KR20140125862A discloses all of the claim limitations as set forth above. KR20140125862A further discloses the external tabs of the one of the A anode electrodes and the C cathode electrodes are laser welded to an inner surface of the terminal (Busbar plate 14 includes slits 15, each slit 15 having a welding plate 63 that can be bent upward to form a flat surface. Tabs 25 are welded to welding plate 63. After the welding process is complete, the welded terminals are bent upwards to form a flat surface. Welds are applied to the upper and lower heads of the welding plate. [0029], Fig. 6A; The process describes welding tabs 25 to an inner surface (i.e., welded to a welding plate 63 to be then folded to form a flat surface) of the busbar plate 14.).
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) 11-13 is/are rejected under 35 U.S.C. 103 as being unpatentable over KR20140125862A, refer to English machine translation by EPO, as applied to claims 1-2, 5, 7-8 above, in view of Park et al. (US 2016/0260952A1).
Regarding claim 11, KR20140125862A discloses all of the claim limitations as set forth above. However, KR20140125862A does not further disclose 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.
Park discloses a connecting structure and method between grid 110 and electrode tab 120 of secondary battery, wherein the connecting method includes cutting the grid, stacking the grid and the electrode tab and then welding ([0018], [0056], Fig. 1-4).
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.
Regarding claim 12, modified KR20140125862A discloses all of the claim limitations as set forth above. Park further discloses the predetermined angle is within +/−10° of an angle formed between the first portion and the second portion of the terminal (Fig. 1-4 show cut at a predetermined angle of around 90°).
Regarding claim 13, modified KR20140125862A discloses all of the claim limitations as set forth above. KR20140125862A further discloses the laser welding is performed through the first portion of the terminal (busbar plate 14 disposed on both right and left sides of tab 25, busbar plate 14 is provided with slits having a welding plate 63 that can be bent upwards to form a flat surface [0025], Fig. 1, 6-8).
Claim(s) 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over KR20140125862A, refer to English machine translation by EPO, as applied to claims 1-2, 5, 7-8 above, in view of Okuda et al. (US 2015/0017509A1).
Regarding claim 14, KR20140125862A discloses all of the claim limitations as set forth above. Although KR20140125862A further discloses spot welding ([0025], [0029], claim 10), 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) 15-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over KR20140125862A, refer to English machine translation by EPO, as applied to claims 1-2, 5, 7-8 above, in view of Tao et al. (US 2019/0305285A1).
Regarding claim 15, KR20140125862A discloses all of the claim limitations as set forth above. However, KR20140125862A does not further disclose pressing the external tabs of the one of the A anode electrodes and the C cathode electrodes against the terminal prior to 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]).
KR20140125862A 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.
Regarding claim 16, KR20140125862A discloses all of the claim limitations as set forth above. However, KR20140125862A 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]).
KR20140125862A 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.
Conclusion
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.
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/James Lee/Primary Examiner, Art Unit 1725 3/6/2026