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 § 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.
Claims 1-2, 4, and 7 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Kim US-20220393284-A1, and further in view of Zhang US-20210071912-A1 and Kim-2 US-20230420764-A1.
Regarding claim 1, Kim US-20220393284-A1 teaches:
A pressure control apparatus for a battery cell (Fig. 4), comprising:
a housing (320) in which the battery cell (311) is disposed;
a cell plate (380) movably disposed ((0085), "Specifically, if the swelling phenomenon of the battery cells 311 is stronger than a designed load limit, the thickness of each battery cell 311 increases, and the pressing plate 380 moves in a lamination direction of the battery cell stack 310" ) in the housing (320) and separating an interior of the housing into:
a cell chamber (310) having the battery cell (311) therein; and
a pressure chamber (330) having a volume of pressurized fluid therein (controlling inflow of the fluid into the tube 330).
Kim teaches a stopper block (390). However, Kim is silent on a valve configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when the pressure in the pressure chamber exceeds a threshold.
Zhang further teaches that a valve can be used in place of a stopper ((0006), “The swing mechanism may comprise a flap or valve block and stopper”).
If the valve of Zhang is placed at the position of the position of the stopper block (390) of Kim in Kim FIG. 4 by substitution of parts, it is inherent that the valve of Zhang will be configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when the pressure in the pressure chamber exceeds a threshold. This is enabled by the configured placement of the valve, as discussed herein.
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Kim by inclusion of a valve configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when the pressure in the pressure chamber exceeds a threshold, as suggested by Zhang. This modification would benefit the system by regulating the pressure of the [pressurized fluid] in the pressure chamber.
Modified Kim is silent on a fluid circuit.
Kim-2 teaches:
a fluid circuit (Kim-2, 153+154; The Examiner notes that Applicant's instant disclosure FIG. 2 depicts the fluid circuit as comprising Applicant fluid inlet and fluid outlet) operably connected to the pressure chamber (111 of Kim-2) to provide the pressurized fluid ((0092), "the fluid lines 153 and 154 and configured to control the supply and discharge of a pressurizing fluid") thereto,
the fluid circuit defining a fluid inlet (153) and a fluid outlet (154) at the pressure chamber;
wherein the valve (159 of Kim-2) is disposed at the fluid outlet.
Modification of the disclosure of modified Kim by inclusion of a fluid circuit, with associated components and positions, as suggested by Kim-2, would benefit the disclosure of modified Kim by ensuring continued pressure to be applied to each cell during volume change of the battery during charging and discharging (Kim-2, (0015)).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective time of filing of the instant disclosure to modify the disclosure of modified Kim by inclusion of a fluid circuit, with associated components and positions, as suggested by Kim-2.
Regarding claim 2, modified Kim teaches the pressure control apparatus of claim 1 (modified Kim), wherein the fluid circuit includes a fluid pump (Kim, 340) to pressurize the pressure chamber with fluid ((0081), "a fluid supply device 340 connected to the tube 330 and ... controlling inflow of the fluid into the tube 330 and maintaining a constant surface pressure of battery cells 311.").
Regarding claim 4, modified Kim teaches the pressure control apparatus of claim 1 (modified Kim) and one or more pressure sensors (360) disposed exterior to the pressure chamber
Modified Kim is silent on one or more pressure sensors (360) disposed in the pressure chamber.
Modified Kim, however, teaches wherein the valve (stopper block 390, modified with replacement by the valve 3 of Zhang ) is operated in response to a pressure exceeding the threshold detected by the one or more pressure sensors (360).
The Examiner notes that the Kim teaches a valve 350 operated in response to a pressure exceeding the threshold detected by the one or more pressure sensors (360) ((0082), “The pressure sensor 360 may be connected to … the fluid control valve 350 and measure the pressure change of the tube 330 into which the fluid flows”; (0081), “a fluid control valve 350 connected to the tube and to the fluid supply device 340, and controlling inflow of the fluid into the tube 330 and maintaining a constant surface pressure of battery cells 311).
Therefore, it would have been obvious to one of ordinary skill in the art to apply the same technology of a valve connected to a pressure sensor to the modified valve 390 of Kim (as previously aforementioned modified by Zhang) that is disposed inside the pressure chamber as it has been held that rearranging parts of an invention involves only routine skill in the art while the device having the claimed dimensions would not perform differently than the prior art device, In re Japikse, 86 USPQ 70 and since it has been held that a mere reversal of the essential working parts of a device involves only routine skill in the art, In re Einstein, 8 USPQ 167.
Moreover, it would be within the skill of one ordinary in the art to include the pressure sensors inside the pressure chamber since the valve is also located inside the pressure chamber. As seen in FIG. 4 of Kim, the pressure sensor 360 is in proximity to the valve 350. Therefore, if the valve 350 is additionally inside the pressure chamber to replace 390 as aforementioned modified, a pressure sensor 360 would additionally be placed inside the pressure chamber to stay in proximity. Furthermore, it has been held that rearranging parts of an invention involves only routine skill in the art while the device having the claimed dimensions would not perform differently than the prior art device, In re Japikse, 86 USPQ 70 and since it has been held that a mere reversal of the essential working parts of a device involves only routine skill in the art, In re Einstein, 8 USPQ 167.
Regarding claim 7, modified Kim the pressure control apparatus of claim 1 (modified Kim), wherein the pressure in the pressure chamber increases in response to an increase in size of the battery cell
The Examiner notes that it is inherent that if a pressure exceeding the threshold is detected by the one or more pressure sensors (Kim, 360), this event occurs from the increase in size of the battery cell.
Therefore, it is inherent that the pressure in the pressure chamber increases in response to an increase in size of the battery cell.
Claim 3 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over modified Kim as applied to claim 1 above, and further in view of Rolver US-20240142054-A1.
Regarding claim 3, modified Kim teaches the pressure control apparatus of claim 1, but is silent on wherein the valve is a passive check valve.
Rolver teaches wherein the valve is a passive check valve ((0029), “Advantageously, a passive check valve and/or pressure relief valve is used for this closure. This prevents excessive backflow into the interior of the fluid tank when draining water or purging, reducing the times for these steps (draining water and discharging gas)”).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Kim by wherein the valve is a passive check valve, as suggested by Rolver. This modification would benefit the system by preventing excessive backflow into the interior of the battery cell for which the pressure control apparatus is applied to.
Claim 5 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over modified Kim as applied to claim 1 above, and further in view of Kato US-20130133759-A1.
Regarding claim 5, modified Kim teaches the pressure control apparatus of claim 1 (modified Kim), but is silent on further comprising a secondary pressure chamber disposed in the housing wherein a secondary valve controls a flow of fluid between the pressure chamber and the secondary pressure chamber.
Kato teaches further comprising a secondary pressure chamber (Kato, 213) disposed in the housing (110) wherein a secondary valve (201, specifically 215) controls a flow of fluid between the pressure chamber (212) and the secondary pressure chamber (213).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Kim by further comprising a secondary pressure chamber, along with an associated secondary valve, as shown by Kato. This modification would benefit the system by controlling the flow of fluid in the pressure control apparatus (Kato, (0063), “Hydrogen from the pipe 122 a flows into the primary-side pressure chamber 212, and hydrogen in the secondary-side pressure chamber 213 flows out into the pipe 123 a.”).
Claim 6 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over modified Kim as applied to claim 5 above, and further in view of Han US-20210159473.
Regarding claim 6, modified Kim teaches the pressure control apparatus of claim 5, but is silent on wherein the secondary valve is a solenoid-actuated valve.
Han teaches wherein the secondary valve is a solenoid-actuated valve (The Examiner notes that Fig-4 of Han shows a solenoid actuated valve 30 with solenoid 44).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Kim by wherein the valve is a solenoid-actuated valve, as suggested by Han. This modification would benefit the system by allowing for Han, (0045), “smart valve member 30 [to] be responsive to material characteristic changes (as described in certain aspects herein) or sensor-based characteristic changes”.
Claims 8-11 and 14 are rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over Liu US-20160111755, and further in view of Kim, Zhang, and Kim-2.
Regarding claim 8, Liu teaches a battery cell assembly of a vehicle, comprising:
a housing ((0580), "sealed battery 400 is all sealed by an encapsulating ... housing) disposed in the vehicle ((0331), "The invention also provides a vehicle, which comprises the battery provided by the invention"):
a battery cell (38) disposed in the housing, including:
a cathode (22);
an anode (26); and
a separator (34) disposed between the cathode (22) and the anode (26);
However, Liu is silent on:
a pressure control apparatus operably connected to the battery cell, including:
a cell plate movably disposed in the housing and separating an interior of the housing into:
a cell chamber having the battery cell therein; and
a pressure chamber having a volume of pressurized fluid therein; and
a valve configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when a pressure in the pressure chamber exceeds a threshold;
a fluid circuit operably connected to the pressure chamber to provide the pressurized fluid thereto, the fluid circuit defining a fluid inlet and fluid outlet at the pressure chamber;
wherein the valve is disposed at the fluid circuit.
Kim teaches:
a pressure control apparatus operably connected to the battery cell ((0009), "a battery module for maintaining the surface pressure of battery cells constant")
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of Liu by inclusion of a pressure control apparatus operably connected to the battery cell, as shown by Kim. This modification would benefit the system by maintaining the surface pressure of the battery cells constant.
Kim further teaches:
a cell plate (380) movably disposed ((0085), "Specifically, if the swelling phenomenon of the battery cells 311 is stronger than a designed load limit, the thickness of each battery cell 311 increases, and the pressing plate 380 moves in a lamination direction of the battery cell stack 310" ) in the housing (320) and separating an interior of the housing into:
a cell chamber (310) having the battery cell (311) therein; and
a pressure chamber (330) having a volume of pressurized fluid therein (controlling inflow of the fluid into the tube 330);
Modified Liu is silent on a valve configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when a pressure in the pressure chamber exceeds a threshold.
Nonetheless, Kim teaches a stopper block (390) that can be configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when the pressure in the pressure chamber exceeds a threshold.
Zhang US-20210071912-A1 further teaches that a valve can be used in place of a stopper ((0006), “The swing mechanism may comprise a flap or valve block and stopper”)
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Liu by inclusion of a valve configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when the pressure in the pressure chamber exceeds a threshold, as suggested by Zhang. This modification would benefit the system by regulating the pressure of the [pressurized fluid] in the pressure chamber. This modification would benefit the system by regulating the pressure of the [pressurized fluid] in the pressure chamber
Modified Liu is silent on a fluid circuit.
Kim-2 teaches:
a fluid circuit (Kim-2, 153+154; The Examiner notes that Applicant's instant disclosure FIG. 2 depicts the fluid circuit as comprising Applicant fluid inlet and fluid outlet) operably connected to the pressure chamber (111 of Kim-2) to provide the pressurized fluid ((0092), "the fluid lines 153 and 154 and configured to control the supply and discharge of a pressurizing fluid") thereto,
the fluid circuit defining a fluid inlet (153) and a fluid outlet (154) at the pressure chamber;
wherein the valve (159 of Kim-2) is disposed at the fluid outlet.
Modification of the disclosure of modified Liu by inclusion of a fluid circuit, with associated components and positions, as suggested by Kim-2, would benefit the disclosure of modified Liu by ensuring continued pressure to be applied to each cell during volume change of the battery during charging and discharging (Kim-2, (0015)).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective time of filing of the instant disclosure to modify the disclosure of modified Liu by inclusion of a fluid circuit, with associated components and positions, as suggested by Kim-2.
Regarding claim 9, modified Liu teaches the battery cell assembly of claim 8 (modified Liu), wherein the fluid circuit includes a fluid pump (Kim, 340) to pressurize the pressure chamber with fluid ((0081), "a fluid supply device 340 connected to the tube 330 and ... controlling inflow of the fluid into the tube 330 and maintaining a constant surface pressure of battery cells 311.").
Regarding claim 10, modified Liu teaches the pressure control apparatus of claim 8, wherein the valve is a passive check valve.
The Examiner notes that Kim teaches a passive stopper block (390) that can be configured to allow a portion of the pressurized fluid to be removed from the pressure chamber when the pressure in the pressure chamber exceeds a threshold.
Regarding claim 11, Modified Liu teaches the battery cell of claim 8, but is silent on further comprising one or more pressure sensors disposed in the pressure chamber wherein the valve is operated in response to a pressure exceeding the threshold detected by the one or more pressure sensors.
Kim and Zhang, however, teach further comprising one or more pressure sensors (Kim, 360) disposed exterior to the pressure chamber (330) wherein the valve (stopper block 390, modified with replacement by the valve 3 of Zhang ) is operated in response to a pressure exceeding the threshold detected by the one or more pressure sensors (360).
The Examiner notes that the Kim teaches a valve 350 operated in response to a pressure exceeding the threshold detected by the one or more pressure sensors (360) ((0082), “The pressure sensor 360 may be connected to … the fluid control valve 350 and measure the pressure change of the tube 330 into which the fluid flows”; (0081), “a fluid control valve 350 connected to the tube and to the fluid supply device 340, and controlling inflow of the fluid into the tube 330 and maintaining a constant surface pressure of battery cells 311).
Therefore, it would have been obvious to one of ordinary skill in the art to apply the same technology of a valve connected to a pressure sensor to the modified valve 390 of modified Liu (as previously aforementioned modified by Zhang) that is disposed inside the pressure chamber
Moreover, it would be obvious to include the pressure sensors inside the pressure chamber since the valve is also located inside the pressure chamber.
Regarding claim 14, modified Liu teaches the battery cell assembly of claim 8 (modified Liu), wherein the pressure in the pressure chamber increases in response to an increase in size of the battery cell.
The Examiner notes that it is inherent that if a pressure exceeding the threshold is detected by the one or more pressure sensors (Kim, 360), this event occurs from the increase in size of the battery cell.
Therefore, it is inherent that the pressure in the pressure chamber increases in response to an increase in size of the battery cell.
Claim 12 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over modified Liu as applied to claim 8 above, and further in view of Kato.
Regarding claim 12, modified Liu teaches the battery cell assembly of claim 8 (modified Liu), but is silent on further comprising a secondary pressure chamber disposed in the housing wherein a secondary valve controls the flow of fluid between the pressure chamber and the secondary pressure chamber.
Kato teaches further comprising a secondary pressure chamber (Kato, 213) disposed in the housing (110) wherein the valve (201, specifically 215) controls a flow of fluid between the pressure chamber (212) and the secondary pressure chamber (213).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Liu by further comprising a secondary pressure chamber, and associated secondary valve, as shown by Kato. This modification would benefit the system by controlling the flow of fluid in the pressure control apparatus (Kato, (0063), “Hydrogen from the pipe 122 a flows into the primary-side pressure chamber 212, and hydrogen in the secondary-side pressure chamber 213 flows out into the pipe 123 a.”).
Claim 13 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over modified Liu as applied to claim 12 above, and further in view of Han.
Regarding claim 13, modified Liu teaches the battery cell assembly of claim 12, but is silent on wherein the secondary valve is a solenoid-actuated valve.
Han teaches wherein the secondary valve is a solenoid-actuated valve (The Examiner notes that Fig-4 of Han shows a solenoid actuated valve 30 with solenoid 44).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Liu by wherein the valve is a solenoid-actuated valve, as suggested by Han. This modification would benefit the system by allowing for Han, (0045), “smart valve member 30 [to] be responsive to material characteristic changes (as described in certain aspects herein) or sensor-based characteristic changes”.
Claim 15 is rejected under pre-AIA 35 U.S.C. 103(a) as being unpatentable over modified Liu as applied to claim 8 above, and further in view of Zhamu.
Regarding claim 15, modified Liu teaches the battery cell assembly of claim 8, but is silent on wherein the battery cell is a lithium metal battery cell.
Zhamu teaches wherein the battery cell is a lithium metal battery cell ((0001), "rechargeable lithium metal battery having a lithium metal layer (in a form of thin lithium foil, coating, or sheet) as an anode active material"; (0002), Lithium metal has the highest capacity (3,861 mAh/g) compared to any other metal or metal-intercalated compound (except Li4.4Si) as an anode active material. Hence, in general, Li metal batteries have a significantly higher energy density than lithium ion batteries.).
Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the system of modified Liu by wherein the battery cell is a lithium metal battery cell, as shown by Zhamu. This modification would benefit the system by increasing energy density of the battery cell.
Response to Amendment
The amendment filed August 7, 2026 has been entered. Claims 1-15 remain pending in the application. Claims 16-20 are withdrawn in the application. Applicant’s amendments to the Specification, Drawings, and Claims have overcome each and every objection and 112(b) rejection previously set fourth in the Non-Final Office Action mailed on May 15, 2026.
The Examiner notes Applicant’s amendments to claim 16. However, the Examiner notes that claim 16 is directed to a non-elected method invention, such election made in Applicant’s response filed March 31, 2026. Therefore, the Examiner will not place weight into consideration of Applicant’s present amendments to claim 16. For further guidance on shifting elected inventions after an election is made, see MPEP § 819.
Response to Arguments
Applicant's arguments filed August 7, 2026 have been fully considered but they are not persuasive.
Applicant’s arguments with respect to claim(s) 1-2, 4, and 7 (Page 7, Paragraph 3 – Page 8, Paragraph 1) have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Applicant’s arguments with respect to claim(s) 8-11 and 14 (Page 8, Paragraph 2 – Paragraph 6) have been considered but are moot because the new ground of rejection does not rely on any reference applied in the prior rejection of record for any teaching or matter specifically challenged in the argument.
Applicant’s arguments with respect to claim(s) 2-7 and 9-15 (Page 8, Paragraph 7-8) have been considered but is not persuasive since they rely on the Applicant’s arguments made in claims 1-2, 4, 7, 8-11, and 14 made above, which were not persuasive.
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 EVAN M ABELSON whose telephone number is (571)272-9302. The examiner can normally be reached Monday - Friday, 7:30 AM - 5:00 PM U.S. EST.
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/E.M.A./Examiner, Art Unit 1721
/NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
