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 with traverse of claims 1-15 in the reply filed on March 31, 2026 is acknowledged. The traversal is on the ground(s) that there is no serious burden to the Examiner and that a search for the elements of claims 16 would obtain the same results as a search for the elements of claim 1. This is not found persuasive because, as noted in restriction, there is a search burden that requires a different field of search including the process of increasing the volume of the cell via cycling (claim 16), a movably disposed cell plate (claim 1), and a valve configured to allow a portion of the pressurized fluid to be removed (claim 1).
The requirement is still deemed proper and is therefore made FINAL.
Claims 16-20 withdrawn from further consideration pursuant to 37 CFR 1.142(b), as being drawn to a nonelected invention, there being no allowable generic or linking claim. Applicant timely traversed the restriction (election) requirement in the reply filed on March 31, 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 5-6, 12-13 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 5 introduces a secondary pressure chamber, but refers to “the valve” disposed in the newly introduced secondary pressure chamber. However, claim 1 previously introduced “the valve” controlling pressure in the first pressure chamber. Furthermore, [0040] of the instant disclosure introduces a new valve separate from the valve introduced in claim 1, which instead controls pressure in the second pressure chamber.
This introduces indefiniteness as to the following:
Type of valve:
The valve from claim 1
A distinct additional valve separate from the valve introduced in claim 1
Location of valve(s):
Inside the first pressure chamber
Inside the second pressure chamber
Additional location(s)
For the purposes of this office actions, the Examiner will interpret “the valve” as
introduced in claim 5 to be a distinct additional valve separate from the valve introduced in claim 1 located inside the second pressure chamber.
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.
Claim(s) 1-2, 4, 7 is/are rejected under 35 U.S.C. 103 as being unpatentable over KIM US-20220393284-A1, and further in view of ZHANG US-20210071912-A1.
Regarding claim 1, KIM 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.
Regarding claim 2, the pressure control apparatus of claim 1 (modified KIM), further comprising a fluid pump operably (KIM, 340) connected to the pressure chamber (330) 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, 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.
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”).
Claim(s) 3 is/are rejected under 35 U.S. Code § 103 as being unpatentable over modified KIM as applied to claim 1 above, and further in view of ROLVER US-20240142054-A1.
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(s) 5 is/are rejected under 35 U.S. Code § 103 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 the 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 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 KIM by further comprising a secondary pressure chamber, 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(s) 6 is/are rejected under 35 U.S. Code § 103 as being unpatentable over modified KIM as applied to claim 1 above, and further in view of HAN US-20210159473-A1.
Regarding claim 6, modified KIM teaches the pressure control apparatus of claim 5, but is silent on wherein the valve is a solenoid-actuated valve.
HAN teaches wherein the 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”.
Claim(s) 8-11, 14 is/are rejected under 35 U.S. Code § 103 as being unpatentable over LIU US-20150111755-A1, and further in view of KIM US-20220393284-A1 and ZHANG US-20210071912-A1.
LIU teaches:
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.
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
Regarding claim 9, modified LIU teaches the battery cell assembly of claim 8 (modified LIU), further comprising a fluid pump operably (KIM, 340) connected to the pressure chamber (330) 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 KIM (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, 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(s) 12 is/are rejected under 35 U.S. Code § 103 as being unpatentable over modified LIU as applied to claim 8 above, and further in view of KATO US-20130133759-A1.
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 the 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 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, 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(s) 13 is/are rejected under 35 U.S. Code § 103 as being unpatentable over modified LIU as applied to claim 8 above, and further in view of HAN US-20210159473-A1.
Regarding claim 13, modified LIU teaches the battery cell assembly of claim 8, but is silent on wherein the valve is a solenoid-actuated valve.
HAN teaches wherein the 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(s) 15 is/are rejected under 35 U.S. Code § 103 as being unpatentable over modified LIU as applied to claim 8 above, and further in view of ZHAMU US-20180294476-A1.
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.
Conclusion
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.
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, Allison Bourke can be reached at (303) 297-4684. 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.
EVAN ABELSON
Examiner
Art Unit 1721
/EVAN M ABELSON/Examiner, Art Unit 1721
/ALLISON BOURKE/Supervisory Patent Examiner, Art Unit 1721
Prosecution Insights