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 .
VENTING OF PRISMATIC BATTERY CELLS
Examiner: Adam Arciero S.N. 18/358,431 Art Unit: 1727 August 17, 2026
DETAILED ACTION
Applicant’s response filed on April 21, 2026 has been received. Claims 1-9 and 11-21 are currently pending. Claims 1 and 11 have been amended. Claim 10 has been canceled. Claims 20-21 are newly added.
The text of those sections of Title 35, U.S. Code not included in this action can be found in a prior Office action.
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 11-20 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Independent claim 11 recites “wherein the crimped has a predetermined failure pressure level of above 12 bars…” which there is no support found in the original disclosure and Applicant did not specifically point out where support can be found for the specific limitation. Fig. 3 shows the number 12 on the right side vertical axis, however there is nothing to define what any of the numbers are referring to in Fig. 3. In addition, there is no specific disclosure that shows that failure occurs above 12 bars in Fig. 3 or the original disclosure. Therefore, the claims contain new matter.
Claim Rejections - 35 USC § 102
The claim rejections under 35 USC 102(a)(1) as being anticipated by Aaron on claims 1-2, 6-8, 11-12 and 14-16 are withdrawn because Applicant has amended the independent claims.
Claim Rejections - 35 USC § 103
The claim rejections under 35 USC 103(a) as being unpatentable over Aaron on claims 3-4, 9 and 17-19 are withdrawn because Applicant has amended the independent claims.
The claim rejections under 35 USC 103(a) as being unpatentable over Aaron and Matsumoto on claims 5 and 13 are withdrawn because Applicant has amended the independent claims.
The claim rejections under 35 USC 103(a) as being unpatentable over Aaron and Lee on claim 10 is withdrawn because Applicant has canceled the claim.
Claim(s) 1-4, 6-9, 17-19 and 21 is/are rejected under 35 U.S.C. 103 as being unpatentable over Aaron et al. (US 2023/0318092 A1) in view of Bradwell et al. (US 2017/0018811 A1).
As to Claims 1-2, Aaron discloses a battery 400, comprising: a plurality of stacked anodes, separators, and cathodes that are housed in a metal can housing, and comprising metal lids provided on each end to close an opening on each end, wherein the lids are brazed (reads on the claimed brazed filler material) (Abstract, Fig. 4, paragraphs [0013 and 0019]). Aaron does not specifically disclose the claimed brazing material.
However, Bradwell teaches of a brazing seal for batteries, wherein the brazing material can comprise a silver/phosphorus alloy (paragraphs [0021, [0168 and [0178]). At the time of the invention, it would have been obvious to one of ordinary skill in the art to modify the brazed seal of Aaron to comprise a silver/phosphorus alloy brazing material because Bradwell teaches that a seal between the housing and lid can be formed (paragraph [0168 and 0186]).
As to Claims 3-4, Aaron does not specifically disclose the brazing materials. However, there are a known finite number of predictable options for selecting a first and second brazing material for connecting the lids to the battery casing (either the same material or different materials with different melting temperatures). The courts have held that a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense, see MPEP 2143, I, E. At the time of the invention, it would have been obvious to one of ordinary skill in the art to choose either the same brazing materials or different brazing materials because Aaron teaches that a hermetically sealed battery cell can be provided (paragraph [0012]).
As to Claims 6-7, Aaron discloses wherein the housing and lids are made of the same material, such as stainless steel or aluminum (paragraph [0012]).
As to Claim 8, Aaron discloses wherein the housing and lids are made of different materials (paragraph [0012]).
As to Claims 9 and 17, Aaron discloses wherein the housing and lids are made of the different materials, such as stainless steel or aluminum (paragraph [0012]). Aaron does not specifically teach that the first metal is different from the second metal in the claimed manner. However, Aaron teaches of a known finite number of predictable solutions for choosing different metals for the battery housing and lids (paragraph [0012]). The courts have held that a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense, see MPEP 2143, I, E. At the time of the invention, it would have been obvious to one of ordinary skill in the art to choose either the same brazing materials or different brazing materials because Aaron teaches that a hermetically sealed battery cell can be provided (paragraph [0012]).
As to Claims 18-19, Aaron discloses wherein the housing and lids can be connected via brazing and crimping (paragraph [0012]). Aaron does not specifically the claimed configurations of brazing and crimping. However, Aaron teaches of a known finite number of predictable solutions for connecting the battery housing and lids (paragraph [0012]). The courts have held that a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense, see MPEP 2143, I, E. At the time of the invention, it would have been obvious to one of ordinary skill in the art to choose either the same brazing materials or different brazing materials because Aaron teaches that a hermetically sealed battery cell can be provided (paragraph [0012]).
As to Claim 21, Bradwell discloses the same brazing material as the claimed invention and therefore it is the position of the Office that the brazing material of Bradwell intrinsically comprises the claimed melting temperature, see MPEP 2112.
Claim(s) 5 is/are rejected under 35 U.S.C. 103 as being unpatentable over Aaron et al. (US 2023/0318092 A1) in view of Bradwell et al. (US 2017/0018811 A1) as applied to claims 1-4, 6-9, 17-19 and 21 in view of Matsumoto et al. (US 2007/0059586 A1).
As to Claim 5, modified Aaron does not specifically disclose a pressure vent cap provided in either of the lids.
However, Matsumoto teaches of a sealed prismatic battery 1, comprising a pressure-based vent 16 provided in the lid 3 of the battery (Abstract, Fig. 2-3 and paragraph [0021]). At the time of the invention, it would have been obvious to one of ordinary skill in the art to modify the battery of Aaron to comprise the claimed pressure-based vent because Matsumoto teaches that the gas in a battery can be released quickly in order to prevent burst of the batteries (paragraph [0024]).
Claim(s) 11-12 and 14-16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Aaron et al. (US 2023/0318092 A1) in view of Carmichael et al. (US 3,069,489 A).
As to Claims 11-12, Aaron discloses a battery 400, comprising: a plurality of stacked anodes, separators, and cathodes that are housed in a metal can housing, and comprising metal lids provided on each end to close an opening on each end, wherein the lids are crimped to the housing (Abstract, Fig. 4, paragraphs [0013 and 0019]). Aaron does not specifically disclose the claimed pressure.
However, Carmichael recognizes the crimping failure pressure as a result-effective variable in designing the crimped seal of a battery to fail at a predetermined pressure to vent gases without blowing out the entire cell cover (col. 3, lines 29-44). The courts have held that a particular parameter must first be recognized as a result-effective variable, i.e., a variable which achieves a recognized result, before the determination of the optimum or workable ranges of said variable might be characterized as routine experimentation, see MPEP 2144.05, II, B. At the time of the invention, it would have been obvious to one of ordinary skill in the art to optimize the crimping pressure to read on the claims because Carmichael teaches that it is possible to vent gases without blowing out the entire cell cover (col. 3, lines 29-44).
As to Claims 14-15, Aaron discloses wherein the housing and lids are made of the same material, such as stainless steel or aluminum (paragraph [0012]).
As to Claim 16, Aaron discloses wherein the housing and lids are made of different materials (paragraph [0012]).
Claim(s) 13 and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Aaron et al. (US 2023/0318092 A1) in view of Carmichael et al. (US 3,069,489 A) as applied to claims 11-12 and 14-16 in view of Matsumoto et al. (US 2007/0059586 A1).
As to Claim 13, modified Aaron does not specifically disclose a pressure vent cap provided in either of the lids.
However, Matsumoto teaches of a sealed prismatic battery 1, comprising a pressure-based vent 16 provided in the lid 3 of the battery (Abstract, Fig. 2-3 and paragraph [0021]). At the time of the invention, it would have been obvious to one of ordinary skill in the art to modify the battery of Aaron to comprise the claimed pressure-based vent because Matsumoto teaches that the gas in a battery can be released quickly in order to prevent burst of the batteries (paragraph [0024]).
As to Claim 20, there are a finite-number of options for the claimed failure pressure level relationship between the crimp and the vent cap (equal or one is greater than the other) and the courts have held that a person of ordinary skill has good reason to pursue the known options within his or her technical grasp. If this leads to the anticipated success, it is likely that product [was] not of innovation but of ordinary skill and common sense, see KSR, MPEP 2143, I, E. At the time of the invention, it would have been obvious to one of ordinary skill in the art to modify the predetermined failure pressure level to be greater than that of the vent cap because Carmichael teaches that it is possible to vent gases without blowing out the entire cell cover (col. 3, lines 29-44).
Response to Arguments
Applicant’s arguments with respect to claim(s) 1 and 11 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.
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 ADAM ARCIERO whose telephone number is (571)270-5116. The examiner can normally be reached Monday-Friday 8:00-5 ET.
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If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Barbara Gilliam can be reached at (571)272-1330. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/ADAM A ARCIERO/Primary Examiner, Art Unit 1727
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