Prosecution Insights
Last updated: October 02, 2026
Application No. 18/359,347

RECHARGEABLE ENERGY STORAGE SYSTEM WITH A UNIFIED CELL HOLDER VENT TRAY AND VENT TRAY COVER SYSTEM

Final Rejection §102§103
Filed
Jul 26, 2023
Examiner
WALLS-MURRAY, JESSIE LOGAN
Art Unit
1728
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
99%
With Interview

Examiner Intelligence

Grants 74% — above average
74%
Career Allowance Rate
114 granted / 153 resolved
+9.5% vs TC avg
Strong +26% interview lift
Without
With
+25.8%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
30 currently pending
Career history
183
Total Applications
across all art units

Statute-Specific Performance

§101
0.5%
-39.5% vs TC avg
§103
55.2%
+15.2% vs TC avg
§102
22.1%
-17.9% vs TC avg
§112
16.5%
-23.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 153 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 . Response to Amendment The amendment files 07/24/2026 has been entered. Claims 1, 6, and 19-20 are substantively amended and supported by the original drawings. The 35 USC 112(b) rejections are overcome by the amendment and now withdrawn. Response to Arguments Applicant’s arguments, see Remarks pg. 8-9, filed 07/27/2026, with respect to the rejection(s) of claim(s) 1 and 19 under 35 USC 102 and 103 have been fully considered and are persuasive, as the amendment differentiates the claims from the primary reference of record (Georgiadis). Therefore, the rejection has been withdrawn. However, upon further consideration, a new ground(s) of rejection is made in view of the amendments which necessitated further search. Claim Objections Claims 1 and 19 are objected to because of the following informalities: a comma (,) appears to be missing at lines 9-10 within each claim. Appropriate correction is required. Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. 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)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. Claim(s) 1-6, 8, 13-14 is/are rejected under 35 U.S.C. 102(a)(2) as being anticipated by Clarabut (US 12,068,498 B1, effectively filed 12/29/2022). Regarding claim 1, Clarabut teaches a battery pack for a vehicle (battery assemblies for aircraft that use electrical propulsion systems, abstract), comprising: a housing (battery pack enclosure 1400, Fig. 14) including at least one pack vent between an interior and an exterior of the housing (the battery pack enclosure 1400 includes a defined path for the vent gas to escape through a pressure relief safety device (e.g., a burst valve) that prevents the battery pack 120 from over pressurizing. The pack vent may be a dual stage system that is used to provide pressure equalization between the battery pack 120 and the environment during normal operation. The vent interfaces with a duct that vents battery emissions out of the aircraft 100; C23L32-39); a plurality of battery cells disposed within the housing (battery cells 530, Fig. 14), each of the plurality of battery cells including a vent at a vent end (ends of cells 530 that open toward vent flap layer 554, Figs. 13A-13B); and a channel tray (pack lid 570 with cell headspace 558, Figs. 13B-14) including channel arrays (venting manifold 556 is interconnected for the cells belonging to one cell group, Fig. 13B in view of Figs. 10B, 12-13A; the battery cells 530 are organized into one or more battery cell groups, and the vent flap assembly 550 may be configured to provide a first space (e.g., the venting manifold 556) corresponding to each battery cell group, C22L64-C23L1) having a plurality of vent openings each positioned in connection with the vent on each of the plurality of battery cells (vent flaps corresponding to battery cells, C21L45-48) and the channel arrays are in connection with the at least one vent of the housing (556 to 558 in Fig. 13B, in view of Fig. 14 and C23L32-39 as cited above), wherein the channel arrays are enclosed from a rest of a volume of the pack (Aside from the vent path, the battery pack enclosure 1400 may be sealed such that cell electrolyte leakage is retained in the enclosure, C23L40-43), and the plurality of vent openings are each provided with a vent cover disposed directly against the vent end of a respective one of the plurality of battery cells (perforated or cantilevered portions of the vent flaps corresponding to the battery cells in each battery cell group are configured to deform to permit flow of gas out of the first space corresponding to the battery cell group, the vent flap assembly 550 may provide a one-way valve placed on-top of the cells and the current collector 540 to safely vent a cell that has gone into thermal runaway while also protecting neighboring cells; C23L3-18). Regarding claim 2, Clarabut teaches the limitations of claim 1 and the housing contains a potting material encapsulating the plurality of battery cells (foam cell holder 520, Figs. 13B-14). Regarding claim 3, Clarabut teaches the limitations of claim 2 and the potting material is one of a foaming resin (battery cells 530 within the foam cell holder 520, C20L65). Regarding claim 4, Clarabut teaches the limitations of claim 1 and the vent covers are configured to rupture in response to a thermal event of the battery cells (each vent flap may include one or more perforated portions or thinned out/etched portions to deform to permit flow of gas from the battery cell, C21L46-48). Regarding claim 5, Clarabut teaches the limitations of claim 1 and the vent covers are flame resistant (vent flap layer 554 may be configured to protect neighboring cell groups 542 from cell ejecta and can be formed using materials such as flexible ceramics or thermoplastic polyimide, C21L59-62; 554 able to resist elevated temperature during thermal runaway, C21L37-42). Regarding claim 6, Clarabut teaches the limitations of claim 1 and the vent covers are integrally formed with the channel tray (vent flap layer 554 layer forms bottom of channel 558, Fig. 13B). Regarding claim 8, Clarabut teaches the limitations of claim 1 and the vent covers are electrically insulating (vent flaps formed using materials such as flexible ceramics, thermoplastic polyimide; C21L59-62). Regarding claim 13, Clarabut teaches the limitations of claim 1 and the vent covers are formed as a strip of vent covers (layer 554 as strip pf multiple perforated flaps, Fig. 13A). Regarding claim 14, Clarabut teaches the limitations of claim 1 and the channel tray includes a battery cell engagement panel (mechanical support layer 552, Figs. 12-13A) and a tray panel (pack lid 570, Figs. 13B-14) the battery cell engagement panel includes the plurality of vent openings therein (where vent flap layers 554 are arranged in openings in support layer 552, Figs. 12-13A). 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. 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) 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Clarabut (US 12,068,498 B1) and further in view of Bryla (US 2019/0006650 A1). Regarding claim 9, Clarabut teaches the limitations of claim 1 but fails to explicitly teach wherein the vent covers are made from a material including one of PA 66, PA6, PP, PU, epoxy, silicone, PE, mica, PS, PVC, ABS, PET, POM, PTFE, PMMA, PC, fiberglass containing plastics, and flame retardant containing plastics. However, Clarabut C21L59-65 teaches: The vent flap layer 554 may be configured to protect neighboring cell groups 542 from cell ejecta and can be formed using materials such as flexible ceramics, thermoplastic polyimide, or any other materials in the same class sharing similar properties and characteristics. Alternatively stated, the vent flap layer 554 can include a thermoplastic material, a ceramic material, or a silicate material. Clarabut also teaches in C21L53-56 teaches that mechanical support layer 552 (which together with vent flap layer 554 makes up the vent flap assembly 550) may include at least one of silicone or polyurethane. Therefore, silicone and PU are taught by Clarabut to be used in conjunction with the vent covers. Clarabut teaches in C21L37-42 that the vent flap assembly 550 includes two layers 552 and 554, which may be flexible and able to resist elevated temperatures (e.g., transient high temperatures or continuous high temperatures) and teaches in C21L46-48 that vent flap includes one or more portions configured to deform to permit flow of gas from the battery cell corresponding to the vent flap. Bryla is analogous in the art of vented batteries (emission of gases and/or flames emitted from one or more electrochemical cells, Abstract) and teaches that seals may be ruptured in any number of ways during an event where gases are released from an electrochemical cell, such as a polymeric seal that will plastically flow until it ruptures under this combination of elevated temperature and pressure ([0027]). Bryla teaches appropriate seal materials include examples of polyvinyl chloride (i.e., PVC), polyethylene (i.e., PE), and other appropriate polymers which are capable of acting as a barrier to oxygen passing through the seal ([0026]). PVC and PE are among the instantly claimed materials. It would have been obvious, at the time of filing, for a person having ordinary skill in the art to modify the vent flaps of Clarabut (which is desired to have reliable opening in the event of thermal runaway and to be protective of surrounding cells, as cited above) with the polymeric seal material such as PVC or PE as taught by Bryla with the motivation of the material being capable of acting as a barrier to oxygen passing during normal conditions, but also imparting ability to plastically flow until it ruptures under an undesirable combination of elevated temperature and pressure (i.e., thermal runaway) as taught by Bryla. Thus, the instant claim 9 is rendered obvious. Claim(s) 15-16 and 19-20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Clarabut (US 12,068,498 B1) and further in view of Keum et al. (US 2023/0275285 A1). Regarding claim 15, Clarabut teaches the limitations of claim 14 (above) and the housing includes a bottom shear plate and an upper shear plate (as shown in Fig. 5B), but fails to teach: the battery cell engagement panel and the tray panel include injection channels extending therethrough, wherein the injection channels are configured to allow a potting material to be injected through the injection channels and between the bottom shear plate and the tray panel. Keum is analogous in the art of vehicle battery packs ([0003]) and teaches a battery a pack (10, with battery cell assembly 100) having a housing (pack case 300) that includes a bottom shear plate (base case 310) and an upper shear plate (cover frame 122 of first case 120) (see Keum Fig. 10). Keum further teaches a battery cell engagement panel (main supports 126 and dividers 124) and a tray panel (seating frame 142 and dividers 146 of second case 140) (see Keum Fig. 10). Keum teaches channels/openings/gaps formed between the respective dividers 124 and 146 of the engagement panels and the tray panel which are configured to allow a potting to be injected therein (the potting resin 400 is injected per [0078]; see also Figs. 4-10 showing locations of adhesives 130/400 which correspond to potting material per [0058, 0077]); therefore, such reads on “injection channels.” Keum further teaches the potting material being positioned between the bottom shear plate and the tray panel (400 between 310 and 140, Figs. 9-10). Keum teaches in [0077-0080] that the potting resin serves as a waterproof adhesive, improves cooling performance of the batteries, and prevents heat transfer to the surroundings during abnormal situations. It would have been obvious, at the time of filing, for a person having ordinary skill in the art to modify Clarabut include the injection channels to be able to inject potting material between the bottom plate of the housing and the tray as taught by Keum, in order hold the battery cells therebetween and impart the beneficial effects of waterproof adhesion, improved cooling performance of the batteries, and prevent heat transfer to the surroundings during abnormal situations at a desired location such as that taught by Keum. Further, the substitution of one known element (the injectable potting resin around the cells of Keum) for another (the preformed foam holder of Clarabut) to obtain predictable results (holding of cells and benefits of Keum cited above); MPEP 2143 I B. Thereby, claim 15 is rendered obvious. Regarding claim 16, Clarabut teaches the limitations of claim 15 above and wherein the housing contains the potting material encapsulating the plurality of battery cells (foam cell holder 520, Figs. 13B-14), but fails to teach such potting material encapsulating the channel tray and bonded to the bottom shear plate and the upper shear plate. Clarabut foes teach 520 being positioned not only between but also beneath cells 530 (Figs. 5B and 13B), to presumably be adjacent bottom plate 510 shown in Fig. 5B. Keum is analogous in the art of vehicle battery packs ([0003]) and teaches a battery a pack (10) having a housing that includes a bottom shear plate (base case 310) and an upper shear plate (first case 120) (see Keum Fig. 10), and that contains a potting material (potting resin 400 as the waterproof adhesive, [0077] and Fig. 4) encapsulating a plurality of battery cells (cells 110 into adhesive 130 which can be same as 400, [0058] and Figs. 9-10 in view of Fig. 5). Keum further teaches a tray panel (second case 140) (see Keum Fig. 10). Keum teaches that tray 140 is bonded to bottom/base 310 and to upper plate 120 (at support extensions 124 thereof) via encapsulation in waterproof adhesive / potting resin 400 ([0077] and Figs. 9-10). Keum teaches in [0077-0080] that the potting resin serves as a waterproof adhesive, improves cooling performance of the batteries, and prevents heat transfer to the surroundings during abnormal situations. It would have been obvious, at the time of filing, for a person having ordinary skill in the art to modify Clarabut include the potting material serving as waterproof adhesive so that the channel tray was encapsulated and bonded to the bottom shear plate and the upper shear plate as taught by Keum, in order impart the beneficial effects of waterproof adhesion, improved cooling performance of the batteries, and prevent heat transfer to the surroundings during abnormal situations at a desired location such as that taught by Keum. Thereby, claim 16 is rendered obvious. Regarding claim 19, Clarabut teaches a battery pack for a vehicle (battery assemblies for aircraft that use electrical propulsion systems, abstract), comprising: a housing (battery pack enclosure 1400, Fig. 14) including at least one pack vent between an interior and an exterior of the housing (the battery pack enclosure 1400 includes a defined path for the vent gas to escape through a pressure relief safety device (e.g., a burst valve) that prevents the battery pack 120 from over pressurizing. The pack vent may be a dual stage system that is used to provide pressure equalization between the battery pack 120 and the environment during normal operation. The vent interfaces with a duct that vents battery emissions out of the aircraft 100; C23L32-39); a plurality of battery cells disposed within the housing (battery cells 530, Fig. 14), each of the plurality of battery cells including a vent at a vent end (ends of cells 530 that open toward vent flap layer 554, Figs. 13A-13B); and a channel tray (pack lid 570 with cell headspace 558, Figs. 13B-14) including channel arrays (venting manifold 556 is interconnected for the cells belonging to one cell group, Fig. 13B in view of Figs. 10B, 12-13A; the battery cells 530 are organized into one or more battery cell groups, and the vent flap assembly 550 may be configured to provide a first space (e.g., the venting manifold 556) corresponding to each battery cell group, C22L64-C23L1) having a plurality of vent openings each positioned in connection with the vent on each of the plurality of battery cells (vent flaps corresponding to battery cells, C21L45-48) and the channel arrays are in connection with the at least one vent of the housing (556 to 558 in Fig. 13B, in view of Fig. 14 and C23L32-39 as cited above), wherein the channel arrays are enclosed from a rest of a volume of the pack (Aside from the vent path, the battery pack enclosure 1400 may be sealed such that cell electrolyte leakage is retained in the enclosure, C23L40-43), and the plurality of vent openings are each provided with a vent cover disposed directly against the vent end of a respective one of the plurality of battery cells (perforated or cantilevered portions of the vent flaps corresponding to the battery cells in each battery cell group are configured to deform to permit flow of gas out of the first space corresponding to the battery cell group, the vent flap assembly 550 may provide a one-way valve placed on-top of the cells and the current collector 540 to safely vent a cell that has gone into thermal runaway while also protecting neighboring cells; C23L3-18), the housing includes a bottom shear plate and an upper shear plate (as shown in Fig. 5B), But fails to teach: the housing contains a potting material encapsulating the plurality of battery cells and the channel tray is bonded to the bottom shear plate and the upper shear plate. Keum is analogous in the art of vehicle battery packs ([0003]) and teaches a battery a pack (10, with battery cell assembly 100) having a housing (pack case 300) that includes a bottom shear plate (base case 310) and an upper shear plate (cover frame 122 of first case 120) (see Keum Fig. 10). Keum further teaches a battery cell engagement panel (main supports 126 and dividers 124) and a tray panel (seating frame 142 and dividers 146 of second case 140) (see Keum Fig. 10). Keum teaches channels/openings/gaps formed between the respective dividers 124 and 146 of the engagement panels and the tray panel which are configured to allow a potting to be injected therein (the potting resin 400 is injected per [0078]; see also Figs. 4-10 showing locations of adhesives 130/400 which correspond to potting material per [0058, 0077]); therefore, such reads on “injection channels.” Keum further teaches the potting material being positioned between the bottom shear plate and the tray panel (400 between 310 and 140, Figs. 9-10). Keum teaches in [0077-0080] that the potting resin serves as a waterproof adhesive, improves cooling performance of the batteries, and prevents heat transfer to the surroundings during abnormal situations. It would have been obvious, at the time of filing, for a person having ordinary skill in the art to modify Clarabut include the injection channels to be able to inject potting material between the bottom plate of the housing and the tray as taught by Keum, in order hold the battery cells therebetween and impart the beneficial effects of waterproof adhesion, improved cooling performance of the batteries, and prevent heat transfer to the surroundings during abnormal situations at a desired location such as that taught by Keum. Further, the substitution of one known element (the injectable potting resin around the cells of Keum) for another (the preformed foam holder of Clarabut) to obtain predictable results (holding of cells and benefits of Keum cited above); MPEP 2143 I B. Thereby, claim 19 is rendered obvious. Regarding claim 20, Clarabut teaches the limitations of claim 19 (above) and the channel tray includes a battery cell engagement panel (mechanical support layer 552, Figs. 12-13A) and a tray panel (pack lid 570, Figs. 13B-14) and teaches that [the battery cell engagement panel includes] passages extending therethrough (where vent flap layers 554 are arranged in openings in support layer 552, Figs. 12-13A), but fails to teach that: the tray panel also includes passages extending therethrough, nor: the passages are configured to allow the potting material to be injected through the passages and between the bottom shear plate and the tray panel. Keum is analogous in the art of vehicle battery packs ([0003]) and teaches a battery a pack (10, with battery cell assembly 100) having a housing (pack case 300) with a battery cell engagement panel (main supports 126 and dividers 124) and a tray panel (seating frame 142 and dividers 146 of second case 140) (see Keum Fig. 10). Keum teaches channels/openings/gaps formed between the respective dividers 124 and 146 of the engagement panels and the tray panel which are configured to allow a potting to be injected therein (the potting resin 400 is injected per [0078]; see also Figs. 4-10 showing locations of adhesives 130/400 which correspond to potting material per [0058, 0077]); therefore, such reads on “injection channels.” Keum further teaches the potting material being positioned between the bottom shear plate and the tray panel (400 between 310 and 140, Figs. 9-10). Keum teaches in [0077-0080] that the potting resin serves as a waterproof adhesive, improves cooling performance of the batteries, and prevents heat transfer to the surroundings during abnormal situations. It would have been obvious, at the time of filing, for a person having ordinary skill in the art to modify Clarabut to include injection channels to be able to inject potting material between the bottom plate of the housing and the tray as taught by Keum, in order impart the beneficial effects of waterproof adhesion, improved cooling performance of the batteries, and prevent heat transfer to the surroundings during abnormal situations at a desired location such as that taught by Keum. Further, the substitution of one known element (the injectable potting resin around the cells of Keum) for another (the preformed foam holder of Clarabut) to obtain predictable results (holding of cells and benefits of Keum cited above); MPEP 2143 I B. Thereby, claim 20 is rendered obvious. 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 Jessie Walls-Murray whose telephone number is (571)272-1664. The examiner can normally be reached M-F, typically 10-4. 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, Matthew Martin can be reached at (571) 270-7871. 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. /JESSIE WALLS-MURRAY/ Primary Examiner, Art Unit 1728
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Prosecution Timeline

Jul 26, 2023
Application Filed
Jun 02, 2026
Non-Final Rejection mailed — §102, §103
Jul 22, 2026
Interview Requested
Jul 23, 2026
Applicant Interview (Telephonic)
Jul 23, 2026
Examiner Interview Summary
Jul 24, 2026
Response Filed
Sep 14, 2026
Final Rejection mailed — §102, §103 (current)

Precedent Cases

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Prosecution Projections

3-4
Expected OA Rounds
74%
Grant Probability
99%
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3y 3m (~0m remaining)
Median Time to Grant
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