Prosecution Insights
Last updated: July 17, 2026
Application No. 18/377,346

CHASSIS CONFIGURED FOR USE WITH PRISMATIC BATTERY CELLS

Non-Final OA §103
Filed
Oct 06, 2023
Priority
Oct 12, 2022 — provisional 63/415,336
Examiner
LIANG, JACKIE
Art Unit
1726
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Enphase Energy Inc.
OA Round
1 (Non-Final)
Grant Probability
Favorable
1-2
OA Rounds

Examiner Intelligence

Grants only 0% of cases
0%
Career Allowance Rate
0 granted / 0 resolved
-65.0% vs TC avg
Minimal +0% lift
Without
With
+0.0%
Interview Lift
resolved cases with interview
Typical timeline
Avg Prosecution
29 currently pending
Career history
29
Total Applications
across all art units

Statute-Specific Performance

§103
87.3%
+47.3% vs TC avg
§102
7.9%
-32.1% vs TC avg
Black line = Tech Center average estimate • Based on career data from 0 resolved cases

Office Action

§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 . Claim Rejections - 35 USC § 103 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 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 and 8-10 are rejected under 35 U.S.C. 103 as being unpatentable over Ruehle et al. (US 2017/0237113 A1, hereinafter “Ruehle”) in view of Wyatt et al. (US 2015/0037616 A1, hereinafter “Wyatt”) and Kim (US 2023/0187759 A1). Regarding claim 1, Ruehle discloses a chassis configured for use an energy storage system (abstract, [0035], and [0053], battery module), comprising: a housing configured to support a plurality of battery cells ([0053] and Fig. 1, receptacle 10 and battery cells 12); and a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall ([0055] and Fig. 1, supports 16a-16d fixed to end plates 14a and 14b). Ruehle does not disclose a first sidewall pad and a top wall pad configured to cushion the plurality of battery cells when supported within the housing and a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells. Wyatt discloses a first sidewall pad ([0161] and Fig. 7, thermal gap pad 108) and a top wall pad ([0161] and Fig. 7, thermal gap pad 115) configured to cushion the plurality of battery cells when supported within the housing. Ruehle and Wyatt are considered to be analogous to the claimed invention because they are in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of Ruehle with the teachings of Wyatt, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would ensure good contact between components and provide vibration dampening (Wyatt [0161]). Modified Ruehle does not disclose a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells. Kim discloses a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells ([0068]-[0070] and Figs. 8, 10, and 11, pressing plate 15). Kim further discloses pressure bolts 53 that press wedge portions 47 on a top cover 17 to generate a pressure for pressing plates 15 ([0065]-[0071] and Figs. 9-11). Kim is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Ruehle with the teachings of Kim, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would press the battery units inward, securing the structural stability of the battery units (Kim [0061]). The limitation “to maintain the plurality of battery cells against a rear wall of the chassis” is merely intended use of the retention bracket. A recitation directed to the manner in which a claimed apparatus is intended to be used does not distinguish the claimed apparatus from the prior art, if the prior art has the capability to so perform. See MPEP § 2111.02, 2112.01, and 2114-2115. The supports 16a-16d of Ruehle are fully capable of maintaining the plurality of battery cells against a rear wall of the chassis, and therefore meet this limitation. Regarding claim 2, modified Ruehle discloses the limitations of claim 1. Modified Ruehle further discloses wherein the first sidewall pad and the top wall pad are made from foam (Wyatt [0161], thermal gap pads 108 and 115 may be a foam-like material). Regarding claim 8, modified Ruehle discloses the limitations of claim 1. Modified Ruehle further discloses wherein the compression wedge comprises a notch (Kim [0069] and Figs. 7, 10, and 11, through holes 55 in pressing plate 15) configured to engage a corresponding protrusion disposed on the second sidewall of the chassis (see Ruehle Annotated Fig. 7 below, protrusion on end plate 14). Ruehle Annotated Fig. 7 PNG media_image1.png 438 636 media_image1.png Greyscale Regarding claim 9, modified Ruehle discloses the limitations of claim 8. Modified Ruehle further discloses wherein the retention bracket comprises apertures that align with the notch, the corresponding protrusion disposed on the second sidewall, and a corresponding protrusion disposed on the first sidewall (Fig. 2 and see Ruehle Annotated Fig. 7 above, aperture on supports 16a-16d), and wherein the apertures on the retention bracket are configured to receive a bolt ([0062] and Fig. 7, screw 48) that engages a threaded aperture defined in the corresponding protrusion disposed on the second sidewall and a threaded aperture defined in the corresponding protrusion disposed on the first sidewall ([0062] and Figs. 2 and 7, internal thread 50 of bushings 44 in end plates 14). Regarding claim 10, modified Ruehle discloses the limitations of claim 1. Ruehle further discloses wherein the plurality of battery cells are a prismatic battery cell electrical configuration ([0056] and Figs. 2 and 3, rectangular battery cells 12). Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Ruehle (US 2017/0237113 A1) in view of Wyatt (US 2015/0037616 A1) and Kim (US 2023/0187759 A1) as applied to claim 1 above, and further in view of Morishita et al. (US 2022/0069398 A1, hereinafter “Morishita”). Regarding claim 3, modified Ruehle discloses the limitations of claim 1. Modified Ruehle does not disclose wherein the chassis is made from die cast metal. Morishita discloses a case 200 that may be a die cast metal material ([0024]). Morishita is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Ruehle with the teachings of Morishita, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would satisfy requirements for characteristics such as strength, heat radiation, and thermal conductivity (Morishita [0024]). Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over Ruehle (US 2017/0237113 A1) in view of Wyatt (US 2015/0037616 A1) and Kim (US 2023/0187759 A1) as applied to claim 1 above, and further in view of Vogel et al. (US 2023/0057595 A1, hereinafter “Vogel”). Regarding claim 7, modified Ruehle discloses the limitations of claim 1. Modified Ruehle does not disclose wherein the compression wedge is made from plastic. Vogel discloses flat components 37 between battery housing module 31 and battery cells 51 that are composed of glass fiber-reinforced plastic ([0056] and Fig. 1). Vogel is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the pressing plate of modified Ruehle with the teachings of Vogel, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would enable electrical insulation and additional thermal insulation (Vogel [0056]). Claims 1-2 and 10 are rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1) and Ruehle (US 2017/0237113 A1). Regarding claim 1, Wyatt discloses a chassis configured for use an energy storage system ([0126] and Fig. 5A, battery module 22), comprising: a housing ([0126] and Fig. 5A, housing 39) configured to support a plurality of battery cells ([0137] and Fig. 7, pouch battery cells 116); and a first sidewall pad ([0161] and Fig. 7, thermal gap pad 115) and a top wall pad ([0161] and Fig. 7, thermal gap pad 108) configured to cushion the plurality of battery cells when supported within the housing. Wyatt does not disclose a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells; and a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall to maintain the plurality of battery cells against a rear wall of the chassis. Kim discloses a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells ([0068]-[0070] and Figs. 8, 10, and 11, pressing plate 15). Kim further discloses pressure bolts 53 that press wedge portions 47 on a top cover 17 to generate a pressure for pressing plates 15 ([0065]-[0071] and Figs. 9-11). Kim is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of Wyatt with the teachings of Kim, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would press the battery units inward, securing the structural stability of the battery units (Kim [0061]). Modified Wyatt does not disclose a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall to maintain the plurality of battery cells against a rear wall of the chassis. Ruehle discloses a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall ([0055] and Fig. 1, supports 16a-16d fixed to end plates 14a and 14b). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Ruehle, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would fix the battery cells through a simple and inexpensive manner, maintaining performance in a temperature-independent manner (Ruehle [0036]). Regarding claim 2, modified Wyatt discloses the limitations of claim 1. Wyatt further discloses further discloses wherein the first sidewall pad and the top wall pad are made from foam ([0161], thermal gap pads 108 and 115 may be a foam-like material). Regarding claim 10, modified Wyatt discloses the limitations of claim 1. Wyatt further discloses wherein the plurality of battery cells are a prismatic battery cell electrical configuration ([0177], also applicable to hard case prismatic battery cells). Claim 3 is rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1) and Ruehle (US 2017/0237113 A1) as applied to claim 1 above, and further in view of Morishita (US 2022/0069398 A1). Regarding claim 3, modified Wyatt discloses the limitations of claim 1. Modified Wyatt does not disclose wherein the chassis is made from die cast metal. Morishita discloses a case 200 that may be a die cast metal material ([0024]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Morishita, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would satisfy requirements for characteristics such as strength, heat radiation, and thermal conductivity (Morishita [0024]). Claims 4 and 5 are rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1) and Ruehle (US 2017/0237113 A1) as applied to claim 1 above, and further in view of Han et al. (CN 112436232 A, machine translation relied upon herein, and hereinafter “Han”) and Chen et al. (US 2021/0066679 A1, hereinafter “Chen”). Regarding claim 4, modified Wyatt discloses the limitations of claim 1. Modified Wyatt discloses a bottom wall of the chassis ([0129] and Fig. 7, heat sink side plate 62). Modified Wyatt does not disclose a removable tray disposed on a top surface of a bottom wall of the chassis and configured to maintain the plurality of battery cells in a relatively upright configuration above the bottom wall when supported within the housing, wherein the removable tray is made from plastic. Han discloses a removable tray ([n0034] and Fig. 5, adjustable tray 1) disposed on a top surface of a bottom wall of the chassis ([n0050] and Fig. 5, modular frame 3) and configured to maintain the plurality of battery cells in a relatively upright configuration above the bottom wall when supported within the housing (Fig. 5, battery cells 2). Han is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Han, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would allow for flexible compatibility with batteries of different specifications, improving the utilization rate of the formation equipment during production (Han [n0051]). Modified Wyatt does not disclose wherein the removable tray is made from plastic. Chen discloses a reservoir portion 5 that comprises a plastic material ([0131]). Chen is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Chen, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would provide favorable deformation properties, effectively absorbing energy and reducing a possibility of sealing failure during collision (Chen [0131]). Regarding claim 5, modified Wyatt discloses the limitations of claim 4. Modified Wyatt further discloses wherein a top surface of the removable tray comprises a plurality of grooves configured to collect fluid in the housing (Han [n0039] and Figs. 2-4, subcavities between multiple adjustment plates 12). Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1), Ruehle (US 2017/0237113 A1), Han (CN 112436232 A), and Chen (US 2021/0066679 A1) as applied to claim 4 above, and further in view of Hayashi et al. (US 2013/0224539 A1, hereinafter “Hayashi”). Regarding claim 6, modified Wyatt discloses the limitations of claim 4. Modified Wyatt discloses wherein a bottom surface of the removable tray comprises a rib that allows fluid in the housing to drain (Han [n0044] and Figs. 2- 4, spaces between bottom plate holes 116 on tray bottom plate 112). Modified Wyatt does not disclose wherein the bottom surface comprises two elongated grooves configured to engage two elongated rails disposed on the top surface of the bottom wall, such that when engaged, the two elongated grooves and two elongated rails prevent lateral movement of the plurality of battery cells. Han discloses a slide track 114 on pallet bottom plate 112 ([n0038] and Fig. 2) and slide rails 33 on frame base plate 31 ([n0050] and Fig. 6). It is of the examiner’s opinion that due to the structure of slide track 114 and slide rails 33, when the two are engaged, lateral movement of the plurality of battery cells would be prevented (Figs. 1 and 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Han, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would facilitate transportation or movement of the pallet (Han [n0038]). Modified Wyatt does not disclose holes defined in the bottom wall of the chassis. Hayashi discloses drain holes 25 at the bottom wall portion 211 of the housing case 20 ([0103] and Figs. 3 and 4). Hayashi is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Hayashi, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would allow for the drainage of accumulated water in the battery case, preventing leakage of the electricity charged in battery cells (Hayashi [0042]). Claim 7 is rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1) and Ruehle (US 2017/0237113 A1) as applied to claim 1 above, and further in view of Vogel (US 2023/0057595 A1). Regarding claim 7, modified Wyatt discloses the limitations of claim 1. Modified Wyatt does not disclose wherein the compression wedge is made from plastic. Vogel discloses flat components 37 between battery housing module 31 and battery cells 51 that are composed of glass fiber-reinforced plastic ([0056] and Fig. 1). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the pressing plate of modified Wyatt with the teachings of Vogel, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would enable electrical insulation and additional thermal insulation (Vogel [0056]). Claims 11-12 and 18-20 are rejected under 35 U.S.C. 103 as being unpatentable over Ruehle (US 2017/0237113 A1) in view of Wyatt (US 2015/0037616 A1), Kim (US 2023/0187759 A1), and Campus et al. (US 2020/0144824 A1, hereinafter “Campus”). Regarding claim 11, Ruehle discloses a chassis configured for use an energy storage system (abstract, [0035], and [0053], battery module), comprising: a housing configured to support a plurality of battery cells ([0053] and Fig. 1, receptacle 10 and battery cells 12); and a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall ([0055] and Fig. 1, supports 16a-16d fixed to end plates 14a and 14b). Ruehle does not disclose an energy management system, comprising: a distributed energy resource comprising a renewable energy source; a load center connected to the renewable energy source; and an energy storage system comprising a chassis, a first sidewall pad and a top wall pad configured to cushion the plurality of battery cells when supported within the housing and a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells. Wyatt discloses a first sidewall pad ([0161] and Fig. 7, thermal gap pad 108) and a top wall pad ([0161] and Fig. 7, thermal gap pad 115) configured to cushion the plurality of battery cells when supported within the housing. Ruehle and Wyatt are considered to be analogous to the claimed invention because they are in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of Ruehle with the teachings of Wyatt, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would ensure good contact between components and provide vibration dampening (Wyatt [0161]). Modified Ruehle does not disclose an energy management system, comprising: a distributed energy resource comprising a renewable energy source; a load center connected to the renewable energy source; and an energy storage system comprising a chassis, a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells. Kim discloses a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells ([0068]-[0070] and Figs. 8, 10, and 11, pressing plate 15). Kim further discloses pressure bolts 53 that press wedge portions 47 on a top cover 17 to generate a pressure for pressing plates 15 ([0065]-[0071] and Figs. 9-11). Kim is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Ruehle with the teachings of Kim, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would press the battery units inward, securing the structural stability of the battery units (Kim [0061]). The limitation “to maintain the plurality of battery cells against a rear wall of the chassis” is merely intended use of the retention bracket. A recitation directed to the manner in which a claimed apparatus is intended to be used does not distinguish the claimed apparatus from the prior art, if the prior art has the capability to so perform. See MPEP § 2111.02, 2112.01, and 2114-2115. The supports 16a-16d of Ruehle are fully capable of maintaining the plurality of battery cells against a rear wall of the chassis, and therefore meet this limitation. Modified Ruehle does not disclose an energy management system, comprising: a distributed energy resource comprising a renewable energy source; a load center connected to the renewable energy source; and an energy storage system comprising a chassis. Campus discloses a microgrid module 200 with a Modular Intelligent Energy Management System ([0033] and Fig. 2), including a container 202 ([0033] and Fig. 2), that may contain solar panels ([0033] and [0059]), DC load centers ([0059]), and a battery bank ([0059]). Campus is considered to be analogous to the claimed invention because it is in the same field of energy management systems. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Ruehle with the teachings of Campus according to known methods to have yielded the predictable result of an energy management system comprising the battery module of modified Ruehle, and one of ordinary skill in the art would have a reasonable expectation of success in doing so (see MPEP § 2143(I)(A)). Regarding claim 12, modified Ruehle discloses the limitations of claim 11. Modified Ruehle further discloses wherein the first sidewall pad and the top wall pad are made from foam (Wyatt [0161], thermal gap pads 108 and 115 may be a foam-like material). Regarding claim 18, modified Ruehle discloses the limitations of claim 11. Modified Ruehle further discloses wherein the compression wedge comprises a notch (Kim [0069] and Figs. 7, 10, and 11, through holes 55 in pressing plate 15) configured to engage a corresponding protrusion disposed on the second sidewall of the chassis (see Ruehle Annotated Fig. 7 above, protrusion on end plate 14). Regarding claim 19, modified Ruehle discloses the limitations of claim 18. Modified Ruehle further discloses wherein the retention bracket comprises apertures that align with the notch, the corresponding protrusion disposed on the second sidewall, and a corresponding protrusion disposed on the first sidewall (Fig. 2 and see Ruehle Annotated Fig. 7 above, aperture on supports 16a-16d), and wherein the apertures on the retention bracket are configured to receive a bolt ([0062] and Fig. 7, screw 48) that engages a threaded aperture defined in the corresponding protrusion disposed on the second sidewall and a threaded aperture defined in the corresponding protrusion disposed on the first sidewall ([0062] and Figs. 2 and 7, internal thread 50 of bushings 44 in end plates 14). Regarding claim 20, modified Ruehle discloses the limitations of claim 11. Ruehle further discloses wherein the plurality of battery cells are a prismatic battery cell electrical configuration ([0056] and Figs. 2 and 3, rectangular battery cells 12). Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Ruehle (US 2017/0237113 A1) in view of Wyatt (US 2015/0037616 A1), Kim (US 2023/0187759 A1) and Campus (US 2020/0144824 A1) as applied to claim 11 above, and further in view of Morishita (US 2022/0069398 A1). Regarding claim 13, modified Ruehle discloses the limitations of claim 11. Modified Ruehle does not disclose wherein the chassis is made from die cast metal. Morishita discloses a case 200 that may be a die cast metal material ([0024]). Morishita is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Ruehle with the teachings of Morishita, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would satisfy requirements for characteristics such as strength, heat radiation, and thermal conductivity (Morishita [0024]). Claim 17 is rejected under 35 U.S.C. 103 as being unpatentable over Ruehle (US 2017/0237113 A1) in view of Wyatt (US 2015/0037616 A1), Kim (US 2023/0187759 A1), and Campus (US 2020/0144824 A1) as applied to claim 11 above, and further in view of Vogel (US 2023/0057595 A1). Regarding claim 17, modified Ruehle discloses the limitations of claim 11. Modified Ruehle does not disclose wherein the compression wedge is made from plastic. Vogel discloses flat components 37 between battery housing module 31 and battery cells 51 that are composed of glass fiber-reinforced plastic ([0056] and Fig. 1). Vogel is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the pressing plate of modified Ruehle with the teachings of Vogel, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would enable electrical insulation and additional thermal insulation (Vogel [0056]). Claims 11-12 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1), Ruehle (US 2017/0237113 A1), and Campus (US 2020/0144824 A1). Regarding claim 11, Wyatt discloses a chassis configured for use an energy storage system ([0126] and Fig. 5A, battery module 22), comprising: a housing ([0126] and Fig. 5A, housing 39) configured to support a plurality of battery cells ([0137] and Fig. 7, pouch battery cells 116); and a first sidewall pad ([0161] and Fig. 7, thermal gap pad 115) and a top wall pad ([0161] and Fig. 7, thermal gap pad 108) configured to cushion the plurality of battery cells when supported within the housing. Wyatt does not disclose an energy management system, comprising: a distributed energy resource comprising a renewable energy source; a load center connected to the renewable energy source; and an energy storage system comprising a chassis, a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells; and a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall to maintain the plurality of battery cells against a rear wall of the chassis. Kim discloses a compression wedge configured to fit between the plurality of battery cells and a second sidewall of the chassis to apply a compressive load on the plurality of battery cells ([0068]-[0070] and Figs. 8, 10, and 11, pressing plate 15). Kim further discloses pressure bolts 53 that press wedge portions 47 on a top cover 17 to generate a pressure for pressing plates 15 ([0065]-[0071] and Figs. 9-11). Kim is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of Wyatt with the teachings of Kim, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would press the battery units inward, securing the structural stability of the battery units (Kim [0061]). Modified Wyatt does not disclose an energy management system, comprising: a distributed energy resource comprising a renewable energy source; a load center connected to the renewable energy source; and an energy storage system comprising a chassis, and a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall to maintain the plurality of battery cells against a rear wall of the chassis. Ruehle discloses a retention bracket configured to connect to a first sidewall of the chassis and the second sidewall ([0055] and Fig. 1, supports 16a-16d fixed to end plates 14a and 14b). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Ruehle, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would fix the battery cells through a simple and inexpensive manner, maintaining performance in a temperature-independent manner (Ruehle [0036]). Modified Wyatt does not disclose an energy management system, comprising: a distributed energy resource comprising a renewable energy source; a load center connected to the renewable energy source; and an energy storage system comprising a chassis. Campus discloses a microgrid module 200 with a Modular Intelligent Energy Management System ([0033] and Fig. 2), including a container 202 ([0033] and Fig. 2), that may contain solar panels ([0033] and [0059]), DC load centers ([0059]), and a battery bank ([0059]). Campus is considered to be analogous to the claimed invention because it is in the same field of energy management systems. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Campus according to known methods to have yielded the predictable result of an energy management system comprising the battery module of modified Wyatt, and one of ordinary skill in the art would have a reasonable expectation of success in doing so (see MPEP § 2143(I)(A)). Regarding claim 12, modified Wyatt discloses the limitations of claim 11. Wyatt further discloses further discloses wherein the first sidewall pad and the top wall pad are made from foam ([0161], thermal gap pads 108 and 115 may be a foam-like material). Regarding claim 20, modified Wyatt discloses the limitations of claim 11. Wyatt further discloses wherein the plurality of battery cells are a prismatic battery cell electrical configuration ([0177], also applicable to hard case prismatic battery cells). Claim 13 is rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1), Ruehle (US 2017/0237113 A1), and Campus (US 2020/0144824 A1) as applied to claim 11 above, and further in view of Morishita (US 2022/0069398 A1). Regarding claim 13, modified Wyatt discloses the limitations of claim 11. Modified Wyatt does not disclose wherein the chassis is made from die cast metal. Morishita discloses a case 200 that may be a die cast metal material ([0024]). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Morishita, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would satisfy requirements for characteristics such as strength, heat radiation, and thermal conductivity (Morishita [0024]). Claims 14 and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1), Ruehle (US 2017/0237113 A1), and Campus (US 2020/0144824 A1) as applied to claim 11 above, and further in view of Han (CN 112436232 A), and Chen (US 2021/0066679 A1). Regarding claim 14, modified Wyatt discloses the limitations of claim 11. Modified Wyatt discloses a bottom wall of the chassis ([0129] and Fig. 7, heat sink side plate 62). Modified Wyatt does not disclose a removable tray disposed on a top surface of a bottom wall of the chassis and configured to maintain the plurality of battery cells in a relatively upright configuration above the bottom wall when supported within the housing, wherein the removable tray is made from plastic. Han discloses a removable tray ([n0034] and Fig. 5, adjustable tray 1) disposed on a top surface of a bottom wall of the chassis ([n0050] and Fig. 5, modular frame 3) and configured to maintain the plurality of battery cells in a relatively upright configuration above the bottom wall when supported within the housing (Fig. 5, battery cells 2). Han is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Han, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would allow for flexible compatibility with batteries of different specifications, improving the utilization rate of the formation equipment during production (Han [n0051]). Modified Wyatt does not disclose wherein the removable tray is made from plastic. Chen discloses a reservoir portion 5 that comprises a plastic material ([0131]). Chen is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Chen, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would provide favorable deformation properties, effectively absorbing energy and reducing a possibility of sealing failure during collision (Chen [0131]). Regarding claim 15, modified Wyatt discloses the limitations of claim 14. Modified Wyatt further discloses wherein a top surface of the removable tray comprises a plurality of grooves configured to collect fluid in the housing (Han [n0039] and Figs. 2-4, subcavities between multiple adjustment plates 12). Claim 16 is rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1), Ruehle (US 2017/0237113 A1), Campus (US 2020/0144824 A1), Han (CN 112436232 A), and Chen (US 2021/0066679 A1) as applied to claim 14 above, and further in view of Hayashi (US 2013/0224539 A1). Regarding claim 16, modified Wyatt discloses the limitations of claim 14. Modified Wyatt discloses wherein a bottom surface of the removable tray comprises a rib that allows fluid in the housing to drain (Han [n0044] and Figs. 2- 4, spaces between bottom plate holes 116 on tray bottom plate 112). Modified Wyatt does not disclose wherein the bottom surface comprises two elongated grooves configured to engage two elongated rails disposed on the top surface of the bottom wall, such that when engaged, the two elongated grooves and two elongated rails prevent lateral movement of the plurality of battery cells. Han discloses a slide track 114 on pallet bottom plate 112 ([n0038] and Fig. 2) and slide rails 33 on frame base plate 31 ([n0050] and Fig. 6). It is of the examiner’s opinion that due to the structure of slide track 114 and slide rails 33, when the two are engaged, lateral movement of the plurality of battery cells would be prevented (Figs. 1 and 10). It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Han, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would facilitate transportation or movement of the pallet (Han [n0038]). Modified Wyatt does not disclose holes defined in the bottom wall of the chassis. Hayashi discloses drain holes 25 at the bottom wall portion 211 of the housing case 20 ([0103] and Figs. 3 and 4). Hayashi is considered to be analogous to the claimed invention because it is in the same field of battery system housings. It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the battery module of modified Wyatt with the teachings of Hayashi, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would allow for the drainage of accumulated water in the battery case, preventing leakage of the electricity charged in battery cells (Hayashi [0042]). Claim 17 is rejected under 35 U.S.C. 103 as being unpatentable over Wyatt (US 2015/0037616 A1) in view of Kim (US 2023/0187759 A1), Ruehle (US 2017/0237113 A1), and Campus (US 2020/0144824 A1) as applied to claim 11 above, and further in view of Vogel (US 2023/0057595 A1). Regarding claim 17, modified Wyatt discloses the limitations of claim 11. Modified Wyatt does not disclose wherein the compression wedge is made from plastic. Vogel discloses flat components 37 between battery housing module 31 and battery cells 51 that are composed of glass fiber-reinforced plastic ([0056] and Fig. 1). It would have been obvious for one of ordinary skill in the art before the effective filing date of the claimed invention to have modified the pressing plate of modified Wyatt with the teachings of Vogel, and one of ordinary skill in the art would have a reasonable expectation of success in doing so. Doing so would enable electrical insulation and additional thermal insulation (Vogel [0056]). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to Jackie Liang whose telephone number is (571)-272-0880. The examiner can normally be reached M-F 8:30AM - 4:30PM. 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, Jeffrey T. Barton can be reached at (571)-272-1307. 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. /J.L./Examiner, Art Unit 1726 /JEFFREY T BARTON/Supervisory Patent Examiner, Art Unit 1726 29 May 2026
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Prosecution Timeline

Oct 06, 2023
Application Filed
Jun 03, 2026
Non-Final Rejection mailed — §103 (current)

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1-2
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Low
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