Prosecution Insights
Last updated: July 17, 2026
Application No. 18/379,246

STORAGE SYSTEM CONFIGURED FOR USE WITH AN ENERGY MANAGEMENT SYSTEM

Non-Final OA §103
Filed
Oct 12, 2023
Priority
Oct 28, 2022 — provisional 63/420,313
Examiner
ZHOU, ZIXUAN
Art Unit
Tech Center
Assignee
Enphase Energy Inc.
OA Round
1 (Non-Final)
77%
Grant Probability
Favorable
1-2
OA Rounds
0m
Est. Remaining
94%
With Interview

Examiner Intelligence

Grants 77% — above average
77%
Career Allowance Rate
473 granted / 616 resolved
+16.8% vs TC avg
Strong +17% interview lift
Without
With
+17.2%
Interview Lift
resolved cases with interview
Typical timeline
2y 9m
Avg Prosecution
43 currently pending
Career history
641
Total Applications
across all art units

Statute-Specific Performance

§101
0.6%
-39.4% vs TC avg
§103
82.5%
+42.5% vs TC avg
§102
11.0%
-29.0% vs TC avg
§112
3.1%
-36.9% vs TC avg
Black line = Tech Center average estimate • Based on career data from 616 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 . Information Disclosure Statement The information disclosure statement (IDS) submitted on 02/22/2024 is in compliance with the provisions of 37 CFR 1.97. Accordingly, the information disclosure statement is being considered by the examiner. 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. Claim(s) 1, 3-9, 11-18, 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Priem (US 2017/0214349) in view of Loncarevic (US 2010/0052615). Regarding claim 1, Priem discloses a storage system (100) configured for use with an energy management system (170, 180, 165), comprising: a rechargeable battery (fig. 1, element 140 and ¶ 0019); a grid detection circuit (100 or 165) operably connected to (see fig. 1 and ¶ 0019) the rechargeable battery (142) such that when an AC power source is not detected by the grid detection circuit (¶ 0022; the genset 100 may automatically activate in response to the ATS 165 or the controller 110 detecting that the utility power fails, and automatically stop in response to the ATS 165 or the controller 110 detecting that the utility power is back) and a voltage at the rechargeable battery falls below a threshold voltage (¶ 0022; the genset 100 may automatically start to charge the battery 140 in response to the battery monitor 142 detecting that the battery condition (e.g., state of charge) is below a predetermined condition); and a switch (fig. 1, element 165) operably connected to the grid detection circuit (110 via a communication interface 160). Priem fails to teach the grid detection circuit places the rechargeable battery into a sleep mode, the switch configured to override the grid detection circuit so that the rechargeable battery exits the sleep mode until a voltage at the rechargeable battery is equal to or greater than a predetermined voltage. Loncarevic further teaches a battery management system is able to control the charging and discharging of the batteries. The battery management system includes a central controlling microcontroller, and during discharging of the associated cell to monitor the state of the associated cell and to inform the central controlling microcontroller when a minimum charging state has been reached, so as to cause the central controlling microcontroller to disconnect the associated cell from the load in claim 14. Therefore, the battery enters sleep mode after the disconnection between the battery cells and the load. Further, Loncarevic further discloses when the battery voltage reaches total maximum voltage and the charging process is stopped by the central microcontroller, the battery cells are ready to exit the sleep mode (non-discharging mode) as long as the cell voltages are above cell voltage min reset, the central microcontroller can re-enable (waking up the battery cells) the discharging process in ¶¶ 0114-0115 and abstract. It would have been obvious to one skilled in the art before the effective filing date of the claimed invention to modify Priem to incorporate with the teaching of Loncarevic by controlling the charging/discharging the battery cells based on the battery states, because it would be advantageous to prevent excessive discharging/charging the battery cells and further prolong the service life of the whole battery. Regarding claims 3, 11 and 20, Priem does not disclose wherein the switch is connected across at least one resistor of a DC protection circuit or a resistor that is not part of the DC protection circuit. PNG media_image1.png 316 1060 media_image1.png Greyscale Loncarevic further teaches a switch is connected across at least one resistor of a DC protection circuit or a resistor (see fig. 9 above) that is not part of the DC protection circuit (see fig. 9). It would have been obvious to one skilled in the art before the effective filing date of the claimed invention to modify Priem to incorporate with the teaching of Loncarevic by connecting the switch with a resistor, because it would be advantageous to prevent unreliable operation or battery damage while preserving ultra-low sleep current. Regarding claims 4 and 12, Priem fails to teach wherein the grid detection circuit is configured to wake-up the rechargeable battery if the voltage at the rechargeable battery is above a first recoverable level and the switch is configured to wake-up the rechargeable battery if the voltage at rechargeable battery is above a second recoverable level different from the first recoverable level. However, Loncarevic further discloses wherein the grid detection circuit (central controlling microcontroller; 14) is configured to wake-up the rechargeable battery (start discharging the battery) if the voltage at the rechargeable battery is above a first recoverable level (¶ 0115; Cell voltage min reset=the lowest voltage amongst cell voltages must reach this value to re-enable discharging) and the switch (central control microcontroller; 14) is configured to wake-up the rechargeable battery if the voltage at rechargeable battery is above a second recoverable level different from the first recoverable level (¶ 0114; when the highest cell voltage reach “cell voltage max”, the battery cells are ready to discharge when they need to). It would have been obvious to one skilled in the art before the effective filing date of the claimed invention to modify Priem to incorporate with the teaching of Loncarevic by controlling the charging/discharging based on different cell voltage parameters, because it would be advantageous to protect the battery cells from overcharging or undervoltage and further prolong the service life of the whole system. Regarding claims 5 and 13, Priem in view of Loncarevic discloses wherein the first recoverable level is about (interpret as “above” or “below”) 2V per cell (3.7 V; Loncarevic, ¶ 0115) and the second recoverable level is about (interpret as “above” or “below”) 3V per cell (4.25V; Loncarevic, ¶ 0114). Regarding claims 6 and 14, Priem in view of Loncarevic discloses wherein the switch is configured to override the grid detection circuit (the genset 100 may automatically activate in response to the ATS 165 or the controller 110 detecting that the utility power fails, and automatically stop in response to the ATS 165 or the controller 110 detecting that the utility power is back) but it fails to disclose the switch is configured to override the grid detection circuit for about 5 minutes. However, to choose 5 minutes for overriding the grid detection circuit, absent any criticality, is only considered to be the “optimum” value of the overriding time of the controller, as stated above, that a person having ordinary skill in the art would have been able to determine using routine experimentation based, among other things, on the desired accuracy and since it has been held that discovering an optimum value of a result effective variable involves only routine skill in the art in order to maintain the power supply to the load without major interruption. See In re Boesch, 205 USPQ 215 (CCPA 1980) and MPEP 2144.04 and 2144.05. Regarding claim 7, Priem discloses wherein the switch (165; ATS) is connected to (directly/indirectly connected to) an under-voltage pin of an IC of a DC protection circuit (¶ 0051; the controller 110 may stop the genset 100 in response to receiving commands from the battery monitor 142 indicating that the battery condition is below a predetermined battery condition level). Regarding claims 8 and 17, Priem discloses a method/CRSM [¶ 0029] for managing a storage system (100) configured for use with an energy management system (170, 180, 165), comprising: detecting if an AC power source is present on the storage system (¶ 0022; the genset 100 may automatically activate in response to the ATS 165 or the controller 110 detecting that the utility power fails, and automatically stop in response to the ATS 165 or the controller 110 detecting that the utility power is back); detecting if a voltage at a rechargeable battery falls below a threshold voltage (¶ 0022; the genset 100 may automatically start to charge the battery 140 in response to the battery monitor 142 detecting that the battery condition (e.g., state of charge) is below a predetermined condition). However, Priem does not disclose the method further includes: placing the rechargeable battery into a sleep mode; and overriding the sleep mode until the voltage at the rechargeable battery is equal to or greater than a predetermined voltage. Loncarevic further teaches a battery management system is able to control the charging and discharging of the batteries. The battery management system includes a central controlling microcontroller, and during discharging of the associated cell to monitor the state of the associated cell and to inform the central controlling microcontroller when a minimum charging state has been reached, so as to cause the central controlling microcontroller to disconnect the associated cell from the load in claim 14. Therefore, the battery enters sleep mode after the disconnection between the battery cells and the load. Further, Loncarevic further discloses when the battery voltage reaches total maximum voltage and the charging process is stopped by the central microcontroller, the battery cells are ready to exit the sleep mode (non-discharging mode) as long as the cell voltages are above cell voltage min reset, the central microcontroller can re-enable (waking up the battery cells) the discharging process in ¶¶ 0114-0115 and abstract. It would have been obvious to one skilled in the art before the effective filing date of the claimed invention to modify Priem to incorporate with the teaching of Loncarevic by controlling the charging/discharging the battery cells based on the battery states, because it would be advantageous to prevent excessive discharging/charging the battery cells and further prolong the service life of the whole battery. Regarding claims 9 and 18, Priem discloses wherein overriding the sleep mode comprises using a switch (¶ 0022; the genset 100 may automatically activate in response to the ATS 165 or the controller 110 detecting that the utility power fails), and wherein the switch is connected (directly/indirectly connected to) to an under-voltage pin of an IC of a DC protection circuit (¶ 0051; the controller 110 may stop the genset 100 in response to receiving commands from the battery monitor 142 indicating that the battery condition is below a predetermined battery condition level). Regarding claim 15, Priem discloses wherein if the AC power source is present on the storage system and the voltage at the rechargeable battery falls below the threshold voltage, further comprising charging the rechargeable battery (¶ 0022; the genset 100 may automatically start to charge the battery 140 in response to the battery monitor 142 detecting that the battery condition (e.g., state of charge) is below a predetermined condition). Regarding claim 16, Priem discloses wherein if the AC power source is present on the storage system and the voltage at the rechargeable battery does not fall below the threshold voltage, further comprising operating the storage system under normal operation (¶¶ 0022, 0024; the smart switch 175 can charge the battery 140 and direct the battery 140 to provide power to the load 190 based on utility demand). Claim(s) 2, 10, 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Priem in view of Loncarevic as applied to claim 1 above, and further in view of Qureshi et al. US 2007/0241930 (hereinafter Qureshi). Regarding claims 2, 10 and 19, Priem in view of Loncarevic discloses the system includes an automatic transfer switch (ATS, fig. 1, element 165; Priem), but the ATS is not a magnetic reed switch. However, Qureshi discloses a device includes a microcontroller 304 and reed switches 302-1 and 302-2 in fig. 4. When such a magnetic pole is not sensed by a switch sensor 302, the Reed switch 302 is open, effectively directing microprocessor 304 to enter sleep mode and conserve energy. Responsive to sensing the magnetic pole, a respective Reed switch closes, causing microcontroller 304 to wake-up from sleep mode in ¶ 0024. It would have been obvious to one skilled in the art before the effective filing date of the claimed invention to modify Priem in view of Loncarevic to incorporate with the teaching of Qureshi by using reed switch to cause microcontroller to wake-up from sleep mode, because it would be advantageous to reduce quiescent current until activated by a magnetic device and further increase durability of the system. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ZIXUAN ZHOU whose telephone number is (571)272-6739. The examiner can normally be reached 9:00 am to 5:00 pm. 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, Julian Huffman can be reached at (571) 272-2147. 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. /ZIXUAN ZHOU/Primary Examiner, Art Unit 2859 06/09/2026
Read full office action

Prosecution Timeline

Oct 12, 2023
Application Filed
Jun 17, 2026
Non-Final Rejection mailed — §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

Patent 12679235
WIRELESS CHARGING RECEIVER, TRANSMITTER, SYSTEM, AND CONTROL METHOD, AND ELECTRIC VEHICLE
3y 7m to grant Granted Jul 14, 2026
Patent 12679553
CRYOGENIC FUEL BOIL OFF POWERED FUEL CELL
3y 5m to grant Granted Jul 14, 2026
Patent 12658737
ELECTRONIC DEVICE COMPRISING WIRELESS CHARGING CIRCUIT
3y 6m to grant Granted Jun 16, 2026
Patent 12636967
METHOD AND DEVICE FOR TIMING SCHEDULED CHARGING, AND TERMINAL EQUIPMENT
3y 5m to grant Granted May 26, 2026
Patent 12641359
CHARGING BOX
3y 5m to grant Granted May 26, 2026
Study what changed to get past this examiner. Based on 5 most recent grants.

Strategy Recommendation AI-generated — please review before filing

Get a prosecution strategy drawn from examiner precedents, rejection analysis, and claim mapping.
Typically takes 5-10 seconds — AI-generated, attorney review required before filing

Prosecution Projections

1-2
Expected OA Rounds
77%
Grant Probability
94%
With Interview (+17.2%)
2y 9m (~0m remaining)
Median Time to Grant
Low
PTA Risk
Based on 616 resolved cases by this examiner. Grant probability derived from career allowance rate.

Sign in with your work email

Enter your email to receive a magic link. No password needed.

Personal email addresses (Gmail, Yahoo, etc.) are not accepted.

Free tier: 3 strategy analyses per month