Prosecution Insights
Last updated: July 17, 2026
Application No. 18/381,194

SECONDARY BATTERY

Non-Final OA §102§103
Filed
Oct 18, 2023
Priority
Dec 01, 2022 — RE 10-2022-0165653
Examiner
MURPHY, RYAN PATRICK
Art Unit
4100
Tech Center
4100
Assignee
Samsung SDI Co., Ltd.
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
-60.0% vs TC avg
Minimal +0% lift
Without
With
+0.0%
Interview Lift
resolved cases with interview
Typical timeline
Avg Prosecution
18 currently pending
Career history
11
Total Applications
across all art units

Statute-Specific Performance

§103
96.6%
+56.6% vs TC avg
Black line = Tech Center average estimate • Based on career data from 0 resolved cases

Office Action

§102 §103
DETAILED ACTION Notice of Pre-AIA or AIA Status [001] The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Priority [002] Acknowledgment is made of applicant’s claim for foreign priority under 35 U.S.C. 119 (a)-(d). The certified copy has been filed in parent Application No.KR-10-2022-0165653, filed on December 1st, 2022. Claim Rejections - 35 USC § 102 [003] 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. [004] 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)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention. [005] Claims 16-18 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Kozuki and Nakashima (US 20050277021 A1; Henceforth, Kozuki). [006] Regarding claim 16, Kozuki teaches a secondary battery (the present invention is applied to a lithium ion secondary battery [0032]), comprising: an electrode assembly (comprising an electrode assembly, [0032]) including: a positive electrode plate (a positive electrode plate, [0032]) having a positive electrode uncoated portion (the positive current collector is left uncoated at both lengthwise ends, [0033]), a negative electrode plate having a negative electrode uncoated portion (the negative current collector is left uncoated at both lengthwise ends, [0035]), the negative electrode uncoated portion including a negative electrode extension uncoated portion of which one end portion is folded (the exposed negative current collector portions are bent along 45° lines […] from a lengthwise direction [0035]), and which extends downward from the electrode assembly (that extends in the opposite direction from the positive electrode, [0035]; the negative electrode portion is oriented downwards in Figure 2b and Figure 3, reproduced below), and a separator between the positive electrode plate and the negative electrode plate (a positive electrode, a negative electrode, and a separator interposed therebetween, [0032]); and a cap assembly coupled to an upper portion of a case and electrically connected to the positive electrode plate (a positive lead extending from the positive electrode is connected to an external positive electrode terminal provided in the sealing plate, which is for closing the opening of the battery case, [0032]). PNG media_image1.png 723 514 media_image1.png Greyscale PNG media_image2.png 459 356 media_image2.png Greyscale Figures 2 (left) and 3 (right), reproduced from Kozuki. [007] Regarding claim 17, Kozuki teaches the secondary battery as claimed in claim 16 (above), wherein the negative electrode extension uncoated portion includes: an overlapping portion folded (element 2c, Figure 3) to an outer surface or an inner surface of the negative electrode uncoated portion (inwards, Figure 3) and in contact with the outer surface or the inner surface of the negative electrode uncoated portion (inner surface, Figure 3); and a protrusion which protrudes downward from the electrode assembly (element 2d, Figure 3). [008] Regarding claim 18, Kozuki teaches the secondary battery as claimed in claim 17 (above), wherein a first width of the protrusion is equal to a second width of the negative electrode plate (Figure 2b shows the width of the protrusion 2d (the dimension running along the winding direction of the electrode) is the same as the width of the electrode (the height dimension, as depicted in Figure 2b)). Claim Rejections - 35 USC § 103 [009] 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. [010] 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. [011] 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. [012] Claims 1-10 are rejected under 35 U.S.C. 103 as being unpatentable over Owaka et al (JP H11135101 A; Henceforth, Owaka), and further in view of Kozuki and Hara et al. (JP H09161837 A; Henceforth, Hara). [013] Regarding claim 1, the instant claim is drawn to a secondary battery, comprising: an electrode assembly including: a positive electrode plate having a positive electrode uncoated portion, a negative electrode plate having a negative electrode uncoated portion, the negative electrode uncoated portion including a negative electrode extension uncoated portion of which one end portion is folded and extending downward from the electrode assembly, and a separator between the positive electrode plate and the negative electrode plate; a case including a side plate with a cylindrical body, the case accommodating the electrode assembly and a lower plate, the lower plate sealing a lower portion of the side plate and the negative electrode uncoated portion being connected to the lower plate of the case; and a cap assembly coupled to an upper portion of the case and electrically connected to the positive electrode plate. [014] Owaka teaches a secondary battery ([0013] and Figure 6, annotated below) comprising an electrode structure ([0007]) including a positive electrode plate, a negative electrode plate and a separator dispersed between them ([0013] teaches the components, and Figure 6 depicts the separator, element 23, dispersed between the electrode plates, element 24 and 25). Owaka teaches both the positive and negative electrode plates have uncoated portions at the beginning and end of the winding portions of the electrodes ([0007]). Owaka depicts the battery case with a cylindrical body (Figure 6; denoted as a “battery can” in [0013]) that has a lower plate sealing the bottom of the battery can, and a cap assembly coupled to the upper portion of the battery can ([0013], element 19 in Figure 6). Owaka teaches the uncoated portions are bent by 90° (see Figure 2, reproduced below). The examiner notes that, by 90° in view of Figure 2, Owaka means that the electrode plates are folded along a 45° line extending in the direction of the electrode plate, such that the resulting angle between the folded portion and the primary extension direction of the electrode plate are 90°. Owaka teaches the positive and negative electrode plates are directly connected to battery terminals extending out of the top plate assembly of the battery ([0008]), but is electrically insulated from the top plate ([0013]). PNG media_image3.png 889 814 media_image3.png Greyscale Figure 6, reproduced from Owaka, annotated by the examiner. PNG media_image4.png 756 669 media_image4.png Greyscale Figure 2, reproduced from Owaka. [015] Owaka does not teach that the negative electrode plate is folded downwards, nor that the negative and positive electrode plates are electrically connected to the bottom plate and top plate of the battery case, respectively. [016] Kozuki teaches an electrochemical element ([0014]) in a secondary battery ([0032]) comprising a positive electrode with a positive current collector with both ends left uncoated by positive active material ([0033]), a negative electrode with a negative current collector with both ends left uncoated ([0035]) with a separator interposed between the two electrodes ([0037]). The positive and negative electrodes are folded along 45° lines in opposite directions, with the positive electrode oriented up, and the negative electrode oriented down ([0033] and [0035]), such that the negative plate is folded inwards (see Figures 2 and 3, above). [017] Kozuki does not teach the negative electrode is electrically connected to the bottom plate of the battery can. [018] Hara teaches a cylindrical battery consisting of a positive electrode, a negative electrode, and a separator wound in a battery case ([0010]), where the negative electrode has uncoated regions on either end in the winding direction of the electrode such that they can fold below the wound core structure ([0010]-[0011]). The uncoated portions are welded to the bottom plate ([0010]), which the examiner notes means they are electrically connected to the bottom plate (also see Figure 2, reproduced below). Hara teaches the positive electrode is welded to the back of the battery lid, which has a positive terminal on the opposing surface of the battery cover ([0016], [0017] and Figure 2). Hara teaches that this configuration reduces the amount of positive active material needed and, by only needing to perform one weld to attach the negative electrode to the battery case, instead of installing a separate connection point, the ability to produce the batteries are improved ([0020]). Hara also notes that, by not needing to weld added components to the negative electrode to connect it to the exterior of the case via a terminal, it decreases the resistance in the welded area ([0008] and [0011]). PNG media_image5.png 469 294 media_image5.png Greyscale Figure 2, reproduced from Hara. [019] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor. There would have been a motivation, as taught by Hara, to electrically connect the negative electrode to the bottom plate of the battery, in order to simply manufacturing by eliminating welding steps, reduce the resistance of the connection between the negative electrode and the battery case, and reduce the amount of active material used in manufacturing the battery. A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the connection methods of Owaka for those taught by Hara, in the same field of endeavor, would have been successful, as Kozuki demonstrated precedent for folding the negative electrode downwards, and the connections of the positive and negative electrodes to the top and bottom plates, respectively, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [020] Regarding claim 2, the instant claim is drawn to the secondary battery as claimed in claim 1, wherein the negative electrode extension uncoated portion includes: an overlapping portion folded to an outer surface or an inner surface of the negative electrode uncoated portion and in contact with the outer surface or the inner surface of the negative electrode uncoated portion; and a protrusion which protrudes downward from the electrode assembly. [021] Owaka, Kozuki, and Hara teach the battery of claim 1. Owaka teaches that the negative electrode uncoated portion is folded to the outer surface of the negative electrode (Figure 2, reproduced above; the dashed line implies it is folded behind the plane of the page). Owaka teaches there is a protrusion extending from the electrode assembly (Figure 2), but does not teach the protrusion is oriented downwards. Kozuki teaches that the negative electrode uncoated portion is folded inwards (Figures 2 and 3, above), which the examiner notes is the opposite orientation than what is taught by Owaka. Both Kozuki and Hara teaches there is a protrusion extending downwards from the electrode assembly (Kozuki: Figure 3; Hara: Figure 2). [022] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards, as taught by Kozuki in the same field of endeavor, such that it is protrudes downwards from the electrode assembly. There would have been a motivation to use uncoated protrusions extending downwards from the negative electrode, as taught by Hara, since welding both ends of the negative electrode together and to the bottom plate to electrically connect the negative electrode to the bottom plate of the battery simplifies manufacturing by eliminating welding steps and reduces the resistance of the connection between the negative electrode and the battery case ([0008], [0011] and [0020]). A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the connection methods of Owaka for those taught by Hara, in the same field of endeavor, would have been successful, as Kozuki demonstrated precedent for folding the negative electrode downwards, and the connections of the positive and negative electrodes to the top and bottom plates, respectively, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [023] Regarding claim 3, the instant claim is drawn to the secondary battery as claimed in claim 2, wherein a first width of the protrusion is equal to a second width of the negative electrode plate. [024] Owaka, Kozuki, and Hara teach the battery of claim 2. Owaka teaches the width of the protrusion (the dimension of the winding direction in Figure 2, above) is the same as the width of the negative electrode plate (the height of the electrode, in Figure 2). The examiner notes this matches how the widths are defined in paragraph 60 of the instant specification and Figure 3 of the instant drawings. The examiner also notes this is similarly taught by Kozuki (Figures 2 and 3). [025] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards such that it protrudes from the electrode assembly, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor, as outlined in claims 1 and 2, above. [026] Regarding claim 4, the instant claim is drawn to the secondary battery as claimed in claim 2, wherein a first width of the protrusion is less than a diameter of the electrode assembly. [027] Owaka, Kozuki, and Hara teach the battery of claim 2. Owaka teaches the width of the protrusion (the dimension of the winding direction in Figure 2, above) is the same as the width of the negative electrode plate (the height of the electrode, in Figure 2). Owaka teaches that the width of the protrusion can be changed via further folding (Figure 2b and [0010]), but not if the width is less than or equal to half the outermost circumference of winding ([0010]). The examiner notes that, since the circumference is related to the diameter by the relation C = dπ, Owaka does not necessarily teaches a width, either before or after folding, that will always be less than the diameter of the electrode assembly. Kozuki teaches an elliptical battery, and thus cannot teach a relevant diameter. [028] Hara teaches that one of the uncoated protrusions is made to a length that is the radius of the electrode group plus the welded section ([0010]) and the other a length that reaches the central space of the electrode group ([0010]). The examiner notes the width of the protrusion is less than the length of the protrusion (Figure 1, annotated below), which means the width of the protrusion is less than the diameter of the electrode assembly. PNG media_image6.png 470 762 media_image6.png Greyscale Figure 1, reproduced from Hara, annotated by the examiner. [029] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards such that it protrudes from the electrode assembly, as taught by Kozuki in the same field of endeavor, such that the width of the protrusion is less than a diameter of the electrode assembly, as taught by Hara in the same field of endeavor. Hara demonstrates precedent for the use of protrusions with a width less than the diameter of the electrode assembly, in order to properly weld the protrusion to the bottom cap of the battery can. A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the protrusions of Owaka for those taught by Hara, in the same field of endeavor, would have been successful, as the configuration and the connections of the negative electrode protrusions, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [030] Regarding claim 5, the instant claim is drawn to the secondary battery as claimed in claim 2, wherein a length of the protrusion is greater than half of a diameter of the electrode assembly and less than the diameter of the electrode assembly. [031] Owaka, Kozuki, and Hara teach the battery of claim 2. Owaka nor Kozuki teach that a length of the protrusion is greater than half of a diameter of the electrode assembly and less than the diameter of the electrode assembly. Hara teaches that one of the uncoated portions is made to a length that is the radius of the electrode group plus the welded section ([0010]) and the other a length that reaches the central space of the electrode group ([0010]). The examiner notes this corresponds to the winding end and beginning sides respectively ([0016]), and the winding end side overlaps the winding beginning side ([0017]), before being welded together ([0017]). The examiner notes that the reference to the phrase “Parts 1 and 2 are joined together at their tips and spot-welded” ([0016]) has been interpreted as making sure the protrusions are properly aligned, as paragraph [0017] goes into more detail on this step, where Hara states they overlap, as mentioned above. The examiner notes that Figure 2 shows the length of the protrusion does not extend the entire length of the diameter, and the value taught by Hara is greater than the radius. Therefore, the length lies within the range taught by the instant claim, and therefore anticipates it. UCB, Inc. v. Actavis Labs. UT, Inc., 65 F.4th 679, 687, 2023 USPQ2d 448 (Fed. Cir. 2023). See MPEP 2131.03. [032] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards, as taught by Kozuki in the same field of endeavor, such that it is protrudes downwards from the electrode assembly and the length of the protrusion is longer than the radius but shorter than the diameter of the electrode stack, as taught by Hara in the same field of endeavor. There would have been a motivation to use the uncoated protrusions extending downwards from the negative electrode, as taught by Hara, since establishing electrical contact by welding the overlapping protrusions extending from both ends of the negative electrode together to the bottom plate simplifies manufacturing by eliminating welding steps and reduces the resistance of the connection between the negative electrode and the battery case ([0008], [0011], [0017] and [0020]). A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the connection methods of Owaka for that taught by Hara, in the same field of endeavor, would have been successful, as Kozuki demonstrated precedent for folding the negative electrode downwards, and the connections of the positive and negative electrodes to the top and bottom plates, respectively, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [033] Regarding claim 6, the instant claim is drawn to the secondary battery as claimed in claim 2, wherein the overlapping portion is in contact with the side plate of the case. The examiner notes that paragraph 38 of the instant specification states that, when a layer/element is “on” another layer/substrate, it can be directly on the substrate, or intervening layers may be present. The same type of distinction is made in paragraph 39 of the instant specification for if A is connected to B. As such, a similar basis for contact with be used in this claim. [034] Owaka, Kozuki, and Hara teach the battery of claim 2. Owaka does not teach that the folded portion is in direct contact with the side plate of the case, but Owaka teaches the separator covers the folded portion of the negative electrode (Figure 6; element 25a is the negative folded portion, and has a separator, element 23, to its right before the battery can wall, element 20). Kozuki teaches that, after winding, the folded leads are welded to the closing plate and the electrode assembly is inserted into the battery can ([0038]). No other layers external are noted, which, in view of Figure 1 (reproduced below), the folded portion is in direct contact with the battery case. PNG media_image7.png 523 526 media_image7.png Greyscale Figure 1, reproduced from Kozuki. [035] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards, as taught by Kozuki in the same field of endeavor, such that the folded region is in contact with the side wall of the battery case, as taught by Owaka and/or Kozuki. There would have been a motivation to have the outer folded region be in contact with the side-wall of the case, since Hara teaches that it is known that, when the negative electrode is in direct contact with the case, the battery case can act as the negative lead for the resulting battery ([0006]). Hara teaches the main issue with that configuration is that the negative active material is usually in contact with the battery case, causing an increase in contact resistance ([0008]). Thus, a person of ordinary skill in the art would have had a reasonable expectation that, by having the uncoated folded portion of the negative electrode in contact with the side wall of the battery case, the configuration would result in the negative electrode being be in electrical contact with the battery case with reduced contact resistance, since the uncoated folded region would be the lowest point of resistance between the negative electrode and the battery case, resulting in it being the main point of electrical contact between the two. [036] Regarding claim 7, the instant claim is drawn to the secondary battery as claimed in claim 2, wherein the separator covers the overlapping portion and is in contact with the side plate of the case. [037] Owaka, Kozuki, and Hara teach the battery of claim 2. Owaka teaches the separator covers the folded portion of the negative electrode (Figure 6; element 25a is the negative folded portion, and has a separator, element 23, to its right before the battery can wall, element 20). [038] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards such that it protrudes from the electrode assembly, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor, as outlined in claims 1 and 2, above. [039] Regarding claim 8, the instant claim is drawn to the secondary battery as claimed in claim 1, wherein: the negative electrode uncoated portion includes a negative electrode front uncoated portion positioned at a winding front portion and a negative electrode finish uncoated portion positioned at a winding finish portion; and the negative electrode extension uncoated portion is formed in the negative electrode finish uncoated portion. [040] Owaka, Kozuki, and Hara teach the battery of claim 1. Owaka teaches both the positive and negative electrode plates have uncoated portions at the beginning and end of the winding portions of the electrodes, and can be bent 90° (in reference to Figure 2, above), to form a protruding extension portion ([0007] and [0009]). The examiner notes Figure 2b demonstrates this for the terminal end of the electrode plate, in view of an embodiment taught in [0009], which matches the instant claim. [041] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards such that it protrudes from the electrode assembly, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor, as outlined in claim 1, above. [042] Regarding claim 9, the instant claim is drawn to the secondary battery as claimed in claim 1, wherein: the negative electrode extension uncoated portion is folded along a folding line connecting an upper end and a lower end of the negative electrode uncoated portion; and a first angle formed between the folding line and the lower end of the negative electrode uncoated portion is an acute angle. [043] Owaka, Kozuki, and Hara teach the battery of claim 1. Owaka teaches both the positive and negative electrode plates have uncoated portions at the beginning and end of the winding portions of the electrodes, where the uncoated region is folded along a line connecting the top and bottom parts of the electrode plate oriented 45° relative to the electrode, creating a bent region with a protrusion that is orthogonal to the winding direction of the electrode ([0007], [0009], and Figure 2, above). [044] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards such that it protrudes from the electrode assembly, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor, as outlined in claim 1, above. [045] Regarding claim 10, the instant claim is drawn to the secondary battery as claimed in claim 9, wherein the negative electrode extension uncoated portion is further folded at least once along a folding line perpendicular to a length direction of the negative electrode uncoated portion. [046] Owaka, Kozuki, and Hara teach the battery of claim 9. Owaka teaches that the width of the protrusion can be changed via further folding (Figure 2b and [0010]), up to n times, but if the width is less than or equal to half the outermost circumference of winding, then n may equal one ([0010]). The examiner notes that the orientation of the folds is orthogonal to the winding direction of the electrode, which corresponds to the direction of the instant claim. [047] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by bending the negative electrode plate downwards such that it protrudes from the electrode assembly, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor, as outlined in claim 1, above. [048] Claims 11-13, and 15 are rejected under 35 U.S.C. 103 as being unpatentable over Owaka, and further in view of Kozuki, Song (WO 2023219329 A2, claiming priority to 5/13/2022; Henceforth, Song) and Hara. [049] Regarding claim 11, the instant claim is drawn to a secondary battery, comprising: an electrode assembly including: a positive electrode plate having a positive electrode uncoated portion, a negative electrode plate having a negative electrode uncoated portion, the negative electrode uncoated portion including a negative electrode extension uncoated portion, and a portion of the negative electrode uncoated portion being cut along a perforated line, folded along a folding line, and, a separator between the positive electrode plate and the negative electrode plate; a case including a side plate with a cylindrical body, the case accommodating the electrode assembly and a lower plate sealing a lower portion of the side plate and the negative electrode uncoated portion extending downward from the electrode assembly and connected to the lower plate of the case; and a cap assembly coupled to an upper portion of the case and electrically connected to the positive electrode plate. [050] Owaka teaches a secondary battery ([0013] and Figure 6, annotated above) comprising an electrode structure ([0007]) including a positive electrode plate, a negative electrode plate and a separator dispersed between them ([0013] teaches the components, and Figure 6 depicts the separator, element 23, dispersed between the electrode plates, element 24 and 25). Owaka teaches both the positive and negative electrode plates have uncoated portions at the beginning and end of the winding portions of the electrodes ([0007]). Owaka depicts the battery case with a cylindrical body (Figure 6; denoted as a “battery can” in [0013]) that has a lower plate sealing the bottom of the battery can, and a cap assembly coupled to the upper portion of the battery can ([0013], element 19 in Figure 6). Owaka teaches the uncoated portions are bent by 90° (see Figure 2, above). The examiner notes that, by 90° in view of Figure 2, Owaka means that the electrode plates are folded along a 45° line extending in the direction of the electrode plate, such that the resulting angle between the folded portion and the primary extension direction of the electrode plate are 90°. Owaka teaches the positive and negative electrode plates are directly connected to battery terminals extending out of the top plate assembly of the battery ([0008]), but is electrically insulated from the top plate ([0013]). [051] Owaka does not teach that a portion of the negative electrode uncoated portion is cut along a perforated line, folded downwards, nor that the negative and positive electrode plates are electrically connected to the bottom plate and top plate of the battery case, respectively. [052] Kozuki teaches an electrochemical element ([0014]) in a secondary battery ([0032]) comprising a positive electrode with a positive current collector with both ends left uncoated by positive active material ([0033], a negative electrode with a negative current collector with both ends left uncoated ([0035]) with a separator interposed between the two electrodes ([0037]). The positive and negative electrodes are folded along 45° lines in opposite directions, with the positive electrode oriented up, and the negative electrode oriented down ([0033] and [0035]), such that the negative plate is folded inwards (see Figures 2 and 3, above). Kozuki teaches that the uncovered portions of positive and negative electrodes can be split into two parts by cutting along a cut line ([0040] and [0041]), where one is the welding piece that is bent along a 45° fold line and has a protrusion extending past the edge of the electrode assembly, and an unbent portion ([0040] and [0041]; Figures 5 and 6, reproduced below). Kozuki teaches this design reduces the areas that do not contribute to power generation, unlike the other embodiments taught ([0039]). PNG media_image8.png 617 473 media_image8.png Greyscale PNG media_image9.png 662 481 media_image9.png Greyscale Figures 5 (left) and 6 (right), reproduced from Kozuki. [053] Kozuki does not teach the negative electrode is electrically connected to the bottom plate of the battery can, nor the cut line is a perforated line. [054] Song teaches a reusable battery ([0001]) containing an electrode structure composed of a first electrode, a second electrode, and a separator ([0009]). Song teaches that cut lines may be provided along the wound electrode structure, allowing the segments to be easily cut by a user ([0076]). The examiner notes Song teaches cut lines may be formed by pre-cutting one side on the substrate into units of a certain length ([0058]), which matches the colloquial description of a perforated line. While this definition is in direct reference to the introduction of a pull tab into a battery housing so a user can easily open the housing ([0059] and [0060]) the cutting line on the electrode body is described using the same terminology, and thus is interpreted as a perforated line. [055] Song does not teach the negative electrode is electrically connected to the bottom plate of the battery can. [056] Hara teaches a cylindrical battery consisting of a positive electrode, a negative electrode, and a separator wound in a battery case ([0010]), where the negative electrode has uncoated regions on either end in the winding direction of the electrode such that they can fold below the wound core structure ([0010]-[0011]). The uncoated portions are welded to the bottom plate ([0010]), which the examiner notes means they are electrically connected to the bottom plate (also see Figure 2, reproduced below). Hara teaches the positive electrode is welded to the back of the battery lid, which has a positive terminal on the opposing surface of the battery cover ([0016], [0017] and Figure 2). Hara teaches that this configuration reduces the amount of positive active material needed and, by only needing to perform one weld to attach the negative electrode to the battery case, instead of installing a separate connection point, the ability to produce the batteries are improved ([0020]). Hara also notes that, by not needing to weld added components to the negative electrode to connect it to the exterior of the case via a terminal, it decreases the resistance in the welded area ([0008] and [0011]). [057] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by having an uncovered portion where a cut is made along a perforated line, as taught by Song in the same field of endeavor, only one segment is bent from the negative electrode plate downwards, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor. There would have been a motivation, as taught by Hara, to electrically connect the negative electrode to the bottom plate of the battery, in order to simply manufacturing by eliminating welding steps, reduce the resistance of the connection between the negative electrode and the battery case, and reduce the amount of active material used in manufacturing the battery. There would have been an additional motivation, to have a split in the uncoated portion to produce a weld tab, in order to reduce the amount of the current collector not contribution to power generation, as taught by Kozuki. There also would have been an motivation motivates the inclusion of a perforated cutting line to allow a user to easily cut an electrode body at desired intervals, as taught by Song in the same field of endeavor ([0076]). A person of ordinary skill in the art would have had a reasonable expectation that the introduction of a perforated cutting line to the electrode structure taught by Kozuki would have been successful, as it would be performing the same function as it had in the system of Song, enabling a user to cut the tab at the desired position more easily. Additionally, a person of ordinary skill in the art would have had a reasonable expectation that the substitution of the connection methods of Owaka for those taught by Hara, in the same field of endeavor, would have been successful, as Kozuki demonstrated precedent for folding a weld tab cut from an uncovered the negative electrode downwards, and the connections of the positive and negative electrodes to the top and bottom plates, respectively, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [058] Regarding claim 12, the instant claim is drawn to the secondary battery as claimed in claim 11, wherein a first width of the negative electrode plate is greater than a diameter of the electrode assembly. [059] Owaka, Kozuki, Song and Hara teach the battery of claim 11. Owaka teaches the width of the protrusion (the dimension of the winding direction in Figure 2, above) is the same as the width of the negative electrode plate (the height of the electrode, in Figure 2). Owaka teaches that the width of the protrusion can be changed via further folding (Figure 2b and [0010]), but not if the width is less than or equal to half the outermost circumference of winding ([0010]). The examiner notes that, since the circumference is related to the diameter by the relation C = dπ, Owaka describes a range wherein the width of the protrusion overlaps with the instant range, since the maximum width of the protrusion of C/2, is greater than the diameter of winding (C/π). [060] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka by having an uncovered portion where a cut is made along a perforated line, as taught by Song in the same field of endeavor, only one segment is bent from the negative electrode plate downwards, as taught by Kozuki in the same field of endeavor, and electrically connecting it to the bottom plate of the battery case, as taught by Hara in the same field of endeavor, as outlined for claim 11, above. The examiner notes the range taught by Owaka overlaps the range taught by the instant claim. It has been held that, in the case where the claimed ranges "overlap or lie inside ranges disclosed by the prior art" a prima facie case of obviousness exists. In re Wertheim, 541 F.2d 257, 191 USPQ 90 (CCPA 1976); In re Woodruff, 919 F.2d 1575, 16 USPQ2d 1934 (Fed. Cir. 1990). See MPEP 2144.05. It would have been obvious for a person of ordinary skill in the art before the effective filing date of the claimed invention to select the width of the electrode from the prior art range, because the prior art teaches the desired utility over the entire range. [061] Regarding claim 13, the instant claim is drawn to the secondary battery as claimed in claim 11, wherein: the perforated line is parallel to a length direction of the negative electrode plate; the folding line connects the perforated line and a lower end of the negative electrode plate; and a first angle formed between the folding line and the lower end of the negative electrode plate is an acute angle. [062] Owaka, Kozuki, Song and Hara teach the battery of claim 11. Kozuki teaches an electrochemical element ([0014]) in a secondary battery ([0032]) comprising a positive electrode with a positive current collector with both ends left uncoated by positive active material ([0033], a negative electrode with a negative current collector with both ends left uncoated ([0035]) with a separator interposed between the two electrodes ([0037]). The positive and negative electrodes are folded along 45° lines in opposite directions, with the positive electrode oriented up, and the negative electrode oriented down ([0033] and [0035]), such that the negative plate is folded inwards (see Figures 2 and 3, above). Kozuki teaches that the uncovered portions of positive and negative electrodes can be split into two parts by cutting along a cut line that is parallel to the winding direction of the battery ([0040] and [0041]), where one is the welding piece that is bent along a 45° fold line and has a protrusion extending past the edge of the electrode assembly, and an unbent portion ([0040] and [0041]; Figures 5 and 6, above). Kozuki teaches this design reduces the areas that do not contribute to power generation, unlike the other embodiments taught ([0039]). The examiner notes the angle of the fold line is acute, and matches the angle described in the instant claim. Kozuki does not explicitly teach the parallel cut line is perforated. [063] Song depicts that the perforated cutting line is perpendicular to the winding direction of the electrode assembly (Figure 8, reproduced below). Song does not explicitly teach the perforated cutting line is parallel to the winding direction of the battery, but Song teaches that the inclusion of a perforated cutting line cut lines allows the segments to be easily cut by a user ([0076]). PNG media_image10.png 265 600 media_image10.png Greyscale Figure 8, reproduced from Song. [064] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by modify the battery structure taught by Owaka, Kozuki, Song and Hara in claim 11, above, by having an uncovered portion where a cut is made along a perforated line, as taught by Song in the same field of endeavor, that is parallel to the winding direction of the battery, wherein a folding line connects the perforated cutting line and a lower end of the negative electrode, such that the angle formed by the folding line and the end of the negative electrode plate is an acute angle, as taught by Kozuki in the same field of endeavor. There would have been an motivation to include a perforated cutting line on an electrode to allow a user to easily cut an electrode body at desired intervals, as taught by Song in the same field of endeavor ([0076]). A person of ordinary skill in the art would have had a reasonable expectation that the introduction of a perforated cutting line, in any orientation or size, to electrode structure taught by Kozuki would have been successful, as it would be performing the same function as it had in the system of Song, enabling a user to cut the electrode plate at the desired position more easily. [065] Regarding claim 15, the instant claim is drawn to the secondary battery as claimed in claim 11, wherein the negative electrode extension uncoated portion includes: an overlapping portion which is folded to an outer surface or an inner surface of the negative electrode uncoated portion and in contact with the outer surface or the inner surface of the negative electrode uncoated portion; and a protrusion which protrudes downward from the electrode assembly. [066] Owaka, Kozuki, Song and Hara teach the battery of claim 11. Owaka teaches that the negative electrode uncoated portion is folded to the outer surface of the negative electrode (Figure 2, reproduced above; the dashed line implies it is folded behind the plane of the page). Owaka teaches there is a protrusion extending from the electrode assembly (Figure 2), but does not teach the protrusion is oriented downwards. Kozuki teaches that the negative electrode uncoated portion is folded inwards (Figures 2 and 3, above), which the examiner notes is the opposite orientation than what is taught by Owaka. Both Kozuki and Hara teaches there is a protrusion extending downwards from the electrode assembly (Kozuki: Figure 3; Hara: Figure 2). [067] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka, Kozuki, Song and Hara in claim 11, above, by folding the negative electrode plate downwards over itself, as taught by Kozuki in the same field of endeavor, such that it is protrudes downwards from the electrode assembly. There would have been a motivation to use uncoated protrusions extending downwards from the negative electrode, as taught by Hara, since welding both ends of the negative electrode together and to the bottom plate to electrically connect the negative electrode to the bottom plate of the battery simplifies manufacturing by eliminating welding steps and reduces the resistance of the connection between the negative electrode and the battery case ([0008], [0011] and [0020]). A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the connection methods of Owaka for those taught by Hara, in the same field of endeavor, would have been successful, as Kozuki demonstrated precedent for folding the negative electrode downwards, and the connections of the positive and negative electrodes to the top and bottom plates, respectively, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [068] Claim 14 is rejected under 35 U.S.C. 103 as being unpatentable over Owaka, Kozuki, Song and Hara, as described for claim 11, above and further in view of Etsuko and Hitoshi (JP 2003123732 A; henceforth, Etsuko). [069] Regarding claim 14, the instant claim is drawn to the secondary battery as claimed in claim 11, wherein: the perforated line is perpendicular to a length direction of the negative electrode plate; and the folding line is parallel to the length direction of the negative electrode plate. [070] Owaka, Kozuki, Song and Hara teach the battery of claim 11. Owaka, Kozuki, and Hara do not teach any embodiments with a cut line perpendicular to the winding direction of the battery. Song teaches the perforated cut line is perpendicular to the winding direction of the battery, but does not teach a folding line parallel to the length direction of the negative electrode plate. [071] Etsuko teaches a lithium-ion polymer battery ([0001]) comprising an electrode element (“electrode assembly”) in which a positive electrode and a negative electrode, each have an active material layer formed on a current collector, with electrode leads led out from the positive electrode and the negative electrode, respectively, wherein the electrode leads are made from the portion of the current collector where the active material layer is not formed ([0009]). Etsuko teaches that this orientation makes it is not necessary to join the electrode leads to the current collector, and the reliability of the connection between the electrode leads and the current collector is also improved ([0010]). Figure 6 (reproduced below) depicts an embodiment wherein a portion of a current collector is cut out to a notch (element 25, below), wherein the tab is folded perpendicular to the length direction of the electrode to the notch, such that it protrudes past the rest of the current collector ([0022]). The examiner notes the current collector is employed as a generic form of the positive and negative current collectors ([0020]), and thus can be applied to either the positive or negative electrode. PNG media_image11.png 325 322 media_image11.png Greyscale Figure 6, reproduced from Etsuko. [072] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Owaka, Kozuki, Song and Hara in claim 11, above, by using a perpendicular perforated cutting line to create a tab which is folded parallel to the winding direction of the battery, as taught by Etsuko in the same field of endeavor. There would have been a motivation to use the configuration taught by Etsuko, since orientation makes it is not necessary to join the electrode leads to the current collector, and the reliability of the connection between the electrode leads and the current collector can be improved ([0010]). A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the protrusions of Owaka and Kozuki for those taught by Etsuko, in the same field of endeavor, would have been successful, as Kozuki previously demonstrated the use of folded uncoated electrode portions, and the function of the electrodes would be identical to what had previously been demonstrated by Etsuko. See MPEP 2143 I (B). Since Kozuki and Hera previously demonstrated the negative electrode tabs could be oriented down, it would have been reasonable to a person of ordinary skill in the art before the effective filing date to modify the orientation of the folded portion of Etsuko to go in the opposite direction, in order to simplify the battery manufacturing process, as previously taught by Hera ([0020]). [073] Claims 19 and 20 are rejected under 35 U.S.C. 103 as being unpatentable over Kozuki, as with claims 16-18, above, and further in view of and Hara. [074] Regarding claim 19, the instant claim is drawn to the secondary battery as claimed in claim 17, wherein a first width of the protrusion is less than a diameter of the electrode assembly. [075] Kozuki teaches the battery of claim 17. Kozuki does not teach the width of the protrusion is less than a diameter of the electrode assembly, as the battery of Kozuki is elliptical. [076] Hara teaches that one of the uncoated protrusions is made to a length that is the radius of the electrode group plus the welded section ([0010]) and the other a length that reaches the central space of the electrode group ([0010]). The examiner notes the width of the protrusion is less than the length of the protrusion (Figure 1, annotated below), which means the width of the protrusion is less than the diameter of the electrode assembly. [077] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Kozuki, such that the width of the protrusion is less than a diameter of the electrode assembly, as taught by Hara in the same field of endeavor. Hara demonstrates precedent for the use of protrusions with a width less than the diameter of the electrode assembly, in order to properly weld the protrusion to the bottom cap of the battery can. A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the protrusions of Kozuki for those taught by Hara, in the same field of endeavor, would have been successful, as the configuration and the connections of the negative electrode protrusions, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). [078] Regarding claim 20, the instant claim is drawn to the secondary battery as claimed in claim 17, wherein a length of the protrusion is greater than half of a diameter of the electrode assembly and less than the diameter of the electrode assembly. [079] Kozuki teaches the battery of claim 17. Kozuki does not teach that a length of the protrusion is greater than half of a diameter of the electrode assembly and less than the diameter of the electrode assembly. [080] Hara teaches that one of the uncoated portions is made to a length that is the radius of the electrode group plus the welded section ([0010]) and the other a length that reaches the central space of the electrode group ([0010]). The examiner notes this corresponds to the winding end and beginning sides respectively ([0016]), and the winding end side overlaps the winding beginning side ([0017]), before being welded together ([0017]). The examiner notes that the reference to the phrase “Parts 1 and 2 are joined together at their tips and spot-welded” ([0016]) has been interpreted as making sure the protrusions are properly aligned, as paragraph [0017] goes into more detail on this step, where Hara states they overlap, as mentioned above. Additionally, the examiner notes the value taught by Hara is greater than the radius, and, in view of Figure 2, less than the diameter, and therefore lies within the range taught by the instant claim, and anticipates it. UCB, Inc. v. Actavis Labs. UT, Inc., 65 F.4th 679, 687, 2023 USPQ2d 448 (Fed. Cir. 2023). See MPEP 2131.03. [081] Therefore, it would have been obvious to a person of ordinary skill in the art before the effective filing date of the claimed invention to modify the battery structure taught by Kozuki by having the length of the protrusion be greater than half of a diameter of the electrode assembly and less than the diameter of the electrode assembly, as taught by Hara in the same field of endeavor. Hara demonstrates precedent for the use of protrusions with a length that is greater than half of the diameter of the electrode assembly and less than the diameter of the electrode assembly, in order to properly weld the protrusion to the bottom cap of the battery can. There would have been a motivation to use the uncoated protrusions extending downwards from the negative electrode, as taught by Hara, since establishing electrical contact by welding the overlapping protrusions extending from both ends of the negative electrode together to the bottom plate simplifies manufacturing by eliminating welding steps and reduces the resistance of the connection between the negative electrode and the battery case ([0008], [0011], [0017] and [0020]). A person of ordinary skill in the art would have had a reasonable expectation that the substitution of the protrusions of Kozuki for those taught by Hara, in the same field of endeavor, would have been successful, as the configuration and the connections of the negative electrode protrusions, would be identical to what had previously been demonstrated by Hara. See MPEP 2143 I (B). Conclusion [082] The prior art made of record and not relied upon is considered pertinent to applicant's disclosure: KR 20220151862 A (Henceforth, Shin). [083] Shin teaches a cylindrical secondary battery comprising: a first electrode plate having a first electrode non-part formed thereon, a second electrode plate having a second electrode non-part formed thereon, and a separator interposed between the first electrode plate and the second electrode plate, and a wound electrode assembly; a cylindrical can accommodating the electrode assembly; a cap assembly coupled to the can to seal the can; a first electrode current collector plate electrically connected to the first electrode non-part; and a second electrode current collector plate electrically connected to the second electrode non-part, wherein at least a portion of the first electrode non-part and the second electrode non-part are bent in one direction before being inserted into the can (Claim 1). Shin teaches the first electrode collector plate is electrically connected to the bottom surface of the can and the second electrode collector plate is electrically connected to the cap assembly (Claim 7), wherein the first electrode plate is a negative electrode and the second electrode plate is a positive electrode (Claim 6). [084] Any inquiry concerning this communication or earlier communications from the examiner should be directed to RYAN P MURPHY whose telephone number is (571)272-9321. The examiner can normally be reached Monday - Friday 8:00 am - 5:30 pm. [085] 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. [086] If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Nicholas A Smith can be reached at (571) 272-8760. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. [087] 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. /RPM/Examiner, Art Unit 1752 /NICHOLAS A SMITH/Supervisory Primary Examiner, Art Unit 1752
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Prosecution Timeline

Oct 18, 2023
Application Filed
Jun 11, 2026
Non-Final Rejection mailed — §102, §103 (current)

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