Prosecution Insights
Last updated: August 17, 2026
Application No. 18/382,788

Power Storage Device and Vehicle

Non-Final OA §102§103
Filed
Oct 23, 2023
Priority
Nov 24, 2022 — JP 2022-187264
Examiner
SERVAGNO, SANTINO MICHALE
Art Unit
1713
Tech Center
1700 — Chemical & Materials Engineering
Assignee
Toyota Motor Corporation
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
17 currently pending
Career history
9
Total Applications
across all art units

Statute-Specific Performance

§103
48.6%
+8.6% vs TC avg
§102
25.7%
-14.3% vs TC avg
§112
8.6%
-31.4% 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 The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Priority Receipt is acknowledged of certified copies of papers required by 37 CFR 1.55. Information Disclosure Statement The information disclosure statements (IDS) submitted on 10/23/2023 and 02/04/2026 have been considered by the examiner. Drawings The drawings are objected to because in Fig. 1, reference number 21 denotes a first portion, which is provided adjacent to a front side of second portion 22 wherein first portion 21 has a size smaller than a size of second portion 22. In Fig. 2, second portion 22 is provided adjacent to the front side of first portion 21, wherein second portion 22 has a size smaller than a size of first portion 21. Corrected drawing sheets in compliance with 37 CFR 1.121(d) are required in reply to the Office action to avoid abandonment of the application. Any amended replacement drawing sheet should include all of the figures appearing on the immediate prior version of the sheet, even if only one figure is being amended. The figure or figure number of an amended drawing should not be labeled as “amended.” If a drawing figure is to be canceled, the appropriate figure must be removed from the replacement sheet, and where necessary, the remaining figures must be renumbered and appropriate changes made to the brief description of the several views of the drawings for consistency. Additional replacement sheets may be necessary to show the renumbering of the remaining figures. Each drawing sheet submitted after the filing date of an application must be labeled in the top margin as either “Replacement Sheet” or “New Sheet” pursuant to 37 CFR 1.121(d). If the changes are not accepted by the examiner, the applicant will be notified and informed of any required corrective action in the next Office action. The objection to the drawings will not be held in abeyance. Claim Interpretation The following is a quotation of 35 U.S.C. 112(f): (f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph: An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof. The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked. As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph: (A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function; (B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and (C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function. Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function. Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function. Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: “flow suppressing portion” in claim 1. Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof. Page 5, lines 27-28 of the instant specification provide support for the “flow suppressing portion” as a block body, while Figure 2 of the instant specification illustrates a “flow suppressing portion” as an elongated, rectangular block. Thus, the limitation will be interpreted as “a physical barrier structure”, and equivalents thereof. If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. Claim Rejections - 35 USC § 102 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. (a)(2) the claimed invention was described in a patent issued under section 151, or in an application for patent published or deemed published under section 122(b), in which the patent or application, as the case may be, names another inventor and was effectively filed before the effective filing date of the claimed invention. 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. Claims 1-3 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Liu et al. (CN 114374040 A). Regarding claim 1, Liu discloses a power storage device (Annotated Liu Fig. 1) comprising: a power storage module (Para. [0047] denotes a power battery that is flexibly connected to a frame 30 through suspension assembly 50, which acts as a power source to a vehicle body.); an accommodation case that has an upper surface and that accommodates the power storage module (Annotated Liu Fig. 1 depicts a power battery pack 60 comprising of an upper surface and accommodates the power storage module (power battery).; and PNG media_image1.png 740 1294 media_image1.png Greyscale Annotated Liu Fig. 1: A power storage device comprised of an accommodation case (power battery pack 60) which houses a power storage module and possesses an upper surface. an electrical connector provided to be connectable to a vehicle-side electrical connector (Para. [0049] describes an electrical connector (negative high-voltage connector 25 and positive high-voltage connector 23) that comprise a second electrical connection assembly. Para. [0048] states that the second electrical connection assembly is connected to a first electrical connection assembly (vehicle-side electrical connector) wherein the first electrical connection assembly is connected to a voltage distribution box of a vehicle.), and a coolant connector provided to be connectable to a vehicle-side coolant connector (Para. [0049] describes a coolant connector (cooling water plug 26), wherein said coolant connector comprises a second cooling water delivery assembly connected to the power battery pack 60. Para. [0048] states that the second cooling water delivery assembly is connected to a first cooling water delivery assembly (vehicle-side coolant connector) wherein said first cooling water delivery assembly is directly connected to a vehicle frame 30 for direct connection to a vehicle cooling system.), wherein the electrical connector and the coolant connector are each provided to protrude upward from the upper surface, and are arranged side by side with a space being interposed between the electrical connector and the coolant connector (Annotated Liu Fig. 3 illustrates an electrical connector (positive high-voltage connector 23 and negative high-voltage connector 25) and a coolant connector (cooling water plug 26) protruding upward from an upper surface of an accommodation case wherein the electrical connector and the coolant connector are arranged side by side with a space interposed between said electrical connector and said coolant connector.), and a flow suppressing portion is provided between the electrical connector and the coolant connector in an arrangement direction in which the electrical connector and the coolant connector are arranged side by side, so as to suppress flow of a coolant from the coolant connector side toward the electrical connector side when the coolant is leaked from the coolant connector (Annotated Liu Fig. 3 shows a flow suppressing portion (denoted by an oval) provided between said electrical connector and said coolant connector in an arrangement direction in which both the electrical connector and the coolant connector are arranged side by side, wherein said flow suppressing portion enables for the suppression of coolant leakage from flowing from the coolant connector side toward the electrical connector side.). PNG media_image2.png 814 1187 media_image2.png Greyscale Annotated Liu Fig. 3: An electrical connector (positive high-voltage connector 23 and negative high-voltage connector 25) and a coolant connector (water cooling plug 26) protruding upward from an upper surface and arranged side by side with a flow suppression portion in the interposing space between said electrical connector and said coolant connector. Regarding claim 2, Liu discloses wherein the flow suppressing portion includes a protrusion provided in the upper surface between the electrical connector and the coolant connector so as to extend along a direction intersecting the arrangement direction (Annotated Liu Fig. 3A displays a protrusion provided in the upper surface between the electrical connector and the coolant collector and extending along a direction intersecting the arrangement direction.). PNG media_image3.png 806 977 media_image3.png Greyscale Annotated Liu Fig. 3A: A protrusion (left arrow) and a groove portion (right arrow) are provided in the upper surface between the electrical connector and the coolant connector wherein said protrusion and groove portion extend along a direction intersecting the arrangement direction. Regarding claim 3, Liu discloses wherein the flow suppressing portion is provided with a groove portion provided in the upper surface between the electrical connector and the coolant connector so as to extend along a direction intersecting the arrangement direction (Annotated Liu Fig. 3A displays a groove portion provided in the upper surface between the electrical connector and the coolant collector and extending along a direction intersecting the arrangement direction.). Claim Rejections - 35 USC § 103 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. 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 set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied 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. Claims 4-5 are rejected under 35 U.S.C. 103 as being unpatentable over Liu, as applied to claim 1, and in further view of Zhang et al. (US 2022/0328999 A1). Regarding claim 4, Liu discloses the power storage device as discussed in claim 1. Liu fails to disclose wherein the accommodation case includes a first chamber in which the electrical connector is provided and a second chamber in which the coolant connector is provided, the first chamber and the second chamber are provided to be separated from each other in the arrangement direction, and the flow suppressing portion is constituted of a clearance formed between the first chamber and the second chamber in the arrangement direction. However, Zhang teaches wherein the accommodation case includes a first chamber in which the electrical connector is provided and a second chamber in which the coolant connector is provided, the first chamber and the second chamber are provided to be separated from each other in the arrangement direction, and the flow suppressing portion is constituted of a clearance formed between the first chamber and the second chamber in the arrangement direction (Annotated Zhang Fig. 1 illustrates a first chamber housing an electrical connector and a second chamber housing a coolant connector, wherein said first chamber and said second chamber are separated from one another in the arrangement direction, and a clearance is provided in the space between the first chamber and the second chamber in the arrangement direction.). PNG media_image4.png 698 971 media_image4.png Greyscale Annotated Zhang Fig. 1: A first chamber (denoted by top arrow) housing an electrical connector; a second chamber (denoted by middle arrow) housing a coolant connector; the first chamber and the second chamber are separated from one another in an arrangement direction, and a flow suppressing portion (clearance – denoted by bottom arrow) is placed between first chamber and second chamber in an arrangement direction. Liu and Zhang are both considered to be analogous to the claimed invention because they are in the same field of designing battery quick-change devices that prevent coolant leakage and are used for mounting batteries onto a vehicle body. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the power storage device of Liu to include a first chamber and a second chamber, wherein the first chamber houses the electrical connector while the second chamber houses the coolant connector. Additionally, both the first chamber and the second chamber are separated from one another in the arrangement direction, and the flow suppressing portion is provided as a clearance formed between the first chamber and the second chamber in the arrangement direction because Zhang teaches having a floating connection between a power storage device and a vehicle wherein the electrical connector and the coolant connector are separated by a flow suppressing portion effectively avoids leakage and splashing of coolant due to the electrical connector and the coolant connector being centrally placed on a mounting base, thus ensuring the water and electrical connection accuracy between parts of the battery quick-change device is high. A high accuracy connection avoids the leakage and splashing of coolant from said coolant connector (Para. [0069]) and use of known techniques to improve similar methods in the same way is obvious. See MPEP 2141. III. (C). Furthermore, the courts have held that making known elements separable (the first chamber housing the electrical connector and the second chamber housing the coolant connector) is within the scope of a person of ordinary skill in the art. See MPEP 2144. V. (C). Regarding claim 5, Liu, as modified by Zhang, discloses wherein a frame is disposed in a clearance to attach the accommodation case to a vehicle body (Annotated Liu Fig. 1A shows a vehicle frame 30 disposed in a clearance to attach the accommodation case to a vehicle body. Para. [0077] mentions that vehicle frame 30 buffers the vibration excitation of the power source to the vehicle body, wherein one of ordinary skill in the art would interpret as a byproduct of a vehicle frame attaching the accommodation case to said vehicle body.). PNG media_image5.png 705 1316 media_image5.png Greyscale Annotated Liu Fig. 1A: A vehicle frame 30 disposed in a clearance provided for attaching the accommodation case (power battery pack 60) to a vehicle body. Claim 6 is rejected under 35 U.S.C. 103 as being unpatentable over Liu, and in further view of Newman et al. (US 2017/0225557 A1). Regarding claim 6, Liu discloses the power storage device as discussed in claim 1. Liu fails to disclose a vehicle comprising: the power storage device; and a vehicle body, wherein the power storage device is detachably attached to said vehicle body. However, Newman teaches a vehicle (Annotated Newman Fig. 1 shows a vehicle 10.) comprising: the power storage device (Annotated Newman Fig. 1 depicts a power storage device (electrical storage device 18).; and a vehicle body (Annotated Newman Fig. 1 discloses a vehicle body 12 comprising vehicle 10.), wherein the power storage device is detachably attached to said vehicle body (Para. [0028] states that battery pack 20 can be attached and removed from bay 22 using latching mechanism 24.). Liu and Newman are both considered to be analogous to the claimed invention because they are in the same field of developing apparatuses for mounting batteries onto a vehicle body. Therefore, it would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to modify the power storage device of Liu to include a vehicle comprising the power storage device and a vehicle body wherein the power storage device is detachably attached to the vehicle body because Newman teaches that the latching mechanism provides a secure connection between a first latch part and a second latch part in order to properly secure a battery to a vehicle body while simultaneously providing a connection that is quickly and easily moved between unlatched and latched parts (para. [0036]) and combining prior art elements according to known methods to yield predictable results is obvious. See MPEP 2141. III. (A). Furthermore, applying a known technique (a latching mechanism) to a known device (a battery-changing apparatus which detachably attaches a power storage device to a vehicle body) ready for improvement which yields predictable results is obvious. See MPEP 2141. III. (D). PNG media_image6.png 779 779 media_image6.png Greyscale Annotated Newman Fig. 1: A vehicle 10 comprised of a vehicle body 12, wherein a power storage device (electrical storage device 18) may be detachably attached to vehicle body 12 using latching mechanism 24. Conclusion Hozumi et. al. (US 2012/0233850 A1) describes a battery replacing apparatus to detachably attach a battery to a vehicle body using vehicle hoist members and locking devices. Contact Information Any inquiry concerning this communication or earlier communications from the examiner should be directed to SANTINO M SERVAGNO whose telephone number is (571)270-0847. The examiner can normally be reached M-Th 8:00 am - 5:00 pm, F 8:00 am - 4:00 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, Joshua Allen can be reached at (571) 270-3176. 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. /SANTINO MICHALE SERVAGNO/Examiner, Art Unit 1713 /JOSHUA L ALLEN/Supervisory Patent Examiner, Art Unit 1713
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Prosecution Timeline

Oct 23, 2023
Application Filed
Jul 22, 2026
Non-Final Rejection mailed — §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
Grant Probability
Low
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