Prosecution Insights
Last updated: August 17, 2026
Application No. 18/386,849

BATTERY CELL INCLUDING INTERNAL TERMINAL LASER-WELDED TO FOLDED EXTERNAL CONNECTOR TABS

Non-Final OA §102§103
Filed
Nov 03, 2023
Examiner
HO, ANDREW YEWHONG
Art Unit
Tech Center
Assignee
GM Global Technology Operations LLC
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
27 currently pending
Career history
4
Total Applications
across all art units

Statute-Specific Performance

§103
55.6%
+15.6% vs TC avg
§102
22.2%
-17.8% vs TC avg
§112
22.2%
-17.8% 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 . Election/Restrictions Applicant’s election without traverse of 1-15 in the reply filed on June 29, 2026 is acknowledged. Claim Rejections - 35 USC § 102 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action: A person shall be entitled to a patent unless – (a)(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. Claim(s) 1, 2 and 7 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Sun et al. (CN 219144431; English translation relied upon, translation obtained from Espacenet). Regarding Claim 1, Sun meets the claimed, A battery cell ([n0048] teaches a battery cell), comprising: a stack ([n0048] teaches an electrode assembly) including: C cathode electrodes([n0077] and Fig. 9 teaches electrode assembly 30, which includes multiple electrode plates 31. [n0048] teaches that these electrode plates may be positive electrodes) each including a cathode current collector ([n0048] teaches a positive current collector, “The positive electrode includes a positive current collector and a positive active material layer”), a cathode active layer arranged on the cathode current collector ([n0048] teaches a positive active material layer layered on at least one surface of the positive current collector, “The positive active material layer is coated on at least one surface of the positive current collector”), and an external connector extending from the cathode current collector ([n0048] and Fig. 9 teaches that the positive current collector has tabs, which necessarily extend from the collector, “The current collector without the positive active material layer protrudes from the current collector with the positive active material layer”); A anode electrodes( [n0077] and Fig. 9 teaches electrode assembly 30, which includes multiple electrode plates 31. [n0048] teaches that these electrode plates may be negative electrodes) each including an anode current collector ([n0048] teaches a negative current collector, “The negative electrode sheet includes a negative current collector and a negative active material layer”), an anode active layer arranged on the anode current collector ([n0048] teaches a negative active material layer layered on at least one surface of the negative current collector, “The negative active material layer is coated on at least one surface of the negative current collector. “), and an external connector extending from the anode current collector ([n0048] teaches that the negative current collector has tabs, which necessarily extend from the collector, “The current collector without the negative active material layer protrudes from the current collector with the negative active material layer”); and S separators ([n0048] teaches a separator), where C, A, and S are integers greater than one ([n0049] teaches multiple positive and negative electrodes and separators); and a first internal terminal ([n0065] and Fig. 9 teach current collector 23 which functions as an internal terminal); wherein each one of the external connectors, of one of the C cathode electrodes and the A anode electrodes, includes a first tab ([n0074] teaches a second tab 322) and a second tab extending farther than the first tab ([n0074] teaches a first tab 321 that's larger than second tab 322), the second tabs are folded onto the first tabs ([n0074] and [n0075] teach that first tab 321 overlaps second tab 322 such that second tab 322 is welded to first tab 321), and the first internal terminal is laser welded onto the second tabs ([n0017] teaches that the electrodes are welded to the connecting member). The examiner notes that this claim is directed towards a product. Product claims are not limited by the manipulation of the recited steps only the structure implied by the steps. In particular, the step recited of the “first internal terminal is laser welded onto the second tabs”. Since the product of the prior art is substantially identical to that of the instant claim, the burden shifts to the Applicant to show a nonobvious difference (see MPEP 2113). Regarding Claim 2, Sun meets the claimed, The battery cell of claim 1, wherein N of the second tabs are folded onto R of the first tabs, N and R are integers with N being equal to or greater than R ([n0085] teaches that the number of first tabs and second tabs are equal). Regarding Claim 7, Sun meets the claimed, The battery cell of claim 1, further comprising a second internal terminal ([n0065] and Fig. 9 teach a second current collector 23 which functions as an internal terminal): wherein each one of the external connectors, of the other one of the C cathode electrodes and the A anode electrodes, includes a third tab and a fourth tab that is longer than the third tab (Fig. 6 and [n0077] teach a third and a fourth tab), the fourth tabs are folded onto the third tabs ([n0074] and [n0075] teach that first tab 321 overlaps second tab 322 such that second tab 322 is welded to first tab 321), and the second internal terminal is laser welded onto the fourth tabs ([n0017] teaches that the electrodes are welded to the connecting member). The examiner notes that this claim is directed towards a product. Product claims are not limited by the manipulation of the recited steps only the structure implied by the steps. In particular, the step recited of the “second internal terminal is laser welded onto the fourth tabs”. Since the product of the prior art is substantially identical to that of the instant claim, the burden shifts to the Applicant to show a nonobvious difference (see MPEP 2113). Claim Rejections - 35 USC § 103 The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claim(s) 5, 6, 8, 11, 12, and 14 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sun et al. (CN 219144431; English translation relied upon, translation obtained from Espacenet). Regarding Claim 5, Sun meets the claimed, The battery cell of claim 1, wherein: a first group of the first tabs is adjacent to a first group of the second tabs (Fig. 6 and [n0070] teach electrode tabs 321 and 322 which are adjacent to each other), the first group of the second tabs is folded in a first direction onto the first group of the first group of the first tabs ([n0074] and [n0075] teach that first tab 321 overlaps second tab 322 such that second tab 322 is welded to first tab 321); and a second group of the first tabs is adjacent to a second group of the second tabs (Fig. 6 and [n0077] teach that there can be multiple groups of electrode tabs, and thus there is a second group of electrode tabs 321 and 322). Sun does not explicitly teach the second group of second tabs being folded in a second direction that is opposite to the first direction. Sun teaches four sets of tabs with two longer tabs and two shorter tabs with both sets of longer tabs on one side. However, as per MPEP 2144.04 V, the rearrangement of parts which would have no effect on the operation of a device are considered a prima facie case of obviousness. Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date to flip which tabs were longer in the tabs as taught by Sun such that the second group of longer tabs would be folded in a second direction, opposite to the first direction, over the second set of shorter tabs. Regarding Claim 6, Sun does not specifically teach the first group of the first tabs (the first group short tabs) being laterally spaced, and aligned with, from the second group of the second tabs (the second group long tabs) in a third direction. Sun does teach the first group long tabs being laterally spaced, and aligned with, the second group long tabs. However, as per MPEP 2144.04 V, the rearrangement of parts which would have no effect on the operation of a device are considered a prima facie case of obviousness. Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date to flip which tabs were longer in the tabs as taught by Sun such that the first group long tabs would be laterally spaced, and aligned with, the second group short tabs, and the second group long tabs laterally spaced, and aligned with, the first group first tabs. Regarding Claim 8, Sun meets the claimed, The battery cell of claim 7, wherein: a first group of the third tabs is adjacent to a first group of the fourth tabs (Fig. 6 and [n0077] teach the tabs adjacent to each other), the first group of the fourth tabs is folded in a first direction onto the first group of the third tabs ([n0074] and [n0075] teach that first tab 321 overlaps second tab 322 such that second tab 322 is welded to first tab 321); and a second group of the third tabs faces a second group of the fourth tabs (Fig. 6 and [n0077] teach the tabs adjacent to each other). Sun does not teach a second group of the fourth tabs being folded onto the second group of the third tabs in a second direction opposite to the first direction. Sun teaches four sets of tabs with two longer tabs and two shorter tabs with both sets of longer tabs on one side. However, as per MPEP 2144.04 V, the rearrangement of parts which would have no effect on the operation of a device are considered a prima facie case of obviousness. Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date to flip which tabs were longer in the tabs as taught by Sun such that the second group of longer tabs would be folded in a second direction, opposite to the first direction, over the second set of shorter tabs. Regarding Claim 11, Sun meets the claimed, A battery cell ([n0048] teaches a battery cell), comprising: a stack ([n0048] teaches an electrode assembly) including: C cathode electrodes([n0077] and Fig. 9 teaches electrode assembly 30, which includes multiple electrode plates 31. [n0048] teaches that these electrode plates may be positive electrodes) each including a cathode current collector ([n0048] teaches a positive current collector, “The positive electrode includes a positive current collector and a positive active material layer”), a cathode active layer arranged on the cathode current collector ([n0048] teaches a positive active material layer layered on at least one surface of the positive current collector, “The positive active material layer is coated on at least one surface of the positive current collector”), and an external connector extending from the cathode current collector ([n0048] teaches that the positive current collector has tabs, which necessarily extend from the collector, “The current collector without the positive active material layer protrudes from the current collector with the positive active material layer”); A anode electrodes ([n0077] and Fig. 9 teaches electrode assembly 30, which includes multiple electrode plates 31. [n0048] teaches that these electrode plates may be positive electrodes ) each including an anode current collector ([n0048] teaches a negative current collector, “The negative electrode sheet includes a negative current collector and a negative active material layer”), an anode active layer arranged on the anode current collector ([n0048] teaches a negative active material layer layered on at least one surface of the negative current collector, “The negative active material layer is coated on at least one surface of the negative current collector”), and an external connector extending from the anode current collector ([n0048] teaches that the negative current collector has tabs, which necessarily extend from the collector, “The current collector without the negative active material layer protrudes from the current collector with the negative active material layer”); and S separators ([n0048] teaches a separator, “The electrode assembly consists of a positive electrode, a negative electrode, and a separator”), where C, A, and S are integers greater than one ([n0049] teaches multiple positive and negative electrodes and separators); and a first internal terminal ([n0065] and Fig. 9 teach current collector 23 which functions as an internal terminal); wherein with respect to one of the C cathode electrodes and the A anode electrodes, the external connectors include: a plurality of first tabs ([n0074] teaches a second tab 322) and a plurality of second tabs extending farther than the plurality of first tabs ([n0074] teaches a first tab 321 that's larger than second tab 322); a first group of the plurality of first tabs and a first group of the plurality of second tabs that is folded in a first direction onto the first group of the plurality of first tabs ([n0074] and [n0075] teach that first tab 321 overlaps second tab 322 such that second tab 322 is welded to first tab 321); […] and the first internal terminal laser welded onto the first group of the plurality of second tabs and the second group of the plurality of second tabs ([n0017] teaches that the electrodes are welded to the connecting member). Sun does not explicitly teach the second group of second tabs being folded in a second direction that is opposite to the first direction. Sun teaches four sets of tabs with two longer tabs and two shorter tabs with both sets of longer tabs on one side. However, as per MPEP 2144.04 V, the rearrangement of parts which would have no effect on the operation of a device are considered a prima facie case of obviousness. Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date to flip which tabs were longer in the tabs as taught by Sun such that the second group of longer tabs would be folded in a second direction, opposite to the first direction, over the second set of shorter tabs. The examiner notes that this claim is directed towards a product. Product claims are not limited by the manipulation of the recited steps only the structure implied by the steps. In particular, the step recited of the “first internal terminal is laser welded onto the second tabs”. Since the product of the prior art is substantially identical to that of the instant claim, the burden shifts to the Applicant to show a nonobvious difference (see MPEP 2113). Regarding Claim 12, Sun does not specifically teach the first group of the first tabs (the first group short tabs) being laterally spaced, and aligned with, from the second group of the second tabs (the second group long tabs) in a third direction. Sun does teach the first group long tabs being laterally spaced, and aligned with, the second group long tabs. However, as per MPEP 2144.04 V, the rearrangement of parts which would have no effect on the operation of a device are considered a prima facie case of obviousness. Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date to flip which tabs were longer in the tabs as taught by Sun such that the first group long tabs would be laterally spaced, and aligned with, the second group short tabs, and the second group long tabs laterally spaced, and aligned with, the first group first tabs. Regarding Claim 14, Sun meets the claimed, The battery cell of claim 11, further comprising a second internal terminal ([n0065] and Fig. 9 teach a second current collector 23 which functions as an internal terminal); wherein with respect to one of the C cathode electrodes and the A anode electrodes, the external connectors include: a plurality of first tabs ([n0074] teaches a second tab 322) and a plurality of second tabs extending farther than the plurality of first tabs ([n0074] teaches a first tab 321 that's larger than second tab 322); a first group of the plurality of first tabs and a first group of the plurality of second tabs that is folded in a first direction onto the first group of the plurality of first tabs ([n0074] and [n0075] teach that first tab 321 overlaps second tab 322 such that second tab 322 is welded to first tab 321); […] and the second internal terminal laser welded onto the first group of the plurality of second tabs and the second group of the plurality of second tabs ([n0017] teaches that the electrodes are welded to the connecting member). Sun does not explicitly teach the second group of second tabs being folded in a second direction that is opposite to the first direction. Sun teaches four sets of tabs with two longer tabs and two shorter tabs with both sets of longer tabs on one side. However, as per MPEP 2144.04 V, the rearrangement of parts which would have no effect on the operation of a device are considered a prima facie case of obviousness. Therefore, it would have been obvious to a person having ordinary skill in the art before the effective filing date to flip which tabs were longer in the tabs as taught by Sun such that the second group of longer tabs would be folded in a second direction, opposite to the first direction, over the second set of shorter tabs. The examiner notes that this claim is directed towards a product. Product claims are not limited by the manipulation of the recited steps only the structure implied by the steps. In particular, the step recited of the “second internal terminal is laser welded onto the second tabs”. Since the product of the prior art is substantially identical to that of the instant claim, the burden shifts to the Applicant to show a nonobvious difference (see MPEP 2113). Claim(s) 3 and 13 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sun et al. (CN 219144431; English translation relied upon, translation obtained from Espacenet) in view of Dietze et al. (US 2023/0261330). Regarding Claim 3, Sun does not specifically teach the first tabs (the short tabs) being folded in the direction of the second tabs (the long tabs). Dietze teaches a busbar for interconnecting flexible cell tabs of a battery module. Dietze meets the claimed, The battery cell of claim 11, wherein: the first group of the plurality of first tabs is folded toward the first group of the plurality of second tabs ([0024] teaches a first tab group 30 of flexible cell tabs 35 welded over second tab group 130 of the flexible cell tabs 35); and the second group of the plurality of first tabs is folded towards the second group of second tabs ([0024] teaches a first tab group 30 of flexible cell tabs 35 welded over second tab group 130 of the flexible cell tabs 35). It would have been obvious to a person having ordinary skill in the art before the effective filing date to have the first group of first tabs to fold towards the first group of the second tabs in order to create a better surface area of welding as opposed to only folding the second tabs over the first tabs, which could cause the first tabs to not fold properly and be crumpled instead (which could further limit conductivity or even damage the tabs). Regarding Claim 13, Sun does not specifically teach the first tabs (the short tabs) being folded in the direction of the second tabs (the long tabs). Dietze teaches a busbar for interconnecting flexible cell tabs of a battery module. Dietze meets the claimed, The battery cell of claim 11, wherein: the first group of the plurality of first tabs is folded toward the first group of the plurality of second tabs ([0024] teaches a first tab group 30 of flexible cell tabs 35 welded over second tab group 130 of the flexible cell tabs 35); and the second group of the plurality of first tabs is folded towards the second group of second tabs ([0024] teaches a first tab group 30 of flexible cell tabs 35 welded over second tab group 130 of the flexible cell tabs 35). It would have been obvious to a person having ordinary skill in the art before the effective filing date to have the first group of first tabs to fold towards the first group of the second tabs in order to create a better surface area of welding as opposed to only folding the second tabs over the first tabs, which could cause the first tabs to not fold properly and be crumpled instead (which could further limit conductivity or even damage the tabs). Claims 4 and 15 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sun et al. (CN 219144431; English translation relied upon, translation obtained from Espacenet) in view of Muraoka et al. (US 2011/0165445) and Bai et al. (US 2023/0246306). Regarding Claim 4, Sun does not particularly teach a longer tab with a maximum length that is less than, or equal to, half of a width of the stack. However, Sun does teach a number of layers equal to or less than 120 (See [n0018]). Muraoka teaches a wound-type secondary battery. While Muraoka does not teach a specific tab length that is less than, or equal to, half of a width of the stack, Muraoka does teach an electrode layer thickness of 150 µm (see [0053] and [0054], “Then, the obtained product is rolled to a thickness of about 150 .mu.m”). Combined with Sun, this would result in a total stack thickness of about 18 mm. It would have been obvious to a person having ordinary skill in the art before the effective filing date to use the electrode layer thickness of 150 µm as taught by Muraoka in order to have a sizeable capacity while not losing on significant ion transport speeds. Sun/Muraoka still does not teach a specific tab length that is less than, or equal to, half of a width of the stack. Bai teaches an electrode assembly with tabs. In particular, Bai teaches a tab length of 4 mm to 15 mm (see [0163], “the length L1 of the tab 102 in the axial direction X of the electrode assembly is 4 millimetres (mm) to 15 millimetres (mm)”). In combination with Sun/Muraoka, this would result in a tab length It would have been obvious to a person having ordinary skill in the art before the effective filing date to have a long tab length of equal to or less than half the stack’s width in order to provide enough length to be properly welded but not extend further so as to waste material or create loose material that could damage or cause shorts within the electrode assembly. Regarding Claim 15, Sun does not particularly teach a longer tab with a maximum length that is less than, or equal to, half of a width of the stack. However, Sun does teach a number of layers equal to or less than 120 (See [n0018]). Muraoka teaches a wound-type secondary battery. While Muraoka does not teach a specific tab length that is less than, or equal to, half of a width of the stack, Muraoka does teach an electrode layer thickness of 150 µm (see [0053] and [0054], “Then, the obtained product is rolled to a thickness of about 150 .mu.m”). Combined with Sun, this would result in a total stack thickness of about 18 mm. It would have been obvious to a person having ordinary skill in the art before the effective filing date to use the electrode layer thickness of 150 µm as taught by Muraoka in order to have a sizeable capacity while not losing on significant ion transport speeds. Sun/Muraoka still does not teach a specific tab length that is less than, or equal to, half of a width of the stack. Bai teaches an electrode assembly with tabs. In particular, Bai teaches a tab length of 4 mm to 15 mm (see [0163], “the length L1 of the tab 102 in the axial direction X of the electrode assembly is 4 millimetres (mm) to 15 millimetres (mm)”). In combination with Sun/Muraoka, this would result in a tab length that is less than or equal to half the width of the stack (i.e. a 4 mm tab length is less than half the 18 mm thickness of the stack). It would have been obvious to a person having ordinary skill in the art before the effective filing date to have a long tab length of equal to or less than half the stack’s width in order to provide enough length to be properly welded but not extend further so as to waste material or create loose material that could damage or cause shorts within the electrode assembly. Claims 9 and 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Sun et al. (CN 219144431; English translation relied upon, translation obtained from Espacenet) in view of Kobayashi et al. (US 2018/0272456). Regarding Claim 9, Sun does not teach that the first terminal and second terminal are on opposite ends of the stack. Kobayashi teaches a method for producing a prismatic secondary battery. Kobayashi meets the claimed, The battery cell of claim 7, wherein the first internal terminal and the second internal terminal are on opposite ends of the stack ([0037] and Fig. 2A teaches the current collectors, tabs, and internal terminals on either ends of the stack). It would have been obvious to a person having ordinary skill in the art before the effective filing date to have the internal terminals on either ends of the stack in order to avoid the possibility of having the negative tabs, collectors, or contacts contact the positive tabs, collectors, or contacts and cause a short. Regarding Claim 10, Sun meets the claimed, The battery cell of claim 9, further comprising: an enclosure ([n0104] and Fig. 9 teach a housing 901); a first external terminal in contact with the first internal terminal ([n0104] and Fig. 9 teach an external terminal 9022); and a second external terminal in contact with the second internal terminal ([n0104] and Fig. 9 teach a second external terminal 9022). Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to ANDREW Y. HO whose telephone number is (571)842-1342. The examiner can normally be reached 7:30 - 6:00, Mon - Thurs. 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, Xiao S. Zhao can be reached at (571) 270-5343. 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. /A.Y.H./ Examiner, Art Unit 1744 /MICHAEL M. ROBINSON/ Primary Examiner, Art Unit 1744
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Prosecution Timeline

Nov 03, 2023
Application Filed
Jul 21, 2026
Non-Final Rejection mailed — §102, §103 (current)

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Expected OA Rounds
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