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 .
Terminal Disclaimer
The terminal disclaimer filed on 03/1717/425,414/2026 disclaiming the terminal portion of any patent granted on this application, which would extend beyond the expiration date of any patent issuing from the US Patent No. 11,906,589 B2, filed July 20, 2022 has been reviewed and is accepted. The terminal disclaimer has been recorded.
Response to Arguments
The reply dated 03/17/2026 has been fully considered. Claims 1–20 remain pending. Claims 1–6 are canceled. Claims 7, 9, 13, and 15 are amended. No new matter is introduced.
The previous rejection of claims 1–20 under 35 U.S.C. 112(b) as indefinite is now moot with respect to claims 1–6 in view of their cancellation. Applicant has amended independent claims 7 and 13 (and dependent claims 9 and 15) to recite “one or more model-based state-of-charge estimates” instead of “plurality of model-based state-of-charge estimates,” which is consistent with the interpretation applied during examination and resolves the indefiniteness concern identified in the prior Office action. Accordingly, the rejection under 35 U.S.C. 112(b) is withdrawn as to claims 7–20.
The previous rejection of claims 1–6 under 35 U.S.C. 101 is rendered moot in view of the cancellation of claims 1–6.
Upon further consideration of the amended claims, independent claims 7 and 13, and dependent claims 8–12 and 14–20, are now rejected under 35 U.S.C. 101. The amendments to claims 7, 9, 13, and 15 have been fully considered; however, the claims continue to recite limitations directed to generating model-based state-of-charge estimates and determining an adaptive state-of-charge estimate based on measured current and voltage using mathematical relationships and data analysis. These limitations are considered to recite an abstract idea (mathematical concepts), and the additional elements, including the current measurement circuit, voltage measurement circuit, processor, and memory, are generic components that perform data gathering and routine processing and do not integrate the abstract idea into a practical application or amount to significantly more. Accordingly, claims 7–20 are rejected under 35 U.S.C. 101 as set forth in this Office Action.
Claims 1–4, 7–10, 13–16, and 19-20 were previously rejected on the ground of nonstatutory obviousness-type double patenting over claims 1–3, 6, 13–14, 15, 17, 19, and 21 of U.S. Patent No. 11,906,589. Claims 1–11 and 13 were also rejected on the ground of nonstatutory obviousness-type double patenting over claims 1–4, 10–13, 16, and 20 of U.S. Patent No. 11,422,195. Applicant has filed terminal disclaimers in compliance with 37 CFR 1.321 to obviate these nonstatutory double patenting rejections. Upon acceptance and recordation of the terminal disclaimers, the nonstatutory double patenting rejections are withdrawn.
The prior rejection of claims 1–2 and 4–6 under 35 U.S.C. 103 is moot in view of the cancellation of claims 1–6. No other claims stand rejected under 35 U.S.C. 103. Accordingly, the § 103 rejection is withdrawn..
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 7–20 are rejected under 35 U.S.C. 101 because the claimed invention is directed to a judicial exception (i.e., an abstract idea) without significantly more.
Representative claim 7 recites, a device for estimating a state-of-charge of an energy storage system… including generating model-based state-of-charge estimates based on measured current and voltage, and determining an adaptive state-of-charge estimate based on an adaptation current derived from the model-based estimates.
Step 1 – Statutory Category
Claim 7 is directed to a machine (device) and therefore falls within a statutory category of patent-eligible subject matter.
Step 2A – Prong One (Judicial Exception)
Under Step 2A Prong One, Claim 7 recites a judicial exception. The following limitations recite the abstract idea:
generating a plurality of one or more model-based state-of-charge estimates based on the measured current and the measured voltage.
determining an adaptive state-of-charge estimate based on an adaptation current and the measured current, wherein the adaptation current is based on the model-based state-of-charge estimates
These limitations fall within the mathematical concepts grouping of abstract ideas (2019 PEG), including: mathematical calculations and relationships (e.g., combining measured current with adaptation current, integration-type operations, see original par. [0050]); and mathematical modeling and estimation techniques (e.g., probabilistic or Bayesian estimation of state-of-charge, see [0040]).
The claim recites processing measured electrical values using mathematical models to generate estimated values, which is a form of data analysis and mathematical computation. Under a broadest reasonable interpretation, these limitations cover performance of mathematical operations applied to input data to derive a result.
Accordingly, Claim 7 recites a judicial exception.
Step 2A – Prong Two (Practical Application)
Under Step 2A Prong Two, Claim 7 does not integrate the judicial exception into a practical application.
Claim 7 further recites the following additional elements:
a current measurement circuit
a voltage measurement circuit
a tangible, non-transitory memory
one or more processors
These additional elements:
collect measured current and voltage data
execute instructions to perform the recited calculations
The current measurement circuit and voltage measurement circuit are used to obtain input data and constitute data gathering, which is insignificant extra-solution activity. The processor and memory are recited generically and perform routine execution of instructions. They do not:
improve the functioning of a computer
improve the operation of the energy storage system
implement a specific control or physical transformation
The claim does not recite any particular manner of controlling the battery or modifying its operation based on the estimated state-of-charge. Instead, the claim applies mathematical estimation techniques to measured data using generic components.
Accordingly, the additional elements do not integrate the abstract idea into a practical application.
Step 2B – Significantly More
Under Step 2B, Claim 7 does not include additional elements that amount to significantly more than the judicial exception.
The additional elements are well-understood, routine, and conventional, as evidenced by Wada et al. (U.S. 10,353,007 B2), which discloses:
a current measurement part for measuring current flowing through a rechargeable battery
estimation of a state-of-charge of the battery based on measured current
calculation of coefficients based on derivatives of the estimated state-of-charge with respect to error parameters
estimation of battery parameters using measured values and mathematical relationships.
Wada et al. demonstrates that: “measuring battery current”; “performing mathematical estimation of battery state”; “using processors to compute parameters based on measured data” are conventional techniques. The present claims similarly:
obtain measured electrical data
apply mathematical models to estimate state-of-charge
perform computations using a processor without reciting any unconventional hardware or technical improvement.
When considered individually and as an ordered combination, the additional elements amount to nothing more than applying mathematical analysis using conventional components in a battery-related context.
Accordingly, Claim 7 does not recite significantly more than the abstract idea.
Dependent Claims 8–12 recite:
additional parameters used in determining the adaptation current (claim 8)
generating an aggregated state-of-charge estimate (claim 9)
integrating current values (claim 10)
determining confidence limits and providing tracking signals (claims 11–12)
These limitations further define: mathematical relationships (aggregation, integration); statistical calculations (confidence limits, standard error) & evaluation of computed values (tracking conditions). These features are part of the abstract mathematical analysis and do not introduce additional elements that integrate the exception into a practical application or amount to significantly more. Accordingly,
Claims 8–12 are rejected under 35 U.S.C. 101 for the same reasons as Claim 7.
Claim 13 recites a system corresponding to Claim 7 and includes substantially the same limitations.
Claims 14–20 recite:
additional inputs for determining the adaptation current (claim 14)
aggregation of estimates (claim 15)
integration of current values (claim 16)
determining confidence limits and tracking signals (claims 17–18)
accounting for drift due to measurement error and self-discharge (claim 19)
error calculation based on a difference between estimates (claim 20)
These limitations: further elaborate on mathematical modeling, estimation, and error compensation; involve statistical analysis and data evaluation. They do not add:
a technological improvement
a specific non-conventional hardware implementation
a transformation of the physical system
Accordingly, Claims 13–20 are rejected under 35 U.S.C. 101 for the same reasons as Claim 7.
Examiner’s Note
All claims 7–20 are rejected under 35 U.S.C. 101 as set forth above.
The Examiner further notes that, based on the prior art of record and the results of the PE2E search (see attached), the references including U.S. 9,641,011 B2 to Ohkawa et al., U.S. 2021/0215769 A1 to Chow et al., and U.S. 2022/0209563 A1 to Sherstyuk et al. do not teach or suggest the claimed subject matter in a manner sufficient to support a rejection under 35 U.S.C. 102 or 103.
Independent claims 7 and 13 were previously indicated as allowable in the Office Action dated December 17, 2025 (see page 23). The present amendments to claims 7, 9, 13, and 15, including the modification from “plurality of model-based state-of-charge estimates” to “one or more model-based state-of-charge estimates,” have been considered and do not alter the prior determination that the claimed subject matter is patentable over the prior art of record.
In particular, the prior art of record fails to teach or suggest the claimed combination of generating model-based state-of-charge estimates using the recited processing framework and determining an adaptive state-of-charge estimate based on an adaptation current derived from such estimates, as recited in claims 7 and 13 as a whole. The dependent claims 8–12 and 14–20 similarly include limitations that are not taught or suggested by the prior art of record.
Accordingly, while the claims are considered allowable over the prior art of record, they are currently rejected under 35 U.S.C. 101 for the reasons set forth above.
The previously applied nonstatutory obviousness-type double patenting rejections have been overcome by the filing of terminal disclaimers and are withdrawn.
Any comments considered necessary by applicant must be submitted no later than the payment of the issue fee and, to avoid processing delays, should preferably accompany the issue fee. Such submissions should be clearly labeled "Comments on Statement of Reasons for Allowance."
During an extensive search (see PE2E attached), the Examiner reviewed additional references relevant to the applicant’s disclosure. However, these references do not anticipate the claims, nor do they render the claimed subject matter obvious.
U.S. 9,641,011 B2 to Ohkawa et al. discloses a battery control device that limits battery current based on predefined constraints and time-window-based current tables. However, Ohkawa does not teach or suggest generating model-based state-of-charge estimates or determining an adaptive state-of-charge estimate based on an adaptation current derived from such estimates.
U.S. 2021/0215769 A1 to Chow et al. discloses determining battery model parameters and estimating battery state using iterative estimation techniques and sensor data. However, Chow does not teach or suggest the specific combination of generating multiple model-based state-of-charge estimates and determining an adaptive state-of-charge estimate based on an adaptation current derived from such estimates as recited.
U.S. 2022/0209563 A1 to Sherstyuk et al. discloses adaptive battery charging using relaxation voltage measurements following discharge pulses. However, Sherstyuk does not teach or suggest the claimed estimation framework involving model-based state-of-charge estimates and adaptation current-based determination.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to TRUNG NGUYEN whose telephone number is (571)272-2066. The examiner can normally be reached on Mon- Friday 8AM - 4:00PM Eastern Time. If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Huy Phan can be reached on 571-272-7924. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300. Information regarding the status of an application may be obtained from the Patent Application Information Retrieval (PAIR) system. Status information for published applications may be obtained from either Private PAIR or Public PAIR. Status information for unpublished applications is available through Private PAIR only. For more information about the PAIR system, see http://pair-direct.uspto.gov. Should you have questions on access to the Private PAIR system, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative or access to the automated information system, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
Examiner: /Trung Q. Nguyen/- Art 2858
April 8, 2026
/HUY Q PHAN/ Supervisory Patent Examiner, Art Unit 2858
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