Prosecution Insights
Last updated: October 04, 2026
Application No. 18/416,312

BATTERY SYSTEMS WTH MODULAR BATTERY PACKS

Non-Final OA §102§103
Filed
Jan 18, 2024
Priority
Feb 17, 2023 — provisional 63/446,461
Examiner
ZEMUI, NATHANAEL T
Art Unit
Tech Center
Assignee
Enphase Energy Inc.
OA Round
1 (Non-Final)
56%
Grant Probability
Moderate
1-2
OA Rounds
11m
Est. Remaining
80%
With Interview

Examiner Intelligence

Grants 56% of resolved cases
56%
Career Allowance Rate
267 granted / 477 resolved
-4.0% vs TC avg
Strong +24% interview lift
Without
With
+24.1%
Interview Lift
resolved cases with interview
Typical timeline
3y 7m
Avg Prosecution
67 currently pending
Career history
534
Total Applications
across all art units

Statute-Specific Performance

§101
0.3%
-39.7% vs TC avg
§103
66.3%
+26.3% vs TC avg
§102
17.6%
-22.4% vs TC avg
§112
14.0%
-26.0% vs TC avg
Black line = Tech Center average estimate • Based on career data from 477 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 . Status of Claims Claims 1-20 are currently pending. 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. Claims 1-3 & 7-9 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Fu (US 2019/0273232 A1). Regarding claims 1-3 & 8-9, Fu teaches an energy storage system comprising: a chassis (102) (fig. 1c; [0071]); a battery module (100) configured to removably connect to the chassis and comprising a plurality of prismatic battery cells (103) held in place via a pair of end plates (107+109) configured to compress the plurality of battery cells together when tightened to form the battery module (figs. 1c; [0071] & [0097]); and a printed circuit board (PCB) assembly (901) connected to the battery module (fig. 9a; [0090]); wherein each end plate comprises a plurality of apertures (970.1+970.2 and holes through which corresponding rods 971.1, 971.2, 971.3, 971.4 are inserted) including a plurality of apertures (970.1+970.2) that extend along a horizontal plane of each end plate ([0090]); and a plurality of apertures (i.e holes through which corresponding rods 971.1, 971.2, 971.3, 971.4 are inserted) that extend along a vertical plane of each end plate (fig. 9c; [0092]). Regarding claim 7, Fu does not explicitly teach each end plate of the pair of end plates comprising a lifting structure. However, it is noted that the sides of each end plate through which each end plate is connected to the chassis (i.e via apertures 107.1 and 107.2) can read on the claimed lifting structure since each end plate can be removed from the chassis by lifting both ends of each plate through the sides as can be seen from fig. 11 of Fu. Claim Rejections - 35 USC § 103 In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status. The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action: A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made. Claims 4-6 are rejected under 35 U.S.C. 103 as being unpatentable over Fu (US 2019/0273232 A1). Regarding claim 4, Fu teaches the energy storage system of claim 1, wherein the plurality of apertures extending along a horizontal plane of each end plate (970.1+970.2) being are configured to connect each end plate to an inner wall of the chassis; and the plurality of apertures extending along a vertical plane of each end plate (i.e holes through which corresponding rods 971.1, 971.2, 971.3, 971.4 are inserted) are configured to receive a corresponding rod (971.1, 971.2, 971.3, 971.4) (fig. 9c; [0090] & [0092]). While Fu does not explicitly teach the plurality of apertures extending along the horizontal plane of each end plate configured to receive a corresponding screw that is used to connect each end plate to an inner wall of the chassis, it would have been obvious to one of ordinary skill in the art to couple the apertures extending along the horizontal plate of each end plate to an inner wall of the chassis through a screw as a well-known means of coupling two components. Regarding claims 5-6, Fu teaches the energy storage system of claim 1 but is silent as to the plurality of battery cells comprising twelve battery cells (claim 5) and eight battery cell (claim 6). While the figures in Fu illustrate a battery module comprising thirteen battery cells, it is noted that the number of cells forming the battery module is found to be an obvious matter of design choice since the use of eight or twelve battery cells in the battery module would not have modified the operation of the battery module. See MPEP 2144.04 IV A. Claim 10 is rejected under 35 U.S.C. 103 as being unpatentable over Fu (US 2019/0273232 A1) in view of Dinkelman (US 2015/0072176 A1). Regarding claim 10, Fu teaches the energy storage system of claim 1, wherein the PCB assembly comprises voltage (V) and temperature (T) sensing components that connect to battery tabs (i.e cathode output end and anode output end) of the battery module ([0092], [0096] & [0115]-[0116]) but is silent as to the connection between the battery tabs and the PCB being via screw or welding. However, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the present invention, to connect the battery tabs and the PCB via welding as well-known means for connecting a PCB to battery tabs in a battery module as taught by Dinkelman ([0101]-[0103]). Claims 11-19 are rejected under 35 U.S.C. 103 as being unpatentable over Fu (US 2019/0273232 A1) in view of Zhao (US 2023/0275447 A1). Regarding claim 11-13 & 17-19, Fu teaches the energy storage system of claims 1-3 & 7-9, as noted above, but is silent as to a distributed energy storage resource comprising a renewable energy source and a load center connected to the renewable energy source. However, the use of an energy storage system (120) along with a distributed energy storage resource comprising a renewable energy source (130) and a load center (110) connected to the renewable energy source is well-known as taught by Zhao ([0033]). Regarding claim 14, Fu as modified by Zhao teaches the energy management system of claim 13. Fu further teaches wherein the plurality of apertures extending along a horizontal plane of each end plate (970.1+970.2) being are configured to connect each end plate to an inner wall of the chassis; and the plurality of apertures extending along a vertical plane of each end plate (i.e holes through which corresponding rods 971.1, 971.2, 971.3, 971.4 are inserted) are configured to receive a corresponding rod (971.1, 971.2, 971.3, 971.4) (fig. 9c; [0090] & [0092]). While Fu does not explicitly teach the plurality of apertures extending along the horizontal plane of each end plate configured to receive a corresponding screw that is used to connect each end plate to an inner wall of the chassis, it would have been obvious to one of ordinary skill in the art to couple the apertures extending along the horizontal plate of each end plate to an inner wall of the chassis through a screw as a well-known means of coupling two components. Regarding claims 15-16, Fu as modified by Zhao teaches the energy management system of claim 11 but is silent as to the plurality of battery cells comprising twelve battery cells (claim 15) and eight battery cell (claim 16). While the figures in Fu illustrate a battery module comprising thirteen battery cells, it is noted that the number of cells forming the battery module is found to be an obvious matter of design choice since the use of eight or twelve battery cells in the battery module would not have modified the operation of the battery module. See MPEP 2144.04 IV A. Claim 20 is rejected under 35 U.S.C. 103 as being unpatentable over Fu (US 2019/0273232 A1) and Zhao (US 2023/0275447 A1), as applied to claims 11-19 above, and further in view of Dinkelman (US 2015/0072176 A1). Regarding claim 20, Fu teaches the energy storage system of claim 11, wherein the PCB assembly comprises voltage (V) and temperature (T) sensing components that connect to battery tabs (i.e cathode output end and anode output end) of the battery module ([0092], [0096] & [0115]-[0116]) but is silent as to the connection between the battery tabs and the PCB being via screw or welding. However, it would have been obvious to one of ordinary skill in the art, before the effective filing date of the present invention, to connect the battery tabs and the PCB via welding as well-known means for connecting a PCB to battery tabs in a battery module as taught by Dinkelman ([0101]-[0103]). Contact Information Any inquiry concerning this communication or earlier communications from the examiner should be directed to NATHANAEL T ZEMUI whose telephone number is (571)272-4894. The examiner can normally be reached M-F 8am-5pm (EST). 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, BARBARA GILLIAM can be reached at (571)272-1330. 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. /NATHANAEL T ZEMUI/Examiner, Art Unit 1727
Read full office action

Prosecution Timeline

Jan 18, 2024
Application Filed
Sep 24, 2026
Non-Final Rejection mailed — §102, §103 (current)

Precedent Cases

Applications granted by this same examiner with similar technology

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3y 7m to grant Granted Sep 15, 2026
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Study what changed to get past this examiner. Based on 5 most recent grants.

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Prosecution Projections

1-2
Expected OA Rounds
56%
Grant Probability
80%
With Interview (+24.1%)
3y 7m (~11m remaining)
Median Time to Grant
Low
PTA Risk
Based on 477 resolved cases by this examiner. Grant probability derived from career allowance rate.

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