Prosecution Insights
Last updated: July 17, 2026
Application No. 18/419,644

RECHARGEABLE ENERGY STORAGE SYSTEM (RESS) INCLUDING A HEAT EXCHANGE MEMBER HAVING A COOLING SYSTEM INCLUDING AN INFLATABLE BLADDER

Non-Final OA §102§103
Filed
Jan 23, 2024
Examiner
LYNCH, VICTORIA HOM
Art Unit
Tech Center
Assignee
GM Global Technology Operations LLC
OA Round
1 (Non-Final)
86%
Grant Probability
Favorable
1-2
OA Rounds
2m
Est. Remaining
96%
With Interview

Examiner Intelligence

Grants 86% — above average
86%
Career Allowance Rate
720 granted / 833 resolved
+26.4% vs TC avg
Moderate +10% lift
Without
With
+9.7%
Interview Lift
resolved cases with interview
Typical timeline
2y 8m
Avg Prosecution
37 currently pending
Career history
859
Total Applications
across all art units

Statute-Specific Performance

§101
0.6%
-39.4% vs TC avg
§103
75.8%
+35.8% vs TC avg
§102
8.2%
-31.8% vs TC avg
§112
10.7%
-29.3% vs TC avg
Black line = Tech Center average estimate • Based on career data from 833 resolved cases

Office Action

§102 §103
DETAILED ACTION Notice of Pre-AIA or AIA Status 1. The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA . Intended use 2. It is noted that the claims have “intended use” language such as “receptive of the inlet conduit” and “receptive of the outlet conduit” and it has been held that a recitation with respect to the manner in which a claimed apparatus is intended to be employed does not differentiate the claimed apparatus from a prior art apparatus satisfying the claimed structural limitations. Ex parte Masham, 2 USPQ2d 1647 (1987). Claim Objections 3. Claim 1 is objected to because of the following informalities: the limitation “into contract” in line 10 includes a drafting error. For the purpose of this Office Action, the limitation has been interpreted as “into contact”. Appropriate correction is required. 4. Claim 10 is objected to because of the following informalities: the limitation “comprising one of a thermal interface material (TIM) layer and an adhesive layer” in lines 1-2 is improper alternative claiming. Alternative claiming may be set forth as "a material (or at least one material) selected from the group consisting of A, B, and C" or "wherein the material is (or is at least one of) A, B, or C" see MPEP 2173.05(h). For the purpose of this Office Action, the limitation has been interpreted as “comprising one of a thermal interface material (TIM) layer or an adhesive layer”. Appropriate correction is required. 5. Claim 11 is objected to because of the following informalities: the limitation “into contract” in line 15 includes a drafting error. For the purpose of this Office Action, the limitation has been interpreted as “into contact”. Appropriate correction is required. 6. Claim 20 is objected to because of the following informalities: the limitation “comprising one of a thermal interface material (TIM) layer and an adhesive layer” in lines 1-2 is improper alternative claiming. Alternative claiming may be set forth as "a material (or at least one material) selected from the group consisting of A, B, and C" or "wherein the material is (or is at least one of) A, B, or C" see MPEP 2173.05(h). For the purpose of this Office Action, the limitation has been interpreted as “comprising one of a thermal interface material (TIM) layer or an adhesive layer”. Appropriate correction is required. Claim Rejections - 35 USC § 102 7. 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. 8. 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. 9. Claim(s) 1 and 11 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Campeau (US2018/0301774). Regarding claim 1, Campeau discloses a battery assembly ([0011], Figs. 6-8) comprising: a housing including a battery cell support surface and a plurality of side walls that collectively define an interior zone(see battery 86 with housing 88 in Fig. 6, [0044] and battery 114 in Fig. 7); a plurality of battery cells arranged in the interior zone(power generating modules [0045]); a heat exchange member mounted to the housing(heat exchange bladder 116, Fig. 7, [0047]), the heat exchange member including a bottom plate(Fig. 7); and a cooling system arranged in the heat exchange member, the cooling system including an inflatable bladder arranged between the battery cell support surface and the bottom plate(see heat exchange bladder 116 in Fig. 7, [0021]), the inflatable bladder being selectively inflated with a cooling fluid to be brought into contact with the battery cell support surface([0034]). Regarding claim 11, Campeau discloses a vehicle (110, Fig. 7) comprising: a body(Fig. 7); a plurality of wheels supporting the body(Fig. 7); an electric drive unit supported in the body(claim 28); and a battery assembly operatively connected to the electric drive unit(114, Fig. 7, claim 28), the battery assembly comprising: a housing including a battery cell support surface and a plurality of side walls that collectively define an interior zone (see battery 86 with housing 88 in Fig. 6, [0044] and battery 114 in Fig. 7); a plurality of battery cells arranged in the interior zone (power generating modules [0045]); a heat exchange member mounted to the housing (heat exchange bladder 116, Fig. 7, [0047]), the heat exchange member including a bottom plate (Fig. 7); and a cooling system arranged in the heat exchange member, the cooling system including an inflatable bladder arranged between the battery cell support surface and the bottom plate (see heat exchange bladder 116 in Fig. 7, [0021]), the inflatable bladder being selectively inflated with a cooling fluid to be brought into contact with the battery cell support surface ([0034]). Claim Rejections - 35 USC § 103 10. 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 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. 11. 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. 12. Claim(s) 2, 8, and 9 is/are rejected under 35 U.S.C. 103 as being unpatentable over Campeau (US2018/0301774) as applied to claim 1 above, and further in view of Volkmann (US2020/0328485). Regarding claim 2, Campeau discloses the bladder 16 may be scaled by providing multiple modular bladders added in series (or parallel) in the fluid path 20 to offer additional cooling as needed based on calculated heat dissipation requirements([0028]) but does not explicitly disclose further comprising a plurality of channels extending between the battery cell support surface and the bottom plate, wherein the inflatable bladder comprises a plurality of inflatable bladders, each of the plurality of inflatable bladders being arranged in a corresponding one of the plurality of channels. Volkmann teaches a system and method for protecting a battery from thermal runaway and/or fire([0001]). Volkmann teaches the battery housing 102 has multiple inlets 108 and one outlet 110, six battery cells a, b, c, d, e, f positioned within the battery housing 102; and four inflators 202(Fig. 2, [0051]). Volkmann teaches the inflators are connected to the battery housing through four conduits 204 in order to provide quick and effective cooling to the battery cells in which abnormality occurred(Fig. 2, [0051]). It would have been obvious to one of ordinary skill in the art to provide the battery assembly of Campeau with a plurality of channels, wherein the inflatable bladder comprises a plurality of inflatable bladders, each of the plurality of inflatable bladders being arranged in a corresponding one of the plurality of channels as taught by Volkmann in order to provide quick and effective cooling to the battery cells in which abnormality occurred. Regarding claim 8, modified Campeau discloses the battery cell support surface fluidically isolates the interior zone from the plurality of inflatable bladders (Campeau, see battery 114 and heat exchange bladder in Fig. 7, and Volkmann, see battery housing 102 and inflators 202 in Fig. 2). Regarding claim 9, modified Campeau discloses the bottom plate includes a non-planar surface having a plurality of projections, each of the plurality of projections extending towards corresponding ones of the plurality of channels(Campeau, see bladder 80 with external support surface 78 in Fig. 8). 13. Claim(s) 3, 4, and 10 is/are rejected under 35 U.S.C. 103 as being unpatentable over Campeau (US2018/0301774), and further in view of Volkmann (US2020/0328485) as applied to claims 1 and 2 above, further in view of Wang et al. (US 9,312,571) as cited in IDS dated 5/22/25. Regarding claim 3, modified Campeau does not explicitly disclose further comprising a cooling fluid supply system including an inlet manifold having an inlet conduit fluidically connected to each of the plurality of inflatable bladders and an outlet manifold having an outlet conduit fluidically connected to each of the plurality of inflatable bladders. Wang teaches traction battery thermal plate with flexible bladder (title). Wang teaches inlet plenums, outlet plenums, and manifolds may also be arranged with the ports and the flexible bladder 190 to assist in obtaining a desired fluid flow therein(Col. 7, lines 61-64). Wang teaches while the inlet port 194 is shown in a central location of one of the side portions of the flexible bladder 190, it is contemplated that the inlet port 194 may be positioned in alternative locations (Col. 7, line 67 to Col. 8, lines 1-3). It would have been obvious to one of ordinary skill in the art to modify the battery assembly of modified Campeau with a cooling fluid supply system including an inlet manifold and an outlet manifold as taught by Wang as applying a known technique to a known device ready for improvement to yield predictable results. MPEP 2143. Regarding claim 4, modified Campeau discloses the heat exchange member includes a first edge, a second edge opposite the first edge, a first side edge, and a second side edge opposite the first side edge (Campeau, see left, right, front, rear sides of heat exchange bladder 116 in Fig. 7), a first stiffening member extends along the first edge, and a second stiffening member extends along the second edge(Campeau, see chassis 112 in Fig. 7), the first stiffening member and the second stiffening member being joined to the bottom plate (Campeau, Fig. 7) but does not explicitly disclose the first stiffening member and the second stiffening member being joined to the battery cell support surface and the bottom plate. It would have been obvious to one of ordinary skill in the art to modify the battery assembly of modified Campeau with the first stiffening member and the second stiffening member being joined to the battery cell support surface and the bottom plate since the heat exchange bladder when relocated under the chassis can contact the battery cell support surface as obvious to try choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success. See MPEP 2143. Regarding claim 10, modified Campeau discloses further comprising one of a thermal interface material (TIM) layer arranged between the plurality of battery cells and the battery cell support surface(Wang, Col. 5, lines 61-63). 14. Claim(s) 5 and 6 is/are rejected under 35 U.S.C. 103 as being unpatentable over Campeau (US2018/0301774), and further in view of Volkmann (US2020/0328485), further in view of Wang et al. (US 9,312,571) as cited in IDS dated 5/22/25 as applied to claims 1-4 above, further in view of Bellenfant et al. (US 2023/0272983). Regarding claim 5, modified Campeau does not explicitly disclose further comprising a plurality of stiffening elements extending between and connected to the first stiffening member and the second stiffening member, each of the plurality of channels being defined by adjacent ones of the plurality of stiffening elements. Bellenfant teaches a system 1 having a set of battery cells 2 to be cooled, for example rowed in one row or two or more rows, and a thermal regulation device 10 arranged to cool the battery cells 2(Figs. 1 & 2, [0046]). Bellenfant teaches the thermal regulation device 10 has a first external plate 11 and a second external plate 12, and also a central member (denoted with reference number 13 in FIGS. 1-3) disposed between the first and second external plates 11 and 12, this central member 13 comprising reliefs 14 arranged to form, with the external plates 11 and 12, two layers 15 and 16 of circulation channels for a heat-transfer fluid, these layers 15 and 16 being on either side of the central member 13, these two layers 15 and 16 having the same heat-transfer fluid circulation direction([0048]). Bellenfant teaches the heat exchanges between the thermal regulation device 10 and the battery cells 2 to be cooled, in particular when this direct contact is over a relatively large surface area, can be optimal([0050]). Bellenfant teaches the reliefs 14 on the central member 13 that form the channels 18 have ribs 20(Fig. 2, [0051]). It would have been obvious to one of ordinary skill in the art to modify the battery assembly of modified Campeau with a plurality of stiffening elements extending between and connected to the first stiffening member and the second stiffening member, each of the plurality of channels being defined by adjacent ones of the plurality of stiffening elements as taught by Bellenfant as obvious to try choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success. See MPEP 2143. Regarding claim 6, modified Campeau discloses select ones of the plurality of stiffening elements include a first recess that is receptive of the inlet conduit and a second recess that is receptive of the outlet conduit(Bellenfant, channels 18 in Fig. 2). 15. Claim(s) 12, 18, and 19 is/are rejected under 35 U.S.C. 103 as being unpatentable over Campeau (US2018/0301774) as applied to claim 11 above, and further in view of Volkmann (US2020/0328485). Regarding claim 12, Campeau discloses the bladder 16 may be scaled by providing multiple modular bladders added in series (or parallel) in the fluid path 20 to offer additional cooling as needed based on calculated heat dissipation requirements([0028]) but does not explicitly disclose further comprising a plurality of channels extending between the battery cell support surface and the bottom plate, wherein the inflatable bladder comprises a plurality of inflatable bladders, each of the plurality of inflatable bladders being arranged in a corresponding one of the plurality of channels. Volkmann teaches a system and method for protecting a battery from thermal runaway and/or fire([0001]). Volkmann teaches the battery housing 102 has multiple inlets 108 and one outlet 110, six battery cells a, b, c, d, e, f positioned within the battery housing 102; and four inflators 202(Fig. 2, [0051]). Volkmann teaches the inflators are connected to the battery housing through four conduits 204 in order to provide quick and effective cooling to the battery cells in which abnormality occurred(Fig. 2, [0051]). It would have been obvious to one of ordinary skill in the art to provide the battery assembly of Campeau with a plurality of channels, wherein the inflatable bladder comprises a plurality of inflatable bladders, each of the plurality of inflatable bladders being arranged in a corresponding one of the plurality of channels as taught by Volkmann in order to provide quick and effective cooling to the battery cells in which abnormality occurred. Regarding claim 18, modified Campeau discloses the battery cell support surface fluidically isolates the interior zone from the plurality of inflatable bladders (Campeau, see battery 114 and heat exchange bladder in Fig. 7, and Volkmann, see battery housing 102 and inflators 202 in Fig. 2). Regarding claim 19, modified Campeau discloses the bottom plate includes a non-planar surface having a plurality of projections, each of the plurality of projections extending towards corresponding ones of the plurality of channels(Campeau, see bladder 80 with external support surface 78 in Fig. 8). 16. Claim(s) 13, 14, and 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over Campeau (US2018/0301774), and further in view of Volkmann (US2020/0328485) as applied to claims 11 and 12 above, further in view of Wang et al. (US 9,312,571) as cited in IDS dated 5/22/25. Regarding claim 13, modified Campeau does not explicitly disclose further comprising a cooling fluid supply system including an inlet manifold having an inlet conduit fluidically connected to each of the plurality of inflatable bladders and an outlet manifold having an outlet conduit fluidically connected to each of the plurality of inflatable bladders. Wang teaches traction battery thermal plate with flexible bladder (title). Wang teaches inlet plenums, outlet plenums, and manifolds may also be arranged with the ports and the flexible bladder 190 to assist in obtaining a desired fluid flow therein(Col. 7, lines 61-64). Wang teaches while the inlet port 194 is shown in a central location of one of the side portions of the flexible bladder 190, it is contemplated that the inlet port 194 may be positioned in alternative locations (Col. 7, line 67 to Col. 8, lines 1-3). It would have been obvious to one of ordinary skill in the art to modify the battery assembly of modified Campeau with a cooling fluid supply system including an inlet manifold and an outlet manifold as taught by Wang as applying a known technique to a known device ready for improvement to yield predictable results. MPEP 2143. Regarding claim 14, modified Campeau discloses the heat exchange member includes a first edge, a second edge opposite the first edge, a first side edge, and a second side edge opposite the first side edge (Campeau, see left, right, front, rear sides of heat exchange bladder 116 in Fig. 7), a first stiffening member extends along the first edge, and a second stiffening member extends along the second edge(Campeau, see chassis 112 in Fig. 7), the first stiffening member and the second stiffening member being joined to the bottom plate (Campeau, Fig. 7) but does not explicitly disclose the first stiffening member and the second stiffening member being joined to the battery cell support surface and the bottom plate. It would have been obvious to one of ordinary skill in the art to modify the battery assembly of modified Campeau with the first stiffening member and the second stiffening member being joined to the battery cell support surface and the bottom plate since the heat exchange bladder when relocated under the chassis can contact the battery cell support surface as obvious to try choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success. See MPEP 2143. Regarding claim 20, modified Campeau discloses further comprising one of a thermal interface material (TIM) layer arranged between the plurality of battery cells and the battery cell support surface(Wang, Col. 5, lines 61-63). 17. Claim(s) 15 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over Campeau (US2018/0301774), and further in view of Volkmann (US2020/0328485), further in view of Wang et al. (US 9,312,571) as cited in IDS dated 5/22/25 as applied to claims 11-14 above, further in view of Bellenfant et al. (US 2023/0272983). Regarding claim 15, modified Campeau does not explicitly disclose further comprising a plurality of stiffening elements extending between and connected to the first stiffening member and the second stiffening member, each of the plurality of channels being defined by adjacent ones of the plurality of stiffening elements. Bellenfant teaches a system 1 having a set of battery cells 2 to be cooled, for example rowed in one row or two or more rows, and a thermal regulation device 10 arranged to cool the battery cells 2(Figs. 1 & 2, [0046]). Bellenfant teaches the thermal regulation device 10 has a first external plate 11 and a second external plate 12, and also a central member (denoted with reference number 13 in FIGS. 1-3) disposed between the first and second external plates 11 and 12, this central member 13 comprising reliefs 14 arranged to form, with the external plates 11 and 12, two layers 15 and 16 of circulation channels for a heat-transfer fluid, these layers 15 and 16 being on either side of the central member 13, these two layers 15 and 16 having the same heat-transfer fluid circulation direction([0048]). Bellenfant teaches the heat exchanges between the thermal regulation device 10 and the battery cells 2 to be cooled, in particular when this direct contact is over a relatively large surface area, can be optimal([0050]). Bellenfant teaches the reliefs 14 on the central member 13 that form the channels 18 have ribs 20(Fig. 2, [0051]). It would have been obvious to one of ordinary skill in the art to modify the battery assembly of modified Campeau with a plurality of stiffening elements extending between and connected to the first stiffening member and the second stiffening member, each of the plurality of channels being defined by adjacent ones of the plurality of stiffening elements as taught by Bellenfant as obvious to try choosing from a finite number of identified, predictable solutions, with a reasonable expectation of success. See MPEP 2143. Regarding claim 16, modified Campeau discloses select ones of the plurality of stiffening elements include a first recess that is receptive of the inlet conduit and a second recess that is receptive of the outlet conduit(Bellenfant, channels 18 in Fig. 2). Allowable Subject Matter 18. Claim 7 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. In particular, the allowable limitation is each of the plurality of stiffening elements includes a vent passage, the battery cell support surface including a plurality of vent gas passages that fluidically connect the interior zone and the vent passage. Bellenfant does not disclose, teach or render obvious each of the plurality of stiffening elements includes a vent passage, the battery cell support surface including a plurality of vent gas passages that fluidically connect the interior zone and the vent passage. 19. Claim 17 is objected to as being dependent upon a rejected base claim, but would be allowable if rewritten in independent form including all of the limitations of the base claim and any intervening claims. In particular, the allowable limitation is each of the plurality of stiffening elements includes a vent passage, the battery cell support surface including a plurality of vent gas passages that fluidically connect the interior zone and the vent passage. Bellenfant does not disclose, teach or render obvious each of the plurality of stiffening elements includes a vent passage, the battery cell support surface including a plurality of vent gas passages that fluidically connect the interior zone and the vent passage. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to VICTORIA HOM LYNCH whose telephone number is (571)272-0489. The examiner can normally be reached 7:30 AM - 4:30 PM EST M-F. 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, Miriam Stagg can be reached at 571-270-5256. 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. /VICTORIA H LYNCH/Primary Examiner, Art Unit 1724
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Prosecution Timeline

Jan 23, 2024
Application Filed
Jul 01, 2026
Non-Final Rejection mailed — §102, §103 (current)

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Prosecution Projections

1-2
Expected OA Rounds
86%
Grant Probability
96%
With Interview (+9.7%)
2y 8m (~2m remaining)
Median Time to Grant
Low
PTA Risk
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