Prosecution Insights
Last updated: August 06, 2026
Application No. 18/421,179

Battery Module with Battery Holder and Immersion Fluid

Non-Final OA §102§103§112
Filed
Jan 24, 2024
Priority
Jan 25, 2023 — provisional 63/481,534
Examiner
MURATA, AUSTIN
Art Unit
Tech Center
Assignee
Power Global Pbc
OA Round
1 (Non-Final)
60%
Grant Probability
Moderate
1-2
OA Rounds
9m
Est. Remaining
81%
With Interview

Examiner Intelligence

Grants 60% of resolved cases
60%
Career Allowance Rate
446 granted / 737 resolved
+0.5% vs TC avg
Strong +21% interview lift
Without
With
+20.7%
Interview Lift
resolved cases with interview
Typical timeline
3y 3m
Avg Prosecution
33 currently pending
Career history
780
Total Applications
across all art units

Statute-Specific Performance

§101
1.0%
-39.0% vs TC avg
§103
60.7%
+20.7% vs TC avg
§102
11.1%
-28.9% vs TC avg
§112
24.5%
-15.5% vs TC avg
Black line = Tech Center average estimate • Based on career data from 737 resolved cases

Office Action

§102 §103 §112
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 . Claim Rejections - 35 USC § 112 The following is a quotation of 35 U.S.C. 112(b): (b) CONCLUSION.—The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention. The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph: The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention. Claim 13 is rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor (or for applications subject to pre-AIA 35 U.S.C. 112, the applicant), regards as the invention. Claim 13 refers to a “low-density” filler. However, the term “low-density” is not defined and makes the scope of the claim vague. It is not clear when a filler would be considered low-density and not low-density. The examiner further notes that the “fluid volume” is not tied to the fluid of claim 1 or any particular space/path for fluid. The limitation could be removed to resolve the issue. However, the remaining limitations are not particularly limiting because most if not all materials compress (take less volume) when a fluid volume increases because the volume space is constant (Va + Vb = Vtotal). When Va increases, Vb must decrease. 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. Claim(s) 1-3, 5, 6, 9, 11 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by KWAG et al. (US 2011/0039142). Regarding claim 1, KWAG teaches a holder case for a plurality of batteries abstract. The holder has a matrix of opening that accommodates circular cells as shown in Fig. 1. Each cell opening has a cross section with a circular part and an extended portion, see Fig. 5. The extended opening creates an annular space between the holder and the battery wall(s) such that air (fluid) flow (f) can help dissipate heat. The reference teaches using air as the coolant [0031] which can be considered a fluid. Regarding claims 2, 3, 5, and 6, As shown in Fig. 5 the flow path f is a common flow path joined by 4 adjacent cells in a repetitive pattern. Regarding claim 9, KWAG teaches that the holder case has two sides 100a and 100b which include first and second finds 121 and 122 for structural stability and the columns 125 and 225 are positioned between them [0036] and [0047]. The reference does not expressly state that the middle columnar layer is an extruded layer, the method of making the layer does not change the structure of the layer. Regarding claim 11, The limitations in claim 11 are directed to the operation of the cell holder by limiting the thermal transfer to a first threshold limit and fluid flow to a second threshold limit. The first and second threshold can be any values and do not limit the structural requirements of the cell holder. The cell holder in KWAG is necessarily able to handle thermal transfer to a first “limit” and flow fluid within a second “limit”. 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. 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. 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. Claim(s) 12 is/are rejected under 35 U.S.C. 103 as being unpatentable over KWAG et al. (US 2011/0039142) in view of MENNICKE et al. (US 5,158,841). Regarding claim 12, KWAG teaches a holder case with cooling channels that flow along a cylindrical cell but does not expressly teach how the air is provided to the channels in the holder. Although the flow channel implicitly requires a supply an inlet and outlet it is not expressly described and one of ordinary skill in the art would naturally consult the art for structures to supply coolant. MENNICKE generally teaches an array of cylindrical cells Fig. 2 with cooling channels can be fed coolant from a distribution space 8 and collecting space 9 in fluid communication with the cooling channels Fig. 5 and column 6 lines 4-15. At the time of filing the invention it would have been prima facie obvious to one of ordinary skill in the art to use a distribution space and collecting space to supply the coolant as a known structure for supplying coolant to channels between cylindrical cells. The distribution plate is capable of increasing fluid flow (by increasing pressure) and will also have the same amount of flow through each channel. Claim(s) 13, 15 and 16 is/are rejected under 35 U.S.C. 103 as being unpatentable over KWAG et al. (US 2011/0039142) in view of HARRIS et al. (US 2019/0259986). Regarding claim 13, KWAG teaches a holder case for a plurality of batteries abstract. The holder has a matrix of opening that accommodates circular cells as shown in Fig. 1. Each cell opening has a cross section with a circular part and an extended portion, see Fig. 5. The extended opening creates an annular space between the holder and the battery wall(s) such that air (fluid) flow (f) can help dissipate heat. The reference teaches using air as the coolant [0031] which can be considered a fluid. The reference teaches a stand alone housing for the module but does not teach using multiple modules in a single battery pack. However, HARRIS teaches that battery modules can be connected to each other to form battery packs (energy storage system) abstract. At the time of filing the invention it would have been prima facie obvious to assemble multiple battery modules together as a duplication of parts to achieve a desired amount of energy storage. Regarding claim 15 and 16, As shown in Fig. 5 the flow path f is a common flow path joined by 4 adjacent cells in a repetitive pattern. Claim(s) 20 is/are rejected under 35 U.S.C. 103 as being unpatentable over KWAG et al. (US 2011/0039142) in view of HARRIS et al. (US 2019/0259986) further in view of GEBBIE et al. (US 2013/0149575). Regarding claim 20, Modified KWAG teaches incorporating multiple battery modules into a battery but does not expressly teach how coolant would be applied to the multiple battery modules. However, GEBBIE teaches provided coolant fluid in a series flow configuration abstract. Assembling in series flow allows for more easier packaging [0003]. At the time of filing the invention it would have been prima facie obvious to connect coolant fluid to multiple battery modules in series because it is a simpler assembly process. Allowable Subject Matter Claims 4, 7, 8, 10, and 17-19 are 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. The following is a statement of reasons for the indication of allowable subject matter: Claims 4 and 17 require extended portions to be grouped together in groups of 3 adjacent openings. KWAG teaches sharing flow space between 4 adjacent openings. Additional prior art is GHOSH et al. (US 2010/0035139) which creates a common flow space between two adjacent openings/cells. DAVIS et al. (2021/0344063) which shows uses a heat exchanger between 3 adjacent cells, see fig. 5. However, the coolant channel (fluid path) does not run along the cell wall (fluid delivering to plurality of openings with extended portions grouped together). Claims 7, 8, 18 and 19 are directed towards the supply and return manifolds connected to the openings. The examiner was unable to find prior art teaching the manifolds that have a supply port and return port on the same first side of the battery module. While the position of the ports may seem like a rearrangement of parts, the examiner notes that by having the ports on the same side, the flow paths to the plurality of cells in an array become varied which changes the operation of the module (more coolant flows through the shorter paths closer to the ports). The examiner was unable to find this particular configuration of a cell holder with flow paths along the length of the cells using the claimed manifold and port configuration. Claim 10 requires the cross-section of the openings to have tear-drop shape which is formed by extending a portion from a point that extends away from the circular portion (exemplified in Figs. 7-8 but not Fig. 9 and 10, see specification [0065]-[0068]). Pertinent prior art includes DAVIS et al. (2021/0344063) which shows uses a heat exchanger between cells but without the holder tear drop shape (circular and extended at a point), see fig. 5. Conclusion Any inquiry concerning this communication or earlier communications from the examiner should be directed to AUSTIN MURATA whose telephone number is (571)270-5596. The examiner can normally be reached M-F 8:30-5. 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, MICHAEL CLEVELAND can be reached at 571272-1418. 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. /AUSTIN MURATA/Primary Examiner, Art Unit 1712
Read full office action

Prosecution Timeline

Jan 24, 2024
Application Filed
Jul 14, 2026
Non-Final Rejection mailed — §102, §103, §112 (current)

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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
60%
Grant Probability
81%
With Interview (+20.7%)
3y 3m (~9m remaining)
Median Time to Grant
Low
PTA Risk
Based on 737 resolved cases by this examiner. Grant probability derived from career allowance rate.

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